Decision

Advice Letter: Jenny Harries, Non-Executive Independent Chair, CPE

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 Community Pharmacy England.

Professor Dame Jenny Harries 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 Community Pharmacy England (CPE) as Non-Executive Independent Chair.

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 taken during Professor Dame Jenny Harries’ time in post, alongside the information and influence the former Chief Executive of the UK Health Security Agency (UKHSA) may offer CPE - which operates within the health sector. 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

CPE is the representative body for community pharmacy contractors in England. Dame Jenny would be joining as Non-Executive Independent Chair, with her role primarily focused on governance and ensuring the organisation’s effective operation. The Committee^{[footnote 1]} took into consideration that Dame Jenny did not make any policy, regulatory or commercial decisions specific to CPE, nor did she have any contractual dealings with the organisation or those it represents. Therefore, the Committee did not consider that this appointment could reasonably be perceived as a reward for decisions made or actions taken in office.

As the former Chief Executive of UKHSA^{[footnote 2]}, an executive agency of the Department of Health and Social Care, Dame Jenny would have had access to a broad range of privileged information. This is particularly significant as UKHSA’s scientific evidence and public health advice directly underpins the services, that CPE negotiates with government on behalf of its members. For example, the Community Pharmacy Contractual Framework (CPCF). There is some direct overlap with her time in government and the work of CPE, and only a short time has passed since she left Crown service. The Committee therefore considered the risks associated with her access to information to be significant.

There are risks associated with Dame Jenny’s contacts and influence. Given the nature of CPE – a trade body that promotes the interest of its member organisations to government – there is a risk she could offer CPE unfair access to, and influence within, government as a result of her time in government service. It is difficult to see how a clear distinction could be drawn between contact Ms Harries has with government and CPE’s influencing agenda/lobbying on CPE’s behalf. It is significant that CPE confirmed Dame Jenny’s role as Non-Executive Independent Chair will not involve lobbying government, which the most senior Crown servants are prevented from doing for two years after leaving office. CPE confirmed this will be carried out by others in the organisation.

3. The Committee’s advice

There is a broad overlap with some of CPE’s work for its members, and Dame Jenny’s former responsibilities in office. The main risk is a reasonable concern that she may offer CPE unfair access to information or influence gained from her time in Crown service, especially as the organisation seeks to influence the direction of government policies. Therefore, the Committee’s advice is that Dame Jenny should not initiate engagement with the government on behalf of CPE whilst she is subject to the Rules, to mitigate the risk that she is seen to be making improper use of her time in office to the unfair benefit of her employer. This would not prevent her from liaising with ministers and officials where the contact is initiated by government. In particular, DHSC may wish to liaise specifically with Ms Harries given her experience and background, which is a matter for government.

The Committee advises, under the government’s Business Appointment Rules, that Professor Dame Jenny Harries’s appointment with Community Pharmacy England 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, she should not become personally involved in lobbying the UK government or any of its arm’s length bodies on behalf of Community Pharmacy England (including parent companies, subsidiaries, partners and clients), nor should she make use, directly or indirectly, of her contacts in the government and/or Crown service contacts to influence policy, secure business/funding or otherwise unfairly advantage Community Pharmacy England (including parent companies, subsidiaries, partners and clients);
• for two years from her last day in Crown service, she may liaise with ministers and officials where the contact is initiated by UK government, but she must not initiate engagement on behalf of Community Pharmacy England (including parent companies, subsidiaries, partners and clients) with the UK government;
• for two years from her last day in Crown service, she should not provide advice to Community Pharmacy England on the terms of a bid or contract with, or relating directly to, the UK Health Security Agency or the Department of Health and Social Care; and
• for two years from her last day in Crown service, she should not advise Community Pharmacy England (including parent companies, subsidiaries, partners and clients) on any work related to the Community Pharmacy Contractual Framework (CPCF), or its successor.

The advice and the conditions under the government’s Business Appointment Rules relate to 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.” 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

Community Pharmacy England (CPE) is the representative body for community pharmacy contractors in England. It works with the Department of Health and Social Care (DHSC) and NHS England to negotiate the Community Pharmacy Contractual Framework (CPCF), which governs the services and remuneration for pharmacies.

In her paid, part-time role as Non-Executive Independent Chair, Professor Dame Jenny Harries’ responsibilities include leading CPE’s governing body and providing strategic governance to the organisation.

Dame Jenny confirmed to the Committee that the role of Non-Executive Independent Chair will not involve direct negotiation with DHSC or lobbying ministers. She stated that the Non-Executive Independent Chair’s duties are clearly separated from any lobbying activities that CPE undertakes, with the Chief Executive of CPE remaining responsible for dealings with government departments and regulators.

Dame Jenny has confirmed that she will not be involved in those aspects of the role entailing contact with government in the form of presenting evidence while subject to the Rules.

4.2 Dealings in office

Dame Jenny advised the Committee that she did not meet with Community Pharmacy England while in service. She was not involved in any commercial or contractual decisions relating to CPE. She also told the Committee that she did not have any involvement in any relevant policy development or decisions that would have uniquely affected CPE and did not have access to sensitive information specific to the organisation.

4.3 Correspondence from Community Pharmacy England

CPE confirmed in writing its understanding of, and agreement to, comply with the Committee’s advice. The Chief Executive provided the following:

• ‘Recognising the responsibilities and obligations of former senior civil servants, we wish to provide the following assurances:
• Dame Jenny Harries will not be involved in any of our lobbying activity; this is not the role of our Non-Executive Chair; this work is carried out by others in the organisation,
• We will respect the Government’s Business Appointments Rules for Former Crown Servants, and
• We will adhere to any conditions of the advice given by ACOBA.’

4.4 Departmental assessment

The Department of Health and Social Care and the Cabinet Office confirmed the details as provided by Dame Jenny. The department stated that she was not involved in decisions specific to CPE.

DHSC and the Cabinet Office noted the significant and ongoing relationship it has with CPE through contractual negotiations. It acknowledged the risks associated with her seniority and access to strategic government thinking, given the direct overlap in the subject matter.

DHSC and the Cabinet Office recommended that this appointment be subject to 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. ↩