Decision

Advice Letter: Rehman Chisthi, UK Parliamentary Visiting Fellow, University of Oklahoma

Published 9 October 2023

1. BUSINESS APPOINTMENT APPLICATION: Rehman Chishti, former Minister for North America, Sanctions and Consular Policy. Paid appointment with the University of Oklahoma.

You sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointments Rules for Former Ministers (the Rules) on an appointment you wish to take up with the University of Oklahoma as a UK Parliamentary Visiting Fellow.

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 you made during your time in office, alongside the information and influence you may offer the University of Oklahoma. 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

The FCDO confirmed that you did not meet with the University of Oklahoma, nor had any involvement in any decisions specifically affecting the university. The Committee^{[footnote 1]} considered the risk this appointment could reasonably be perceived as a reward for decisions made or actions taken in office is low.

You confirmed that during your time as Minister for North America, you had no access to specific information of relevance to this proposed role, which the FCDO confirmed. It is significant that you were in office for a limited period and have been out of office for over 12 months. This limits the inherent risks associated with your access to information as a former minister.

There are inherent risks associated with any former minister’s contacts in government. The risks are significantly limited in this case given this is a short term academic role with no involvement in the university’s wider business.

3. The Committee’s advice

The Committee did not consider this appointment raises any particular proprietary concerns under the government’s Rules, subject to the conditions below. These make it clear that you cannot make use of your access to privileged information, contacts or influence gained from your time in ministerial office to the unfair benefit of the University of Oklahoma.

The Committee advises, under the government’s Business Appointment Rules, that your role with the University of Oklahoma should 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 government or its arm’s length bodies on behalf of the University of Oklahoma (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 the University of Oklahoma, including parent companies, subsidiaries, partners and clients); and

• for two years from your last day in ministerial office, you should not provide advice to the University of Oklahoma (including parent companies, subsidiaries, partners and clients) on the terms of, or with regard to the subject matter of, a bid with, or contract relating directly to the work of government or its arm’s length bodies.

The advice and the conditions under the government’s Business Appointment Rules relate to an individual’s previous role in government only; they are separate to rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists or the Parliamentary Commissioner for Standards. It is an individual’s 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 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.” This Rule is separate and not a replacement for the Rules in the House.

You must inform us as soon as you take up this role, or if it is announced that you will do so. 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.

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 informed the Committee that you wish to take up a short term paid appointment as a UK Parliamentary Visiting Fellow with the University of Oklahoma. You said your role will entail-

○ Speaking with students in various classes. For example- in economics, political science, religions studies, and international area studies.

○ 3 town hall style public speaking events as a parliamentarian, covering topics on: the UK political system, religious freedom, the UK-USA special relationship

You said your role will not involve any contacts or dealing with government.

4.2 Dealings in office.

You advised the Committee that during your time as Minister for North America, you had no specific access to information of relevance to the University of Oklahoma.

You advised the Committee that you did not make any policy or regulatory decisions specific to the University of Oklahoma, nor did you meet them whilst in office.

4.3 Department Assessment

The FCDO confirmed the details you provided and recommended standard conditions be applied.

1. This application for advice was considered by: Sarah de Gay; The Rt Hon Lord Pickles; Mike Weir; The Baroness Jones of Whitchurch; Andrew Cumpsty; and Isabel Doverty. ↩