Decision

Summary of business appointments applications - John Godfrey

Published 26 September 2017

John Godfrey left his role as Director of Policy at No.10 in April 2017.

John Godfrey sought advice under the Business Appointment Rules about taking up an appointment as Head of Corporate Affairs at Legal & General. He had worked for 10 years in a similar role, prior to joining Government in July 2016.

Mr Godfrey explained that his duties would include: advice on and delivery of group media relations and communications; corporate social responsibility and advice to the CEO on stakeholder relations and issues including public policy. This is a full-time, paid position.

The Committee sought information from HM Treasury, which noted that there are a number of policy areas relevant to Legal & General’s business where there was activity during the period that Mr Godfrey was in office, including: personal injury claims discount rate (PIDR); modular housing; budget discussions on Insurance Premium Tax; and the response to John Cridland’s review of retirement age. However, Sue Gray, Director General, Propriety & Ethics in the Cabinet Office advised the Committee that, due to his previous connection with Legal & General, Mr Godfrey either recused himself from or was not involved in matters where Legal & General (and their competitors) have a commercial interest, including these areas.

The Cabinet Office is content that the appropriate safeguards were in place during Mr Godfrey’s government employment, and has no concerns about this appointment, subject to imposing conditions around the use of official information and contacts and a 2-year lobbying ban.

The Committee’s detailed consideration of this application is included in its letter of 8 September 2017.

Given the measures Mr Godfrey and the department took to put safeguards in place during his time in post and that he is returning to his previous employer after less than a year in Government, the Committee concluded that 4 months is a sufficient gap between leaving his role at No.10 and his returning to work at Legal & General.

The Permanent Secretary for the Cabinet Office accepted the Committee’s advice that, in accordance with the Government’s Business Appointment Rules, the appointment be subject to the following conditions:

  • that he should not draw on (disclose or use for the benefit of himself or the organisation to which this advice refers) any privileged information available to him from his time in Crown service; and
  • for two years from his last day in service, he should not become personally involved in lobbying Government on behalf of Legal & General Group Plc or its subsidiaries or clients, nor should he make use, directly or indirectly, of his Government and/or Crown service contacts to influence policy or secure business on their behalf.

The letter containing the Committee’s advice was sent in September 2017 and the appointment was taken up later that month.

Mary Jo Jacobi recused herself from this application.