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Campaigning and election law webinar

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Slides from a webinar, broadcast on 14 November 2019, covering what you need to be aware of in charity and electoral law during a general election, and providing guidance and tools to help your organisation campaign with confidence.

Watch the webinar at: https://www.youtube.com/watch?v=tmInr8tBlLc

Published in: Government & Nonprofit
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Campaigning and election law webinar

  1. 1. General Election 2019 Campaigning and Election Law Douglas Dowell (NCVO) Stacey Frier (Bond) Suhan Rajkumar (Bates Wells) November 2019
  2. 2. 1. Legal Framework 2. Implications for campaigners (you) What we’ll cover Political Parties, Elections and Referendums Act 2000 (‘PPERA’) General Elections, EPEs, devolved authorities, referendums Representation of the People Act 1983 (‘RPA’) All elections (including local government/councils etc) Charities: CC9 Campaigning and political activity by charities at any time Charities: ‘Charities, Elections & Referendums’ Campaigning and political activities by charities ahead of an election
  3. 3. Charity law
  4. 4. charitable purposes• Established for only • Not charitable if political. • Can campaign and undertake political activity. • ONLY if supports delivering • Not sole and continuing activity • Never party political • Must stress independence Charity Law: Fundamental Principles Clear Reasonable Evidence Basis charitable purposes Always be aware of your objects
  5. 5. Carefully consider CC9 and trustee risk analysis Charity Commission Guidance on campaigning generally – CC9 Speaking out: guidance on campaigning and political activity by charities Campaigning Political activity
  6. 6. • Applies from the period between the announcement of an election and the date it is held (usually from the formal publication of an election notice) • Whilst CC9 always applies, the time before an election is particularly sensitive for charities to navigate and their independence must be protected • “The guiding principle of charity law in terms of elections is that charities must be, and be seen to be, independent from party politics” • The guidance is shaped around what the Commission deems the key risk areas for a charity’s party political independence Charity Commission supplementary guidance – ‘Charities, Elections and Referendums’ Policies Publicity Parties Candidates
  7. 7. Policies • You must never support a party or candidate or make a donation to a party or candidate • A Charity’s policy position on an issue may coincide with, be the same as or different from one of the political parties • Fine to continue to campaign on that issue and advocate the charity’s policy but must stress independence • Must also take steps to manage the risk of alignment/disparity between charity and party’s position being so overt that the perception of its independence is affected • May still be regulated activity under election law as the test is broader
  8. 8. Publicity • Must never support a party or candidate • Must not make a call to vote or attempt to influence voter behaviour - e.g. explicitly compare charity’s views to those of a candidate or party • Acceptable to achieve a similar effect through indirect means – e.g. if your charity supports the opening of 1000 new libraries in England it could outline the position of each party on that policy position • Can publish a manifesto in order to publicise the charity’s core issues, where the charity is trying to persuade parties to adopt the policies which it advocates, or is trying to raise the public profile of those issues. Not acceptable where the intention is to influence voter behaviour • Must refuse any request to be mentioned in a party manifesto • Also consider the government/local authority pre-election period - risk to funding/relationship?
  9. 9. Candidates and Parties • You must never support a party or candidate or make a donation to a party or candidate • You can invite candidates and party representatives to public meetings about the charity’s issues, i.e. speak at a reception or debate, but cannot be seen as endorsing, supporting, or prejudicing a party or candidate • To combat this, CC advises inviting as broad a spectrum of candidates as possible – this is complex area as charity and election law can conflict here • You can engage with candidates but must be wary of becoming associated in the minds of public with a candidate or party – you must manage the risk that candidates may think it is of benefit to their profile to publicly support the charity
  10. 10. • Charity Commission report on GE 2015 charity issues highlighted risks of social media. E.g. Brent Private Tenants’ Rights Group Limit were subject to engagement with the CC as the charity’s twitter account was used inadvertently by a staff member to air support for a specific party (note no regulatory action was taken as accepted in error) You should remind staff, volunteers and officers: • Should a candidate/party associate themselves with charity content or policies, re-tweeting them may be seen as an endorsement; • To avoid use of party political or party campaign hashtags; and • To ensure that personal views of staff are not conveyed through any charity platform or with charity branding – senior staff are a higher risk as even using personal channels may be seen to be speaking on behalf of the charity. • To have controls/training in place to ensure that staff are aware of their responsibilities in this time and need to separate work and personal use of social media. Risk area: social media
  11. 11. Election law
  12. 12. The two election law regimes: the RPA and PPERA • The RPA governs local campaigns – Defined by EC as “non-party campaigns for or against one or more candidates in constituency, ward or other electoral area” – Applies from dissolution of Parliament (in the case of a general election) until the election: 6 November 2019 – 12 December 2019 – Regulated by the police/CPS – Charities are very unlikely to carry out activity subject to the RPA • PPERA governs general campaigns – Defined by EC as “non-party campaigns for or against a political party, policy, issue or a particular type of candidate.” – Applies during the regulated period before an election. – Regulated by the Electoral Commission • Electoral Commission guidance implies a clear distinction between PPERA and the RPA but both can apply to some campaigns
  13. 13. General campaigning rules - PPERA
  14. 14. The Political Parties Elections and Referendums Act 2000 (PPERA) • Introduced after political funding ‘scandals’ to give transparency on donations and spending of parties • Third party campaigners which are seen to be trying to influence an election outcome are also covered by the rules – Aimed at large scale advertising campaigns – Partly an anti-avoidance measure • Created a framework of: – Registration with the Electoral Commission – Spending and donation controls – Reporting requirements • Lobbying Act in 2014 significantly widened PPERA’s scope
  15. 15. ELECTORAL LAW: ARE YOU SPENDING ENOUGH TO NEED TO WORRY? • You only need to register with the Electoral Commission if you’re spending more than these amounts on regulated activity: • England: £20,000 • Scotland, Wales or Northern Ireland: £10,000 • If you know your campaign budget (including staff time) is definitely under this, you won’t need to register even if the activity is regulated • But don’t forget constituency limits – you can’t spend more than £9,750 in any one constituency (including their share of any general campaigning you’re doing) • You still need to follow charity law and guidance
  16. 16. How PPERA works for non party campaigners In the regulated period leading up to certain elections, PPERA regulates spending which may be seen as intended to influence the election outcome and donations received to support that spending. Length of regulated period depends on election: A general election = 12 months up to the election EPEs, Scottish Parliament, Welsh/NI Assembly = 4 months e.g. 2019 General Election: 12 December 2018 – 12 December 2019 12 month GE regulated period can be retrospective
  17. 17. Retrospective regulated periods 2017…
  18. 18. For this election: the regulated period started on 12 December 2018 Retrospective regulated periods September 2019…
  19. 19. IT’S A SNAP ELECTION – BUT THE ELECTORAL COMMISSION WILL TAKE THAT INTO ACCOUNT • The retrospective nature of the regulated period worried some campaigners in 2017, though the Electoral Commission offered some reassurance • The guidance is much clearer about this now • Many campaigns are purely issues-based rather than focusing on candidates or parties, and issues may not be sufficiently closely and publicly associated with a party, parties or category of candidates to meet the purpose test. • You are unlikely to be reasonably regarded as intending to influence people to vote in an election when you do not know or expect that the election is happening – and where this was the case, your activity is unlikely to have met the purpose test. • The specific GE 2019 guidance says: ‘However, most campaign activity undertaken before an election is announced is unlikely to meet the purpose test.’
  20. 20. WHAT ARE THE EXCEPTIONS? • If you ran campaigns which met the purpose test in a different election in the regulated period, then they are regulated activity: • European Parliament elections (23 May 2019) • Local elections (2 May 2019) • If you anticipated or made reference to the future election before it was announced, that’s more likely to meet the purpose test: • this is less likely to affect charities • the Electoral Commission gives ‘Vote Conservative in the coming election’, or ‘Unseat MPs who voted for austerity’ as examples
  21. 21. Recap: registration and spending limits – general elections • If you may spend more than: – £20,000 in England, or – £10,000 in any of Scotland, Wales or Northern Ireland • Then you must register with the Electoral Commission before you exceed that registration threshold • What if we won’t cross those thresholds? – Think about charity law and some compliance requirements – but broadly, nothing to worry about!
  22. 22. • Additional administrative burden – Keeping invoices – Tracking spending – Reporting spending (published to the public) – Controls on donations you can receive • Higher spending limits – £479,550 in England – £73,400 in Scotland – £55,259 in Wales – £37,550 in Northern Ireland – Adds up to £645,759, but due to attribution rules, in practice overall limit for a UK-wide campaign is generally £584,817 Registered non-party campaigners at General Election 2019
  23. 23. Other spending limits to consider Targeted spending rules: if your campaign can reasonably be regarded as intended to influence voters to vote for one particular political party or any of its candidates and no others, then you will have access to a lower registered spending limit Designed to catch organisations such as Momentum – but could apply to some other campaigns Constituency spending limits: £9,750 per constituency if spending is “wholly or substantially confined to a particular constituency or constituencies” and has “no significant effect” in other constituencies You must split your national spend between constituencies equally unless your activity is wholly or substantially confined to one or more particular constituencies. Unclear boundaries between constituency level limits under PPERA and the RPA
  24. 24. Are you incurring PPERA regulated spending? One way to determine whether spending is regulated by PPERA is to apply 3 tests: 1. Activity test 2. Public test 3. Purpose test
  25. 25. The Activity Test – Material made available to the public by whatever means (eg leaflets, adverts, websites, social media, reports, etc) – Canvassing or market research seeking views or information from members of the public. – Press conferences or other media events, organised by or on behalf of the non party. – Transport of persons to any places with a view to obtaining publicity. – Public rallies or other public events, other than annual conferences of the third party (including all expenses in respect of events - eg premises hire, provision of goods, services or facilities) Spending on the following activities may be regulated under PPERA: Including all associated staff time costs and other overheads
  26. 26. The Activity Test - exceptions – Volunteer time (but expenses will be caught) – Publications in newspapers and periodicals (other than paid ads) – Interviews on BBC and other broadcast media where there is a duty of impartiality - eg local radio, sky, C4 (but video on demand will be caught) – Translations from Welsh to English – Reasonable non-reimbursed personal travel expenses – Reasonable expenses attributable to disability – Security costs for meetings – Website content may not be regulated if not promoted by email, twitter, facebook viral marketing (but risky) The following activities will not result in regulated spending under PPERA:
  27. 27. The Public Test Expenditure generally will not be regulated if it is not directed towards the public. EC guidance states that an organisation’s ‘members’ or ‘committed supporters’ are not the public, including:- • Regular donors by direct debit • People ‘actively involved’ in the organisation Signing up to mailing lists or social networking sites does not constitute active involvement. Influencing activities that exclusively target MPs, PPCs etc are not caught – private lobbying not public campaigning
  28. 28. • Expenditure is only controlled if it is directed at the public or a section of the public • Constitutional members – would not be ‘public’ • “Committed supporters” not caught – e.g. those giving regularly by direct debit • People who sign up to mailing list or like your social media pages – probably still amount to ‘public’ Do your members comprise a “section of the public” for the purposes of PPERA?
  29. 29. The Purpose Test Spending which passes the other tests will be regulated under PPERA if it can: “reasonably be regarded as intended to promote or procure electoral success at any relevant election for – (i) one or more particular registered parties, (ii) one or more registered parties who advocate [or do not advocate] particular policies or who otherwise fall within a particular category of such parties, or (iii) candidates who hold [or do not hold] particular opinions or who advocate [or do not advocate] particular policies or who otherwise fall within a particular category of candidates” (PPERA s85(2))
  30. 30. The Purpose Test The following can also be caught under the purpose test: Prejudicing a party or candidate It includes prejudicing the electoral prospects of other parties or candidates (PPERA s85(4)(b)) Activity that does not name a party or candidate “a course of conduct may constitute the doing of one of those things even though it does not involve any express mention being made of the name of any party or candidate” [PPERA s85(4)) Multi-purpose activities “it is immaterial that it can reasonably be regarded as intended to achieve any other purpose as well” (PPERA s85(4)(A))
  31. 31. Electoral Commission Guidance • In almost all cases, an activity will meet the purpose test if it: – explicitly promotes political parties or candidates who support your campaign’s aims, or – implicitly promotes some parties or candidates over others, for example by setting out or comparing the merits of the positions of political parties or candidates on a policy • If your campaign does not mention candidates, parties, or elections, then your spending is less likely to be regulated. In order for an activity to meet the test, the voter needs to know which way they are being persuaded to vote. • However, your campaign might identify a political party, parties, or group of candidates implicitly, without naming them – eg if a policy/issue is so closely and publicly associated with a party, parties or category of candidates that it is effectively a shorthand for them. • Specific policies may be more likely than more general issues to be closely associated with parties or candidates.
  32. 32. Electoral Commission Guidance • When you intend something, you can in some circumstances be reasonably regarded as having a different intention, or a further intention. • E.g. the primary intention of your campaign may be: – raising awareness of an issue – influencing political parties to adopt a policy in their manifestos – providing information to voters – encouraging people to register to vote • But, your campaign will still meet the purpose test if it can also be reasonably regarded as intended to influence voters to vote for or against a political party or category of candidates. • For example, suppose for example your intention is to influence political parties to adopt a policy. If you go about this by identifying and promoting parties and candidates who have already adopted the policy, then this will meet the purpose test.
  33. 33. Electoral Commission Guidance • A political party may publicly adopt policies that you are already campaigning for or against. • If your campaign did not meet the purpose test before the party changed its position, your planned campaign remains unlikely to meet the test. • However, as a result of the party changing their position, you might enhance or increase your spending on the issue over what you originally planned. • In this case, the further campaign spending will be regulated if it can reasonably be regarded as intended to promote or criticise the party. • If you welcome a political party’s commitment to a policy that you have campaigned on, and it is clear that you would welcome a commitment from any political party, this will typically not meet the purpose test. • “If you are a charity and abide by charity law and guidance from the relevant charity regulator, in most circumstances your campaign activity is unlikely to meet the purpose test.”
  34. 34. THE NEW GUIDANCE RECOGNISES CHARITIES ARE DIFFERENT • The new guidance recognises that charities are bound by charity law, not just electoral law • It also recognises that some NGOs are bound by their own rules not to be partisan or part- political • The Electoral Commission’s guidance says: ‘If you are a charity and abide by charity law and guidance from the relevant charity regulator, in most circumstances your campaign activity is unlikely to meet the purpose test.’ • This means charities should still consider how much you’re spending and then (if relevant) the public and purpose test, but are unlikely to be carrying out regulated activity
  35. 35. Electoral Commission Guidance To assess whether your campaign meets the purpose test you should consider:- WOULD A REASONABLE PERSON REGARD YOUR CAMPAIGN AS INTENDED TO INFLUENCE VOTER CHOICE? Tone: is the tone of your campaign negative or positive towards a political party or parties or a policy that categories of candidates support or do not support. Context and Timing: is the issue prominent, is there a clear area of difference between the political parties, are you campaigning as a reaction to a policy or position of a political party, are you campaigning close to the election day. Call to Action: are you asking people (whether explicitly or implicitly) to vote for a particular political party or categories of candidate?
  36. 36. WHAT’S BETTER ABOUT THE PURPOSE TEST GUIDANCE? • The language about the purpose test is clearer and sharper • The factors the Commission takes into account in deciding whether the test is met are more tightly defined: • ‘call to action’ is now narrowed to ‘call to action to voters’ – so this is only about an explicit or implicit ask to vote in a particular way • ‘implicitly promoting parties or candidates’ is more clearly worded – . In particular, it now refers to ‘setting out or comparing the merits of the positions of political parties or candidates on a policy’ – not just the positions. • If a party adopts a policy you’ve already been campaigning on, carrying on with what you were already doing or planning to do is unlikely to become regulated activity as a result
  37. 37. Purpose test – campaign example: Team Future
  38. 38. Stonewall
  39. 39. CND
  40. 40. (1) Ensuring that expenditure that does pass the “purpose” test (2) Ensuring that expenditure does not pass the “public” test (3) Ensuring that expenditure does not relate to a regulated campaign activity, e.g: – Production and publication of materials (including leaflets, emails) – Canvassing and market research – Press conferences or other media events – Public events and rallies – Transport of people for the purposes of obtaining publicity Recap: how can you avoid incurring “controlled expenditure” which would be regulated under PPERA?
  41. 41. Adapting your strategy? • Campaigning for/against legislation in parliament – Timing campaign activity to coincide with Parliamentary debates on the Bill & focus on why the Bill should become law • Terminology and tone during the regulated period – Think carefully about: • hashtags identified with a party or candidate • terminology that is very overtly associated with a particular party • Use of colours/images e.g. blue, orange, red backgrounds, use of ballot box images – E.g. “Bedroom tax” – 2015 GE • EC : this “was a particular clear and prominent policy of the Conservative Party at the election; it was closely and publicly associated with them.” • A campaign against the bedroom tax likely to meet the purpose test – “the very phrase ‘bedroom tax’ is one that was coined and used by the Conservatives’ opponents in that election campaign.”
  42. 42. Working as a coalition / joint working • Contentious and unclear area of election law – risk area • Recent investigation into the Darren Grimes / BeLeave and Vote Leave relationship / donation
  43. 43. Campaigning in a coalition - joint working • If you and another campaigner are incurring joint spending in a joint campaign, then the regulated spending by each campaigner counts towards the regulated spending total for both campaigners. – eg if you spend £100 of regulated spending under a common “plan or other arrangement” with another campaigner and they spend £30,000, you both need to account for £30,100 of regulate spending – Could result in in spending by other organisations being attributed to your organisation – so consider carefully • ‘Minor campaigners’ can nominate a ‘lead campaigner’ who registers with the Electoral Commission and the lead campaigner is then responsible for reporting the minor campaigner’s spending • Minor campaigner does not then have to register separately with the Commission unless it spends more than the registration threshold in total
  44. 44. Campaigning in a coalition - joint working Guiding principle: “honest and reasonable assessment, based on the facts, whether you and another non-party campaigner are spending money as part of a common plan or arrangement” • PROBABLY NOT joint working if: – You speak at another campaigner’s event without being involved in any other way – You have informal discussions with another campaigner, or keep each other informed, in a way that does not involve decision- making or coordinating your plans – You endorse another campaign without having any further involvement – for example if you: – sign a letter written by another campaigner – add your branding to another campaign – publicise your support for another campaign • PROBABLY joint working if: – You have joint advertising campaigns, leaflets or events – You coordinate your regulated campaign activity with another campaigner – for example, if you agree that you should each cover particular areas, arguments or voters – Another campaigner can approve or has significant influence over your leaflets, websites, or other campaign activity Electoral Commission guidance:
  45. 45. What do you have to do if you register? • Have a system in place for authorising spending on regulated campaign activity (must be the ‘responsible person’ or people authorised by him/her in writing) • Keep invoices or receipts for payments over £200 made as part of your spending on regulated activity • Report to the Electoral Commission on spending on regulated activity over £10,000 in Wales/Scotland/Northern Ireland or £20,000 in England • Check that you can accept any donations you receive that are over £500 towards your regulated campaign activity, and keep a record of them • Comply with the reporting requirements for donations you receive for spending on regulated campaign activity
  46. 46. Donations (if you are registered) Only ‘relevant donations’ are regulated Value over £500 (can include commercial value of things given for free or at non-commercial rate) • Only ‘permissible donors’ can give donations for regulated spending – must take all reasonable steps to check donor is permissible: – detailed rules, but, excludes UK political parties and foreign people/entities • Can be a criminal offence to accept a donation that isn’t permissible, e.g. from someone not on electoral roll Reporting • Total donations over £500 MUST be reported in post-poll returns • Donations over £7,500 MUST be reported during pre-election polling periods and after the election, including: (a) The amount donated (b) The date donation received (c) Information relating to identity of the donor
  47. 47. Imprints • Under PPERA, an imprint must be included in hard copy election material printed/distributed at any time (not just in a regulated period) • Must include name and address of: – the printer of the material – the promoter (the person who has authorised the printing) – any organisation the promoter is acting on behalf of • Rules do not legally apply to electronic election materials, e.g. web pages and emails (yet – Government due to change this). But, Electoral Commission says good practice to include imprint on electronic material • E.g. of imprint: Printed by Leaflet Distribution Network, 145-157 St. John Street, London. Promoted by [Suhan Rajkumar] on behalf of [Bates Wells], both of [10 Queen Street Place, London].
  48. 48. Carry on campaigning: some reassurance Campaigning, advocacy and political activity are all legitimate and valuable activities for charities to undertake. Many charities have strong links to their beneficiaries, and more generally to their local communities, commanding high levels of public trust and confidence, and representing a myriad of diverse causes. Because of this, they are uniquely placed to campaign and advocate on behalf of their beneficiaries.” The Charity Commission “Civil society has a long and proud tradition of campaigning for change and providing voice for the disempowered and disadvantaged in society… The government is determined that charities and social enterprises should be fully confident in their right to speak in public debates, and to have a strong campaigning and advocacy role.” Department for Digital, Culture, Media and Sport
  49. 49. Electoral Commission - To register or not to register? Decide whether to register or not • Review your plans • Involve your Board Minimise spend on regulated activity • Use volunteer time Put necessary procedures in place for monitoring decisions and spending • Familiarise yourself with the rules • Review plans and seek advice • Internal training • Update sign-off procedures • Set up recording system • Keep management teams and board updated Limit regulated activity • Focus on behind the scenes political work • Engage with your ‘committed supporters’ • Only send press releases to newspapers and broadcast media • Interviews in newspapers and broadcast media If you don’t want to register… If you decide to register… In either case… Register • Register early • Nominate responsible person • Monitor and track spend • Keep invoices
  50. 50. Sign off procedure Activity recorded in spreadsheet Send to Policy Manager to approve Policy/election material and advocacy activity (including tweets, blogs, press stories on website, newsletters etc.) If issue is borderline get sign off from Policy Director for approval Once decision made policy advisor to confirm reasoning via email Call/email Electoral Commission if further information needed
  51. 51. Recording system REGULATION LOG Activity number Activity Name Activity Description Bond only or Joint (B/J) Name of campaign or group (if joint) Public test (Y/N/M) Purpose test (Y/N/M) Legal advice sought? (Y/N) Regulated (Y/N/M) Rationale for decision Expected cost Actual cost Decision signed off by Example Manifesto scorecards Publish and share scorecards that rank manifesto commitments on aid J Aid campaign Y Y N Y Scorecards will be shared on social media so would pass public test. They compare manifesto commitments so would pass purpose test. £ 2,000.00 Director NON STAFF COSTS Activity number Activity name Cost description PIN Regulated activity (Y/N) Joint activity (Y/N) Cost (£) Example Manifesto scorecards Design PIN0001 Y Y £500.00 Example Manifesto scorecards Printing PIN0001 Y Y £100.00 STAFF COSTS Activity Number Activity name Bond staff Regulated (Y/N) Joint (Y/N) Staff hours on activity Total staff time Total staff costs (completed by GM)17-23 April 24-30 April 1-7 May 8-14 May Example Manifesto scorecards Public Affairs Manager Y Y 0 1 2 2 5 Example Manifesto scorecards Policy Adviser Y Y 0 0 4 1 5
  52. 52. Questions?
  53. 53. We use the word ‘partner’ to refer to a member of the LLP or an employee or consultant with equivalent standing and qualifications. Thank you
  54. 54. Contact us Simon Steeden Partner 020 7551 7782 s.steeden@bateswells.co.uk Suhan Rajkumar Associate 020 7551 7718 s.rajkumar@bateswells.co.uk
  55. 55. GET IN TOUCH • NCVO guidance: https://knowhow.ncvo.org.uk/ • Contact: douglas.dowell@ncvo.org.uk
  56. 56. Contact us Suhan Rajkumar Associate 020 7551 7718 s.rajkumar@bateswells.co.uk For further information Visit the Bond website: https://www.bond.org.uk/lobbying-act For templates or advice email: sfrier@bond.org.uk
  57. 57. Schedule: Local campaigning rules - RPA
  58. 58. The Representation of the People Act 1983 (RPA) • Regulates administration of elections, rules for candidates and their agents, general criminal electoral offences such as bribery, and local campaigns – e.g. constituency level campaigns • At a general election, no expenses can be incurred over £700 “with a view to promoting or procuring the election of a candidate” (which will also include seeking to restrict a candidate/party from being elected) • After the candidate becomes a candidate – generally after dissolution of Parliament in a snap election campaign • By any person other than the candidate, their agent and persons authorised in writing by the agent • On regulated activities
  59. 59. What activities are regulated under the RPA? • Regulated activities under the RPA include: – holding public meetings or organising any public display; – issuing advertisements, circulars or publications; or – otherwise presenting to the electors the candidate or his views or the extent or nature of his backing or disparaging another candidate (a broad test); • Regulated activities do not include: – The publication of any matter relating to an election in a newspaper or periodical or in a broadcast by the BBC or other licenses broadcasters – Travel expenses – Any amount not exceeding £700 “not incurred in pursuance of a plan suggested or concerted with others” – similar to the joint spending rules under PPERA (covered later)

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