You are meeting a new client to carry out some pro bono work. The client is a charity and employs staff to undertake lobbying. Your work stream will focus predominantly on PR and media engagement, although some discussions with civil servants may be necessary. Consequently, the client asks you to omit their name from the APPC register.
The disclosure requirement covers all public affairs work of whatever nature for all clients, fee-paying or not, including advice as well as direct interaction with institutions of government. APPC guidance has always been for member firms to “err on the side of caution” when registering clients. The register is up-dated quarterly and, if no public affairs services have been provided during that quarter, a client’s name should not be included in the register.
Clause 18 of the APPC Code of Conduct states
Members must disclose the names of all their clients and practitioners in the APPC Register. A member providing secretariat or other services for an All-Party Parliamentary Group must list that APPG as a client, together with the name(s) of the APPG’s funder(s) and any associated organisation(s).