Correspondence from ACOBA to Richard Harrington, appointments without advice (Stephenson Harwood LLP, Regal Holdco Limited, Cluster Partners Limited)
Updated 9 July 2025
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I am writing to you in my capacity as Interim Chair of the Advisory Committee on Business Appointments (ACOBA). We have received a request for information from a member of the public, under the Freedom of Information Act 2000 (FOIA) about your role with Stephenson Harwood LLP. Your LinkedIn profile [footnote 1] records that you have worked with Stephenson Harwood LLP since March 2024.
Our records show that you left your role as the Minister for Refugees jointly in the Department for Levelling Up, Housing and Communities and the Home Office in September 2022. You were required to seek advice for any appointments or employment you took up within two years of leaving office under the government’s Business Appointments Rules (the Rules). This requirement is set out clearly in the Ministerial Code [footnote 2], including specifically that former ministers ‘must ensure that no new appointments are announced, or taken up, before the Committee has been able to provide its advice’.
The government’s Rules exist to protect the integrity of government. Applicants have a personal responsibility to understand and comply with the Rules and to manage the propriety of appointments taken up after leaving government service. ACOBA has not received from you an application for advice in relation to Stephenson Harwood LLP.
In addition, I have become aware of two further appointments for which the Committee has not received applications for advice. According to publicly available information, you took up an appointment with Cluster Partners Limited in December 2023[footnote 3] and a further appointment with Regal Holdco Limited in July 2024.[footnote 4]
This is surprising, knowing that you previously received correspondence from ACOBA for a breach of the Rules in 2021 and you later sought and received advice on appointments within the first few months of leaving office in 2022. The relevant correspondence is available on the ACOBA website here: https://www.gov.uk/government/publications/harrington-richard-parliamentary-under-secretary-of-state-at-the-department-for-business-energy-and-industrial-strategy-acoba
I am writing to understand the circumstances behind your failures to seek advice; and to provide you with an opportunity to tell us about any steps you have taken to ensure the probity in these appointments. Additionally please note ACOBA will respond to the request under FOIA to confirm ACOBA holds no information relevant on this appointment, and that we will be writing to you about it.
It is ACOBA’s policy to report any breaches of the Rules to government, and in line with our policy of transparency, we will publish our correspondence in due course. I would be grateful for a reply to this letter before Monday 28 April. Your reply, or any failure to respond, will be included in our publication.
Isabel Doverty Interim Chair ACOBA