Decision

Advice letter: Jo Churchill, Non Executive Director, Norfolk and Waveney University Hospital Group

Updated 27 January 2026

1. BUSINESS APPOINTMENT APPLICATION: Jo Churchill, former Minister of State (Minister for Employment), Department for Work and Pensions – Paid appointment as Non-Executive Director, Norfolk and Waveney University Hospital Group

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on joining Norfolk and Waveney University Hospital Group as a Non-Executive Director.

The purpose of the Rules, as you will be aware, is to protect the integrity of government and to avoid any suspicion that those who have served in government might profit improperly from that experience or that an employer might gain unfair advantage through privileged access to government. To achieve these aims, I designate conditions that former ministers must follow.

The Ministerial Code requires former ministers to ensure that no new appointments are announced or taken up before I have provided my advice. On 11 December 2025, I consulted you about draft advice on this application. In January 2026, you responded to accept the draft advice and also informed me that you had already attended a board meeting, and therefore taken up the role. I note from the Norfolk and Waveney University Hospital Group website that your appointment to the board has been announced and that the board meeting took place on 17 December.

It is disappointing that you chose to take up the appointment and allow it to be announced without awaiting advice, particularly given that the board meeting in question took place almost a week after you were consulted on the draft advice. However, in view of the circumstances – including your written assurance that your work for the Norfolk and Waveney University Hospital Group to date does not contravene the conditions set out below – I am prepared to issue this advice on the basis that your failure to comply with the procedure in this instance carries no significantly damaging consequences.

The material information and my consideration are set out in the annex. In light of this, I consider the following conditions to be appropriate, recognising that it is your responsibility to ensure that these are demonstrably applied in practice:

• Privileged information condition – You should not draw on (disclose or use for the benefit of Norfolk and Waveney University Hospital Group, related parties and clients) any privileged information available to you from your time in ministerial office. This is an ongoing duty irrespective of the time elapsed since you left office.

• Lobbying condition – For two years from your last day in office, you should not become personally involved in lobbying the UK Government or its arm’s length bodies on behalf of Norfolk and Waveney University Hospital Group (including related parties and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or ministerial office to influence policy, secure business/funding or otherwise unfairly advantage of Norfolk and Waveney University Hospital Group (including related parties and clients).

• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with Norfolk and Waveney University Hospital Group (including related parties and clients) that involves providing advice 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 or its arm’s length bodies.

I would be grateful if you would note the following points:

• My advice is not an endorsement of the appointment.

• The advice relates solely to your previous role in government; it is 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. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with my advice.

• By ‘privileged information’, I mean official information to which you had access as a consequence of holding office and which is not publicly available. You are also reminded that you may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code or otherwise.

• As set out in the Rules, the lobbying restriction means that former ministers ‘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’.

As soon as you take up the appointment, or if it is announced that you will do so, you are obliged under the Rules to inform my secretariat who will then publish this letter. You must also 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.

I would be grateful if you would note the following points:

• My advice is not an endorsement of the appointment.

• The advice relates solely to your previous role in government; it is 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. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with my advice.

• By ‘privileged information’, I mean official information to which you had access as a consequence of holding office and which is not publicly available. You are also reminded that you may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code or otherwise.

• As set out in the Rules, the lobbying restriction means that former ministers ‘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’.

As soon as you take up the appointment, or if it is announced that you will do so, you are obliged under the Rules to inform my secretariat who will then publish this letter. You must also 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.

Yours sincerely,

Sir Laurie Magnus CBE

Independent Adviser on Ministerial Standards

2. Annex – Material information and consideration of the risks

2.1 The role

You wish to take up a paid, part-time role as a Non-Executive Director at the Norfolk and Waveney University Hospital Group (NWUHG), a strategic partnership of Norfolk-based NHS foundation trust hospitals that coordinates resources and services in order to improve patient care in the region. You stated in your application that you will have standard non-executive director duties and that the role will likely take up approximately five days per month initially, reducing to about two days per month thereafter. The role involves no direct relationship with government.

You confirmed that you will have no contact with government in this role.

2.2 Dealings in office

You said you neither met with, nor made any policy, regulatory or commercial decisions specific to, NWUHG. You stated that you had no access to information that could unfairly advantage the organisation.

2.3 Departmental assessment

DWP confirmed the details you provided in your application, including that you had no access to information that could offer an unfair advantage and that you made no decisions specific to the organisation. It had no concerns and recommended the standard conditions.

2.4 My consideration of the risks

You made no policy, regulatory or commercial decisions specific to NWUHG and DWP has no concerns over your access to privileged information – this limits the risks.

As a group of NHS foundation trust hospitals, NWUHG will have an interest in government policy. You have confirmed that you will not have contact with government and I note that, as described, your role is internal in nature and does not include lobbying. In view of this, I find that the risks here are appropriately mitigated by the standard lobbying and contracts and bids conditions.