 |
Northern Ireland Government Affairs Group
CODE OF PROFESSIONAL CONDUCT
Contents:
1.
Introduction
2. Code of Conduct
3. Composition of Disciplinary Committee
4. Benefits of compliance
5. Enforcement procedures
6. Public information
Introduction
Public affairs
professionals established the Northern Ireland Government Affairs
Group in 2000 to raise the standards and enhance the reputation
of public affairs locally.
Members come
from a wide range of backgrounds – commercial public affairs
and PR companies, the voluntary sector, education, trade associations,
business and industry, and professional bodies. They share a common
desire to ensure that public affairs and lobbying activities on
behalf of local interest groups are undertaken professionally and
responsibly.
The Northern
Ireland Government Affairs Group (NIGAG) aims to:
- Provide
members with regular opportunities to hear and discuss views and
case histories with relevant speakers;
- Respond
to or initiate statements on policy issues affecting the conduct
of public affairs; and
- Take opportunities
to encourage and facilitate educational activities for members
and aspiring practitioners.
NIGAG’s
members believe that the lobbying of politicians and governmental
institutions is an entirely proper and legitimate activity in itself.
It occurs in all free and democratic societies, and is indeed a
fundamental democratic right. Lobbying fulfils a number of highly
proper functions:
- Lobbyists
act as a bridge between policy makers and wider civil society.
They ensure that politicians and civil servants are aware of the
needs, desires and interests of particular groups of people or
organisations; or alternatively that they can play a part in ensuring
that the interests of specialised and homogenous groups are represented;
- Lobbyists
enable interest groups and sections of the electorate to participate
in the political process beyond casting votes at elections, ensuring
decision makers remain responsive to public opinion between elections;
and
- Lobbyists
assist public office holders to find solutions to specific policy
problems or issues, thus improving the quality of our government.
For
the purposes of this Code of Professional Conduct, lobbying is defined
as:
“All activity associated with representing the
interests of a client or employer as regards any matter of public
policy. This includes the provision of information and advice, as
well as the actual advocacy of a point of view.”
As part of
the professional development it has developed this Code of Professional
Conduct as a mechanism by which the activities of its members can
be self-regulated. It is a response to the legitimate need to ensure
that
political institutions
and the public alike are protected from unprofessional behaviour
on the part of those seeking to influence public policy here.
All members
of NIGAG – whether in-house executives, employees or owners
of commercial consultancies, sole traders, or others – are
required to formally adopt this Code and to ensure that they meet
all its provisions in all their professional activity.
Code
of Professional Conduct
- All members
of the Northern Ireland Government Affairs Group must take care
to ensure that none of their activities or behaviour causes, or
has the potential to cause, damage to the reputation of NIGAG
itself or to their profession more generally.
- Members
must at all times deal with clients/employers and all the institutions
of government (local, regional, central and international public
bodies) honestly, transparently, with integrity and ethically.
- Members
are required to take all reasonable steps to establish that all
information and advocacy supplied by them to clients/employers
or to public office-holders/press – and supplied by clients/employers
to NIGAG members or to public office-holders/press – is
factually accurate and honest.
- For the
purposes of this Code of Professional Conduct, “public office-holders”
are defined as outlined in the attached footnote. For the purposes
of this Code of Professional Conduct, “press” is defined
as outlined in the attached footnote.
- Members must
always observe a positive duty in all their professional dealings
to proactively disclose the identity of their client or employer,
and to be open in providing other information when requested (within
the normal boundaries of commercial confidentiality).
- If a member
believes that the objectives or activities of his or her client/employer
may be unethical, illegal or contrary to good professional practice,
he or she is required to so advise the client/employer and should
refuse to act on behalf of the client/employer in respect of the
furtherance of those objectives and activities.
- Members
must take care to ensure that no reasonable person could believe
a member to be making inflated or misleading claims to anyone
regarding their access to, or influence over, any institution
of government, public office-holder or member of the press. In
particular, members are absolutely prohibited from suggesting
that a given objective can be guaranteed if it would involve a
public office-holder or member of the press making any decision
or taking any action.
- All members
are responsible for ensuring that any financial relationships
involved in their professional dealings are legal, ethical and
could not reasonably be construed as being potentially illegal
or unethical. In particular, members should not offer any financial
incentive (in cash or in kind) to any public office-holder, member
of the press, other lobbyist, client, or potential client, which
could be interpreted as improper or questionable ethically. Nor
should a member accept any such incentive. This provision does
not relate to modest entertainment or hospitality expenditure,
or to the presentation of token and proportionate business mementos,
or to the ordinary payment to political parties and related organisations
of fees for activities such as fringe meetings at conferences
and the sponsorship of political events and activities. Members
should also think carefully, about the desirability of providing
financial or other assistance for electoral purposes.
- Members
must not represent conflicting interests as to do so inevitably
raises legitimate questions of ethical conduct. They may, with
the explicit and informed consent of all other parties involved,
represent competing interests so long as it remains possible to
provide each of the parties with an equal professionalism and
duty of care. This is a particularly difficult issue as the representation
of conflicting interests calls into question the professional
integrity not solely of the individual member but of the industry
as a whole. NIGAG holds that one person cannot credibly advise
or make representations on behalf of conflicting interests.
- Members
should take special care to keep entirely separate – and
be seen to do so – their professional activities and responsibilities
and their personal and individual membership of and involvement
in political parties, pressure groups, related organisations and
other political causes. In particular, they should make no reference
either to their membership of the Northern Ireland Government
Affairs Group or their status as a ‘NIGAG Registered Public
Affairs Practitioner’ in the course of their personal activities.
If any conflict or potential conflict arises between their professional
duties and their personal activities, they must in all cases give
precedence to their professional responsibilities and should consider
whether it is necessary or desirable to resign any relevant personal
memberships or cease any relevant personal involvements.
- Members
are obliged to observe and strictly adhere to any rules, conventions
and guidelines relating to the obtaining, release and dissemination
of all parliamentary, governmental, official and political documents
and materials. If an unsolicited copy of any such paper is supplied
to a member other than in accordance with the normal procedures,
the original must be returned to the relevant public body along
with an undertaking that no copies have been made and that the
information contained in the document will not be made use of
in any way.
- In their
professional capacity as lobbyists/government relations consultants,
members should neither hold nor seek to obtain passes issued to
Members’ personal staff, the media or staff of political
parties, which confer entitlement to access (or other privileges)
to the Northern Ireland Assembly, the Palace of Westminster, the
Scottish Parliament, the Welsh Assembly, the Dail Eireann, or
any premises of a governmental or public body. Such passes are
intended only for those individuals whose professional duties
require particular levels of access. Members of NIGAG, in any
circumstances, should not abuse them. NIGAG members may have a
legitimate right to such passes by virtue of personal positions
held as a paid employee of a Member, the media or a political
party. In all cases, though, it is held by NIGAG to be grossly
unethical to use such a pass to gain entry to a parliamentary
or governmental building if the member is actually conducting
business there during that visit in their professional capacity
as a lobbyist/government relations consultant rather than as an
employee entitled to hold such a pass. If NIGAG members have other
paid employment, the professional requirements outlined in this
Code take precedence. If, for instance, a NIGAG member in possession
of such a pass intends to conduct several items of business of
a dual nature within a parliamentary building, they are obliged
to enter the building and conduct themselves throughout that visit
on the basis that they are a non-pass holder. If it is drawn to
the attention of the Disciplinary Committee that a member holding
such a pass has, on any date following approval of this Code of
Professional Conduct by NIGAG’s Executive Committee, abused
the access or facilities provided by such a pass, such behaviour
would – if proven to the satisfaction of the Disciplinary
Committee – constitute misconduct sufficiently serious to
be drawn to the attention of the authorities of the Northern Ireland
Assembly and liable to lead to expulsion from the Northern Ireland
Government Affairs Group.
- NIGAG members
must, while in the Northern Ireland Assembly or any other parliamentary
or governmental building, observe the rules and procedures of
that institution.
- Members
are required to treat all public office-holders with courtesy
and respect at all times.
Composition
of Disciplinary Committee
The Disciplinary
Committee consists of three NIGAG members appointed by the Chairman.
No member of NIGAG directly involved in an alleged breach of this
Code of Conduct (in no matter what capacity) may sit on the Disciplinary
Committee while the alleged breach is under investigation.
Enforcement
Procedures
Adherence to
the terms of this Code of Professional Conduct is a compulsory requirement
of membership of the Northern Ireland Government Affairs Group.
If a complaint is received by the Chairman from any source about
alleged misconduct (defined as any breach of the specific items
included in the Code) by a member of NIGAG, he or she shall ask
NIGAG’s Disciplinary Committee to investigate the complaint
in whatever way the Committee deems appropriate and to make recommendations
to the NIGAG Executive Committee which is the final arbiter. No
member may participate in the deliberations of either committee
if he or she is materially involved in the complaint.
The Disciplinary
Committee’s recommendations – and the final decision
of the Executive Committee – can take a number of forms:
- That the
complaint has not been proven to the satisfaction of the Disciplinary
Committee and is therefore dismissed;
- That the
misconduct complained of is essentially minor in nature, in which
case the member concerned will receive a written warning that
he or she must ensure the Code is complied with rigorously in
the future;
- That the
misconduct is significant and liable to cause the integrity of
the Northern Ireland Government Affairs Group itself to be called
into question, and that therefore the member involved shall be
expelled from the group. In this event, the group has the option
of disassociating itself from the member in any way it feels appropriate
– for instance, issuing a press release detailing the findings
of the Disciplinary Committee; informing the expelled member’s
employers; or informing all Members of the Northern Ireland Assembly;
or
- Ultimately
– if the transgression appears sufficiently disturbing and
serious – the authorities of the Northern Ireland Assembly
may be asked to consider whether the misconduct is such that the
Assembly itself should take action against the offender.
Benefits
arising from compliance
The most important
benefit attached to compliance with the terms of the Code of Professional
Conduct is that the lobbying/government relations/public affairs
profession in Northern Ireland will both be professional and ethical,
and seen by others as being professional and ethical. That is of
inestimable value to all practitioners, in whose interest it is
that policy makers and the public alike perceive their profession
as reputable, legitimate and of a high standard.
More particularly,
all NIGAG members, accepting the requirements of this Code as an
obligation arising from their membership of the Group, are entitled
to refer to themselves as a ‘Northern Ireland Government Affairs
Group Registered Public Affairs Practitioner’ or ‘NIGAG
Registered Public Affairs Practitioner’. The group will promote
this scheme, and it is to be hoped that over time both clients and
employers insist on only being represented by professionals who
can describe themselves as such. Companies with several employees
can only use this description if all executives and employees involved
in lobbying and government relation’s activities are individually
entitled to the description through their membership of NIGAG.
Public
Information
In order to
ensure the widest possible public awareness of the provisions of
this Code of Professional Conduct, upon initial adoption and following
all subsequent amendments to the Code, the Chairman of NIGAG will
send a copy to all local MPs, MEPs and MLAs, and will issue a press
release on the terms of the Code.
Annex One –
Evidentiary Standards
For the purposes of this Code of Professional Conduct,
“public office-holders” are defined as: all elected
or appointed Members of any legislative body in the United Kingdom,
Ireland or European Union; officials and staff employed by or at
those institutions or by those Members; members and officials of
local authorities; members and staff of the various cross-border
and British-Irish institutions established under the Good Friday
Agreement; civil servants of all descriptions; and members and staff
of all non-departmental public bodies. For the purposes of this
Code of Professional Conduct, “press” is defined as
including: all journalists, researchers, editors and production
staff working for any print, broadcast or electronic media outlet,
as well as freelance journalists and writers.
Back
to Top
|
|
