Decision

Advice Letter: Oliver Dowden, Strategy Advisor, Heni Limited

Updated 16 September 2025

1. BUSINESS APPOINTMENT APPLICATION: The Rt. Hon. Sir Oliver Dowden CBE MP, former Deputy Prime Minister, Chancellor of the Duchy of Lancaster, and Secretary of State in the Cabinet Office. Paid appointment with Pierce Protocols Limited, trading as Heni Limited. 

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 your role as Strategy Adviser with Pierce Protocols Limited, trading as Heni Limited.

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 you made during your time in office, alongside the information and influence you may offer Heni Limited. 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 Rules^{[footnote 1]} sets out that former minister must abide by the Committee’s advice. It is an applicant’s personal responsibility to manage the propriety of any appointment. Former ministers 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 presented

The Cabinet Office confirmed you did not meet with, nor have involvement in any decisions specific to Heni Limited during your time in office. The Committee^{[footnote 2]} considered the risk this appointment could reasonably be perceived as a reward for decisions made or actions taken in office is low. 

As Deputy Prime Minister, Chancellor of the Duchy of Lancaster and Secretary of State in the Cabinet Office you had access to sensitive information across government. The Committee noted there are mitigating factors that limit the real and perceived risks associated with your access to sensitive information: 

• The Cabinet Office said they are not aware of any sensitive information you had access to in your recent former positions that would offer an unfair advantage to Heni Limited. 
• The Cabinet Office also said that it does not hold a relationship with Heni Limited. 

Your role as Strategy Adviser is focussed on analysing and advising Heni Limited on strategy and performance in relation to global cultural, technological and market trends affecting the company and its wider corporate interests. There are risks associated with your influence and network of contacts gained whilst in ministerial office. However, it has been noted in your application that your role will not involve contact with, or lobbying of, government. 

3. The Committee’s advice

The Committee determined the risks identified can be appropriately mitigated by the conditions below. These make it clear that you cannot make use of information or influence gained from your time in ministerial service to the unfair advantage of Heni Limited. 

In accordance with the government’s Business Appointment Rules, the Committee advises this appointment with Pierce Protocols Limited, trading as Heni Limited 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 Pierce Protocols Limited, trading as Heni Limited (including parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or ministerial office to influence policy, secure business/funding or otherwise unfairly advantage Heni Limited (including parent companies, subsidiaries, partners and clients); and

• for two years from your last day in ministerial office, you should not provide advice to Pierce Protocols Limited, trading as Heni Limited 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. 

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 3]}. 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 Ministerial Code or otherwise.

The Business Appointment Rules explain that the restriction on lobbying means that you “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”.  

You must inform us as soon as you take up employment with this organisation, or if it is announced that you will do so. Please 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 said you have been offered a paid, part time appointment with Pierce Protocols Limited, trading as Heni Limited as a Strategy Adviser. 

According to its website, Heni Limited is a technology company pioneering art markets and information. It works with artists and estates across various sectors including print-making, book publishing, NFTs, art research and analysis. You have described Heni Limited as being an international art services business. 

In your (paid) role as Strategic Adviser, you stated that you will be responsible for providing advice and analysis on long-term global cultural, technological and market trends and developments affecting Heni Limited and its wider corporate interests. 

You confirmed that your role would not ‘involve affecting or influencing, in any manner, any current or proposed legislation or any government or official opposition actions. Nor providing advice on public policy and current affairs; or advice in general terms about how Parliament works. In providing these services I would not draw on any privileged information gained from my time in public office.’

You have also confirmed your role will not involve contact with, or lobbying of government.

4.2 Dealings in office

You said that none of your recent roles in the Cabinet Office included involvement in policy development, contractual and/or commercial decisions specific to Heni Limited. You also said that you did not have any official dealings/ contact with Heni Limited during your time in office and that there is no departmental relationship with it. You also stated that you did not have any access to privileged information.

4.3 Departmental assessment

Your former department, the Cabinet Office, was consulted on your appointment. The department confirmed the above information and stated:

• You did not make any regulatory or policy decisions that would have affected Heni Limited, nor did you meet with the company.

• The Cabinet Office does not hold a relationship with Heni Limited. 
• It did not consider you to have access to privileged information that could be considered to offer an unfair insight/advantage to the proposed employer.
• You did not make any funding or contractual/commercial decisions that affected Heni Limited. 

The Cabinet Office did not have concerns with the appointment. recommended standard conditions.

1. Which apply by virtue of the Civil Service Management Code, The Code of Conduct for Special Advisers, The King’s Regulations and the Diplomatic Service Code. ↩

2. This application for advice was considered by Andrew Cumpsty; Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE DL; The Rt Hon Lord Pickles; The Baroness Thornton; Michael Prescott; and Mike Weir. ↩

3. 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 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. ↩