The House of Lords commissioner for standards has launched an investigation into the Conservative peer Michelle Mone, relating to the PPE company awarded £203m government contracts via the “VIP lane” after she referred it to the Cabinet Office in May 2020.

The investigation follows a complaint by the Labour peer George Foulkes on 6 January, after the Guardian reported that leaked files appear to suggest Lady Mone and her husband, the Isle of Man-based financier Douglas Barrowman, were secretly involved in the company, PPE Medpro.

Foulkes asked the commissioners to investigate whether Mone may have breached the Lords code of conduct by failing to declare an interest in the company, and by lobbying for it to be awarded government contracts.

The commissioner confirmed that the investigation would be for “alleged involvement in procuring contracts for PPE Medpro, leading to potential breaches” of three provisions of the Lords code, which cover the requirement that peers publicly register “all relevant interests”, and prohibit them from lobbying for a company or a person in which a peer “has a financial interest”.

The commissioner also stated that Mone would be investigated under the more general provisions of the code’s paragraph 9, which includes that peers “should always act on their personal honour”; must never accept “any financial inducement as an incentive or reward for exercising parliamentary influence”; and “must not seek to profit from membership of the house by accepting or agreeing to accept payment or other incentive or reward in return for providing parliamentary advice or services.”

Mone, appointed a Conservative peer by David Cameron in 2015 after selling an 80% stake in her Ultimo lingerie company, has consistently denied any “role or function” in the company, and her lawyers have said she is “not connected to PPE Medpro in any capacity”.

The possible sanctions for a peer found to have breached the code of conduct, which are determined by the conduct committee, range from merely having to correct a breach, to the most serious penalty of expulsion from the Lords.

PPE Medpro was awarded an £80.85m contract in May 2020 to supply face masks, followed by a £122m contract in June 2020 to supply 25m surgical gowns. Barrowman has also denied being an investor, and his lawyers have said he “was not personally involved in working for PPEM in relation to PPE contracts”.

In December 2020 lawyers for Barrowman and the company also told the Guardian that: “Neither [Barrowman] nor anybody involved with PPEM approached any MPs, peers, government officials, ministers, NHS staff or other health professionals as part of making the approach to the government to offer to supply PPE.”

The sole registered owner of the UK-registered company is Anthony Page, who works for Barrowman’s family office at his Isle of Man financial services firm Knox Group.

In November 2021, following a freedom of information request pursued by the Good Law Project, the government disclosed that Mone had originally referred PPE Medpro to the Cabinet Office, contacting the office of minister Theodore Agnew, her fellow Conservative peer who was responsible for procurement during the Covid pandemic. More recently the government confirmed that Mone made that referral on 7 May 2020, five days before PPE Medpro was even incorporated.

Agnew’s office referred PPE Medpro to the “VIP lane” for politically connected firms, which gave companies a 10 times greater chance of being awarded a contract. The VIP lane was ruled unlawful last week in the high court following a challenge by the Good Law Project.

The Guardian reported on 6 January that leaked files appear to suggest both Mone and Barrowman were involved in the business of PPE Medpro. One person closely involved in PPE Medpro claimed Barrowman was “part of the financial consortium that backed” the company and was even involved in initial conversations with the Department of Health and Social Care (DHSC).

The leaked files appear to suggest that the UK company is effectively a subsidiary of another company named PPE Medpro Ltd, registered in the Isle of Man a day earlier. Barrowman appeared to have been personally involved in setting up agreements for the Isle of Man company with a London importing company, Loudwater Trade and Finance, which would source and supply the PPE.

In one of the agreements, PPE Medpro (Isle of Man) stated that it would use its “extensive network to seek to secure rolling forward order contracts with the NHS and other government bodies within the British Isles”.

From the two contracts, to supply millions of face masks and surgical gowns, the Guardian understands that PPE Medpro may have made in excess of £40m gross profits. The company declined to say whether that figure was accurate.

Mone’s representatives have said she had no interest in PPE Medpro, and denied any wrongdoing.

“The reason why no interest in PPE Medpro appears in Baroness Mone’s register of interests is because no such interest exists,” her lawyer said in December 2020.

Barrowman’s lawyers have said the Guardian’s reporting amounted to “clutching at straws” and was “largely incorrect”.

Mone’s lawyers said the Guardian’s reporting was “grounded entirely on supposition and speculation and not based on accuracy”, adding: “She is under no obligation to say anything to you.”

In a statement, Mone said: “I completely refute these allegations. I was asked to help at a time of national emergency. I declared all necessary interests and have done nothing wrong. I will cooperate fully with any investigation.”

Foulkes told the Guardian: “I welcome the decision of the commissioner to investigate what appears to be breaches of the code of conduct by Baroness Mone under three provisions dealing with failure to register interests and paid lobbying.”