Decision

Correspondence: Anne Marie-Trevelyan, Strategic Advisor, Babcock International Group Plc

Published 2 June 2026

1. COMPLIANCE WITH BUSINESS APPOINTMENT ADVICE: The Rt Hon Anne-Marie Trevelyan, former Minister of State for the Indo-Pacific – Babcock International Group Plc

2 June 2026

Dear Ms Trevelyan,

I am writing in the context of my responsibility to advise former ministers under the Government’s Business Appointment Rules (the Rules), a function previously exercised by the Advisory Committee on Business Appointments (ACOBA). 

Thank you for our meeting to discuss your compliance with ACOBA’s advice under the Rules in relation to your role as Strategic Advisor with Babcock International Group Plc, which you started in September 2025. You confirmed that, since taking up this role, you had engaged with the Minister for Defence Readiness and Industry (‘the Minister’). I understand that you and he are friends and that some of your interactions were of a purely social character, which is not a concern under the Rules. However, as we discussed, elements of your communication were directed to him in his capacity as a Government minister, and therefore contravene the conditions specified in ACOBA’s published letter of advice of September 2025 (Annex). 

You stated that this was a naive mistake on your part. You explained that you were not engaging with the Minister in connection with your Babcock role, but instead acting privately and out of friendship. Having heard the Minister give a speech which, you felt, omitted important information relating to Babcock and which prompted adverse comments from some journalists who were also present, you had wanted to share your perspective with the Minister. You also described a separate instance where, prompted by a Babcock colleague’s impression that the Minister was unaware of its work on a particular US contract, you had provided the Minister with publicly available information about this contract and offered a fuller briefing from the company’s government relations team. I explained that, whilst your motivation might be understandable, your account of your communication with the Minister contravened the conditions specified in ACOBA’s advice.

The purpose of the Rules 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. ACOBA applied conditions to your appointment at Babcock, in order to achieve these aims, which were set out in its letter of advice to you. These conditions included:

• Lobbying condition – “for two years from your last day in ministerial office, you should not become personally involved in lobbying the government or its arm’s length bodies on behalf of Babcock International Group Plc (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 Babcock International Group Plc (including parent companies, subsidiaries, partners and clients)” 
• Engagement restriction – “for two years from your last day in ministerial office, you must not directly engage with the UK government or its arm’s length bodies on behalf of Babcock International Group Plc (including parent companies, subsidiaries, partners and clients)”.

Your letter of advice from ACOBA included confirmation from Babcock that it did not “ask or expect its employees who are former government officials to undertake any form of lobbying” and that the company would “adhere to the conditions”.

You have made clear the seriousness with which you take your responsibilities as a former minister, including in relation to the Rules. I appreciate that you are dismayed to find yourself in this position. I also note your explanation that you were communicating out of friendship with the Minister, rather than with intent to enhance Babcock’s position in relation to any contract with the UK Government. You have confirmed, however, that you contacted the minister on matters relating to Babcock and did so in order to influence his knowledge and understanding of the naval defence industry. This act of contacting the Minister to highlight Babcock’s work, irrespective of your intention, contravened the conditions specified by ACOBA that you should neither “directly engage with” nor “become personally involved in lobbying” the Government in your role.

My remit allows me to make breaches of the Rules public. Accordingly, this correspondence will be published on my GOV.UK pages. I am copying this letter to the Director of Propriety and Ethics in the Cabinet Office.

Yours sincerely,

Sir Laurie Magnus CBE

Independent Adviser on Ministerial Standards

2. Annex – ACOBA’s advice to Anne-Marie Trevelyan on the role of Strategic Advisor, Babcock International Group Plc, in September 2025

ACOBA advised Ms Trevelyan about taking up an appointment with Babcock International Group Plc, setting out its consideration and the conditions imposed on the appointment in September 2025. The appointment was taken up later that month.