Decision

Advice Letter: Olivia Bloomfield, Advisory Board Member, Gresham House Asset Management Limited

Published 26 March 2025

1. BUSINESS APPOINTMENT APPLICATION: Baroness Olivia Bloomfield of Hinton Waldrist, former Government Whip, House of Lords. Paid appointment with Gresham House Asset Management Limited.

You sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointments Rules for Former Ministers (the Rules) on an appointment you wish to take up with Gresham House Asset Management Limited (Gresham House) as an Advisory Board Member. 

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 Gresham House. 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 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

You made no policy, regulatory or commercial decisions specific to Gresham House whilst in office. Your only interaction with the company was a meeting with the CEO to discuss sustainability and climate change, over three years ago. Therefore, the Committee^{[footnote 1]} determined that the risk you were offered the role as a reward for your actions taken in office, is low. 

As a former minister, there are risks associated with your access to privileged information. The Department for Energy Security and Net Zero (DESNZ^{[footnote 2]})  confirmed you did not have access to any specific information that could provide an unfair advantage to Gresham House. Further, you have been out of office for over 12 months, creating a gap between your access to information and your role with the company. 

There are inherent risks with any former minister that your network and influence might offer the company unfair access to government. 

3. The Committee’s advice 

The conditions below make it clear you must not make use of your access to privileged information, contacts or influence gained from your time in ministerial office to the unfair benefit of Gresham House. The Committee considered the conditions below appropriately mitigate the risks identified above.

The Committee advises, under the government’s Business Appointment Rules, that your role with Gresham House Asset Management Limited should 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 service; 

• 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 Gresham House Asset Management Limited  (including parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or Crown service to influence policy, secure business/funding or otherwise unfairly advantage Gresham House Asset Management Limited  (including parent companies, subsidiaries, partners and clients); and

• for two years from your last day in ministerial office, you should not provide advice to Gresham House Asset Management Limited (including parent companies, subsidiaries, partners and clients) 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 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]}. You are reminded that as a Member of the House of Lords you are prevented from any paid lobbying under the House of Lords Code of Conduct. 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 employment with this organisation, or if it is announced that you will do so. Please 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.

4. Annex - Material Information

4.1 The role

According to its website, Gresham House is a specialist alternative asset management firm:

• listed on the London Stock Exchange’s Alternative Investment Market (AIM).

• that offers a broad range of funds, direct investments and tailored investment. opportunities, including co-investment, across a range of alternative investment strategies.

• which has clients that include individual investors, financial advisers, institutional investors, charities and endowments, family offices, and business owners.

In your paid, part-time role as Member of the Advisory Board, you stated you will participate in meetings - with the Advisory Board providing a forum within which to discuss and debate the Group’s product and service offering.  You confirmed your role will not involve contact with, or lobbying government. 

4.2 Dealings in office

You advised the Committee that you were not involved in policy, regulatory or commercial decisions, nor did you have access to sensitive information specific to Gresham House.

4.3 Departmental Assessment 

DESNZ confirmed the details you provided and stated the following: 

• the House of Lords Whips Office confirmed that you met with the CEO of Gresham House on 8 June 2021 to discuss sustainability and climate change as a BEIS whip.  

• you were not involved in decisions specific to Gresham House.

• it does not hold a relationship with Gresham House.

• it did not have concerns regarding your access to sensitive information. It noted that it is unlikely that information you possess would provide an unfair advantage given the length of time since you left office [over 12 months] and the subsequent change in government administration. 

DESNZ did not have concerns with the appointment and recommended the standard conditions.

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

2. Following the Machinery of Government changes in February 2023, the Department for Business, Energy and Industrial Strategy split to form the Department for Energy Security and Net Zero; the Department for Business and Trade; and the Department for Science, Innovation and Technology. ↩

3. 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. Advice on your 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. ↩