Decision

Advice Letter: Natalie Evans, Chair of Campaign Board, Coalition on Secure Technology

Updated 22 December 2023

1. BUSINESS APPOINTMENT APPLICATION: Baroness Evans of Bowes Park, former Lord of the Privy Seal and Leader of the House of Lords. Paid application to join the Coalition on Secure Technology.

You sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointments Rules for Former Ministers (the Rules) on an appointment you wish to take up with the Coalition on Secure Technology as Chair of Campaign Board.

The purpose of the Rules is to protect the integrity of the government. Under the Rules, the Committee’s remit is to consider the risks associated with the actions and decisions made during your time in office, alongside the information and influence a former minister may offer the Coalition on Secure Technology. The material information taken into consideration by the Committee is set out in the annex below.

The Committee’s advice is not an endorsement of the appointment - it imposes a number of conditions to mitigate the potential risks to government associated with the appointment under the Rules.

The Ministerial Code sets out that ministers must abide by the Committee’s advice. It is an applicant’s personal responsibility to manage the propriety of any appointment. Former ministers of the Crown, and Members of Parliament, are expected to uphold the highest standards of propriety and act in accordance with the 7 Principles of Public Life.

2. The Committee’s consideration of the risk presented

You did not meet with the Coalition on Secure Technology during your time as a minister; nor did you make any decisions specific to the company whilst in office. Therefore, the Committee^{[footnote 1]} considered the risk this appointment could reasonably be perceived as a reward for decisions made or actions taken in office is low.

As a former minister, there are inherent risks associated with your access to privileged information and knowledge. However, the Cabinet Office confirmed there is no direct overlap with your time in office and it did not have any concerns regarding your access to information.

As with any application, your contacts and influence across government could offer your employer an unfair advantage, especially if it looked to influence government policy. You confirmed that your proposed role would not involve any contact with government and would not undertake any direct advocacy on behalf of the Coalition on Secure Technology towards UK government ministers or officials, maintaining full compliance with the House of Lords Code of Conduct.

3. The Committee’s advice

The Committee did not consider this appointment raises any particular proprietary concerns under the government’s Business Appointment Rules. The standard conditions below will sufficiently mitigate the risks in this case. These prevent you from drawing on your privileged information, contacts and influence gained in ministerial office to the unfair advantage of the Coalition on Secure Technology.

Taking these factors into account, in accordance with the government’s Business Appointment Rules, the Committee’s advice is this appointment with the Coalition on Secure Technology be subject to the following conditions:

• you should not draw on (disclose or use for the benefit of yourself or the persons or organisations to which this advice refers) any privileged information available to you from your time in ministerial office;

• for two years from your last day in ministerial office, you should not become personally involved in lobbying the UK government or its arm’s length bodies on behalf of the Coalition on Secure Technology (including parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or Crown service to influence policy, secure business/funding or otherwise unfairly advantage the Coalition on Secure Technology (including parent companies, subsidiaries, partners and clients); and

• for two years from your last day in ministerial office you should not undertake any work with the Coalition on Secure Technology (including parent companies, subsidiaries, partners and clients) that involves providing advice on the terms of, or with regard to the subject matter of a bid with, or contract relating directly to the work of, the UK government or its arm’s length bodies.

The advice and the conditions under the government’s Business Appointment Rules relate to your previous role in government only; they are separate to rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists or the Parliamentary Commissioner for Standards. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with this Committee’s advice.

By ‘privileged information’ we mean official information to which a Minister or Crown servant has had access as a consequence of his or her office or employment and which has not been made publicly available. Applicants are also reminded that they may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Civil Service Code or otherwise.

The Business Appointment Rules explain that the restriction on lobbying means that the former Crown servant/minister “should not engage in communication with government (ministers, civil servants, including special advisers, and other relevant officials/public office holders) – wherever it takes place - with a view to influencing a government decision, policy or contract award/grant in relation to their own interests or the interests of the organisation by which they are employed, or to whom they are contracted or with which they hold office.” This Rule is separate and not a replacement for the Rules in the House.

You must inform us as soon as you take up this role, or if it is announced that you will do so. You must also inform us if you propose to extend or otherwise change the nature of your role as, depending on the circumstances, it may be necessary for you to make a fresh application.

Once the appointment has been publicly announced or taken up, we will publish this letter on the Committee’s website, and where appropriate, refer to it in the relevant annual report.

4. Annex - Material Information

4.1 The role

You stated that the Coalition on Secure Technology is a newly created campaign organisation. You stated it aims to produce research and information about the possible impacts on the UK economy of the UK’s dependence on internationally sourced Internet of Everything (IoT) modular chips^{[footnote 2]}.

You said in your paid, part-time capacity as Chair of the Campaign Board that your responsibilities are to:

• Chair regular meetings of the Campaign Board which will oversee the work of the Group

• Act as an occasional spokesperson for the campaign highlighting with the public, media and appropriate bodies the research and evidence that the Group generates in order to inform public debate in a transparent way.

You stated your role would not involve contact with government and said you would not undertake any advocacy on behalf of the Coalition on Secure Technology towards UK government ministers or officials, maintaining full compliance with the House of Lords Code of Conduct.

4.2 Dealings in office

You advised the Committee that you did not meet with the Coalition on Secure Technology whilst in office. You said you did not have any involvement in policy, regulatory or commercial decisions that would have been specific to the company.

4.3 Departmental Assessment

The Cabinet Office confirmed the details you provided and did not have concerns about the appointment.

1. This application for advice was considered by Andrew Cumpsty; The Rt Hon Baroness Jones of Whitchurch; The Rt Hon Lord Pickles; Richard Thomas; and Mike Weir. Jonathan Baume, Sarah de Gay and Isabel Doverty were unavailable. ↩

2. IoT modules or chips are electronic devices installed in machines, objects, and things that are capable of connecting to wireless networks and transmitting and receiving data. ↩