Cabinet 'Ethics Committee' approval for HSBC's Baroness Rona Fairhead vs ICAP's Michael Spencer

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Dear Cabinet Office,

I am interested in the specific procedures, particulars and records (i.e. selection criteria, staff procedures/ protocols, meeting notes/ records) surrounding the nomination and screening of candidates for the House of Lords, which pass through the Cabinet desk for screening by the Cabinet Office Head of Ethics - Sue Gray [1].

In particular - I am interested in information relating to 'Ethics Approval' screening process by Sue Gray's team for two specific individuals, both of whom as prominent public and business figures - are of significant public interest:

1) Michael Spencer, who was nominated four times for the Lords by David Cameron, and blocked on each occasion by Cabinet; ostensibly for issues relating to the Iceland banking scandal, and the involvement of ICAP in the LIBOR [2] interest rate rigging scandal; and

2) Baroness Rona Fairhead, who despite grave misgivings regarding her conduct and competence, both as a HSBC Non-Executive Director, during the laundering of Mexican drug cash for the Sinaloa drug cartel, which left tens of thousands dead, and her dire performance in front of Margaret Hodge and the Public Accounts Committee as Chair of the BBC Trust [3] - yet was inexplicably approved as being suitable to pass ethics screening?

3) I would like to understand on which specific 'ethics' criteria Mr Spencer was deemed unsuitable for the Lords, yet Baroness Rona Fairhead was passed fit for purpose?

4) Which members of Sue Gray's Cabinet staff were present when these decisions were made? and how was the approval process both recorded and communicated to Cabinet staff? (please provide records of relevant communications).

I look forward to your response.

Yours faithfully,

Joel M Benjamin


FOI Team Mailbox, Cabinet Office



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