Page:Formal Complaints about the Conduct of The Right Honourable Dominic Raab MP, Deputy Prime Minister, Lord Chancellor, and Secretary of State for Justice.pdf/4

 10. A third formal complaint was made on 23 November 2022. It contained allegations about the conduct of the DPM at the Department for Exiting the European Union ("DExEU"), in his capacity as Secretary of State. I will refer to this complaint as the "DExEU Complaint". On 24 November 2022 the Prime Minister asked me, and I agreed, also to establish the specific facts surrounding this complaint, in line with the Terms of Reference. On 25 November 2022, the Government confirmed this publicly. On 5 December 2022 the Minister for the Cabinet Office provided an answer to a written Parliamentary question, stating that the Prime Minister had asked me to establish the specific facts surrounding the DExEU Complaint, in line with the Terms of Reference.

11. Between 25 November 2022 and 13 December 2022 five further formal complaints were made about the DPM's conduct at the Ministry of Justice, in his capacity as Lord Chancellor and Secretary of State. The Prime Minister asked me, and I agreed, to include these additional complaints as part of the investigation and in line with the Terms of Reference. This was publicly confirmed on 14 December 2022. For obvious reasons, I will refer to these complaints as the "MoJ Additional Complaints".

12. There are therefore eight formal complaints within the Terms of Reference: (1) the MoJ Group Complaint; (2) the FCDO Complaint; (3) the DExEU Complaint; and (4)-(8) the MoJ Additional Complaints. Any other number in this respect which appeared in media reporting was not correct.

13. I will refer for short to the MoJ Group Complaint and the MoJ Additional Complaints as the "MoJ Complaints". I will refer compendiously to the MoJ Complaints, the FCDO Complaint and the DExEU Complaint as "the Complaints".

14. All of the Complaints were treated, for the purpose of the investigation, as arising pursuant to the Ministerial Code. The relevant versions of the Ministerial Code, in force at the material times, were those issued by the then Prime Minister, Mrs May, in January 2018 and by the subsequent Prime Minister, Mr Johnson, in August 2019. So far as necessary, I explain below the nature and content of the Ministerial Code.

15. My role under the Terms of Reference has at all times been to investigate and establish the facts in relation to the Complaints. This has been an investigation into the specific facts surrounding the relevant allegations, rather than an inquiry into general matters