Decision

Advice Letter: Ian Gale, Chief Growth Officer, Draken Europe

Published 12 August 2025

1. BUSINESS APPOINTMENT APPLICATION: Air Marshal Ian Gale, former Director General Joint Forces Development at the Ministry of Defence. Paid appointment with Draken Europe.

Air Marshal Ian Gale (AM Gale) 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 his proposed role as Chief Growth Officer with Draken Europe (Draken).

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 AM Gale made during his time in office, alongside the information and influence he may offer Draken. The material information taken into consideration by the Committee is set out in the annex.

The Committee considered whether this appointment was unsuitable given AM Gale’s former role as the Director General (DG) for Joint Forces Development, and Draken’s work within the defence sector. The Committee also considered the information provided by his former department about his specific dealings with this employer and the sector.

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

Draken is a provider of ‘adversary air services’ to the armed forces/militaries, in order to train military personnel to defend themselves. This is known as Interim Red Air Aggressor Training Service (IRAATS). Tactical air training is a regulated sector. Draken currently holds a contract with the Ministry of Defence (MOD) to provide IRAATS.^{[footnote 2]} AM Gale proposes to become Draken’s Chief Growth Officer. His responsibilities will include international business growth, developing and leading a growth strategy and bid preparation.

Whilst in office, AM Gale made no decisions specific to Draken, did not meet the company, and had no involvement in its contract with the MOD to provide IRAATS. The MOD confirmed the contract sits with Air Command in the Royal Air Force – which is entirely separate to UK Strategic Command (UK StratComm) and AM Gale’s role in military education. Air Command has its own separate coordination of equipment, capability, infrastructure and training. Therefore, the risk that AM Gale could reasonably be perceived to have been offered this role as a reward for decisions made or actions taken in office is low.

As Draken is a defence company that provides services across the defence and aerospace sectors, there is a significant risk that AM Gale had broad access to information on military development and future warfare, for example, the MOD’s requirements, operational capabilities, policy and strategy. There are several factors that help to reduce the risks associated with his access to information: - The MOD is not aware of any information AM Gale had access to that could unfairly advantage Draken.

• AM Gale left his role in August 2023, providing an 11-month gap since he last had access to information at the MOD.

• AM Gale’s role is focused outside of the UK.

• AM Gale’s role did not involve responsibility for tactical training – this was wholly separate to his role in education for military leadership and warfare doctrine.

Nonetheless, there remains a risk that AM Gale could grant Draken an unfair advantage through access to information, given that he proposes to advise in the defence sector, and Draken’s obvious interest in military training within the UK MOD.

AM Gale could offer Draken an unfair advantage by virtue of his influence and contacts in the MOD. This is of particular concern given Draken holds a contract with the MOD that it may look to renew in 2025. Whilst AM Gale confirmed he would have no involvement in the UK defence sector and no contact with the MOD on these matters, this remains a significant risk that needs to be mitigated. The Committee therefore asked the employer, Draken, to confirm AM Gale’s role could and would be separate to its work in UK Defence.

The Committee considered it is likely that AM Gale would have amassed a network of contacts while in office, including in external organisations and foreign militaries. AM Gale was clear with the Committee that it is not his intention to use his contacts inappropriately or for the unfair advantage of developing Draken’s business, though there remains a risk he could offer such contacts as a result of his time in office.

3. The Committee’s advice

The Committee considered that AM Gale’s role within the MOD presents real and perceived risks as regards his ability to offer an unfair advantage through his access to information and influence. The Committee recognised that the MOD’s view that his ability to offer unfair advantage to Draken was limited but also recognised that it is hard to argue against his privileged insight into the defence sector in the UK. The Committee has therefore imposed a ban on him advising on the defence sector in this role.

Draken’s potential interest in MOD policy, strategy and future contract decisions across the aerospace sector, is the largest risk. It is significant that Draken has confirmed to the Committee that it will ensure compliance with the conditions of this advice, including that he will have no role in working in the UK defence market.

The Committee advises, under the government’s Business Appointment Rules, that AM Gale’s role with Draken Europe should be subject to the following conditions:

• he should not draw on (disclose or use for the benefit of herself 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 its arm’s length bodies on behalf of Draken Europe (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 to influence policy, secure business/funding or otherwise unfairly advantage Draken Europe (including parent companies, subsidiaries, partners and clients);

• for two years from his last day in Crown service, he should not provide advice to Draken Europe (including parent companies, subsidiaries or partners) on the terms of, or with regard to the subject matter of, a bid or contract with, or relating directly to the work of the UK government, the MOD and its trading funds, or their arm’s length bodies;

• for two years from his last day in office, he should not become personally involved in lobbying contacts he has developed during his time in office and in other governments and organisations for the purpose of securing business for any company or organisation (including parent companies, subsidiaries and partners);

• for two years from his last day in Crown service, he should not advise Draken Europe (including parent companies, subsidiaries, partners and clients) on any matters relating to the whole of the UK defence sector/industry; and

• for two years from his last day in Crown service he must not directly engage with the UK government or its arm’s length bodies on behalf of Draken Europe (including parent companies, subsidiaries, partners and clients).

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 3]} 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.

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’.

AM Gale must inform us as soon as he takes up employment with this organisation, or if it is announced that he will do so, by emailing the office at the above address. He must also inform us if he proposes to extend or otherwise change the nature of his role as, depending on the circumstances, it may be necessary for him 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

AM Gale wishes to take up a role with Draken Europe, the European branch of Draken International – headquartered in Florida, USA. Draken is a provider of ‘adversary air services’ to the armed forces/militaries. This is known as Interim Red Air Aggressor Training Service (IRAATS). It operates services across the defence and aerospace sectors. According to its website:

• Its primary role is to train military personnel to defend themselves on land, in the sea and air.

• It provides electronic warfare opponents and target aircraft.

• It has manned aircrafts and drones to deliver adversary training to simulate a fighter pilot at war, and data-gathering missions.

• It also tests and evaluates the potential of aviation solutions for its customers – e.g. testing of drones for intelligence, surveillance and reconnaissance missions, search and rescue, infrastructure monitoring.

Draken Europe has a current contract with the UK MOD (specifically with the Royal Air Force), reported to be worth approximately £100 million over three years. It runs from 2022 to 2025.^{[footnote 4]} Draken Europe also provides services for other European defence departments such as the Netherlands’ Ministry of Defence.

In this paid, full-time role as Chief Growth Officer, AM Gale described his responsibilities as including:

• International business growth, outside of the UK, specifically expanding the company’s offering in Europe, the Middle East, and possibly the Far East.

• Liaising with current customers, though specifically not in the UK.

• Developing and leading a growth strategy and prioritisation of campaigns as well as bid preparation for those countries above, and not within the UK.

• Contributing to overall company strategy.

AM Gale stated that his role will not have contact with the MOD.

Draken provided confirmation to the Committee that it will ring-fence AM Gale’s role and comply with the conditions set out in this advice letter.

4.2 Dealings in office

AM Gale said that he did not meet with Draken while in office and that he did not make any decisions (policy, regulatory, operational or commercial) specific to the company. He does not consider he has any access to information of specific relevance to this application.

AM Gale told the Committee that while in office he was a member of several boards in the MOD, including the Joint Requirements Oversight Committee (JROC), which looks at the strategy policy and future of warfare and engages with requirements for equipment based on that assessment. JROC does not consider funding or approvals – that is done by the Investment Appraisals Committee. AM Gale was not a member of this committee. Additionally, the Draken contract did not qualify for consideration at higher MOD level because these committees only deal with Category A contracts (contracts exceeding £400 million in value), and Draken does not qualify. It is entirely managed by the RAF.

AM Gale also explained that his role was in UK Strategic Command (UK StratComm). As Director General Joint Force Development his role involved leadership and military education. He said that tactical training and development is devolved to individual military services – in this case, the RAF – and therefore not under his purview. He said that while StratComm has broad oversight of Air Command, Air Command has its own separate coordination of equipment, capability, infrastructure and training. StratComm and Air Command separately procure equipment from Defence Equipment and Support (DE&S).

4.3 Department assessment

The MOD confirmed the details provided in AM Gale’s application, including that:

• AM Gale did not make any policy, commercial or strategy decisions relevant to Draken;

• the contract between the MOD and Draken sits with Air Command within the RAF and AM Gale did not have any involvement with it; and

• AM Gale did not have any contact with Draken or its competitors.

The MOD said AM Gale would have had information/knowledge on general strategy at StratComm by virtue of his role. Though the MOD said this would not have had specific overlap with Draken’s areas of operation because that strategy and policy would sit with the RAF specifically, rather than with StratComm.

The MOD also said that AM Gale, was previously Assistant Chief of Air Staff (ACAS), AM Gale would have been involved in establishing the RAF’s strategy and approach in its latest integrated review (IR), published in 2023. This does not appear to have any relevance to Draken, but rather to RAF strategy generally, and has since been published.^{[footnote 5]}

The MOD recommended that this role be subject to the standard conditions, plus a limitation on his role: that he not be involved in any commercial business whose purpose is the support of UK Armed Forces.

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. https://www.janes.com/osint-insights/defence-news/defence/draken-europe-awarded-interim-red-air-training-contract-for-uk ↩

3. 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 in the case of peers. ↩

4. https://www.key.aero/article/uk-turn-draken-europe-red-air-solution ↩

5. https://www.gov.uk/government/publications/integrated-review-refresh-2023-responding-to-a-more-contested-and-volatile-world/integrated-review-refresh-2023-responding-to-a-more-contested-and-volatile-world ↩