Decision

Advice letter: Andrew Mitchell, Senior Adviser, Subaha Investments

Published 3 February 2026

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Sir Andrew Mitchell, former Minister of State, Deputy Foreign Secretary and Minister of State for Development and Africa – Paid appointment as Senior Adviser, Subaha Investments

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on joining Subaha Investments as a Senior Adviser.

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 Subaha Investments, related parties and clients) 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 Subaha Investments (including related parties 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 Subaha Investments (including related parties and clients).

• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with Subaha Investments (including related parties 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.

• Business development restriction – For two years from your last day in office, you should not become personally involved in lobbying contacts you acquired during your time in office in other governments and organisations for the purpose of securing business for Subaha Investments (including related parties and clients).

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 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. 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.

• 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 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 a Senior Adviser with Subaha Investments (Subaha), a diversified investment manager overseeing multiple funds under one corporate structure. Subaha is being incorporated in Mauritius as a Global Business Licence (GBL) company, and will hold a Collective Investment Scheme licence on regulatory completion. The role involves investment strategy, investment advisory services, and the identification and structuring of investment opportunities for Subaha’s funds and vehicles.

You confirmed that, prior to re-entering politics in October 2022, you advised several international investment banks and managers.

You also confirmed that you will have no contact with, or undertake any lobbying of, government in this role.

2.2 Dealings in office

You said you did not meet with, or make any policy, regulatory or commercial decisions specific to Subaha, given it was established after you left office. You said that you engaged with investment managers while in office, but had no access to information that could provide an unfair advantage to the company.

2.3 Departmental assessment

Your former department, the Foreign, Commonwealth & Development Office (FCDO), considered that the policy insight you may give Subaha offered no unfair advantage due to the time passed since you left office. The department also noted that British International Investment is not an investor in the fund.

The FCDO recommended the standard conditions.

2.4 My consideration of the risks

You made no policy, regulatory or commercial decisions specific to Subaha, and the FCDO has no concerns over your access to privileged information – the risks are therefore limited.

As an investment manager, Subaha will have an interest in government policy and in co-investment and partnership relationships with the UK government. You have been clear that the role will not include lobbying, but there remains a risk you could be perceived to offer this new company unfair access to government. However, this risk is limited because:

• the role is not focussed on the UK
• you will not be the only Subaha staff with an existing FCDO relationship

Your role involves developing Subaha’s business. There is a risk that you may leverage contacts gained whilst in office, for example in foreign governments and the private sector, to unfairly advantage the company. I have therefore applied a condition preventing you from lobbying external contacts acquired only as a result of your time in office to secure business.