Decision

Advice Letter: Guy Opperman, Senior Advisor (International), Smart Pension Limited

Published 12 August 2025

1. BUSINESS APPOINTMENT APPLICATION: Guy Opperman, former Minister for Roads and Local Transport at the Department for Transport, and previously Minister of State at the Department for Work and Pensions. Paid appointment with Smart Pension Limited.

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 with Smart Pension Limited (Smart Pension) as a Senior Advisor (International).

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 Smart Pension, 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

Smart Pension is a digital pensions company, running a defined contribution auto-enrolment employment pension scheme, and regulated by the Pensions Regulator. As a Senior Advisor you said that your role will involve selling Smart Pension products overseas assisting the company in building its partnerships internationally. You said that you will not be involved in the UK branch of the company.

As a former Parliamentary Under Secretary of State (PUS) for Pensions and Financial Inclusion, the Department for Work and Pensions (DWP) said that you made policy and regulatory decisions relating to the pensions sector, which would have directly impacted Smart Pension. DWP said that as PUS you had official meetings with Smart Pension as well as its competitors; and that while Smart Pension is a major stakeholder in DWP, there is no contractual relationship between DWP and Smart Pension. The risks associated with these dealings with Smart Pension are limited by the fact that you left this specific role as PUS more than two years ago, and as such, the Committee[footnote 1] considered that the risk that this role could reasonably be seen as a reward for your decisions made and actions taken in office is low.

There is no overlap with your responsibilities in your most recent roles as Minister of State for Roads and Local Transport and Minister of State for Employment. The DWP said that as Parliamentary Under Secretary of State for Pensions and Financial Inclusion you had access to commercially sensitive information about Smart Pension’s competitors, and pensions policy and regulatory reforms, which would grant Smart Pension an unfair advantage. This risk is significantly limited by the fact that you left your role as Parliamentary Under Secretary of State for Pensions and Financial Inclusion more than two years ago. Over that time, the sensitive information to which you had access will either have entered the public domain or moved on, such that it is no longer commercially sensitive.

The risk of overlap remains given that you will be working with clients of Smart Pension, the identity of whom are unknown. This raises a reasonable risk that you may be asked to advise on matters you were materially involved with as a minister, or where you had a relationship with the client as a minister.

As a DWP stakeholder, Smart Pension has an interest in government policy and regulation on pensions. As such, there are risks associated with your influence and network of contacts gained in office. In particular, you may be seen to be able to offer unfair access to DWP and its arm’s length bodies involved in pensions policy and regulation, to Smart Pension or its clients. This risk is mitigated by the following factors:

  • You said that your role will not involve any contact with or lobbying of government, in line with the lobbying ban that applies to all former ministers on leaving office.

  • Your role will be international facing – you will be helping to sell Smart Pension products, promote the company, and establish partnerships, to international clients. You said that you will not be involved in the company’s UK enterprise.

  • Smart Pension has a pre-existing relationship with DWP, which reduces the risk that you were employed to assist in establishing one.

In your role in business and partnership development, there is a risk that you may be seen to draw on your contacts in the private sector and/or foreign governments gained only as a result of your role as a minister.

3. The Committee’s advice

The Committee considered that the risks associated with your access to information and influence to be limited for the reasons explained above. That you left your role as Parliamentary Under Secretary of State for Pensions and Financial Inclusion more than two years ago is a significant mitigating factor. The Committee determined that these risks can be appropriately mitigated by the conditions below – which seek to prevent you from making improper use of privileged information, contacts and your influence to the company’s unfair advantage.

Additionally, the Committee imposed a restriction on lobbying contacts you made during your time in office in other governments and organisations outside of the UK government for the purpose of securing business for Smart Pension.

To address the risk associated with Smart Pension’s unknown clients, the Committee has imposed a condition to limit the scope of your role. This makes clear that you should not advise on work with regard to any policy or regulation you had material involvement in, or responsibility for, in your two most recent two roles in government.

In accordance with the government’s Business Appointment Rules, the Committee advises that this appointment with Smart Pension Ltd 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 any of its arm’s length bodies on behalf of Smart Pension Ltd (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 Smart Pension Ltd (including parent companies, subsidiaries, partners and clients);

  • for two years from your last day in ministerial office, you should not provide advice to on behalf of Smart Pension Ltd (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 any of its arm’s length bodies;

  • for two years from your last day in ministerial office, you should not become personally involved in lobbying contacts you developed during your time in office in other governments and organisations for the purpose of securing business for Smart Pension Ltd; and

  • for two years since your last day in office, you should not advise Smart Pension or its clients on any work with regard to any policy or regulatory decisions which you had a material role in developing or determining, or where you had a relationship with the relevant client during your time as Minister of State for Roads and Local Transport at the Department for Transport and Minister of State for Employment at the Department for Work and Pensions.

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 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(s), 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

Smart Pension is a digital pensions and retirement technology business, delivering pension technology platforms in partnership with other financial institutions, and running a defined contribution master trust pension scheme setup for employers to enrol employees in a workplace pension scheme. It is the fourth largest auto-enrolment provider (by membership) in the UK pensions market. Its Pensions Master Trust is regulated by the Pensions Regulator.

You seek to take up a paid, part-time role as a Senior Advisor (international), and your role would involve:

  • selling Smart Pension products overseas;
  • promoting the company overseas; and
  • assisting the company in building its partnerships internationally.
  • You said that you will not have any involvement with the UK branch of the company, and that your role will not involve any contact with the UK government.

4.2 Dealings in office

Of your time in office, you said that following:

  • you did not make any policy, commercial or regulatory decisions specific to Smart Pension in any of your ministerial roles;
  • you only contact with Smart Pension in your Parliamentary Under Secretary of State for Pensions and Financial Inclusion, in the form of ministerial meetings and roundtables, but this occurred more than two years ago;
  • you did not have access to sensitive information through any of your ministerial roles, that could grant Smart Pension an unfair advantage; and
  • DWP does have dealings with Smart Pension, as a pension provider.

4.3 Departmental assessment

DfT and DWP were consulted on this application. You were the Parliamentary Under Secretary for Pensions and Financial Inclusion between June 2017 and September 2022. This role ended more than two years ago, and whilst it is relevant to this application and your decisions and access to information from this role have been considered, these do not present any particular concerns, given the amount of time that has passed since you left this role.

DfT said that you did not make any decisions specific to Smart Pension as Minister for Roads and Local Transport, nor did you contact or have access to any information that could grant Smart Pension an unfair advantage.

DWP said that as Minister of State for Employment you did not make any decisions specific to Smart Pension, nor did you have access to any information that could grant Smart Pension an unfair advantage.

DWP said the following regarding your role as Parliamentary Under Secretary of State for Pensions and Financial Inclusion:

  • You were responsible for workplace pensions policy decisions, including major policy on Auto-Enrolment,[footnote 3] regulatory initiatives such as Value for Members[footnote 4] Assessments and Pensions Dashboards[footnote 5] - all of which would have affected Smart Pension as a workplace pensions provider.

  • You had meetings with Smart Pension in office. These included:
    • 1:1 ministerial meetings
    • formal DWP meetings
    • Roundtables
    • Informal contact
  • You had contact with competitors of Smart Pension at pension-provider roundtables and formal departmental meetings / visits. This includes Nest - a government-funded pension provider and ALB of DWP, of strategic importance to the government’s auto-enrolment policy.[footnote 6]

  • You did have access to commercially sensitive information that could grant Smart Pension an unfair advantage. This included:
    • material relating to the government-funded Nest pension scheme;[footnote 7]
    • all private pensions policy submissions during his tenure at DWP (including as Parliamentary Under Secretary for Pensions and Financial Inclusion and Minister of State for Employment), including advice on the 2023 Mansion House pensions reform proposals[footnote 8] (a major set of private pensions regulatory reforms developed over that period) which would have directly affected Smart Pension.
  • Smart Pension is a key stakeholder for DWP. The department engaged with Smart Pension as part of its work to address self-employed people saving for retirement.

  • DWP had no record of any spend/ commercial relationship with Smart Pension.

As regards your decision-making in office as Parliamentary Under Secretary of State for Pensions and Financial Inclusion, DWP said that the decisions are now in the public domain, or have moved on, as you left this role more than two years ago.

As regards your access to information, DWP said that the passage of time has reduced the commercial value of this insight, and noted that the 2023 Mansion House Reforms were announced by the previous government and have been largely adopted by this government (they were announced in the Kings Speech in relation to the upcoming Pensions Bill).

The departments recommended standard conditions.

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

  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. www.thepensionsregulator.gov.uk/en/business-advisers/automatic-enrolment-guide-for-business-advisers/duties-for-new-employers 

  4. www.thepensionsregulator.gov.uk/en/document-library/scheme-management-detailed-guidance/governing-body-detailed-guidance/5-value-for-members 

  5. www.pensionsdashboardsprogramme.org.uk/about and www.smartpension.co.uk/news-and-media/joins-dashboard-operators-coalition 

  6. assets.publishing.service.gov.uk/media/5a82bfa7e5274a2e87dc2c88/auto-key-facts-enrolment-booklet.pdf 

  7. www.nestpensions.org.uk/schemeweb/nest.html 

  8. www.gov.uk/government/collections/mansion-house-2023