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Established in 2001 by a group of Conservative members of Parliament, Policy Exchange is a think tank that was intended to mark a shift in British conservatism towards more liberal social attitudes mixed with right-wing economic policy. Its founders believed the Conservatives were an out of touch party which had put off potential voters through its negativity, xenophobia and social conservatism.
The institution steadily made a name for itself in conservative circles until David Cameron—who had launched his campaign for leadership of the Tories at a Policy Exchange event in 2005—was elected prime minister. At that point, Policy Exchange scholars and thinkers, including the likes of Alexander Meleagrou-Hitchens, began attracting more widespread attention and in some cases landed influential government roles.
The organization is mostly focused on British domestic issues, but it has a significant voice in Conservative foreign policy as well. Its views are closely associated with neoconservatism in the United States. Its director, Dean Godson, began his tenure at Policy Exchange in 2005 as its lead researcher on “Terrorism and Security” and soon became director of its International Program. In 2013, he was elevated to the post of director of the entire think tank.
A Right Web report summed up Godson’s neoconservative background, saying “Godson began his career as special assistant to John Lehman, a secretary of the navy under Ronald Reagan who has supported the work of a number of neoconservative groups in the United States, including the Project for the New American Century, the Center for Security Policy, and the Cold War-era version of the Committee on the Present Danger. He also worked as librarian to Sir James Goldsmith, and as special assistant to Conrad Black.”
Policy Exchange added International Trade and Security and Extremism to its areas of study under Godson, reflecting his greater emphasis on foreign affairs and terrorism. Although—like most British political institutions across the spectrum—it has been forced to devote a significant amount of its resources to Brexit after the UK voted to leave the European Union, Policy Exchange has continued to focus on the Muslim community, both within and outside of Britain.
Most recently, Policy Exchange issued a report entitled Defining Islamophobia which assailed a report by the All-Party Parliamentary Group (APPG) on British Muslims which sought to do just that. The APPG issued a basic definition which it urged both the government and civil society to adopt: “Islamophobia is rooted in racism and is a type of racism that targets expressions of Muslimness or perceived Muslimness.” The report—authored by Ambassador Sir John Jenkins with an extensive preamble by Trevor Phillips, a senior fellow at Policy Exchange—argued that the APPG definition was too vague and could threaten any criticism of Islam as well as present a challenge to the British government in its efforts to counter “violent extremism.”
Jenkins—who served as UK ambassador to Syria, Iraq, Libya, and Saudi Arabia, among other roles—led a Policy Review into the Muslim Brotherhood and Political Islamism in 2014. His report concluded that “for the most part, the Muslim Brotherhood have preferred nonviolent incremental change on the grounds of expediency. …But they are prepared to countenance violence—including, from time to time, terrorism—where gradualism is ineffective. They have deliberately, wittingly and openly incubated and sustained an organization—Hamas—whose military wing has been proscribed in the UK as a terrorist organisation (and which has been proscribed in its entirety by other countries). … Aspects of Muslim Brotherhood ideology and tactics, in this country and overseas, are contrary to our values and have been contrary to our national interests and our national security.”
Phillips—in an accompanying op-ed in the Times of London—argued “To define Islamophobia as “anti-Muslim” racism means, in effect, that all Muslims should be treated exactly as others are. But tackling Muslim disadvantage demands different treatment, with prayer rooms, special holiday arrangements and so on. Combating racial disadvantage necessitates the opposite, ensuring that people are treated similarly irrespective of their ethnicity.”
Jenkins’ and Phillips’ report alleged that the APPG was unduly influenced by a Muslim group called MEND [Muslim Engagement and Development], “an organisation with a tarnished reputation in Government circles.” Yet MEND—then called iEngage—was commended in 2014 by the World Economic Forum as an example of “best practice” in “Human Rights Promotion and Protection.”
While right wing outlets—such as Breitbart News, for example—supported the Policy Exchange paper, others commended the APPG definition. “Short and accessible, the new definition is neither too complex nor overly academic, which maximises its potential appeal to both public and political audiences,” wrote Chris Allen, an associate professor in Hate Studies at the University of Leicester. “While the working definition is unlikely to appease those who ultimately deny Islamophobia’s existence, if it draws attention to Islamophobia and its negative consequences, that can only be a good thing.”
In July 2018, several Policy Exchange associates—Richard Ekins, Patrick Hennessey, and MPs Khalid Mahmood, and Tom Tugendhat—authored a paper strongly urging the UK government to update the legal definition of “treason” so it could be applied to UK citizens who joined or attempted to join ISIS or similar groups. Entitled Aiding the Enemy: How and why to restore the law of treason, the paper argued that existing laws against treason were outdated and inadequate and that the act of betrayal itself must be harshly penalized in addition to whatever criminal acts the treason may have embodied.
“The offence would be of general application and may be of increasing importance in an age of rising great power competition in which the UK faces the threat of attacks. … fromhostile states that are designed to fall short of international armed conflict,” write the authors.
One high-ranking official in the Conservative government, Amber Rudd, applauded the report, telling reporters, “The time has come for us to consider additional measures, such as those set out in this report, that we need to deal with those who betray this country.”
The report was issued at a particularly sensitive time. The Tory home secretary, Sajid Javid, had ignited a furious public debate when he decided to help the United States to convict two captured ISIS fighters who had been UK citizens until their citizenship was stripped over the allegations. As a conviction in the U.S. could carry a penalty of death, many British citizens objected to Javid’s decision, saying he had taken “the power of life and death into his own hands.” There were calls for the two men to be brought back to the UK for trial.
In January 2019, the High Court rejected a petition that would have required Javid to get assurances from the U.S. that it would not seek the death penalty before he could share the information Britain had on the case. Policy Exchange spoke approvingly of the decision and contended that their recommendations regarding the treason laws would “help prevent this happening in the first place.”
Taking on the Policy Exchange report directly, British pundit Kenan Malik wrote, “The existence of a nation state as a political community is vital to the healthy function of democracy. But that community does not have a claim upon the individual in some essentialist fashion. Nor can it be the only call on an individual’s moral conscience.” He warned of the many historical and contemporary incidents of the charge of treason being levied against political opponents. “The charge of betrayal is to politics as that of apostasy is to religion.
“Jihadists should be tried for their actions,” Malik concluded. “Those actions do seek to undermine social trust and to break the bonds that hold communities together. Labellingthem traitors will do little, however, either to challenge jihadism or to restore trust.”
A Controversial History
Policy Exchange has a history of controversy. In 2008, Nick Clegg—the leader of the Liberal Democratic Party at the time—lashed out at Policy Exchange for circulating a dossier that made the case for boycotting a Global Peace and Unity event in London meant to promote dialogue between Muslim and non-Muslim communities and accused some of the participants of being “extremists.” Clegg, a key figure in British politics at the time, questioned the accuracy of Policy Exchange’s report and the basis for its claims. “In particular I was appalled to see ‘evidence’ quoted from the Society for American National Existence, an organisation which seeks to make the practice of Islam illegal, punishable by 20 years in prison,” Clegg wrote. “I need hardly point out how illogical it is to attempt to criticise one set of extreme views by citing another. …That a think-tank professing to promote ‘a free society based on strong communities [and] personal freedom’ would act to undermine tolerance across our society worries me greatly.”
A year earlier, Policy Exchange had come under fire for a report entitled “The Hijacking of British Islam.” The report suggested that a full 25 percent of UK mosques were disseminating “politically radical material.” That conclusion was based on receipts they produced showing the purchase of allegedly radical literature from the mosques. The BBC show Newsnight was prepared to run a segment on the report but determined that at least some of the receipts Policy Exchange had presented may have been fraudulent.
Dean Godson of Policy Exchange accused the BBC of “bottling up” the report, which led BBC news editor Peter Barron to respond with the BBC’s conclusions about the five receipts in question, based on the examination of a forensic scientist who had concluded they were likely forgeries. “Mr Godson says he stands by his report 100 percent. I also stand by our report 100 percent. I don’t think we can both be right.” The report was removed from the Policy Exchange web site by March 2009, replaced with a message acknowledging that one of the sites they had accused of disseminating the questionable material had not done so.
Policy Exchange got a zero star rating on funding transparency in 2016 from Transparify, a project of the Open Society Institute which tracks the transparency of think tanks’ funding. According to their report, Policy Exchange is one of only four UK think tanks that “still consider it acceptable to take money from hidden hands behind closed doors.”
In a separate article in 2017, the organization expressed its concern that Policy Exchange’s opacity enables questionable practices, writing, “Policy Exchange has previously used evidence that appears to have been fabricated; the resulting report led to fake news headlines in several media outlets that had naively trusted ‘research’ conducted by an opaque think tank.”
Who Funds You, another organization tracking funding transparency stated that Policy Exchange took in £3,553,565 in fiscal year 2017, but also gives the think tank its lowest grade, E, for transparency.
 Andy Beckett, “What can they be thinking?” The Guardian, September 25, 2008, https://www.theguardian.com/politics/2008/sep/26/thinktanks.conservatives
 David Miller, “Reactionary Censorship in the UK: The Case of SpinProfiles,” Right Web, August 18, 2010, https://rightweb.irc-online.org/reactionary_censorship_in_the_uk_the_case_of_spinprofiles/
 Sir John Jenkins, “Defining Islamophobia: A Policy Exchange Research Note,” Policy Exchange, December 20, 2018, https://policyexchange.org.uk/wp-content/uploads/2018/12/Defining-Islamophobia.pdf
 Tom Barnes and Shehab Khan, “Government urged to adopt new definition of Islamophobia following rise in hate crimes,” The Independent, December 13, 2018, https://www.independent.co.uk/news/uk/politics/islamophobia-definition-racism-uk-british-muslims-letter-government-discrimination-a8682621.html
 “Muslim Brotherhood Review: Main Findings,” House of Commons, December 17, 2015, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/486932/Muslim_Brotherhood_Review_Main_Findings.pdf
 Trevor Phillips, “It’s wrong to treat British Muslims as a racial group,” Times of London, December 20, 2018, https://www.thetimes.co.uk/article/it-s-wrong-to-treat-british-muslims-as-a-racial-group-9xj8bf0vx
 Global Agenda Council on the Role of Faith, “Why Care about Faith?” World Economic Forum, September 2014, http://www3.weforum.org/docs/GAC/2014/WEF_GAC_RoleFaith_WhyCareAboutFaith_Report_2014.pdf
 Victoria Friedman, “Extremist-linked Muslim Group ‘Exerted Decisive Influence’ on Govt ‘Islamophobia’ Report,” Breitbart News, December 22, 2018, https://www.breitbart.com/europe/2018/12/22/controversial-muslim-lobby-group-mend-influence-uk-first-islamophobia-report/
 Chris Allen, “Why UK’s working definition of Islamophobia as a ‘type of racism’ is a historic step,” The Conversation, November 27, 2018, https://theconversation.com/why-uks-working-definition-of-islamophobia-as-a-type-of-racism-is-a-historic-step-107657
 Richard Ekins, Patrick Hennessey, and MPs Khalid Mahmood, and Tom Tugendhat, “Aiding the Enemy: How and why to restore the law of treason,” Policy Exchange, July 25, 2018, https://policyexchange.org.uk/wp-content/uploads/2018/07/Aiding-the-Enemy.pdf
 Vikram Dodd and Jessica Elgot, “Javid accused of assuming ‘power of life and death’ over Isis suspects,” The Guardian, July 24, 2018, https://www.theguardian.com/law/2018/jul/24/uk-may-face-legal-challenge-over-us-extradition-of-isis-pair
 Policy Exchange, Twitter, January 19, 2019, https://twitter.com/Policy_Exchange/status/1086237180241027073
 Kenan Malik, “If we want to build trust in society, a new treason law is no way to do it,” The Guardian, July 29, 2018, https://www.theguardian.com/commentisfree/2018/jul/29/if-we-want-to-rebuild-trust-in-society-a-new-treason-law-is-no-way-to-do-it
 The correct name of the organization is Society of Americans for National Existence. You can find out more about them in their Right Web profile. https://rightweb.irc-online.org/profile/society_of_americans_for_national_existence/
 Mark Pack, “Nick Clegg attacks Policy Exchange for “offensive” and “underhand” briefing,” Liberal Democrat Voice, October 24, 2008, https://www.libdemvoice.org/nick-clegg-attacks-policy-exchange-for-offensive-and-underhand-briefing-5064.html
 Tom Griffin, “Who Are the ‘Eurocons’?” Right Web, December 4, 2009, http://rightweb.irc-online.org/who_are_the_eurocons/
 Peter Barron, “Disastrous misjudgement?” BBC News, December 13, 2007, http://www.bbc.co.uk/blogs/theeditors/2007/12/disastrous__misjudgement.html
 Sunny Hundal, “ Exclusive: Policy Exchange forced to apologise; takes report off website,” Liberal Conspiracy, March 30, 2009, http://liberalconspiracy.org/2009/03/30/exclusive-policy-exchange-forced-to-apologise-takes-report-off-website/
 Transparify, Tbilisi/Georgia, “How Transparent are Think Tanks about Who Funds Them 2016?” Transparify, June 29, 2016, https://static1.squarespace.com/static/52e1f399e4b06a94c0cdaa41/t/5773022de6f2e1ecf70b26d1/1467154992324/Transparify+2016+Think+Tanks+Report.pdf
 Till Bruckner, “Think tanks, evidence and policy: democratic players or clandestine lobbyists?” LSE Impact Blog, February 8, 2017, http://blogs.lse.ac.uk/impactofsocialsciences/2017/02/08/think-tanks-evidence-and-policy/