Decision

Advice Letter: Brandon Lewis, Chairman of the Board, Henry Jackson Society

Updated 17 September 2025

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Sir Brandon Lewis CBE MP, former Lord Chancellor and Secretary of State for Justice, Secretary of State for Northern Ireland. Unpaid appointment with the Henry Jackson Society.

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 unpaid role with the Henry Jackson Society (HJS) as Chairman of the Board.

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 made during your time as a minister, alongside the information and influence a former Secretary of State may offer HJS. 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

When considering this application, the Committee^{[footnote 1]} took into account this appointment as Chairman of the Board is unpaid^{[footnote 2]}. Generally, the Committee’s experience is that the risks related to unpaid roles are limited. The purpose of the Rules is to protect the integrity of government by considering the real and perceived risks associated with former Crown servants joining outside organisations. Those risks include: using privileged access to contacts and information to the benefit of themselves or those they represent. The Rules also seek to mitigate the risks that individuals may make decisions or take action in office to in expectation of rewards, on leaving government. These risks are significantly limited in unpaid cases due to the lack of financial gain to the individual.  

The Northern Ireland Office (NIO) and Ministry of Justice (MOJ) confirmed that you did not have any contact with HJS while in office and made no decisions specific to HJS, though it no doubt has an interest in government policy. As such, the risk that this unpaid appointment could reasonably be perceived as a reward for decisions or actions taken in office is low.

There are inherent risks associated with your access to information and network of contacts in office. The Committee noted you will have no contact with the government in this role. 

3. The Committee’s advice

The Committee did not consider that this appointment raises any particular propriety concerns under the government’s Rules. The risks are appropriately mitigated by the standard conditions below. In particular, they seek to prevent you from drawing on your privileged information, contacts and influence within government to the unfair advantage of HJS.

In accordance with the government’s Business Appointment Rules, the Committee advises that this appointment with the Henry Jackson Society 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 Henry Jackson Society (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 Henry Jackson Society (including parent companies, subsidiaries, partners and clients); and

• for two years from your last day in ministerial office you should not undertake any work with Henry Jackson Society (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 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. 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 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 this role, or if it is announced that you will do so. 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.

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 Henry Jackson Society is a trans-Atlantic foreign policy and national security think tank, based in the United Kingdom. According to its website, it is a ‘policy-shaping force that fights for the principles and alliances which keep societies free.’ It aims to work ‘across borders and party lines to combat extremism, advance democracy and human rights and make a stand in an increasingly uncertain world’.

You told the Committee that your role will be unpaid and part-time; and will involve the following responsibilities: 

• Chairing the bi-annual board meetings; and 
• Helping shape strategic development of the think tank.

You said that your role will not involve contact with government. 

4.2 Dealings in office

You said that you did not meet with HJS while in office; and that you did not make any policy or commercial decisions specific to HJS; and that you did not have any access to sensitive information specific to HJS.

4.3 Departmental assessment 

The NIO and MOJ were consulted in this application. Both departments confirmed the details in your application. 

Neither department had any concerns regarding this appointment and the standard conditions were recommended to mitigate any inherent risks.

1. This application for advice was considered by Isabel Doverty; Hedley Finn OBE; Sarah de Gay;  Dawid Konotey-Ahulu CBE DL; The Rt Hon Lord Pickles; Michael Prescott; and Mike Weir. The Rt Hon The Lord Pickles and Andrew Cumpsty were recused from this application in line with ACOBA’s published Code of Practice. This letter contains the Committee’s advice, arrived at without Lord Pickles’ input and which he is sending in his capacity as Chair of the Committee. ↩

2. By unpaid the Committee means that no remuneration of any kind is received for the role.  Applicants must declare where it is agreed or anticipated they may receive remuneration or some other compensation at some stage in the future. ↩