29 August 2017 Dear David Farrar, By exmail: dpfépf@gmall com CAMPAIGN FOR CHANGE ‘Thank you for your letter of 28 June 2017 regarding the Campaign for Change. The Electoral Commission has looked into the matters that you have ralsed and has sought information about the eampaign from both Matt MeCarten and Andrew Kirton, the General Secretary ofthe New Zealand Labour Party Having reviewed all ofthe information provided, the Electoral Commission has ‘considered wiatif any donation and expense obligations arose prior tothe Labour Party taking over on 28 June 2017, ‘The Electoral Commission has concluded that funds spent on the Campaign for Change ‘wore candidate donations and will need fo be declared in candidate return after the election. Election expenses [Mr McCarten has advised that no printed materials and no other election advertising materials were produced by campaign for change in support ofthe Labour Pary or ‘candidates. On this basis we have concluded that no election expenses were involved. Election expenses are defined as costs incurred preparing and publishing election advertisements published during the regulated period “The expenses involved in the campaign for change were casts of accommodation, food and transport which are not by defniton election expenses and so there a= no ‘compliance consequences that arise regarding election expenses, Donations CCangidate donations are defined in section 207 ofthe Act as a donation of money or {goods or services or ofa combination of those things that is made to a cardidate or to ‘any person on the candidate's behalf for use in the candidate's campaign, ‘The definition means that a donation i no inked o any particular time period. Money (goods, services provided at any time for use inthe candidate's campaign area Candidate donation at 10,9642 a St PO E58 Wg 64, New Zand ts ea a a vest‘The voluntary labour of the intems does not qualify as a candidate donation as the definition excludes a person's labour provided toa candidate free of charge \While the definition of election expense means that it does not cover all campaign costs such as food, transport hall hire et, the defntion of candidate donation isnot so limited. It does not mati what i might be used for ~ it s @ candidate donation if its for tse inthe candidate's campaign ‘Although media coverage referred to ‘private donors’ being involved, Mr McCarton has ‘confirmed that he personaly paid forthe costs. Media coverage of the toal amount of, ‘spending Involved anticipated a larger campaign based on the campaign 2ontining Tonger than tdi. Mr MeCarten has advised that $65,095 was spent up fo the point at which the Party stepped in to take over on 23 June. ‘The Electoral Commission has taken the view that by personally paying for costs in ‘support of the efforts of volunteers campaigning for Labour Party candidases, Mr [MeCarten made candidate donations for the purposes ofthe Electoral Ac, [Mr MeCarten advised thatthe volunteers spent half their time engaged in politically ‘eutal enrolment encouragement and partly engaged in supporting a nuniber of ‘Auckland Labour Party candidte campaigns. “The Commission was not persuaded by the suggestion thatthe intems, bang party engaged campaigning for Labour Party candidates and party to enrol voters, were likely tohave been wholly non-partisan in fufiling the latter role. The Commission concluded ‘that the volunteers were involved with Labour candidate campaigns and Auckland Labour Party organisers were involved, the Commission did not think thatthe Campaign ‘or Change activities could be apportioned as being non-partisan. The Commission ‘concluded that the total cost of $85,095 for the 27 days of the campaign should be regarded as being candidate donations dstibuted between each ofthe Auckland Labour candidates, Mr MeCarten has agreed to provide further information about the exact share for each of the Labour candidates involve from the $65,095 lata. Once the amounts are determined, he will make each candidate aware ofthe amount that he has donated to them so that they can record those amounts for their donations compliance and slsclosure in January 2018, On the basis ofthe information proved, the Commission is satisfied that no party donations were involved, “Thank you for bringing this matte o the Commissions attention. Alig Wight Chist Electoral Oticor