Decision

Advice letter: Jo Churchill, Non-Executive Member, NHS Essex Integrated Care Board

Updated 1 April 2026

1. BUSINESS APPOINTMENT APPLICATION: Jo Churchill, former Minister of State (Minister for Employment), Department for Work and Pensions – Paid appointment as Non-Executive Member, NHS Essex Integrated Care Board

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on joining NHS Essex Integrated Care Board as a non-executive member. 

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 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 NHS Essex Integrated Care Board, including its related parties) 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 NHS Essex Integrated Care Board (including related parties); 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 NHS Essex Integrated Care Board (including related parties).

• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with NHS Essex Integrated Care Board (including related parties) 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.

• By ‘related parties’, I mean any parent companies, subsidiaries, clients and/or other partners as may be relevant.

• 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 member at NHS Essex Integrated Care Board (Essex ICB), a statutory NHS organisation that will become an official body on 1 April 2025. It is responsible for planning, funding and coordinating local health services for the Essex population. It will also work with local authorities to enhance health outcomes and tackle health inequalities. You stated in your application that you will have standard non-executive member duties and that your role will take up 1 day per week. 

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

2.2 Dealings in office

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

2.3 Departmental assessment

DWP confirmed that, though you will have met with organisations that will constitute Essex ICB, including other integrated care boards, you made no decisions specific to the organisation and any information you hold will be out of date. 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 Essex ICB or the organisations that it will comprise and DWP has no concerns over your access to privileged information – this limits the risks.

You previously held the role of Parliamentary Under Secretary for Health at the Department of Health and Social Care (DHSC) until September 2021, which would have provided general insight into the sector in which Essex ICB operates. The risks related to your access to information at DHSC are significantly limited given that more than four years have passed. Further, the Rules do not prohibit you from utilising your general skills, knowledge, experience, and any publicly available information. 

As an NHS organisation, Essex ICB will have an interest in government policy and will likely engage with government once it is fully established. 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.