Standards of Conduct Committee

Thank you. It's really good to be here. Thank you for having me. So, Transparency International is a global network of around 100 different, we call them 'chapters', based around the world within countries. I work for Transparency International UK. We're one of the UK's leading anti-corruption organisations. We have quite a broad remit. We work on dirty money and money laundering coming into the UK, and we also look at the use of public resources and also political integrity, political corruption and that includes lobbying, which we're here to discuss today.

Thank you, Rachel. So, if I can kick off with some questions around the nature of lobbying then, and just a fairly open question to begin with. What do you understand by the term 'lobbying'?

Yes, of course. So, we would say—. I think we would probably agree with the international standard on lobbying: lobbying occurs when an individual—any individual or a group or an organisation—makes communications directed towards a public official with the intention of influencing public decision making. So, we do not define or constrict our definition to who is lobbying, where the lobbying has taken place or the method of communication, whether that's written, oral or an in-person meeting. It's all about is someone making a communication directly or indirectly to a public official with the specific intention of influencing decision making.

I think the one exception we would have to that definition would be a citizen, for example, meeting with a representative on a private matter, as long as those private affairs, for example, do not compromise the wider public interest. So, for example, if they had an individual business interest—for example, maybe they were doing some backdoor lobbying to try and secure a Government contract. So, as long as it didn't include that sort of thing, then we would say citizen representations on their private matters are an exception to that.

I do just also want to say to kick off that I don't think that lobbying in and of itself is bad; I think it can be an incredibly good thing. It can be incredibly positive. It's important for democracy when it's conducted ethically and transparently. It can mean that public officials like yourselves have access to experts and their research, but it also gives you the opportunity to listen to those who will be impacted by any decisions that you make. So, when it's done well, I think it can be incredibly positive, but it must be done transparently and ethically.

Thank you, Rachel. You've encapsulated so much in that answer already, I think there's only one other thing that I would like to clarify with you on this, and that's just your idea about a lobbyist. Does a lobbyist have to be a paid official, or could they be an unpaid volunteer? Where do you sit with that?

So, it would include unpaid volunteers for us. I do have to make the distinction and say although we think anyone who is making that representation wanting to influence public decision making is doing lobbying, when it comes to regulation, we wouldn't necessarily say that everyone that is caught within that definition should, for example, have to make filings on a lobbying register. But I would say that those who are doing lobbying outside of their paid employment, it might not be proportionate to ask them to, for example, sign up to a register. But that's why it's so important that you have a suite of measures in place. So, you might have a lobbying register, but you also have, as the Welsh Government does, ministerial meetings data that are released on a quarterly basis, because those other things might capture that kind of lobbying. It's very important that we don't forget about unpaid lobbying. We want to know who is influencing public decision making, but, yes, you need to be proportionate about what burdens you put on different people.

Thank you, Rachel. I'll bring in John Griffiths now. John.

Diolch yn fawr, Cadeirydd, and bore da, Rachel. Rachel, in terms of what you've already said about lobbying possibly being of value and positive when done well, could you add a little detail to that in terms of what you think is that value that can be brought to a democracy?

Yes, absolutely. It is a way for policy makers to gather the opinions and evidence of those experts. There's a lot of research and analysis out there on a range of different issues that—. At the end of the day, we want public decision making to be informed and strengthened, and we want that expertise to be brought into those conversations. This only contributes to better decisions, both in the Senedd and in Government.

I think, actually, if there are public officials—and I expect many of you would fall under this definition—that really want to make sure that all interested groups are being involved in those discussions and that everyone is being listened to, having transparent data on who, for example, Government Ministers are meeting with and who their advisers are meeting with, can really help you assess, 'Is that happening? Are there any groups that are being left out? And, if so, let's study the data. Oh yes, look, we're not listening to that group, let's address that, let's make sure we bring them in.' And that data, for example, coming through a register or through ministerial meetings data, if that is happening in a timely fashion—so, it's not happening a year after the fact that the decision has already been made, but it's happening in a timely fashion—that can really help.

So, to give an example: I've got colleagues in Transparency International EU, and they've told me that, during the 2008 financial crash and the crisis that followed, I think there were Members of the European Parliament that actually studied the meetings data, and realised that, whereas there'd been lots of meetings with representatives of financial institutions, there hadn't been many, if any, meetings on financial regulation with those who were representing the public interest. And some might argue that that might have contributed to the situation, where the regulations weren't really quite sufficient, and they weren't working in the public interest, and, as a result of that, I think they actually pushed for more representation from non-governmental organisations and from civil society. And in fact, there was a whole organisation, called Finance Watch, that ended up being created out of that analysis, and the public interest is now much more represented at the EU level, which is really good.

On the flip side, we did some analysis a couple of years ago, looking at housing policy that's made at Westminster, and we realised, through looking at meetings data, but also conducting interviews, that whereas lots of developers had been consulted on housing—and, actually, the Westminster Government had met with lots of civil society groups—groups representing renters had been entirely left out of the conversation, and just hadn't been represented in any of those discussions. And it's interesting and tragic. There is a rental crisis at the moment, particularly in England. In fact, I think there was something on the BBC News website over the weekend about people in Devon wanting to rent in the towns where they'd grown up, and where their communities and their jobs are, and they just can't afford to. So, it's unsurprising when you look at the data that renters just haven't been represented. But that data is there, and it could be used for good, if people really want to analyse, 'What spots are we missing, who else can we draw in?'

Okay. Thanks for that, Rachel. Rachel, would you draw an ethical distinction between providing information and advocacy?

I probably wouldn't say one is ethical and one isn't. I think it's absolutely fine to go to representatives, wanting to influence decision making. I think that's good. I would say—just going back to that definition of lobbying—I think anyone who is presenting information with a desire to influence a process is lobbying, and I think that can be really ethical. I'd imagine everyone you're meeting with, everyone you receive submissions from, during the course of this inquiry, they're probably not just meeting with you. I am partly meeting with you because I'm Welsh, and I really care about this process, but I'm also here today because I'm hoping that some of the research and analysis I share, you might consider it, it might have some impact, it might influence your decisions. So, I would say that what I'm doing right now, for example, is lobbying, and I think that can be done ethically and transparently.

Okay. Rachel, a final question from me: could you offer the committee a view on what are the essential requirements to enable lobbying to be beneficial, and what would impede that?

Absolutely. So, I think it's about having all the different pieces of the puzzle in place. So, if you're looking at a register of lobbyists, making sure it includes in-house as well as consultant lobbyists. I think, when you look at registers around the world, the vast majority of people and organisations that are registered are in-house. So, you want to make sure that it captures the full scale of lobbying. I think you want to make sure that it doesn't impede participation—so, we need transparency, but there needs to be that balance, so that it's proportional, it doesn't put any disproportionate burdens on people to participate. And you just need to make sure the information is there, so that lobbying cannot happen via a backdoor. You want to make sure that it's not just those with the most resources who get the most access and get the most influence—that everybody gets a say and that everybody is included. And I can go into more technical detail on what that looks like later on, if that's of interest.

Okay, Rachel. Diolch yn fawr.

Diolch.

Okay. Thank you, John. I'll bring in Peredur Owen Griffiths now then. Pered.

Diolch, Vikki, a bore da, Rachel. Before I move on to the flip side of the coin, the disadvantages or disvalue of lobbying, those things that you were mentioning to John, is there somewhere in the world that you operate in, or have colleagues in, who do that well?

Yes, absolutely. I would really recommend the Canadian system. So, we have a chapter—Transparency International Canada. So, we've looked a little bit and, in preparation for this this morning, I was a bit of a nerd; I was on their registry this morning, having a little look around at what they do. I mean, in terms of a register, I really love what they do there, and I can share links after this, if you want to have a look yourself. Because they collect a lot of information on who is making representations, without placing too much of a burden on people to be reporting the meetings and the calls that they're having. So, for example, they have a kind of central page for each organisation, and I think they have to update it either every six months or every year, I can't remember which. They have to put everything on there, such as the individuals from the organisation who might come and have meetings, and they have to put a list of all the issues they work on, a list of the particular pieces of legislation they're working on at that point and may try to influence, and then, under each issue, a couple of bullet points on what their objectives are and just say, 'housing' or 'infrastructure', actually why they're lobbying, what they're trying to do. There is so much information on those central pages, so that when they have to report meetings—I think within 28 days of those meetings occurring—there's very little information they need to submit. So, it's really quick, really easy. It's the date, it's the name of the person, it's the department, and I think it's just the name of the issue—they can say, 'housing'—and they submit that; it's really quick, really easy. And then if you as, say, a policy maker, is wanting to assess who is having an impact, or if you're from civil society or a journalist, you just go to those lists of meetings and see, 'Oh, they've mentioned that issue; I wonder what they were talking about.' But then you can just go to that central page, and all the information's there without the lobbyists having to enter all that information every time they do that. So, I think that's a really good, really important system. It includes in-house lobbyists as well, and it also includes face-to-face, written and oral meetings, which is good, and it kind of avoids some of the problems we've seen in Westminster—I don't think the Westminster system is working brilliantly—but also some of the problems we've seen in Scotland too.

I think the Irish system is also good; it's a good one to look at. They do require the purpose of the meetings—the detailed purpose, I think—to be submitted with each kind of meeting filing rather than it being collected in a central place. So, it maybe places a little bit more of a burden on people submitting information, but that's pretty good.

I'd also say, actually, I think there are improvements that can be made to the Welsh ministerial meetings data, but it's already fairly good, I'd say, compared to other jurisdictions—Westminster, for example. For example, Wales publishes all the different departments in one comma-separated values file, which allows you to track in one document and do a bit of analysis, which is great. I can talk a little bit about areas for improvement, although we did mention that in our submission, so you might not want to go over that again.

Thank you. That's great. And I certainly would be interested in seeing some of that stuff from Canada as well. We've looked a little bit at Ireland already, but thanks for that.

But, going on to my substantive questions on the disvalue of lobbying, as opposed to what you were talking to John Griffiths about. Does lobbying pose any problems for, or obstruct, the proper conduct of representative democratic politics, and are there any concerns that lobbying may appear to subvert the democratic process?

Yes, absolutely, and I think this is why it's so important that we get it right, that it is a positive thing. So, when it happens behind closed doors, it can provide cover for privileged access and undue influence that can, at worst, even corrupt our politics; at a minimum, it can certainly impact public confidence and the integrity of those in public office. Even if the things that may be happening behind closed doors, there's nothing inherently dodgy that's happening there, from a public point of view, that can really impact how much you trust public officials and institutions. I think, at worst, that can lead to policy outcomes that only benefit the interest groups with the most resources. And where it also involves things like procurement contracts, it can risks hundreds, if not millions, of pounds of public money.

To demonstrate that, you may have seen in the news—I'm losing track of time, through the pandemic and after the pandemic—I think it was either last year or the year before, the Westferry Printworks development scandal in Westminster: the Secretary of State for Housing, Communities and Local Government at the time intervened on behalf of a party donor, after being lobbied at a private fundraising event. I think this party donor sat next to him at the event and actually then pressured officials to basically write letters saying that the housing Secretary is insisting that this development is approved before this deadline, and it was approved before a particular deadline when community levies would have come into force. So, it was basically helping the developer avoid paying millions of pounds in levy fees, but then that cost—it was about £40 million that was then going to go on the people of Tower Hamlets, basically, coming out of the public purse to pay for these levies for essential infrastructure. It was then later reviewed because this all came out, and then that decision was squashed and reversed, thankfully, so that didn't come from the public purse. But that could have obviously had financial ramifications, but it certainly had, I would imagine, an impact on public trust, which once you lose, once it starts to decline, is incredibly difficult to claw back.

You've talked in your previous answers and in that answer as well, and you've indicated that lobbying can undermine transparency and can create inequality of access. I'm just wondering what your thoughts were on what the—. Talking about the Canadian system, the Irish system, and other systems, how do they try and make it more transparent, and how do you stop people with very deep pockets from getting that access, and that inequality of access? I'm a bit of a data geek; I quite like data. That data that's collected, when you're analysing who we've talked to and who we haven't, is that realistic in real time? In the course of a consultation, could you actually do that data analysis within that time to be able to find the gaps in the data, if you like?

So, I think it depends on how timely the data filings are. So, in Canada, for example, they have to file their meetings data within 28 days of having the meeting, which, again, is not too burdensome because the detail is held and is updated, I think it's every six months, in a central place, so that's quite easy to do. There are many places that do it quarterly. Wales is quite good in terms of—. The last filing we looked at, I think it was July to September 2022. It was quarterly, and I think the data was released in October, so within 28 days of that quarter. We would still probably hold up Canada as best practice because, as you say, if you're wanting to analyse data in real time, with the meetings posted within 28 days of them happening, often consultations can go on for several months, so that is enough time to be analysing, 'Okay, where are the gaps?'

I think data could probably be released in an easier-to-analyse way. So, something that Transparency International does, both at the EU level and also at the Westminster level, is we scrape the data that is released. At Westminster, it's particularly difficult because they release it department by department. We've actually put it all together in a user-friendly website called open access, and you can actually search all historical data since data has started being collected for Westminster and for the EU, and analyse over time who different departments are meeting with as well. So, I think there's definitely a step up that can be reached in maybe publishing data in a way that will make it more easy to analyse and to search.

I think one of your other questions was in terms of how do we make sure that people don't go round the backdoors, and particularly those with a lot of resources. So, one of the problems with the Westminster system is that the ministerial meetings data only covers meetings that Ministers have in an 'official' capacity. So, if I met with the Minister, let's say, in the Home Office, and we had a particular discussion about something I was hoping that the Minister would take on, it would be recorded. If instead I said, 'Shall we go out for dinner tonight?' and we had the exact same conversation, with the exact same purpose and intention, that would probably count as being held in an unofficial personal capacity, and that Minister wouldn't have to report it. And that happens a lot. We saw with Westferry, for example—. I'm not saying that the person did this, but it would be possible—. Actually, let's just step away from that case study. It would be possible to, say, if you were wanting to influence a Minister, find out they're going to a private fundraising function and have a word with the organisation and say, 'Could you sit me next to this person? I want to have a conversation with them.' You might even pay to go to that function, for example, which means that those with resources would be able to do that, and those without those resources wouldn't be able to do that, and have that conversation and have that not recorded. So, I think it's really important that when you're looking at a register, when you're looking at data—meetings data—that you record all the communication that might happen when that Minister or their senior advisers are being lobbied, and don't leave those loopholes because people will find a way to exploit them.

And finally from me, if I may, Chair, we've talked a little bit about different types of lobbying and that informal sitting next to somebody in a dinner or a meeting in an office or whatever those might be. There's online, you've got by letter, you've got all sorts of different ways; do different forms of lobbying pose different levels of threat to democratic institutions?

That's a good question. I would say, if things are done—. If there is transparency over the lobbying that is happening, then I think it lowers the risk, because it's more likely that someone will pick up on, for example, if there are unequal representations or there are certain people having much more representation than others, and that will be addressed. When that happens behind closed doors, I think the risk is much higher that it will lead to an outcome that is not in the public interest.

I think you've also got to consider the role of big money in politics, so, making sure that major donors to political parties, for example, aren't getting exclusive access in return for those donations, and making sure that exclusive access isn't promised in return for donations. There was an example of that happening in Westminster—I can't remember, maybe it was a few years ago; I remember it being in The Times, with a particular political party. Someone saying, 'If you give more than this amount of money, you get to go to dinner with these politicians, or you get particular access to this policy unit'. It's just making sure that that doesn't happen, and there are strict rules around those who donate large amounts of money not getting privileged access that maybe someone who doesn't have those resources wouldn't be able to have themselves.

Thank you. Diolch, Vikki.

Thank you, Pred. Before we move on, if I could just ask two questions off the back of the things that you discussed there. So, you talked about informal lobbying and, from what I understand, there's certainly a pattern within political parties that, if a dinner is being hosted, people can pay a premium to be sat on certain tables with the highest ranking members of that party. Have you got a view on that and where it should sit within the things that we are looking at here?

Yes. I think, let's say that the party is the party of Government and there are Ministers, let's say, at that function, and someone has a conversation with them, it should be their duty, I would imagine, to go straight back to their civil servants the next day and just say, 'By the way, this person from this trade body or this charity sat next me, and they wanted to talk to me about this Bill or this consultation that we're running at the moment. Could you please include it in the data?' And hopefully, that wouldn't be too burdensome, it would be just a quick email or a quick minute-long conversation with a civil servant to make sure that that's captured in the data. So, yes, I would do that. I'd recommend that.

And in terms of Transparency International, you talked about the work that you've been doing at a UK and an EU level to scrape the data and to correlate it in an user-friendly way for people to access. Am I right in taking from that that, that is not work that you've done with any of the devolved Parliaments to date?

Not yet. I'd love to, though. I'd to do one for Wales and to scrape that data, because you do have good data to scrape. So, yes, it's all about funding, but I think if we could get the funding to do it at the devolved level, we'd really love to do that. I think not just for Wales, but also for the Scottish Government and also in Northern Ireland too.

Thank you. Okay, I'll bring in Natasha Asghar now, then. Natasha.

Thank you so much, Chair. Hi, Rachel. As you know, the Senedd, obviously, currently only has guidance when it comes to lobbying, so I just want to know, obviously, with everything out there, there is a certain danger associated with it. So, can the dangers posed by lobbying be managed by effective regulation, going forward?

Yes. I think they should at least be minimised—absolutely. And I guess it's a question of, 'What does effective legislation look like and what does effective regulation look like?' And I think it's about having the different pieces of the puzzle in place—so, having an effective register that is proportionate, which we've fully discussed, making sure that it includes in-house consultants and making sure that it's not just about face-to-face meetings, but other forms of influence towards Ministers as well. I think you also want to make sure that ministerial meetings data is as good as it can be, and we've suggested some improvements to the Welsh Government's data in our written submission. Also, making sure that other things are in place as well. I had a quick look at some of the other submissions, and the Senedd commissioner, I think, suggested that he should be able to initiate his own investigations, and I would say that that is definitely a recommendation that we would stand behind.

And, also, the fourth piece of the puzzle is the revolving door. So, again, I think the revolving door between the public and the private sector can be a really good thing. It's good to have people with expertise coming into Government, but it needs to be regulated properly. And, unfortunately, the Advisory Committee on Business Appointments—ACOBA— is just that; it's just an advisory committee. You've probably all looked at this yourselves. It has no resources to monitor whether its advice is taken up for former Ministers going into the private sector, and, also, it has no powers to apply sanctions if that is advice is ignored. I think I've seen in the past when Ministers, former Ministers, have ignored advice, and the most that ACOBA can do is just publish a strongly worded letter, which I don't think is effective regulation. So, I think that aspect needs to be looked at too.

So, Rachel, do you think that we should have a legal framework in place that does have the power to enforce sanctions, going forward?

I think, with the revolving door, ACOBA just needs some teeth. At the moment, it has no teeth. So, what that looks like is up to you, and up to the Government, but it needs to be more than just an advisory, giving out advice that can be easily ignored. So, yes, I'd probably go for statutory regulation, yes.

Okay. And, just speaking of regulation, and whose responsibility is it, whose responsibility should it be? Should it be the lobbyist, the lobbied, or both?

Both. So, I think that's why you need both sides of the coin. So, you need a statutory register, I think, for those who are lobbying, and that doesn't just include people who have the word 'lobbyist' in their title. For example, I work for a charity, you're probably aware that people who work for charities have jobs that are quite wide-ranging. I do all sorts of things, but, let's be honest, one of the things I do is lobby. And, so, people like me who don't have 'lobbyist' in their title, who are in-house, should, I think, have to register. But, on the flip side of that, I think you do need good meetings data for those who meet with Ministers, because, for example, that can capture the unpaid lobbying side of things, where you might decide it's disproportionate to ask those doing this in their spare time to have to submit filings, but, at least then you will have the full picture of who is influencing Government.

Great. Thank you very much. Chair, with regard to the rest of the questions, do you want me just to carry on as I'm going?

[Inaudible.]

You're on mute. [Laughter.]

Feel free, Natasha, to explore other areas of interest, and, then, the rest of us can come in when you're done.

Fine, perfect. All right then, Rachel, we've got a long way to go, you and I, if that's okay. Just speaking a little bit more about the register of lobbyists then, obviously, we've spoken to—. Prior to Christmas, we actually had meetings with representatives from the Scottish, the Irish and the UK Government departments, and they've given us quite a bit of insight. So, if the Senedd, hypothetically, was to introduce a register, be it voluntary or statutory, going forward, do you have any views on certain areas? And I want to ask you—you can use sentences, paragraphs, whatever you want to—but what's your view on what type of lobbyist exactly should fall within the scope? So, consultant, in-house—I know you mentioned it previously in one of your answers, but, just going forward, if you could elaborate a bit more, that would be really appreciated.

So, consultant and in-house lobbyists should be included, and particularly in-house, because in-house make up the vast majority of the lobbyists who are registered on the Scottish register, on the Irish register. And, in fact, the Organisation for Economic Co-operation and Development did a study of 22 different registers across the world, and 18 of them included in-house. It's incredibly important to do that. I would say, to be proportionate, it should include people that do that as part of their paid employment. So, even if they're not paid specifically to be a lobbyist, or to be a lobbyist for someone else, if that is part of their paid work, then, I think, they should be included in that.

I don't have strong feelings on whether unpaid lobbyists, or those doing it in their spare time should be, but I'm very sympathetic to the view that it might place a disproportionate burden on them to include them in a register.

I've got you. I'm going to come back a little bit on sanctions, if that's okay with you, because I know that you touched upon it previously when I asked you the question. But, what sanctions, if any, should basically follow the parliamentarians who are lobbied by unregistered lobbyists, because there are quite a few out of them out there?

Yes, that is a good question. Can I come back to you on that one in writing? Is that okay? I'd like to have a little think about it.

Of course, that's fine. And there is a sub-question to that. You're more than welcome to answer it now or come back to us later on that one. But I just wanted to know what sanctions, if any, should follow for lobbyists who operate unrecognised, assuming that there is a statutory requirement to register prior to undertaking lobbying activities? It's kind of the same umbrella, but if you can please elaborate on that one. You're more than welcome to come back to me, like you said, on that one—that's fine.

Yes. I might come back and actually look at what some other countries are doing, if that's okay, and come back in writing.

Absolutely. You're more than welcome to. In fact, that would be welcome, to have the comparison for us as well.

Yes, okay. Yes, brilliant. I can do that.

I'll talk to you a little bit about publication of meetings, if that's all right.

Yes, brilliant.

You touched upon the publication of meetings in different other areas and Parliaments and I know you're interested in that as well. But going forward, we obviously publish our meetings retrospectively, as you mentioned, on a quarterly basis. So, going forward, what type of meetings, or meetings with whom, about what, and what settings should actually be entered into our record of meetings to make it as transparent, and, I should say, as open as possible to the public?

I would say with Ministers, and probably their senior advisers as well, because senior advisers have a lot of influence over ministerial decisions and are often a kind of proxy for meeting with the Minister. So, I would say, yes, with Ministers and possibly their senior advisers as well, in terms of the scope of what's captured.

And just since, obviously, COVID—. Oh, sorry. Pred wants to come in, so—

Just on that point, should the register then be extended to meetings with senior advisers? Should they fall under the same level of expectation as a Minister?

I would certainly recommend that you consider that, yes. I wouldn't say that I feel as strongly on that point as I do with Ministers, but I think it's certainly something to look at, particularly within the Welsh Government context, and in terms of how much influence senior advisers have on Ministers. I would encourage you to seriously consider that as part of the inquiry that you're doing, yes.

Diolch. Sorry, Natasha, for cutting across.

No, no, no—please feel free to join in at any time. Rachel, obviously with COVID and the way it's gone, meetings can be defined in many different ways. Obviously, prior to COVID, a face-to-face, one-to-one would have been what we all deemed as 'a meeting', but now you've got Zoom meetings, you've got WhatsApp, you've got Teams, you've got a million different things aside from a face-to-face option of having a meeting—dinner parties, all sorts of things that can be considered a meeting. And you mentioned previously in one of the answers about a paid dinner where you can meet somebody or meet a Minister and have a conversation with them. So, in the eyes of this going forward, what constitutes as a meeting? That should be registered, I should say—sorry, that was a follow-up part of it.

I would say any significant conversation with a Minister that discusses a particular policy decision or procurement contract, for example, and I think it's interesting that you mention the COVID example. In Scotland, because only technically face-to-face meetings are included within that remit, not calls, during COVID if you were on a Zoom call and you just switched off your camera, as a lobbyist, then suddenly that didn't have to be reported, which I think was an interesting loophole. So, I would say any significant conversations, whether that happens face to face, on Zoom with a camera, on Zoom without a camera, on the phone, or sat next to each other at a fundraising dinner. If there is a significant conversation that happens where one person is trying to influence the public official in relation to a public decision-making process, then that should be recorded.

Does that mean not just Ministers? That means any one of us.

We would say Ministers. We don't really have any strong feelings on whether that should include Assembly Members. That might be something that you want to consider, but I think you've got to think about proportionality as well. Our recommendations definitely focus on the Ministers, and perhaps their advisers.

Rachel, I know that you mentioned about time frames and having a time duration to register things. Some people have 28 days. Some others have quarterly update requirements. In a perfect world, if you were in charge, what would be the ideal time frame that you would set us to be able to register? What's the time frame in which you would want us to actually declare, 'This is what's happened in this time'?

I would go with the Canadian model, particularly for a statutory register, so the lobbyists having to report, I would say, within 28 days, again making sure that that reporting is not too burdensome. I would echo their system of having lots of information updated, say, every six months on a central page. But the ministerial meetings data, I think if that could be done monthly as well, that would be amazing, particularly if, let's say, committees like yours are monitoring certain consultations to see whether all the different interest groups are being brought into the picture. That would enable you to actually do that analysis and that monitoring, and then give a gentle challenge to the Government if you don't think that all sides of an argument or all interested parties are being brought in.

Okay, fantastic. Thank you so much for answering that. I'm going to fly the flag for our civil servants, now, if that's okay, with my next question. If this was a perfect world and we did have that facility, there may be an argument saying that it would add undue administrative pressures on civil servants and those working for Members to make sure that the data was updated regularly and to make sure that they were kept abreast of everything. Do you feel that the publication of meetings, going forward—because there can be quite a substantial number of meetings on certain affairs taking place—would place an unnecessary burden? Some would say it's necessary, but do you feel that it would place a burden on many civil servants there?

I'm not a civil servant, so I will admit to the limits of my view, but I don't think so. But, I would encourage the Government to make sure that adequate resources are put into doing that reporting—so, not increasing the reporting requirements and not giving additional resources to civil servants or additional staff time, for example. It probably would be unfair to place additional burdens without additional resources. So, I would encourage Ministers and Government departments, for example, and you in your representations to them, to consider that and make sure that the resources are there for them to be able to handle an increase in reporting.

Thank you so much, Rachel. I just want to talk to you a little bit about the revolving door. Often, we see politicians who lose their seats, they retire, they decide they want to have a bit of a career change, so sometimes they adopt new careers, and often that can consist of lobbying for various causes, or setting up their own company, et cetera. So, I just wanted to ask you, from your feedback, from your opinion, from the various views that you've probably gauged from your line of work, what risks there are to democracy that specifically might possibly arise from politicians—or members in their office, even, who are leaving after having done a job for a Minister, for example—taking up positions as lobbyists a short time after leaving their job?

I think this is why a ban—I think there is a two-year ban in place—is so important, because if you are in a job that you know you're about to lose, or if maybe within the next two to three years it's possible you'll lose that job, of course you're going to be thinking, 'How do I pay my rent? How do I pay my mortgage?' and you're going to be thinking about future employment. And you don't want to place someone in a position where, even subconsciously, they may have a brief and they're thinking about, 'Oh, but maybe that company I'm engaging with might give me a job.' And even subconsciously, even if it's not conscious, if you're, say, overseeing a development decision or a procurement contract, you do not want to even subconsciously be favouring a particular company in terms of contracts or in terms of your influence on legislation if they have particular views.

I think there is a risk there that that can happen, that people in office who are looking to leave in the near future may be influenced by certain stakeholders if they're hoping to get a job with them. We've definitely seen that in Westminster, and we've done analysis at Westminster. We've certainly seen certain correlations of certain big contracts given to companies who maybe weren't the best placed, and then that Minister has gone on to work for that company. I would say, in certain high-risk sectors, some advocates may say there might be a lifetime ban on going to work for those industries. So, for example, defence at Westminster—we would say that that's pretty suspect. But, I think you need a good ban in place for Ministers taking on jobs, particularly within their field of influence.

But it can work the other way as well. So, if someone has previously worked in public office and then gone on to work in a similar field for a company and they have very good relationships, you want to make sure they're not getting privileged access or influence because of those relationships that they still hold. But that's where transparency can come in. If you have really good transparency on who is meeting with who and who is communicating with who, then you can assess whether that's happening and hopefully address it if you think that it is.

You mentioned two years, the two-year ban; in Ireland, they have a 12-month restriction on their designated public officials, who need to, obviously, apply for permission, going forward. In a perfect world, which system do you think would be better, the 12 months or the 24 months?

I think if we're talking about Ministers, the ministerial level, then I think it does need to be 24 months, because of the influence they have when they're in office and the risk of their decision making becoming skewed because they're looking to that future employment. Obviously, if you're looking at less senior jobs, then maybe it can be a shorter time period, but I think with Ministers it should be at least two years.

Fine. And there is obviously that question of cooling-off periods as well. So that, you feel, stands for the majority of Ministers as well, across the board?

Yes.

That's fine. Thank you so much. Chair, those are my questions completed. Thank you so much, Rachel, for answering them.

Thank you, Natasha. Thank you, Rachel. I'll just check if there are any other Members with any follow-up questions for Rachel. No, everyone looks content. I certainly am. Thank you, Rachel. You've provided us with some really useful and interesting answers and further food for thought for this inquiry. So, I'd like to thank you for your time today. Just to note, a copy of the transcript will be provided to you as soon as possible so that it can be checked for factual accuracy.

Diolch. It's been a real pleasure to be here. I will follow up on those points. But also to say that we do have a network of chapters around the world. If there's anything I can help with, putting you in contact with contacts in other countries or any other analysis, please do let me know and I'll be happy to help out.

That's really useful. Thank you. I'm sure that we will keep in touch.