Decision

Advice letter: Tom Pursglove, commission with Serco Group PLC under Ascalane Partners Ltd

Updated 7 July 2026

1. BUSINESS APPOINTMENT APPLICATION: Tom Pursglove, former Minister of State for Legal Migration and the Border, Home Office – Paid commission with Serco Group PLC under the independent consultancy, Ascalane Partners 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 client commission with Serco Group PLC under the independent consultancy, Ascalane Partners Ltd (Ascalane). 

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, as applied to Ascalane, together with a role restriction specific to this commission with Serco Group PLC, 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 Serco Group PLC, including its related parties) 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 Serco Group PLC (including its related parties), 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 Serco Group PLC (including its related parties).
• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with Serco Group PLC (including its related parties) 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.
• Business development restriction – For two years from your last day in office, you should not become personally involved in lobbying contacts you acquired during your time in office in other governments and organisations for the purpose of securing business for Serco Group PLC (including its related parties). 
• Role restriction – For two years from your last day in office, you are prevented from advising Serco Group PLC (including its related parties and clients) on matters related to the UK immigration system and estate, including immigration accommodation contracts. 

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 governing the registration of consultant lobbyists, from the Code of Conduct and Rules of the House of Commons and from the House of Lords Code of Conduct. 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.
• By ‘related parties’, I mean any parent companies, subsidiaries, clients and/or other partners as may be relevant.
• 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 stated that this is a client commission under your independent consultancy, Ascalane Partners Ltd (Ascalane), which provides advice to clients across several areas, including UK public policy, regulatory developments and the broader political landscape, and on which the former Advisory Committee on Business Appointments (ACOBA) provided advice.

In this commission, you wish to advise Serco Group PLC (Serco), a British multinational defence, health, space, justice, migration, customer and transport services provider company, on matters including UK public policy, regulatory developments, the political landscape and international affairs. This is broadly consistent with the description that you provided to ACOBA of Ascalane’s work, except that the latter additionally includes prospecting for and securing new business.

You confirmed that, in this commission, you would not:

• engage in any work relating to Serco’s immigration system contracts with the Home Office 
• lobby or have any engagement with government ministers or officials on Serco’s behalf 
• disclose privileged information from your time in government
• seek to draw on your network of contacts in government
• have involvement with bids or contracts involving government.

2.2 Dealings in office

You said that, as Minister of State for Legal Migration and the Border, you made no policy, regulatory or commercial decisions specific to Serco but that you were involved in decisions which affected the wider immigration accommodation estate:  - the programme delivering the closure of 190 asylum hotels - the advancement of policy around large sites alternatives - increasing occupancy across the existing immigration estate, with a view to increase value for money and minimise the accommodation’s physical footprint.

You noted that Serco holds contracts with the Home Office and provides immigration accommodation on the Home Office’s behalf. You added that you met with Serco whilst in office, in relation to the immigration accommodation estate. 

You also said that, in a limited and broad sense, you had access to commercially sensitive information about competitors in the form of contract monitoring management data. This was largely related to immigration accommodation occupancy levels, value for money considerations, and asylum hotel closure arrangements. 

You added that Serco was awarded a disability assessment contract by the Department for Work and Pensions in September 2023, at which time you held office as the Minister for Disabled People, Health and Work in the department. You noted that you do not expect your role with Serco to include work in this area. 

2.3 Departmental assessment

The Home Office confirmed that, as a minister, you made no policy, regulatory, commercial or contractual decisions specific to Serco. The department noted that you had access to submissions and briefing material that affected the immigration services sector as a whole, including:  - Asylum Accommodation National Audit Office Report  - Scientific Age Assessment proof of concept briefing pack - Illegal Migration Act submissions  - submissions and decisions relating to immigration accommodation at the business case or policy approval stage, which followed competitive processes and without the ability to influence supplier choice - a review of commercial options and procurement process for a communications provider for organised immigration crime. 

The Home Office said that you met with Serco in office in the context of immigration accommodation site visits and general stakeholder and industry engagement, and that no decisions were made as a result of these meetings. 

The Home Office confirmed that it has a well‐established commercial relationship with Serco, which holds long-term and active contracts to deliver services across areas including asylum accommodation and immigration‐related operations. Additionally, the Home Office said that its engagement with Serco occurs through standard government-supplier channels, led by officials, and through established governance processes, with ministerial approval sought where required. The Home Office added that it follows a regulated and competitive process when contracting with third‑party suppliers, including Serco. While ministers approve business cases and contract awards, the procurement process is governed by strict regulations and ensures that ministers cannot influence the final outcome, supplier selection or pricing. 

The department considered you to have had access to commercially sensitive information relevant to the immigration services sector that could offer Serco an unfair advantage. Examples of your access to such information include high-level market intelligence, competitor pricing, performance and operational risks, unannounced operational proposals, and procurement strategies and decisions across the immigration accommodation sector. The Home Office said that, though a portion of this information will, by now, be in the public domain or may no longer be relevant, some may retain relevance to current market participants – particularly given Serco’s long-term contracts, the scale of its role in the immigration system and the concentrated market of the immigration services. 

The Home Office recommended a role restriction be applied to your role with Serco which prevents you from engaging in any work relevant to the immigration system, including immigration accommodation contracts and immigration estate services. 

2.4 My consideration of the risks 

The conditions applied to an independent consultancy role also apply to the client commissions under it. Commissions are then assessed separately to identify any new risks that were not apparent at the time the consultancy was considered and, where necessary, to advise additional conditions. 

As a Minister of State for Legal Migration and the Border, with responsibilities including the immigration system and immigration estate, you were involved in sector-wide decisions which could be seen broadly to benefit Serco. Therefore, I consider that there is a risk of a perception of reward for your decisions taken in office. However, this risk is limited because:  - you made no decisions specific to Serco – including decisions related to contracts - decisions you made would have impacted Serco both positively and negatively  - no new contracts were awarded to Serco during your most recent role in office  - the Home Office confirmed that, though ministers approve business cases and contract awards, procurement follows a regulated process which ensures ministers cannot influence the final outcome - you left office nearly 24 months ago, which places an appropriate separation between any decision-making that could be seen to broadly benefit Serco and your taking up of the role. 

I note that in September 2023, whilst you were Minister for Disabled People, Health and Work at the Department for Work and Pensions, Serco was awarded a contract with the department. I consider the risk of a perception of reward related to this decision in office to be significantly limited by this having taken place nearly three years ago, which places a separation longer than the maximum restriction under the Rules between any decision-making that could be seen to benefit Serco and your taking up the role.

I note that the commission will not involve securing business on Serco’s behalf. 

As a government services supplier that holds multiple contracts with the UK government, Serco has a clear commercial interest in government. There is, therefore, a risk that you could be perceived to offer Serco unfair access to government. However, this risk is limited because: 

• you have been clear the role will not include lobbying or any engagement with government on Serco’s behalf 
• you confirmed that the role will not involve any work relevant to Serco’s immigration accommodation contracts 
• your role is internal and separate from Serco’s commercial activities: you will advise Serco on public policy, the broader political and regulatory landscape and international affairs. 

I also consider it of significant relevance that Serco has provided written confirmation of its agreement to comply with the advice and the separation of your role from lobbying. 

There is a specific risk of unfair advantage associated with your access to commercially sensitive information related to the immigration services sector. It would be inappropriate for a former minister in possession of commercially sensitive information to take up, without restriction, a role involving advice to whom the information may be relevant. I consider restricting the role to prevent you from advising Serco on matters related to the UK immigration system and estate, including immigration accommodation contracts, to be the appropriate mitigation of this risk.

I therefore consider the risks related to this appointment are not sufficiently mitigated by the conditions applied to your Ascalane role alone, and advise that an additional role restriction should apply to this commission.