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House of Commons

Public Administration
and Constitutional Affairs
Committee

Appointment of the
Commissioner for
Public Appointments
Seventh Report of Session 201516

HC 869

House of Commons
Public Administration
and Constitutional Affairs
Committee

Appointment of the
Commissioner for
Public Appointments
Seventh Report of Session 201516
Report, together with formal minutes
relating to the report
Ordered by the House of Commons to be printed
12 April 2016

HC 869

Published on 14 April 2016


by authority of the House of Commons

The Public Administration and Constitutional Affairs Committee


The Public Administration and Constitutional Affairs Committee
is appointed by the House of Commons to examine the reports of
the Parliamentary Commissioner for Administration and the Health
Service Commissioner for England, which are laid before this House,
and matters in connection therewith; to consider matters relating to
the quality and standards of administration provided by civil service
departments, and other matters relating to the civil service; and to
consider constitutional affairs.
Current membership

Mr Bernard Jenkin MP (Conservative, Harwich and North Essex) (Chair)

Ronnie Cowan MP (Scottish National Party, Inverclyde)

Oliver Dowden MP (Conservative, Hertsmere)

Paul Flynn MP (Labour, Newport West)

Rt Hon Cheryl Gillan MP (Conservative, Chesham and Amersham)

Kate Hoey MP (Labour, Vauxhall)

Kelvin Hopkins MP (Labour, Luton North)

Rt Hon David Jones MP (Conservative, Clwyd West)

Gerald Jones MP (Labour, Merthyr Tydfil and Rhymney)

Tom Tugendhat MP (Conservative, Tonbridge and Malling)

Mr Andrew Turner MP (Conservative, Isle of Wight)

Powers

The Committee is one of the departmental select committees, the


powers of which are set out in House of Commons Standing Orders,
principally in SO No 146. These are available on the internet via
www.parliament.uk.
Publication

Committee reports are published on the Committees website at


www.parliament.uk/pacac and in print by Order of the House.
Evidence relating to this report is published on the relevant
inquiry page of the Committees website.
Committee staff

The current staff of the Committee are: Dr Rebecca Davies (Clerk);

Ms Rhiannon Hollis (Clerk); James Harrison (Second Clerk); Dr Adam

Evans (Committee Specialist); Dr Henry Midgley; (Committee Specialist);

Ms Penny McLean (Committee Specialist); Rebecca Usden (Committee

Specialist); Natalie Howard (Hansard Scholar); Ana Ferreira (Senior

Committee Assistant); Iwona Hankin (Committee Assistant);

and Mr Alex Paterson (Media Officer).

Contacts

All correspondence should be addressed to the Clerk of the Public


Administration and Constitutional Affairs Committee, House of
Commons, London SW1A 0AA. The telephone number for general
enquiries is 020 7219 2107/2995, the Committees email address is
pacac@parliament.uk.

Appointment of the Commissioner for Public Appointments

Contents

Appointment of the Commissioner for Public Appointments

Separating the posts of Commissioner for Public Appointments and First Civil Service

Commissioner
3

Recruitment Process

Role and criteria

Mr Riddell, the Governments preferred candidate

Appointing the Commissioner for Public Appointments, post-Grimstone

Conclusions and recommendations

Appendix 1: Letter from the Minister for the Cabinet Office to the Chair of

PACAC dated 14 March 2016

Appendix 2: Annex attached to the letter from the Minister from the Cabinet

Office

Appendix 3: CV: Rt Hon Peter Riddell CBE

11

Formal Minutes

15

Witness

16

List of Reports from the Committee during the current Parliament

17

Appointment of the Commissioner for Public Appointments

1 Appointment of the Commissioner


for Public Appointments
Separating the posts of Commissioner for Public Appointments and
First Civil Service Commissioner
1. The post of Commissioner for Public Appointments was established in 1995,
following the recommendation of the Committee on Standards in Public Lifes first report
(the Nolan Report). The Nolan Report recommended the posts creation as a means
of enhancing public confidence in the public appointments process and the quality of
appointments made under it. The role of the Commissioner for Public Appointments is
set out in the Public Appointments Order in Council 2015. Since the post and office of the
Commissioner was established in 1995, there have been four Commissioners for Public
Appointments.
2. From 2011 to 2016, the post of Commissioner was held jointly with the role of
First Civil Service Commissioner, by Sir David Normington. However, with Sir David
Normingtons tenure coming to a close, the posts of First Civil Service Commissioner
and Commissioner for Public Appointments have been advertised separately. This was
the result of a recommendation made to Ministers by Sir Gerry Grimstone, prior to
the publication of his review of public appointments.1 As indicated by the recruitment
campaign for this post, the Commissioner will be expected to work with the Government
in implementing the Grimstone Reviews recommendations.
3. The Grimstone review was published in March 2015. Concerns have been raised
by the Committee for Standards in Public Life and the former Commissioner for Public
Appointments, Sir David Normington, about the cumulative effect of Grimstones
proposals.2 We remain concerned that the changes proposed by Grimstone, as
interpreted by the government, alongside other changes such as the introduction of
Enlarged Ministerial Offices, may be leading to an increasing politicisation of senior
public appointments and we will report on our inquiry into the Grimstone proposals
after the Code of Practice for Public Appointments and new Order-in-Council have
been published.

Recruitment Process
4. On 14 March the Minister for the Cabinet Office, Rt Hon Matthew Hancock MP
wrote to the Chair of PACAC informing the Committee that the Governments preferred
candidate for the post of Commissioner for Public Appointments was the Rt Hon Peter
Riddell CBE.
5. Mr Riddell was selected from an open recruitment process. The recruitment panel
consisted of John Manzoni, Chief Executive of the Civil Service and Permanent Secretary
for the Cabinet Office; Sue Gray, Director General, Propriety and Ethics; and Paul Kirby,
the independent panel member and non-executive member of the Cabinet Office Board.
1
2

Cabinet Office, Commissioner for Public Appointments: Candidate Brief and Job Specification, January 2016, p.3
Written Evidence from Sir David Normington and Committee for Standards in Public Life

Appointment of the Commissioner for Public Appointments

According to information on the recruitment process supplied by the Cabinet Office, a


total of 27 applications were received (11 female and 16 male candidates).3 Interviews were
held on 26 February and 1 March 2016.

Role and criteria


6.

The main responsibilities of the Commissioner are to:

Provide leadershippersonal and professionaland regulatory decision-making.


Raise the profile of public appointments and actively encourage a more diverse range
of candidates to apply.
Report annually on public appointments and publish occasional thematic reviews
with a view to informing good practice.
Provide an independent check and balance to help assure and maintain the integrity
of public appointments.
7. The application pack outlined the following as the skills and expertise that would be
required in the successful candidate:
Essential Criteria
The successful candidate will have:
Personal credibility and integrity to command the confidence of Ministers, senior
officials, Public Appointees and the public.
The ability to lead and to engage effectively with diverse and high profile stakeholders.
Excellent judgement and the ability to assimilate a range of evidence and perspectives.
An understanding of operating in a regulatory regime.
Desirable criteria

Experience of governance in the private, public or voluntary sectors.

Mr Riddell, the Governments preferred candidate


8. The preferred candidate, Rt Hon Peter Riddell CBE has had a long and distinguished
career in public life, including as a political journalist and assistant editor to The Times.
He has also been a Director (Chief Executive) of the Institute for Government, a former
independent reviewer of the Committee on Standards in Public Life and a former Chair
of the Hansard Society.
9. At a preliminary hearing on 21 March, we asked Mr Riddell about his vision for the
role, his views on the Grimstone review, and how he would go about implementing its
recommendations in collaboration with Ministers. However, following this preliminary
hearing with Mr Riddell, we remained concerned that we had not had the time required
3

See Appendix 2 of this report for more details of the recruitment process

Appointment of the Commissioner for Public Appointments

to undertake scrutiny of the Grimstone review. Sir Gerry Grimstone was appointed to
lead a review of the Commissioner for Public Appointments in March 2015, with the
expectation that this review would report by the summer.4 On 2 July 2015, the Minister
for the Cabinet Office and Paymaster General, Rt Hon Matthew Hancock MP announced
that the review would be published by the end of 2015.5 It was not until 11 March 2016 that
the Grimstone review finally reported and on 14 March, only three days after the reviews
publication, we were informed that Mr Riddell was the Governments preferred candidate
for the post of Commissioner.
10. Because of this timescale we had had no opportunity, by the time of Mr Riddells
appearance before the Committee on 21 March, to consider the Grimstone review. We
concluded that it would have been inappropriate for us to make a report on the Governments
preferred candidate which could have been interpreted as implying a judgement on the
Grimstone report. We have since issued a call for evidence on the Grimstone review and
intend to report on the implications of Sir Gerry Grimstones review in the near future,
but only after the Government has published its draft revised Code of Practice.
11. In light of these concerns, we therefore decided to hold a second pre-appointment
hearing with Mr Riddell, held on 12 April. At this hearing, we asked Mr Riddell further
questions on the Grimstone review and its implications for the Commissioner for Public
Appointments and to explain how he would safeguard the independence and influence of
the post of Commissioner, post-Grimstone. We also asked Mr Riddell to elaborate further
on his strategy to bolster public engagement in the appointments process, the quality and
diversity of applicants and how he would prevent the reforms proposed by Grimstone
resulting in excesses of Ministerial patronage in the appointments process.
12. Mr Riddell has had a long and distinguished career in journalism, as Chair of the
Hansard Society and most recently as Director of the Institute for Government. However,
we are concerned that Mr Riddell lacks experience of managing a large organisation
or of making appointments. Therefore, while PACAC endorses his appointment as the
Commissioner for Public Appointments, this endorsement is not unqualified. PACAC
will be closely monitoring how he works with Ministers to implement the Grimstone
reviews recommendations and how he responds to the recommendations PACAC will
make on the Grimstone review in due course. We intend to be a critical friend of Mr
Riddell as Commissioner for Public Appointments and will make use of our ability
to carry out follow-up scrutiny if necessary to make sure that our concerns are being
heard. We agree with Sir Gerry Grimstone that the role of Commissioner for Public
Appointments should be robust and authoritative and not be undermined.

Appointing the Commissioner for Public Appointments, postGrimstone


13. As we noted earlier in this report, the Commissioner for Public Appointments was
established in 1995 as a means of enhancing public confidence in the appointments process.
In the context of the changes to the appointments process outlined in the Grimstone
reviews report and the concerns that have arisen from these recommendations, PACAC
recommends that in future the appointment of the Commissioner should be subject to a
4
5

Review of the Office of the Commissioner for Public Appointments: Written Statement - HCWS448, 23 March 2015
Review of the Office of the Commissioner for Public Appointments: Written statement - HCWS82, 2 July 2015

Appointment of the Commissioner for Public Appointments

resolution of both Houses of Parliament, as is the case for the Chair of the UK Statistics
Authority and the Comptroller and Auditor General. Such a resolution would underline,
and act as a public reassurance of, the independence and status of the Commissioner
for Public Appointments. A similar procedure should apply for the post of First Civil
Service Commissioner.

Appointment of the Commissioner for Public Appointments

Conclusions and recommendations

Separating the posts of Commissioner for Public Appointments and


First Civil Service Commissioner
1.

We remain concerned that the changes proposed by Grimstone, as interpreted


by the government, alongside other changes such as the introduction of Enlarged
Ministerial Offices, may be leading to an increasing politicisation of senior public
appointments and we will report on our inquiry into the Grimstone proposals after
the Code of Practice for Public Appointments and new Order-in-Council have been
published. (Paragraph 3)
Mr Riddell, the Governments preferred candidate

2.

Mr Riddell has had a long and distinguished career in journalism, as Chair of the
Hansard Society and most recently as Director of the Institute for Government.
However, we are concerned that Mr Riddell lacks experience of managing a large
organisation or of making appointments. Therefore, while PACAC endorses his
appointment as the Commissioner for Public Appointments, this endorsement is
not unqualified. PACAC will be closely monitoring how he works with Ministers to
implement the Grimstone reviews recommendations and how he responds to the
recommendations PACAC will make on the Grimstone review in due course. We
intend to be a critical friend of Mr Riddell as Commissioner for Public Appointments
and will make use of our ability to carry out follow-up scrutiny if necessary to make
sure that our concerns are being heard. We agree with Sir Gerry Grimstone that the
role of Commissioner for Public Appointments should be robust and authoritative
and not be undermined. (Paragraph 12)
Appointing the Commissioner for Public Appointments, postGrimstone

3.

As we noted earlier in this report, the Commissioner for Public Appointments was
established in 1995 as a means of enhancing public confidence in the appointments
process. In the context of the changes to the appointments process outlined in
the Grimstone reviews report and the concerns that have arisen from these
recommendations, PACAC recommends that in future the appointment of the
Commissioner should be subject to a resolution of both Houses of Parliament, as
is the case for the Chair of the UK Statistics Authority and the Comptroller and
Auditor General. Such a resolution would underline, and act as a public reassurance
of, the independence and status of the Commissioner for Public Appointments. A
similar procedure should apply for the post of First Civil Service Commissioner.
(Paragraph 13)

Appointment of the Commissioner for Public Appointments

Appendix 1: Letter from the Minister for


the Cabinet Office to the Chair of PACAC
dated 14 March 2016
Chair of the Public Administration and Constitutional Affairs
Committee
As you will be aware, we have been working to identify and appoint a successor for Sir
David Normington to undertake the role of Commissioner for Public Appointments.
I am now pleased to put forward the Governments preferred candidate, Peter Riddell, for
pre-appointment scrutiny following a fair and open competition that was conducted in
line with the Commissioner for Public Appointments Code of Practice.
As you will be aware, Peter was previously political editor of The Times, a member of
the Gibson review and is currently Director of the Institute for Government. He has an
excellent understanding of the role and challenges ahead and is someone of gravitas,
integrity and independence.
All candidates were informed prior to appointment that the position is subject to scrutiny
by the Public Administration and Constitutional Affairs Select Committee.
Relevant information relating to the recruitment process is set out in the attached Annex.
Rt Hon Matthew Hancock MP, 14 March 2016

Appointment of the Commissioner for Public Appointments

Appendix 2: Annex attached to the letter


from the Minister from the Cabinet
Office
Commissioner for Public Appointments
The name of the Governments preferred candidate is Peter Riddell. His CV and declaration
of interests is attached.
Role and background
The Commissioner for Public Appointments regulates the processes by which Ministers
(including Welsh Ministers) make appointments to the boards of national and regional
public bodies. The role of the Commissioner was created in 1995 following the First Report
of the Committee on Standards in Public Life under the chairmanship of Lord Nolan. The
Commissioner is an independent office-holder, appointed by Her Majesty the Queen.
The new Commissioner has been recruited following a fair and open competition.
Although not an OCPA regulated role, the competition has been run in line with the
principles of the OCPA Code of Practice.
Recruitment Process
The post was advertised in the normal way on the Cabinet Office Public Appointments
website from January to February 2016, with remuneration of 56,000 per annum based
on a commitment of 2 days a week on average, and for a five-year-non-renewable term of
office.
The panel members were:
John ManzoniPanel ChairPermanent Secretary, Cabinet Office
Sue GrayDirector General Propriety and Ethics
Paul KirbyIndependent Panel Member and non-executive member of the Cabinet Office
Board
Candidates were asked to submit their CV and supporting letter setting out how they met
the essential criteria which was set out in the role specification:
Personal credibility and integrity to command the confidence of Ministers, senior
officials, Public Appointees and the public;
The ability to lead and to engage effectively with diverse and high profile stakeholders;
Excellent judgement and the ability to assimilate a range of evidence and perspectives;
and
An understanding of operating in a regulatory regime.

10

Appointment of the Commissioner for Public Appointments

There was also one desirable criteria experience of governance in the private, public or
voluntary sectors.
Sifting of applications
In total, 27 applications were received (eleven female and sixteen male). After longlisting
10 candidates, the panel agreed that 6 of these candidates presented strong evidence
against the full range of selection criteria and were invited for interview.
Final Interviews
Panel interviews were held on 26 February and 1 March.
Taking account of performance at interview, together with all the other evidence that had
been obtained, summaries of the panels views on each of the candidates were submitted
to the Minister for the Cabinet Office.

Appointment of the Commissioner for Public Appointments

11

Appendix 3: CV: Rt Hon Peter Riddell CBE


The Rt Hon Peter John Robert Riddell CBEborn 14 October, 1948, Torquay, Devon.
Married 1994, Avril, with one daughter. Emily, born 1996.
Education:
Dulwich College and Sidney Sussex College, Cambridge (BA, History and Economics,
MA)
Professional Career:
Financial Times197091, working as a financial, property, City columnist, economics
correspondent; political editor based at Westminster; US Editor and Washington
Bureau Chief.
The Timespolitical columnist and chief political commentator, September 1991 to
July 2010; from November 2008 to June 2010 performing these roles on a three day a
week basis.
Institute for GovernmentDirector (chief executive) since January 2012 and
previously Senior Fellow from November 2008 when I worked on a study of transitions
in government after general elections, and was closely involved as a participant in a
group advising the Cabinet Office on what became the draft Cabinet Manual. I also
co-authored a study on what makes an effective minister. Frequent public speeches
and appearances before select committees.
Member of privy counsellor inquiry into alleged UK involvement into detainees and
retention (the Gibson inquiry) from July 2010 until December 2011 (shortly before
the Government decided to wind down the inquiry because of legal problems and
continuing police inquiries).
Member of Parliamentary and Political Services Honours Committee from March
2012.
Independent reviewer of the future of the Committee on Standards in Public Life on
behalf of the Cabinet Office, September to December 2012 ( a triennial review under
the Public Bodies Act, 2010).
Regular appearances on radio and television current affairs programmes, notably as
one of the presenters of the Week in Westminster programme from the mid-1980s
until 2011 (apart from my time in the USA).
Appointed to the Privy CouncilJuly 2010.
Awarded a CBEJune 2012 for services to journalism and other public service.
Outside activities:
Treasurer from 1982 to 1984 of Maternity Alliance, a charity bringing together other
groups concerned with mothers and babies both pre and post-natal.

12

Appointment of the Commissioner for Public Appointments

Chair, from 2007 to 2012 of the Hansard Society, the leading, non-partisan, group
promoting understanding of Parliament, and a charity. This involved chairing both its
executive committee and its advisory council and supervising fund-raising activities.
I served on its council since 1994 and was joint vice chairman of its Commission on
Scrutiny.
Chair for five years up to 2005-06 of the advisory board of the Economic and Social
Research Councils five year devolution and constitutional change programme.
Joint chair of an independent commission on the impact of the changes to the electoral
system since 1997, and their possible implications for Westminster.
Chair of a working party on ways to broaden the selection of candidates for political
office which reported in 2002.
Member of the advisory board of what is now the Centre for Contemporary British
History at the Institute of Historical Research, University of London, from the mid
1990s until 2009, and, for four years, of the research advisory board of the Committee
on Standards in Public Life ( mainly advising on its polling and qualitative research).
Since the summer of 2009 I have been a Governor of my old school, Dulwich College,
and I serve on its education committee.
I have also been actively involved in talking to schools and colleges about political and
constitutional issues.
Visiting Professor of Political History at Queen Mary and Westfield College, London,
from 2000 until 2003.
Member of HFCE sub-panel on politics and international relations for REF exercise
(from 2010 until April 2012 when I resigned because of a conflict of interest, and time,
with my appointment as Director of the IfG).
Professional Awards:
Economic and Financial Journalist of the Year, 1980, Wincott Awards (received in
1981).
Political Journalist of the Year, the House Magazine, 1985.
Political Columnist of the Year, Political Studies Association, 2005

Channel Four Political Book of the Year, 2004 ( for Hug Them Close, see below)

Academic recognition:
Hon DLitt, University of Greenwich, 2001
Hon DLitt, University of Edinburgh, 2007
Fellow of the Royal Historical Society, 1998.
Honorary Fellow of the Political Studies Association, 2006.

Appointment of the Commissioner for Public Appointments

13

Honorary Fellow, Sidney Sussex College, Cambridge, 2005.


Academician of the Academy of Social Sciences, 2012.
One of the inaugural winners in 2010 of the British Academy Presidents Medal for
signal services to the cause of the humanities and social sciences.
Publications:
The Thatcher Government ( 1983, 2nd edition 1985)
The Thatcher Decade ( 1989, 2nd edition as The Thatcher Era and Its Legacy, 1991)
Honest Opportunism- the rise of the career politician ( 1993, 2nd edition 1996)
Parliament under Pressure ( 1998, 2nd edition as Parliament under Blair 2000)
Hug Them Close- Blair, Clinton, Bush and special relationship ( 2003, 2nd edition
2004)
The Unfulfilled Prime Minister- Tony Blairs quest for a legacy (2005, 2nd edition
2006).

In Defence of Politiciansin spite of themselves (2011).

In addition, I have written chapters for several books, including:


Public Sector Pay, in How Much are Public Servants Worth?, Edited by John Gretton
and Anthony Harrison. 1982
Cabinet and Parliament, in The Thatcher Effect, edited by Dennis Kavanagh and
Anthony Seldon, 1989
Ideology in Practice, in A Conservative Revolution?, edited by Andrew Adonis and
Tim Hames, 1994.
John Major and Parliament, in The Major Effect, edited by Dennis Kavanagh and
Anthony Seldon, 1994
Tony Blair as Prime Minister, in The Blair Effect, The Blair Government 19972001,
edited by Anthony Seldon, 2001
Margaret Thatcher, the Lady who Made the Weather, in The Political Legacy of
Margaret Thatcher, edited by Stanislao Pugliese, 2003
Parliament and the Media, in Parliament in the 21st Century, edited by Nicholas
Baldwin, 2005
Europe, in The Blair Effect, 2001-05, edited by Anthony Seldon, 2005.
What if Britain had joined the Common Market in 1957, in President Gore and other
things that never happened, edited by Duncan Brack, 2006.
Labours Conversion to Constitutional Reform, in Reinventing Britain, Constitutional
Change under New Labour, edited by Andrew McDonald, 2007

14

Appointment of the Commissioner for Public Appointments

A chapter on Gordon Browns first year in office in When Gordon Took the Helm,
edited by Michael Rush and Philip Giddings, 2008.
Media Pressures on Politics in Constitutional Futures Revisited, Britains Constitution
to 2020, edited by Robert Hazell, 2008.
Articles in a variety of learned journals, including Political Quarterly: the Journal of
Legislative Studies: Parliamentary Affairs; and Contemporary British History. Articles
on the media and politics in the British Journalism Review and elsewhere.

Appointment of the Commissioner for Public Appointments

15

Formal Minutes
Tuesday 12 April 2016
Members present:
Bernard Jenkin, in the Chair
Ronnie Cowan

Kelvin Hopkins

Oliver Dowden

Mr David Jones

Mr Paul Flynn

Tom Tugendhat

Mrs Cheryl Gillan

Mr Andrew Turner

Kate Hoey
Draft Report (Appointment of the Commissioner for Public Appointments), proposed by

the Chair, brought up and read.

Ordered, That the draft Report be read a second time, paragraph by paragraph.

Paragraphs 1 to 13 read and agreed to.

Resolved, That the Report be the Seventh Report of the Committee to the House.

Ordered, That the Chair make the Report to the House.

[Adjourned till Tuesday 19 April at 10.30am.

16

Appointment of the Commissioner for Public Appointments

Witness
The following witnesses gave evidence. Transcripts can be viewed on the inquiry publications
page of the Committees website.

Monday 21 March 2016


Rt Hon Peter Riddell CBE, preferred candidate for the Commissioner for
Public Appointments

Question number

152

Tuesday 12 April 2016


Rt Hon Peter Riddell CBE, preferred candidate for the Commissioner for
Public Appointments

53104

Appointment of the Commissioner for Public Appointments

17

List of Reports from the Committee


during the current Parliament
All publications from the Committee are available on the Committees website at
www.parliament.uk/pacac.

Session 201516
First Report

Follow-up to PHSO Report: Dying without


dignity

HC 432

Second Report

Appointment of the UKs delegation to the


Parliamentary Assembly of the Council of
Europe

HC 658

Third Report

The 2015 charity fundraising controversy:


lessons for trustees, the Charity Commission,
and regulators

HC 431

Fourth Report

The collapse of Kids Company: lessons for


charity trustees, professional firms, the Charity
Commission, and Whitehall

HC 433

Fifth Report

The Future of the Union, part one: English Votes


for English laws

HC 523

Sixth Report

Follow up to PHSO Report of an investigation


into a complaint about HS2 Ltd

HC 793

First Special Report Developing Civil Service Skills: a unified


approach: Government Response to the Public
Administration Select Committees Fourth
Report of Session 201415

HC 526

Second Special
Report

HC 725

Lessons for Civil Service impartiality for


the Scottish independence referendum:
Government Response to the Public
Administration Select Committees Fifth Report
of Session 201415

Third Special Report Follow-up to PHSO Report: Dying without


dignity: Government response to the
Committees First Report of Session 201516

HC 770

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