Decision

Advice letter: Penny Mordaunt, Non-Executive Director, Boka Capital Ltd

Published 2 March 2026

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Penny Mordaunt, former Leader of the Commons and Lord President of the Council, Cabinet Office – Paid appointment as Non-Executive Director, Boka Capital Ltd

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on taking up a paid, part-time role as a Non-Executive Director at Boka Capital Ltd.

The purpose of the Rules, as you will be aware, is to protect the integrity of government and to avoid any suspicion that those who have served in government might profit improperly from that experience or that an employer might gain unfair advantage through privileged access to government. To achieve these aims, I designate conditions that former ministers must follow.

The material information and my consideration are set out in the annex. In light of this, I consider the following conditions to be appropriate, recognising that it is your responsibility to ensure that these are demonstrably applied in practice:

• Privileged information condition – You should not draw on (disclose or use for the benefit of Boka Capital Ltd, related parties and clients) any privileged information available to you from your time in ministerial office. This is an ongoing duty irrespective of the time elapsed since you left office.

• Lobbying condition – For two years from your last day in office, you should not become personally involved in lobbying the UK Government or its arm’s length bodies on behalf of Boka Capital Ltd (including its related parties and clients); nor should you make use of any contacts in government, including ministers, to influence policy or secure business/funding or otherwise unfairly advantage Boka Capital Ltd (including its related parties and clients).

• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with Boka Capital Ltd (including related parties 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.

• Role restriction – For two years from your last day in office, you are prevented from advising Boka Capital Ltd (including related parties and clients) on matters in which you were materially involved during your time in office.

I would be grateful if you would note the following points:

• My advice is not an endorsement of the appointment.

• The advice relates solely to your previous role in government; it is 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. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with my advice.

• By ‘privileged information’, I mean official information to which you had access as a consequence of holding office and which is not publicly available. You are also reminded that you may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code or otherwise.

• As set out in the Rules, the lobbying restriction means that former ministers ‘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’.

As soon as you take up the appointment, or if it is announced that you will do so, you are obliged under the Rules to inform my secretariat who will then publish this letter. 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.

Yours sincerely,

Sir Laurie Magnus CBE Independent Adviser on Ministerial Standards

2. Annex – Material information and consideration of the risks

2.1 The role

You wish to take up a paid, part-time role as a Non-Executive Director with Boka Capital Ltd (Boka), a global investment firm focused on the defence, security and tech sectors.

You have confirmed that this is an internal advisory position and that you will not lobby or contact government. You said that as Non-Executive Director you will have oversight of the boards of companies invested in by Boka. These are likely to be defence, security or tech firms.

2.2 Dealings in office

You said that you neither met with Boka nor made any policy, regulatory, or commercial decisions specifically related to the company. You confirmed that you had no access to information that could unfairly advantage the company.

2.3 Departmental assessment

The Cabinet Office confirmed the details you provided and had no concerns with this appointment. It recommended the standard conditions.

2.4 My consideration of the risks

As you made no policy, regulatory or commercial decisions specific to Boka and as the Cabinet Office has no concerns over your access to privileged information related to Boka, the risks are limited.

As an investment firm, Boka may have an interest in government policy in the sectors it operates in. There is a risk you could be perceived to offer Boka and the companies it invests in unfair access to the government. This risk is limited as the proposed role is an internal position and you confirmed that the role will not involve contact with government. As such, I consider the risk related to lobbying to be appropriately mitigated by the standard lobbying condition.

There is a risk associated with the unknown nature of the companies invested in by Boka whose boards you will oversee on Boka’s behalf. The risk of real or perceived unfair advantage to these companies, and by extension to Boka, associated with your privileged information, access to government and any overlap between your responsibilities in office and the investee companies’ activities cannot be accurately assessed due to their unknown nature. I consider the risk to be appropriately mitigated by restricting the role to prevent you from advising on matters you were materially involved in during your time in office.