Decision

Advice Letter: Darren Mott, Advisor, Marylebone Design Collectif Ltd

Updated 12 March 2024

1. BUSINESS APPOINTMENT APPLICATION: Lord Darren Mott OBE, former Government Whip in the House of Lords. Paid appointment with Marylebone Design Collectif Limited.

You sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointments Rules for former Crown servants (the Rules) on taking up an appointment with Marylebone Design Collectif Ltd (MDC(UK)) as an Advisor.

The purpose of the Rules is to protect the integrity of the government. The Committee has considered the risks associated with the actions and decisions made during your time in office, alongside the information and influence a former Government Whip in the House of Lords may offer MDC(UK). The material information taken into consideration by the Committee is set out in the annex.

The Committee’s advice is not an endorsement of the appointment – it imposes a number of conditions to mitigate the potential risks to the 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 risks

There is no known overlap with your time as a minister and MDC(UK’s work.  You did not meet with MDC(UK) during your time as a minister, nor did you make any decisions specific to them 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 result of your time as a minister there are inherent risks regarding your general access to information, contacts and influence within government. The risks are limited given there is no direct overlap between your role in government and your proposed role with MDC(UK).

3. The Committee’s advice 

The Committee did not consider this appointment raises any particular proprietary concerns under the government’s Rules. The inherent risks are appropriately mitigated by the standard conditions below. In particular, they prevent  you from drawing on your privileged information and using your contacts and influence within government to the unfair advantage of MDC(UK).

In accordance with the government’s Business Appointment Rules, the Committee advises this role with Marylebone Design Collectif Ltd 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 Marylebone Design Collectif Ltd (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 Marylebone Design Collectif Ltd (including parent companies, subsidiaries, partners and clients); 

• for two years from your last day in ministerial office you should not undertake any work with Marylebone Design Collectif Ltd  (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 from rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists, the Parliamentary Commissioner for Standards and the Registrar of Lords’ Interests^{[footnote 2]}. You are reminded that as a Member of the House of Lords you are prevented from any paid lobbying under the House of Lords Code of Conduct. It is an applicant’s personal responsibility to understand any other rules and regulations they 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

MDC(UK) is an interior design company. It is also a creative hub and app that aims to empower future designers. The collective offers mentorship to designers, assisting in setting up their business, through individually tailored programmes.

You said in your paid, part-time role, your advisory responsibilities will include: 

• Strategic counsel: offering insights and counsel on the organisation’s strategic alignment and objectives.
• Advisory expertise: leveraging expertise to assist the organisation in navigating challenges and seizing opportunities for commercial success.
• Board enhancement: ensuring and improving  functioning of the board, training, evaluations and succession planning. 
• Guidance for the CEO: supporting the CEO’s performance - establishing clear expectations and delivering feedback, providing leadership support.
• Progress monitoring regarding brand initiatives for the business as a whole. 

You state that you have an offer of employment but did not apply for an advertised role. You said that this role came about through a longstanding contact made while working at the Conservative Party, who you have been friends with for over 25 years.  They work with MDC(UK) and suggested your experience would help guide and grow the business.

You stated that in your role you will not have any contact with government. 

4.2 Dealings in office

You advised the Committee that you did not meet with MDC(UK) 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. It confirmed that you made no policy decisions relating to MDC(UK). 

The Cabinet Office confirmed you did not have access to sensitive information and had no concerns with the appointment.

1. This application for advice was considered by Andrew Cumpsty; Sarah de Gay; Isabel Doverty; Hedley Finn OBE; The Rt Hon Baroness Jones of Whitchurch; The Rt Hon Lord Pickles; Michael Prescott; and Michael Weir. ↩

2. All Peers and Members of Parliament are prevented from paid lobbying under the House of Commons Code of Conduct and the Code of Conduct for Members of the House of Lords. Advice on your obligations under the Code can be sought from the Parliamentary Commissioners for Standards, in the case of MPs, or the Registrar of Lords’ Interests, in the case of peers. ↩