Decision

Advice letter: Philip Barton, Member of the Advisory Board, Strategy International Holdings Ltd

Published 29 July 2025

1. BUSINESS APPOINTMENT APPLICATION: Sir Philip Barton KCMG OBE, former Permanent Under-Secretary at the Foreign, Commonwealth and Development Office. Unpaid appointment with Strategy International Holdings Ltd. 

Sir Philip sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Crown Servants (the Rules) on an unpaid role he wishes to take up with Strategy International Holdings Ltd (Strategy International) as a Member of the Advisory Board.

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 Sir Philip’s time in office, alongside the information and influence he may offer Strategy International. 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]} set out that Crown servants must abide by the Committee’s advice. It is an applicant’s personal responsibility to manage the propriety of any appointment. Former Crown servants 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

When considering this application, the Committee^{[footnote 2]} took into account that the appointment is unpaid^{[footnote 3]}. Generally, the Committee’s experience is that the risks related to unpaid roles are limited. The purpose of the Rules is to protect the integrity of the government by considering the real and perceived risks associated with former Crown servants joining outside organisations. Those risks include using privileged access to contacts and information to the benefit of themselves or those they represent. The Rules also seek to mitigate the risks that individuals may make decisions, or take action in office, in expectation of rewards on leaving government. These risks are significantly limited in unpaid cases due to the lack of financial gain to the individual.

Though Sir Philip had no specific contact with Strategy International whilst in office, as a former Permanent Secretary of the FCDO, he may have met with Strategy International members involved in bidding for UK government contracts or supplying publicly funded projects.

There are inherent risks with Sir Philip’s access to information, privileged network of contacts and his potential influence within government, as a former Permanent Secretary. The Committee agreed with the FCDO that the risks associated with this unpaid role are limited.

3. The Committee’s advice

The Committee did not consider this unpaid appointment to raise any particular concerns under the government’s Business Appointment Rules. The standard conditions below sufficiently mitigate the inherent risks. These seek to prevent Sir Philip from making improper use of privileged information, contacts and influence to the unfair advantage of the organisation.

Therefore, in accordance with the government’s Business Appointment Rules, the Committee advises that this appointment with Strategy International Holdings Ltd be subject to the following conditions:

• Sir Philip should not draw on (disclose or use for the benefit of himself or the persons or organisations to which this advice refers) any privileged information available to him from his time in Crown service;

• for two years from his last day in Crown service, he should not become personally involved in lobbying the UK government or its arm’s length bodies on behalf of Strategy International Holdings Ltd (including parent companies, subsidiaries, partners and clients); nor should he make use, directly or indirectly, of his contacts in the government and/or Crown service to influence policy, secure business/funding or otherwise unfairly advantage Strategy International Holdings Ltd (including parent companies, subsidiaries, partners and clients); and

• for two years from his last day in Crown service, he should not undertake any work with Strategy International Holdings 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 his 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 4]}. 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/Civil Service Code or otherwise.

The Business Appointment Rules explain that the restriction on lobbying means that the former Crown servant ‘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.’

Sir Philip must inform us as soon as he takes up this role, or if it is announced that he will do so, and we will publish this letter on our website. He must also inform us if he proposes to extend or otherwise change the nature of his role as, depending on the circumstances, it may be necessary for him to make a fresh application.

4. Annex – Material Information 

4.1 The role

Strategy International Holdings Ltd (Strategy International) offers business networking and trade and investment consulting services to businesses registered in the UK. Strategy International owns, supports and co-ordinates a group of five interlinked organisations that report to having a shared objective to significantly enhance the United Kingdom’s prosperity:

• The D Group - which uses its network of business, government, technology, and thought leaders to provide important insights and connections for its diverse members’ leadership;

• British Expertise International - who deliver emerging market export insights and opportunities for the UK hard and soft infrastructure sector;

• British Foreign Policy Group - a think tank providing original research and polling on UK foreign policy views from diverse domestic stakeholders, with a focus on UK enterprise.;

• The Future Leaders Group - which delivers strengths-based training and development programmes for mid-career executives destined for C-level; and

• Defence Impact - a not-for-profit enterprise created to support and enhance the partnership between UK Business and the Nation’s Armed Forces.

Sir Philip wishes to take up a part-time, unpaid role as a Member of the Advisory Board. The Board’s function is to offer input during three annual advisory board meetings, addressing various challenges for UK and international business. Additionally, board members are available to advise group management on current issues as needed. The Board holds no governance responsibilities or standing. Sir Philip will contribute by providing insights on geopolitical trends and international events. This includes assessing their potential impact on Strategy International’s business network members and facilitating UK and international contacts to enhance members’ understanding and responses.

4.2 Dealings in office 

Sir Philip stated that he did not make any policy, regulatory or commercial decisions specific to Strategy International, and that he did not have any access to information that could grant the organisation an unfair advantage. He also stated that there was no relationship between Strategy International and the FCDO.

4.3 Departmental assessment 

The FCDO and Cabinet Office confirmed that Sir Philip did not make any policy, regulatory or commercial decisions specific to Strategy International.

The Cabinet Office noted that due to the seniority of his official role, Sir Philip may have had access to government policy in development which could be perceived to be of assistance to Strategy International.

The Cabinet Office also stated that as a former Permanent Secretary of the FCDO, Sir Philip may have met with Strategy International members involved in bidding for UK Government contracts or supplying publicly funded projects.

The FCDO and Cabinet Office recommended the 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 Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Michael Prescott; and The Baroness Thornton. Dawid Konotey-Ahulu CBE DL was unavailable. ↩

3. By unpaid the Committee means that no remuneration of any kind is received for the role. Applicants must declare where it is agreed or anticipated they may receive remuneration or some other compensation at some stage in the future. ↩

4. 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. ↩