Decision

Advice Letter: Sarah Munby, Lay Member of the Board of Governors, University of Manchester

Published 20 August 2025

1. BUSINESS APPOINTMENT APPLICATION: Sarah Munby, former Permanent Secretary of the Department for Science, Innovation and Technology. Unpaid appointment with the University of Manchester.

Ms Munby sought advice from the Advisory Committee on Business Appointments(the Committee) under the government’s Business Appointment Rules for Former Crown Servants (the Rules) on an unpaid role she wishes to take up with the University of Manchester (the University) as a Lay Member of the Board of Governors.

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 Ms Munby’s time in office, alongside the information and influence she may offer the University. 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 Rules^{[footnote 1]} set out that Crown servants must abide by the Committee’s advice. It is an applicant’s personal responsibility to manage the propriety of any appointment. Former Crown servants 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 2]} took into account that this appointment is unpaid^{[footnote 3]}. 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 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, 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 University receives government funding via arrangements within Ms Munby’s former department - Department for Science, Innovation and Technology (DSIT). Whilst she was responsible for the department as Permanent Secretary, she had no visibility of, nor involvement in, specific grants. There is a general overlap between Ms Munby’s policy responsibilities – in leading DSIT with responsibility for research in the UK – and the impacts of this on an overall group of universities. The Committee agreed with DSIT that the risks associated with this unpaid role are limited.

As a former Permanent Secretary, Ms Munby is subject under the Rules to a minimum waiting period of three months between leaving paid employment and taking up any outside appointment.

3. The Committee’s advice

The Committee did not consider this unpaid appointment to raise any particular concerns under the government’s Business Appointment Rules. The standard conditions below sufficiently mitigate the inherent risks. These seek to prevent Ms Munby 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 that this appointment with the University of Manchester be subject to the following conditions:

• a waiting period of three months from her last day in Crown service;

• Ms Munby should not draw on (disclose or use for the benefit of himself or the persons or organisations to which this advice refers) any privileged information available to her from her time in Crown service;

• for two years from her last day in Crown service, she should not become personally involved in lobbying the UK government or its arm’s length bodies on behalf of the University of Manchester (including parent companies, subsidiaries, partners and clients); nor should she make use, directly or indirectly, of her contacts in the government and/or Crown service to influence policy, secure business/funding or otherwise unfairly advantage the University of Manchester (including parent companies, subsidiaries, partners and clients); and

• for two years from her last day in Crown service, she should not undertake any work with the University of Manchester (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 her 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 4]}. 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/Civil Service Code or otherwise.

The Business Appointment Rules explain that the restriction on lobbying means that the former Crown servant ‘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.’

Ms Munby must inform us as soon as she takes up this role, or if it is announced that she will do so, and we will publish this letter on our website. She must also inform us if she proposes to extend or otherwise change the nature of her role as, depending on the circumstances, it may be necessary for her to make a fresh application.

4. Annex - Material Information

4.1 The role

The University of Manchester (the University) is a public research and teaching university. It has charitable status.

Ms Munby wishes to take up a part-time, unpaid role as Lay Member of the Board of Governors (the Board). She told the Committee that the Board’s role is to ensure that the work being undertaken on its behalf is consistent with the University’s corporate objectives. Ms Munby is expected to attend approximately six Board meetings per year and serve on a Board committee. The role is described as being to:

• constructively challenge University strategy;
• scrutinise performance management;
• interrogate financial and risk management systems;
• uphold high standards of integrity;
• take into account the views of stakeholders; and
• (from time to time) chair appeals or grievance processes.

Ms Munby stated that the University has said that the role does not in any way involve either lobbying activity, direct contact with the government, or involvement in contracting or bidding with the government. She noted that the bulk of the role will have nothing to do with the government, though the Board will be asked to comment on University strategy, and government policy is inherently relevant to that.

4.2 Dealings in office

Ms Munby stated that she did not make any policy, regulatory or commercial decisions specific to the University, though policy responsibilities (to lead the Department with responsibility for research in the UK) has meant she has worked on policy that impacts the University as part of the overall group of universities. In all cases she was not involved in personally writing the policy, but teams in her department have done so. She noted that DSIT’s work has included:

• setting funding envelopes and key strategic priorities for major R&D bodies including UKRI, ARIA and UKSA, via the processes of which some funding will ultimately pass to universities, including the University;

• working alongside the Department for Education and the Office for Students to support their thinking on how the government should guarantee the financial stability of universities and effectively handle instances of institutional distress;

• working on security of UK research and how to support UK institutions in strengthening the way they handle national security topics;

• trying to influence overall government policy on issues that impact research, like talent immigration;

• announcing in February 2022 an Innovation Accelerator programme in which Greater Manchester was one of three regions selected as part of a pilot to fund innovation clusters – she was not the instigator, designer or decision maker, and individual project funding decisions were not taken by DSIT;

• overseeing a range of arm’s length bodies that provide research grants, with responsibility for their senior appointments, governance, etc – she had no role in any grant giving, and day-to-day sponsorship is led by one of her director-generals and team.

Ms Munby said that she attended a prize-giving event hosted for DSIT at the Whitworth (a venue owned by the University) at which University members may have been present. She was also overall Permanent Secretary champion for the Civil Service in Manchester (where DSIT has a large office) but she does not recall any specific contact with the University.

Ms Munby noted that the University receives significant government research funding, which is ultimately overseen by DSIT and its arm’s length bodies. Decisions on grant-making are primarily made by independent members of peer review bodies. She had neither visibility of, nor involvement in, these grants and does not know the amounts and dates of them.

Ms Munby said that she did not have any access to information that could grant the University an unfair advantage.

4.3 Departmental assessment

DSIT and the Cabinet Office confirmed Ms Munby’s account of her level of involvement in policy, regulatory or commercial decisions specific to the University during her time in office.

DSIT and the Cabinet Office confirmed that she has visited the University for a lab tour and a prize-giving ceremony, noting this level of contact is similar to her contact with other universities.

DSIT and the Cabinet Office confirmed that the University receives funding for its research from the department. DSIT noted that decisions on grant-making are primarily made by independent members of peer review bodies, and that Ms Munby had neither visibility of nor involvement in these grants.

DSIT and the Cabinet Office stated that Ms Munby may retain privileged information from her time in Crown service that may be beneficial to the prospective employer. Therefore, she should be reminded of her lifelong duty to maintain the confidentiality of this information.

DSIT and the Cabinet Office recommended the following conditions:

• a restriction from lobbying UK government officials on behalf of the prospective employer for 2 years following her final day in service;

• a reminder of her ongoing duties in respect of confidentiality of information gained as a result of her time as a Crown servant;

• a reminder that if she is to contact officials of the UK government, to do so via official channels; and

• a three-month waiting period.

1. Which apply by virtue of the Civil Service Management Code, The Code of Conduct for Special Advisers, The King’s Regulations and the Diplomatic Service Code. ↩

2. 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. ↩

3. 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. ↩

4. 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. ↩