Dear Ms Edwards, Following the Sunday Telegraph article which raised fresh concerns of coordination between Remain campaigns, I am writing to you to provide additional evidence of how these campaigns had a ‘common plan’ over the production and distribution of the ‘Don’t F**k My Future’ videos in question. I am encouraged that, in response to the article, you stated you will ‘consider [the allegations] in line with [y]our enforcement policy.’ Given the importance of the issue and the need for this to be looked into in detail, I have gathered together evidence to aid you in your investigation and to make clear how this coordination was in breach of electoral rules. The statutory framework As you will be well aware, Electoral Commission rules state that if campaigns are working together and have a ‘common plan’, they are subject to ‘joint campaign rules’. This means that, if one of the campaigns is a designated organisation – in this case Britain Stronger in Europe – the cost of the campaign counts towards the designated organisation only. Indeed, Electoral Commission guidance dictates that ‘you are very likely to be working together if you have joint advertising campaigns, leaflets or events’ (Electoral Commission link). This rule ensures that designated campaigns cannot outsource the costs of the advertisement to another campaign in order to circumvent its spending limit. Coordination of production and distribution of the advertising campaign Having looked through the documents on the Electoral Commission’s website, I note that, according to Adam & Eve/DDB’s returns, producing these advertisements cost in excess of £76,000. However, only one campaign – Wake Up And Vote – ever paid an invoice to DDB for producing the videos, and only for £24,000 (link). The remainder of the cost appears to have been funded by a mixture of payments and donations from other campaigns and major Remain donors. Wake Up And Vote Directly invoiced by ‘Adam and Eve’. Asked to pay £24,000 for the video (link) Wake Up And Vote received the entirety of their funding (£100,000) from Lisbet Rausing, one of the main donors to Britain Stronger in Europe and Conservatives IN (link) Britain Stronger in Europe Gave £7,467 to DDB on 1 June for ‘advertising’, but this was declared as notional expenditure with ‘Adam & Eve’, so no invoice or further details were provided (link). This means it is unclear what precise advertising it is for We Are Europe We Are Europe Gave £10,000 to DDB on 29 June but did not declare any joint spending (link) Received the majority of its funding from two of Britain Stronger in Europe’s main donors, Lord Sainsbury (£116,000) and Ian Taylor (£99,000) Britain Stronger in Europe, Wake Up And Vote, We Are Europe, and DDB were all registered as independent campaigners in their own right but none declared this as joint spending. Despite only one campaign paying an invoice for the advertisements and registering this with the Electoral Commission, multiple campaigns were reported to be involved in producing the videos: 14th June – it was reported that the ads were made for We Are Europe (link, link) 14th June – in an interview with the co-founder of ‘We Are Europe’, it was reported that the videos are a ‘collaboration between agencies adam&eveDDB and Kin&Co, alongside campaign groups Wake up & Vote and We Are Europe’ (link) 15th June – it was reported that the ad was made for Britain Stronger In Europe (link) 24th June – it was reported that the ads were made for We are EU (presumably ‘We are Europe’) (link) Britain Stronger in Europe, Wake Up And Vote, We Are Europe, and DDB all distributed these videos widely on social media. And despite not reporting any payments towards the cost of the video, Britain Stronger in Europe hosted the advert on its website (link), with no branding added to suggest that it was not an official Britain Stronger in Europe video. It is important to note that the video on the website was not ‘shared’ (which might be seen as in keeping with the rules), but was actually hosted. This means that Britain Stronger in Europe were provided with a service which they then made use of in their advertising. To anyone visiting their website, it would have appeared that the video was produced by Britain Stronger in Europe for their campaign purposes. This is a clear breach of the spending rules. This goes further than any accusations levelled at Vote Leave about having a ‘common plan’ for campaign activity. This provides demonstrable evidence that Remain campaigns colluded in producing adverts with a ‘common plan’, and in doing so avoided the cost of the project being included in Britain Stronger in Europe’s spending. Questions over the creation of Wake Up And Vote There are legitimate questions over the reasons behind the establishment of Wake Up And Vote, and the subsequent funding it received. It registered with the Electoral Commission as a permitted participant on 24 May 2016, less than one month before the referendum. It received a sole donation of £100,000, despite having no unique campaign messaging or evidence of prior campaigning in the referendum – surely a prerequisite for being given such a large donation. The donor was Lisbet Rausing, who also gave money to Britain Stronger in Europe and Conservatives IN. This begs the questions of how Ms Rausing found out about Wake Up And Vote, what persuaded her to donate such a large sum to a campaign with no distinct message, and indeed whether Ms Rausing was in fact directed to give money to Wake Up And Vote by senior figures within the official Remain campaign as it was close to its spending limit. Close connections between Britain Stronger in Europe and Wake Up And Vote are evident elsewhere. The same senior DDB production staff were employed for Don’t Fuck My Future (link) as for Britain Stronger in Europe’s launch video (link), namely Ben Priest (chief creative officer) and executive creative directors Ben Tollet and Richard Brim. Again, this evidence of coordination between campaigns goes a long way further than claims made against Vote Leave, of which the Electoral Commission is currently investigating. Not only did Remain campaigns use the same supplier, but this supplier was itself a registered permitted participant. It’s important to stress that it cannot be said that the adverts for which Wake Up And Vote contributed to financially were politically neutral, and thereby might not count towards Britain Stronger in Europe’s spending limit. A number of those who took part in the adverts (link) also signed a letter (link) – organised by Britain Stronger in Europe – calling on the UK to stay in the EU, including Keira Knightley, Laura Bailey, Dame Vivienne Westwood and Jessie Ware. Professor Stephen Hawking appeared in one of Britain Stronger in Europe’s official TV adverts (link), whilst former darts player Bobby George wore a Britain Stronger in Europe t-shirt in his short video (link). Further links between Britain Stronger in Europe and smaller Remain campaigns The establishment of Wake Up And Vote so close to referendum day was by no means unique, nor are its close ties with Britain Stronger in Europe. As detailed in my previous correspondence with you, four other Remain campaigns registered as permitted participants in the last month of the campaign: Best for Our Future Ltd, DDB UK Ltd, Proud Robinson Ltd and Virgin Management Ltd. These campaigns received hundreds of thousands of pounds in donations from figures who had previously donated money to Britain Stronger in Europe and other Remain campaigns. It is remarkable that close to £1 million was donated to these organisations which had no prior record of campaigning in the referendum and had no distinct message from the official Remain campaign. Indeed, much of this money was spent on advertising, yet there is no evidence that they had unique messages which sought to target a different audience to Britain Stronger in Europe. It is therefore wholly reasonable to believe that these campaigns were set up for the sole purpose of Britain Stronger in Europe evading its spending limit, with a ‘common plan’ in both their messaging and audience. Conclusion As this evidence reveals, there is clear reason to believe that Britain Stronger in Europe avoided breaching its spending limits by channeling funds through smaller Remain campaigns which were set up less than a month before the referendum vote. These campaigns received donations for figures who were known to Britain Stronger in Europe, shared advertising agencies, promoted each other’s adverts and exhibited no clear difference in their messaging – all evident indications of a ‘common plan’. All this evidence is far more serious than the accusations made at Vote Leave. I again implore you to show equity. You must either open an investigation into Britain Stronger in Europe, or – if you believe that the material detailed above is not evidence of a ‘common plan’, you should end the investigation into Vote Leave. I look forward to hearing from you. Yours sincerely, Rt Hon Priti Patel Member of Parliament for Witham