Decision

Advice letter: Baroness Blackwood, Advisory Board Member, Reuben College, Oxford University

Updated 27 April 2022

The Committee has considered your application to work with Reuben College, Oxford University.

1. The Committee’s role and remit

As you will be aware, it is the Committee’s role to advise on the conditions that should apply to appointments or employment under the Government’s Business Appointments Rules for Former Ministers (the Rules), which apply to former Ministers for two years after they leave office. The Rules seek to counter suspicion that:

a) the decisions and statements of a serving Minister might be influenced by the hope or expectation of future employment with a particular firm or organisation; or

b) an employer could make improper use of official information to which a former Minister has had access; or

c) there may be cause for concern about the appointment in some other particular respect.

When the Committee considers applications, it must have in mind that the Government has judged that it is in the public interest that former Ministers with experience in Government should be able to move into business or into other areas of public life, and to be able to start a new career or resume a former one. It is equally important that when a former Minister takes up a particular appointment or employment, there should be no cause for any suspicion of impropriety.

It is not the Committee’s role to pass judgment on whether an appointment is appropriate or suitable in any other regard.

2. The Application

You sought the Committee’s advice on taking up an unpaid part time role as an advisory board member for Reuben College, Oxford University.

You said Reuben College is a new graduate college of the University of Oxford, dedicated to fostering interdisciplinary exchange within an inclusive, innovative and impact-oriented community. The website states ‘Reuben College provides a scholarly home where students will thrive in an environment driven by entrepreneurial thinking, collaborative working and intellectual discovery’. You informed the Committee as an advisory board member you will ‘…offer strategic advice to assist Reuben College providing a high quality, well governed scholarly home where students will thrive in an environment driven by entrepreneurial thinking, collaborative working and intellectual discovery’. You said you were contacted directly by Professor Lionel Tarassenko with whom you have a long standing professional relationship. You said he is a former constituent and you worked together when you were Chair of Science &Technology Select Committee. You said your role will not involve contact with government.

You informed the Committee you did not meet Reuben College whilst in office as it did not exist while you were a Minister. However, you did inform the Committee Professor Tarassenko was one of the authors of the Topol Review which fell within her portfolio. He is also Head of R&D at Sensyne which has dealings with DHSC but you confirmed you did not meet him in that capacity during your time at the Department. You stated all your meetings with external organisations/individuals are published in accordance with Cabinet Office guidelines.

You confirmed you had no involvement in relevant policy development or decisions in relation to Reuben College and are unaware of any contractual relationship between the Department for Health and Social Care (DHSC) and Reuben College. You also informed the Committee that you are the current Chair of Genomics England.

Your former Department, DHSC was contacted about this application. It confirmed your application details and stated it had no concerns with you taking up this appointment. The Department further confirmed you did not have any access to sensitive information relevant to the organisation and confirmed it does not have a relationship with the organisation.

3. The Committee’s consideration

The Committee noted that you made no contractual or policy decisions whilst in office that would have affected Reuben College directly and the Department has raised no concerns with this appointment. The Committee considered therefore, the risk this unpaid appointment is a reward for actions taken whilst in office is low.

The Committee also considered as a former Minister it could be perceived you have access to general information that could provide the organisation with an unfair advantage. However, the Department confirmed that you did not have access to sensitive information that would be relevant to Reuben College, and the Committee noted that over 11 months have now passed since you held office. The Committee therefore did not consider the risks surrounding your access to privileged information to be high. It would nevertheless draw your attention to the conditions below which prevent you from drawing on any privileged information from your time in office, or in any ongoing role in which you have contact with the UK Government, to advise Reuben College.

As a former Minister, you are also prevented from lobbying the UK Government, including indirectly via your contacts within Government/Whitehall. The Committee would also draw your attention to the below restriction that would prevent you from providing advice on the terms of a bid with, or contract relating directly to the work of, the UK Government.

The Committee would therefore recommend that this application to join Reuben College, Oxford University be made 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 Reuben College, Oxford University (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 Reuben College, Oxford University (including parent companies, subsidiaries, partners and clients); and

  • for two years from your last day in Ministerial office you should not undertake any work with Reuben College, Oxford University (including parent companies, subsidiaries, partners and clients) that involves providing advice on the terms of a bid with, or contract relating directly to the work of, the UK Government and its Arm’s Length Bodies.

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/Minister “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.”

The Committee also notes that in addition to the conditions imposed on this appointment, there are separate rules in place with regard to your role in the House of Lords.

I should be grateful if you would inform us as soon as you take up this appointment, or if it is announced that you will do so. We shall otherwise not be able to deal with any enquiries since we do not release information about appointments that have not been taken up or announced. This could lead to a false assumption being made about whether you had complied with the Ministerial Code. Similarly, I should be grateful if you would inform us if you propose to extend or otherwise change your role with the organisation as depending on the circumstances, it might be necessary for you to seek fresh advice.

Once this 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.