Decision

Advice Letter: Lucy Frazer, Honorary Fellow, Cambridge Judge Business School, University of Cambridge

Published 12 August 2025

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Lucy Frazer KC, former Secretary of State for the Department of Culture, Media and Sport. Paid appointment with Cambridge Judge Business School, University of Cambridge.

You sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Ministers (the Rules) on taking up an appointment with Cambridge Judge Business School, University of Cambridge, as an Honorary Fellow.

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 a former minister may offer Cambridge Judge Business School. 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

There is no direct overlap between your responsibilities in ministerial office and this role. You did not meet with Cambridge Judge Business School, nor did you make any decisions specific to the organisation whilst in office. When considering this application, the Committee^{[footnote 1]} took into account this appointment as Honorary Fellow at Cambridge Judge Business School is a partly unremunerated and academic role. Generally, the Committee’s experience is that the risks related to academic roles are limited. Therefore, the Committee considered the risk this appointment could reasonably be perceived as a reward for decisions or actions taken in office is low.

As a former minister, there are inherent risks associated with your access to privileged information, contacts and influence within government. The risks are limited given your former department confirmed they are not aware of any privileged information you had access to that may offer Cambridge Judge Business School an unfair advantage, you have been out of office for 11 months and you confirmed your proposed role would not involve contact with government.

3. The Committee’s advice

The Committee determined the risks identified can be appropriately mitigated by the conditions below. These make it clear that you cannot make use of privileged information, contacts or influence gained from your time in ministerial office to the unfair advantage of Cambridge Judge Business School.

In accordance with the government’s Business Appointment Rules, the Committee advises this role with Cambridge Judge Business School, University of Cambridge 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 Cambridge Judge Business School, University of Cambridge (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 Cambridge Judge Business School, University of Cambridge (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 Cambridge Judge Business School, University of Cambridge (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.

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 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.’

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

According to its website, Cambridge Judge Business School at the University of Cambridge offers education and research in business and management studies, from undergraduate to PhD level, and professional diplomas.

Within Cambridge Judge Business School, the Centre for Business Research conducts research on various aspects of business. The research generated helps inform decisions across the private and public sector and is utilised by researchers, businesses, civil society organisations and policymakers.

Cambridge Judge Business school maintains a relationship with the UK government broadly via contributing to government consultations, informing policy through research, and having some faculty members provide advice to the government.

In your role as Honorary Fellow, you stated the honorary aspect of this work will be unpaid, but there is scope to lead seminars, deliver speeches and mentor students. You said any lectures or speeches you deliver will be paid. You said you will not have any contact with the UK government in this role.

4.2 Dealings in office

You informed the Committee that in your capacity as a minister, you did not meet with, nor were involved in any policy, regulatory or commercial decisions, nor had access to sensitive information specific to Cambridge Judge Business School.

4.3 Departmental assessment

The Department for Culture, Media and Sport (DCMS) confirmed the details you provided, including that you made no decisions specific to Cambridge Judge Business School and you had no access to information that is likely to offer the organisation an unfair advantage.

DCMS recommended the standard conditions.

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