Advisory Committee on Business Appointments

Sir Alex applied for an advertised post as a lay member of the QC Appointments Selection Panel, which is responsible for assessing applications and interviewing individuals who wish to be appointed Queen’s Counsel. It is a limited company and is independent of Government, the Bar Council and the Law Society. The role that he has been offered will take up 30-35 days a year, and he does not expect it to require any contact with Government.

When considering the application the Committee noted that, while Sir Alex had had limited involvement in the setting up of the Panel in 2004, he had had no official dealings with his prospective employer during his last two years of service and that the Panel is independent of Government. It also noted that as he retired over a year ago, the three-month waiting period usually observed by Permanent Secretaries has expired. The Committee also received confirmation from the Cabinet Office that there is no conflict of interest between his new appointment and his position as the Prime Minister’s Independent Adviser on Ministerial Interests.

The Prime Minister accepted the recommendation of the Committee that, the three-month waiting period for Permanent Secretaries having expired, the application be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying Government on behalf of his new employer.  

Dame Christine sought permission to accept an advertised post as the Chair of the Council of the University of Buckinghamshire. She will be responsible for ensuring that the Council exercises effective control over the strategic direction of the university, and that the performance of the University is adequately assessed against the objectives which the Council has approved.

When considering the application,the Committee noted that Dame Christine had had no official dealings with her prospective employer or its competitors.

The Prime Minister accepted the Committee's recommendation that the application be approved subject to the condition that, for two years from her last day of service, she should not become personally involved in lobbying UK government on behalf of her new employer.

Dame Christine sought approval to accept non-executive directorship with the NHS Trust Development Authority, an ‘Arm’s Length Body’ which was established as a special health authority in June 2012 to provide, from April 2013, governance and accountability for NHS trusts in England and delivery of the foundation trust pipeline.  

The Prime Minister accepted the Committee's recommendation that the application be approved subject to the condition that, for two years from her last day of service, she should not become personally involved in lobbying UK government on behalf of her new employer.

Dame Christine sought approval to accept a part-time appointment as Chair of the Local Education and Training Board (LETB) of North and East London. In 2012 Health Education England inherited responsibility for delivering education and training for the NHS. To support it in this work, each region will have its own LETB to take on education and training in their area from March 2013.

The Committee noted that Dame Christine had had no official dealings with her prospective employer, which is a new body set up following the announcement in January 2012 of a new policy framework for education and training of the health workforce. It also noted that she had applied for an advertised post.

The Prime Minister accepted the Committee's recommendation that the application be approved subject to the condition that, for two years from her last day of service, she should not become personally involved in lobbying Government on behalf of her new employer.

Mr Behan sought permission to accept a full-time post as Chief Executive of the Care Quality Commission (CQC), a non-departmental public body sponsored by the Department of Health that regulates all health and social care services in England.

The Committee noted that, due to uncertainty as to whether Mr Behan would remain a civil servant when he took up his new post, the appointment was accepted and announced before its advice had been sought. However, it also noted that the CQC is an NDPB sponsored by the Department of Health and that, as a result, the usual concerns regarding former officials lobbying on behalf of their new employers do not apply here. 

The Prime Minister accepted the Committee's recommendation that the application be approved unconditionally.

Mr Brack sought permission to set up as an independent consultant providing policy research and analysis on aspects of international environmental policy; writing and editing on current political issues and political history; and providing policy research and advice on aspects of UK government and environmental policy.

When considering the application, the Committee noted that Mr Brack had previously had dealings with some of the organisations he listed as possible clients but it recognised that they were not of a contractual nature, that he had contacts with these organisations prior to becoming Special Advisor and that the majority of his work will not be strongly related to his experience at DECC.

The Permanent Secretary accepted the committee’s recommendation that the application be approved on the following terms:

- for six months from his last day of service he should submit a fresh application for any commission he wishes to accept with companies in policy areas within his remit at DECC (Climate policy (UK, EU and international), nuclear, gas, carbon capture and storage, biomass and biofuels, Green Investment Bank, energy-intensive industries and environmental taxation);

- for 12 months from the same date, he should not undertake any work which involves providing advice to any company or organisation on the terms of any bid or contract relating to the work of DECC;

- that, for 2 years from the same date, he should not become personally involved in lobbying UK Government Ministers or Crown servants, including Special Advisers, on behalf of any of his clients; and

- once he has received approval to set up as an independent consultant, he must, for two years from his last day of service, seek confirmation from the Committee directly that each individual commission is permissible under the terms of his consultancy before taking it up. If, after enquiry, the Committee takes the view that a commission is, or may be, outside the terms of the consultancy he will be expected to submit a fresh application.

As with all Special Advisers, the Committee makes this recommendation on the understanding that, if he has not already done so, Mr Brack will be required to confirm in writing to DECC that he recognises that he will continue to be bound by the provisions of the criminal law (including the Official Secrets Act) which protect certain categories of information, and by his duty of confidentiality owed to the Crown.

The Committee noted with concern that Mr Brack had accepted commissions with Chatham House, Westminster Explained, Maitland Communications and WWF before receiving approval for his independent consultancy, yet it finds these commissions permissible under the terms of his consultancy as set out above.

Commissions
November/December 2012 - WWF, Global Witness, Forest Trends, Chatham House/Forest Trends, the Children's Investment Fund Foundation, Understanding Modern/Gov 

Sir Alasdair sought advice about accepting a part-time appointment as a Non Executive Director with UCL Hospital NHS Foundation Trust. The Trust is one of the largest in the UK, made up of seven London hospitals (University College Hospital, the Royal National Throat, Nose and Ear Hospital, the Royal London Hospital for Integrated Medicine, the Hospital for Tropical Diseases, the National Hospital for Neurology and Neurosurgery, the Heart Hospital and the Eastman Dental Hospital). His role will include providing advice on the strategic management of the Trust.

When considering the application, the Committee took into account that Sir Alasdair was not a Permanent Secretary equivalent, he is not subject to a three-month waiting period, and as his proposed appointment raises no concerns in terms of it being a reward or of him having had access to commercially sensitive information or future policy, there would be no difficulty in him taking up the post as he intends immediately after he leaves Crown service.

The Prime Minister  accepted the Committee’s recommendation that the application be approved subject to the condition that,  for two years from his last day of service, he should not become personally involved in lobbying Government on behalf of his new employer.

Mr Brinkley sought permission to set up as an independent consultant, building a London-based portfolio of advisory and non-executive positions, offering strategic advice on international political issues, political risk assessment and a senior interface for dealings with governments and other organisations. Under this consultancy he wished to take up a commission with Associated British Foods plc (ABF). He had been on secondment to ABF from March 2010 until September 2011.

The Foreign Secretary accepted the Committee's recommendation that the appointment be approved subject to the conditions that:

- for 12 months from his last day of service he should not undertake any work which involves providing advice on the terms of any bid or contract relating to the work of the FCO; and

- for two years from the same date, he should not become personally involved in lobbying the UK Government on behalf of any of his clients.

His commission with ABF was approved subject to a waiting period of six months from the date on which his secondment to the company ended in addition to the conditions set out above.

Sir Simon sought permission to take up a full-time appointment as a Programme Director with BAE Systems, with responsibility for delivering the company's military aircraft export programme on the Arabian Peninsula.

Having received detailed advice from the MOD, the Committee noted that Sir Simon had had no commercial dealings with BAE Systems or other companies, and any contact he had had with the company was limited to ensuring that it ha a clear view of Air Command's priorities. It also noted that his proposed role would be solely Middle East facing with no responsibility for UK sales.

The Prime Minister accepted the Committee's recommendation that the application be approved subject to a waiting period of three months from his last day of service, and to the condition that, for two years from the same date, he should not become personally involved in lobbying UK Government on behalf of his new employer.

Ms Phillipa Buckley sought permission to set up as an independent consultant in order to undertake a one-off commission with Malachite Advisors Ltd. Malachite Advisors Ltd is a London based strategic advisory firm that advises multinational organisations on their investments and presence in emerging markets.

When considering this application, the Committee took into account that Ms Buckley will be working in a team of four, contributing to Malachite’s six week project on behalf of a large oil and gas client by conducting desk based research into the political, social and business operating environment in Morocco. The Committee also noted that, whilst she might need to contact and/or meet third parties to seek their views and advice, this commission is not likely to involve representing Malachite’s or its client’s interests to the Government. The Committee took into account the fact that your Department has no relationship with Malachite Advisors Ltd. In addition, the Committee took into account the fact that, during her last two years of service, Ms Buckley has not: had any contractual dealings with her prospective employer; had access to any commercially sensitive information about any of her prospective employer’s competitors; or been involved in the development or administration of any policy or decisions (including the award of grants) that could have affected her prospective employer or its competitors.

The Permanent Secretary of DFID accepted the committee’s recommendation that the application be approved on the condition that, for the duration of her contract with Malachite Advisers Ltd, Ms Buckley should not become personally involved in lobbying UK Government Ministers or Crown servants, including Special Advisers, on behalf of her new employer, its parent company or its clients.

Date of Approval
Approval Letter

Ms Phillipa Buckley sought permission to accept a full-time paid appointment with EleQtra. EleQtra (Infraco) Ltd specialises in infrastructure development, managing private and public sector funds to create investment opportunities in infrastructure (such as power, transport and water) in developing countries.

When considering the application, the Committee took into account the that, during her last two years of service, Ms Buckley has not: had any contractual dealings with her prospective employer; had access to any commercially sensitive information about any of her prospective employer’s competitors; or been involved in the development or administration of any policy or decisions (including the award of grants) that could have affected her prospective employer or its competitors.

The Committee also noted that Ms Buckley has confirmed that this appointment might involve contact and/or dealings with her former Department and/or Government more generally. However, if any contact occurs, it would be with officials in DFID’s country offices where Ms Buckley would be developing a project. The Committee noted that Ms Buckley will not lobby DFID Ministers, officials or special advisers, the aim of any contact being to ensure that in-country officials along with other international donors present in the country were aware of the aims and progress of the project she will be developing.

The Permanent Secretary of DFID accepted the committee’s recommendations that the application be approved subject to the following conditions:

- that for 12 months from her last day of service, she should not undertake any duties that involve advising on the terms of any bid or contract relating to DFID or have contact with senior officials in DFID in relation to any bids or contracts on behalf of her new employer, its parent company or its clients; and

 - that for two years from her last day of service she should not become personally involved in lobbying UK Government Ministers or Crown servants, including Special Advisers, on behalf of her new employer, its parent company or its clients.

Date of approval
Approval letter

January 2013

Sir Andrew sought permission to accept a non-executive directorship with defence contractor General Dynamics UK.

When considering the application the Committee noted that Sir Andrew retired from the Civil Service 15 months ago and that he had had no contractual dealings with General Dynamics whilst in post.

The Prime Minister accepted the recommendation of the Committee that the application be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK government on behalf of his new employer.

The ERDB was established in 1991 to help countries in the region stretching from central Europe, across the Balkans and into central Asia to become open, market economies by providing project financing for banks, industries and businesses. It is owned by 63 countries, the European Union and the European Investment Bank. Sir Suma was nominated by the Chancellor of the Exchequer to be the UK's candidate for the post of President of the Bank and was subsequently elected by its shareholders in May 2012.

The Committee noted with concern that the appointment had been announced before it could provide its advice on it. However, it also noted that Sir Suma had had no official contact with the ERDB as Permanent Secretary of the Ministry of Justice and that he had had only limited contact while he was Permanent Secretary of DFID over four years ago, and that he had been nominated by the Chancellor of the Exchequer and elected by the shareholders. Having received assurances that the public interest was best served by Sir Suma being able to take up the role immediately, the Committee judged that no questions of propriety or public concern arose from the appointment and that therefore the standard three-month waiting period observed by former Permanent Secretaries could be waived.

The Prime Minister accepted the Committee's recommendation that the appointment be approved subject to the condition that, for two years from his last day of service, Sir Suma should not become personally involved in lobbying Ministry of Justice Ministers or officials, including Special Advisers, on behalf of his new employer, the usual three-month waiting period imposed on Permanent Secretaries being waived.

Mr Collington sought permission to accept a full-time post as Chief Operating Officer of recruitment services firm Alexander Mann Solutions.

When considering the application the Committee noted that Mr Collington's new role will focus on the management of AMS' delivery centres and improving efficiency rather than directly engaging with clients or potential clients, and he has stated clearly that he will not be involved in bidding for Government work. It also noted that he has had no official dealings with AMS.

The Prime Minister accepted the Committee's recommendation that the application be approved subject to the conditions that:

- for 12 months from his last day of service, he should not become involved in advising on bids or contracts for Government business; and

- for 2 years from the same date he should not become personally involved in lobbying Governent on behalf of his new employer or its clients. 

Lt Gen Coward sought permission to accept a part-time paid appointment as a non-executive director of Redline Aviation Security Ltd who provide security assessments, audits, training and management support for aviation industry clients. It also undertakes work with two partner companies: Citadel International Security Services Ltd and Robson Handling Technology Ltd.

When considering the application, the Committee noted that the company lists the MOD as a client. However, the Committee noted that Lt Gen Coward had no official dealings with his prospective employer or its competitors during his last two years of service. Furthermore, he was not involved in any MOD decisions that might affect the business of the proposed employer.

The Prime Minister accepted the Committee’s recommendation that the application be approved subject to the conditions that, for 12 months from his last day of service, Lt Gen Coward should not provide advice to his new employer, its partners or clients on any bid or contract directly related to the work of the MOD, and, for two years from the same date, he should not become personally involved in lobbying UK Government on behalf of his new employer, its partners or clients.

Patrick Crawford
Chief Executive, Export Credits Guarantee Department

Mr Crawford sought permission to accept a full-time post as Chief Executive of Charity Bank, which was founded in 2002 by the Charities Aid Foundation to provide loans and guarantees to small charities, social enterprises and community organisations.

When considering the application, the Committee noted that Mr Crawford had had no official dealings with Charity Bank or access to any commercially sensitive information that would affect his application. It also noted his undertaking that in his new post he would have no involvement with the Export Credit Guarantee Department, UK Trade and Investment, or Crossrail Limited, or with any UK company in relation to exporting or investing overseas or with any UK export-related activities.

The Prime Minister accepted the Committee's recommendation that the application be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying Government on behalf of his new employer or its investors.

New appointment announced

Mr Easton sought permission to accept a full-time appointment as Care UK's Managing Director for Health. Care UK is one of the UK's largest independent healthcare providers working in partnership with the NHS to deliver more than fifty services across the country.   

When considering the application the Committee set aside any potential issues arising from Mr Easton’s position on the NHS Commissioning Board as these are not for the Committee to address, and considered the proposed appointment from the perspective of a Department of Health SCS 3 civil servant moving to a healthcare provider.

When considering the application the Committee noted that Mr Easton has been leading on efficiency and transformation of healthcare service, including looking at ways in which the outsourcing of service provision can contribute to this process, and that he will have gained considerable insight into Government policy in this area. Therefore there is the risk that any healthcare provider who wished to employ him could be thought, however incorrectly, to be gaining an unfair advantage by doing so. It could also be thought that he was being ‘rewarded’ by such an organisation for influencing policy on outsourcing in a way in which benefitted them in the widest sense. The Committee was of the view that the most effective way to address these issues was by ensuring that there was a clear gap between Mr Easton leaving the Department of Health and joining Care UK. Given his lack of any direct, contractual involvement with the company, and the fact that the reorganisation of the Department of Health will mean that many of its functions will soon transfer to other organisations, it felt that a gap of three months would be sufficient.

The Prime Minister accepted the Committee’s recommendation that the application be approved subject to:

- a waiting period of three months from his last day of service;

- the condition that, for 12 months from the same date, he should not become involved in advising on bids or contracts for Department of Health business; and

- that, for two years from the same date, he should not become personally involved in lobbying UK Government on behalf of his new employer.

Sir John sought permission to accept a part-time appointment as Chairman of the Edinburgh Airport Board. he was offered the position by Global Infrastructure Management LLC, part of Global Infrastructure Partners, which bought the airport in April 2012.

The Committee noted that the appointment had been announced before approval of it could be granted but in view of the time that had elapsed since Sir John left the Scottish Government, it saw no difficulty with him taking it up in June.

The First Minister accepted the Committee's recommendation that the application be approved subject to the condition that, for two years from his last day of service, Sir John should not beome personally involved in lobbying UK Government Ministers or officials, including Special Advisers, on behalf of his new employer.

Mike Falvey
Chief People Officer, HM Revenue & Customs

Corporate Services Director, Four Seasons Healthcare

Appointment announced
Appointmnet to be taken up

Mr Falvey sought permission to accept a full-time paid appointment as a Corporate Service Director with the Four Seasons Health Care (FSHC). FSHC is the UK’s largest independent health and social care provider. Its parent company is Terra Firma. FSHC operates 445 care homes with 22,364 beds and 61 specialist care centres with 1,601 beds in England, Scotland, Wales, Northern Ireland, Jersey and the Isle of Man. It employs more than 30,000 staff caring for more than 20,000 residents. Mr Falvey has been offered a full-time paid appointment as Corporate Services Director. His responsibilities will include: strategy; communications; marketing/public relations; human resources; information technology and stakeholder relations.

When considering this application, the Committee noted there will be no contact and/or dealings with his former Department. The Committee took into account that FSHC does from time to time have dealings/contact with the Department of Health and the NHS; however, these meetings are at a strategic level and are led by the Chief Executive and the Non-Executive Chairman. The Committee took into account that there is a possibility that, with his responsibility for stakeholder relations, the Corporate Services Director might be called upon (on occasion) to support the ongoing relationship. The Committee noted that Mr Falvey did not have official or contractual dealings and has not been responsible for people who have had contractual dealings with his prospective employer during his last two years of service. Furthermore, it took into account that he has not had access to commercially sensitive information about any competitors or been involved in the development or administration of any departmental policy or decisions (including the award of grants) that could have affected his prospective employer or its competitors.

The Prime Minister has accepted the Committee’s recommendation that this application be approved subject to the condition that, for two years from his last day of service, Mr Falvey should not:

• draw on any privileged information available to him whilst in Crown service; and
• become personally involved in lobbying Government on behalf of his new employer, its parent company or its clients.

March 2013

Mr Harley sought approval to accept a part-time advisory appointment with Amor Group.

When considering the applicaion, the Committee noted that at no time had he had any official dealings with Amor Group and that, within the last two years of his service, he had had no official dealings with its competitors and no access to any commercially sensitive information concerning them.

The Prime Minister accepted the Committee's recommendation that, on the basis that Mr Harley would not draw on any privileged information available to him as a civil servant, his application be approved subject to th conditions that, for 12 months from his last day of service, he should not provide advice to his new empoloyer on any bid or contract directly relating to the work of any UK Government Department, and, for two years from the same date, he should not become personally involved in lobbying Government on behalf of his new employer.  
  

Mr Hartnett sought permission to accept a part-time appointment as an adviser to HSBC Holding's new Board Committee on Financial Systems Vulnerabilities. The Committee will provide governance, oversight and policy guidance over HSBC’s framework of controls and procedures designed to identify areas where HSBC may expose itself and through its own exposure, the financial system more broadly, to financial crime or system abuse. Mr Hartnett is one of a small number of subject matter experts who have been appointed to the Committee.

When considering the application, the Committee noted that, whilst working in Government, Mr Hartnett had official dealings with HSBC over a number of years, but that these contacts were no more significant than the contacts he had with other banks operating in the UK. Furthermore, it noted that the appointment will not involve any consideration of UK tax liabilities or affairs (or any involvement with HMRC); the Board Committee’s remit is aimed at preventing financial crime and other abuses of the financial system; and that Mr Hartnett would not have a role in the day-to-day management of HSBC’s affairs - he would not be an executive or non-executive director of the bank. It also noted that he has already served the three-month waiting period which is required of former Permanent Secretaries.

The Prime Minister accepted the Committee’s recommendation that the application be approved subject to the condition that, for two years from his last day of service, Mr Hartnett should not become personally involved in lobbying Government on behalf of his new employer.  

Date of approval
Approval letter

Mr Hartnett sought permission to accept a part-time role with Deloitte, which will involve providing advice to overseas tax administrations and governments.

When considering the application the Committee noted that Mr Hartnett’s appointment with Deloitte would involve supporting the development of tax administrations in other countries. It was also noted that whilst working in Government, Mr Hartnett did have official dealings with Deloitte, and that he also dealt with a wide range of major accountancy and law firms during his time in HMRC and the Inland Revenue before that.

The Prime Minister has accepted the Committee’s recommendation that the application be approved subject to the conditions that he:

- should not draw on any privileged information available to him whilst in Crown service;
- has no involvement in either a representative or advisory capacity for any taxpayer that he has been involved with whilst at HMRC;
- is not involved whilst engaged by Deloitte in any work considering how UK taxation, for any of their clients, can be mitigated or avoided;
- has no involvement in negotiation or management of contracts with HMRC; 
- has no involvement in discussions with other fiscal authorities of UK’s confidential tax policy where he has been involved in that area of work in HMRC; and
- does not become personally involved in lobbying Government on behalf of his new employer for two years from his last day of service.

March 2013

 June 2012

Ms Jackson sought approval to accept a temporary, full-time post as Interim Director of Global Development at UCL Partners, one of five accredited academic health systems in the UK, which describes itself as working with a range of stakeholders to translate cutting edge research and innovation into measurable health gains for patients.  

The Committee noted that her new role would be overseas-focused rather than UK policy facing and that it was temporary in nature. She had also had no involvement in policy development and her official post did not cover academic health science, the field in which her new employer operates.

The Permanent Secretary of the Department of Health accepted the Committee's recommendation that the appointment, noting that it is a three-month contract, be approved subject to the condition that, for two years from her last day of service, she should not become personally involved in lobbying UK Government Ministers or Crown servants, including Special Advisers, on behalf of her new employer.

As with all Special Advisers, the Committee made its recommendation on the understanding that, if she had already done so, Ms Jackson would be required to confirm in writing to the department that she recognises she will continue to be bound by the provisions of the criminal law (including the Official Secrets Act) which protect certain categories of information and by her duty of confidentiality owed to the Crown.
 

Date of approval

Constituency Office of Danny Alexander, taken up September 2012

Constituency Office of John Thurso, taken up October 2012

Media work for BBC Scotland undertaken in September 2012

Ms Jardine sought permission to accept part-time roles supporting the communication operation in Danny Alexander's constituency office and as a constituency organiser for John Thurso. She also sought permission to accept work as an independent media commentator.

The Committee noted that Ms Jardine's role as a special adviser in No. 10 involved providing advice on the media and issues concerning Scotland.   It noted that the constituency roles were offered following her decision to resign to spend more time in Scotland, and that her proposed new employment as a media commentaor would mainly be focused on Scottish politics.  In reaching its decision, the Committee noted that, in her official role, Ms Jardine had no access to information that would give her an unfair advantage and that no lobbying of any goverment department was anticipated.

The Permanent Secretary accepted the Committee's recommendation that, on the basis that Ms Jardine would not draw on any privileged information available to her as a special adviser, her application be approved subject to the condition that, for 12 months from her last day of service, she should not become personally involved in lobbying Government on behalf of any of her new employers.  

Mr Kenrick sought permission to set up as an independent consultant advising clients on energy and climate change policy, and communications. His initial commission is with Adam Smith International in Nigeria working on a climate change and governance project being carried out with the Nigeria Infrastructure Advisory Facility.

The Permanent Secretary accepted the Committee's recommendation that the application be approved subject to the conditions that:

- for six months from his last day of service he should submit a fresh application for any commission he wishes to accept with companies in the energy sector;

- for twelve months from the same date he should not undertake any work which involves providing advice to any company or organisation on the terms of any bid or contract relating to the work of DECC;

- for two years from the same date, he should not become personally involved in lobbying UK Goverment Ministers or Crown servants, including Special advisers, on behalf of his clients.

In addition, once he has received approval to set up as an independent consultant, he must seek confirmation from the Committee directly that each individual commission is permissable under the terms of his consultancy before taking it up. If, after enquiry, the Committee takes the view that a commission is, or may be, outside the terms of the consultancy, he will be expected to submit a fresh application.  

As with all Special Advisers, the Committee made this recommendation on the understanding that, if he had not already done so, Mr Kenrick, will be required to confirm in writing to DECC that he recognises that he will continue to be bound by the provisions of the criminal law (including the Official Secrets Act) which protect certain categories of information, and by his duty of confidentiality owed to the Crown.

Commissions 
March 2012 - Adam Smith International/Nigeria Infrastructure Advisory Facility
June 2012 - Greenpeace.

Mr Kenrick sought approval to take up a full-time post as Interim Head of Public Affairs for WWF-UK (formerly known as the World Wildlife Fund). While WWF-UK is best known for its conservation work, it also campaigns on climate change and sustainability issues. Part of the responsibilities of the post will be to increase the organisation's influence and profile in Westminster, Whitehall, Brussels and the UK's devolved administrations.

The Committee noted that, given the nature of his responsibilities, a 'blanket' restriction on lobbying would prevent him from carrying out his new role. 

The Permanent Secretary accepted the Committee's recommendation that the application be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer but that, in this case, the condition would not be intended to prevent him from communicating with Government in the normal course of business.

As with all Special Advisers, the Committee made this recommendation on the understanding that, if he had not already done so, Mr Kenrick, will be required to confirm in writing to DECC that he recognises that he will continue to be bound by the provisions of the criminal law (including the Official Secrets Act) which protect certain categories of information, and by his duty of confidentiality owed to the Crown.

Mr Kohli sought permission to accept a full-time appointment as a Director of Deloitte Consulting's Federal Government Practice based in New York. He will work on strategy projects largely for clients in the US Government, with a special focus on work with developing countries, organisational performance, reorganisation, budgeting and innovation in government agencies.

When considering the application, the Committee noted that Mr Kohli had been on sabbatical from the Civil Service since November 2009, during which time he had been working as a Senior Fellow at the Center for American Progress in Washington. It also noted that he had dealings with Deloitte whilst at the Better Regulation Executive and that his new role will focus on strategy projects with for clients in the US Government, particularly on work with developing countries.

The Prime Minister accepted the Committee's recommendation that the appointment be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.

Sir Paul sought permission to accept a full-time paid post as Secretary General of The Order of St John, the international charity which provides first aid, health care and support services worldwide.

When considering this application, the Committee noted that Sir Paul had no previous involvement with his prospective employer or its competitors. The Committee also noted that MOD has no relationship with the Order of St John and that his proposed responsibilities are removed from his MOD duties. The Committee took into account that it is anticipated that the appointment will not include any contact or dealings with MOD or any lobbying activity. Furthermore, ten months had passed since he left Crown service.

The Prime Minister accepted the Committee’s recommendation that the application be approved subject to the condition that for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.

Date of approval
Approval letter

Mr Lamey sought permisson to accept an appointment as Chief Operating Officer of Kelway, an IT services provider with operations in the UK, South Africa and the United Arab Emirates. he will be responsible for improving the company's performance.

When considering the application the Committee noted that although, as a member of HMRC's Executive Committee, he will have been privy to discussions about HMRC's overall IT strategy and that, as Director General lead for Universal Credit, he will have a good knowledge of that programme, it has been five years since he was HMRC's Chief Information Officer.

The Prime Minister accepted the Committee's recommendation that the application be approved subject to the conditions that:

- for two years from his last day of service, he should not become involved in any work related to contracts with HMRC or to the Universal Credit Programme; and that

- for two years from the same date, he should not become personally involved in lobbying government on behalf of his new employer.

Sir Stephen Laws KCB QC
Former First Parliamentary Counsel

Sir Stephen sought permission to accept a part-time, unpaid appointment as a member of the Executive Committee of Statute Law Society, a charitable body which aims to educate the legal profession and the public about the legislative process.

The Committee coud see no reasonable scope for criticism of this unpaid appointment being taken up forthwith as it did not raise any questions of propriety. Although the Committee saw little likelihood that Sir Stephen would seek to use his new position to lobby Government, it considered that it would be proper for the normal two-year restriction on lobbying Government provided by the Rules to be applied.

The Prime Minister accepted the Committee's recommendation that the appointment be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying Government on behalf of his new employer, the automatic three-month waiting period being waived.

Sir Stephen sought permission to accept a part-time, unpaid appointment with the UCL Constitution Unit's working group on House of Lords Reform, in which he would be providing technical advice and drafting assistance with any new proposals.  

The Committee noted that the Constitution Unit is a leading academic stakeholder in a policy area for which Sir Stephen's former Department provided the Government lead, and that in his former role Sir Stephen was responsible for managing the Government's relationship with UCL.  However, the Committee considered that, while questions may have been asked about the propriety of accepting a similar appointment when the Government was preparing its own Bill on House of Lords Reform, Sir Stephen had in fact actively resisted accepting work which could have led to a perceived conflict of interest.  The Committee took into account tha some seven months had elapsed since Sir Stephen had left his post as First Parliamentary Counsel, and that the Government's abandonment of its own Bill meant that there could be no reasonable criticism of the proposed unpaid work with UCL on conflict of interest or other propriety grounds.  The Committee saw little likelihood that Sir Stephen would seek to use his new post to lobby Government, but considered that it would, nonetheless, be proper for the normal two-year restriction on lobbying Government provided by the Rules to be applied. 

The Prime Minister accepted the Committee's recommendation that the aplication be approved subject to the condition that, for two years from Sir Stephen's last day of service, he should not become personally involved in lobbying Goverment on behalf of his new employer.

Ms Littley sought retrospective approval for an appointment she had taken up as a non-executive director of James Hardie Industries, an industrial building materials firm which operates mainly in Australia and the USA.

The Committee wrote to the Prime Minister noting that the appointment had been accepted before an application had been made for permission to do so. It also noted, however, that Ms Littley had had no official dealings with her new employer and that over a year had passed since she had left Crown service.

The Prime Minister accepted the Committee's recommendation that the application be approved unconditionally.

Andrew Lloyd CMG MBE
Former High Commissioner to Nigeria

Mr Lloyd sough permission to accept a full-time post as Vice President (Communcations) with Statoil, an integrated oil and gas company with upstream oil, gas and biofuel operations in over thirty countries. Mr Lloyd will be responsible for the company's internal and external communications, and for developing its global business strategy and development.

When considering the application, the Committee noted that Mr Lloyd was not subject to any automatic waiting period.

The Foreign Secretary accepted the Committee's recommendation that the application be approved subject to the conditions that:

- for six months from Mr Lloyd's last day in post, he should not return to Nigeria for business purposes, advise on it, or have dealings with companies there;

- for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.
  

Managing Partner, Crest Advisory LLP

After leaving Crown service Mr Lockhart-Mirams founded Crest Advisory LLP to provide advice to prospective police and crime commissioners, criminal justice agencies and the security sector. While the company was incorporated in October 2011, he did not begin work on any projects until January 2012.

While this was a retrospective application, the Committee noted that Mr Lockhart-Mirams had been out of post for seven months before starting work with his new company. It also received assurances that none of the information to which he was privy would give his company an unfair advantage, and it recognised that his former department had no dealings with the company.

The Committee wrote to the Cabinet Office's interim Permanent Secretary, noting with concern that the appointment had been accepted before an application had been made for permission to do so, and - on the understanding that he did not draw on privileged information available to him whilst in post - recommending that the application be approved subject to the conditions for two years from his last day of service, Mr Lockhart-Mirams should not become personally involved in lobbying UK Government Ministers, including Special Advisers, on behalf of his company. She accepted this recommendation.

As with all Special Advisers, the Committee made its recommendation on the understanding that, if he had already done so, Mr Lockhart-Mirams would be required to confirm in writing to the department that he recognises he will continue to be bound by the provisions of the criminal law (including the Official Secrets Act) which protect certain categories of information and by his duty of confidentiality owed to the Crown.

Sir Mark sought permission to accept a part-time, paid appointment with Allocate Software  providing guidance and assistance on growing its business within defence. Allocate Software provides specialist workforce optimisation and corporate governance, risk and compliance IT software to public and private sector clients, with a focus on health and social care, defence, and maritime offshore oil and gas industries. Its DefenceSuite applications are designed to integrate operational analysis and force preparation with forecasting, resourcing and costing. Customers include NATO, the Royal Navy and the Army.

When considering this application, the Committee noted that Allocate Software is an MOD supplier. However, the contract it holds was awarded well before Sir Mark became Adjutant General and, while he attended occasional meetings with company employees to provide user feedback regarding the software it supplies, he and the MOD have confirmed that he had no involvement in any decisions affecting them.

The Prime Minister accepted the Committee’s recommndation that the application be approved subject to the conditions that, for 12 months from his last day of service, he should not advise on the terms of any bid or contract related to the work of the MOD, and  for two years from the same date, he should not become personally involved in lobbying UK Government on behalf of his new employer.

These conditions would not be intended to prevent Sir Mark from having dealings with the MOD in the normal course of business.

Sir Mark sought permission to accept a part-time appointment with Capita, one of the UK’s largest business outsourcing and professional services companies, with clients in both the public and private sectors. He will provide guidance, advice and assistace on growing Capita’s business with Defence. He expects this to cover HR services, training and career transition, and that it will involve discussions with senior MOD officials.

When considering this application, the Committee noted that, in March 2012, Capita was awarded the contract to deliver the Recruitment Partnership Project by Army HQ. However, while Sir Mark had responsibility for the Army’s strategic personnel policy as Adjutant General, he and the MOD have confirmed that he had no dealings with Capita or their competitors, or involvement in any decisions affecting them.

The Prime Minister accepted the Committee’s advice that the application be approved subject to:

- a waiting period of three months from his last day of service; and to the conditions that

- for 12 months from his last day of service, he should not advise on the terms of any bid or contract related to the work of the MOD; and

- for two years from the same date, he should not become personally involved in lobbying UK Government on behalf of his new employer.

These conditions would not be intended to prevent Sir Mark from having dealings with the MOD in the normal course of business.  

Ms Mayer was asked by the Royal Armouries to carry out short piece of consultancy work for them.

The Committee noted that Ms Mayer had taken up the appointment before approval had been given for her to do so. However, it was content that it raised no propriety issues.

The Prime Minister accepted the Committee's recommendation that the application be approved unconditionally.

Poppy Mitchell-Rose
Former Special Adviser, HMT

Ms Mitchell-Rose sought permission to accept a full-time appointment as an Associate Director with Freud Communications.

The Committee noted that Ms Mitchell-Rose’s role at HM Treasury had been logistical and organisational, and she not had any significant role in policy decisions. Neither had she handled any significantly commercially sensitive information, nor had substantial dealings with any company that is a competitor of her proposed employer, or any official dealings with her proposed employer.

The Permanent Secretary accepted the Committee's advice that the application be approved subject to the condition that, for twelve months from her last day of service, Ms Mitchell-Rose should not become personally involved in lobbying Government on behalf of her new employer.

Mr Morgan sought permission to accept a part-time appointment as an adviser with MHP Communications.

When considering the application, the Committee noted that Mr Morgan had had some limited dealings with the company Health Mandate, which, following a merger with MHP Communications, now forms the latter company's health sector arm, MHP Health Mandate. Mr Morgan attended a meeting with the company and a range of other healthcare stakeholders, in which he updated those present on the Government's NHS plans.  However, he had not been involved in any poluicy decisions that would have directly affected the company or its competitors. 

The Prime Minister accepted the Committee's recommendation that, on the basis that Mr Morgan would not draw on ay privileged information available to him as a Special Adviser, his application be approved subject to the conditions that:

- for 12 months from his last day of service, he should not provide advice to his new employer or its clients on any bid or contract directly relating to the work of the Department of Health, and;

- for two years from the same date, he should not become personally involved in lobbying UK Government on behalf of his new employer.  In addition, Mr Morgan should make clear in any dealings he has with other organisations with which MHP has or is seeking work involving the health sector, that he is not representing the Department of Health and that he has no special access to the Department.  

Dame Gill sought permission to accept a part-time appointment with Complwithus, a start-up company created to help recruiters develop a new approach to employee checks.  

The Committee noted that Dame Gill had had no official dealings with Compliwithus or its competitors and that, while she envisaged that her role with the company had the potential to improve patient safety and help the NHS and other organisations comply with legal requirements whilst saving money, it was not aimed at government. The Committee also noted that Dame Gill was not a career civil servat and had only been in a government role since 2008; that her role as Permanent Secretary to the Welsh Government did not involve close dealings with Whitehall; and that for the last two years she had been serving a Labour Government in Wales at a time when there was a Coalition Government in Westminster.   

The First Minister accepted the Committee's recommendaion that the application be approved subject to the conditions that, for three months after Dame Gill's last day of service, she should have no personal contact with the Welsh Government or with NHS Wales in relation to her new employer or its business, and that, for two years from the same date, she should not become personally involved in lobbying Government on behalf of her new employer; the automatic three-month waiting period applicable to Permanent Secretaries being waived. 
  

May 2012
June 2012

Lord O'Donnell sought permission to accept an appointment as a Strategic Adviser to the President and Chief Executive of TD Bank Group. He will provide them with advice on goverment, regulatory and strategic matters and will assist in explaining its 'growth story' to key constituents.

When considering his application the Committee noted that the three-month waiting period usually observed by those at Permanent Secretary level and above had expired. It also noted that TD Bank Group is primarily a retail bank with branches in the US and Canada, and that Lord O'Donnell had had no official dealings with them.

The Prime Minister accepted the recommendation of the Committee that, the three-month waiting period for Permanent Secretaries and above having expired, the application be approved subject to the conditions that he should not draw on any privileged information available to him whilst in Crown service and that, for two years from his last day of service, he should not become personally involved in lobbying government on behalf of his new employer or its clients.

Lord O'Donnell made a retrospective application for permission to accept a part-time appointment as Chairman of the Legatum Institute's Commission on Wellbeing Policy. The Legatum Institute describes itself as a independent non-partisan public policy organisation. Its new Wellbeing Policy Commission was set up in July 2012 to examine a range of issues, including welfare policy, health, and work and wellbeing.

When considering the application, the Committee noted that the three-month waiting period usually observed by Permanent Secretaries and above had expired. It also noted that he had had no official dealings with the Institute. However, it was aware that the appointment was already in the public domain and, when making its recommendation to the Prime Minister, it noted with concern that the announcement had been made before approval had been sought.

The Prime Minister accepted the Committee's recommendation that, the three-month waiting period for Permanent Secretaries (and above) having expired, the application be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.

Frontier Economics is one of Europe's largest economics consulting firms. Lord O'Donnell sought permission to accept a part-time role advising on economics and public policy.

When considering the application the Committee noted that the three-month waiting period usually observed by Permanent Secretaries and above had expired.

The Prime Minister accepted the Committee's recommendation that the appointment be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.
  

Lord O'Donnell sought permission to accept an unpaid, part-time appointment as a Visiting Professor at LSE's Centre for Economic Performance. He will give lectures and seminars with an emphasis on well-being issues.

When considering the application the Committee noted that the three-month waiting period usually observed by Permanent Secretaries and above had expired.

Lord O'Donnell sought permission to accept a part-time, unpaid appointment as a Visiting Professor in UCL's Constitution Unit. He will give lectures and seminars and assist with the Unit's research.

When considering the application the Committee noted that the three-month waiting period usually observed by Permanent Secretaries and above had expired.

The Prime Minister accepted the Committee's recommendation that the appointment be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.

Following a speech he gave to the UN in April 2012 on happiness and well-being, Lord O'Donnell was asked to take on the unpaid role of Chair of the World Economic Forum's Global Agenda Group on Well-being and Mental Health.  

When considering the application the Committee noted that the three-month waiting period usually observed by Permanent Secretaries and above has expired.

The Prime Minister accepted the recommendation of the Committee that, the three-month waiting period for Permanent Secretaries (and above) having expired, his application be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employers.

Date of approval
Approval letter

Lord O'Donnell has been asked to join the Institute for Government as a Senior Fellow.

When considering the application the Committee noted that the three-month waiting period usually observed by Permanent Secretaries and above has expired.

The Prime Minister accepted the recommendation of the Committee that, the three-month waiting period for Permanent Secretaries (and above) having expired, his application be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.

The Economist Trust was established to ensure the independence of the editor of The Economist. As an unpaid member of the Trust, Lord O'Donnell will be consulted on certain corporate activities such as the appointment of editor or of the Chairman of the Economist Group.

When considering your application the Committee noted that the three-month waiting period usually observed by Permanent Secretaries and above has expired.

The Prime Minister accepted the recommendation of the Committee that, the three-month waiting period for Permanent Secretaries (and above) having expired, his application be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.

In 2001 the Singapore Government se up its Civil Service College to provide training, learning, research and staff development for the public sector. Lord O'Donnell will give lectures, workshops and seminars on public policy issues.  

When considering your application the Committee noted that the three-month waiting period usually observed by Permanent Secretaries and above has expired.

The Prime Minister accepted the recommendation of the Committee that, the three-month waiting period for Permanent Secretaries (and above) having expired, his application be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.

Date of approval
Approval letter

Mr O'Shaughnessy sought permission to accept an unpaid, part-time appointment as an Honorary Research Fellow at the University of Birmingham's School of Education.

The Permanent Secretary accepted the Committee's recommendation that the appointment be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying government on behalf of his new employer.

As with all Special Advisers, the Committee made the recommendation on the understanding that Mr O'Shaughnessy had confirmed in writing to the department that he recognises that he will continue to be bound by the provisions of the criminal law (including the Official Secrets Act) which protect certain categories of information, and by his duty of confidentiality owed to the Crown.

Sir William sought permission to accept a part-time appointment as a Non-executive Director of HSBC Bank Middle East and as an adviser on the Middle East to HSBC's Chief Executive Officer.  

When considering the application, the Committee noted that Sir William did not have any official dealings with his prospective employer while Ambassador to Afghanistan, and that he did not intend to take up the appointment until 1 July 2012, three months after his retirement from the Diplomatic Srvice. 

The Foreign Secretary accepted the Committee's recommendation that, on the understanding that Sir William would not be taking up the appointment until 1 July 2012, and on the basis that he would not draw on any privileged information that was available to him as an Ambassador, his applicaion be approved subject to the conditions that, for six months from his last day of service, he should not revisit Afghanistan for business purposes, advise on Afghanistan, or have dealings with companies there, and that, for two years from the same date, he should not become personally involved in lobbying the UK Government on behalf of his new employer or its clients. 

Mr Pavitt sought  permission to set up as an independent IT and Project consultant and to accept a commisson as Director of IT Transformation with Aviva Insurance. 

The Committee noted that Mr Pavitt had spent some 23 years as Chief Information Officer in local government and the private sector prior to joining HMRC in September 2009, and that he had not had any official dealings with Aviva Insurance or its competitors.

The Prime Minister accepted the Committee's recommendation that, on the basis that there is no change in the circumstances of Mr Pavitt's application up to the date of his departure from the civil service in January 2013, his application be approved subject to the conditions that:

- for 12 months from his last day of serice, he should not undertake any work which involves providing advice to any company or organisation on the terms of any bid or contract relating directly to the work of HMRC:

- for two years from the same date, he should not become personally involved in lobbying Government on behalf of any of his clients: and

- for two years from his last day of service, he must seek confirmation from the Committee directly that each individual commission he wishes to accept is permissible under the terms of his consultancy before taking it up.  If, after enquiry, the Committee takes the view that a commission is, or may be, outside the terms of the consultancy, he will be expected to submit a fresh application.
 

Sir Tom sought permission to accept a part-time appointment as a trainer and consultant with CPDS, who provide training and professional development programmes for diplomats, civil servants, politicians and corporate executives.

The Foreign Secretary accepted the Committee's recommendation that the application be approved subject to the conditions that:

- for six months from his last day in post, he should not return to Saudi Arabia for business purposes, give advice on it or have dealings with companies there;

- for twelve months from his last day of service, he should not undertake any work for his new employer which involves providing advice on the terms of any bid or contract relating to the work of the FCO; and

- for two years from his last day of service, he should not he should not become personally involved in lobbying UK government on behalf of his new employer.

Sir Tom sought approval to accept a part-time appointment as a member of the Advisory Council of Wilton Park, an executive agency of the FCO.

Given the relationship between the FCO and Wilton Park, the Committee recognised that Sir Tom would have some contact with the FCO and it saw no difficulty in this.  

The Foreign Secretary accepted the Committee's recommendation that the application be approved subject to the conditions that: 

- for six months from his last day in post, he should not return to Saudi Arabia for business purposes, give advice on it or have dealings with companies there; and

 for two years from his last day of service, he should not he should not become personally involved in lobbying UK government on behalf of his new employer.

Sir Tom sought permission to become an assocate with Africa Matters (AML), a consultancy firm which works with the private sector to mitigate their risk of investing particularly in Africa. Sir Tom was approached by AML’s Chairman, Baroness Walker, about joining the company as an associate on a part-time basis. At the present time they are interested in using his services in relation to an Israel-related project that one of their clients, French bank Societe Generale, wishes to undertake, but it is possible that AML may ask him to undertake further work in the future.

When considering the application this application the Committee noted that Sir Tom had had no dealings with AML or its competitors and that, as he left post at the end of May 2012, he was no longer subject to the six-month moratorium observed by former Ambassadors on returning to the country of their last posting for business purposes, giving advice on it or having dealings with companies there.

Senior Advisor and member of the advisory team, GPW 

Sir Tom Phillips sought permission to accept an appointment as a senior adviser and member of GPW’s advisory team. GPW is an international business intelligence firm serving multinationals, law firms, financial institutions, investors and sovereign and government organisations. The organisation provides political risk analysis; relationship and influence mapping; due diligence assessments; dispute consulting and investigations; and political and business monitoring services. It has offices in London and Dubai. His role will be include promoting the company and its business; offering advice and assistance with business development and introductions to new client prospects; attending internal, client and new prospect meetings; and giving advice/assistance on specific assignments. His particular area of focus will be the Middle East but wider engagement is also envisaged. The post is paid.

When considering the application the Committee noted that Sir Tom will have contact and/or dealings with his former Department and Government, and GPW-related work and events might occasionally bring him into contact with Government officials. However there will be no lobbying of Ministers or officials in this role.

The Foreign Secretary accepted the recommendation of the Committee that, the usual six month moratorium observed by Ambassadors on having business dealings with the country of their last posting having expired, the appointment be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying the UK Government on behalf of his new employers or their clients.

Sir Tom Phillips sought permission to accept a part-time appointment as International Adviser to The Prince’s Charities International Sustainability Unit (ISU). The Prince’s Charities International Sustainability Unit was set up in 2010 to build on the success of HRH The Prince of Wales’ Rainforests Project. It works to facilitate consensus on how to resolve some of the key environmental challenges facing the world, specifically those to do with food security, ecosystem resilience and the depletion of natural capital. In addition to monitoring progress on the tropical forest finance package agreed at the Oslo Climate and Forest Conference of 2010, the ISU is developing its own sustainable agriculture and marine ecosystems programmes, bringing together public, private and NGO organisations with interests in these areas to advance possible solutions. Sir Tom has been asked to join the ISU as its International Adviser providing it with advice on international affairs. This will take up around three days a month.

When considering the application the Committee noted that while Sir Tom will not be required to lobby Government, his role will almost certainly involve occasional contact with Government departments such as the FCO and DFID, in the run-up to visits by The Prince when issues related to the ISU and the sustainable development agenda are involved.

The Foreign Secretary accepted the Committee’s recommendation that the application be approved subject to the condition that, for two years from his last day of service, Sir Tom should not become personally involved in lobbying UK Government on behalf of his new employer.

Dame Anne sought permission to accept a part-time paid appointment as a non-executive director of Ashmore Group plc, an investment management company dedicated to emerging markets.

When considering this application the Committee noted that Dame Anne had had no dealings with Ashmore Group plc or its competitors. The Committee also noted that she applied for an advertised post. Furthermore, as she left Crown service at the end of October 2011, she was no longer subject to the usual six-month moratorium observed by former Ambassadors on returning to the country of their last posting for business purposes, giving advice on it or having dealings with companies there.

The Foreign Secretary accepted the Committee's recommendation that, noting the usual six-month moratorium had now expired, the application be approved subject to the condition that, for two years from her last day of service, Dame Anne should not become personally involved in lobbying UK Government on behalf of her new employer or its clients.

Mr Pyle sought permission to accept a full-time appointment as Director of Development for Yes Scotland, the umbrella organisation set up to campaign for a yes vote in the referendum on Scottish independence in 2014.

When considering the application, the Committee noted with concern that the appointment had been announced before approval had been obtained. However, it was of the view that the appointment raised no propriety concerns under the business appointment rules. It also noted that, as Mr Pyle was not an SCS3 equivalent, he is not subject to the standard two-year lobbying ban imposed on staff at that level.

The Permanent Secretary of the Scottish Government accepted the Committee's recommendation that the appointment be approved unconditionally.

As with all Special Advisers, the Committee made its recommendation on the understanding that, if he had already done so, Mr Pyle would be required to confirm in writing to the department that he recognises he will continue to be bound by the provisions of the criminal law (including the Official Secrets Act) which protect certain categories of information and by his duty of confidentiality owed to the Crown.

Mr Russell sought permission to accept a part-time position as a non-executive director of VTB Capital plc, the investment business of VTB Group, a Russian financial group with operations in Russia, the CIS, Europe, Asia, Africa and the USA.

When considering the application the Committee noted that Mr Russell had had no dealings with VTB Capital and that there was no connection between his position as Chief Executive of the Skills Funding Agency and his proposed new role.

The Prime Minister accepted the Committee's recommendation that the application be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer or its clients.
  

Dr Saunders sought permission to accept a part-time appointment as a non-executive director of Becatech Systems, who provide specialist security services and technologies in the UK and overseas. The company went into administration last summer and was then bought by the Guinness Group. Its main product supports the requirements of the Centre for the Protection of National Infrastructure on the perimeter security of water installations and heritage sites. It also provides personal protection devices to US Special Forces, and tracking and other special electronic devices to police, security services and intelligence agencies.

When considering the appointment, the Committee noted that Becatech, in its present form, is a new company that was set up some six months after Dr Saunders left Dstl, and that she had no dealings with its predecessor. It also noted that she had no access to commercially sensitive information on competitors, and that it has now been almost ten months since she left the Agency.

The Prime Minister accepted the Committee’s recommendation that the application be approved subject to the condition that, for two years from her last day of service, she should not become personally involved in lobbying UK Government on behalf of her new employer or its clients.

Ms Scholefield sought permission to accept a full-time appointment as the Secretary and Chief Legal Officer of the LSE.

The Committee noted that she had not, at any point in her career, had significant dealings with her prospective employer or its competitors, or had official responsibility for any matters directly relevant to the LSE's business in education, training and research.

The Prime Minister accepted the Committee's recommendation that the appointment be approved subject to the condition that, for two years from her last day of service, she should not become personally involved in lobbying Government on behalf of her new employer.

Adam Sharples CB
Former Director General of Employment, Department for Work and Pensions

Mr Sharples sought permission to become non-executive Chairperson of the Ixion Group of Companies, a non-profit organisation that is part of Anglia Ruskin University. Ixion provides business support services to corporate organisations. It also manages an delivers a range of employment related services, such as NVQs, business small and medium enterprise start-ups and business for growth strategies, mentoring programmes, apprenticeships, reducing re-offending, European framework and innovation funding, training, change management consultancy, business advice, marketing, web and new media development, project management, telemarketing, and contact centre/employer engagement management, to public and private sector clients. In connection with this role he would also become a member of the Board of the University.

When considering the application, the Committee noted that Mr Sharples had been responsible for people who had had contractual dealings with Ixion over the last two years of his service. The Committee took into account that Mr Sharples had had dealings with a large number of companies in the welfare to work sector - principally the prime contractors for the Work Programme.  He was responsible for the overall design and delivery of the employment programmes but was not directly involved in the detailed assessment of individual bids.  As the Director General for Employment at the DWP, he was responsible for advising Ministers on employment programmes.  However, he did not have any contact with Ixion at any stage.  The Committee also took into account that the DWP have no current or historic prime contracts with Ixion but that the company is listed as a subcontractor for twelve live Welfare to Work contracts.  The Committee noted that the employment programme policy changed markedly with the introduction of the Work Programme in 2011, but was now stable.  The Committee also took into account that Mr Sharples did not have any knowledge as a result of being a former civil servant that would provide  an unfair competitive advantage. Finally, the Committee noted that Mr Sharples had had no direct dealings with Ixion or its competitors so his proposed appointment would not appear to be open to criticism that it was a reward for past favours or that he had any access to trade secrets.     

The Prime Minister accepted the Committee's recommendation that the application be appoved subject to the conditions that:

- for twelve months from his last day of serice, he should not undertake any work for Ixion that involved providing advice on the terms of any bid or contract relating to the work of the DWP; and

- for two years from his last day of service,  he should not become personally involved in lobbying Government on behalf of his new employer. 

Took up new appointment

Mr Sharples sought permission to accept a part-time appointment as a Trustee and Director of the Prince’s Initiative for Mature Enterprise (PRIME), a national charity that provides support for the over fifties to re-enter the labour market through self-employment.

When considering this application, the Committee noted that Mr Sharples had not had any contractual or official dealings with PRIME over the last two years in Crown service or any significant contractual dealings before that. Whilst Mr Sharples was not personally aware that he had been responsible for people who had contractual dealings with PRIME, given that he was responsible for the labour market programmes, it was possible that some of his staff at the DWP had some contact with them. Mr Sharples had dealings with a large number of companies in the welfare to work sector – principally the prime contractors for the Work Programme - but he was not directly involved in the detailed assessment of individual bids. Furthermore, as the Director General for Employment in the DWP, Mr Sharples was also responsible for advising Ministers on employment programmes. However, the Committee noted that he did not have any contact with PRIME or any of its competitors at any stage. In addition, he did not have access to any commercially sensitive or valuable information that would provide an unfair competitive advantage.

The Prime Minister accepted the Committee's recommendation that the appointment be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.
 

Mr Sharples sought permission to join a team led by the Centre for Economic and Social Inclusion, a not-for-profit company dedicated to tackling disadvantage and promoting social inclusion in the labour market. The Centre is bidding for a contract to provide consultancy support for the Irish Government in its design and modelling of a proposed new employment programme.

The Committee noted that Mr Sharples had not had any direct contractual dealings with his prospective employer over the last two years of service or any significant contractual dealings before that. Furthermore, he had not been responsible for people who had contractual dealings with them. The Committee noted that he had provided informal advice to the Irish Government in October-December 2011, after leaving the DWP. Furthermore, the Centre for Economic and Social Inclusion was a partner of the DWP and they jointly organised the annual welfare to work convention, at which Mr Sharples spoke on several occasions. The Committee noted that Mr Sharples had not had access to any commercially sensitive information about any competitors of his prospective employer. Furthermore, he does not have any knowledge that would provide him with an unfair competitive advantage.

The Prime Minister accepted the Committee's recommendation that the appointment be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.

Mr Sharples sought approval to accept a part-time paid appointment as a member of Praesidian Capital's Executive Advisory Board. Praesidian is a private investment firm, which was established in 2002 in the United States to manage funds on behalf of leading global financial institutions and high net worth individuals. It provides capital to private lower middle market companies. Its investments generally range in size from $5 million to $20 million. Mr Sharples will provide advice on the establishment of its business in the United Kingdom and on the political and regulatory environment.

When considering this application, the Committee noted that Mr Sharples had not had any contractual dealings with Praesidian Capital over the last two years or any significant contractual dealings before that. He had dealings with a large number of companies in the welfare to work sector – principally the prime contractors for the Work Programme. However, he had not had access to any commercially sensitive information about any competitors of his prospective employer. The Committee observed that the DWP have no current or historic contracts with Praesidian Capital. Furthermore, Mr Sharples had no knowledge acquired as a result of being a Civil Servant that would provide an unfair competitive advantage. Given that Mr Sharples has had no direct dealings with Praesidian Capital or its competitors, his proposed appointment could not appear to be open to criticism that it was a reward for past favours or that he had any access to trade secrets. Furthermore, there did not appear to be any obvious cross over between his proposed work with Praesidian and his work at the DWP.

The Prime Minister accepted the recommendation of the Committee that the application be approved subject to the condition that, for two years from his last day of service, Mr Sharples should not become personally involved in lobbying UK Government on behalf of his new employer.  

Sir Nigel sought permission to accept a part-time appointment as a Senior Adviser to the CEO and Chairman, and other senior executives of Universal Music Group, on international political developments, market strategies and regulatory issues.

When considering the application, the Committee had noted that it had been over three months since Sir Nigel had left Crown service and nearly six months since he left post.  The Committee also received assurances that any dealings Sir Nigel had with UGM whilst in post did not go beyond normal official contact and recognised that the FCO does not have any relationship with the company. 

The Foreign Secretary accepted the Committee's recommendation that the application be approved - on the understanding that he would not draw on privileged information available to him whilst in post - subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government Ministers or crown servants, including Special Advisers, on behalf of his new employer. 
  

Mr Smith sought permission to undertake two short pieces of work for Pinewood Shepperton film studios. He had been asked to write a speech for the Chief Executive to deliver at the Global Business Summit on Creative Content hosted by UKTI, and to carry out a research project on film and tv studio production facilities in the UK.

The Committee was of the view that the proposedwork raised no particular propriety concerns under the Business Appointment Rules provided that he did not draw on any privileged information that was available to him as a Special Adviser or become enaged in lobbying his former department.

The Permanent Secretary accepted the Committee's recommendation that the application be approved subject to the condition that, for six months from his last day of service, he should not become personally involved in lobbying DCMS on behalf of his new employer.

As with all Special Advisers, the Committee made its recommendation on the understanding that, if he had already done so, Mr Smith would be required to confirm in writing to the department that he recognises he will continue to be bound by the provisions of the criminal law (including the Official Secrets Act) which protect certain categories of information and by his duty of confidentiality owed to the Crown.
   

Date of approval

New appointment announced
Appointment to be taken up 

June 2012
September 2012

Sir Adrian sought permission to accept a full-time appointment as the Vice-Chancellor of the University of London when his fixed-term contract ends in August 2012.

When considering the application the Committee noted the inward-facing nature of his new role, his previous association with the University as its Deputy Vice-Chancellor and his lengthy experience in academic administration before joining the Civil Service. It also took into account the information he an the department had provided with regard to his lack of involvement in policy which would have had an impact on his new employer.

The Prime Minister accepted the recommendation that the appointment be approved subject to the condition that, for two years from his last day of service, he should not become personally involved in lobbying UK Government on behalf of his new employer.

Mr Smith sought permission to accept a full-time appointment as Group Technical Director of Tesco PLC. 

When considering the application, the Committee noted that Mr Smith had not had any contractual dealings with Tesco over the last two years of his service, or any significant contractual dealings with the company before that - nor has he been responsible for individuals who have had such dealings with his proposed employer.

The Committee took into account the fact that Mr Smith has had official, non contractual, contact with his prospective employer during the normal course of his work as a Crown servant with the FSA.  The FSA liaises with staff at Tesco PLC, as a major food retailer, in relation to the following: incident management (for example, the withdrawal or recalling of products); collaborating on initiatives to reduce food borne illness; meetings of the Institute of Grocery Distribution Technical Forum (attended by all retailers and key manufacturers); and liaison with the British Retail Consortium and its members on policy issues.  In addition, the FSA is the authority within the UK for food safety and standards for all commercial food production, including all UK based food suppliers to companies such as Tesco PLC.  The FSA regulates meat businesses that supply UK retailers and catering outlets and charges for its regulatory activities. Tesco PLC does not, however, own any food processing businesses in the UK. 

The Committee noted that Mr Smith has had dealings with other companies, including all of the UK's major food retailers, dairy companies, meat producers and quick service restaurants; various grocery manufacturers and food service businesses; and all UK farming unions.  However, the Committee took into account that, during the course of his official duties, Mr Smith did not have access to commercially sensitive information about Tesco PLC's competitors.  

The Committee observed that the FSA works in a transparent manner and that it does not treat any business more or less favourably.  Policy decisions are made by a Board of non-executive members at open meetings that are broadcast live and are available on the FSA's website.  The Committee noted that, whilst Mr Smith would attend these meetings, he was not - as Chief Executive - a member of the Board. Furthermore, Mr Smith was not in a position in his role with the FSA to make policies that could benefit or harm one company over another.  The proposed appointment could not, therefore, be deemed a reward.   

The Committee further noted that Mr Smith would serve one month's notice before joining Tesco PLC. 

The Prime Minister accepted the Committee's recommendation that the application be approved subject to the condition that, for two years from his last day of service, Mr Smith should not become personally involved in lobbying the UK Government on behalf of his new employer. 
 

Admiral Soar sought permission to set up as an independent consultant offering services to a wide range of business leaders on long term strategy; formulation of business plans; and leadership and risk management, and to accept a commission with Babcock International Group.

When considering the application, the Committee noted that Admiral Soar's intention was to provide strategic business advice not specific to defence or to specific contracts. The Committee also noted that his last day in post was 6 January 2012, that he had confirmed that in his previous role he had limited influence over MOD commercial arrangements, and that he had not exerted any influence over MOD contracts or commercial arrangements over the past two years.  

The Prime Minister accepted the Committee's recommendation that the application be approved, on the basis that Admiral Soar would not draw on privileged information available to him whilst in post, subject to the conditions that:

- for six months from his last day of service, he should not seek to accept any commission   with companies in the defence sector; and 

- for 12 months from the same date, he should not undertake any work which involved providing advice to any company or organisation on the terms of any bid or contract relating to the work of the MOD; and

- for two years from the same date, he should not become personally involved in lobbying UK Government Ministers or Crown servants, including Special Advisers, on behalf of his clients; and that

- he must seek confirmation from the Committee directly that each individual commission is permissible under the terms of his consultancy before taking it up. (If, after enquiry, the Committee takes the view that a commission is, or may be, outside the terms of the consultancy, he will be expected to submit a fresh appliction.) 
  

Admiral Soar sought permission to accept a part-time appointment as Non-executive Chairman of Vessel Protection Solutions Ltd.   

When considering the application, the Committee noted that Admiral Soar had already sought and received approval to accept a commission with VPS, following the approval of his independent consultancy, that he had had no official dealings with the company or its competitors, and that the company works with clients from the commercial shipping sector rather than the military.

The Prime Minister accepted the Committee's recommendaion that the application be approved on the same terms as the commission with VPS, namely that, for 12 months from his last day of service, he should not advise his new employer on the terms of any bid or contract for MOD business; and that, for two years from the same date, he should not become personally involved in lobbying UK Government on behalf of his new employer. 

Ms Squire sought permission to accept a full-time post as Head of Press for the Conservative Party.

The Committee was of the view that the appointment raised no propriety concerns under the Business Appointment Rules. It noted that Ms Squire was not an SCS Payband 3 equivalent and therefore she is not subject to the standard two-year lobbying ban imposed on staff at that level.

The Permanent Secretary of the Department for Work and Pensions accepted the Committee's recommendation that the application be approved unconditionally.

As with all Special Advisers, the Committee made the recommendation on the understanding that, if she has not already done so, she must confirm in writing to the department that she recognises that she continues to be bound by the provisions of the criminal law (including the Official Secrets Act) which protect certain categories of information, and by her duty of confidentiality owed to the Crown.

Mr Stephenson sought permission to accept a full-time appointment as the Director of External Affairs with the British Banking Association. 

The Committee noted that Mr Sephenson had had no official dealings with the British Banking Association as a Special Adviser and that the Department was satisfied that he had had no significant dealings with any financial services firms.

The Permanent Secretary accepted the Committee's recommendation that the application be approved subject to the condition that, for two years from his last day of service, Mr Stephenson should not become personally involved in lobbying the UK Government on behalf of his new employer or any of its members.    

Oliver Waghorn
Former Special Adviser to the Secretary of State for Defence

 October 2012

Mr Waghorn who sought permission to accept a paid appointment as an adviser with Interel Consulting UK. Interel Consulting UK is a strategic communications and government relations company, in a role that involves providing corporate communications, reputation management and public affairs advice to a range of clients in the UK and Europe.

When considering the application, the Committee noted the fact that Mr Waghorn anticipates that his new appointment will include contact and/or dealings with his former department/Government if required to attain publically available information or to coordinate communications in areas of mutual interest. However, the Committee noted that he does not anticipate any lobbying activity at any level.

The Permanent Secretary accepted the Committee’s recommendation that the application be approved on the following terms:

 - for 12 months from his last day of service, he should not advise on the terms of any bid or contract related to the work of the MOD or have contact with senior officials at the MOD in relation to any bids or contracts; and

 - for two years from his last day of service, Mr Waghorn should not become personally involved in lobbying Government on behalf of his new employer, its parent company or its clients.

Ms Wallace sought permission to accept a full-time appointment as the Provost of Oriel College Oxford, a full-time paid role providing leadership of the college and governing body. She does not expect to have any contact with government.

When considering the application the Committee noted that the usual three-month waiting period observed by former Permanent Secretaries had expired. It also noted that her new appointment has no connection with her former role and that she did not intend to take it up until 1 September 2013.

The Prime Minister accepted the Committee’s recommendation that, the three-month waiting period observed by former Permanent Secretaries having expired, the application be approved subject to the condition that, for two years from her last day of service, she should not become personally involved in lobbying UK Government on behalf of her new employer

Ms Waring sought permission to accept a full-time, paid appointment as Head of Corporate Affairs at Global Radio, one of the UK’s largest rdio compaies, with control over a number of radio stations including Heart, Capital and Classic FM. It forms part of Global, which also includes Global Talent and Global Publishing.Her new role will involve working closely with its Board, developing a strategic plan for its corporate affairs and helping shape the business.

When considering this application, the Committee took into account the fact that, during her last two years of service, Ms Waring has not: had any contractual dealings with her prospective employer; had access to any commercially sensitive information about any of her prospective employer’s competitors; or been involved in the development or administration of any policy or decisions (including the award of grants) that could have affected her prospective employer or its competitors. The Committee was, therefore, of the view that the proposed post raised no particular propriety concerns under the Business Appointments Rules.

The Permanent Secretary of DECC accepted the Committee's recommendation that the appointment be approved subject to the condition that, for two years from her last day of service, Ms Waring should not become personally involved in lobbying UK Government Ministers or Crown servants, including Special Advisers, on behalf of her new employer, its parent company or its clients.

As with all Special Advisers, the Committee made this recommendation on the understanding that, if she has not already done so, Ms Waring must confirm in writing to your Department that she recognises that she continues to be bound by the provisions of the criminal law (including the Official Secrets Act), which protect certain categories of information, and by her duty of confidentiality owed to the Crown.

Sir David Warren KCMG
Former HM Ambassador to Tokyo

Sir David sought permission to accept a part-time appointment as a consultant and Visiting Professor at De Montfort University. He will be advising on the University’s evolving strategy of engagement with Japan and undertake workshops with public policy students. He will also be engaging with the Theatre Archive Project, a joint British Library/De Montfort project reinvestigating British theatre history 1945-1968, from the perspectives of both the theatregoer and the practitioner, and he will carry out interviews and research as part of this. He expects his work for the university to take up around four days a month.

The Secretary of State accepted the Committee's recommendation that the application be approved subject to the conditions that:

- for six months from his last day in post he should not return to Japan for business purposes, give advice on it or have dealings with companies there; and
- for two years from his last day of service, Sir David should not become personally involved in lobbying UK government on behalf of his new employer.

Sir Bob sought permission to accept a part-time post with Monash University, Melbourne. He has been asked to design and lead a yearly conference or series of think tanks on sustainability issues for the South East Asia and Pacific Region.  

When considering the application, the Committee noted Sir Bob’s long scientific career and that this will be a part-time role designing and leading a yearly conference or series of think tanks on sustainability issues for the South East Asia and Pacific Region for an Australian university.

The Prime Minister accepted the Committee’s recommendation that the application be approved subject to the condition that, for two years from his last day of service, Sir Bob should not become personally involved in lobbying the UK Government on behalf of his new employer.

Lieutenant General White-Spunner made a retrspective application for permission to accept a part-time appointment as the Executive Chairman of the Countryside Alliance. The Countryside Alliance is a charity that campaigns on rural issues.

The Committee noted with concern that the appointment had been taken up before approval of it could be granted.

The Prime Minister accepted the Committee's recommendation that the application be approved retrospectively subject to the condition that, for two years from his last day of service, he should not becme personally involved in lobbying Ministry of Defence Ministers or officials, including Special Advisers, on behalf of his new employer.
  

Dr Sean Worth
Former Special Adviser, Prime Minister's Office

Dr Worth sought permission to accept a full-time position as Head of the Better Public Services Project, which has been set up by think tank Policy Exchange to examine the impact of greater competition, technological innovations and new models of service ownership on the delivery of public services.

When considering the application the Committee noted that Dr Worth had had no dealings with Policy Exchange whilst in office and that he had had no involvement in policy development. It also recognised the wide-ranging nature of the role he wished to accept and that Policy Exchange is a registered charity.

The Permanent Secretary of the Cabinet Office accepted the Committee's recommendation that the application be approved subject to the condition that, for 12 months from his last day of service, he should not become personally involved in lobbying UK Government Ministers or Crown servants, including Special Advisers, on behalf of his new employer.

As with all Special Advisers, the Committee made its recommendation on the understanding that, if he had already done so, Dr Worth would be required to confirm in writing to the department that he recognises he will continue to be bound by the provisions of the criminal law (including the Official Secrets Act) which protect certain categories of information and by his duty of confidentiality owed to the Crown.

Dr Worth sought permission to accept a part-time appointment as a strategic adviser to public affairs and PR company MHP Communications. He will work with its public affairs practice, providing political counsel to some clients and in order to help to train MHP staff.

The Committee noted that Dr Worth had had no official dealings with his new employer and that he had not had access to any commercially sensitive information about its competitors.

The Permanent Secretary of the Cabinet Office accepted the Committee's recommendation that the application be approved subject to the condition that, for 12 months from his last day of service, he should not become personally involved in lobbying Government on behalf of his new employer or its clients.

As with all Special Advisers, the Committee made its recommendation on the understanding that, if he had already done so, Dr Worth would be required to confirm in writing to the department that he recognises he will continue to be bound by the provisions of the criminal law (including the Official Secrets Act) which protect certain categories of information and by his duty of confidentiality owed to the Crown.