Decision

Advice Letter: Natalie Evans, Chair of the Board, St George's Guildhall and Creative Hub, King's Lynn

Updated 22 December 2023

1. BUSINESS APPOINTMENT APPLICATION: Baroness Evans of Bowes Park, former Leader of the House of Lords. Unpaid appointment with St George’s Guildhall and Creative Hub, King’s Lynn (St George’s)

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 unpaid role you want to take up with St George’s.

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 made during your time in office, alongside the information and influence you may offer to St George’s. 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

When considering this application, the Committee^{[footnote 2]} took into account this role as Chair of the Board to St George’s is unpaid^{[footnote 2]} . Generally, the Committee’s experience is that the risks related to unpaid roles are limited. The purpose of the Rules is to protect the integrity of the government by considering the real and perceived risks associated with the former ministers joining outside organisations. Those risks include: using privileged access to contacts and information to the benefit of themselves or those they represent. The Rules also seek to mitigate the risks that individuals may make decisions or take action in office to in expectation of rewards, on leaving government. These risks are significantly limited in unpaid cases due to the lack of financial gain to the individual.

The Cabinet Office confirmed this proposed role does not overlap with your time in office and the unpaid nature of this appointment limits the real and perceived risk of you making improper use of information or the network gained in government for your personal benefit.

3. The Committee’s advice

The Committee did not consider this appointment raises any particular proprietary concerns under the government’s Business Appointment Rules. The standard conditions below, preventing you from drawing on your privileged information and contacts to the unfair advantage of the St George’s, will sufficiently mitigate the risks in this case.

In accordance with the government’s Business Appointment Rules, the Committee advises this appointment with the St George’s Guildhall and Creative Hub, King’s Lynn 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 arms’ length bodies on behalf of St George’s Guildhall and Creative Hub, King’s Lynn (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 to St George’s Guildhall and Creative Hub, King’s Lynn (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 St George’s Guildhall and Creative Hub, King’s Lynn (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 arms’ 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 to rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists or the Parliamentary Commissioner for Standards. It is your personal responsibility to understand any other rules and regulations you 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 said St George’s is a charitable incorporated organisation that aims to promote the arts, culture, heritage and science. It seeks to advance the education of the public in, although not limited to, the performing and visual arts, the built heritage, creativity and entrepreneurialism throughout the United Kingdom.

You informed the Committee that your role as Chair of the Board to St George’s will include: the governance St George’s; ensuring the organisation adheres to its charitable objectives; ensuring the organisation is well run and efficient; and overseeing a professional management team who will be responsible for the day to day management of the Centre

You said your role will not involve any contact or dealings with government. Dealings in office

You confirmed you had had no official contact with St George’s when you were Leader of the House of Lords and said you:

• did not have any involvement in any relevant policy development or decisions that would have affected St George’s;

• do not have access to sensitive information that would provide an unfair advantage;

• had no commercial or contractual responsibilities relating to St George’s; and

• did not meet with competitors of St George’s nor have access to sensitive information regarding competitors.

4.2 Department Assessment

The Cabinet Office confirmed the details you provided and stated you did not meet St George’s in your official capacity. It recommended the standard conditions

1. By unpaid the Committee means that no remuneration of any kind is received for the role. Applicants must declare where it is agreed or anticipated they may receive remuneration or some other compensation at some stage in the future. ↩ ↩²