Matter referred on 21 April 2022 (conduct of Rt Hon Boris Johnson): Final Report/Conclusions and recommendations

by House of Commons Committee of Privileges

Conclusions and recommendations

Gathering on 20 May 2020

1. We conclude that, on the basis of the evidence we have received, some senior No. 10 officials were concerned about the social nature of the 20 May 2020 gathering and were reluctant for it to go ahead. It is not clear whether those concerns were raised with Mr Johnson at the time. The social nature of the gathering was indicated by the high number of people invited, with some attendees from outside No. 10 as well as Mr Johnson’s wife (who we consider it is obvious cannot be described as an “absolutely necessary participant”), and the installation in the garden of trestle tables with alcohol available. There is evidence that the number of people in attendance increased during the time that Mr Johnson was at the gathering. (Paragraph 36)

2. We note that for the gathering to have been compliant with the Rules, it would have had to have been “essential” for work purposes. We do not consider that a social gathering held purely for the purpose of improving staff morale can be regarded as having been essential for work purposes. Moreover, as we set out in further detail below, we do not believe Mr Johnson would have advised the public that this was the case had he been asked this at the time. (Paragraph 37)

Gathering on 19 June 2020

3. We conclude that there is evidence that the gathering in the Cabinet Room to celebrate Mr Johnson’s birthday on 19 June 2020 was attended by at least 17 people other than Mr Johnson, including by individuals who were not his work colleagues, and that it was not socially distanced. We note that Mr Johnson did not explain why he believed the event was “reasonably necessary for work purposes” other than to say that it took place immediately before a work meeting, and that “it seemed to me […] perfectly proper” for officials to be “asked to come and wish me a happy birthday” which we do not regard as convincing. Mr Johnson was also unable to explain why he considered his wife and interior designer “absolutely necessary participants” in a work-related meeting. His assertion that the Prime Minister’s family are entitled to use every part of the building does not constitute an explanation. We note that the Metropolitan Police issued Mr Johnson a Fixed Penalty Notice in connection with this event. Mr Johnson accepts that his attendance was unlawful but states that he is not clear precisely how he committed an offence. We note that he had the right in law to decline to accept the FPN if he had wished to assert he had committed no offence, but that he chose not to do so. (Paragraph 48)

Gathering on 13 November 2020

4. We note that organisations across the UK were suffering severe staff morale pressures during the Covid pandemic; we do not consider that this in itself provided a licence for Mr Johnson’s conveniently flexible interpretation of the Rules on gatherings, or the Guidance on social distancing. We note that Mr Johnson equivocated when asked whether he would have condoned gatherings for this purpose in other organisations. In view of Mr Johnson’s repeated exhortations to the public to follow the Rules and Guidance, indicating the importance he attached to their being taken seriously, we do not believe that, if asked at the time whether unsocially distanced “leaving dos” to maintain staff morale were permitted under the Rules and Guidance in force at the time, he would have advised the British public that they were. We note that the fact that Fixed Penalty Notices were issued for this gathering supports the conclusion that such gatherings were, in fact, not permitted under the Rules then in force. (Paragraph 65)

5. We conclude that there is photographic evidence of Mr Johnson’s presence at an event on 13 November 2020 where there was no social distancing; that no mitigations are visible in the photographs; and that the Covid Rules and Guidance at the time did not allow a socially undistanced event to proceed purely for the purpose of maintaining staff morale, and that this would have been clear to Mr Johnson. (Paragraph 66)

Gathering on 27 November 2020

6. We conclude that Mr Johnson attended an impromptu event in the Press Office vestibule on 27 November 2020 at which there is evidence from some attendees that social distancing was not observed. One witness stated that there were “certainly more than 20” people in attendance. Another stated that Mr Johnson made a joke about the lack of social distancing. Mr Johnson draws attention to the Second Permanent Secretary’s conclusion that “15 to 20 people” were present. There is not a large gap between the two estimates and clearly no-one was taking an exact count of numbers. Even if it were at the lower estimate of 15, that was too many for social distancing of 1 metre, let alone 2 metres, in that space. We note further evidence that there was a large gathering of people in the vestibule, sufficient to make it difficult for a person to make their way through the room. (Paragraph 73)

7. Mr Johnson stated that he was in attendance for about 10 minutes. This would have afforded him opportunity to observe a large gathering of people in the relatively small space of the vestibule. We have received no evidence that significant mitigations or efforts to maintain social distancing were in place at the event. We have noted earlier (see paragraphs 37 and 66) our conclusion that no reasonable reading of the Covid Guidance at the time would have considered a socially undistanced event purely for the purpose of maintaining staff morale permissible. (Paragraph 74)

Gathering on 18 December 2020

8. Mr Johnson argues that he heard nothing from his flat, nor did he see anyone “detectably under the influence of alcohol”, but it is not claimed that he did. Mr Johnson asserts that he did not observe what was going on as he passed the entrance to the Press Office, because his “mind was decisively elsewhere” and “my attention is often elsewhere when I am returning to the flat”. This may have been the case, but it is in our view not a credible reason why he would not have observed the gathering. Given the evidence we have received that between 25 and 40 people attended the gathering, that drinking began at 5 pm and the event was “beyond desk drinks” and continued till “the early hours”, and that Mr Johnson walked past at 9.58 pm, given that the issue of Fixed Penalty Notices suggests the social (not work-related) nature of the event, for at least some time (and the evidence we have suggests that would be a significant proportion of the event), and given that we know from our own evidence that social distancing was not observed, we conclude that Mr Johnson is unlikely to have been unaware, as he returned to his flat, that a crowded gathering that was in breach of the Covid Rules and Guidance was taking place in the Press Office vestibule. We accept, however, that it is possible, though unlikely, that there was nothing untoward occurring in the vestibule at the time he ascended to the flat. (Paragraph 83)

Gathering on 14 January 2021

9. We note that some participants in the gathering received Fixed Penalty Notices. As we have commented earlier (see paragraphs 37 and 66), we do not consider that an event at this time was compliant with Covid Rules if the purpose of the event was purely to maintain staff morale. (Paragraph 94)

Gatherings: conclusions

10. We have set out and analysed evidence on six gatherings. This establishes that Mr Johnson had personal knowledge that should have led him, at least after due reflection and as gathering succeeded gathering, to question whether the Covid Rules and Guidance were being complied with. (Paragraph 109)

11. For several of the No. 10 gatherings, as we have detailed, Mr Johnson has argued that it did not occur to him that they were in breach of Rules or Guidance. This is despite the fact that he must have been aware of the number of people attending, of the absence of official work being done, and of the absence of social distancing without visible mitigations. In each case he argues that he genuinely believed the events were covered by a work-related exemption to the Rules. He also argues that efforts to socially distance and the putting in place of some mitigations where possible (albeit somewhere other than where the gatherings were taking place) were sufficient for compliance with the Guidance. (Paragraph 110)

12. With regard to the Rules: the gathering had to be essential or reasonably necessary for work purposes. A workplace ‘thank you’, leaving drink, birthday celebration or motivational event is obviously neither essential or reasonably necessary. Mr Johnson is adamant that he believed all of the events which he attended and of which he had direct knowledge were essential. That belief, which he continues to assert, has no reasonable basis in the Rules or on the facts. A reasonable person looking at the events and the Rules would not have the belief that Mr Johnson has professed. That is plain from the fact that around the UK during the period of pandemic restrictions these events did not take place. (Paragraph 111)

13. This point is reinforced by the exposure of the mock Downing Street press conference video which became public in December 2021. When asked about one of the gatherings we have examined, that of 18 December 2020, and more generally whether the Prime Minister would “condone having a Christmas party”, Mr Johnson’s then Press Secretary Allegra Stratton was unable to think of any credible response, and was evidently embarrassed. (Paragraph 112) 14. Five of the six events we have focussed on had the core purpose of thanking staff who had been working hard, or raising morale following the departure of staff. Mr Johnson, when asked whether he would have condoned gatherings for this purpose in other organisations, declined to say that he would. As we concluded in paragraphs 37 and 65 above, in view of Mr Johnson’s repeated exhortations to the public to follow the Rules and Guidance, indicating the importance he attached to their being taken seriously, we do not believe that, if asked at the time whether unsocially distanced “leaving dos” to maintain staff morale were permitted under the Rules and Guidance, he would have advised the British public that they were. (Paragraph 113)

15.In respect of the sixth event, the gathering to celebrate his birthday on 19 June 2020, while we have no reason to think that the meeting that followed this event was anything other than a necessary work meeting, Mr Johnson was unable to provide a convincing reason why this prior gathering was “reasonably necessary for work purposes”. (Paragraph 114)

16. With regard to the Guidance, there was no obvious social distancing at any of the events for which the Committee has photographs, and we have direct evidence about the lack of social distancing from witnesses. We have no evidence of substantive mitigations in place in the rooms or areas where the gatherings took place (save the 20 May 2020 gathering in the garden because it was open air). The mitigations described by Mr Johnson do not relate to the activities complained of. At best they are such marginal expedients as not touching pens or passing things to each other, except of course alcohol. (Paragraph 115)

17. Mr Johnson concedes that social distancing was not possible at these events but maintains the Guidance was complied with “completely”. That is not correct. Mr Johnson refers to social distancing of less than 2 metres as “imperfect” social distancing. This term is not in the Guidance. Without all possible efforts being made to redesign the event, to allow for social distancing of at least 1-metre with substantive mitigations, is non-compliance. This inability to maintain full social distancing would have brought into operation the clause in the Guidance relating to considering whether, in these circumstances, the event should take place at all. We conclude that Mr Johnson’s persistence in putting forward this unsustainable interpretation of the Guidance is both disingenuous and a retrospective contrivance to mislead the House and this Committee. (Paragraph 116)

18. We think it highly unlikely on the balance of probabilities that Mr Johnson, in the light of his cumulative direct personal experience of these events, and his familiarity with the Rules and Guidance as their most prominent public promoter, could have genuinely believed at the time of his statements to the House that the Rules or Guidance were being complied with. We think it just as unlikely he could have continued to believe this at the time of his evidence to our Committee. We conclude that when he told the House and this Committee that the Rules and Guidance were being complied with, his own knowledge was such that he deliberately misled the House and this Committee. (Paragraph 117)

What Mr Johnson was told by others, and what he told the House

19. The overall thrust of Mr Johnson’s evidence to the Committee has been to downplay the significance and narrow the scope of the assertions he made to the House. He has argued that (a) the assurances he referred to related only to one gathering, that on 18 December 2020, and were correct in relation to that gathering; (b) his assertions to the House relating to assurances about Covid compliance were only in respect of the Rules, not the Guidance; and (c) when he referred three times to having repeatedly been assured about compliance, by “repeatedly” he meant “on more than one occasion and by more than one person”. (Paragraph 180)

20. The problem with Mr Johnson’s attempts to portray his assertions to the House as narrow in scope is that this interpretation is directly at odds with the overall impression Members of the House, the media and the public received at the time from Mr Johnson’s responses at PMQs. The message which Mr Johnson clearly meant to convey was that Rules and Guidance at No. 10 had been complied with at all times. Indeed, Mr Johnson initially asserted that Guidance had been complied with when he had meant to say Rules, and rather than correcting what he now admits to have been an error, subsequently reiterated this assertion despite having been advised by his Principal Private Secretary not to make this claim. He was content to convey the impression that the events (plural) against which allegations had been made were in fact “non-events”, and, to paraphrase, that it was nonsense to suggest that the rule-makers at the heart of government were also rule-breakers. (Paragraph 181)

21. The impression the House would have taken, and we conclude, would have been intended to take, from Mr Johnson’s repeated references to assurances was that those assurances had been overarching and comprehensive, and to be given great weight. In fact, as we have seen, the only assurances that we can be certain were given to Mr Johnson were arrived at in haste based on a press “line to take”, were not subject to investigation before either session of PMQs, and did not emanate from senior permanent civil servants or government lawyers but from two media advisers and were based only on their personal recollections. Although Mr Johnson claimed several times to have been given the assurances “repeatedly”, in evidence to us he scaled down that claim by arguing that by “repeatedly” he had meant “on more than one occasion” (so possibly only twice). (Paragraph 182)

22. Mr Johnson’s attempt in his evidence to us to claim that his assertions at PMQs were narrow in scope amounts to ex post facto justification and was clearly not the message he intended to convey at the time. As an ex post facto justification, it is false. Mr Johnson’s failure to seek adequate assurances has also to be seen in the context of his direct personal experience of non-compliance with Covid Rules and Guidance at a series of gatherings which he attended or was aware of, as detailed earlier in this report. (Paragraph 183)

Misleading the House

23. Using the categories of misleading set out in paragraph 32 of the Fourth Report, we conclude that:

1. Mr Johnson misled the House when he said on 1 December 2021 that all Guidance was followed completely in No. 10, when he said on 8 December 2021 that the Rules and Guidance were followed at all times, on 12 January 2022 when he said that events at No. 10 were within the Rules and Guidance, and on 25 May 2022 when he said that the Rules and Guidance had been followed at all times when he was present at gatherings to wish staff farewell. See paragraph 117.
2. Mr Johnson misled the House when he failed to tell the House about his own knowledge of the gatherings where the Rules or Guidance had been broken. See paragraphs 23 to 94.
3. Mr Johnson misled the House when he said on 8 December 2021 that he relied upon repeated assurances that the rules had not been broken. There is evidence that Mr Johnson was assured by two individuals who had worked at No. 10 at the time that they did not think the gathering of 18 December 2020 had broken Covid rules—see paragraphs 136 to 144, and 176. However, we conclude that:
   1. Mr Johnson had personal knowledge about gatherings which he should have disclosed. See paragraphs 23 to 94.
   2. Mr Johnson concedes that there was no assurance about any gathering’s compliance with the guidance that was in place at the time (as opposed to compliance with the Covid rules), yet Mr Johnson gave the House the impression that those assurances had been overarching and comprehensive in respect of No. 10’s compliance with all Covid measures. See paragraphs 144, 146, 161, and 180 to 183.
   3. The purported assurances were only about the gathering of 18 December 2020, not more generally about No. 10’s compliance with the Rules and Guidance, yet Mr Johnson gave the House the impression that those assurances had been overarching and comprehensive in respect of No. 10’s compliance with Covid measures across the whole period of restrictions. In particular, we have received no evidence that any specific assurance was provided in relation to the gatherings of 20 May 2020, 19 June 2020, 13 November 2020, 27 November 2020 and 14 January 2021 which we have examined in detail. See paragraphs 145, and 180 to 183.
   4. The context for the initial purported assurance was in response to a media inquiry and the assertion that Covid rules were followed was initially developed in haste, and without further investigation, as a media line to take. They were therefore not appropriate for Mr Johnson to cite as an authoritative indication of No. 10’s compliance with Covid measures. See paragraphs 137 to 141.
   5. The only two purported assurances for which there is firm evidence did not emanate from senior permanent civil servants or government lawyers but from two media advisers, one of whom was a personal political appointment by Mr Johnson. The purported assurances consisted only of what those individuals themselves believed about the compliance of the gathering of 18 December 2020 with the Rules. They were therefore not appropriate to be cited as an authoritative indication of No. 10’s compliance with Covid measures. See paragraphs 139 to 144, 163 to 165, and 176 to 178.
4. Mr Johnson misled the House when he gave the impression that there needed to be an investigation by the Second Permanent Secretary to establish whether the rules and guidance had been broken before he could answer questions to the House. While repeatedly making that statement to the House, he had personal knowledge that he did not reveal. See paragraphs 23 to 94, and 127.
5. We additionally find that Mr Johnson misled the House when he purported to correct the record on 25 May 2022. We have concluded above that his statement on that date that the Covid Rules and Guidance were followed while he was in attendance at farewell gatherings at No. 10 was misleading. As such, it represented a continuation of his previous misleading of the House, and seeking to present it as a correction was itself misleading. His insistence on the truthfulness of this statement in his written evidence, and his refusal to correct the record when invited to do so during his oral evidence on 22 March 2023, is a further misleading. See paragraphs 131, and 187. (Paragraph 188)

24. We further conclude that Mr Johnson has been disingenuous with the Committee in ways which amount to misleading, as follows:

1. By adopting a narrow and restricted interpretation of the assertions he gave to the House in PMQs on 1 and 8 December 2021 which is at odds with the general impression he clearly wished to give in the House that all Rules and Guidance at No. 10 had been followed at all times. See paragraphs 180 to 183.
2. By claiming that when he referred to having been repeatedly assured, by “repeatedly” he had meant merely “on more than one occasion”. We note that this is contrary to common English usage. It is clear that when Mr Johnson used the term “repeatedly” at PMQs, he wished his audience to suppose that there had been multiple occasions at which assurances had been given, rather than merely more than one, and, as suggested by our evidence, possibly as few as two. See paragraph 134.
3. By undertaking to provide the Committee with the name of another person who had provided assurances, and then failing to do so. See paragraphs 167 to 169.
4. By stating at the oral evidence session that the Committee had withheld from publication “the evidence that I rely on, which answers the charges” and “a large number of extracts which I rely upon in my defence”, but then, when the Committee had facilitated the production of that evidence accompanied by statements of truth, failing to make any use of it in his subsequent final submission. This strongly suggests that Mr Johnson did not “rely on” the evidence at all but was simply using it as a gambit to criticise the Committee in the public hearing. See paragraph 220.
5. By advancing an unsustainable interpretation of Guidance in order that he can deny the implications of the evidence showing a lack of social distancing. See paragraphs 99 to 102, and 115 to 116.

6. By being unable to deny that he said the words “probably the most unsocially distanced gathering in the UK right now” while not admitting that he said them, which has the ring of avoidance about it. See paragraphs 68 to 69. (Paragraph 189)

Was it a contempt?

25. We have given very careful consideration to the question of whether Mr Johnson misled the House recklessly or intentionally. He himself told us that:

I am here to say to you, hand on heart, that I did not lie to the House. When those statements were made, they were made in good faith, and on the basis of what I honestly knew and believed at the time. (Paragraph 198)

26. Mr Johnson argues that whether or not the Covid Rules and Guidance were breached at gatherings he attended, or was aware of, at No. 10 (and he continues to maintain in the case of the six gatherings we investigated that they were not breached), he himself, along with many others at No. 10, genuinely believed they were complying with the Rules and Guidance. (Paragraph 199)

27. To a great extent this defence depends on whether Mr Johnson genuinely believed that the gatherings were work events that satisfied the criteria in the Rules that such events be (before June 2020) “essential for work purposes” or (from June 2020) “reasonably necessary for work purposes”, and the criteria in the Guidance that, if social distancing cannot be observed, such an event “needs to continue for the business [or organisation] to operate”. We have noted that Mr Johnson was not willing to say that, if asked, he would have advised the general public that work events intended solely to raise morale satisfied these criteria. We have set out, at paragraph 117 above, our conclusion that it is “unlikely on the balance of probabilities that Mr Johnson, in the light of his cumulative direct personal experience of these events, could have genuinely believed that the Rules or Guidance were being complied with”. (Paragraph 200)

28. We have also set out, in paragraphs 188 to 189 above, a list of ways in which we consider Mr Johnson has misled the House or been disingenuous in his responses to our inquiry. His personal knowledge of breaches of the rules and guidance, combined with his repeated failures pro-actively to investigate and seek authoritative assurances as to compliance issues, amount to a deliberate closing of his mind or at least reckless behaviour. We find it highly unlikely that Mr Johnson having given any reflection to these matters could himself have believed the assertions he made to the House at the time when he was making them, still less that he could continue to believe them to this day. Someone who is repeatedly reckless and continues to deny that which is patent is a person whose conduct is sufficient to demonstrate intent. Many aspects of Mr Johnson’s defence are not credible: taken together, they form sufficient basis for a conclusion that he intended to mislead. (Paragraph 201)

29. We conclude that in deliberately misleading the House Mr Johnson committed a serious contempt. (Paragraph 202)

Recommended sanction

30. We have concluded above that in deliberately misleading the House Mr Johnson committed a serious contempt. The contempt was all the more serious because it was committed by the Prime Minister, the most senior member of the government. There is no precedent for a Prime Minister having been found to have deliberately misled the House. He misled the House on an issue of the greatest importance to the House and to the public, and did so repeatedly. He declined our invitation to reconsider his assertions that what he said to the House was truthful. His defence to the allegation that he misled was an ex post facto justification and no more than an artifice. He misled the Committee in the presentation of his evidence. (Paragraph 210)

31. Having taken into account the factors set out above, we considered what sanction would be appropriate in this case. We unanimously concluded that the minimum sanction we should recommend to the House should be suspension from the service of the House sufficient to engage the provisions of the Recall of MPs Act. (Paragraph 211)

32. In agreeing to recommend that sanction, we took into account that this case will set a precedent for the standards of accountability and honesty that the House expects of Ministers. We have no doubt that Parliament and the public expect the bar to be set high and for there to be serious consequences if a Minister, as in this case, impedes or obstructs the functioning of the House by deliberately misleading it. (Paragraph 212)

33. Having reached this provisional conclusion as to the recommended sanction, we then followed the procedure we had set out in our procedure resolution, and communicated to Mr Johnson the Committee’s proposal to recommend a sanction of suspension for a period long enough to engage the provisions of the Recall of MPs Act, inviting his comments. This material was sent to Mr Johnson under conditions of strict confidentiality. We set out the events that followed, and our view of their implications for sanctioning Mr Johnson, in the next section of this report. (Paragraph 213)

Mr Johnson’s resignation as an MP and his attack upon the Committee

34. We note that Mr Johnson does not merely criticise the fairness of the Committee’s procedures; he also attacks in very strong, indeed vitriolic, terms the integrity, honesty and honour of its members. He stated that the Committee had “forced him out […] anti-democratically”. This attack on a committee carrying out its remit from the democratically elected House itself amounts to an attack on our democratic institutions. We consider that these statements are completely unacceptable. In our view this conduct, together with the egregious breach of confidentiality, is a serious further contempt. (Paragraph 222)

35. Notwithstanding his protestations of respect for the Committee, and his earlier deprecation of language such as “kangaroo courts” and “witch hunts”, we note that in his statement of 9 June Mr Johnson himself used precisely those abusive terms to describe the Committee. This leaves us in no doubt that he was insincere in his attempts to distance himself from the campaign of abuse and intimidation of committee members. This in our view constitutes a further significant contempt. (Paragraph 224)

36. On 12 June 2023 at 11.57 pm Mr Johnson’s lawyers delivered to the Committee a further purported response to our warning letter of 8 June. We have considered its contents even though we are not obliged to do so. The response was not accompanied by a statement of truth from Mr Johnson. The response makes a series of tendentious accusations. The document is reproduced in full at Annex 3 together with our comments on each paragraph. (Paragraph 226)

37. Before his latest purported submission we had decided to treat Mr Johnson’s public statement made on 9 June in response to our warning letter as his response to that letter and his last submissions to this inquiry. We note that on 9 June Mr Johnson stated that “[i]t is in no one’s interest […] that the process the Committee has launched should continue for a single day further.” We agree with Mr Johnson’s view on that point. (Paragraph 227)

38. Contrary to Mr Johnson’s assertions, he has been given multiple opportunities to set out his views and to comment on the evidence in the inquiry:

• We set out in detail the evidence and the issues to be raised with him in our Fourth Report published on 3 March 2023.
• We disclosed to Mr Johnson in unredacted form all the evidence we proposed to rely upon and the identity of all our witnesses.
• At the start of the inquiry, in July 2022, Mr Johnson was invited to make an initial submission in writing concerning the allegations and to identify any witnesses that he believed could give relevant evidence. He did not make such a submission or identify any witnesses.
• Mr Johnson was invited to give oral evidence and publish a written statement, which he did and was questioned about the evidence and issues raised in the Fourth Report.
• Mr Johnson was invited to make final submissions in the inquiry and did so.
• Mr Johnson was sent details of our proposed criticisms of him, and the evidence supporting them, on 8 June 2022, and invited to respond.
• None of the evidence which we relied on in the material sent to Mr Johnson on 8 June was new to Mr Johnson. It was the same as that which was put to him in the Fourth Report and in the oral evidence session. He had the opportunity to respond to that in oral evidence and by written submission and he did.
• In his oral evidence Mr Johnson accused the Committee of suppressing evidence which would be helpful to him. We invited him to identify any such evidence. The Committee obtained that evidence from the witnesses he had indicated, supported by statements of truth. In the event he placed no reliance on it. The clear implication is that there was nothing in the evidence and his criticism in public was a cynical attempt to manipulate Member and public opinion. (Paragraph 228)

39. Our final conclusion is in relation to sanction. Although Mr Johnson’s resignation as an MP renders it impossible for a sanction of suspension to be imposed, we draw attention to the fact that before the events of Friday 9 June we had provisionally agreed to recommend a suspension long enough to engage the provisions of the Recall of MPs Act. In the light of Mr Johnson’s further contempts, we put on record that if he had not resigned his seat, we would have recommended that he be suspended from the service of the House for 90 days for repeated contempts and for seeking to undermine the parliamentary process, by:

• Deliberately misleading the House
• Deliberately misleading the Committee
• Breaching confidence
• Impugning the Committee and thereby undermining the democratic process of the House
• Being complicit in the campaign of abuse and attempted intimidation of the Committee

In view of the fact that Mr Johnson is no longer a Member, we recommend that he should not be granted a former Member’s pass. (Paragraph 229)