Decision

Advice letter: Sue Gray, Chair of the Board of Advisors, Friends of Afghan Women Network

Updated 2 June 2025

1. BUSINESS APPOINTMENT APPLICATION: Baroness Susan Gray CBE, former Chief of Staff, Prime Minister’s Office. Unpaid appointment with the Friends of Afghan Women Network.

Baroness Gray 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 an unpaid role as Chair of the Board of Advisors with the Friends of Afghan Women Network (FAWN).

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 Baroness Gray’s time in office, alongside the information and influence a former Crown servant may offer FAWN. The material information taken into consideration by the Committee is set out in the annex.

The Committee has advised that a number of conditions be imposed to mitigate the potential risks to government associated with this appointment under the Rules. The Committee’s advice is not an endorsement of this application in any other respect.

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

When considering this application, the Committee^{[footnote 2]} took into account that this appointment with FAWN is unpaid.^{[footnote 3]} Generally, the Committee’s experience is that the risks related to unpaid roles are limited. The purpose of the Rules is to protect the integrity of government by considering the real and perceived risks associated with former Crown servants joining outside organisations. Those risks include: using privileged access to contacts and information to the benefit of themselves or those they represent. The Rules also seek to mitigate the risks that individuals may make decisions, or take action in office, in expectation of rewards on leaving government. These risks are significantly limited in unpaid cases due to the lack of financial gain to the individual.

As with any former senior Crown servant, there are inherent risks associated with Baroness Gray’s access to information, contacts and influence within government. In this unpaid role these risks are limited. Alongside the lack of financial gain or any specific overlap with her responsibilities in office, the role is limited to providing advice to the Network, with no contact with government.

3. The Committee’s advice

The Committee did not consider this appointment to raise any particular propriety concerns under the government’s Business Appointment Rules. As above, the role’s unpaid nature significantly limits the risks, subject to standard conditions. These seek to prevent Baroness Gray from drawing on privileged information and using her contacts to FAWN’s unfair advantage, and will sufficiently mitigate the risks in this unpaid appointment.

In accordance with the government’s Business Appointment Rules, the Committee advises that Baroness Gray’s appointment with the Friends of Afghan Women Network be subject to the following conditions:

• Baroness Gray 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 her from her time in Crown service;

• for two years from her last day in Crown service, she should not become personally involved in lobbying the UK government or any of its arm’s length bodies on behalf of the Friends of Afghan Women Network (including parent companies, subsidiaries, partners and clients); nor should she make use, directly or indirectly, of her contacts in the government to influence policy, secure business/funding or otherwise unfairly advantage the Friends of Afghan Women Network (including parent companies, subsidiaries, partners and clients); and

• for two years from her last day in Crown service, she should not provide advice to the Friends of Afghan Women Network 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 or any of its arm’s length bodies.

The advice and the conditions under the government’s Business Appointment Rules relate to the 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 4]} The applicant is reminded that, as a Member of the House of Lords, she is prevented from any paid lobbying under the House of Lords 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’.

Baroness Gray must inform us as soon as she takes up this work or if it is announced that she will do so. Similarly, she must inform us if she proposes to extend or otherwise change her role with the organisation as depending on the circumstances, it might be necessary for her to seek fresh advice.

Once this 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

Baroness Gray wishes to take up a part-time, unpaid role as a Chair of the Board of Advisors, Friends of Afghan Women Network (FAWN).

FAWN is an organisation aimed at empowering Afghan women and girls by advancing their economic resilience, safeguarding their human rights, and promoting equitable access to education. Its website states that it takes practical steps providing direct on-the-ground support to women to stay active and connected, build sustainable livelihoods, and access essential resources.

As Chair of FAWN’s Board of Advisors, Baroness Gray stated that her responsibilities will be to attend one to two virtual board meetings annually, provide input to any consultations each year and participate in key events, with no contact with government.

4.2 Dealings in office

Baroness Gray said that she did not make any policy, regulatory or commercial decisions specific to FAWN, that she did not have any access to information that could grant the network an unfair advantage, and that she had no dealings with the network while in office. She said that it is unlikely that she has specific privileged information of continuing relevance to FAWN.

4.3 Departmental assessment

The Cabinet Office confirmed the details that Baroness Gray provided, noting that FAWN was established after she left service. It further noted the low risk associated with the appointment, highlighting its unpaid and part-time nature with a limited time commitment, the lack of contact with government, the fact that the organisation’s work appears not to be commercial and that her former role was not specifically focused on international affairs or Afghanistan, and the low likelihood that Baroness Gray would have had access to any particular information of ongoing relevance to the network. The Cabinet Office recommended that standard conditions apply.

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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. This application for advice was considered by Andrew Cumpsty; Sarah de Gay; Isabel Doverty; Hedley Finn OBE; Dawid Konotey-Ahulu CBE; The Rt Hon Lord Pickles; Michael Prescott; Mike Weir. The Baroness Thornton was absent. ↩

3. By unpaid the Committee means that no remuneration of any kind is received for the role. Applicants must declare where it is agreed or anticipated they may receive remuneration or some other compensation at some stage in the future. ↩

4. 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. ↩