Decision

Advice Letter: David Rutley, Non-Executive Director, ABTA Limited

Published 27 January 2026

1. BUSINESS APPOINTMENT APPLICATION: David Rutley, former Parliamentary Under Secretary of State, Foreign, Commonwealth & Development Office  – Paid appointment as Non-Executive Director, ABTA Limited

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on taking up a paid, part-time role as Non-Executive Director at ABTA Limited. 

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 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 ABTA Limited, including its related parties and clients) 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 ABTA Limited (including its related parties and clients); nor should you make use of any contacts in government, including ministers, to influence policy or secure business/funding or otherwise unfairly advantage ABTA Limited (including its related parties and clients). 
• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with ABTA Limited (including its related parties 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.
• Engagement restriction – For two years from your last day in office, you should not initiate any engagement with the UK Government or its arm’s length bodies on behalf of ABTA Limited (including its related parties and clients).

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 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. 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.
• 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 said that ABTA Limited (ABTA) is a trade association for UK travel agents, tour operators and the wider travel industry. ABTA has an active lobbying function, representing its members’ interests to government. It also works with governments and members to ensure travel information is accurate. 

You said that you will, as Non-Executive Director, help set the strategic direction of ABTA, ensure governance and support the executive team by attending six board meetings per year. You confirmed there will be no contact with government in this role. 

2.2 Dealings in office

You said that, as a minister, you met with ABTA at an annual stakeholder event organised by the Foreign, Commonwealth & Development Office (FCDO) to learn about ABTA’s work. You said that you did not make any policy, regulatory, or commercial decisions specific to ABTA, nor had access to information that could unfairly advantage ABTA.

You added that ABTA regularly collaborates with the FCDO on many travel-related matters. This includes bi-weekly meetings with the FCDO Prevent Team and other meetings in which FCDO provides insights on travel advice changes and consular case numbers.  

2.3 Departmental assessment

The FCDO confirmed the details you provided and added that, as Minister for the Americas, Caribbean and Overseas Territories, you were responsible for policy decisions about FCDO travel advice level changes for the region. ABTA uses FCDO travel advice as a risk measure – changes can mean ABTA members must offer customers a refund and, in cases where the FCDO advises against all travel, coordinate customer returns to the UK. 

The FCDO said you had occasional meetings with ABTA at FCDO events for the travel industry and that you had one follow-up meeting with ABTA’s CEO in March 2024.

The FCDO confirmed its relationship with ABTA, adding that ABTA is a Travel Aware Partner and key industry stakeholder for Consular and Crisis Directorate teams and is crucial for amplifying travel safety messages. The FCDO stays in touch with ABTA through in-person and virtual events.

The FCDO recommended the standard conditions. 

2.4 My consideration of the risks 

As a former Minister for the Americas, Caribbean and Overseas Territories, you made decisions around travel advice level changes in this region that could be seen to broadly impact the area in which ABTA and its members operate. You also occasionally met with ABTA whilst in office. There is, therefore, a risk of perception of reward for your decisions taken in office. However, I consider this risk to be limited because: 

• you made no decisions specific to ABTA or its members 
• decisions you made would have impacted ABTA’s members both positively and negatively 
• your decisions would have been made in the context of FCDO information sources over which ABTA had no influence 
• you left office nearly 18 months ago, which places an appropriate separation between any decision-making that could be seen to broadly benefit ABTA or its members and your taking up of the role. 

The FCDO had no concerns over your access to privileged information – the risks here are therefore limited.

As a trade association, ABTA will have an interest in government policy and has an active lobbying function. It is relevant that ABTA has provided written confirmation that your role will be separate from lobbying activity. Nonetheless, due to the nature of the organisation and its relationship with your former department, there remains a risk of a perception of a former minister being employed by ABTA in order to provide unfair access and influence on behalf of the member organisations that it represents. In view of this perception risk, I have applied a condition preventing you from initiating direct engagement with the UK Government on behalf of ABTA (including related parties and clients) for a period of two  years from the 5 July 2024.