Decision

Advice Letter: Robert Halfon, Chair, Stansted Airport College

Updated 23 September 2025

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Robert Halfon, former Minister of State for Skills, Apprenticeships and Higher Education for the Department for Education. Unpaid appointment with Stansted Airport College.

You 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 you wish to take up with Stansted Airport College.

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 a former minister may offer Stansted Airport College. 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 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

When considering this application, the Committee^{[footnote 1]} took into account this appointment as Chair of Stansted Airport College Advisory Group is unpaid.^{[footnote 2]} 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. 

This proposed role has some overlap with your time in post given its focus on further education. The Department for Education confirmed that it has a relationship with Harlow College, of which Stansted Airport College is a part. The department confirmed you were involved in policy and commercial decisions that broadly affected the further education sector, but were not aware of any decisions or access to information specific to Stansted Airport College.

As a former minister, there are inherent risks associated with your contacts and influence within government. The Committee noted your role is internal to the organisation and does not involve contact with government.

3. The Committee’s advice

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

In accordance with the government’s Business Appointment Rules, the Committee advises this appointment with Stansted Airport College 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 service;

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

• for two years from your last day in ministerial service, you should not provide advice to Stansted Airport College 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 an applicant’s 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 Commissioner for Standards.^{[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. 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 this work or if it is announced that you will do so. Similarly, you must inform us if you propose to extend or otherwise change your role with the organisation as depending on the circumstances, it might be necessary for you to seek fresh advice.

Once this appointment has been publicly announced or taken up, we will publish this letter on the Committee’s website.

4. Annex - Material Information

4.1 The role

According to its website, Stansted Airport College is a further education provider, operated as part of the Harlow College Group. It offers specialist and vocational courses in the fields of aviation, engineering and events management.

You stated you will be the Chair of Stansted Airport College Advisory Group which will meet 3-5 times a year. It  supports Harlow College/Stansted Airport College in its activities to advise and promote the College where possible. You confirmed your role does not involve contact with government

4.2 Dealings in office

You advised the Committee that you were previously constituency MP for Harlow and therefore had contact and involvement with Harlow College in your capacity as an MP. You added that in your capacity as minister, you attended:

• the college when you opened its Institute of Technology on 9 February 2024; and

• a meeting with small business employers and Harlow College.

You added that in a ministerial capacity, you met with Stansted Airport College as well as a number of further education (FE) colleges and senior FE college staff to discuss government policy.

You stated you are not aware of making any specific decisions as a minister directly regarding Harlow or Stansted Airport College but did regularly make broad decisions about further education which would have impacted both colleges, alongside other providers.

You stated you did not possess any sensitive information specific to Stansted Airport College.

4.3 Departmental assessment

DfE confirmed the details you provided and:

• it has a relationship with Harlow College – which receives funding from DfE and its arm’s length body, the Education, Skills and Funding Agency (ESFA).

• you were not involved in commercial or policy decisions specific to Stansted College, however you would have broadly made decisions about further education which would have had an impact on Harlow college.

• it was not aware of any sensitive information you had access to specific to Stansted Airport College, however as minister you would have access to generic  information on the further education sector.

• it did not have concerns regarding your appointment, noting ‘as this is an unpaid role, we consider the risks to be minimal and do not foresee any improper reasons for the applicant to take up this position.’

The department recommended the standard conditions.

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

2. 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. ↩

3. All Peers and Members of Parliament are prevented from paid lobbying under the Parliamentary Code of Conduct and the Code of Conduct for Members of the House of Lords. ↩