Decision

Advice Letter: Jenny Harries, Non Executive Director, Biotech Growth Trust

Published 17 September 2025

1. BUSINESS APPOINTMENT APPLICATION: Professor Dame Jenny Harries DBE DL, former Chief Executive of UK Health Security Agency. Paid appointment with Biotech Growth Trust PLC. 

Professor Dame Jenny Harries (Dame Jenny) 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 taking up an appointment with Biotech Growth Trust PLC (Biotech Growth Trust) as Non Executive Director. 

The purpose of the Rules is to protect the integrity of the government. The Committee^{[footnote 1]} has considered the risks associated with the actions and decisions taken during Dame Jenny’s time in government service, alongside the information and influence a former Crown servant may offer Biotech Growth Trust. The material information taken into consideration by the Committee is set out in the annex.

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 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 risk presented

Biotech Growth Trust is a London-listed investment trust that seeks capital appreciation through investment in the global biotechnology industry. As Non-Executive Director, Dame Jenny’s role is to to bring independent judgement, contribute to strategy, enhance the Board’s skills and maintain the Company’s reputation. 

As Chief Executive of the UK Health Security Agency (UKHSA)^{[footnote 2]}, Dame Jenny met with representatives across the biotech, pharmaceutical and life sciences industries. This was in the context of ascertaining and/or explaining public health risks, rather than focus on life sciences products. In addition, the Cabinet Office and Department of Health and Social Care (DHSC) confirmed that Dame Jenny made no decisions, commercial or otherwise, specific to Biotech Growth Trust. The Committee therefore considered that the risk that she could reasonably be considered to have been offered this role as a reward for decisions made, or actions taken, in government service is low. 

There is an overlap between the role that Dame Jenny wishes to take up with Biotech Growth Trust and her previous role as Chief Executive of UKHSA. Dame Jenny had access to a wide range of information at the top level of government, that may be of use to any organisation that operates in a similar health space. The Committee agreed with the Cabinet Office and DHSC that the risk associated with her access to information is limited for the following reasons:

• her role was focused on national health protections and strategy, not commercial work with start-ups, with the exception of Moderna in the early stages of the pandemic, now a number of years ago;

• though she had broad engagement in the biotech sector, UKHSA’s direct contractual and commercial links are handled by a dedicated commercial team and she had no direct involvement in the work ; and

• the government has now published ‘The UK’s Modern Industrial Strategy 2025’, setting out its 10 year plan - placing the government’s high-level priorities for the Life Sciences in the public domain (in which Biotech Growth Trust operates). 

• the departments are not aware of any specific information that would likely provide an unfair advantage, and this is a general as opposed to specific risk.

There are risks associated with contacts and influence gained within government and externally.  This would arise should Dame Jenny draw on contacts gained only as a result of  her  role at UKHSA to influence government or to secure investment opportunities in the private sector. The Committee recognised that she likely amassed a wide network of contacts, including in the healthcare sector, from before she entered government.  

The Committee took into account that Dame Jenny has a professional background in life sciences, pharmacology and public health protection response.

3. The Committee’s advice

The Committee considered the risks under the government’s Business Appointment Rules are mitigated by the conditions below.  These seek to prevent Dame Jenny from drawing on privileged information, contacts and influence to the unfair advantage of Biotech Growth Trust.

The Committee advises, under the government’s Business Appointment Rules, that Professor Dame Jenny’s appointment with Biotech Growth Trust PLC be subject to the following conditions:

• a waiting period of three months from her last day in Crown service;

• she 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 (31 May 2025), she should not become personally involved in lobbying the UK government or any of its arm’s length bodies on behalf of Biotech Growth Trust PLC (including parent companies, subsidiaries, partners and clients); and

• for two years from her last day in Crown service, she should not provide advice to Biotech Growth Trust PLC on the terms of, or with regard to the subject matter of, a bid or contract with, or relating directly to, the UK Health Security Agency or the Department of Health and Social Care. 

The advice and the conditions under the government’s Business Appointment Rules relate to Professor Dame Jenny’s previous role in government only. They are separate from rules administered by other bodies which may apply to her. 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 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 “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.”

Professor Dame Jenny 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.

4. Annex – Material Information

4.1 The role

The Biotech Growth Trust PLC (Biotech Growth Trust) is a London-listed investment trust that seeks capital appreciation through investment in the worldwide biotechnology industry. It primarily invests in a diversified portfolio of shares in biotechnology companies on a worldwide basis, with a focus on small to mid-sized organisations.

In her paid, part-time role as a Non-Executive Director, Dame Jenny Harries will provide independent judgment on matters of strategy and performance and contribute to the Board’s collective duty to serve shareholder interests. Her key duties will involve helping to formulate strategy by monitoring investment performance and assessing risk , enhancing the Board’s skills and expertise and maintaining the company’s reputation through corporate governance. She stated that her role will involve no contact or dealings with government.

Dame Jenny confirmed that the role of Non Executive Director will not involve direct negotiation with DHSC or lobbying ministers.

4.2 Dealings in office

Dame Jenny advised the Committee that she had no official dealings with Biotech Growth Trust while in service. She was not involved in any commercial or contractual decisions relating to Biotech Growth Trust, nor in any policy development that would have uniquely affected the trust. She did not have access to sensitive information specific to the organisation.

While in office, Dame Jenny met with representatives across the biotech, pharmaceutical and life sciences industries. She said event attendance and subsequent stakeholder engagement arose as a product of her technical interest, professional training in pharmacology and science, and her responsibility for pandemic preparedness. Dame Jenny said many of the meetings were to ascertain or explain public health risk or translation rather than any focus on life science products.

Dame Jenny noted her support for the HMG strategic partnership with the company Moderna. However, she said she had no direct involvement in the contractual work and does not consider this a conflict as Moderna’s size likely puts it outside Biotech Growth Trust’s investment criteria.

4.3 Departmental assessment 

The Department of Health and Social Care (DHSC) and the Cabinet Office confirmed the details provided by Dame Jenny. The departments confirmed she had no official dealings with Biotech Growth Trust and that the appointment was unlikely to be seen as a reward.

DHSC and the Cabinet Office noted that as a very senior official, Dame Jenny would have been exposed to a wide range of information that may be beneficial for her prospective employer and its investments. However, the departments stated they saw no unfair advantage in this appointment and had no objection to it proceeding. The departments recommended standard conditions.

1. This application for advice was considered by Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE DL; Michael Prescott; and The Baroness Thornton. ↩

2. The UK Health Security Agency is a government agency responsible for all health security in England, and some reserved public health protection matters across the whole of the United Kingdom. It is an executive agency of the Department of Health and Social Care. ↩