Decision

Advice Letter: Dominic Johnson, Member of the Advisory Board, Commonwealth Enterprise and Investment Council

Published 17 September 2025

1. BUSINESS APPOINTMENT APPLICATION: Lord Dominic Johnson of Lainston CBE, former Minister for Investment at Department for Business and Trade. Paid appointment with the Commonwealth Enterprise and Investment Council.

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 Member of the Advisory Board with the Commonwealth Enterprise and Investment Council (CWEIC).

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 the Commonwealth Enterprise and Investment Council 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

CWEIC is mandated by the 56 leaders of the Commonwealth to promote trade, business and economic growth through connecting businesses with government officials and decision-makers across the Commonwealth. It is an accredited organisation and is also mandated to deliver the Commonwealth Business Forum alongside the Commonwealth Heads of Government Meeting.

As the former Minister for Investment, you met with CWEIC during your time in office and were involved in driving the relationship between CWEIC and the Department for Business and Trade (DBT). However, you did not make any policy, regulatory or commercial decisions specific to CWEIC while in office. The Committee^{[footnote 1]} considered that the risk that this role could reasonably be seen as a reward for your decisions made and actions taken in office is low.

As Minister for Investment, it is likely that you had access to a broad range of sensitive information that may overlap with your proposed role at CWEIC, given the organisation’s focus is on driving trade and investment in the Commonwealth. The Committee considered the risk here is limited given:

• the organisation works closely with Commonwealth governments to facilitate trade and investment between these nations, a UK government priority and any potential to offer unfair advantage would be limited;

• DBT has no concerns regarding your access to information and noted nothing specific to CWEIC;

• you have been out of office for over 12 months reducing the currency of any information you had access to; and

• the role draws on your longstanding experience in facilitating business expansion from outside your time in office.

There are risks associated with your contacts and influence in government and the potential for CWEIC to gain unfair access or influence as a result. You said that your role will not involve contact with UK government – which all former ministers are prevented from doing for two years under the government’s Rules. Further, given that your role as a Member of the Advisory Board is likely to involve the development of CWEIC’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 partners or business for CWEIC, therefore offering a potential unfair advantage.

3. The Committee’s advice

The Committee determined the risks identified can be appropriately mitigated by the conditions below. These make it clear that you cannot make use of privileged information, contacts or influence gained from your time in ministerial service to the unfair advantage of the CWEIC.

In accordance with the government’s Business Appointment Rules, the Committee advises this appointment with the Commonwealth Enterprise and Investment Council 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 the Commonwealth Enterprise and Investment Council (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 the Commonwealth Enterprise and Investment Council (including parent companies, subsidiaries, partners and clients);

• for two years from your last day in ministerial office, you should not provide advice to the Commonwealth Enterprise and Investment Council (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 the Commonwealth Enterprise and Investment Council (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 you ‘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. 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, 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

The Commonwealth Enterprise and Investment Council is mandated by the 56 leaders of the Commonwealth to promote trade, business and economic growth through connecting businesses with government officials and decision-makers across the Commonwealth. It is an accredited organisation and is also mandated to deliver the Commonwealth Business Forum alongside the Commonwealth Heads of Government Meeting.

In your paid, part-time role as Member of the Advisory Board, you stated you will:

• help the organisation with its brand positioning and how it projects its image internationally;

• give advice on how it structures its products and services and market these to key audiences, mostly outside the UK; and

• advise the organisation on expanding its international network.

You said that you will not have contact with government in this role.

You stated that business expansion has effectively been your career for thirty years and that it is this experience, rather than your government experience, that CWEIC is seeking to leverage in this role.

4.2 Dealings in office

You said that you had contact with CWEIC during your time in office, and supported the organisation to strengthen its ties with DBT, but did not make any decisions specific to CWEIC. You said you did not have access to any information that could grant an unfair advantage to CWEIC and/or its clients.

4.3 Departmental assessment

DBT was consulted on your application. It provided the following information:

• You had limited contact with CWEIC, and there was a non-substantial engagement between DBT and CWEIC driven by you – but this did not lead to any decisions to progress the relationship from where it currently stood;

• You did not make any decisions specific and/or relevant to CWEIC, with the responsibility for this falling to others in the department;

• You do not possess access to any privileged information specific to CWEIC;

• CWEIC’s partners have relationships with British Embassies in Commonwealth countries which are managed by the FCDO.

DBT recommended the standard conditions and a ban on lobbying external contacts for the purposes of business development.

1. This application for advice was considered by Isabel Doverty; Hedley Finn OBE; Sarah de Gay; 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. ↩