Lord Cunningham asked the Commissioner to investigate him following a conversation between Lord Cunningham and undercover Sunday Times journalists, which was covertly recorded by the journalists. The journalists posed as strategic consultants representing a South Korean investor looking to market innovative solar technology in the United Kingdom. The consultants wanted to recruit parliamentarians to further the client’s interests within Parliament and government. The newspaper subsequently published articles about Lord Cunningham alleging that during the conversation Lord Cunningham breached the Code of Conduct by indicating he was willing (a) to host functions in the House of Lords on behalf of a paying client; (b) to help establish an all-party group at the behest of the client; and © to act as a paid advocate in the House and to provide parliamentary advice and services. In addition to those three allegations, which were published, Lord Cunningham made comments in his discussion with the undercover journalists that the Commissioner considered raised concerns as to the integrity of a previous investigation into Lord Cunningham. The Commissioner found that Lord Cunningham did not demonstrate a clear willingness to breach the Code of Conduct in relation to any of the three allegations that were published. In respect of Lord Cunningham’s comments about a previous investigation by the Sub-Committee on Lords’ Interests, the Commissioner found that, when considered in the light of the facts about what happened, Lord Cunningham was not culpable of a failure to act on his personal honour. He has therefore been cleared of breaching the Code of Conduct.