Decision

Advice Letter: Robert Courts, Chair of the Advisory Board, Aviation Infrastructure Resilience

Updated 1 July 2025

1. BUSINESS APPOINTMENT APPLICATION: Mr Robert Courts KC, former Solicitor General at the Attorney General’s Office. Paid appointment with Aviation Infrastructure Resilience.

You sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Ministers (the Rules) on taking up an appointment with Aviation Infrastructure Resilience (AIR) as Chair 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 taken during your time in office, alongside the information and influence a former minister may offer AIR. 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

There is no direct overlap between your ministerial responsibilities at the Attorney General’s Office and this role. Whilst you previously held a ministerial role related to aviation, you left this more than two and a half years ago and this is a new media platform. As Solicitor General you did not meet with AIR, nor did you make any decisions specific to the company. Therefore, the Committee^{[footnote 1]} considered the risk this appointment could reasonably be perceived as a reward for decisions or actions taken in office is low.

As a former minister, there are inherent risks associated with your access to privileged information, contacts and influence within government. The risks are limited given the AGO confirmed it is not aware of any privileged information you had access to that may offer AIR an unfair advantage.  Further, you have been out of office for 11 months and you are subject to the Law Officers’ Convention which prevents you from disclosing legally privileged and confidential information outside government, including Law Officer’s advice.

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 AIR – this includes the ban on lobbying the UK government on behalf of AIR or its partners, such as the British Aviation Group.

In accordance with the government’s Business Appointment Rules, the Committee advises this role with Aviation Infrastructure Resilience 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 AIR (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 AIR (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 AIR (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 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.^{[footnote 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 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.’

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 said AIR is a new media platform and annual event around responsible growth of aviation infrastructure in the UK, with the first event scheduled for 30 September to 1 October 2026 in London.

According to AIR’s website, it is a business-to-business digital platform for the UK aviation infrastructure sector to network and share best practices in sustainability, resilience, and digitisation. It is aimed at UK airports, investors, central and local government and top-tier suppliers. The platform will share a variety of digital content, including webinars and podcasts, and will host an annual conference in partnership with the British Aviation Group – a representative body for British companies involved in aviation and airport development and operation.^{[footnote 3]}

In your paid role as Chair of the Advisory Board, you stated you will oversee quarterly meetings; contribute to the digital and live programmes (keynote addresses, podcasts etc.); and contribute to media and sector-outreach. You described it as a management and advocacy role and said there will be no contact with government.

4.2 Dealings in office

You informed the Committee that in your capacity as Solicitor General, you did not meet with, nor were involved in any policy, regulatory or commercial decisions, nor had access to sensitive information specific to AIR.

4.3 Departmental assessment

The AGO confirmed the details you provided, including that you made no decisions specific to AIR and you had no access to information that is likely to offer the company an unfair advantage.

Whilst the AGO did not consider you had access to information that would offer AIR an unfair advantage, the AGO stated you had access to legally privileged and confidential information, including Law Officers’ advice. The AGO noted ‘in addition to legal privilege, Law Officers’ advice is subject to the Law Officers’ Convention, which provides that neither the existence nor content of any Law Officers’ advice should be disclosed outside government without the Law Officers’ explicit consent.’

The AGO stated no concerns and recommended the standard conditions.

1. This application for advice was considered by Isabel Doverty; Hedley Finn OBE; The Baroness Thornton; and Michael Prescott. Sarah de Gay 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. ↩

3. https://www.britishaviationgroup.co.uk/about/ ↩