Decision

Advice Letter: Viscount Camrose, Non Executive Director, Lumi Network Limited

Updated 18 June 2025

1. BUSINESS APPOINTMENT APPLICATION: The Viscount Camrose, former Parliamentary Under Secretary of State (Minister for Artificial Intelligence and Intellectual Property) in the Department for Science, Innovation and Technology. Paid appointment with Lumi Network Limited. 

You approached the Advisory Committee on Business Appointments the Committee under the government’s Business Appointments Rules for Former Ministers (the Rules) seeking advice on taking up a paid role as a Non Executive Director with Lumi Network Limited (Lumi Network). 

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 your time in office, alongside the information and influence you may offer Lumi Network. 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 Ministerial Code sets out that ministers must abide by the Committee’s advice.  It is an applicant’s personal responsibility to manage the propriety of any appointment. Former ministers of the Crown, and Members of Parliament, 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

As Minister for Artificial Intelligence and Intellectual Property at the Department for Science, Innovation and Technology (DSIT), you met with a range of companies operating in the Artificial Intelligence (AI) sector, including Lumi Network. DSIT confirmed that any policy decisions you were involved in would have been related to the AI sector as a whole – not to Lumi Network specifically. Therefore, the Committee[1] considered the risk this role could reasonably be seen as a reward for decisions made in office was low.

As a former minister at DSIT, you had access to privileged information on AI policies and priorities of the UK government. DSIT was not aware of any specific information you had access to that would offer an unfair advantage to this company; and it has been over three months since you last had access to information as a minister.

There are risks associated with your influence and network of contacts gained whilst in ministerial office. As an educational technology firm, Lumi Network would have a general interest in the direction of government policy in relation.  However, you noted your role will not involve contact with, or lobbying of government.

Your role involves advising Lumi Network on identifying business opportunities and strategy. There is therefore a risk of unfair advantage to Lumi Network, were you to draw specifically on private sector contacts that you only gained as a result of your role as Minister for Artificial Intelligence and Intellectual Property.

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 privileged information, contacts or influence gained from your time in ministerial office to the unfair advantage of Lumi Network.

Additionally, the Committee imposed a restriction on lobbying contacts you made during your time in office in other governments and organisations outside of the UK government for the purpose of securing business for Lumi Network

In accordance with the government’s Business Appointment Rules, the Committee advises this appointment with Lumi Network 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 Lumi Network 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 Lumi Network Limited  Limited (including parent companies, subsidiaries, partners and clients);

• for two years from your last day in ministerial office, you should not undertake any work with Lumi Network Limited (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; and

• for two years since your last day in ministerial office, you should not become personally involved in lobbying contacts you developed during your time in office in other governments and organisations for the purpose of securing business and investments for Lumi Network Limited.

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[2]. 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 stated Lumi Network is an educational technology company. According to its website, it is an AI-augmented lifelong learning platform for 10-25-year-olds to solve real world problems (aligned to the United Nations Sustainability Development Goals) and build skills to prepare them for college, career and life.

In your (paid) role as Non Executive Director, you stated role will involve identifying business opportunities, help develop business strategy, and contribute to board oversight.

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

4.2 Dealings in office

You informed the Committee that you had extensive dealings with the tech sector - with tech businesses of all sizes, operating in both hardware and software, including an introductory meeting with the CEO of Lumi Network.

You stated you were not involved in any policy, commercial or regulatory decisions, nor do you possess any sensitive information specific to Lumi Network.

4.3 Departmental assessment 

DSIT confirmed the details you provided, and:

1. You were not involved in decisions specific to Lumi Network & any policy decisions you were involved in would have been related to the AI sector as a whole.
2. You had a formal introduction with the CEO of Lumi Network, with no follow up or decisions made as a result.
3. You would have had contact with companies broadly operate/involved in AI and its application, though nothing specific regarding competitors of Lumi Network who operate in educational technology.
4. It flagged no specific information you may possess, noting changes in the department’s direction and policy following the change in government administration as an additional limiting factor and stating that the relevant information from your time in government is in the public domain.
5. DSIT did not have concerns with the appointment and noted the importance of your ongoing duty of confidentiality.

DSIT recommended the standard conditions.

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

[2] 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.