Decision

Advice letter: Paul Maynard, Consultant, Aon Plc

Published 2 December 2025

1. BUSINESS APPOINTMENT APPLICATION: Paul Maynard, former Parliamentary Under Secretary at Department for Work and Pensions - Paid appointment with Aon Plc.

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 appointment with Aon Plc as a Consultant.

The purpose of the Rules is to protect the integrity of the government. The Committee ^{[footnote 1]} has considered the risks associated with the actions and decisions taken during your time in office, alongside the information and influence you may offer Aon as a former minister. The material information taken into consideration by the Committee is set out in the annex below.

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

Aon is a private sector financial services company providing a range of professional services. Through its subsidiaries, it works in commercial risk, reinsurance, retirement, health, wealth, and data and analytic services. It is also a workplace pension advisor and works with public sector and private sector clients. You said that your role as consultant is to help Aon develop its strategy for engagement with government and to advise Aon on how government operates.

There is a significant overlap with your responsibilities at the Department of Work and Pensions (DWP) and this role. As Parliamentary Under-Secretary of State, you had responsibility for pensions and made decisions on pension policy that affected Aon and competitors. These policy decisions were made at a sector wide level and no decisions made were specific to Aon. Further, you made no commercial decisions that affected Aon. In the circumstances the committee considered that the risk that this appointment was a reward for decisions made in office is low.

As Parliamentary Under-Secretary at DWP, you had access to general privileged information regarding the pensions sector. DWP said that you had sight of privileged commercial information regarding the government Nest Pension scheme whilst in office. DWP confirmed that this information was no longer considered relevant and is not commercially advantageous to Aon. Further, you have been out of office for over 12 months, and since then there have been a number of key developments in the pension sector implemented following the change in government which have reduced the currency of any information you had access to;

• the government launched a Pensions Investment Review.
• the government announced in the Autumn Budget (October 2024) it would be reforming Inheritance Tax on unused pension funds and subsequently consulted on this. 
• in June 2025, the Pension Schemes Bill was introduced to Parliament - legislating for the outcome of the Pensions Investment Review - a smaller number of bigger, better governed, better value pension providers investing in a wider range of productive assets.

The Committee agrees that the risk of privileged information is limited and that any privileged information available to you from your time in office at DWP is no longer commercially advantageous.

There is a risk associated with your contacts developed in office and influence within government and the unfair access you may offer Aon, especially as Aon regularly engages with DWP through consultations as part of the policymaking process. Further, you said your role is focused on advising Aon on its strategy  to more effectively communicate and influence government and to advise Aon on the way in which the government operates. Whilst you intend not to contact or lobby the government in this role, there is a risk you will be seen to offer access and/or influence within your former department that Aon might not otherwise gain.  It is significant Aon confirmed your role will not include any lobbying.

3. The Committee’s advice

The Committee considers the main risk here is a reasonable concern  that you may offer Aon unfair access to the government, especially as the organisation regularly engages with DWP during the policymaking process. Therefore, the Committee’s advice is you should have no direct engagement with the government on behalf of Aon whilst you are subject to the Rules, to mitigate the risk that you are seen to be making improper use of your time in office to the unfair benefit of your employer/ its members.

The remaining conditions appropriately mitigate the risks associated with your access to privileged information, contacts and influence from your time in government. 

Taking these factors into account, in accordance with the government’s Business Appointment Rules, the Committee’s advice is this appointment with Aon plc be subject to the following conditions:

• a waiting period of at least six months from your last day in office - now passed;
• 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 Aon (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 Aon (including parent companies, subsidiaries, partners, clients and members);  *for two years from your last day in ministerial office you should not undertake any work with Aon (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; and *for two years from your last day in ministerial office you should not have any engagement on behalf of Aon (including parent companies, subsidiaries, partners, clients and members) with the UK government.

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 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.

Isabel Doverty

Interim Chair

ACOBA

4. Annex - Material Information

4.1 The role 

Aon is a private sector financial services company-  providing a range of professional services. Through its subsidiaries, it works in commercial risk, reinsurance, retirement, health, wealth, and data and analytic services. Aon is also a workplace pension provider and works with private and public sector clients.

In your paid, part-time role as consultant, you said that you would be advising Aon on its engagement strategy with government and provide insight more broadly into the workings of government and the policymaking process.

You confirmed your role will not involve contact with government.

4.2 Correspondence with Aon

Aon confirmed in writing its understanding of and agreement to comply with the Committee’s advice, stating: ‘Aon will not ask or require Paul to do work for us outside of the limitations that are set out by the Committee.’

4.3 Dealings in office

You said that you met with a number of sector representatives during your time in ministerial office. You said that you made decisions related to pension policy but you did not make any decisions specific to Aon.

4.4 Departmental Assessment

DWP confirmed the details provided in your application and added that you had contact with Aon at a ministerial meeting.

DWP recommended standard conditions.

1. This application for advice was considered by Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE; Michael Prescott and The Baroness Thornton; ↩

2. All Peers and Members of Parliament are prevented from paid lobbying under the the House of Commons Code of Conduct and the Code of Conduct for Members of the House of Lords. ↩