In an annual strategy meeting with PetroleumOil inc. – a high profile American based client – the client’s Public Affairs Manager notes that his CEO is keen to raise the profile of the company with key decision makers in Parliament. Around 30 key MPs and Peers have been identified as “core targets” for the CEO to engage with over the next 12 months.

The client is keen to deliver the new engagement programme as smoothly as possible. He suggests that as the CEO will be in the House of Commons at least twice a month over the next year, one option would be to secure a parliamentary pass to allow the CEO to pass more smoothly through the House of Commons’ security gates. The client is happy to pay for any associated administrative costs and is keen to stress that this pass is not intended to be under hand in any way, but purely to act as a “logistical asset” to his CEO.

In this scenario, even though a parliamentary pass would be sought by the agency for the client, the same rules apply.  Whilst clearly presented as a ‘logistical asset’, the same rules should be applied so as to avoid granting privileged access to any one individual.  The right course of action is to refuse the client’s request whilst seeking a way to accommodate his concerns.

Clause 14 of the APPC’s Code of Conduct states

Political practitioners must not hold any pass conferring entitlement to access to the Palace of Westminster, to the premises of the Scottish Parliament or the National Assembly of Wales or the Northern Ireland Assembly or the Greater London Authority or any department or agency of government.  The only exceptions are:

  • Where the relevant institution is a client of the political practitioner and requires the political practitioner to hold a pass to enter their premises.
  • Where the political practitioner holds a pass as a spouse or civil partner of a member or as a former member of the relevant institution, in which case the pass must never be used whilst the practitioner is acting in a professional capacity.