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DGA GROUP UK LIMITED PUBLIC AFFAIRS CODE OF CONDUCT

1: Introduction

DGA Group UK Limited (“DGA” or “we”) is committed to the highest standards of integrity, transparency, and respect for democratic processes in all consultant lobbying activities. We recognise our responsibility to act in the public interest, to maintain public trust, and to uphold the reputation of our clients and the wider industry. 

This Code of Conduct (“Code”) sets out the standards that we and those acting on its behalf, including directors, employees, contractors, and consultants (“Personnel”) engaged by DGA on behalf of its clients, will observe when undertaking consultant lobbying activities, as defined under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014 (“the Act”) (see https://www.legislation.gov.uk/ukpga/2014/4/pdfs/ukpga_20140004_en.pdf).  All such individuals are required to comply with this Code as a condition of their engagement. The Office of the Registrar of Consultant Lobbyists (“ORCL”) was created by the Act, and all Personnel have accessed https://registrarofconsultantlobbyists.org.uk and read the Guidance from the ORCL. Where appropriate, we benchmark our standards against those of the Association of Professional Political Consultants (“APPC”) and similar organisations.

This Code is published on DGA’s corporate website and can be accessed at https://dgagroup.com/UK-public-affairs-code-of-conduct, where it is freely available for viewing via no more than two clicks from the home page. No registration, login, or payment is required to view or download the Code. The URL will be maintained and updated as necessary to ensure continued accessibility. 

We will operate in compliance with the obligations under the Act, uphold this Code in all our consultant lobbying activities, and keep this Code publicly available, so that clients, public officials, those lobbied, and the public can inspect it.

This Code governs how we behave in communications with Ministers, Permanent Secretaries, or positions equivalent to Permanent Secretary (including Cabinet Secretary, Chief Executive of His Majesty’s Revenue and Customs, Chief Medical Officer, Director of Public Prosecutions, First Parliamentary Counsel, Government Chief Scientific Adviser, Head of the Civil Service, and Prime Minister’s Adviser for Europe and Global Issues), when representing clients or arranging/facilitating such communication, in return for payment.

2: Our Standards

Our consultant lobbying standards reflect our commitment to professionalism, ethical conduct, and accountability. Our standards in consultant lobbying include that: 

  • We will at all times comply with the Act, its definitions, registration requirements, and guidance from the Registrar of Consultant Lobbyists.
  • In addition to the usual standards of honesty, fairness, and respect, we will comply with provisions of our Code specific to consultant lobbying: e.g., transparency about clients, clear record-keeping, avoiding misleading representations, and conflicts of interest, among others.
  • We will respect confidentiality, except where disclosure is required by law or is necessary for transparency.
  • Our responsibilities to those to whom we make representations include that:
    • We will ensure that any communication made to Ministers or Permanent Secretaries or their equivalents is accurate, not misleading, properly attributed, and reflects the interests and instructions of our clients truthfully.
    • We will respect the public interest, the role of government, and avoid actions that could bring consultant lobbying into disrepute.
    • We will be clear about whom we represent.
  • We will provide transparency about clients and payments:
    • We will ensure that all clients on whose behalf we carry out consultant lobbying are properly declared in our Quarterly Information Returns, whether or not payment has been received at time of communication, in accordance with the requirements of the Act and Guidance from the ORCL. Client names will be provided in full, without acronyms unless the acronym is the registered name of the client.
    • If acting on behalf of multiple clients for a single communication, we will correctly declare each client.
  • We will maintain adequate records of our consultant lobbying activities that identify clients, nature of communications, timing, and to what government business they relate. Records will be retained for a minimum of seven years and will be subject to periodic internal audit to ensure compliance with this Code and statutory requirements. The Head of Public Affairs is responsible for overseeing record-keeping and audit processes.
  • We will avoid or appropriately manage conflicts of interest, including those between clients, between client interests and public duties, or between personal interests and professional responsibilities. All Personnel must promptly disclose any actual or potential conflict of interest to the Head of Public Affairs. The Head of Public Affairs will assess the situation and determine appropriate steps, which may include recusal from certain activities, disclosure to affected parties, or other remedial action. Examples of conflicts include, but are not limited to: 
    • Acting for two clients with competing interests in the same matter;
    • Having a personal or financial interest in a matter on which DGA is instructed to lobby; or 
    • Engaging in outside activities that could compromise impartiality.
  • We will be respectful in our interactions, avoid harassment or improper pressure, ensure communications are appropriate in form and content, and not deploy undue influence or misrepresentation.

3: Complaints Procedure

This section defines how complaints are handled under this Code.  Any client, public official or person to whom a representation has been made on behalf of a client by DGA, or any other person affected by DGA’s consultant lobbying activity, may file a complaint.  Complaints must be made in writing within one year of alleged breach.

The complaint must include sufficient detail to identify the issue: who made the representation, what was said or done, on behalf of which client, when and where (if known), why the complainant thinks it breached the Code, and provide relevant evidence.

Complaints regarding breaches of this Code should be sent to the Partner, Head of Public Affairs at DGA Group UK Limited at ukpublicaffairscodeofconduct@dgagroup.com. This email address will be monitored and updated as Personnel change, with changes notified to the ORCL in accordance with ORCL Guidance.

A written response should be issued to the complainant within 10 business days of receipt of complaint. If the complaint is not resolved to the satisfaction of the complainant, it will be referred to a suitably experienced independent external adjudicator (see “Complaints and External Oversight”). 

4: Complaints and External Oversight

All unresolved complaints will be referred to an Independent Adjudicator. The adjudicator will provide independent oversight and binding decisions in accordance with ORCL Guidance. Details of the complaints process are published in this Code and updated as necessary.

In addition to the Independent Adjudicator, the complaint also should be given to the person about whom the complaint is made who will have five working days to respond to the Independent Adjudicator, with a copy of the response sent to the complainant.  The Independent Adjudicator will review the unresolved complaints and ensure fairness, independence, and accountability.  The Independent Adjudicator will act as an investigator rather than an advocate and will assess, with the complainant, whether the complaint can be resolved without a formal process or whether a formal process is required. The complainant must agree to the confidential nature of the procedure. If the Independent Adjudicator finds against the complainant, the complainant will bear the costs of the Independent Adjudicator. The complainant must agree that the decision of the Independent Adjudicator is final and binding and there is no right to appeal or any other rights or remedies against DGA.

The Act grants the ORCL civil and criminal enforcement powers.  If civil or criminal legal action has been initiated, the formal complaints process will not be pursued until the outcome of the legal action is known.

5: Disposition and Sanctions

The Independent Adjudicator will determine if the complaint should be dismissed or accepted.  If the reported breach is supported and the complaint is accepted:

  • The Personnel in question will be subject to DGA’s disciplinary process as set forth in the DGA Employee Handbook and could include apologies, correction of misinformation, changes to internal processes, reporting to the ORCL if required and – if needed – sanctioning involved individuals. The severity of the sanction will be proportionate to the nature and seriousness of the breach.
  • In the event that the Independent Adjudicator determines that this Code of Conduct has been breached by DGA rather than individual Personnel, the Independent Adjudicator may require remedial action to minimise risks of future breaches of the Code and additional actions. 

The Independent Adjudicator may require that DGA publish on its website its determinations and additional information, such as any disciplinary or remedial action, within five days of acceptance of the complaint for a period of 30 days, in accordance with the ORCL Guidance on transparency. Publication will be made at https://dgagroup.com/UK-Public-Affairs-Code-of-Conduct and will include the nature of the complaint, the determination reached, and any remedial actions taken, whilst protecting confidential information where appropriate.

6: Compliance

DGA Group UK Limited undertakes to comply with this Code of Conduct that can be found at https://dgagroup.com/UK-Public-Affairs-Code-of-Conduct in relation to its consultant lobbying activity under the Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Act 2014. We will ensure that all those engaged in or participating in consultant lobbying activity on behalf of the DGA will comply with the stated Code of Conduct.  

We will confirm with each Quarterly Information Return that this undertaking remains in place.  We will also in each Quarterly Information Return confirm that all Personnel acting for DGA in consultant lobbying have complied with, and are bound, by this Code.

DGA will monitor compliance with this Code internally (through supervision, audits, senior management review, training, etc.).  We will review this Code at least annually to ensure it remains appropriate for its purpose, in light of any changes to the law, best practices, or any issues arising from complaints. All relevant Personnel will receive training on the Code and confirm their compliance upon amendment. 

All Personnel who engage in consultant lobbying read and acknowledge they have read this Code at time of hire by DGA and confirm that they will comply with its provisions. This Code is addressed to external parties, including clients, public officials, and those affected by DGA’s consultant lobbying activities, in accordance with Guidance from the ORCL. DGA will provide training regarding this Code so that all Personnel understand their responsibilities. Refresher training will be provided following any material amendments to the Code. Attendance at training is mandatory and will be recorded.

DGA encourages all Personnel and third parties to report any concerns or suspected breaches of this Code in good faith. Individuals who raise concerns will be protected from retaliation or adverse consequences as a result of making a report. Internal complaints should be addressed to the Partner, Head of Public Affairs at DGA Group UK Limited, who serves as compliance officer, at ukpublicaffairscodeofconduct@dgagroup.com. All reports will be investigated as soon as practicable and thoroughly.

This DGA Group UK Limited Public Affairs Code of Conduct is issued on 10 February 2026 and replaces all prior versions.