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.