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Roy Alder CBE, Head of Executive Support
Medicines and Healthcare products Regulatory Agency
Market Towers, 1 Nine Elms Lane
London SW8 5NQ

25 June 2005


Dear Mr Alder,

I remain deeply concerned about the Agency's attitude and response to the Chairman's recreational interest in the stockmarket. As I've previously emphasised, the issue is not personal probity, though quality of leadership and personal judgment certainly comes into it.

The central issue here is to do with difference between justice being done, and being seen to be done. In this case, the guidance of the Legal Services Commission very much seems to apply

"Sometimes, although you may not consider there to be a risk that a set of circumstances would create a conflict of interest, an objective third party might perceive there to be such a risk. Such `apparent' conflicts of interest are also conflicts of interest and must be dealt with in the same manner as all others. Everyone must carefully consider how an objective third party might view the circumstances."

To the extent this does apply, it seems all the more disquieting when the Agency goes into `refute' mode, repeatedly finding that its own policies and actions have been above suspicion and reproach. This tendency has been underlined in recent correspondence with Professor Woods, and was also specifically referred to in the report of the House of Commons Health Committee.

In relation to the MHRA Chairman's recreational interest in the stockmarket, it does seem rather complacent for the Agency to rely on compliance with the relevant codes. They hardly seem sufficient: see annotations attached.

For the avoidance of doubt, I would like to see this matter referred for an authoritative third party opinion, perhaps to the Committee on Standards in Public Life. I would be quite happy to back off if you were prepared to undertake this and, because the sufficiency of the relevant codes is in question, that would seem the most appropriate course. I'd be grateful for your thoughts on this.

Yours sincerely,
Charles Medawar