Decision

Advice letter: Andrew Gwynne, Consultant, Ibrahim Dogus

Published 15 September 2026

1. BUSINESS APPOINTMENT APPLICATION: Andrew Gwynne, former Parliamentary Under-Secretary of State, Department of Health and Social Care – Consultant for Ibrahim Dogus, conducting research and providing advice and administrative support for SME4Labour and CEFTUS Ltd 

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on taking up a role as Consultant with Ibrahim Dogus to conduct research and provide advice and administrative support for SME4Labour and CEFTUS Ltd, also known as the Centre for Türkiye Studies. 

The purpose of the Rules, as you will be aware, is to protect the integrity of government and to avoid any suspicion that those who have served in government might profit improperly from that experience or that an employer might gain unfair advantage through privileged access to government. To achieve these aims, I designate conditions that former ministers must follow. 

The material information and my consideration are set out in the annex. In light of this, I consider the following conditions to be appropriate, recognising that it is your responsibility to ensure that these are demonstrably applied in practice:

• Privileged information condition – You should not draw on (disclose or use for the benefit of Ibrahim Dogus, SME4Labour and CEFTUS Ltd, including their related parties) any privileged information available to you from your time in ministerial office. This is an ongoing duty irrespective of the time elapsed since you left office.
• Lobbying condition – For two years from your last day in office, you should not become personally involved in lobbying the UK Government or its arm’s length bodies on behalf of Ibrahim Dogus, SME4Labour and CEFTUS Ltd (including their related parties); 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 Ibrahim Dogus, SME4Labour and CEFTUS Ltd (including their related parties).
• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with Ibrahim Dogus, SME4Labour and CEFTUS Ltd (including their related parties) 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. 

I would be grateful if you would note the following points:

• My advice is not an endorsement of the appointment.
• The advice relates solely to your previous role in government; it is separate from rules governing the registration of consultant lobbyists, from the Code of Conduct and Rules of the House of Commons and from the House of Lords Code of Conduct. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with my advice.
• By ‘privileged information’, I mean official information to which you had access as a consequence of holding office and which is not publicly available. You are also reminded that you may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code or otherwise.
• By ‘related parties’, I mean any parent companies, subsidiaries, clients and/or other partners as may be relevant.
• As set out in the Rules, the lobbying restriction means that former ministers ‘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’.

As soon as you take up the appointment, or if it is announced that you will do so, you are obliged under the Rules to inform my secretariat who will then publish this letter. You must also inform us if you propose to extend or otherwise change the nature of your role – including, for the avoidance of doubt, working in any capacity other than for SME4Labour or CEFTUS Ltd – as, depending on the circumstances, it may be necessary for you to make a fresh application.

Yours sincerely,

Sir Laurie Magnus CBE

Independent Adviser on Ministerial Standards

2. Annex – Material information and consideration of the risks 

2.1 The role

You wish to take up a paid, part-time role as Consultant for Ibrahim Dogus. You stated that in your role as Consultant you will provide research, administrative support and advice, including Parliament-facing work, for two organisations, namely SME4Labour and CEFTUS Ltd, also known as the Centre for Türkiye Studies (CEFTUS). 

Ibrahim Dogus is a businessperson and politician. He is the director of SME4Labour, CEFTUS and other organisations. 

SME4Labour is an independent, not-for-profit organisation that connects small and medium-sized enterprises (SMEs) with MPs, peers, councillors and stakeholders. CEFTUS is an independent think tank based in London that aims to foster dialogue between the UK, Turkey and Turkey’s neighbouring countries. CEFTUS organises the annual British Kebab Awards which includes attendance by politicians and celebrates the kebab industry. 

You confirmed that you will not have contact with the UK Government in this role. 

2.2 Dealings in office

You said that, as a minister, you neither met with nor made any policy, regulatory or commercial decisions specific to Ibrahim Dogus, SME4Labour or CEFTUS. You said that you had no access to information that could grant this individual or these organisations an unfair advantage.

You added that you were lead minister on the Tobacco and Vapes Bill for the House of Commons Committee stage in January 2025. You said that you were no longer a minister and no longer involved with the House of Commons proceedings by the third reading and that you have no knowledge related to the Tobacco and Vapes Bill after 8 February 2025. You said that SME4Labour’s work includes an interest in the impact of the Tobacco and Vapes Act 2026 on SMEs. 

2.3 Departmental assessment

The Department of Health and Social Care (DHSC) confirmed the details you provided and did not consider you to have access to relevant privileged information that could offer Ibrahim Dogus, SME4Labour or CEFTUS an unfair advantage, given the passage of time and limited overlap between the two organisations’ operations and your ministerial responsibilities. 

DHSC confirmed that you were lead minister on the Tobacco and Vapes Bill for the House of Commons Committee stage and that this may have some impact on SMEs, which SME4Labour represents. DHSC noted that the ensuing Tobacco and Vapes Act 2026 has received Royal Assent and information related to this is in the public domain.

DHSC added that there is no departmental relationship with Ibrahim Dogus, SME4Labour or CEFTUS. 

In addition to recommending the standard conditions, DHSC noted the need to consider a potential risk of influencing, given SME4Labour’s interest in DHSC policy areas for which you held ministerial responsibility. 

2.4 My consideration of the risks 

You were lead minister on the Tobacco and Vapes Bill for the House of Commons Committee stage, guiding decisions that could be seen to broadly impact SMEs, which SME4Labour represents. There is, therefore, a risk of perception of reward for your actions taken in office. However, I consider this risk to be limited because:

• you made no decisions specific to Ibrahim Dogus, SME4Labour or CEFTUS 
• you did not meet with Ibrahim Dogus, SME4Labour or CEFTUS in your ministerial capacity  
• the decision-making process in relation to the Tobacco and Vapes Bill is recorded by Hansard, publicly setting out your involvement in the debate of the Tobacco and Vapes Bill
• you left office nearly 19 months ago, which places an appropriate separation between any decision-making that could be seen to broadly benefit Ibrahim Dogus, SME4Labour or CEFTUS and your taking up of the role. 

DHSC had no concerns over your access to privileged information due to the passage of time and limited overlap with your ministerial responsibilities – the risks here are therefore limited.

I consider it of significant relevance that Ibrahim Dogus has provided written confirmation both of the separation of your role from lobbying and that the scope of the role extends only to SME4Labour and CEFTUS as described in your application, and is compatible with adhering to the advice in this letter.

As a think tank, CEFTUS will have an interest in government policy. SME4Labour will also have an interest in government policy related to SMEs and has previously lobbied government. There is, therefore, a risk that you could be perceived to offer Ibrahim Dogus and his associated organisations unfair access to government. However, this risk is limited because:

• there is no relationship between your former department and Ibrahim Dogus, SME4Labour or CEFTUS 
• your role is internal and separate from lobbying activities: you will provide research, administrative support and advice, including Parliament-facing work, and Ibrahim Dogus has provided written confirmation of this 
• you will have no contact with the UK Government in this role.

Ibrahim Dogus’s interests span further than the activities of SME4Labour and CEFTUS and, as such, it is conceivable that he could ask you to work on aspects of his other interests that are outside the scope of your application for this advice. There would, in those circumstances, be a risk of overlap between the area of work and the responsibilities you had as minister – a risk that cannot be assessed as the work is not known. However, I consider this risk to be significantly limited by Ibrahim Dogus’s written confirmation that the scope of your role is limited to SME4Labour and CEFTUS. You are also reminded that this advice is specific to SME4Labour and CEFTUS and the role as described, and that you must inform us should you propose to extend or otherwise change the nature of your role.