Mr John Lyon CB

Commissioner for Standards

Office of the Parliamentary Commissioner for Standards
House of Commons
London
SW1A 0AA

18th January 2009

Sent by post and fax to 0207 219 0490

Dear Mr Lyon,

Yesterday Peter Watt, the former General Secretary of the Labour Party, revealed that
Gordon Brown MP had a secret, off-the-books, fund of up to £50,000 per year of donations
for his own personal use. According to Mr Watt, the only record of this fund was kept by Mr
Brown, unofficially, in an exercise book. We believe the circumstances surrounding this
"fund with no name" contravene the rules governing the behaviour of Members of
Parliament.

Select Committee on Members’ Interests, First Report, Session 1991–92, “Registration and
Declaration of Financial Interests”, HC 236, paragraph 27 states that Members of Parliament
must “provide information of any financial interest or other material benefit which a Member
receives which might reasonably be thought by others to influence his or her actions,
speeches or votes in Parliament, or actions taken in his or her capacity as a Member of
Parliament.” Mr Brown did not do this.

Mr Watt believes that the money was spent on "personal private polling", if this were the
case then it would almost certainly contravene these rules. Whatever the money was spent
on, the secretive way in which it was raised, kept and used highlights some serious
questions that must be asked of Mr Brown in a thorough investigation by the Parliamentary
Standards Commission. The Code of Conduct and The Guide to the Rules Relating to the
Conduct of Members also states “Members are responsible for making a full disclosure of
their interests, and if they have relevant interests which do not fall clearly into one or other
of the specified categories, they are nonetheless expected to register them.” Clearly, Mr
Brown did not do this.

T : 020 7837 3312 F : 070 9201 2337 E : team@sunlight-cops.org.uk

Albion Buildings, 1 Back Hill, London, EC1R 5EN
A not-for-profit company limited by guarantee, advocating political transparency and openness.
For your information, Mr Brown's relationship with The Smith Institute was investigated in
2008. Similar concerns had been raised that he was using money from a supposedly neutral
charity to employ private pollster Bob Shrum, working directly for Mr Brown. The Charities
Commissioner reported that Mr Shrum was not paid for using funds from the Smith
Institute, so there is good cause to investigate whether Mr Brown's personal pollster, Mr
Shrum, was paid from this "fund with no name". If this was the case there would be no
doubt that this is a "material benefit which a Member receives which might reasonably be
thought by others to influence his or her actions."

We would urge you, in the strongest possible terms, to investigate this hitherto unrevealed
fund for the personal benefit of a Member of Parliament.

Thank you for your time and we would appreciate an acknowledgement of the receipt of this
letter.

Yours sincerely,

Harry Cole
Centre for Open Politics
harry@sunlight-cops.org.uk

T : 020 7837 3312 F : 070 9201 2337 E : team@sunlight-cops.org.uk

Albion Buildings, 1 Back Hill, London, EC1R 5EN
A not-for-profit company limited by guarantee, advocating political transparency and openness.