Decision

Advice Letter: Boris Johnson, Speaker, Harry Walker Agency LLC

Updated 19 April 2024

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Boris Johnson MP, former Prime Minister. Paid appointment with the Harry Walker Agency LLC.

You sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointments Rules for former ministers (the Rules) on taking up an appointment as a speaker with the Harry Walker Agency LLC (HWA). The material information taken into consideration by the Committee is set out in the annex below.

The purpose of the Rules is to protect the integrity of the government. Under the Rules, the Committee’s remit is to consider the risks associated with the actions and decisions made during your time in office, alongside the information and influence a former minister may offer HWA.

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.

It should also be noted that in addition to the conditions imposed on this appointment under the government’s Business Appointment Rules, there are separate rules in place with regard to your role as a member of the House of Commons.

2. The Committee’s consideration of the risks presented

The Committee^{[footnote 1]} does not consider joining a speaking agency raises any particular concerns under the government’s Business Appointment Rules, provided it is subject to standard conditions which prevent improper use of information and influence. These cases will normally be subject to the standard conditions below after checking with your former department. It is an individual’s responsibility to manage the propriety of the specific pieces of work undertaken. In particular, as the former Prime Minister, you must be careful not to offer any unfair insight as a result of your access to information and potential influence in government - which the conditions below seek to mitigate.

It is also relevant that you had no official dealings with the agency in office, and therefore the risk this role could reasonably be seen as a reward for decisions made, or actions taken, in office is low.

3. The Committee’s advice

The government’s Rules state that as a former member of the Cabinet, you are subject to a three month waiting period as standard.

The Committee advises, under the government’s Business Appointment Rules, that your appointment with the Harry Walker Agency LLC be subject to the following conditions:

• a waiting period of three months from your last day in ministerial office;

• 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 the Harry Walker Agency LLC (including parent companies, subsidiaries, partners 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 the Harry Walker Agency LLC (including parent companies, subsidiaries, partners and clients);

• for two years from your last day in ministerial office, you should not undertake any work with the Harry Walker Agency LLC (including parent companies, subsidiaries, partners 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.

The advice and the conditions under the government’s Business Appointment Rules relate to your previous roles in government only; they are separate to rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists or the Parliamentary Commissioner for Standards. It is your personal responsibility to understand any other rules and regulations you 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 Civil Service 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’.

You must inform us as soon as you take up employment with this organisation, or if it is announced that you will do so, and we will publish this letter on our website.

Any failure to do so may lead to a false assumption being made about whether you had complied with the Rules.

You must 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, we will publish this letter on the Committee’s website, and where appropriate, refer to it in the relevant annual report.

4. Annex - Material information

4.1 The role

You said you would undertake speaking engagements arranged via HWA. You said the agency will begin exploring engagements once you have left office, but at this time you do not have any information about which organisations you will be speaking to and being paid by.

4.2 Dealings in office

HWA has no relationship with government. You said you did not meet with the company whilst in office, nor did you make any decisions specific to it.

4.3 Department Assessment

The Cabinet Office confirmed the details you provided.

The Cabinet Office said it has no concerns about this appointment, noting it is not uncommon for former ministers and senior Crown servants to join speaking agencies. The department recommended the standard conditions.

1. This application for advice was considered by Jonathan Baume; Isabel Doverty; Sarah de Gay; Susan Liautaud; The Rt Hon Lord Pickles; Richard Thomas; and Mike Weir. Andrew Cumpsty and Lord Larry Whitty were unavailable. ↩