Tom Tugendhat

Role, work or services: Writing
Payer: News Corp UK & Ireland Limited (Journalism), 1 London Bridge Street, London, SE1 9GF
(Registered 28 January 2025)
Payment: £500
Received on: 24 November 2025. Hours: 1 hr Writing an article.
(Registered 24 November 2025)
Payment: £500
Received on: 22 December 2025. Hours: 3 hrs.
(Registered 5 January 2026)
Payment: £200 Writing an article for The Times
Received on: 25 March 2026. Hours: 2 hrs.
(Registered 2 April 2026)
Payment: £500 Writing an article for The Sun
Received on: 25 March 2026. Hours: 3 hrs.
(Registered 2 April 2026)
Payment: £200
Received on: 24 April 2026. Hours: 4 hrs.
(Registered 18 May 2026)

Role, work or services: Writing articles
From: 28 January 2025.
Payer: Telegraph Media Group Limited (Newspaper), 111 Buckingham Palace Road, London SW1W 0DT
(Registered 6 February 2025)
Payment: £250
Received on: 13 October 2025. Hours: 3 hrs.
(Registered 28 October 2025)
Payment: £250
Received on: 19 December 2025. Hours: 2 hrs.
(Registered 5 January 2026)
Payment: £250
Received on: 19 December 2025. Hours: 2 hrs Approximate.
(Registered 5 January 2026)
Payment: £250 Writing an article
Received on: 19 December 2025. Hours: 2 hrs.
(Registered 5 January 2026)
Payment: £1,400
Received on: 14 April 2026. Hours: 6 hrs.
(Registered 14 April 2026)
Payment: £950
Received on: 31 March 2026. Hours: 8 hrs.
(Registered 17 April 2026)
Payment: £5,600 Payment for 8 different articles, at £700 per article.
Received on: 9 June 2026. Hours: 21 hrs.
(Registered 18 June 2026)
Payment: £2,800 Payment for four different articles, at £700 each
Received on: 23 June 2026. Hours: 10 hrs.
(Registered 25 June 2026)
Payment: £2,800 four articles written (£700 each)
Received on: 4 August 2026. Hours: 8 hrs.
(Registered 7 August 2026)

Role, work or services: Public speaking
From: 28 March 2025.
Payer: Spoken Ltd (Speaking bureau), Somerset House, Strand, London WC2R 1LA
ACOBA consulted: Yes
(Registered 3 April 2025)
Payment: £3,200 Speaking at a conference event for Defaqto on 27 November 2025.
Received on: 11 December 2025. Hours: 7 hrs (estimated), including travel and preparation time.
Ultimate payer: Defaqto, 12 Haddenham Business Park, Haddenham HP17 8LJ
Donated to: a charity
(Registered 19 December 2025)

Role, work or services: Writing an article
From: 18 February 2025.
Payer: Daily Mail (Newspaper), Northcliffe House, 2 Derry Street, Kensington, London W8 5TT
(Registered 24 April 2025)
Payment: £600
Received on: 12 March 2026. Hours: 3 hrs.
(Registered 12 March 2026)

Role, work or services: Writing
From: 5 June 2025.
Payer: The Spectator (Newspaper), 22 Old Queen St, London SW1H 9HP
Additional information: Any payments will be listed below.
(Registered 27 June 2025)

Role, work or services: Member of the advisory board
From: 1 July 2025.
Payer: Sulnox Group Plc (Environmental science and technology company), 10-12 Orange Street, London, England, WC2H 7DQ
ACOBA consulted: Yes
(Registered 27 June 2025)
Remuneration: £8,750 a quarter (payment will be made at the end of each quarter)
Hours: 10 hrs a month Estimated
(Registered 27 June 2025)
Payment: Attending a Sulnox Advisory Board Meeting, value £1,511.51
Received on: 17 July 2026. Hours: 5.5 hrs The payment includes costs of flights (£1,110.15), accommodation (£202.41) and airport transfer payment (£198.95) which has yet to be paid, but I have provided payment details and it is expected this will also be covered.
(Registered 17 August 2026)

Role, work or services: Advisor
From: 31 January 2026.
Payer: Observer Research Foundation Middle East (Think tank), 12.03 Convention Tower, Dubai World Trade Centre, Dubai, United Arab Emirates
ACOBA consulted: Yes
(Registered 6 February 2026)
Remuneration: £3,067.88 a month Payment of $50,000 annually, paid monthly. The value is calculated based on the exchange rate at 06/02/2026
From: 31 January 2026.
Hours: 2 hrs a week
(Registered 6 February 2026)

Role, work or services: Writing articles
From: 5 February 2026.
Payer: Tiempo Company (News organisation), 399 Boylston Street, 6th Floor, Boston, MA 02116
(Registered 5 March 2026)
Payment: £1,767.24 Payment for three articles
Received on: 5 February 2026. Hours: 7.5 hrs.
(Registered 5 March 2026)

Role, work or services: Writing articles
From: 4 March 2026.
Payer: The London Standard (Newspaper), Alphabeta, 14-18 Finsbury Square, London EC2A 1AH
(Registered 12 March 2026)
Payment: £500
Received on: 4 March 2026. Hours: 2 hrs.
(Registered 12 March 2026)

Role, work or services: Writing articles
From: 9 March 2026.
Payer: Dow Jones & Company, Inc. (Publishing), 1211 Avenue of the Americas, New York
(Registered 2 April 2026)
Payment: £375 Writing an article for the Wall Street Journal
Received on: 1 April 2026. Hours: 2 hrs.
(Registered 2 April 2026)
Payment: £185 Writing an article for the Wall Street Journal
Received on: 9 March 2026. Hours: 2 hrs.
(Registered 2 April 2026)
Payment: £370
Received on: 4 May 2026. Hours: 4 hrs.
(Registered 15 May 2026)
Payment: £370
Received on: 28 May 2026. Hours: 4 hrs.
(Registered 29 May 2026)
Payment: £370
Received on: 15 July 2026. Hours: 4 hrs.
(Registered 15 July 2026)

Role, work or services: Speaking engagement
From: 16 July 2026.
Payer: D'Angelin & Co. Limited (Financial services / Investment banking), 1 Love Lane, London EC2V 7JN
(Registered 3 August 2026)
Payment: £10,407.70
Received on: 30 July 2026. Hours: 1 hr.
(Registered 3 August 2026)

Name of donor: Artha Global
Address of donor: First Floor, 10 Queen Street Place, London EC4R1BE
Estimate of the probable value (or amount of any donation): Flights (£2,615.78), accommodation (£649.98), food (£164.59) and visa (£598.57), value £4,082.95
Destination of visit: India (Kochi)
Dates of visit: 28 August 2025 to 1 September 2025
Purpose of visit: Attendance at a conference on geopolitical issues and economic growth in Kochi, India.
(Registered 6 October 2025)

Name of donor: Hudson Institute
Address of donor: 1201 Pennsylvania Avenue NW, Suite 400, Washington DC 20004
Estimate of the probable value (or amount of any donation): Flights (£16,094.12), accommodation (£1,554), value £17,648.12
Destination of visit: United States (New York)
Dates of visit: 5 September 2025 to 8 September 2025
Purpose of visit: Attendance at a conference to discuss the transatlantic alliance.
(Registered 6 October 2025)

Name of donor: Commonwealth War Graves Commission
Address of donor: 2 Marlow Road, Maidenhead, Berkshire SL6 7DX
Estimate of the probable value (or amount of any donation): Flights (£370.49), three nights accommodation (£315), coaches (£139.82), food (£206.24) and airport transfer (£71.98), value £1,103.53
Destination of visit: Turkey (Istanbul and Canakkale)
Dates of visit: 15 September 2025 to 18 September 2025
Purpose of visit: In my capacity as Commonwealth War Graves’ Commissioner, I undertook a tour of Gallipoli to see Helles Memorial, V Beach Cemetery, Lone Pine, Chunuk Bair, and the Anzac Commemorative Site.
(Registered 16 October 2025)

Name of donor: With Honor Action
Address of donor: 700 Pennsylvania Ave SE, Ste 420, Washington, DC 20003
Estimate of the probable value (or amount of any donation): £9,468.30 reimbursement for return flights (£8,902.94) and two nights accommodation (£565.36). Expected reimbursement of accommodation tax (£95.32), taxi to Heathrow (£84.77), taxi to IAD (£43.03) and taxi to and from the event (£31.78)
Destination of visit: United States (Washington)
Dates of visit: 7 October 2025 to 10 October 2025
Purpose of visit: Reimbursement of costs associated with attending a cross-partisan conference, supporting veteran leadership in UK and US politics.
(Registered 7 November 2025)

Name of donor: NEWEST
Address of donor: Corp One Rockefeller Plaza, New York, NY 10022
Estimate of the probable value (or amount of any donation): £981.03 flights (£582), accommodation (£270.03) and taxi (£129)
Destination of visit: Italy (Milan)
Dates of visit: 20 October 2025 to 21 October 2025
Purpose of visit: To give a speech on UK-Europe relations at geopolitical and business conference, hosted by SDA Bocconi School of Management.
(Registered 17 November 2025)

Name of donor: The University of Notre Dame Australia
Address of donor: 19 Mouat Street, Fremantle WA 6959, Australia
Estimate of the probable value (or amount of any donation): Flights (£674.38), accommodation (£858.58) and taxis (£414.38), value £1,947.34
Destination of visit: Italy (Rome)
Dates of visit: 27 October 2025 to 29 October 2025
Purpose of visit: Speaking on 'The Church and the World' hosted by The University of Notre Dame Australia in Rome, Italy
(Registered 26 November 2025)

Name of donor: PDSA Veranstaltungs-und Betriebs GmbH
Address of donor: Thurngasse 13/18, 1090 Wien, Austria
Estimate of the probable value (or amount of any donation): Return flights (£743.32) and one night's accommodation including breakfast (£247.95), value £991.27
Destination of visit: Austria (Vienna)
Dates of visit: 6 November 2025 to 7 November 2025
Purpose of visit: Speaking at the Global Peter Drucker Forum on the overlap between business and politics.
(Registered 3 December 2025)

Name of donor: The Globe and Mail
Address of donor: 351 King Street East, Suite 1600, Toronto, ON, M5A 0N1
Estimate of the probable value (or amount of any donation): Flights £2,120.70, Accommodation £1,032.16, Travel £127.83, value £3,280.69
Destination of visit: Canada (Toronta/Ottawa)
Dates of visit: 12 January 2026 to 17 January 2026
Purpose of visit: Meeting with journalists and political leaders
(Registered 11 February 2026)

Name of donor: Taiwan Ministry of Foreign Affairs
Address of donor: 2 Ketagalan Boulevard, Zhongzheng District, Taipei City 100202, Taiwan
Estimate of the probable value (or amount of any donation): Flights £6,090, Accommodation £435, Taxis £240, Meals £158, value £6,923
Destination of visit: Taiwan
Dates of visit: 17 January 2026 to 21 January 2026
Purpose of visit: Meeting with Taiwanese officials
(Registered 11 February 2026)

Name of donor: Observer Research Foundation
Address of donor: 20 Rouse Avenue Institutional Area, Near Bal Bhavan, ITO, New Delhi 110002, India
Estimate of the probable value (or amount of any donation): Return flights (£3,922), accommodation including food (£666), Airport Transfers (£37), value £4,625
Destination of visit: India (Delhi)
Dates of visit: 4 March 2026 to 8 March 2026
Purpose of visit: Political and Commonwealth War Graves Commission meetings.
(Registered 2 April 2026)

Name of donor: Hudson Institute
Address of donor: 1201 Pennsylvania Avenue NW, Suite 400, Washington, DC 20004
Estimate of the probable value (or amount of any donation): Flights (£5455.59) Accommodation (£1335.22) Transport (£197.99), value £6,988.80
Destination of visit: United States
Dates of visit: 19 April 2026 to 27 April 2026
Purpose of visit: Attending meetings organised by Hudson Institute which is a think tank.
(Registered 22 May 2026)

Name of donor: Hudson Institute
Address of donor: 1201 Pennsylvania Avenue NW, Suite 400, Washington, DC 20004
Estimate of the probable value (or amount of any donation): Flights (£10,729.80) and accommodation (£1,139.90), value £11,868.70
Destination of visit: United States (San Francisco)
Dates of visit: 3 May 2026 to 8 May 2026
Purpose of visit: Attending meetings organised by Hudson Institute.
(Registered 30 May 2026)

Name of donor: Sihtasutus Rahvusvaheline Kaitseuuringute Keskus (International Centre for Defence and Security)
Address of donor: Narva mnt 63/4, Tallinn 10120, Estonia
Estimate of the probable value (or amount of any donation): Flights (£1.323.54), accommodation (£554.70), car from airport (£18), value £1,896.24
Destination of visit: Estonia (Tallinn)
Dates of visit: 13 May 2026 to 16 May 2026
Purpose of visit: Speaking at the Lennart Meri Conference.
(Registered 13 June 2026)

Name of donor: (1) Ocean Affairs Council, Taiwan (2) Taiwan Ministry of Foreign Affairs
Address of donor: (1) 4F, No. 25, Chenggong 2nd Rd., Qianzhen Dist., Kaohsiung City 806614, Taiwan (R.O.C.) (2) 2 Ketagalan Boulevard, Zhongzheng District, Taipei City 100202, Taiwan
Estimate of the probable value (or amount of any donation): (1) Flights (£9,632), accommodation (£414), food (£138) and local transport (£46), value £10,230 (2) Flights (£110) and bus (£210) for an additional visit to Kinmen Island (Taiwan) undertaken on 9 July 2026, value £320
Destination of visit: Taiwan
Dates of visit: 5 July 2026 to 10 July 2026
Purpose of visit: For the purpose of speaking on a geopolitical panel at the Ocean Affairs Council Forum.
(Registered 7 August 2026)

Type of land/property: Residential property (flats)
Number of properties: 4
Location: Essonne, France
Ownership details: Owned jointly with three family members
(Registered 4 June 2015)

Type of land/property: Agricultural land (including forestry)
Location: Essonne, France
Ownership details: Owned jointly with eleven family members
(Registered 4 June 2015)

Name of company or organisation: AccuRx Ltd
Nature of business: A software company building technology to improve communication in healthcare.
Interest held: from 23 March 2026
(Registered 23 March 2026)

Chairman of the Conservative Friends of Afghanistan.
Date interest arose: 25 March 2019
(Registered 1 April 2019)

Commissioned officer in Royal Naval Reserve.
Date interest arose: 1 April 2022
(Registered 12 April 2022)

Distinguished Fellow at the Hudson Institute, Washington DC, USA
Date interest arose: 1 February 2025
(Registered 26 February 2025)

Chairman of the Dossity Advisory Board
Date interest arose: 26 March 2025
(Registered 9 April 2025)

Commissioner of the Commonwealth War Graves Commission. This is an unpaid role.
Date interest arose: 1 May 2025
(Registered 8 May 2025)

Member of the Advisory Board of United Against a Nuclear Iran. This is a non-profit that campaigns against Iran's nuclear ambitions. This is an unpaid role.
(Registered 23 June 2025)

Appointment as a patron of Hong Kong Watch. This is an unpaid role.
Date interest arose: 27 June 2025
(Registered 27 June 2025)

Parliamentary patron of the Conservative Friends of CANZUK. This is an unpaid role.
Date interest arose: 1 July 2025
(Registered 16 July 2025)

Holding below registrable threshold in Juliand Digital Ltd (productivity software). These shares were transferred to a blind trust in May 2023 and returned August 2025.
Date interest arose: 22 August 2025
(Registered 4 September 2025)

Name of donor: Brox.AI
Advisory Board Member (I have a shareholding that is below the threshold for registration under Category 7)
Date interest arose: 23 December 2025
(Registered 6 February 2026)

Name of donor: International Centre for Defence and Security
Member of the International Advisory Board [unpaid]
Date interest arose: 31 January 2026
(Registered 6 February 2026)

Name of donor: Peace.com, Inc/Peace Planet Ltd
Advisory Board Member (I have a shareholding that is below the threshold for registration under Category 7).
Date interest arose: 2 February 2026
(Registered 6 February 2026)

Chairman of the Conservative Friends of Hong Kong. This is an unpaid role.
Date interest arose: 27 January 2026
(Registered 11 February 2026)

Member of the Leadership Council, Fortify Rights. This is an unpaid role.
Date interest arose: 23 February 2026
(Registered 23 February 2026)

Chairman, Conservative Friends of Hong Kong. This is an unpaid role.
Date interest arose: 23 January 2026
(Registered 23 February 2026)

Advisory Board Member for the Committee for Freedom in Hong Kong Foundation. This is an unpaid role.
Date interest arose: 21 May 2026
(Registered 27 May 2026)

Shareholding in Beauhurst Ltd (corporate data). (This interests is below the threshold for registration under Category 7.)
Date interest arose: 19 June 2026
(Registered 23 June 2026)