Decision

Advice Letter: Luke Hall, Head of Policy and Campaigns, Brazelton Centre UK

Updated 1 June 2026

1. BUSINESS APPOINTMENT APPLICATION: Luke Hall, former Minister of State for Skills, Apprenticeships and Higher Education, Department for Education – Head of Policy and Campaigns, Brazelton Centre UK.

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on joining the Brazelton Centre UK as Head of Policy and Campaigns.  

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 the Brazelton Centre UK, 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 the Brazelton Centre UK (including its 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 the Brazelton Centre UK (including its related parties).
• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with the Brazelton Centre UK (including its 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.
• Business development restriction – For two years from your last day in office, you should not become personally involved in lobbying contacts you acquired during your time in office in other governments and organisations for the purpose of securing business for the Brazelton Centre UK (including its related parties). 

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 governing the registration of consultant lobbyists, from the Code of Conduct and Rules of the House of Commons and from the House of Lords Code of Conduct. 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 Head of Policy and Campaigns, Brazelton Centre UK, a registered charity supporting babies, young children and their families through training, research and practice. The charity delivers training courses to health practitioners across the UK, provides workshops and information for parents, and develops campaigns to raise awareness of newborn behaviour.   In your role as Head of Policy and Campaigns, you will: 

• help deliver Brazelton Centre UK’s priorities through policy insight, communications and external engagement 
• help shape and coordinate campaigns that raise awareness of infant‐behaviour approaches and support the organisation’s wider strategy
• build relationships with local authorities, commissioners and sector partners to support uptake of Newborn Behavioural Observations and related courses, including those offered by Brazelton Centre UK.  

You added that you may engage with Members of Parliament to discuss Brazelton Centre UK’s priorities. You confirmed that you will not have contact with the UK Government in this role. 

2.2 Departmental assessment

The Department for Education (DfE) confirmed that, in your short period in office, you were neither involved in regulatory or policy decisions nor had access to sensitive information that may provide an unfair advantage to Brazelton Centre UK. The department had no concerns and recommended the standard conditions. 

2.3 My consideration of the risks 

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

Given your role as Head of Policy and Campaigns and Brazelton Centre UK’s likely interest in government policy related to newborn and infant care, there is some risk that you could be perceived as being appointed to influence the Government on the organisation’s behalf. However, this risk is limited as you have confirmed that you will not have contact with government in this role and I note the brevity of your tenure as minister with little overlap with Brazelton Centre UK’s area of work. Accordingly, I consider the risks of offering unfair access to be limited and appropriately mitigated by the standard lobbying and contracts and bids conditions. 

Your proposed role includes building external relationships to support the uptake of Newborn Behavioural Observations and related courses, including those offered by Brazelton Centre UK. You will likely have a wide network from before you entered government. However, you may also have contacts acquired as a result of your ministerial role and there is a risk that you could be seen to advantage Brazelton Centre UK were you to draw on such contacts to secure business on its behalf. I have therefore applied a restriction that prevents you from lobbying any contacts acquired solely from your time in office for the purpose of securing business for Brazelton Centre UK.