From: Bob Posner Sent: 05 January 2018 17:40 To: Andy O'Neill; Louise Edwards; John Franks;- Cc: Subject: Scotland in'Union query I spoke by telephone with Pamela Nash. In summary: . PN commenced by referring to information stolen from their organisation and the police were considering. I said we were not seeking this apparently stolen information from those organisations who might have received it, but would be writing to her organisation to establish whether they had complied with the rules as a MPG and I hoped that they would be able to satisfy us in that regard. . PN considers we should have responded to her email today and that our media line today is misleading. . I explained that we were not obliged to provide an advice service by immediate response, but in the context of this matter as statutory regulator we were considering the issues consistent with our enforcement Policy, and as indicated would be writing to her organisation next week. Our reply would take into account and address the points PN had raised in her email as part of that. . Also that our media line is not misleading, it is in fact accurate, irrespective of her concern on how some elements of the media might choose to report matters. I also said nevertheless in view of her concern we would reflect on this sort of standard media line, but I thought it was right in view of our role as regulator and I trusted PN would respect that we have to proceed consistent with our Enforcement Policy process. . I also corrected her assertion that we had been pro-actively speaking to the media, explaining that our Comms Team had simply responded to media query received, with what is a brief standard type line. . PN thought we should apologise for not responding to her email and our media line. I said I could not see that was appropriate as we are doing ourjob as regulator in a normal way. PN said she might or would complain further. I said we have a complaints process. I said that I respected her concerns, but I doubted I would be able to allay them from her perspective. I said we were not responsible for how the media accurately or otherwise report matters. . The line went dead at PNs end of the line. PN sent an email to James saying her line had failed and could I ring back. I did twice, but got voicemail twice. I left a message I had called back. Bob. From: Sent: 05 Janua 2018 17:30 To: Subject: FW: FW: In Confidence Hi Pamela, Bob tried to call back a couple of times but couldn?t get through. He's left for the day now. Kind refards, From:? Sent: 05 January 2018 17:08 To: ?Pamela Nash' Subject: RE: FW: In Con?dence Hi Pamela, what's the best number for you and he?ll call you again From: Pamela Nash Sent: 05 Janua 2018 17:04 Tad Subject: Re: FW: In Con?dence Dear James I have just been Speaking to your director Bob, but the call appears to have been cutoff. I do not have a number for him or an email address to contact him again, but I would appreciate if you would let him know that he can call me to discuss this further, but if not I will be in touch with the Electoral Commission. Kind regards Pamela Pamela Vash Chief Executh 0 Scotland in Union tut scotlandmunloncouk t: ascotlandmumon scotlandinunion Scotland in Union look forward to elcoming you to our Burns Night in Glasgow on 2nd February 2017, get 3 our tickets here! This email. together with any attached ?les. is con?dential and for the sole use of the i not the intended recipient (or responsible ior delivery of this e-mail to the intended recipient) - please contact us immediately on and delete this e-mail. you should not copy. [onward or use it nor disclose its contents to any other person. If you are not the intended recipient you are noti?ed that disclosing. copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. Internet communications are capable of data corruption. Scotland in Union accept no responsibility for changes made to this e-mail after it was sent. Neither Scotland in Union nor the Individual sender accept any liability or responsibility ior viruses It is your responsibility to this e-mail and any attachments and otherwise take precautions to check for and protect against viruses Dear Pamela, Thank you for your email, I understand you have also telephoned. To con?rm, we are reviewing your questions and will respond to your queries in due course. Kind regards. Senior Financial Reporting Adviser The Electoral Commission 3 Bunhill Row London 8Y2 electoralcommissionorq.uk v0urvotematters.co.uk Twitter Facebook Bloq Sent: 05 Januai 2 To: Subject: In Con?dence I understand that you have previously advised our Executive Director on our registration requirements. I would be grateful if you con?rm the following points: 2 . The dates during which it is required that non-party campaigners report their donations over a certain value for the General Election 2017 (I understand this to be 3rd May 2017 to 8th June 2017). . The exact threshold of donation to be reported to the Electoral Commission during the election period (I understand this is over ?7500, donations of ?7500 and under do not need to be reported). I would be grateful if you could also clarify the rules around successful auctions bids at fundraising events for non-party campaigners. We have not received any in the reporting periods, but I am interested to know how they should be recorded (is the whole bid considered a donation by the Electoral Commission or should costs of the event where the auction is taking place and the cost of the prize be removed) If the auction item is donated, are both the value of the donation and the success?il bid considered donations? Thank you for your advice. Best wishes Pamela Pamela Vash Chief Fweutive Scotland in Union a u.scotland1numon.w.uk t: 61 scotlandmumon seotlandinunion Scotland in Lnion look forward to welcoming you to our Burns Night in Glasgow on 2nd February 2017. get your tickets here! This email. together with any attached ?les. is con?dential and for the sole use of the not the intended recipient (or responsible for delivery of this e-mail to the intended recipient) - please contact us immediater and delete this e-mail: you should not copy. forward or use it nor disclose its contents to any other person It you are not the names l'EClplenl you are noti?ed that disclosing copying distributing or taking any action in reliance on the contents of this inlomiation is strictly prohibited. Internet communications are capable of data corruption Scotland in Union accept no responsibility for changes made to this email after it was sent. Neither Scotland in Union nor the individual sender accept any liability or responsibiEity for viruses. It is your responsibility to scan this email and any attachments and otherwise take precautions to check for and protect against viruses Page 1 of 7 - Please see attached, which I hope all makes sense, and is in order! 1. XML submission. 2. Detailed workings, which consist of an updated version of the salary return (?rst tab) and then apportionment of each month?s salary allocation to the relevant categories, thus giving the totals which appear in the XML submission. As you can see, because the team's duties overlap considerably, I think the best way to make a fair estimate has been to do the initial gross allocation at the individual level, then sum the total for the month, and then consider which the key regulated activities were in that month in order to allocate to categories. I believe this is now as fair and comprehensive an estimate which I can make, and hope that it ?ts the bill. Please do get back to me if you have any questions or clari?cations, othenvise thank you in advance for doing the upload, as it's certainly helped me to be able to use the XML. Many thanks Alastair Good morning Alastair The spreadsheet you provided entitled salary return GE2017 corrected' is suf?cient evidence of your workings. We will of course redact personal information before publication. regards to the actual return, if you would rather use the XML spreadsheet that we provided that is not a problem. I con?rm that we will delete the single-line entry and upload the new items of expenditure to PEF Online on your behalf. In answer to your ?rst question, you should use the relevant category (is. Canvassing or Market Research) in Column C, as you have entered in under Example 1. Please do not enter Staff and Overheads in Column C. I hope this helps. Please let us know if you have any further questions. Best Regards Financial Reporting Adviser The Electoral Commission 3 Bunhiil Row London EC1Y 8Y2 yourvotemalterscouk 0830132018 Page 2 of 7 Twitter ?cebook Slot: From: Alastair Cameron Sent: 04 September 2017 18:34 To: Cc: Subject: Re: UK Parliamentary General Election 2017 spending return Thanks -(and -with whom I recently discussed this too) I'd arrived at the previous total by considering what proportion of each staff member's time could be reasonablv said to be on activities which could be construed to pass purpose] public tests. For example, for I?d estimated 50% of his time should be declared, as much of his role is on social me ia, contacting vo unteers and running stalls etc, and for our Press Of?cer I'd put the same, as much of his work is public (but he also writes newsletters and has other duties, so de?nitely not 100%). I can now try to re-estimate based on categories and then each staff member per category, but it will be only an estimate as with a small team people's roles do overlap somewhat, and unlike a political party quite a lot of our activity doesn't pass public or purpose tests. I think I understand the ask below more clearly now, though - for (say) 'Events? I will have to consider what proportion of each staff member's time should be allocated that month. I think I will need to produce a data table of month] staff member] category,i amount, which would also be the detailed breakdown you need, and then do a pivot table (month/ category] amount) and copy the totals by category into the return. This still feels pretty onerous, particularly compared to the requirement for Scottish Parliament Election 2016, but on the assumption that everyone's having to do it, and that it provides a useful degree of transparency, of course we will comply. I would rather use the spreadsheet, I think, thanks, as otherwise it's more laborious entering into PEF, and also I won't be able to check whether it matches overall, so I'll do that. I think my only remaining questions therefore are: 1. Whether in Column I should be using the Category (see Example 1 in attached), or using 'Staff and Overheads' in Column and noting the category in Column {see Example 2 in attached); and 2. To con?rm that someone will delete the single-line entry which is in our return currently, and upload the data in the submission spreadsheet instead. Many thanks Alastair Dear Alastair. .5 away just now, so am picking this up. I appreciate this is additional admin that you hadn't anticipated. Both-nd myself will be available throughout this week to help you if needed. don?t hesitate to contact us if we can be of assistance. 0830112018 Page 3 of 7 On the return. you should have an item for staff costs where relevant against each category transport. election material etc. In this case. the supplier?s name would be the organisation's name. you do not need to do a line on the return for each individual and they will not be named when we publish the return. As you must do a statement of all individual payments. it follows that each payroll will be a payment made. if there was regulated activity during that month. It may well be that there was not regulated activity in each month. in which case you needn't put an item. So you are correct. there is a maximum of 12 5 items to add. In reality. this may not be this many. In terms of a breakdown. if you can then provide to us in a spreadsheet or email. a demonstration of your workings. so that will include a breakdown of your costs by staff member. We will redact personal information before publishing. Our IT team are checking if your return can be re-opened on PEF Online. Alternatively. you can enter the items into the spreadsheet attached and we will merge this into your return on your behalf. which may be the easier option. Kind regards. Senior Financial Reporting Adviser The Electoral Commission 3 Bunhill Row London EC1Y BYZ 020 7271 0506 electoralcommISSIonorq uk vourvotemattersco uk Twitter Facebook I Blog Sent: 29 August 2017 21m: To: PEF Inbox Subject: RE: UK Parliamentary General Election 2017 spending return Thanks for this. I'll do my best by 8th September, but please note that I submitted a return very and have only just had your note below. :20] 8 Page 4 of 7 I won't be in a position to log into PEF until 5th September, so I am a bit concerned about response times encounter any issues and need to ask any further questions. Therefore, please can you con?rm in advance: 1. Do I need to enter this in PEF as one entry per month (so 12 entries, as the period covers 12 months)? (Rather than just emailing to you, for example.) 2. Is SIU's return now re-opened in PEF, Le. not showing as submitted? If so, do I need to delete the original item and then add the 12 new items? 3. When I go into PEF online have I understood correctiy that for each entry, I need a breakdown by staff member (?ve or so) and by category (?ve or so), so that for each month there wilt be c25 lines in a spreadsheet] pdf, and thus 12 25 (total 300) lines of data in total? I'm just asking this because it seems a pretty major admin burden for a small organisation, but that's what it seems to imply in your emails below. Thanks Alastair On 24 Aug 2017 4:53 pm, Inbox"?wrote: HI Alastair Thanks for your email. Non-party campaigners that spent below ?250,000 on regulated activity must submit a complete return no later than Friday 8 September 2017. so you should aim to provide the requested information to us by that date. Please note that for the payment dates. you should be able to use the payroll dates. You must enter each separate payroll date as a separate individual payment on PEF Online i e. one each for April 2017, May 2017 etc A spreadsheet or a PDF of the breakdowns is suf?cient, one each per payroll date. Once agam. please get back in touch if you have any further questions Best Regards Financial Reporting Adviser 08f01f2018 Page 5 of 7 The Electoral Commission 3 Bunhill Row London EC1Y BYZ yourvotematterscouk Twitter Facebook Blog From: Alastair Cameron? Sent: 23 August 2017 0 :51 To: PEF Inbox Subject: Re: UK Parliamentary General Election 2017 spending return Hello Sorry, I missed that requirement - I think last time we did a return, it wasn't needed. I can do this estimated breakdown by staff member and category, but I am currently on holiday in France without my PC. I hope it's OK to do this on my return, probably 10th] 11th September (I return on 5th September but will be straight back to my paid work)? Also, can I just provide you with a spreadsheet] document of the breakdown? Thanks Alastair On 22 Aug 2017 6:13 pm, Inbox" ?wrote: Dear Mr Cameron Thank you for submitting the spending return for Scotland in Union on PEF Online. I note that you have entered staff costs of 227,532.06 under reference SP0320338 but have not provided documentary evidence for this item of expenditure of over ?200. Please refer to the following for guidance on submitting staff costs. You are required to report staf?ng costs in respect of relevant categories. We ask that you make an honest and reasonable assessment of the amount of staff time. and therefore costs. attributable to each category. So. in each category - say. events you will have an item for staff costs. and again for election material etc. In the return you do not need to break down each individual staff member as a supplier. as we will not publish this anyway for data protection reasons. 8 Page 6 of 7 For evidence. we do not require staff paystips. A statement detailing the name of each staff member and your calculations on the time they spent on regulated activity will suf?ce. For example: Staff Total regulated spend Category Name of person 1 210.000 Travel Nil Events ?5.000 Eiection material ?5,000 Etc Etc We will always redact information which can identify an individual's identity as part of our process prior to publication. We will stitl publish the totals you submit next to each category and the totals which appear on the evidence you provide. Please do not redact any information yourself. We will apply the redactions prior to publication. When you submit your return. please include the totals (for relevant staff) against each category. which we will publish- For the payment dates. you should be able to use the payroll dates (I presume they are all the same for all staff). I hdpe that is clear. but don't hesitate to contact us furthetr if you have any queries. Best regards Financial Reporting Adviser The Electoral Commission 3 Bunhill Row London 8Y2 orq.uk yourvctematters co.uk Twitter Facebook Blog 08/01/2018 Page 7 of 7 Alastair Cameron Scotland In Union Scotland In Union is registered in Scotland, Number 492324. Alastair Cameron Scotland In Union . IUI..U Please come to one of our fundraisinq dinners - in Edinburgh on Thursday 26th October 2017, and in London on Wednesday 15th November 2017,r and support our campaign, making the positive case for Scotland in the UK. Scotland In Union is registered in Scotland, Number 492324. 08.301 #20 8 E-mail: RE: Spending return Page 1 of 4 E-mail RE: Spending return Sent Date 10/08/2017 09:57 Subject RE: Spending return Phew. Funny that I couldn't see it myself, but maybe I was looking under the wrong entry too, or perhaps I can?t access it once it?s been submitted but not yet published? Anyway, as you have con?rmed it's submitted successfully, I'll relax now! Thanks Alastair Dear Mr Cameron. Thank you for your email. I can now confirm the Scotland in Union return for the 201? UKPGE has been submitted on PEF Online. Please accept my apologies for the confusion - I had accidentally looked at the previous regulated entity pro?le for Scotland in Union (registered 26 January 2015 to 06 May 2016) rather than the current one (registered 26 May 2017). Thanks again, Financial Reporting Of?cer The Electoral Commission 3 Bunhill Row London EC1Y 8Y2 electoralcommissronorg uk yourvotematterscouk Twitter! Facebook Blog 08f01f2018 E-mail: RE: Spending return Page 2 of 4 IE From= Alastair cammu? Sent: 07 August 2017 22:16 To: Cc: Subject: Re: Spending return Hello -and .51 know Is on leave) I am confused and concerned by this. I knowl submitted an expenditure return, and I received an acknowledgement email and saved all the details. 1 have fonrvarded the confirmation email to you eparately. and will now forward to -s well. and I attach here the details which I downloaded after receivmg con?rmation. However, I have this evening logged back into PEFonline, and it shows as 'in progress' with no details submitted at all. It would appear that the PEF database has lost all the information I entered, which took many hours of painstaking work. Please could someone look into this as a matter of urgency. and check the situation around the time on 16th July when I completed and submitted my return (having repeatedly saved along the way)? I presume there is Some kind of edit or version history which would enable this investigation. and that the information can be recovered. I look forward to hearing from you urgently. Thank you Alastair Cameron On 7 August 2017 at 09:32. Mette Christensen ?wrote: Dear Alastair Thank you for your query to the Electoral Commission regarding submitting the spending return for Scotland in Union for the UK Parliamentary general election. 1i 08i01i2018 E-mail: RE: Spending return Page 3 of 4 I have checked with colleagues. who has informed me that your return is 'in progress', which means that you will need to log back in to PEP oniins and click ?submit' to complete the submission. If you need anything further then please let me know. Kind regards Senior Adviser Elections and Campaigners The Electoral Commission Lothian Chambers 59-63 George IV Bridge Edinburgh EH11 RN Tel Mo Fa Twitter Facebook Blog Alastair Cameron Scotland In UniOn uk Scotland In Uniori is registered in Scotland. Number 492324. Regarding Scotland In Union From: PEF Inbox Sent: 03 August 2017 16:42 To: PEF Inbox Subject: Action required: Reporting requirements following the UK Parliamentary General Election Attachments: XML Third Party Campaign Expenditurexls Dear Responsible Person, I am writing to explain your spending and donations reporting responsibilities as a registered non- party campaigner following the UK Parliamentary General Election on 8 June 2017. Do I need to complete a spending return? You must complete a spending return if you spent above the registration threshold on regulated activity in any part of the UK during the regulated period that ran from 9 June 2016 to 8 June 2017. This is ?20,000 in England, or ?10,000 in either Scotland, Wales or Northern Ireland. If you did not spend above this threshold, you do not need to complete a full spending return, but should let us know by return email that this is the case and the amount you spent. If you did spend above any of the registration thresholds, you must report your spending and donations to us in full. The deadlines for this are as follows: - If you spent ?250,000 or below on regulated activity, you must submit your spending return not later than Friday 8 September 2017 - If you spent more than ?250,000 on regulated activity, you must submit your spending return not later than Friday 8 December 2017. You must also have your return audited and submit an auditor's report alongside the return It is a legal requirement to submit a complete return and all relevant invoices or receipts for individual payments over ?200. If you do not submit your return by the statutory deadline, you will be liable for enforcement action, in line with the Commission?s published Enforcement Policy. How do I complete my return? There are three methods by which you can complete the return: . on paper, one form each for spending (form I explanatory notes) and donations (form exolanatorv notes) . using our online database PEF Online 0 XML spreadsheet attached (for spending only. You should use PEF Online or the paper form to submit donations) For shorter returns, you may ?nd it easier to use the paper form or enter the data line by line into PEF Online yourself. For ease and particularly for larger returns, we recommend you use the XML spreadsheet to capture your spending, and return it to us to manage uploading it into the PEF Online system on your behalf. Please note our emaii system cannot accept messages larger than 10MB. If this is going to be an issue, please contact us to discuss alternatives. What does my return need to include? Your return must include: A statement of alt payments made, inciuding payments, notional expenditure, unpaid expenses and disputed claims - Invoices for payments over ?200 . A donation report, including details of: c. all impermissible donations all accepted donations over ?7,500 :3 all accepted donations that add up to over ?7,500 from the same donor :3 the total of all other accepted donations that were worth more than ?500 and less than or equal to ?7,500. You do not need to provide details of these donations but just the total ?gure Audit report if your regulated spending exceeds ?250,000 . A declaration by the responsible person (see wording below) Declaration I declare that have examined the information in this return and that, to the best of my knowledge and belief, it is a complete and correct return as required by law, and that all expenses shown in it as paid have been paid by me or by a person authorised under section 90 of the Political Parties, Elections and Referendums Act 2000. Submitted by the responsible person. Signed.- Printed Name: Date.- What resources are available to help? We have produced a suite of guidance documents on the rules that apply to non-party campaigners, and on how to complete your papenrvork. We are here to help, so if on reading the documents, you have further questions, please don't hesitate to contact us on 0333 103 1928 or E-mail: Re: Registering after lapse - Scotland In Union Page 1 of 3 E-mail Re: Registering after Sent Date 26/05/2017 23:20 E-mail From Alastair Cameron Cc Subject Re: Registering after lapse - Scotland In Union Thanks-and for your help on the phone earlier today. Notwithstanding recent email conversation in which I have indicated that we believe we do not need to register, I have now registered SIU as new as discussed. so that we can complete a post-poll expenditure report for the relevant activities as discussed with- Thanks for your help. Alastair Alastair. Thank you for our conversation today. I can con?rm that you need to create a new entity in PEF Online. in our conversation you said that you were going to do the application this evening. As Monday is a bank holiday I will review your application on Tuesday and confirm receipt with you. Regards Senior Adviser - Registration The Electoral Commission 3 Bunhill Row London, EC1Y BYZ Tel: Fax: sec .orJ my aboutmvvo'e to uk Putting voters first E-mail: Re: Registering after lapse - Scotland In Union Page 2 of 3 IE English_Logo_Landscape_RG You can now register to vote online Follow us on Twitter Like us on Facebook Read our Blog Sent: ay To: 1 Subject: FW: Registering after lapse - Scotland In Union We received this email from SM From: Alastair cameron Sent: 25 May 2017 23:34 To: PEF Inbox Cc: Subject: Registering after lapse - Scotland In Union Heiln I am the Responsible Person for Scotland In Union, a non-party campaign group- We have previously been registered via PEFonline. but deliberately let our registration lapse after the 2016 Scottish Parliament election. as at the time we intended taking no part in the Council elections in 2017 (and of course didn't know a General Election might be called). In correspondence with the Electoral Commission of?ce in Scotland, I believe we may now need to register again, but when I log into my PEFonline account 1 can't see how to re-activate registration. Please could you either tet me know what to do, or change the status of Scotland In Union to being registered rather than lapsed? Many thanks Alastair Cameron Alastair Cameron Scotland In Union 08f01i2018 E?mail: Re: Registering after lapse - Scotland In Union Wacotlandlnunionco uk Scotland In Union is registered in Scotland. Number 492324. Alastair Cameron Scotland In Union Scotland In Union is registered in Scotland, Number 492324. Regarding 2017-04-25 Campaign activities by Scotland in Union Keywords Duration Priority Nomal Due Category Sub-Category PEF Directorate Categories PEF Parent Category PEF Category Attachments -J E-Mail Attachments Activity Attachment Associated View File Name File Size {Bytes} image003.jpg selected) Status Reason Received Page 3 of 3 08.301 #2018 Page 1 of 2 Thank you,-- that's very helpful. We will take a look at this and discuss it at our Management Meeting on Monday, then decide how to proceed. We may need to come back for some clari?cations, which I hope will be OK. Regards Alastair Dear Mr Cameron Thank you for your enquiry on Wednesday regarding the rules for non-party campaigners at the forthcoming UKPGE. We have now published core guidance for NPCs, which you are able to ?nd here: campaiq mars/201 7-elections Once you have had a chance to read the guidance, then please get in touch if you have any further questions. Kind regards Senior Adviser Elections and Campaigners The Electoral Commission Lothian Chambers 59-63 George IV Bridge Edinburgh EH1 1 RN Tel: Mo Fax E-mail: Re: RE: W: Scotland in Union Page 1 of 15 E-mail Sent Date 11(05/2017 20:09 E-mail From Alastair Cameron Cc Subject Re: RE: FW: Scotland in Union Thank you, Mette. I will look forward to meeting you then. Kind regards Alastair Dear Alistair Thank you for your reply. Monday 19 June at 14:00 at our office would be fine. Kind regards Senior Adviser Elections and Campaigners The Electoral Commission Lothian Chambers 59-63 George IV Bridge Edinburgh EH11RN Tel: Mob Fax: yourvotemattersco uk Twitter Facebook Blog 08.301100] 8 E?mail: Re: RE: FW: Scotland in Union Page 2 of 15 EC GE English Email signature Sent: 05 June 2017 22:1 To: Cc: Graeme Pearson Subject: Re: RE: FW: Scotland in Union Thanks - I did wonder whether 9th June might have been a challenge! I?m keen that we don't delay our return, so was wondering whether Monday 19th might be possible (103m or 2pm)? If not. then perhaps Friday 23rd at 2.30pm? We have put in returns for Scottish Parliament 2016 and UKGE 2015 before. so I think we'd be OK. but just think it could be worth taking up your kind offer if possible. Many thanks Alastair Dear Alastair Thank you for your reply. Unfortunately. we will not be able to meet on Friday, due to post election work on that day. We would. however. be able to meet any time on 16. 23 or 27 June. Alternatively. if there is any date, which suits you better. then please let me know and I can suggest a suitable time. Kind regards 08l01l201 8 E-mail: Re: RE: FW: Scotland in Union Page 3 of 15 Senior Adviser Elections and Campaigners The Electoral Commission Lothian Chambers 59-63 George IV Bridge Edinburgh EH11RN Tel: Mo Fax electoralcommissionorg uk yourvotematterscouk Twitter Facebook Blog EC GE English Email signature Sent: 01 June 2017 22: 3 TO: CC: Graeme Pearson Subject: Re: RE: FW: Scotland in Union Thank you very much for this clari?cation; it's very helpful. I now understand we will have to go back through the whole period and determine which of our expenditure is on activities which pass the public and purpose tests, in order to submit our post-poll expenditure report. It seems ironic that we are going to have to report so much. when we deliberately stayed out of the local elections. and have done no campaigning for the UK general election, but at least we now know what we need to do, so that's very useful. While I think we have now clari?ed the main point which we were concerned with. which was the time period and the impact (or lack thereof) of us not participating since the GE was called, it is kind of you to offer to meet for advice, and I'd like to take that offer up if possible- I'm currently on in Edinburgh on certain days of the week, so the next E-mail: Re: RE: FW: Scotland in Union Page 4 of 15 opportunity for me would be on Friday 9th June; 3 could meet any time up to 10.30am. or between 2.30pm and 3.30pm. I imagine half an hour would be suf?cient? Do any of those times work for you. despite it being the day after the election itself? Many thanks Alastair Dear Alastair Thank you for your reply. [thought it might be helpful to clarify the section in the 'Overview of Regulated Non-Party Campaigning' guidance, which you cited in your email. That section would only apply in cases where a potitlcal party has changed their position on an issue that you are campaigning for, as the campaign previously would not have been for or against a political party, or particular categories of candidate, including campaigns on policies or issues closely associated with a particular party or category of candidates. It is our view that parties in Scotland do have a clear position on the issue that you have been campaigning for, and that they have maintained that position during your campaign. The rules for non-party campaigners would therefore apply to some of your previous campaign activities not because there has been a change in party policy. but because the rules for a UK Parliamentary election has changed the context of your campaign. Secondly, thank you for confirming that you intend to register with the Commission as a non-party campaigner, and I understand that you submitted an application on Friday. Once registered you will need to: - submit weekly pre-poll donation reports, which will start from the day that you register. The reporting dates are set out on our website here: campaigners - submit a spending return to the Commission within 3 months of the election if the regulated activity that you have undertaken amount to more than ?10,000. The Commission offers an advice and guidance service in order to support campaigners to comply with the rules. In that respect we would be happy to meet with you in the next few weeks to discuss your campaign activities in further detail. Do let me know if you would be interested in a meeting. If you have any further questions about the rules at this stage, then please let me know. Kind regards Senior Adviser Elections and Campaigners The Electoral Commission Lothian Chambers 08l01l201 8 E-mail: Re: RE: FW: Scotland in Union Page 5 of 15 59-63 George IV Bridge Edinburgh EH11RN Tel: Mob Fax: electoralcommissuonorg.uk yourvotematterscook Twitter Facebook Blog EC GE English Email signature Sent: 24 Ma 2017 23: To: Cc: Graeme Pearson Subject: Re: RE: FW: Scotland in Union Dear- Thank you for your guidance, below. on how Scotland In Union should consider registration for the UK General Election. -1as forwarded it on to me as the Director responsible, and because I have managed our registration and returns previously. Scotland In Union su5pended our public activity when the General Election was announced on 18 April 2017. We believe we are not required to report retrospectively, based on Page 16 of the Electoral Commission's 'Overview of Regulated Non-Party Campaigning' guidance: Sometimes, a political party may publicly adopt policies that you are already campaigning for. if your campaign was not previously regulated, your subsequent campaign activity is unlikely to become regulated campaign activity simply because a 0850192018 E-mail: Re: RE: FW: Scotland in Union Page 6 of 15 party has changed its position. However, it may become regulated campaign activity if, for example, you: - publicise the political party's support in your subsequent campaigning, or - alter or increase your campaigning activity on the policy as a result of their support. We betieve that our campaign for Scotland in the UK, and against a second referendum, falls under this description. As we have carried out no campaigning activity which is relevant to the General Election since the election was announced on 18 April 2017, we have nothing to report since then. We note, however, your highlighting of the Council elections period. SIU deliberately took no direct part in the Council election campaign. as we believe that the issue of the future of the UK Union should not be relevant to local elections. We did continue some of our own campaign activities during the period, without touching on matters of Local Government responsibility. That said, some people and organisations did appear to make the UK Union part of their Council campaigns, so I presume that is why the period is of particular interest to you. Thus, we think we need to consider the period between the start of the regulated period of the Council elections (which we are taking as being 22 March 2017, as the ?rst day a candidature could have be declared) and 18 April 2017, which was when the General Etection was announced and the point at which we suspended our campaign activities. We believe that our expenditure in this period on activity which could potentially be considered to pass the public and purpose tests will be under ?10,000 in total. (I believe it will consist of the costs of one newspaper advert of c?1,500, some staff time, some paid design work, and the costs of some lea?ets which we did give out during that period. but I need to contact our staff to con?rm this.) Notwithstanding our view that we therefore are likely to be under the threshold (subject to working out the exact amounts), in the interests of transparency and following your email, we will now register as a non-party campaign group, and we will declare in our post-poll expenditure return any of our activities which we believe pass the purpose and public tests between 22 March 2017 and 18 April 2017 (or indeed 8 June 2017). We hope that we have interpreted the various guidance correctly, and that we have correctly de?ned the period which would be of interest. Please could you let me know as soon as possible if there is anything in the rationale above which you believe means we have missed something? We are of course very keen to ensure that we comply with all relevant regulation and legislation. Many thanks, and I look forward to hearing from you. I will go ahead and register Scotland In Union using PEFonline tomorrow, Thursday 25 May 2017, and we will adopt the approach described above, unless you have any further points which you think might be relevant. Thank you again for your assistance. Kind regards Alastair Cameron 08i01x?201 8 E-mail: Re: RE: FW: Scotland in Union Page 7 of 15 Director Forwarded messa From: Date: 24 May 2017 3:26 pm. Subject: RE: FW: Scotland in Union To @scotlandinunion.co.uk> Cc: near- Thank you for your response. We note your comments regarding the retrospective period and would refer you to our guidance regarding spending before the UKPGE was announced. Our speci?c concerns relate to campaigning undertaken by yourselves just prior to and during the candidate regulated period of the Scottish council elections. We are aware that during this period. you . produced and distributed lea?ets I took out a newspaper advertisement. Please note that campaigning in and around the council elections for or against a particular party or category of candidates will count towards your spending, despite the fact that the UKPGE had not been called at that point. This spending will have been regulated if it meets the public and the purpose test. Please con?rm that you have speci?cally considered the application of the rules to these activities and confirm that the amount spent was below ?10,000 (the threshold for registering for spending in Scotland). in the event that the spending on these activities meets both tests and is over this amount, you must register with us. Registering will ensure that your spending is reported and therefore transparent, and that there is no risk of you committing any further offence. We are unlikely to consider enforcement action against non-party campaigners that have taken prompt steps to register, even if their regulated spending is in excess of the registration threshold. prior to the UKPGE being called. If you are not sure about whether spending is regulated. you should consider whether registering will remove the risk of your breaking the spending rules. We are happy to discuss this further. May we please have a response by cob Friday 26 May 2017. Kind regards Senior Adviser Elections and Campaigners The Electoral Commission Lothian Chambers 59-63 George IV Bridge 083018018 E-mail: Re: RE: FW: Scotland in Union Page 8 of 15 Edinburgh EH1 1 RN electoralcommission org le yourvotematters co.uk Twitter Facebook Blog EC GE English Email signature Fromm Sent: ay To: Subject: Re: FW: Scotland in Union Thanks for your email last week. Apologies for my delayed response - _o was working from home all last week. As you know, we are very conscientous about our activities and ensuring that we always do the right thing. Along with every other campaign group and charity, we obviously had no idea that a snap election would be called in May so it is somewhat a surprise to learn that the electoral campaign period can he backdated retrospectively. In light of your email, our CEO, Graeme Pearson held a discussion with the team and we do not currently identify activities coming within your remit. but we will review the earlier period of the year and will be in contact should that view change. I hope this answers your question. but do of course get in touch if not. All best wishes Please note my usual working hours are 9am-5pm Monday to Thursd 1y only. 08.90 1 ?201 8 E-mail: Re: RE: FW: Scotland in Union Page 9 of 15 Research and Events Manager Scotland In Union Scotland In Union is registered in Scotlandr Number 492324. Thank you for your email. and for making us aware of your campaign intentions. The regulated period for non-party campaigners at the 2017 UK Parliamentary General Election (UKPGE) began on 9 June 2016 and will end on polling day, 8 June 2017. This means that campaign activities that you have undertaken between 9 June 2016 and the date that you decided to stop campaigning could potentially be considered regulated activity, if they meet the purpose and the public test. During the UKPGE regulated period non-party campaigners are subject to limits on their spending on ?regulated campaign activity'. These limits and the activities that are considered regulated campaigning are set out in further detail in our guidance for non-party campaigners. which you are able to find here: As part of the Commission?s ongoing monitoring approach we have observed that you have undertaken a number of campaign activities during this period. and that these have intensi?ed in the last few months. You will therefore need to consider each of the activities that you have already undertaken in the context of what would be considered regulated campaign activity for the UKPGE or any of the other elections that were held during the regulated period. Once you have assessed whether you believe prior campaign activities undertaken during the regulated period could be considered regulated campaigning. then we would be grateful if you could confirm which activities you consider to be regulated (if any). and the cost of the activities that you consider regulated. Kind regards Senior Adviser Elections and Campaigners The Electoral Commission Lothian Chambers 59-63 George IV Bridge Edinburgh EH11RN Tel: Mo E-mail: Re: RE: FW: Scotland in Union Page 10 of 15 electoralcommissnonorg uk yourvotematters co.uk Twitter Facebook Blog EC GE English Email signature co and in Union Lovely to hear from you again! This is just a note to let you know we will not be campaigning in the general election (or council elections). and are going to take a step back until after June 8th. A note is going on our website today to inform people of our position. We are therefore not planning to register with the Electoral Commission. Please let me know if this is ok? I look forward to hearing back from you Please note my usual working hours are 9am-5pm Monday to Thursday only. Research and Events Manager Scotland In Union 08f01l2018 E-mail: Re: RE: FW: Scotland in Union Page 11 of 15 Scotland In Union is registered in Scotland, Number 492324- veal Thank you for your email. which has been forwarded to me for response. Non-party campaigners that intend to spent more than ?10,000 on regulated campaigning ahead of a UK Parliamentary general election. Scottish Parliamentary election. Welsh Assembly election or a Northern Irish Assembly election are required to register with the Electoral Commission. Any campaigner at a referendum who intends to spend more than the threshold set out in the referendum legislation would also need to register with the Commission. The next scheduled poll at which non-party campaigners may be required to register with the Commission would be the UK Parliamentary election in 2020. However, in the event that a referendum place before then, the detailed rules for campaigners would be set out in the referendum legislation and we would be happy to meet with you to discuss the rules once they have been agreed by the relevant parliament. If you need any further advice at this stage, then please let me know. Kind regards Senior Adviser Elections and Campaigners The Electoral Commission Lothian Chambers 59-63 George IV Bridge Edinburgh EH1 1 RN EC Scotland Email signature 08.301f2018 Email: Re: RE: FW: Scotland in Union Page 12 of 15 From Date: 6 March 2017 17:05:07 GMT To: Susan Bruce Cc: Andy O'Neill Subject: Re: Scotland in Union Dear Dame Susan Many thanks for your response. I will wait to hear back from you in due course. All best P-ease note my u5ual wor- hours are 9am 5pm Monday to Thursday only. Research and Events Manager Scotland In Union Scotland In Union is registered in Scotland, Number 492324. On 4 March 2017 at 00:12. Susan Bruce ?wrote: Thank you for your email. I am happy to arrange a follow up to your enquiry. I have copied in my colleague, Andy O'Neill who heads up the Scotland Of?ce of the Electoral Commission. I will discuss this with him to enable us to offer the most appropriate advice on registration. Either Andy or i will come back to you in early course. Your sincerely. Sue Bruce Dame Sue Bruce Electoral Commissioner, Scotland The Electoral Commission Lothian Chambers 59-63 George Bridge Edinburgh EH1 1RN Sent from my iPad 0n 2 Mar 2017, at 12:14, wrote: Dear Dame Susan 08.301920] 8 Email: Re: RE: FW: Scotland in Union Page 13 of 15 I am writing from pro-UK campaign group, Scotland in Union. We are a non-party organisation campaigning against another referendum and making the positive case for staying part of the UK. Our Chief Exec. Graeme Pearson, has indicated that he would value your advice going forward' ahead of any pressing need to seek it should things develop. We understand there is no need for us to register with the Electoral Commission ahead of the council elections as we have no involvement there. Graeme would be more than happy to come and discuss this face to face if that would be convenient to you, alternatively perhaps we could schedule a phone call? I look forward to hearing back from you Please note my usual working hours are 9am-5pm Monday to Thursday only. ulc- Scotland In Union is registered in Scotland. Number 492324. Alastair Cameron Scotland In Union Scotland In Union is registered in Scotland. Number 492324. Alastair Cameron Scotland In Union co.uk Scotland In Union is registered in Scotland. Number 492324. ?201 8