Decision

Advice letter: Robert Courts, Partner, Future Fuels Partnership

Published 5 November 2025

The advice below was considered and provided by ACOBA before it closed on 12 October 2025, but taken up by the applicant on or after 13 October and therefore published after the ACOBA’s closure. The Independent Adviser has not had a role in this advice.

1. BUSINESS APPOINTMENT APPLICATION: Mr Robert Courts KC, former Solicitor General at the Attorney General’s Office. Paid appointment with Future Fuels Partnership.

You approached the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for former Ministers (the Rules) seeking advice on taking up a paid role as a Partner with Future Fuels Partnership (FFP).

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 you may offer FFP. 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

You described FFP as a clean fuel consultancy company which deals with supplier companies. You stated that, as Partner, you would be responsible for overseeing operations relating to sustainable fuel distribution. Either with FFP as an intermediary, or as a distributor itself, to industries with high fuel consumption who wish to see better environmental and cost outcomes.

As Solicitor General at the Attorney General’s Office (AGO), you were not responsible for any commercial, regulatory, or policy decisions specific to FFP or the sector it operates in, nor did you meet with the company during your time in office. Therefore, the Committee^{[footnote 1]} considered the risk that you were offered this role as a reward for decisions or actions taken in post was low.

As a former minister, you will have had access to general sensitive information that could benefit many organisations, including FFP. The AGO noted that, as former Solicitor General, you would have had access to legally privileged information and insight that could offer clients of FFP an unfair advantage. The Committee considered the risks limited as the AGO did not note any specific information that presents a risk and alongside your ongoing duty of confidentiality, you are also subject to the Law Officers’ Convention.

Whilst limited, the risk regarding your access to information is greatest should you advise FFP or its clients in relation to matters you had specific responsibility for whilst in office. As FFP’s clients and the specific work you will be asked to undertake are unknown, this is a risk which may arise. .

As with any former minister, there are risks associated with your contacts and influence within government and the potential for FFP to gain unfair access or influence as a result. The Committee considered it significant that your role as Partner of FFP excludes any dealings with government, in accordance with the lobbying ban that applies to all former ministers for two years after leaving office.

There are also risks associated with your network of contacts in external organisations gained whilst in ministerial office. You stated that, as Partner, you will oversee operations relating to sustainable fuel distribution. There is therefore a risk of unfair advantage to FFP, were you to draw specifically on contacts that you only gained as result of your role in office.

3. The Committee’s advice

The Committee determined the risks identified can be appropriately mitigated by the conditions below. These seek to prevent use of privileged information, contacts or influence gained from your time in ministerial service to the unfair advantage of FFP. Alongside the standard conditions, to mitigate the risk associated with unknown clients, the Committee has imposed a restriction to prevent you from advising on work specifically overlapping with your recent ministerial role.

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 FFP.

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

• for two years from your last day in ministerial office you should not undertake any work with Future Fuels Partnership (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;

• for two years since your last day in ministerial office, you should not advise Future Fuels Partnership (including parent companies, subsidiaries, partners and clients) on any policy you had specific involvement in or responsibility for as Solicitor General at the Attorney General’s Office, nor where you had a relationship with the relevant client during your time in the role; and

• for two years from your last day in ministerial office, you should not become personally involved in lobbying contacts you have developed during your time in office and in other governments and organisations for the purpose of securing business for Future Fuels Partnership (including parent companies, subsidiaries and partners).

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 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, this advice will be published.

Isabel Doverty

Interim Chair

ACOBA

4. Annex - Material information

4.1 The role

You stated that FFP is a partnership also involving Rt Hon Nigel Adams, former Minister of State without Portfolio at the Cabinet Office and Tom Pursglove, the former Minister of State for Legal Migration and the Border. Its focus is on clean and future fuels with supplier companies

You stated that, in your paid, part-time role as Partner, you will be responsible for overseeing operations relating to sustainable fuel distribution – either with FFP as an intermediary, or a distributor itself – to industries with high fuel consumption who wish to see better environmental and cost outcomes.

You stated your role will not involve contact with government.

4.2 Dealings in office

You stated you did not have involvement in any policy, commercial or regulatory decisions specific to FFP, nor did you meet with the company during your time in office. You added that you do not possess sensitive information that could provide an unfair advantage to FFP.

4.3 Departmental assessment

The AGO confirmed the details you provided and stated the following:

• it did not have any concerns regarding decisions or policies made during your time in office; and

• you had access to confidential and legally privileged information which if disclosed inappropriately could be considered to offer an unfair advantage to FFP and its clients.

The AGO recommended the standard conditions to appropriately mitigate the risk relating to the access and use of any sensitive information you may possess. The department also highlighted that: ‘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.’

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