Decision

Advice Letter: Guy Opperman, Advisor, The General Organisation for Social Insurance, the Government of Saudi Arabia

Updated 16 September 2025

1. BUSINESS APPOINTMENT APPLICATION: Mr Guy Opperman, former Minister for Roads and Local Transport at the Department for Transport, and previously Minister for Employment at the Department for Work and Pensions. Paid appointment with the General Organisation for Social Insurance, the Government of the Kingdom of Saudi Arabia. 

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 as an Advisor with the General Organisation for Social Insurance (GOSI), the Government of the Kingdom of Saudi Arabia.  

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 taken during your time in office, alongside the information and influence you may offer GOSI 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

GOSI is a Saudi Arabian government agency based in Riyadh, responsible for managing social insurance for employees in the country. It was established to implement the provisions of the Kingdom of Saudi Arabia’s Social Insurance Law and follow-up the process of achieving compulsory insurance coverage – collecting contributions from employers and paying benefits for the eligible contributors or their family members. 

GOSI and the wider Government of the Kingdom of Saudi Arabia, have relationships with the UK government: 

• the Department for Transport (DfT) has occasional contact with representatives of the Saudi government to discuss transport issues that are of shared interest. Further, the department maintains contact in the context of inward or outward bilateral visits by ministers and/or officials, meetings at multilateral fora, trade shows, or through collaborative work programmes developed to help ensure safe and secure connectivity between the UK and the Kingdom of Saudi Arabia. 
• there is a Memorandum of Understanding on labour cooperation between the Department for Work and Pensions (DWP) and the Ministry of Labour and Social Development of Saudi Arabia, signed in 2019 by the then Secretary of State. 
• the Foreign, Commonwealth and Development Office (FCDO) is developing a new pensions-focused initiative within the UK-Saudi financial services relationship, building strong ties with GOSI and its leadership. The department stated that discussions are ongoing to shape the initiative, which will be integrated into the updated HM Treasury–Saudi Ministry of Finance Memorandum of Understanding, with support from the City of London Corporation. 

Whilst the Kingdom of Saudi Arabia has a relationship with your former departments, this was not specific to your recent ministerial portfolios. DfT and DWP confirmed that you did not meet with GOSI, nor were you involved in policy, regulatory or commercial decisions specific to the organisation. Therefore, the Committee^{[footnote 1]} considered the risk that this appointment could reasonably be perceived as a reward for decisions or actions taken in office is low. 

As a former minister, it is likely that you had access to a broad range of sensitive information that may provide any company an unfair advantage, including GOSI. The risks are limited as there is no direct overlap with your time in office and the work of GOSI. Further, DfT and DWP do not consider you to possess sensitive information that could provide an unfair advantage to GOSI. This is a general risk and you have been out of office for over 12 months – putting a gap between your last having had access to information and taking up this role. 

As with any former minister, there are risks associated with your contacts and influence within government – with the potential for GOSI to gain unfair access or influence as a result. You confirmed your role excludes any dealings with the UK government, reducing the risk you could be perceived to be lobbying government – which all former ministers are prevented from doing for two years after leaving office. 

The Committee took into account your experience in pensions, social insurance and matters that relate to the work of GOSI from your experience as Parliamentary Under-Secretary of State for Pensions and Financial Inclusion at DWP, a role you held over two years ago. DWP did not raise any concerns during your time in that ministerial role that would raise concerns to this proposed appointment. 

3. The Committee’s advice 

The Committee determined the risks identified in this application can be appropriately mitigated by the conditions below. These make it clear that you cannot make use of privileged information, contacts or influence gained from your time in ministerial office to the unfair advantage of GOSI. 

The Committee advises, under the government’s Business Appointment Rules, that your appointment with the General Organisation for Social Insurance, the Kingdom of Saudi Arabia 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 government or any of its arm’s length bodies on behalf of the General Organisation for Social Insurance, the Kingdom of Saudi Arabia (including parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in government and/or Crown service to influence policy, secure business/funding or otherwise unfairly advantage the General Organisation for Social Insurance, the Kingdom of Saudi Arabia (including parent companies, subsidiaries, partners and clients); and

• for two years from your last day in ministerial office, you should not provide advice to the General Organisation for Social Insurance, the Kingdom of Saudi Arabia (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 and 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 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 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. 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. 

4. Annex – material information 

4.1 The role

GOSI is a Saudi Arabian government agency based in Riyadh, responsible for managing social insurance for employees in the country. The agency was established to implement the provisions of the Kingdom of Saudi Arabia’s Social Insurance Law and follow-up the process of achieving compulsory insurance coverage, collecting contributions from employers and paying benefits for the eligible contributors or their family members.

The Government of the Kingdom of Saudi Arabia and the UK government has a broad, long standing strategic partnership that includes economic and social collaboration.^{[footnote 3]} Most recently, the formation of the UK-Saudi Sustainable Infrastructure Assembly to boost trade flows between the nations and partnerships in sustainable infrastructure, investment and development.^{[footnote 4][footnote 5]}

In your paid, part-time role as Advisor, you stated that you will be involved in helping in the creation of a retirement strategy for the Government of the Kingdom of Saudi Arabia. You stated that the UK is a world leader in automatic enrolment pensions and the Government of the Kingdom of Saudi Arabia wishes to understand and then plan a retirement strategy using defined contributions pensions in the long term – which you will help advise on. You added that the retirement strategy is an existing document that the Government of the Kingdom of Saudi Arabia has been working on for several years and now wishes to fine tune with your input. 

You confirmed that your role will not involve contact with, or lobbying of, the UK government. 

You stated you were approached by representatives of GOSI when they visited London due to your knowledge of retirement strategies around the world. 

4.2 Dealings in office

You advised the Committee that you did not meet with GOSI, nor were you involved in decisions specific to GOSI, nor did you have access to sensitive information that could provide an unfair advantage to the organisation.

4.3 Departmental assessment 

The DfT, DWP and FCDO provided their views on your proposed appointment. 

DfT and DWP confirmed that you did not meet with GOSI, nor were you involved in policy, commercial or regulatory decisions specific to the organisation during your recent ministerial roles. 

DWP stated that you attended the Middle East Investor Relations Association (MEIRA) Conference in Dubai in October 2021, at which the Saudi Arabian government was also represented. The department stated you had no arrangements for a formal bilateral meeting with them.

DfT stated that it has occasional contact with representatives of the Government of the Kingdom of Saudi Arabia to discuss transport issues of shared interest, and added:

• some of this engagement will relate to formal structures or agreements – such as the UK/Saudi Arabia: Air Services Agreement; or the two memoranda of understanding agreed in 2023 between the then Secretary of State for Transport and Minister of Transport and Logistic Services for Saudi Arabia in relation to cooperation on future transport modes and cooperation in the railway sector.
• other contact may be in the context of inward or outward bilateral visits by ministers or officials, meetings at multilateral fora, trade shows, or through collaborative work programmes developed to help ensure safe and secure connectivity between the UK and the Kingdom of Saudi Arabia. An Annex to the Memorandum of Understanding between the General Authority of Civil Aviation and the Department for Transport on the Recognition of Aviation Security Measures for One-Stop Security was signed and announced on 23 June 2025.^{[footnote 6]}

DWP stated that there is a memorandum of understanding on labour cooperation between DWP and the Ministry of Labour and Social Development of Saudi Arabia, signed in 2019 by the then Secretary of State for DWP. This was due for renewal in 2024 and has technically expired.

The FCDO was consulted on this appointment as it is with a foreign government entity. The department stated that it has a relationship with GOSI, namely that it is developing a new pensions-focused initiative within the UK-Saudi financial services relationship, building strong ties with GOSI and its leadership, particularly the Governor, who also chairs the Insurance Authority. A recent UK visit by GOSI and the Insurance Authority to London enabled engagement with key pension (both UK government and Industry) stakeholders and laid the foundation for a collaborative roadmap aligned with UK Growth objectives. Discussions are ongoing to shape this roadmap, which will be integrated into the updated HM Treasury–Saudi Ministry of Finance Memorandum of Understanding, with support from the City of London Corporation.

The departments do not consider you to possess sensitive information that may provide an unfair advantage to GOSI. 

The departments did not have concerns with the appointment. The FCDO stated that you  could be a valuable advocate for such a cause so it does not hold concerns with this appointment. It also added that it is helpful to build UK-Saudi insurance/finance industry and institutional links, and not unusual for the Government of the Kingdom of Saudi Arabia to look for expertise from those with UK government experience. 

The departments recommended the standard conditions apply to the proposed appointment.

1. 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. ↩

2. 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. ↩

3. https://www.gov.uk/world/saudi-arabia/news#:~:text=Our%20mission,and%20climate%20security%2C%20and%20defence. ↩

4. https://news.cityoflondon.gov.uk/new-uk-saudi-sustainable-infrastructure-assembly-to-boost-trade-flows-and-champion-vision-2030/ ↩

5. https://news.daleel.gov.sa/industry/uk-saudi-infrastructure-assembly-boosts-sustainable-investment#:~:text=New%20platform%20enhances%20UK%2DSaudi,finance%20and%20sustainable%20infrastructure%20projects.&text=The%20Lord%20Mayor%20of%20the,United%20Kingdom%20and%20Saudi%20Arabia. ↩

6. www.caa.gov.qa/en/news/saudi-arabia-uk-sign-one-stop-security-deal-transit-passengers ↩