Unregistered interests: ca. 50% of MLAs don’t declare £150 payments from Lobbyist Company?

There are lots of interesting little details in the Assembly Register of Member’s Interests. Two MLAs being paid a small sum for filling in surveys isn’t one of them:

Miscellaneous Interests

Jim Wells and Paul Givan

Stratagem Northern Ireland: a survey company which occasionally surveys the views of MLAs on a wide range of issues. A fee of £50.00 is payable for each survey completed.

You can find the results of numerous Stratagem surveys of MLAs online but details of how they are conducted now only seem available via a cached link. Stratagem claims 55 MLAs have signed up to answer these surveys up to 3 times a year with a guaranteed response rate of at least 40.

The panel gives organisations a unique chance to engage with a balanced group of over 55 MLAs across all political parties. These MLAs have agreed to respond to questions in a short questionnaire sent two to three times a year. Stratagem guarantees a response rate of at least 40 MLAs.

That’s a little more interesting when stood beside Wells and Givan’s declaration that each survey completed attracts a payment. While Strategem do not state there is a payment there is – £50 per survey. That’s a fee of up to £150 a year paid directly from Stratagem to between 40 and 55 MLAs, something all but two aren’t declaring on the Register. Slugger understands (edits to add: that sounds really wanky – I rang Quintin and asked him) all MLAs ultimately pass their Stratagem payment to a charitable cause.

So did Wells and Givan needless declare a small sum paid to them by a lobbying company or have up to 53 MLAs failed to register their payments from Stratagem?

That depends on how you interpret Section 69 of the Code of Conduct:

Category 10

Miscellaneous Interests: Any relevant financial interest not falling clearly within one of the above categories.

69. Members should register here any financial interests which might reasonably be thought by others to influence a Member’s actions, speeches or votes in the Assembly, or actions taken in his or her capacity as a Member of the Assembly but which do not fall clearly into any of the above Categories. It is a cardinal principle that Members are responsible for making a full disclosure of their own interests in the Register; and if they have relevant interests which do not fall clearly into one or other of the specified Categories, they will nonetheless be expected to register them.

Adds: there may be an argument the £150 falls into another category some of which allow amounts under 0.5% of the member’s salary (£217) to be exempt from declaration. With Wells and Givan’s treating the payments as declarable it seems 53 MLAs could face having to make that argument given Section 12 states:

Failure to register an interest may be an offence under section 43 of the Northern Ireland Act 1998. The Committee on Standards and Privileges may refer to the Public Prosecution Service complaints received in respect of such an alleged failure.

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