Decision

Advice letter: Gareth Davies, Senior Adviser, I Squared Capital Advisors (UK) LLP

Published 10 March 2026

1. BUSINESS APPOINTMENT APPLICATION: Gareth Davies, former Exchequer Secretary to the Treasury,  HM Treasury – Paid appointment as Senior Advisor, I Squared Capital Advisors (UK) LLP

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on taking up a paid, part-time role as Senior Advisor at I Squared Capital Advisors. 

The purpose of the Rules, as you will be aware, is to protect the integrity of government and to avoid any suspicion that those who have served in government might profit improperly from that experience or that an employer might gain unfair advantage through privileged access to government. To achieve these aims, I designate conditions that former ministers must follow. 

The material information and my consideration are set out in the annex. In light of this, I consider the following conditions to be appropriate, recognising that it is your responsibility to ensure that these are demonstrably applied in practice:

• Privileged information condition – You should not draw on (disclose or use for the benefit of I Squared Capital Advisors (UK) LLP, including its related parties and clients) any privileged information available to you from your time in ministerial office. This is an ongoing duty irrespective of the time elapsed since you left office.

• Lobbying condition – For two years from your last day in office, you should not become personally involved in lobbying the UK Government or its arm’s length bodies on behalf of I Squared Capital Advisors (UK) LLP (including its related parties and clients); nor should you make use of any contacts in government, including ministers, to influence policy or secure business/funding or otherwise unfairly advantage I Squared Capital Advisors (UK) LLP (including its related parties and clients). 

• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with I Squared Capital Advisors (UK) LLP (including its related parties 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.

• Role restriction – For two years from your last day in office, you should not advise I Squared Capital Advisors (UK) LLP (including its related parties and clients) on any matter in which you were materially involved, or where you had material dealings with the related party or client, whilst in office.

• Business development restriction – For two years from your last day in office, you should not become personally involved in lobbying contacts you acquired during your time in office in other governments and organisations for the purpose of securing business for I Squared Capital Advisors (UK) LLP (including its related parties and clients). 

I would be grateful if you would note the following points:

• My advice is not an endorsement of the appointment.

• The advice relates solely to your previous role in government; it is 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. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with my advice.

• By ‘privileged information’, I mean official information to which you had access as a consequence of holding office and which is not publicly available. You are also reminded that you may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code or otherwise.

• As set out in the Rules, the lobbying restriction means that former ministers ‘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’.

As soon as you take up the appointment, or if it is announced that you will do so, you are obliged under the Rules to inform my secretariat who will then publish this letter. 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.

Yours sincerely,

Sir Laurie Magnus CBE

Independent Adviser on Ministerial Standards

2. Annex – Material information and consideration of the risks 

2.1 The role

You wish to take up a paid, part-time role as a Senior Advisor with I Squared Capital Advisors (UK) LLP (ISQA), a subsidiary of I Squared Capital, a private equity firm specialising in global infrastructure investment. ISQA is responsible for managing I Squared Capital’s private equity funds. You stated in your application that you will advise on ISQA’s evaluation of infrastructure investments and targets, offer insights and analyses on the existing portfolio companies, provide macroeconomic and geopolitical advice, and assist fundraising by introducing ISQA services to new clients and strengthening current relationships.

You confirmed there will be no contact with government in this role. 

2.2 Dealings in office

You said that you neither met with ISQA nor made any policy, regulatory, or commercial decisions specific to the company. You added that you were involved in fiscal policies and signed the Venture Capital Investment Compact – decisions which affected the wider investment sector.

You confirmed that you had no access to information that could unfairly advantage ISQA.

You engaged with institutions in the investment management, private equity and infrastructure sectors. You said any engagement was generic, policy-focused and applied equally across the sector.

2.3 Departmental assessment

HM Treasury (HMT) confirmed the details you provided. HMT also confirmed that your engagements with the sector did not result in your having access to privileged commercial information that could be considered to offer an unfair advantage to ISQA. It added that you were responsible for infrastructure in office and made key infrastructure policy decisions, including setting the direction of the UK Infrastructure Bank; introducing the full expensing for plant and machinery in the May 2024 Finance Bill; and announcing the extension of the Investment Zones programme. 

HMT noted your extensive professional expertise in the investment sector gained prior to your time in office and recommended the standard conditions. 

2.4 My consideration of the risks 

As Exchequer Secretary to the Treasury with responsibilities including infrastructure, you made sector-wide decisions that could be seen broadly to benefit ISQA, its clients or the companies in which it invests. Therefore, I consider there is a risk of perception of reward for your decisions taken in office. However, this risk is limited because: 

• you made no decisions specific to ISQA and did not meet with ISQA whilst in office;

• there is no relationship between HMT and ISQA;

• you are resuming an already extensive career in investment management, leveraging skills and experience gained prior to your time in office; and  

• you left office nearly 18 months ago; this places an appropriate separation between any decision-making that could be seen broadly to benefit ISQA and your taking up of the role. 

HMT had no concerns over your access to privileged information – the risks here are therefore limited.

As an investment firm, ISQA may have an interest in government policy that applies in the sectors in which it operates. There is a risk you could be perceived to offer unfair access to the government to ISQA, its clients and the companies in which it invests. This risk is limited as you confirmed that the role will not involve contact with government. As such, I consider the risk related to lobbying to be appropriately mitigated by the standard lobbying condition. 

As part of your role, you may advise ISQA’s clients and companies in which ISQA invests. The risk of real or perceived unfair advantage to these companies, and by extension to ISQA, associated with your privileged information, access to government and any overlap between your responsibilities in office and the activities of investee companies and clients, cannot be accurately assessed due to their unknown nature. I consider the appropriate mitigation of these risks to be twofold: first, to restrict the role to prevent you from advising ISQA, its clients or companies in which it has a stake on any matter in which you were materially involved while in office, and second, to restrict the role to prevent you from advising ISQA’s clients or investee companies where you had material dealings with the client or investee company during your time in office.

You will likely have a wide network from before you entered government. However, in respect of contacts acquired only as a result of your role as a minister, there is a risk that you could be seen to advantage ISQA unfairly by drawing on such contacts to secure business on its behalf. I have therefore applied a restriction to prevent you from lobbying any contacts acquired solely during your time in office for the purpose of securing business for ISQA.