Decision

Advice Letter: Natalie Evans, Senior Adviser, Gresham House Asset Management Limited

Updated 22 December 2023

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Baroness Evans of Bowes Park, former Leader of the House of Lords. Paid appointment to join Gresham House Asset Management Limited.

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 appointment you wish to take up with Gresham House Asset Management Limited (Gresham House) as a Senior Adviser to Gresham House, British Sustainable Infrastructure Funds (BSIF). The material information taken into consideration by the Committee is set out in the annex below.

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 Gresham House. 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 risk presented

The Committee^{[footnote 1]} noted you did not meet with Gresham House during your time as a minister. The Cabinet Office also confirmed you did not make any decisions specific to Gresham House whilst in office. Therefore, the Committee considered the risk this appointment could reasonably be perceived as a reward for decisions made or actions taken in office is low.

As a former minister, there are inherent risks associated with your access to privileged information as well as your contacts and influence within government. However, the Cabinet Office confirmed there was no direct overlap with your time in office and it did not have any concerns regarding your access to information. The Committee also noted your proposed role would not involve any contact with government.

You informed the Committee that part of your role will be to advise the Fund and their ‘portfolio companies’ on UK public policy developments and the broader political landscape. As such, the Committee noted there is a risk of the unknown nature of the clients associated with the Fund and there is a risk you may advise on matters that overlap with your time in office, which would raise risks under the Rules.

3. The Committee’s advice

To address the risk associated with Gresham House’s unknown clients, the Committee considered it necessary to impose a further condition. This makes it clear that in working with the company, you should not advise on work with regard to any policy you had specific material involvement in or responsibility for in your recent time as Lord Privy Seal and Leader of the House of Lords. The Committee noted this risk was limited given your responsibility in government was surrounding matters within the House, not policy development.

The Committee did not consider this appointment raises any particular proprietary concerns under the government’s Business Appointment Rules. The standard conditions below will sufficiently mitigate the risks in this case. These seek to prevent you from drawing on your privileged information, contacts and influence gained in ministerial office to the unfair advantage of Gresham House.

Taking these factors into account, in accordance with the government’s Business Appointment Rules, the Committee’s advice is this appointment with Gresham House Asset Management Limited 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 Gresham House Asset Management Limited (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 Gresham House Asset Management Limited (including parent companies, subsidiaries, partners and clients);

• for two years from your last day in ministerial office you should not undertake any work with Gresham House Asset Management Limited (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; and

• for two years since your last day in office, you should not advise Gresham House Asset Management Limited or its subsidiaries on any work with regard to any policy you had material involvement in or specific responsibility for as Lord Privy Seal and Leader of the House of Lords nor where you had a relationship with the relevant business during your time as Lord Privy Seal and Leader of the House of Lords.

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 the nature of the company is in specialist asset management - focused on investing in sustainable companies. Its parent company is Gresham House plc. Its website says Gresham House is a specialist alternative asset manager, listed on the London Stock Exchange’s Alternative Investment Market (AIM). They offer a broad range of funds, direct investments and tailored investment opportunities. Their clients include individual investors, financial advisers, institutional investors, charities and endowments, family offices, and business owners

You said you will be an external adviser as part of the British Sustainable Infrastructure Funds^{[footnote 2]} (BSIF) Advisory Board. You said you would provide strategic analysis, insight and advice to the Fund and their portfolio companies on UK public policy developments and the broader political landscape which may affect them and their wider corporate interests. You also said this role will not involve any lobbying of government on behalf of the Fund or its clients.

4.2 Dealings in office

You advised the Committee that you did not meet with Gresham House whilst in office. You said you did not have any involvement in policy, regulatory or commercial decisions that would have been specific to the company.

4.3 Departmental assessment

Cabinet Office confirmed the details you provided confirming there is no departmental relationship with Gresham House and confirmed that you made no policy decisions relating to Gresham House. Cabinet Office confirmed you did not have access to sensitive information and had no concerns with the appointment, recommending the standard conditions.

1. This application for advice was considered by Jonathan Baume; Andrew Cumpsty; Isabel Doverty; Sarah de Gay; The Rt Hon Lord Pickles; Mike Weir; Richard Thomas and Lord Larry Whitty. ↩

2. This is a fund focussed on investments that ‘…are good for people and the planet’. ↩