Decision

Advice Letter: Robert Courts, commission with Marshall of Cambridge (Holdings) Limited under Ascalane Partners Ltd

Updated 7 July 2026

1. BUSINESS APPOINTMENT APPLICATION: Robert Courts KC, former Solicitor General, Attorney General’s Office – Paid commission with Marshall of Cambridge (Holdings) Limited under the independent consultancy, Ascalane Partners Ltd 

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on taking up a commission with Marshall of Cambridge (Holdings) Limited, trading as Marshall Group, under your independent consultancy, Ascalane Partners Ltd (Ascalane).

The purpose of the Rules, as you will be aware, is to protect the integrity of government and to avoid any suspicion that those who have served in government might profit improperly from that experience or that an employer might gain unfair advantage through privileged access to government. To achieve these aims, I designate conditions that former ministers must follow. 

The material information and my consideration are set out in the annex. In light of this, I consider the following conditions, as applied to Ascalane, to be appropriate, recognising that it is your responsibility to ensure that these are demonstrably applied in practice:

• Privileged information condition – You should not draw on (disclose or use for the benefit of Marshall of Cambridge (Holdings) Limited, including its related parties) any privileged information available to you from your time in ministerial office. This is an ongoing duty irrespective of the time elapsed since you left office.
• Lobbying condition – For two years from your last day in office, you should not become personally involved in lobbying the UK Government or its arm’s length bodies on behalf of Marshall of Cambridge (Holdings) Limited (including its related parties); 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 Marshall of Cambridge (Holdings) Limited (including its related parties).
• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with Marshall of Cambridge (Holdings) Limited (including its related parties) 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.
• Business development restriction – For two years from your last day in office, you should not become personally involved in lobbying contacts you acquired during your time in office in other governments and organisations for the purpose of securing business for Marshall of Cambridge (Holdings) Limited (including its related parties). 

I would be grateful if you would note the following points:

• My advice is not an endorsement of the appointment.
• The advice relates solely to your previous role in government; it is separate from rules governing the registration of consultant lobbyists, from the Code of Conduct and Rules of the House of Commons and from the House of Lords Code of Conduct. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with my advice.
• By ‘privileged information’, I mean official information to which you had access as a consequence of holding office and which is not publicly available. You are also reminded that you may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code or otherwise.
• By ‘related parties’, I mean any parent companies, subsidiaries, clients and/or other partners as may be relevant.
• As set out in the Rules, the lobbying restriction means that former ministers ‘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’.

As soon as you take up the appointment, or if it is announced that you will do so, you are obliged under the Rules to inform my secretariat who will then publish this letter. 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.

Yours sincerely,

Sir Laurie Magnus CBE

Independent Adviser on Ministerial Standards

2. Annex – Material information and consideration of the risks 

2.1 The role

You stated that this is a client commission under your independent consultancy, Ascalane Partners Ltd (Ascalane), which provides advice to clients across several areas, including UK public policy, regulatory developments and the broader political landscape and on which the former Advisory Committee on Business Appointments (ACOBA) provided advice.

In this commission, you wish to advise Marshall of Cambridge (Holdings) Limited (Marshall), an aerospace and defence company in the UK, on matters including UK public policy, regulatory developments, the political landscape, international affairs and business development. This is broadly consistent with the description that you provided to ACOBA of Ascalane’s work. 

You confirmed that, in this commission, you would not:

• lobby government ministers or officials or have any UK government engagement on Marshall’s behalf
• disclose privileged information from your time in government
• seek to draw on your network of contacts in government
• have involvement with bids or contracts involving the UK government.

2.2 Dealings in office

You said that, as Solicitor General, you made no policy, regulatory or commercial decisions specific to Marshall, and you had no access to information that could grant it an unfair advantage.

2.3 Departmental assessment

The Attorney General’s Office (AGO) confirmed the details you provided. The AGO added that you hold no sensitive information specific to Marshall but may have had access to confidential and legally privileged information that could offer it an unfair advantage. 

The AGO recommended the standard conditions and highlighted that, as a former Law Officer, you are subject to a further mitigation regarding the usability of sensitive information: ‘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.’ 

2.4 My consideration of the risks 

The conditions applied to an independent consultancy role also apply to the client commissions under it. Commissions are then assessed separately to identify any new risks that were not apparent at the time the consultancy was considered and, where necessary, to advise additional conditions.   You made no policy, regulatory or commercial decisions specific to Marshall – the risk of this commission being perceived as a reward for decisions or actions in office is limited.

As Solicitor General, you may have had access to confidential and legally privileged information that could unfairly advantage any company, including Marshall. However, this risk is limited because: 

• you are subject to the Law Officers’ Convention – the fact that the Law Officers have advised or have not advised, and the content of their advice must not be disclosed outside government without their authority, as provided for under the Ministerial Code (paragraph 5.14) 
• there is no overlap between your time in office and the work undertaken by Marshall  Further, it has been nearly 24 months since you last had access to privileged information and there has since been a change in government
• you had no access to sensitive information specific to Marshall.

As a government services supplier, Marshall has a clear commercial interest in government. There is, therefore, a risk that you could be perceived to offer Marshall unfair access to government. However, this risk is limited because: 

• you have been clear the role will not include lobbying or any engagement with UK government on Marshall’s behalf 
• you confirmed that the role will not include work on UK government bids and contracts
• your role is internal and separate from Marshall’s commercial activities: you will advise Marshall on public policy, the broader political and regulatory landscape, international affairs and business development. 

Your commission involves developing Marshall’s business. You will likely have a wide network from before you entered government. However, you may also have contacts acquired as a result of your ministerial role and there is a risk that you could be seen to advantage Marshall were you to draw on such contacts to secure business on its behalf. I have therefore applied a condition preventing you from lobbying external contacts acquired only as a result of your time in office to secure business – this is consistent with the conditions applied to Ascalane.

I therefore consider the risks related to this appointment to be appropriately mitigated by the conditions applied to your Ascalane role and advise no additional conditions should apply to this commission.