Decision

Advice letter: Penny Mordaunt, Advisory Board Member, Museum of the Prime Minister

Updated 30 April 2025

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Penny Mordaunt, former Lord President of the Council and Leader of the House of Commons. Unpaid appointment with the Museum of the Prime Minister.

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 an unpaid role as Advisory Board Member for the Museum of the Prime Minister (MoPM), registered with the Charity Commission as PM Museum Ltd.  

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 in office, alongside the information and influence you may offer MoPM. 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

When considering this application, the Committee^{[footnote 1]} took into account this appointment as Advisory Board Member 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 the Government by considering the real and perceived risks associated with former ministers 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.

You had no official dealing with the organisation in office and there is no specific overlap with your time in office.  There are inherent risks, as with any  former Cabinet minister, that you have access to information and also contacts and influence within government that could benefit the organisation.

3. The Committee’s advice

The Committee considered that the risks in this application can be sufficiently mitigated by the standard conditions below, which seek to prevent you from making improper use of privileged information, contacts and influence to the unfair advantage of the organisation.

Therefore, in accordance with the government’s Business Appointment Rules, the Committee advises this appointment with the Museum of the Prime Minister 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 arms’ length bodies on behalf of the Museum of the Prime Minister (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 Museum of the Prime Minister (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 the Museum of the Prime Minister (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 arms’ 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.^{[footnote 3]} 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 and we will publish this letter on our website. 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.

4. Annex - Material Information

4.1 The role

According to its website, the Museum of the Prime Minister (MoPM) is dedicated to the history, influence, interpretation and legacy of the Prime Ministers of the United Kingdom. It will collect and conserve items related to those who have served as Prime Minister and promote the understanding of British history and the values of leadership, good government and democracy.

You wish to take up a part-time, unpaid role as Advisory Board Member at the Museum of the Prime Minister.

4.2 Dealings in office

You said that you did not make any policy, regulatory or commercial decisions specific to the Museum of the Prime Minister, that you did not have any access to information that could grant the Museum of the Prime Minister an unfair advantage, and that there was no relationship between the Museum of the Prime Minister and the Cabinet Office.

You stated that you were briefed on the project in your capacity as Leader of the Commons.

4.3 Departmental Assessment

The Cabinet Office confirmed the details you provided and recommended the standard conditions. 

1. This application for advice was considered by Andrew Cumpsty; Hedley Finn OBE; Sarah de Gay; Dawid Konotay-Ahulu OBE DL; The Rt Hon Lord Eric Pickles; Michael Prescott; The Baroness Thornton; and Mike Weir. Isabel Doverty was unavailable. ↩

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. ↩

3. 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 obligations under the Code can be sought from the Parliamentary Commissioners for Standards, in the case of MPs, or the Registrar of Lords’ Interests, in the case of peers. ↩