Correspondence from ACOBA to Richard Harrington, breach of the Rules (Stephenson Harwood LLP, Regal Holdco Limited)
Updated 9 July 2025
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Thank you for your reply of 28 April 2025 in respect of your work with Stephenson Harwood LLP, Regal Holdco Limited and Cluster Partners Limited – two of which you commenced prior to receiving ACOBA’s advice. The correspondence on this matter is annexed to this letter.
Your most recent departure from government was in September 2022. You apologised to ACOBA for miscalculating the time period in which you were required to notify ACOBA of any appointments. This explanation is surprising, given you previously sought and received advice for two appointments in 2022 – one appointment with Canaccord and another with Intelligent FS Ltd. Further, you were notified of your breach of the Rules for failing to seek advice in February 2021, following your previous departure from government in 2019.
As set out clearly in the Ministerial Code ‘…former Ministers must ensure that no new appointments are announced, or taken up, before the Committee has been able to provide its advice.’ The purpose of the Rules is to protect the integrity of government by considering the real and perceived risks associated with former ministers joining outside organisations.
Protecting the integrity of the government has not been possible here. Failing to await advice before taking up roles with Stephenson Harwood LLP and Regal Holdco Limited is an unambiguous breach and clear disregard of the government’s Rules and the requirements of the ministerial code.
You also informed ACOBA that Cluster Partners Limited was established in 2023 but did not commence any activity until ‘much later on’ – therefore you evidence you had not taken this up until the company was active in September 2024. This was after the two years in which the government’s Rules apply to former ministers and outside ACOBA’s scope.
Next steps
Please find enclosed the correspondence reporting of this matter to the government, as the owners of the Rules. In line with ACOBA’s commitment to transparency, all correspondence will be published on the website.
Isabel Doverty Interim Chair ACOBA
Copied to:
The Rt Hon Pat McFadden MP, Chancellor of the Duchy of Lancaster and Minister for Intergovernmental Relations;
The Rt Hon Nick Thomas-Symonds MP, Minister for the Cabinet Office;
Darren Tierney Director General, Propriety and Ethics, Cabinet Office.