Would you be surprised if I told you that, almost six months on from her all-too-public appearance on ‘I’m a Celebrity Get Me Out of Here’, Nadine Dorries still hasn’t registered her income from appearing on the show with the House of Commons authorities?

In fact, according to the most recent edition of the House of Commons Register of Members’ Interests she hasn’t declared any outside interests or earnings since June 2012, although she did register a gift in kind from Conservative Home in October 2012, which consisted of a Conference Pass, accommodation and travel for last year’s Conservative Party Conference, valued at £700.

That’s a little odd isn’t?

Between August 2011 and May 2012, the Register of Members’ Interests shows that Dorries was paid:

– £1,900 by the Daily Mail for two articles published between August October 2011,

– £5,000 by the Mail on Sunday for articles published between January and May 2012,

– £1,440 by Hat Trick Productions for an appearance on Have I got News For You in May 2012,

– £300 by The Sun for articles published in May 2012,

– £300 by H Bauer Publishing for articles published in Bella Magazine in May 2012, and

– £3,000 by Conservative Home for a writing weekly column between January and May 2012.

However, since that last set of registrations in June 2012, Dorries has registered nothing whatsoever in terms of remunerated outside interest despite appearing on ‘I’m a Celebrity…”,  continuing to write a regular weekly column for Conservative Home and signing with a showbiz agent, ASM Damage, where her profile notes an appearance on Channel 5’s ‘The Wright Stuff’ in June 2012 which has also yet to make an appearance on her register entry.

To be clear about the rules regarding the Register of Interests, MPs are required to update their register entry with any new registrable interests, such as payments for work undertaken outside the House, within four weeks and although there are lower limits on some categories of interest below which registration is not required, so MPs don’t have to update the register every time they’re given tea and biscuits at a meeting, these limits do not apply to paid work, remunerated directorships or the provision of services to clients.

That being the case, how has Dorries managed to go almost six months without registering her payment for appearing on ‘I’m a Celebrity…’?

Well, there is one way in which Dorries could possibly avoid registering payments for media work as paid employment, which would be to set up a service company to receive the money on her behalf and then pay it on to her as an employee of that company, or via a remunerated directorship or perhaps even in the form of shareholder’s dividend. Ultimately she would still have to declare any such payments on the register but this would at least help to avoid disclosing exactly how much she’d been paid for specific gigs and, depending on how these payments are made, she would also be able to pay a bit less tax on her outside income than might otherwise have been the case had it been paid directly to her.

And sure enough, about a month before Dorries jetted off to the Australian jungle for a bite or two of ostrich cloaca (3 October 2012) records at Companies House show that Dorries was appointed as the sole director of a Staffordshire-based company called Averbrook Limited – well, Staffordshire-based in the sense that its registered office is an accountancy firm in Staffordshire.

Now this is where it gets interesting because Averbrook Limited is not a new company at all.

It was originally set up in May 1994 by three business consultants but was then taken over in November 1995 by an Andrew James Rayment, a former teacher with a somewhat intriguing commercial history if an article which appeared in TES in June 2011 is anything to go by:

In a special TES investigation, Chris Johnston reveals how private fortunes were made from a system developed with public money.

Bedfordshire could, in theory, be a wealthy council by now. After all, it was there that, back in the mid-1980s, the computer software was developed which now carries out the administrative drudgery in nine out of 10 school offices.

SIMS, the School Information Management System, is a multi-million pound business. But Bedfordshire no longer owns SIMS. Instead the software, the School Information Management System, is in the hands of education giants Capita, as are several of Bedfordshire’s former staff.

The episode has angered and baffled many in the county who can’t understand how a prize asset was apparently sold off so cheaply. But those most closely involved with SIMS say the fault lies with Bedfordshire which, like other public-sector bodies, has proved unable or unwilling to develop business.

So the story here is that in 1982/3, a teacher at a Bedfordshire school wrote a piece of software which generates computerised pupil reports and over the next 3-4 years the system was rolled out to all upper and high schools in the country on the back of funding provided by the local authority. However, in 1988, the council lost control of the project and, crucially, the software, to a company set up by its original author and three other Bedfordshire employees, including Andrew Rayment, who had previously been deputy head of a Bedfordshire School, and Geoffrey Wainwright, who’d been the council’s deputy Chief Education Officer.

According to the article, exactly how the council lost control of the system remains unclear, although it did receive around £1 million in cash somewhere along the line, plus another £1 million in income additional software and maintenance services. Six years later, the company that gained control of the system in 1988, sold the business on to Capita for a tidy profit, reported £10 million, with several former council employees who’d been involved in the project subsequently joining Capita.

Exactly what went on within Bedfordshire Council in the late 80s is anyone guess and, as should be obvious from the article, rather contested, but what it serves to establish is that Rayment is fairly wealthy man and also a man with connections. He was a member of Mid Bedfordshire District Council from 1995 to 2009, serving as Leader of the Council between 1999 and 2002, and in 2003 he was appointed High Sheriff of Bedfordshire.

As recently as August 201o, so far as I can confirm, Rayment was also the Chairman of Mid-Bedfordshire Conservative Association, although he appears to have retired from that position by the time that it filed its 2011 return with the Electoral Commission, as that document gives the Chairman’s name as Paul Duckett. Nevertheless with his background I would surprised if Rayment didn’t still wield a fair degree of influence within Dorries’ local CA.

Getting back to Averbrook, its financials show the company has been dormant since 2006 and that it hasn’t done any significant trading for a fair bit longer than that, with Rayment as its sole shareholder and Company Secretary, with a nominal holding of just £100, and his wife serving as its sole director. Or at least that was the case right up until end of March 2012 when Rayment’s wife suddenly stepped down as a Director with Rayment seemingly following her out the door, at least on paper, six weeks later, at which point its registered office and the position of Company Secretary were both transferred to an accountancy firm in Newcastle-under-Lyme.

And there it sat, until early October 2012 and Dorries’s appointment as a director, in which she her occupation as  “writer/commentator/TV Radio personality” (but not MP), all of which came on the same day that the accountancy firm resigned as Company Secretary.

What wasn’t at all clear at the time was whether or not Dorries, in addition to becoming the company’s sole director, had also acquired the company outright by taking over Rayment’s nominal shareholding but it seems that the answer to that question may lay in the company’s most recent filing with Companies House, on March 15 2013, which shows that Andrew Rayment was reappointed as a director of Averbrook Limited on 27th February 2013.

Mmm… curiouser and curiouser – and all the more so for the fact that despite becoming a director of a limited company which, on the face of it, would appear to be intended to operate as a vehicle for Dorries’ media work, Averbrook Limited also has yet to make an appearance on Dorries’ register of interests.

Now there are, of course, rules covering the registration of directorship and shareholdings. MPs are required to register any remunerated directorships, not matter how much remuneration they receive, and any directorships for which they are not individually remunerated but nevertheless receive payments for via another company in the same group. There also required to register an interest in any company in which they hold at least a 15% shareholding or any kind of shareholding if the value of their shares amounts to more than the current parliamentary salary, and this applies to not only to companies in which MPs have a direct beneficial interest but also those in in which a registrable shareholding is held in the name of an MPs partner, spouse or children.

So, if Dorries receives any kind of payment from Averbrook for media work that’s been routed through the company, as either an employee or as a director, or if she owns more than 15% of the shares in the company then it has to be registered with the House of Commons, which means either than she’s failed to register an interest in line with the rules or that she hasn’t received any payments from Averbrook and doesn’t own at least 15% of the company’s shares, which leads us back to the question of what, exactly, has happened to her appearance fee from ‘I’m a Celebrity…’?

After all, one would assume that the show’s production company will have paid up reasonably promptly – they’re not going to attract many celebs onto the show if they get a reputation for tardiness in coughing over the appearance money – so is the company being used to carry the payment forward into the current tax year, which would look very much like a bit of tax avoidance, or has it gone somewhere other than into Dorries’ own coffers? Either possibility might well allow Dorries to avoid registering Averbrook for the time being without breaking parliamentary rules but not without raising quite a few interesting and potentially rather awkward questions in other areas.

Oooh, and while we’re on the subject of the “I’m a Celebrity…” money, does anyone know whether Dorries ever made good on her promise to donate her MP’s salary for the period she was away from the Commons to charity?

With all the negative publicity she got for skipping out on her constituents at the time, you’d have thought she’d have made a bit of show of being seen to hand over at least least some of the promised cash to a worthwhile cause, but apparently not – unless anyone knows differently, in which case comments are open.

So, despite there being rules which require her to register any paid employment, remunerated directorships or significant shareholdings within four weeks, Dorries has registered nothing whatsoever in the last 11 months in those area and, lest we forget, she is also currently the subject of an ongoing inquiry by the Independent Parliamentary Standards Authority into her claims for accommodation and travel expenses.

Now it is well worth remembering here that in making news of that inquiry public, IPSA said nothing whatsoever about any of the exact matters they were intending to look into only that she “may have been paid an amount under the MPs’ Scheme of Business Costs and Expenses that should not have been allowed” and that it would be claims submitted for accommodation expenditure and travel and subsistence. Everything else that appeared in the press at the time, i.e. that the inquiry related to an allegation of subletting based on a single electricity bill and a duplicate claim for travel expenses submitted by a member of Dorries’ staff, came from just one source – Nadine Dorries.

Or at least that was the case until I published an analysis of Dorries’ personal travel expense claims for the period that IPSA had identified as being under investigation which indicated that she’d actually been making very little use of taxpayer-funded Pimlico flat while, at the same time, commuting on an almost daily basis to and from her constituency home to the House, also at the taxpayers’ expense.

Somewhat unusually, on this occasion, that article drew a response from Dorries, a rambling blog in which she sought to explain her apparent need for both a £1,600 a month London flat and travel expenses to cover the cost of commuting to and from the House of Commons on a near-enough daily basis in terms of a previously unmentioned role as the main carer of a thirteen-year old Labrador.

This, naturally enough, supplied her an excuse to try and lay on her usual ‘poor me’ shtick with a cement mixer:

I am quite sure the IPSA solution to my being a single mum and lone carer of a family and a dog would be to have the dog put down and my child adopted, but I’d rather not. The barrister who told the MP to drop his case may never have taken it on in the first place if he had known about IPSA.

Although she did neglect to mention the fact that even the youngest of her three daughters is now in her early 20s and living away from the family home for most of the year while studying at a university in Liverpool – I could be wrong, but I don’t think you can put a 20/21 year old adult up for adoption.

Dorries also claimed, in this section of her blog post, that she had only been commuting ‘for a little while’ and only then because the dog wasn’t allowed at her London flat, a comment which prompted me to go back over the rest of expenses claims to see just exactly how long a ‘little while’ might have actually been.

Now I did try to go back as far as 2010/2011 and look at everything Dorries claimed from the date of that year’s general election onwards but I was unable to produce full set of figures for that period due to the abysmal state of the expenses paperwork that was submitted for a two month period in the second and third quarter of the year, which appeared to have been compiled with the help of an Enigma machine. However, from the data I was able to analyse it appears Dorries commuted to and from the Commons from her constituency home on a daily basis during the period from the general election to the summer recess in July after which she managed to rent a place in London. For the rest of that financial year, up to the end of March 2011, she appears to have adopted the general pattern one expects to see from backbench MPs who claim for a second home in London, i.e. she travelled down to London at the start of the working week  on either Sunday or Monday and then stayed in the capital while the House was sitting, returning to her constituency home either on Thursday evening or on Friday.

From April 2011 onwards, Dorries’ expense claims were in a good enough state to enable me to crunch the numbers and, to save time, I’ve compiled the quarterly data for her accommodation and travel expenses claims from April 2011 to the beginning of November 2012 (the most recent data uploaded to IPSA’s website when I did the analysis) into an infographic which should serve to clarify IPSA’s reasons for investigating her expenses very nicely.

UPDATE – 9 May 2013

IPSA has now published the remaining expenses data for the 3rd quarter of 2012-13, which I’ve added to the figures in the infographic to provide a full view of Dorries’ expenses claims over seven quarters from April 2011 to December 2012.

So it would seem that Dorries’ idea of a ‘little while’ is actually more than a year because the pattern of regular daily commutes to and from the House of Commons from her constituency home actually began in earnest in the third quarter to 2011/12 and escalated quickly to a point where, during the period that IPSA is actually investigating, Dorries’ London flat was costing the taxpayer well in excess of £900 for every night that she actually stayed in it.

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UPDATE – 9 May 2013

The new data from IPSA covers the period during which Dorries skipped off to Australia for a diet of kangaroo testicles and ostrich cloaca, with the records showing that her last visit to the House of Commons before ‘I’m a Celebrity…’ was on 1 November 2012 and that she didn’t then return to the House until 27th November.

Dorries has claimed on a number of occasions that she took the time off to do the show while Parliament was on a half-term break and that she didn’t, therefore, miss any debates in the House. In fact, Parliament’s own records show that the House of Commons was actually in session on 13 of the 25 days between the 1st and 27th November 2012 and this it’s ‘half-term break’ amounted to just two days (14th-15th November 2012) when it might otherwise have sat.

With this new data, we can also see Dorries’s full expenses claims for the 2012 calendar year, during which the House of Commons was in session for 142 days.

For the entire year, she claimed £18,481  in rent for her second home, a flat in Pimlico, plus a further £908 to cover Council Tax on the flat and utility bills. During that year, the data from IPSA indicates that she spend just 25 nights at her flat at a cost to the taxpayer in rent alone of £754 per night (£790 per night if you include Council Tax and other bills claimed on expenses).

On the travel front, Dorries claimed a total of £4,030 in expenses from travel to and from the House of Commons from her constituency, making a round trip on the same day on 86 occasions at a cost to the taxpayer of £3,351 for the year, which means that 83% of the travel expenses claimed when she attended the House of Common related to daily commutes from her 4 bedroom constituency home to London and back and all on top of the £19,749 claimed for a second home in Pimlico.

And with that, back to the original article…

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So what precipitated this sudden change in behaviour and was it indeed due solely to an officious security guard telling Dorries that her dog was canina non grata, as she’d claimed back in February.

Well, my own inquiries indicate that something else happened over the summer of 2011 that may well have had a considerable influence over the amount of time Dorries was actually spending at her London flat.

In July/August 2011, Dorries moved house – specifically she relocated her constituency home to a 4 bedroom, 2 bathroom, 2 reception room property in Westoning, one that had been sold on the open market only a matter of three months earlier for £345,000.

Now that is interesting – Dorries made a single day commuter run from her constituency home to Westminster and back just once in the six months prior to her move into a £345,000 house in her constituency but in the quarter after she moved she made the same run 24 times at a cost to the taxpayer of over £900. That’s an expensive dog, especially as she continued to commute for more than a year, racking up travel claims of close to £5,500 when you include those increasing rare occasions on which she made only a one-way trip, while claiming almost £21,000 for rent on a London property she used overnight only 35 times in 13 months.

However, that’s not the most interesting thing about Dorries’ move to Westoning. For that you need to head over the Land Registry and dig out the records for the property in Westoning in which she’s been living since July/August 2011 where you’ll find not only that it was purchased only three months before Dorries moved in – enough time for a few renovations – but also the identity of the person who bought the property in May 2011…

… Andrew James Rayment*.

* oh yes, and his wife, of course, who I’m deliberately leaving out of all this for lack of evidence of any direct connection with Dorries.

Yes, that is the exact same Andrew Rayment who, a little over a year later, was happy to casually toss Dorries a spare limited company – Averbrook Limited – to funnel her as yet undeclared media income into and yes, it does appear that he also owns Dorries’ constituency home, which he and wife bought just three months or so before she moved in.

And, of course, since February this year, Rayment is also, once again, a director of Averbrook Limited in addition to his still being listed on several due diligence websites as its sole shareholder.

Having had the whip suspended by the Conservative Party it would appear that Dorries is not quite the independent Member of Parliament her constituents might have supposed her to be – on paper, at least, she looks rather more like a wholly owned subsidiary of a former Chairman of her local Conservative Association.

Okay, okay – maybe ‘wholly owned subsidiary’ is bit strong but I’m nevertheless sure that Dorries must feel personally indebted to Rayment for his sterling support and largesse over the last three years or so, all of which would suggest that it’s highly unlikely that she’ll be hopping over Nigel Farage’s fence any time soon.

This is all legal and above board, I’m sure, but nevertheless Dorries’ constituents and even some members of her local association might be inclined to wonder exactly how a former chairman of Mid Bedfordshire Conservative Association came to be both their MPs landlord and a director of a company that appears to exist, these days, solely for the purpose of receiving monies earned by that same MP from their media work – monies that have yet to be declared openly on the House of Commons’ Register of Members’ Interests.

Getting back to the IPSA investigation, what I’m sure you’ll appreciate from the data in the infographic is that one of the key reasons that they’ve chosen to investigate Dorries’ finances is this little matter of her having her cake and eating it for more than a year by claiming sizeable sums of money for the rent on a little-used London flat while at the same time commuting regularly between her constituency home and Westminster on a daily basis, all of which makes recent efforts by her friends in Tory Party to push the issue of her ongoing suspension look more than a little bit premature.

Let’s face it, just about the last thing that the Tory High Command are going to want is for a situation to arise in which they re-admit Dorries back into the fold, only for her to then censured by IPSA and the Parliamentary Standards Committee over her expenses claims*.

* Written before the Tories took her back into the fold, which goes to prove that you should never underestimate the stupidity of the political classes.

It may not be a case of Duck Houses and moat-cleaning but claiming  just over £4,000 in daily commuting expenses on top of £20,000 rent for a London flat just to be able get home and feed the dog is something that many outside observers will readily consider to be taking the piss even if, technically speaking, it turns out to be permissible within the current rules of the House of Commons.

Compared to that scenario, Dorries’ cry of “Infamy! Infamy! Osborne’s got it in for me!” seems less than convincing.