Decision

Advice Letter: Stephen Parkinson, Chairman, Heritage Railway Association

Published 7 October 2025

1. BUSINESS APPOINTMENT APPLICATION: Lord Parkinson of Whitley Bay, former Parliamentary Under-Secretary of State at the Department for Digital, Culture, Media and Sport. Unpaid appointment with the Heritage Railway Association. 

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 an unpaid role as Chairman of the Heritage Railway Association (HRA).

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 the HRA. 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

When considering this application, the Committee^{[footnote 1]} took into account that this appointment as Chairman of the HRA is unpaid^{[footnote 2]}. 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 ministers 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. 

There are inherent risks associated with any former minister’s access to information, network of contacts and influence in government. While the risks associated with access to information are limited in this unpaid role, there is a heightened risk of improper use of contacts and influence associated with the HRA’s role - as a trade association representing the interests of its members. This might raise a reasonable concern that you could be seen to lobby the government, which the Rules generally prohibit all former ministers from doing for two years on leaving office. You have asked the Committee to consider reducing  the two-year lobbying ban since your role in the House of Lords, including as Shadow Heritage Minister, means that you already raise issues relevant to the heritage rail sector more generally with government. As is usual in such cases, the Committee accepts that you must be able to raise issues with the government in your capacity as a member of the House of Lords and you remain  free to do so - noting that there are other Codes and rules in place governing the propriety of this, as set out in paragraph 10,  which are  unrelated to the Business Appointment Rules. To seek to influence government outside your Parliamentary duties would remain improper under government’s Rules. 

It is significant that HRA confirmed its agreement to the Committee’s advice. 

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 you from making improper use of privileged information, contacts and influence to the unfair advantage of the organisation.

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

• for two years from your last day in ministerial office you should not undertake any work with the Heritage Railway Association (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 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 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 and we will publish this letter on our website. You must 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.

4. Annex – Material Information

4.1 The role 

The Heritage Railway Association (HRA) is a not-for-profit company limited by guarantee, currently seeking full charitable status. It serves as a UK-wide trade association and professional support body for the heritage rail sector. The HRA represents its 300 members to various stakeholders, including local, national, and devolved governments, regulatory bodies, the media, and tourism organisations. In addition, it focuses on developing best practices, offering guidance, and providing business support to its members. 

You wish to take up a part-time, unpaid role as Chairman of the HRA. As the Chair of the HRA board, you will have responsibility for the following:

• Strategic direction, supported by the CEO;

• Guiding the HRA’s future, including its transition to a charity;

• Managing risk and financial health;

• Ensuring strategic delivery;

• Setting organisational direction;

• Assessing risks and capitalising on opportunities;

• Promoting the UK’s heritage rail;

• Supporting the CEO in running the trade association;

• Supporting the team’s work on business support, fundraising, and resilience; and

• Acting as the HRA’s ambassador along with the CEO.

4.2 Correspondence with the HRA

The HRA confirmed in writing its agreement to comply with the Committee’s advice.

4.3 Dealings in office

You said that you did not make any policy, regulatory or commercial decisions specific to the HRA, and that you did not have any access to information that could grant the organisation an unfair advantage. You also stated that there was no relationship between the HRA and the Department for Digital, Culture, Media and Sport (DCMS).

4.4 Departmental Assessment

DCMS confirmed that you did not make any policy, regulatory or commercial decisions specific to the HRA, and that you did not have any access to information that could grant the organisation an unfair advantage.

DCMS noted that it does not have any active policy work concerning the HRA. Although the HRA is a stakeholder within the wider heritage sector, DCMS does not engage with them regularly, in detail, or proactively.

DCMS recommended the standard conditions along with written confirmation from the employer that the role can be separated from lobbying activities.

1. This application for advice was considered by Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE; Michael Prescott; and The Baroness Thornton. ↩

2. 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. ↩

3. 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 your obligations under the Code can be sought from the Parliamentary Commissioner for Standards, in the case of MPs, or the Registrar of Lords’ Interests, in the case of peers. ↩