Lord O'Neill asked the Commissioner to investigate him following a conversation between Lord O'Neill 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 contacted Lord O'Neill stating that they would publish an article alleging that during the conversation Lord O'Neill 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 act as a paid advocate in the House and to provide parliamentary advice and services; © to help establish an all-party group at the behest of the client. No article was in fact published. The Commissioner was concerned at some statements that Lord O'Neill made but found that he did not demonstrate a clear willingness to breach the Code of Conduct in relation to any of the above allegations. He has therefore been cleared of breaching the Code of Conduct