Decision

Advice Letter: Chris Heaton-Harris, Senior Advisor to the Chairman and CEO, Rivada Space Networks Gmbh

Updated 6 October 2025

1. BUSINESS APPOINTMENT APPLICATION: Chris Heaton-Harris, former Secretary of State for Northern Ireland. Paid appointment with Rivada Space Networks Gmbh.

You approached the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Ministers (the Rules) seeking advice on taking up a paid role as a Senior Advisor to the Chairman and CEO of Rivada Space Networks Gmbh (Rivada Space). 

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 your time in office, alongside the information and influence you may offer Rivada Space as a former minister. 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 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

Rivada Space is a wholly owned subsidiary of Rivada Networks, a US-based telecommunications company specialising in innovative wireless communications solutions. Rivada Space operates as Rivada Networks’ German-incorporated arm and focuses on satellite-based connectivity services to provide global broadband coverage, particularly for remote and underserved areas. It is based in the US and Germany, with its headquarters in Munich. You stated that as Senior Advisor to the Chairman and CEO, you would act as a business advisor and confidant as the business grows. 

As the former Secretary of State for Northern Ireland, you did not meet with Rivada Space, nor make any policy, regulatory or commercial decisions specific or relevant to the company while in office. The Committee^{[footnote 1]} considered that the risk that this role could reasonably be seen as a reward for  decisions made or actions taken in office was low.

As Secretary of State for Northern Ireland, it is likely that you had access to a broad range of sensitive information that may overlap with your proposed role with Rivada Space, given that the company’s work can intersect with, and be applicable to, a range of sectors. The Committee considered the risk is limited given there is no known overlap between this role and your time in office, it has been over 14 months since you left office, and the Northern Ireland Office is not aware of any specific information of risk. 

There are risks associated with your contacts and influence in government and the potential for Rivada Space to gain unfair access or influence as a result. You noted that  your role may have some contact with government at events. Whilst this is not contrary to the Rules, to comply with the lobbying ban that applies to all former ministers for two years on leaving office, you must avoid contact that could reasonably be perceived as lobbying government.

Further, given that your role is likely to involve the development of Rivada Space’s business, there is a risk that any contacts you may have developed whilst in office, in external organisations and foreign governments, could be seen to be useful in securing business for Rivada Space, therefore offering a potential unfair advantage. 

3. The Committee’s advice

The Committee determined the risks identified in this application can be appropriately mitigated by the conditions below. These seek to prevent you from making improper use of your privileged access to information, contacts and influence from your time in office. 

In accordance with the government’s Business Appointment Rules, the Committee advises that this appointment with Rivada Space Networks Gmbh be 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 office;

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

• for two years from your last day in ministerial office, you should not provide advice to Rivada Space Networks Gmbh (including parent companies, subsidiaries, partners and clients) on the terms of, or with regard to the subject matter of, a bid with, or contract relating directly to the work of the UK government; and

• for two years from your last day in ministerial office, you should not become personally involved in lobbying contacts you have developed during your time in office and in other governments and organisations for the purpose of securing business for Rivada Space Networks Gmbh (including parent companies, subsidiaries and partners).

The advice and the conditions under the government’s Business Appointment Rules relate to your previous role in government only; they are separate from rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists, the Parliamentary Commissioner for Standards and the Registrar of Lords’ Interests^{[footnote 2]}. 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 Ministerial 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’. This Rule is separate and not a replacement for the Rules in the House.

You must inform us as soon as you take up employment with this organisation, or if it is announced that you will do so. Please inform us if you propose to extend or otherwise change the nature of your role as, depending on the circumstances, it may be necessary for you to make a fresh application.

Once the appointment has been publicly announced or taken up, the advice letter will be published.

4. Annex – material information

4.1 The role

Rivada Space Networks Gmbh (Rivada Space) is a German-based company which focuses on satellite-based connectivity services, leveraging low Earth orbit satellite technology to provide global broadband coverage, particularly for remote and underserved areas. Its parent company is US-based Rivada Networks, which is a telecommunications company specialising in innovative wireless communication solutions. Rivada Networks has worked with government agencies in the United States. 

In your paid, part-time role as Senior Advisor, you stated that you will be a business advisor, confidant and ‘critical friend’ to the Chairman and CEO as the business grows. You confirmed that you could have contact with government through attending events with, or on behalf of, the Chairman and CEO. 

4.2 Dealings in office

You said you had no involvement in policy, contractual and/or commercial decisions specific to Rivada Space. You also said that you did not have official dealings/ contact with Rivada Space during your time in office and that the Northern Ireland Office does not have a relationship with the company. 

4.3 Departmental assessment 

The Northern Ireland Office (NIO) was consulted on your application. It provided the following information: 

• There is no departmental relationship with Rivada Space and/or Rivada Networks and you did not have any contact with the company while in office. 

• You were not responsible for any policy, regulatory, contractual and/or funding decisions specific or relevant to Rivada Space. 

• You do not possess any privileged information specific and/or relevant to Rivada Space that could be considered to offer an unfair insight/advantage to the proposed employer.

NIO recommended the standard conditions.

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

2. All Peers and Members of Parliament are prevented from paid lobbying under the House of Commons Code of Conduct and the Code of Conduct for Members of the House of Lords. Advice on your obligations under the Code can be sought from the Parliamentary Commissioner for Standards, in the case of MPs, or the Registrar of Lords’ Interests, in the case of peers. ↩