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Letter of Complaint to Mark Lewin the Returning Officer & Chief Executive IOM Government 15 September 2026

• Dear Mark
• I am writing directly to you in your capacities as Chief Executive and Returning Officer concerning the conduct of the Chair at the Cabinet Office-organised Douglas Central pre-election meeting at Ballakermeen High School on Tuesday 8 September 2026.
• I know you personally, and I believe that we have mutual respect for one another. I therefore hope you will receive this complaint in the constructive spirit in which it is made. Nevertheless, the matters raised are serious and, with the General Election taking place on 24 September, require urgent attention.
• At approximately 28:45 in the official recording, the Chair introduced himself as follows:

“My name is Captain Steven Carter, and I’m the Captain of the Parish of Lonan, and I have been appointed by the Cabinet Office to chair this meeting.”

• There is therefore no ambiguity about Captain Carter’s identity or the authority under which he was acting.
• My complaint concerns:

1. Captain Carter’s departure from the political impartiality expected of a Cabinet Office-appointed chair;
2. his description of my policy as “a little disingenuous”;
3. his subsequent attempt to prohibit “generalized accusations against the government”;
4. his warning that anyone making such accusations would be asked to leave;
5. the resulting chilling effect upon my participation; and
6. the temporary unavailability of the official recording.

My prepared speech

• At approximately 36:01, I began delivering my prepared three-minute candidate speech.
• It was plainly visible to Captain Carter and the other candidates that I was reading from printed pages. They were propped against a bottle of water so that I could hold the microphone and keep one hand free for gestures. I was not making an improvised allegation in the heat of debate.
• My speech began with the story of my five-year-old son asking me to draw a square with three lines. I used the story to illustrate how a fresh perspective can produce a solution which conventional thinking has overlooked.
• I then announced Transform Isle of Man’s proposal to pursue legislation providing a time-limited, conditional amnesty for politicians and civil servants who make a full and truthful disclosure of serious wrongdoing in public office.
• I explained that those responsible would not be allowed to remain in positions of public trust, but that those who came forward, told the whole truth and cooperated fully would be protected from prosecution for what they disclosed.
• The purpose of the policy is to help establish what, if anything, has happened to our public finances over the past twenty years and to reset the culture of political life on the Isle of Man.
• In my speech, I referred to “a culture that has allowed incompetence, corruption or both to flourish.” For greater caution, I have since decided that the printed manifesto will say “a culture that may have allowed incompetence, corruption or both to flourish.” That amendment is not an admission that my original statement was dishonest or improper.
• This was a policy proposal for establishing the truth. It was not an allegation that an identified politician or civil servant had committed a particular criminal offence.

Captain Carter’s “disingenuous” comment

• At approximately 39:10, Captain Carter intervened and said:

“I think that is a little disingenuous.”

• For completeness, this occurred just after the expiration of my three-minute allocation. I accept that Captain Carter was entitled to bring my speech to a conclusion on timekeeping grounds.
• My complaint is not that he enforced the time limit. It is that he departed from neutral timekeeping and publicly expressed an adverse political judgement about my policy.
• The word “disingenuous” is capable of implying insincerity, calculated lack of candour or an intention to mislead. A neutral intervention would have been to state that my time had expired and allow the policy to be questioned during the subsequent discussion.
• When I responded that I could provide evidence during the discussion and asked whether I might finish, Captain Carter replied:

“Yes. Yes. Just quickly.”

• I then completed the final lines of my prepared speech.

Parliamentary privilege and the warning about removal

• At approximately 53:36, after the candidate speeches and immediately before questions from the audience, Captain Carter returned to the subject.
• He reminded candidates that they did not have parliamentary privilege. He then said:

“I would not have anybody making accusations—generalized accusations against the government.”

• He continued:

“If anybody makes any accusations like that, I shall ask you to leave the meeting.”

• Although Captain Carter used the words “anybody” and “candidates,” his reference to accusations “like that” plainly connected the warning to an earlier statement. In context, I reasonably understood his remarks as directed primarily at me and at the criticism of governmental culture contained in my prepared speech.
• The warning was not confined to knowingly false statements, personal abuse or defamatory allegations against identifiable individuals. It purported to prohibit generalised “accusations against the government.”
• That is an exceptionally broad restriction to impose at an election meeting. Candidates must be free to scrutinise government, public administration and the handling of public money, subject always to the ordinary law and reasonable rules of conduct.
• Captain Carter suggested that there was nobody present to defend against the accusations. However, I had not accused an identified absent person of committing an offence. I had criticised governmental culture generally. Moreover, the serving Treasury Minister was present as a fellow candidate.
• I would therefore be grateful for an explanation of precisely whose interests Captain Carter believed he was protecting and what authority entitled him to restrict general political criticism of the Government.

Contemporaneous evidence of the chilling effect

• The effect of Captain Carter’s warning became apparent almost immediately.
• At approximately 56:26, I began answering the first audience question, which concerned government reserves and pensions. While expressing concern about the Island’s finances, I said at approximately 57:15:

“I’m not allowed to say anything, but…”

• That was an unprepared and contemporaneous expression of how I understood Captain Carter’s warning. It was not a description constructed after the event.
• I continued attempting to answer the question, but I felt harassed and constrained. My complaint is not that I was rendered completely silent. It is that I believed I had to qualify and restrict legitimate criticism of the Government because further remarks could expose me to another intervention or removal from the meeting.
• The warning therefore had a demonstrable chilling effect upon my participation in an official election event.

Subsequent publication by Chris Thomas

• Chris Thomas, the Treasury Minister and a fellow Douglas Central candidate, subsequently published the following account:

“There was a shocking moment in the Douglas Central hustings when George Hargreaves, Transform IOM leader, announced a new policy of an amnesty for politicians and civil servants who had committed criminal offences. He provided no evidence and the allegation seemed to relate to film.“ I pulled him up, as did the chair.”

• Mr Thomas’s statement provides contemporaneous confirmation of his understanding that both he and Captain Carter had intervened against me.
• It also materially recasts what I said. “Serious wrongdoing” is not synonymous with a proven criminal offence. I proposed a mechanism through which possible wrongdoing could be disclosed and investigated; I did not accuse an identified person of committing an offence.
• When Captain Carter challenged me, I expressly offered to provide evidence during the discussion. Furthermore, my prepared speech did not mention Mr Thomas, CinemaNX, the Media Development Fund or any other film matter. The suggestion that the policy “seemed to relate to film” was Mr Thomas’s own inference.
• I am obtaining legal advice concerning the potentially defamatory implications of the statements made and subsequently published. I expressly reserve all my legal rights.

The principle underlying the policy

• Transform Isle of Man’s policy is not intended to trivialise or conceal wrongdoing. Nor would it allow anyone who had abused public office to continue occupying a position of public trust.
• Its underlying principle is broadly comparable to the truth-and-reconciliation approach adopted in South Africa: complete and truthful disclosure may sometimes be necessary if a society is to uncover past wrongdoing and move forward.
• It also reflects a principle shared by Christianity and other faith traditions that admission of wrongdoing can open the way to forgiveness, reconciliation and restoration.
• Candidates were entitled to disagree with the policy and subject it to rigorous questioning. The person appointed by the Cabinet Office to chair the meeting should not, however, have adopted a partisan position upon its merits or restricted legitimate criticism of government.

Temporary unavailability of the recording

• Following the meeting, the official recording was found to be unavailable online at a time when recordings of other Cabinet Office constituency meetings remained accessible.
• This concern was raised publicly and contemporaneously by my fellow Transform Isle of Man candidate, Creena Mason. Commenting on a post published by the verified Isle of Man Government Facebook account, she asked:

“Can you tell me why the recording isn’t available? Thanks”

• A screenshot of that exchange is attached. It shows that Creena’s question had been posted four days before the screenshot was taken. No response from the Isle of Man Government is visible in the captured exchange.
• I recognise that the screenshot does not, by itself, establish why the recording was unavailable or who was responsible. It does, however, corroborate that its unavailability was noticed and publicly questioned at the time.
• I have since obtained a copy of the recording and transcript. The recording was published at:
• https://www.youtube.com/live/rEfmcOw_w1Q
• Video ID: rEfmcOw_w1QPlease confirm:

1. whether the recording was removed, restricted, unpublished or temporarily made unavailable;
2. the period during which it was unavailable;
3. why its availability changed;
4. who authorised or implemented that change;
5. whether Creena Mason’s public query was seen or referred to the Cabinet Office; and
6. whether the original recording, publication data and associated records remain preserved.

• I do not presently allege that the recording was made unavailable in order to conceal the incident. I do, however, require a transparent explanation, particularly because it contains the best contemporaneous evidence of my complaint.
• Please ensure that no relevant recording, transcript, metadata, viewing data, instructions, correspondence or other material is deleted, overwritten or altered while this complaint and any contemplated legal proceedings remain outstanding.

Action requested

• I ask you to arrange:

1. preservation of all relevant evidence;
2. disclosure of the rules, instructions and briefing supplied to Captain Carter;
3. identification of the rule which I was considered to have breached or been at risk of breaching;
4. an explanation of how describing my policy as “a little disingenuous” was compatible with the impartiality expected of a Cabinet Office-appointed chair;
5. identification of the authority under which Captain Carter purported to prohibit generalised accusations against the Government;
6. confirmation of whether any other candidate was similarly criticised, warned or threatened with removal;
7. an investigation conducted by someone who had no involvement in organising or chairing the meeting;
8. an appropriate apology and public correction if the investigation concludes that the required standard of neutrality was not maintained; and
9. assurance that Transform Isle of Man and its candidates will receive fair and impartial treatment throughout the remainder of the election.

• Please acknowledge this complaint and confirm preservation of the evidence within two working days.
• As the General Election takes place on 24 September, I would be grateful for a substantive response as soon as reasonably possible and, in any event, within five working days.
• Accountability is one of the foundational principles of Transform Isle of Man. It applies to us just as it applies to politicians and government.
• If we are unwilling to defend our own right to participate fairly in the democratic process, the electorate could reasonably question whether we would defend their rights when entrusted with public office.
• I hope that, given the mutual respect which I believe exists between us, you will ensure that this matter is examined openly, impartially and with the urgency necessary to protect public confidence in the election process.
• Yours sincerely,
• George

George Hargreaves BA (Hons) Lond., MSt Oxon, Dip. Theol. Oxon, AKC

Candidate for the House of Keys for Douglas Central

Leader of the Transform Isle of Man Party

73-75 | Strand Street | Douglas | Isle of Man |IM1 2EN

+44 7624 266380 | jgh@transformiom.im 

www.transformiom.im

Youtube Video: 

https://www.youtube.com/live/rEfmcOw_w1Q

Relevant timestamps: 39:10, 53:36–54:17 and 56:26–57:17.

Letter of Complaint to Mark Lewin the Returning Officer & Chief Executive IOM Government 16 September 2026

• Dear Mark,
• I wish to make a further formal complaint concerning a separate matter. This complaint relates to the handling of my request for nomination papers for the Marown Commissioners by election and the advice reportedly given by the Crown and Elections Team.
• I attach a Word document containing the complete email exchange with Ms Devereau. Please note that the emails appear in reverse chronological order, with the most recent email first.
• On 5 September 2026, I contacted the Clerk to Marown Parish Commissioners in the following terms:
• “Dear Mrs Devereau, I noted on our Community Notice Board in Ballagarey Road that there is to be a by election for the Marown Commissioners. Please urgently send me all documentation necessary to contest the by election.”
• The request came from me as Leader of Transform Isle of Man. I did not state that I personally intended to stand in the election. Nor did I ask for advice about my eligibility or the compatibility of membership of the House of Keys with membership of a local authority.
• Instead of simply providing the requested election documents, Ms Devereau assumed that I personally intended to stand. She then identified my candidacy in the House of Keys General Election and contacted the Crown and Elections Team about my circumstances.
• On 7 September, Ms Devereau informed me:
• “I have just spoken with the Crown and Elections Team as I was unsure of the protocol and they have explained that you are not able to be an MHK and a Commissioner and you therefore need to decide which position you want to stand for.”

She continued:

• “If you want to proceed to stand as a Commissioner, and not as an MHK, then please let me know and I will send you the relevant paperwork to complete.”
• Ms Devereau therefore declined to provide the requested documents unless I confirmed that I would abandon my candidacy for the House of Keys.
• This imposed an additional condition upon access to the nomination process. No statutory basis for that condition was identified. It was particularly serious because nominations closed at 1pm on 9 September, only two days after Ms Devereau’s response.
• I challenged the position and asked Ms Devereau to identify the relevant legislation. In her subsequent response, she relied upon section 29 of the Elections (Keys and Local Authorities) Act 2020. That section provides that a member of a local authority who becomes a member of the Legislative Council or the House of Keys ceases to be a member of the local authority.
• Section 29 concerns the simultaneous holding of two offices. It does not state that a person is prohibited from standing as a candidate in elections taking place on different dates. At the time of the correspondence and the close of nominations, I was not an MHK.
• Ms Devereau did not identify any provision expressly preventing such a nomination. She nevertheless sent the papers on the stated basis that my wife might wish to stand. This confirms that the documents were readily available, but they had not been provided in response to my original request.
• This complaint is not simply about a difference of legal interpretation. A request for election documentation was made by the Leader of a registered political party. Without first asking who the intended candidate might be, the Clerk assumed that I intended to stand, investigated my personal eligibility and introduced an objection based upon my candidacy in another election.
• This raises an additional question of consistency and impartiality. The correspondence does not indicate whether the Clerk made enquiries about the eligibility or personal circumstances of the other prospective or declared candidate in the Marown election. If enquiries were made only about me, I require an explanation of why I was singled out for additional scrutiny.
• I request that this complaint be investigated formally and that I receive answers to the following questions:

1. Why were the requested nomination papers not supplied immediately in response to my original request?
2. Why did Ms Devereau assume that I personally intended to stand when my email did not say this?
3. Why did Ms Devereau investigate my circumstances before establishing the identity of the intended candidate?
4. Who within the Crown and Elections Team advised Ms Devereau that I had to decide which position I wanted to stand for?
5. What precise statutory provision or regulation was relied upon when that advice was given?
6. What exactly did Ms Devereau tell the Crown and Elections Team, and what was the complete advice given in response?
7. Did the Crown and Elections Team advise Ms Devereau not to provide the nomination papers unless I abandoned my House of Keys candidacy?
8. Why was section 29 treated as a prohibition upon candidacy when its wording concerns the holding of office?
9. Did Ms Devereau contact the Crown and Elections Team about the eligibility or personal circumstances of the other prospective or declared candidate in the Marown by election?
10. If no equivalent enquiry was made about the other candidate, why was I subjected to scrutiny that was not applied to that person?
11. Were any other individuals required to establish their eligibility, or answer questions about other public offices or candidacies, before being supplied with the nomination documents?
12. What steps will now be taken to ensure that election documents are provided promptly, consistently and impartially?

• Please preserve all records relating to this matter, including emails, internal messages, telephone logs, call recordings, handwritten notes and communications between Ms Devereau, Marown Parish Commissioners, the Crown and Elections Team and any other public official.
• I understand that calls to government offices may be recorded for training, monitoring or other purposes. If the relevant telephone conversation was recorded, that recording must be preserved pending the investigation and any subsequent proceedings. If no recording exists, please confirm whether the call was recorded, the applicable recording and retention policy, and whether any recording was deleted or overwritten after the date of the call.
• I request copies of all records of the enquiry made concerning me and the advice given in response, subject only to any redactions strictly required by law.
• Because this matter concerns access to an election and the impartiality of those responsible for administering the democratic process, I ask that the complaint be investigated by someone who was not involved in the original enquiry or advice.
• For the avoidance of doubt, this is a separate complaint from the complaint I submitted yesterday, and I ask that it be recorded and investigated separately.
• Please acknowledge receipt of this complaint and its attachment, identify the complaints procedure being followed and provide the anticipated date for a substantive response.
• Kindest regards,
• George