APCO Worldwide

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APCO offices, 90 Long Acre, Central London
APCO offices, Rue Montoyer 47, Brussels

The lobbying company APCO Worldwide was born out of the Washington-based tobacco industry law firm Arnold and Porter, from which it derives it name. APCO Worldwide was founded in 1984 as APCO Associates Inc. by Margery Kraus, who was its first president and CEO. APCO Worldwide has offices in 24 locations in North America, Europe, Asia and Africa. In September 2004 Kraus led a management buy-out of her firm from Grey Global Group, making APCO one of the largest privately owned communication and public affairs firms in the world.[1]

Helping Big Tobacco

Fighting the EPA's passive smoking regulation

In December 1992, the US Environmental Protection Agency (EPA) published a landmark report called Respiratory Health Effects of Passive Smoking which classified environmental tobacco smoke (ETS) as a grade A carcinogen. Shortly afterwards, in February 1993 Ellen Merlo, Philip Morris's senior vice-president of corporate affairs, sent a letter to the company's CEO and president William I. Campbell explaining: "Our overriding objective is to discredit the EPA report ... Concurrently, it is our objective to prevent states and cities, as well as businesses, from passive-smoking bans." For this purpose she had hired APCO. In advice attached to Merlo's letter, APCO warned:"No matter how strong the arguments, industry spokespeople are, in and of themselves, not always credible or appropriate messengers." The industry could only win by associating its fight against a ban on passive smoking with other people and other issues. APCO advised that the industry should therefore set up astroturf movements and proposed to set up "a national coalition intended to educate the media, public officials and the public about the dangers of 'junk science'. Coalition will address credibility of government's scientific studies, risk-assessment techniques and misuse of tax dollars ... Upon formation of Coalition, key leaders will begin media outreach, eg editorial board tours, opinion articles, and brief elected officials in selected states." For a fee of $150,000, APCO would found the coalition, write its mission statements, and "prepare and place opinion articles in key markets". The coalition would cost $75,000 to set up.[2]

Founding The Advancement of Sound Science Coalition

A letter and proposal to Vic Han, Philip Morris's director of communications, from APCO's Margery Kraus shows that APCO was instrumental in setting up TASSC, The Advancement of Sound Science Coalition, the Philip Morris front group dedicated to countering scientific findings of the ill health effects of second-hand smoking.

Kraus writes to Han:

I am pleased to present you with an outline of APCO Associates Inc.'s (APCO) proposed activities on behalf of Philip Morris, USA for 1994. This proposal outlines (i) our work with The Advancement of Sound Science Coalition (TASSC) ; (ii) the development of a media relations strategy and (iii) APCO's role in assisting Philip Morris and its Regional Directors in targeted states.
APCO is very excited about the development and progress of TASSC. The national coalition currently has over 300 members, with representation from business and industry, the scientific and academic communities, and public officials. We are looking forward to the successful launching of TASSC this fall. We believe the groundwork we conduct to complete the launch will enable TASSC to expand and assist Philip Morris in its efforts with issues in targeted states in 1994.[3]

APCO describes its strategy of recruiting third-party apparently independent scientists to parrot the industry line:

APCO will conduct an on-going program of outreach to credible scientists and academicians to enlist their support and participation with TASSC and its related issues ., In this regard, APCO will identify and recruit targeted individuals by matching scientists and academicians to key TASSC issues. The scientists and academicians will be encouraged to participate in TASSC media activities...[4]

APCO then describes its media relations plan:

As a follow-up to the launching of TASSC, APCO will implement a comprehensive media relations effort which would include the development of a TASSC Public Information Bureau. The primary objective of the TASSC Public Information Bureau is to (i) maximize coverage of the coalition; (ii) disseminate key messages of the coalition; and (iii) maximize the use of TASSC and its members into Philip Morris's issues in targeted states....[5]

APCO's strategy even includes grassroots groups:

ASSISTANCE TO REGIONAL DIRECTORS IN TARGETED STATES: APCO will assist the Regional Directors in states targeted by Philip Morris. This includes utilizing TASSC as a tool in targeted legislative battles, developing and/or working with other coalitions and grassroots groups, and implementing approved campaign tactics and efforts.[6]

London office

APCO Offices, 90 Long Acre, Central London

In London APCO is based in an expensive tower block in Covent Garden at 90 Long Acre London WC2E 9RA (In November 2004 the building also housed the offices of Weber Europe (now known as GolinHarris), part of Weber Shandwick, owned by Interpublic). [7]

According to the lease agents these offices had lain empty for some months. Offices in this block cost between £35-45 per square foot depending in how high they are (in November 2004). Each floor includes 10,200 square feet: a total of between £357,000 and £459,000 - per month![8]

Location of these offices away from Westminster is said to be a competitive disadvantage.

Brussels Office

Elizabeth Crossick is deputy director of APCO Worldwide’s Brussels Office she took up the post in October 2011. Paolo Nicoletti is the APCO Brussels managing director and Michael Burrell is vice-chair for Europe. [9]

People

APCO UK has close links with the Government and political parties:

  • Darren Murphy, Director of APCO UK, "is a former adviser to the Blair government, a position he held from May 1997 to September 2005. As special adviser for political communication in the prime minister's office he provided Tony Blair with strategic and political advice on all media issues, was responsible for media planning and scheduling, message development and contributing to the content of Tony Blair's speeches, articles and interviews. Most recently, he was head of government relations and external affairs for AstraZeneca UK."[10] [11]
90LongAcre-wide.jpg
APCO Offices, 90 Long Acre, Central London
  • Senior Consultant Martin Sawer "left Whitehall to join the public affairs industry in 1987, having previously worked for nearly three years at 10 Downing Street in the private office of the then Prime Minister, Margaret Thatcher".[12]
  • APCO 'Senior Counsellor' David Clark "was a Special Adviser at the Foreign and Commonwealth Office between 1997 and 2001. He first joined Robin Cook's staff in 1994 and was closely involved in the development of Labour's foreign policy in the run up to the 1997 general election".[13]
Someone such as Sir Liam will tell us what works and what doesn’t. It’s a sounding board for strategy. It’s not about access. It’s about understanding the stakeholder environment and really looking at the client’s objective and making sure we help in achieving it.[14]

September 2014-November 2014

James Acheson-Gray | Graham Ackerman | Morgane Becouran | Alexandra Bigland | Edward Bird | Lidia Borisova | Matthew Bostrom | William Browne | Michael Burrell | Magdalen Bush | Donna Castle | David Clark | Douwe Cosijn | Sara Cruz | Victoria Ergolavou | Thomas Eymond-Laritaz | David Fanthorpe | Keir Ferguson | Chris Genasi | Jochem Gerritsen | Roger Hayes | Bridget Heath | Mitch Henderson | Kristin Heume | Charlotte Higgo | Jolyon Kimble | Alexander Kolawole | Rasika Krishna-Schmid | Janki Lalji | Maria Lavrova | Daniella Lebor | Chris Levy | Stephanie Lvovich | Elise Martin-Davies | Danielle McGuigan | Douglas Miller | Emma Putt | Dawn Robinson | Jenny Runnacles | Martin Sawer | Andrew Sikorski | Brad Staples | Laure Stein | Jessica Sullivan | William Wallace | Edward Walsh | Joe Whitwell[17]

June 2014-August 2014

James Acheson-Gray | Graham Ackerman | Alexandra Bigland | Edward Bird | Lidia Borisova | Matthew Bostrom | William Browne | Michael Burrell | Magdalen Bush | Alex Clackson | David Clark | Douwe Cosijn | Sara Cruz | Victoria Ergolavou | Thomas Eymond-Laritaz | David Fanthorpe | Keir Ferguson | Chris Genasi | Jochem Gerritsen | Carenza Harvey | Roger Hayes | Bridget Heath | Mitch Henderson | Charlotte Higgo | Jolyon Kimble | Alexander Kolawole | Rasika Krishna-Schmid | Janki Lalji | Maria Lavrova | Daniella Lebor | Stephanie Lvovich | Elise Martin-Davies | Danielle McGuigan | Douglas Miller | Emma Putt | Dawn Robinson | Jenny Runnacles | Martin Sawer | Laure Stein | Jessica Sullivan | William Wallace | Edward Walsh | Joe Whitwell[18]

March 2014-May 2014

James Acheson-Gray | Graham Ackerman | Alexandra Bigland | Edward Bird | Lidia Borisova | Matthew Bostrom | William Browne | Michael Burrell | Magdalen Bush | Alex Clackson | David Clark | Douwe Cosijn | Sara Cruz | Victoria Ergolavou | Thomas Eymond-Laritaz | David Fanthorpe | Keir Ferguson | Chris Genasi | Mohammed Habib | Roger Hayes | Mitch Henderson | Charlotte Higgo | Jolyon Kimble | Alexander Kolawole | Rasika Krishna-Schmid | Janki Lalji | Maria Lavrova | Daniella Lebor | Stephanie Lvovich | Elise Martin-Davies | Danielle McGuigan | Douglas Miller | Joanne Milroy | Emma Putt | Dawn Robinson | Jenny Runnacles | Martin Sawer | Laure Stein | Jessica Sullivan | Bridget Taylor | William Wallace | Edward Walsh[19]

Former people

  • Mark Adams, a high-flying private secretary at Downing Street for both Major and Blair, worked at APCO. He went on to run Foresight Communications[20] and these days is a freelance consultant.
  • Former director of Public Affairs Nick Sutcliffe "is an elected local authority member in west Surrey, chairs a local government scrutiny panel and is a development control committee member. Prior to entering public affairs, Nick worked at Westminster for four members of parliament, undertaking research work on defence, the economy and social security issues. He has also worked on Capitol Hill for a US congressman".[21] Joined lobbying firm PPS in 2007 as a director.
  • Former senior consultant Alasdair Liddell's "career spans nearly 30 years in NHS management, including six years as a top civil servant in the Department of Health under both Conservative and Labour administrations". Liddell joined the Bell Pottinger Group as a consultant to The Collective, a division of Bell Pottinger.[22]
  • Emerging Markets Director Simon Whitehead "spent 2 years working at Conservative Central Office, where he implemented communications, marketing and fundraising strategies before, during and after the 1997 General Election".[23] Whitehead now works for Hill and Knowlton London.

Clients

September 2014-November 2014

Anheuser-Busch InBev | Blue Fish Association | British Association of Pharmaceutical Wholesalers | Butler Snow PLLC | Chartered Society of Physiotherapy | Children's Investment Fund Foundation | Church of Jesus Christ of the Latter-day Saints | Dubai World Central | eBay Inc | Education Testing Services | GE Healthcare | GML Limited | Intuit | Mars Inc. | Mead Johnson Nutrition | Microsoft | MOL | Naftogaz | Reckitt Benckiser | Rimal Investment Projects LLC | Scotts Company Ltd | Sodexo | Tetra Pak[17]

June 2014-August 2014

Anheuser-BuschInBev | British Association of Pharmaceutical Wholesalers | Butler Snow PLLC | Church of Jesus Christ of the Latter-day Saints | eBay Inc | Education Testing Services | European Azerbaijan Society | GE Healthcare | GML Limited | Intuit | Mars Inc.| Mead Johnson | Nutrition | Microsoft | MOL | Novartis | Scotts Company Ltd| Sodexo | TE Connectivity | White & Case LLP| Wuxi Suntech Power[18]

March 2014-May 2014

AGT Group GmbH | Anheuser-Busch InBev | BlackBerry | Blue Cross Blue Shield Association | British Association of Pharmaceutical Wholesalers | Butler Snow PLLC | Cambridge University Judge Business School | Church of Jesus Christ Lattter Day Saints | Constellium | Credit Suisse | Dalian Worldwide Investments Ltd | Danaher UK Industries | DEK International | DePuy International | Dubai Government Media Office | eBay Inc | Education Testing Services | European Azerbaijan Society | FleetCor Europe | General Electric | Ginsters | GML Limited | Honeywell International | Hughes Hubbard & Reed LLP | Intuit | Jaguar Land Rover | Mars Incorporated | Masdar | MasterCard Europe | Mead Johnson Nutrition | Microsoft | MOL | Nadav Foundation | National Association of Insurance Commissioners | Netjets Management Ltd | Novozymes North America Inc | Recolight Ltd | Rimal Investment Projects LLC | Rotary Foundation | Samworth Brothers Group | SCA Hygiene Products AB | Schneider Electric | Sodexo UK | TE Connectivity | The Scotts Company Ltd | Tokyo Electric Power Company | Turkish Airlines | White & Case LLP | Wuxi Suntech Power[19]

Snapshot of lobbying clients in 2008:[24]
Abbott Nutrition | Advertising Education Forum | ACCURAY Europe | BodmerFischer Ltd | Bonita Ventures Limited | Borealis AG | British Association of Pharmaceutical Wholesalers | Cleanevent | Coca-Cola Great Britain | The Coca-Cola Company | Creative Direction Consultants Ltd | Denplan | Duninga Developments | Ebay Inc. | ESB International Ltd | Ethicon Endo-Surgery (Europe) GmbH | FBC Media UK | Gate Gourmet Ltd London | GML Limited | Housing Corporation/Tenant Services Authority | Hughes Hubbard & Reed LLP | Humana Europe | IMS Health | Johnson Controls Inc. | Johnson & Johnson | Media Smart UK Ltd | Merck Sharp & Dohme Ltd | Medicines for Malaria Venture | Microsoft | Netjets Europe | Nike Inc | Norilsk Nickel | OTE Hellenic Telecommunications Organization | Phadia UK | Philip Morris | Plastics Europe | SABMiller | Solvay Pharmaceuticals GMBH | Tyco Electronics | Virgin Healthcare | Wyeth Pharmaceuticals

Previous clients

Yukos

One of APCO's former clients is Yukos, the Russian oil giant whose former chief executive, Mikhail Khodorkovsky, was arrested at gunpoint in 2003.

In 2005, Khodorkovsky was sentenced to nine years in jail for fraud and tax evasion. Khodorkovsky's business associate and co-defendant, Platon Lebedev, was found guilty of the same charges and given the same sentence.[26] Other major shareholders have fled Russia to evade arrest.

A 2003 article for The Business by Neil Thapar reports:

Yukos's international advisory board was set up in April to assist senior company officials. Stuart Eizenstat, ex-US Deputy Treasury Secretary who is also a former ambassador to the European Union (EU), said Yukos's Washington-based lobbying firm, APCO, had hired lawyers in the wake of the Kremlin's campaign against the company.[27]
He said: "We do not want to get into the details of the allegations, which have not been made public but there are lots of actions which are being considered. These include the European human rights courts and the United Nations. We are not at that stage yet. APCO has retained a team of lawyers who are looking at the human rights issues. We are also looking at this as an economic and political issue."[28]

The Daily Mail

According to a report in the Sunday Express in 2003, APCO may have lobbied MEPs to try to derail legislation in the proposed EU constitution that could end Jonathan Harmsworth, 4th Viscount Rothermere's control over the media group Daily Mail and General Trust (DMGT). DMGT owns the Daily Mail newspaper, which ran a campaign for a referendum on the proposed EU constitution.

Anil Bhoyrul writes:

The Daily Mail's frenzied campaign for a referendum on the proposed EU constitution may convince readers that the main issue is jobs, homes and pensions but there is a more pressing agenda behind the patriotic call to arms. One early casualty of a new constitution would be Lord Rothermere, the Mail's controlling shareholder. He would almost certainly be kicked out of power.
So worried is the tycoon that he is conducting a personal campaign against the proposed legislation, lobbying officials in Downing Street and travelling to Brussels to press his case in person. Last week, in what was hyped as its own referendum, Daily Mail readers were urged to join his calls for a vote on new EU suggestions.
Rothermere's troubles centre on EU proposals on mergers and acquisitions, which had been expected to be agreed by July 1. Under articles 9 and 11, individuals would be prevented from owning "multiple voting rights": in effect, controlling shares such as those in DMGT, whereby Rothermere controls 80 per cent of the voting shares even though he and his family own just 19 per cent of the equity.
Sources say that, given DMGT's current market value of GBP 2.42 billion, less than half that of three years ago, it could fall prey to a foreign takeover. An EU executive source said: "If the new EU proposals came in, Rothermere would be gone. At that value, DMGT would be swallowed up." It is understood that, late last year, Rothermere personally visited EU Internal Market Commissioner Frits Bolkestein to try to persuade him to drop the new directive. Sources suggest the meeting may have been organised by media lobby group APCO, which may have also been used to lobby several MEPs on Rothermere's behalf.
Rothermere may have had some success so far, with the EU unlikely to agree any changes before Greece hands over its presidency of the EU on July 1, but the deadlock is largely down to the lobbying of more powerful tycoons such as Sweden's Wallenberg family, which controls several public companies despite having a minimal capital outlay.
The EU source said: "Rothermere came banging his drum because he is worried that, if it went through, he couldn't keep 80 per cent control of DMGT. He'd have to give ordinary shareholders the same voting rights and that would be the beginning of the end for him. He put a good case but the reason for the deadlock is because of lobbying from the likes of the Wallenberg family. These are serious players."
An EU spokesman added: "All I can say is that, after 15 years of negotiations, we are probably back to square one on this." Rothermere, meanwhile, is taking no chances and, through his Mail newspapers, has stepped up his personal campaign for a referendum on the new EU constitution.[29]

Cyber-lobbying and Astroturf campaigns

APCO underlines the importance of online campaigning to clients. According to its website (in 2006) under the headline 'Focusing creative minds on grassroots mobilisation':

APCO supports the premise that 'all politics is local'. Persuading members of the public to engage with their elected representatives is integral to any issue-based campaign. We inform and motivate people about the issue and create opportunities that allow them to make their views heard. Recent grassroots campaigns have successfully mobilised employees, customers, pensioners, residents groups and suppliers.[30]

APCO offers services to clients to mobilse support. Again, according to its website:

We design websites that recruit volunteers and supporters and keep them informed about a campaign's progress. Supporters are also able to contact relevant decision-making bodies directly from the sites. This empowers them to become actively - and effectively - engaged in a campaign.[31]

Education industry lobbying

APCO has lobbied for a number of companies involved in the education industry. It also says it has 'built numerous national and [US] state coalitions on a variety of issues including... education.'

ETS, or Education Testing Services, the global testing company, which runs the TOEFL exams among other tests, is listed as a UK client (2014 -). APCO's website also features a case study of its work for ETS, which says that APCO has, over the last 10 years, implemented a corporate communications and government relations program to boost ETS’s reputation in China.[32] ETS has been criticised for its monopolistic power in the US. In the UK, in 2014 the BBC reported that the Home Office suspended English language tests run by ETS after an investigation uncovered systematic fraud in the student visa system. Secret filming of government-approved English exams needed for a visa showed entire rooms of candidates having the tests faked for them.[33]

APCO has also lobbied for the Children's Investment Fund Foundation in the UK. The London-based Foundation is a venture philanthropy charity established by Jamie Cooper-Hohn and her husband hedge fund manager Chris Hohn that focuses on improving the lives of children living in poverty in developing countries. In 2014, the Children's Investment Fund Foundation along with Instiglio, UBS Optimus Foundation and Educate Girls launched the first Development Impact Bond to try and reduce the gender gap in education in Rural India. UBS is providing an investment to the Indian NGO, Educate Girls. The Children's Investment Fund Foundation as 'outcome payer' will pay based on enrollment and learning outcomes. UBS Optimus Foundation stands to receive their initial investment back plus a return on investment based on the performance of the program.

Another of APCO clients, Microsoft, is also heavily involved in the education industry.

Holmes Report profile

According to the Holmes Report, 2005: [34]

Last year [2004] was a momentous one for APCO, which finally was able to extricate itself from its relationship with Grey Advertising and emerge as an independent public affairs and strategic communications firm. If the prolonged negotiations that culminated in a management buyout (supported by merchant bank Wind River) in 2004 were a distraction, it wasn't apparent from the firm's performance in 2004. New business included assignments from Ahold (corporate reputation management in the wake of an accounting scandal); the Canadian Embassy (online communication); Corporation for National and Community Service (online communication); Elsevier (corporate positioning); the Government of Indonesia (media and government relations); and the U.S. Department of Agriculture (food safety campaign).
The firm also expanded its relationship with the Business Roundtable, an association of CEOs of the largest companies in America, to include public affairs and communications work with the organization's trade, health & retirement, environment and security task forces. Revenue growth was an incredible 24 percent – best among the top-tier agencies profiled here.
APCO has always enjoyed a unique ability to attract some of the biggest names in government -- some as affiliated consultants, many as full-time employees -- and 2004 saw the addition of two very big names: former Senate Majority Leader, Senator Bob Dole, who will serve as a senior counselor; and former U.S. Secretary of State Henry Kissinger, whose firm entered into a unique strategic alliance with APCO shortly after the MBO. Other additions include Roger Lowe, formerly senior vice president and director of the Washington, D.C., public affairs practice of Porter Novelli; Mike Tuffin, a veteran of America's Health Insurance Plans and PhRMA; Patty Kennedy, a Burson Marsteller veteran who joined the fledgling New York office; and Simon Miller, managing director of APCO U.K. They join a veteran leadership team that includes Margery Kraus and Neal Cohen; executive vice presidents Don Bonker and Jane Garvey; and senior vice presidents such as B. Jay Cooper, Marc Ginsberg, Kent Jarrell, and Don Riegle.
APCO is involved in some of the biggest issues facing the world today, from the rule of law in Russia to the global battle against HIV/AIDS, from antitrust issues for Microsoft to the liberalization of the financial services industry. Highlights of the firm's work include working with Toyota and its law firm Weil Gotshal & Manges after criticism of the company's bulletproof vests; helping Pfizer promote its Share Card and U Share Drug Discount Card programs; continuing its reputation management work with World Wrestling Entertainment, promoting its youth voter initiative, Smackdown Your Vote!; and assisting the Canadian Embassy with its efforts to raise awareness of the country's contributions to the American economy.

Contact, References and Resources

Contact

90 Long Acre, London, WC2
http://www.apcoworldwide.com/uk

Resources

See: The Corporate Capture of the NHS

References

  1. "Margery Kraus", APCO Worldwide website, accessed January 2009.
  2. George Monbiot, The denial industry, The Guardian, 29 September 2006
  3. All the quotations from Kraus's letter are from: Margery Kraus, APCO Associates, letter to Vic Han of Philip Morris, 23 September 1993, accessed January 2009. The letter can also be downloaded as a pdf here.
  4. All the quotations from Kraus's letter are from: Margery Kraus, APCO Associates, letter to Vic Han of Philip Morris, 23 September 1993, accessed January 2009. The letter can also be downloaded as a pdf here.
  5. All the quotations from Kraus's letter are from: Margery Kraus, APCO Associates, letter to Vic Han of Philip Morris, 23 September 1993, accessed January 2009. The letter can also be downloaded as a pdf here
  6. All the quotations from Kraus's letter are from: Margery Kraus, APCO Associates, letter to Vic Han of Philip Morris, 23 September 1993, accessed January 2009. The letter can also be downloaded as a pdf here.
  7. 'APCO website – Contact us', undated, accessed June 2006.
  8. Information from leasing agents given to David Miller October 2004.
  9. Public Affairs,BRUSSELS: APCO Worldwide has recruited Elizabeth Crossick as deputy managing director of its Brussels office 10th October 2011, accessed 31st October 2011
  10. "Darren Murphy", Virtual Vantage Points website, accessed January 2009.
  11. APCO UK - Our People, undated, accessed June 2006.
  12. APCO UK - Our People, undated, accessed June 2006.
  13. APCO UK - Our People, undated, accessed June 2006.
  14. David Singleton,Liam Donaldson takes up role with lobbying firm APCO, prweek.com, 27 July 2011, accessed 1 August 2010
  15. John Hutton, APCO Worldwide, acc 29 October 2013
  16. Rod Muir APCO swoops for former MEP Public Affairs News, 25 September 2014, accessed 19 January 2015
  17. 17.0 17.1 Register 1st September 2014 - 30th November 2014 APPC, accessed 19 January 2015
  18. 18.0 18.1 Register 1st June 2014 - 31st August 2014 APPC, accessed 16 October 2014
  19. 19.0 19.1 APPC Register for 1st March 2014 - 31st May 2014, accessed September 2014
  20. Michael White and Kevin Maguire, 'Prime suspect in mole hunt laughs off link to leak', The Guardian, 18 November 2000.
  21. APCO UK - Our People, undated, accessed June 2006.
  22. APCO UK - Our People, undated, accessed June 2006.
  23. APCO UK - Our People, undated, accessed June 2006.
  24. APPC register, to December 2008
  25. Unison, The rise of the “public services industry” (Pdf), September 2008
  26. Nick Paton Walsh, 'Russian oligarch jailed for nine years', The Guardian, 1 June 2005.
  27. Neil Thapar, "Yukos plans Khodorkovsky human rights appeal", The Business, November 9, 2003, p. 5
  28. Neil Thapar, "Yukos plans Khodorkovsky human rights appeal", The Business, November 9, 2003, p. 5
  29. Anil Bhoyrul, "Financial Express – Media uncovered Rothermere's real motive for referendum crusade: Mail EU agenda", Sunday Express, June 15, 2003, Finance section, p. 26
  30. APCO UK – Grassroots mobilization, APCO website, accessed June 2006.
  31. APCO website, page no longer available.
  32. APCO website, accessed August 2015
  33. Richard Watson, Student visa system fraud exposed in BBC investigation, BBC website, 10 February 2014
  34. Holmes Report 2005 – APCO worldwide, 29 September 2005, accessed June 2006.

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