Decision

Advice letter: George Freeman, Chairman of the Advisory Board, Nodenza Venture Partners Management PLC

Updated 18 June 2025

1. BUSINESS APPOINTMENT APPLICATION: Mr George Freeman MP, former Minister of State for Science, Research and Innovation. Paid appointment with Nodenza Venture Partners Management PLC.

You approached the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Ministers (the Rules) seeking advice on taking up a paid role as Chairman of the Advisory Board with Nodenza Venture Partners Management PLC (Nodenza).

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 Nodenza, as a former minister. 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

As Minister of State for Science, Research and Innovation at the Department for Science, Innovation and Technology (DSIT), you met with a range of companies operating in the life sciences sector. DSIT confirmed you did not meet with, nor were you involved in decisions specific to Nodenza during your time in office. The department stated that any policy decisions or engagement you were involved in would have been related to the life sciences sector as a whole, not Nodenza specifically. Therefore, the Committee^{[footnote 1]} considered the risk this role could reasonably be seen as a reward for decisions made in office was low.

As a former minister at DSIT, you had access to privileged information on scientific, technological and industrial policies and priorities of the UK government. DSIT was not aware of any specific information you had access to that would offer an unfair advantage to this company, and it has been over 6 months since you last had access to information as a minister.

There are risks associated with your influence and network of contacts gained in ministerial office. As a venture capital firm that invests in companies operating in the biotechnology, medical devices, and life sciences sectors, it would have a general interest in the direction of government policy in relation to these areas. However, you noted you will not lobby government on its behalf, and this will not form part of your role.

Your role involves advising Nodenza’s partners on matters that might help to build its investment portfolio. There is therefore a risk of unfair advantage to Nodenza, were you to draw specifically on private sector contacts that you only gained as a result of your role as Minister of State for Science, Research and Innovation. However, the Committee noted your experience gained in science and innovation prior to your time in office.

3. The Committee’s advice 

The Committee considered the conditions below are sufficient to mitigate the risks related to this role. These seek to prevent you from making use of privileged information, contacts and influence gained from your recent time in ministerial office to the unfair advantage of Nodenza.

In accordance with the government’s Business Appointment Rules, the Committee advises this appointment with Nodenza Venture Partners Management PLC 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 any of its arm’s length bodies on behalf of Nodenza Venture Partners Management PLC (including parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or ministerial office to influence policy, secure business/funding or otherwise unfairly advantage Nodenza Venture Partners Management PLC (including parent companies, subsidiaries, partners and clients);

• for two years from your last day in ministerial office, you should not provide advice to or on behalf of Nodenza Venture Partners Management PLC (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;

• for two years from your last day in ministerial office, you should not become personally involved in lobbying contacts you developed during your time in office in other governments and organisations for the purpose of securing business for Nodenza Venture Partners Management PLC.

The advice and the conditions under the government’s Business Appointment Rules relate to your previous role in government only; there are separate 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]} You are reminded that as a Member of Parliament you have a separate ban on paid lobbying under the Parliamentary Code of Conduct. 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 employment with this organisation, or if it is announced that you will do so. Please 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, Nodenza is a venture capital firm based in New York. The firm invests in companies operating in the biotechnology, medical devices, and life sciences sectors. You added it has no known relationship with government.

In your paid, part-time role as Chairman of Advisory Board, you stated that your role will involve:

• chairing the twice yearly advisory board meeting;

• giving advice to partners on the biotech, science and research and development industries;

• providing other ad hoc advice to partners in support of venture capital funding as required.

You stated you made it clear to Nodenza that your role will not include lobbying or contact with government.

You stated you considered this as returning to a former career prior to becoming an MP and then a minister. You stated that your previous work focused on science and technology consulting, corporate finance advisory, and investing. You added that you worked for the Cambridge Cluster,^{[footnote 3]} founding and financing high-growth technology companies and promoting industries in biology and life sciences.

4.2 Dealings in office. 

You advised the Committee that you did not meet with, nor were you involved in policy, regulatory or commercial decisions specific to Nodenza. You stated that you do not possess sensitive information specific to the company.

4.3 Departmental Assessment 

DSIT confirmed the details you provided and stated the following:

• DSIT identified no strong link to any competitor but noted you will have been present at events with life sciences strategy companies throughout your time as minister;

• DSIT does not hold a relationship to Nodenza;

• you did not meet with, nor were involved in decisions specific to Nodenza, and any policy decisions or engagement you were involved in would have been related to the life sciences sector as a whole; and

• you do not possess sensitive information specific to Nodenza. DSIT noted that, as a longstanding Minister for Science, you had access to a range of policy proposals, in theory giving insight into policy proposals and performance across several policy areas, but identified no specific issues where this access would offer an unfair insight/advantage.

DSIT noted that you will clearly retain some relevant insights from being Minister of State for Science, Research and Innovation but noted no specific risks or concerns arising from that; and recommended the standard conditions. 

1. This application for advice was considered by Andrew Cumpsty; Isabel Doverty; Sarah de Gay; Dawid Konotey-Ahulu CBE DL; The Rt Hon Baroness Jones of Whitchurch; The Rt Hon Lord Eric Pickles; Michael Prescott; and Mike Weir. Hedley Finn OBE was unavailable.  ↩

2. All Peers and Members of Parliament are prevented from paid lobbying under the House of Commons Code of Conduct. Advice on your obligations under the Code can be sought from the Parliamentary Commissioner for Standards, in the case of MPs.  ↩

3. https://www.cambridgenetwork.co.uk/the-network/cambridge-cluster ↩