Decision

Advice Letter: Crawford Falconer, Senior Advisor, Bradshaw Advisory Ltd

Published 10 October 2025

1. BUSINESS APPOINTMENT APPLICATION: Sir Crawford Falconer KCMG, former Second Permanent Secretary and Chief Trade Negotiation Adviser at the Department for Business and Trade. Paid appointment with Bradshaw Advisory Ltd. 

Sir Crawford sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Crown Servants (the Rules) on a proposed appointment with Bradshaw Advisory Ltd (Bradshaw Advisory) as a Senior Advisor.

The purpose of the Rules is to protect the integrity of the government. Under the Rules, the Committee’s remit is to consider the risks associated with the actions and decisions taken during Sir Crawford’s recent time in government service, alongside the information and influence a former senior Crown servant may offer Bradshaw Advisory. 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 Rules^{[footnote 1]} set out that Crown servants must abide by the Committee’s advice. It is an applicant’s personal responsibility to manage the propriety of any appointment. Former Crown servants 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

Bradshaw Advisory is a public affairs and economics consultancy that helps clients solve public policy challenges by providing expertise in economics, data, policy, and public.  Sir Crawford seeks to work within its planned Trans-Atlantic Trade and Security Unit to provide advice to UK and US businesses on matters of trade and security.  His role will focus on senior counsel; US, global risk and horizon scanning; advising on specific tariff and customs issues; and advising on the interpretation of legislation and international agreements. 

As Second Permanent Secretary and Chief Trade Negotiation Adviser, Sir Crawford held a central and influential role within the Civil Service. He would therefore have had oversight of the broad direction of decisions within his former department (the Department for Business and Trade^{[footnote 2]} -DBT). His only interaction with Bradshaw Advisory in office was speaking at a breakfast roundtable event it hosted in September 2024.  Sir Crawford made no decisions, commercial or otherwise, specific to Bradshaw Advisory  during his recent time in government service. Therefore, the Committee^{[footnote 3]}considered the risk he could reasonably be seen to have been offered this role as a reward for decisions made, or actions taken, in office was low. 

Sir Crawford held privileged insight on government policy, including the strategic thinking surrounding trade, related negotiations and international trade relations. The Committee considered the risks were limited. DBT is not aware of any specific information Sir Crawford was privy to that may now provide an unfair advantage to Bradshaw Advisory and/or its clients. He has also been out of government service for over nine months – putting a gap between when he last had access to information and taking up this role, reducing the likelihood it is sufficiently up to date to offer an unfair advantage. Further, since leaving government service there have been significant announcements in regard to policy decisions and forecasts on trade, both within the UK and globally which reduces the risk: 

• The UK government’s Spring Statement^{[footnote 4]} and Spending Review^{[footnote 5]} placed national economic & financial objectives in the public domain. Further, the ‘Fiscal Risk and Sustainability’ report by the Office of Budget Responsibility ^{[footnote 6]} outlined its outlook for the horizon on global trade and economic growth in the context of ongoing trade negotiations, potential tariff increases, as well as domestic responses to tariffs imposed by other nations - overall impacting on key markets in the UK. 

• External to the UK, trade policy has been significantly impacted by the response to announcements in April 2025 led by the US administration^{[footnote 7]}, and ongoing reviews of international agreements/ partnerships. Trade is a dynamic subject matter, which has been, and continues to be, affected by policy announcements by the US administration and international financial institutions such as the International Monetary Fund, World Trade Organisation and World Bank. 

• There is information available through gov.uk^{[footnote 8]} that lists measures once the UK has entered into a new trade agreement or arrangement with a third country or territory as well as the World Trade Organisation Tariff & Trade Data - a platform for open-source trade data. 

Given the factors above, the Committee agreed with DBT that the  risk related to his access to privileged information is general rather than specific. The risk regarding Sir Crawford’s access to information is greatest should he advise Bradshaw Advisory and/or its clients in relation to matters he had specific responsibility for as Second Permanent Secretary and Chief Trade Negotiation Adviser. 

As a former senior official working at the heart of government and the Civil Service, there is a risk that Sir Crawford might be seen to offer unfair access to, and influence within, government. Particularly, in the context of working for a firm that operates in public affairs and has an interest in influencing government policy. The Committee considered it significant that: 

• The role he described as Senior Advisor excludes any dealings with government; and
• Bradshaw Advisory has confirmed that he will not undertake any activities which conflict with ACOBA’s advice and he will not be involved in lobbying the UK government.

This reduces the risk Sir Crawford might be seen as lobbying government in this role, which former Crown servants are prevented from doing for two years on leaving office under the Rules. 

In addition, it was relevant to the Committee’s consideration that Sir Crawford has extensive experience in foreign affairs and trade predating his recent time in Crown service. 

3. The Committee’s advice

The Committee determined the risks identified in this application can be appropriately mitigated by the conditions below. These make it clear that Sir Crawford must not make use of any privileged access to information, contacts or influence gained from his time in government to the unfair advantage of Bradshaw Advisory. 

It is significant that Bradshaw Advisory confirmed its adherence to the Committee’s advice and, in particular, that Sir Crawford would not be involved in any lobbying of the UK government.

Alongside the standard conditions, to mitigate the risk associated with unknown clients, the Committee has imposed a restriction to prevent Sir Crawford from advising on work specifically overlapping with his recent role in government service. 

The Committee’s advice, under the government’s Business Appointment Rules, is that this appointment with Bradshaw Advisory Ltd should be subject to the following conditions:

• he should not draw on (disclose or use for the benefit of himself or the persons or organisations to which this advice refers) any privileged information available to him from his time in Crown service;

• for two years from his last day in Crown service, he should not become personally involved in lobbying the UK government or any of its arm’s length bodies on behalf of Bradshaw Advisory Ltd (including parent companies, subsidiaries, partners and clients); nor should he make use, directly or indirectly, of his contacts in the government and/or Crown service contacts to influence policy, secure business/funding or otherwise unfairly advantage Bradshaw Advisory Ltd (including parent companies, subsidiaries, partners and clients); 

• for two years from his last day in Crown service, he should not provide advice to Bradshaw Advisory Ltd (including parent companies, subsidiaries, partners and clients) 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 any of its arm’s length bodies; and

• for two years from his last day in Crown service, he should not advise Bradshaw Advisory Ltd (including parent companies, subsidiaries, partners and clients) on any policy he had specific involvement in or responsibility for as Second Permanent Secretary and Chief Trade Negotiation Adviser at the Department for Business and Trade, nor where he had a relationship with the relevant client during his recent role in Crown service. 

The advice and the conditions under the government’s Business Appointment Rules relate to an applicant’s 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 9]}. 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/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.’

Sir Crawford must inform us as soon as he takes up this work or if it is announced that he will do so. Similarly, he must inform us if he proposes to extend or otherwise change his role with the organisation as depending on the circumstances, it might be necessary for him to seek fresh advice.

Once this appointment has been publicly announced or taken up, we will publish this letter on the Committee’s website.

4. Annex - material information

4.1 The role

According to its website, Bradshaw Advisory is a UK-based public affairs and economics consultancy that helps clients solve public policy challenges by integrating expertise in economics, data, policy, and public affairs. It is a registered consultant lobbyist^{[footnote 10]}. Sir Crawford stated that Bradshaw Advisory alongside its partners in the United States - Akin Gump Strauss Hauer & Feld LLP - are establishing a Trans-Atlantic Trade and Security Unit to provide advice to UK and US businesses on matters of trade and security. 

Of the Trans-Atlantic Trade and Security Unit, Sir Crawford stated: 

• it will be run by Bradshaw Advisory
• it is yet to be formally established and will only be so with the onboarding of the business’ clients. It will potentially provide a range of advice to UK businesses on how to engage with the US administration on trade issues, how to navigate newly imposed US tariffs and supply chains as well as what might be on the horizon as regards to future global trade policy issues.

Of his paid, part-time role as Senior Advisor, Sir Crawford stated he will be providing individual businesses with some of the following services:

• senior counsel
• US, global risk and horizon scanning
• advising on specific tariff and customs issues
• advising on the interpretation of legislation and international agreements. 

Sir Crawford confirmed his role will not involve contact with the UK government

Sir Crawford’s has extensive experience in foreign affairs and trade predating his time in government, including his roles as: 

• Deputy Secretary (Vice Minister) in the New Zealand Ministry of Foreign Affairs and Trade.
• New Zealand Ambassador and Permanent Representative to the World Trade Organisation (WTO) Geneva.
• Chair of the WTO DOHA round negotiations on agriculture and cotton
• Trade strategy coordinator and WTO senior official for the New Zealand Foreign and Trade Ministry.
• Leading trade projects at the Organisation for Economic Co-operation and Development (OECD) on services and trade value added. 
• Director of Multilateral trade in the New Zealand Trade Ministry
• Fellow at the New Zealand Institute of Policy Studies.

4.2 Correspondence with Bradshaw Advisory 

Bradshaw Advisory confirmed in writing its understanding of, and agreement to, comply with the Committee’s advice.  It stated the company will support Sir Crawford in adhering to ACOBA’s conditions and will not ask him to undertake any duties that would amount to a breach of them. In doing so, Bradshaw Advisory confirmed Sir Crawford’s role will involve engagement with, and/or lobbying of, the UK government. 

4.3 Dealings in office

Sir Crawford stated on 19 September 2024, he spoke at a breakfast roundtable event hosted by Bradshaw Advisory, with guests including current and prospective clients of the company. He also added he met with competitors of Bradshaw Advisory, attending events on informal background briefings on the government’s trade, with: 

• FTI consulting on 19 June 2023.
• City UK on 2 May 2024.
• Deloitte on 29 August 2024.

Sir Crawford confirmed he was not involved in any decisions specific to Bradshaw Advisory, as a result of his meeting with the company or otherwise, nor does he possess sensitive information specific to the company. 

4.4 Departmental assessment 

DBT confirmed the details in Sir Crawford’s application and provided its views on this appointment.  It said: 

• the sole interaction with Bradshaw Advisory was as noted by Sir Crawford above
• no decisions were made as a result of this interaction, nor was he involved in any decisions, commercial or otherwise, specific to Bradshaw Advisory
• there is no funding/contractual relationship with Bradshaw Advisory but the company is a stakeholder via engagement through roundtables and/or consultations.

DBT stated Sir Crawford would have held privileged information on a range of areas, though the department was not aware of any specific information that presents a concern or likely unfair advantage to Bradshaw Advisory.

DBT stated Sir Crawford is a recognised global expert in the trade area and therefore it is reasonable that Bradshaw Advisory would have approached him as a preferred candidate, irrespective of his experience in government.

DBT recommended standard conditions and that Sir Crawford must identify his duties as a former civil servant when engaging clients of Bradshaw Advisory.

1. Which apply by virtue of the Civil Service Management Code, The Code of Conduct for Special Advisers, The King’s Regulations and the Diplomatic Service Code. ↩

2. Sir Crawford held responsibility at the Department for International Trade as Second Permanent Secretary and Chief Trade Negotiation Adviser . Following the Machinery of Government changes in March 2023, his duties moved to the then- formed Department for Business and Trade. ↩

3. This application for advice was considered by Isabel Doverty; Hedley Finn OBE; Dawid Konotey-Ahulu CBE DL; The Baroness Thornton; and Michael Prescott. Sarah de Gay was absent. ↩

4. https://www.gov.uk/government/topical-events/spring-statement-2025 ↩

5. https://www.gov.uk/government/topical-events/spending-review-2025 ↩

6. https://obr.uk/frs/fiscal-risks-and-sustainability-july-2025/ ↩

7. https://www.whitehouse.gov/presidential-actions/2025/04/regulating-imports-with-a-reciprocal-tariff-to-rectify-trade-practices-that-contribute-to-large-and-persistent-annual-united-states-goods-trade-deficits/ ↩

8. https://www.data.gov.uk/dataset/2af878bc-f302-49fd-98ef-9d1f4a63a318/tariffs-to-trade-with-the-uk-from-1-january-20211/datafile/a64ec2de-9c82-4ce9-8982-3ef88d2f11b3/preview ↩

9. 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. ↩

10. https://orcl.my.site.com/CLR_Public_Profile?id=0014J00000iC6O4QAK ↩