Decision

Advice Letter: Stephen Oldfield, Trustee, The Think Ahead Organisation

Updated 21 May 2025

1. BUSINESS APPOINTMENT APPLICATION: Stephen Philip Oldfield CB, former Chief Commercial Officer and Director General of Commercial and Life Sciences at the Department of Health and Social Care. Unpaid appointment with The Think Ahead Organisation.

Mr Oldfield 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 he wishes to take up with the The Think Ahead Organisation (Think Ahead).

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 Mr Oldfield’s time in office, alongside the information and influence a former Crown servant may offer Think Ahead. The material information taken into consideration by the Committee is set out in the annex.

The Committee has advised that a number of conditions be imposed to mitigate the potential risks to government associated with this appointment under the Rules. The Committee’s advice is not an endorsement of this application in any other respect.

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 this appointment as Trustee 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 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.

Since 2019, Think Ahead has had a contractual relationship with the Department for Health and Social Care (DHSC) relating to Think Ahead’s mental health and social work program and its graduate program. Mr Oldfield was not involved in the substance of the contract which was a matter for DHSC officials - not the Cabinet Office commercial team. Given this is an unpaid role and there is a limited overlap with Mr Oldfield’s time in office, the risk that this appointment could reasonably be perceived as a reward for decisions or actions taken in office is low.

As a former senior Crown servant, there are inherent risks associated with your contacts and influence within government. The role is internal to the organisation and does not involve contact with government.

3. The Committee’s advice

The Committee did not consider this appointment raises any particular propriety concerns under the government’s Business Appointment Rules. As above, the unpaid signature of this role significantly limits the risks subject to standard conditions. These seek to prevent Mr Oldfield from drawing on privileged information and using his contacts to the unfair advantage of his new employer, will sufficiently mitigate the risks in this unpaid appointment.

In accordance with the government’s Business Appointment Rules, the Committee advises this appointment with the Think Ahead Organisation subject to the following conditions:

• Mr Oldfield 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 him from him time in Crown service;

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

• for two years from his last day in Crown service, he should not provide advice to the Think Ahead Organisation on the terms of, or with regard to the subject matter of, a bid or contract with, or relating directly to the work of the UK government or any of its arm’s length bodies.

The advice and the conditions under the government’s Business Appointment Rules relate to an applicant’s previous role in government only; there are separate rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists, the Parliamentary Commissioner for Standards and the Commissioner for Standards^{[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 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’.

Mr Oldfield must inform us as soon as he takes up this work or if it is announced that he will do so. Similarly, he must inform us if he proposes to extend or otherwise change his role with the organisation as depending on the circumstances, it might be necessary for him to seek fresh advice.

Once this appointment has been publicly announced or taken up, we will publish this letter on the Committee’s website.

4. Annex - Material Information

4.1 The Role

Think Ahead is a registered charity with the Charity Commission^{[footnote 5]}. According to the Charity Commission, the main objectives of Think Ahead are:

• The advancement of education and training in particular in the fields of mental health care social work and social care and allied fields.

• The advancement of physical and mental health to improve standards of social care.

• To raise the awareness of mental health issues and promote research for the education of the public.

• The relief of those in need.

Mr Oldfied stated that Think Ahead is a registered charity whose purpose is to recruit, train and promote the mental health workforce in social care, ensuring the right professionals can deliver the right support at the right time. Mr Oldfield stated that Think Ahead receives funding from DHSC. According to its website, government funding up to £27m to Think Ahead. It receives funding from DHSC for its two-year, fully funded training programme which trains up to 160 mental health social workers every year.

In his unpaid, part-time role as Trustee, Mr Oldfield stated he will help further and support the aims of the charity, as well as provide oversight of governance. Trustees will participate in board meetings, attend other meetings with employees and stakeholders as required, and help build a future strategy for the organisation.

Mr Oldfield confirmed his role will not involve contact with government. He added that the executive team of Think Ahead have direct contact with DHSC in agreeing the continued funding of Think Ahead’s program and in contract management performance meetings. Mr Oldfield said that any contact with government is fully delegated to the Chief Executive.

4.2 Dealings in office

Mr Oldfiled confirmed that the contract funding for Think Ahead in May 2019, for the value of £27 million, sat with the Mental Health Directorate of DHSC who were managing the contract and had no reporting line to him. He added he was not involved in any policy, regulatory decisions nor had access to sensitive information specific to Think Ahead.

4.3 Departmental assessment

Cabinet Office confirmed the details Mr Oldfield provided and stated that:

• it did not hold a relationship with Think Ahead but DHSC did as described above;

• Mr Oldfield was not involved in policy or regulatory decisions specific to Think Ahead;

• it does not have concerns regarding Mr Oldfield’s access to sensitive information specific to Think Ahead; and

• it did not have concerns regarding Mr Oldfield’s appointment and recommended the standard conditions.

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 Andrew Cumpsty; Isabel Doverty; Hedley Finn OBE; The Rt Hon Lord Pickles; Michael Prescott; Mike Weir; Sarah de Gay; and Dawid Konotey-Ahulu CBE DL. ↩

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 Parliamentary Code of Conduct and the Code of Conduct for Members of the House of Lords. ↩

5. https://register-of-charities.charitycommission.gov.uk/charity-search/-/charity-details/5075841 ↩