Decision

Advice: Lee Rowley, Chief Strategy Officer/Director, Public Sector & Government Practice, S&A Transform Group

Published 18 November 2025

1. BUSINESS APPOINTMENT APPLICATION: Lee Rowley, former Minister of State, Department for Levelling Up, Housing and Communities – Paid appointment as Chief Strategy Officer/Director, Public Sector & Government Practice, S&A Transform Group.

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on joining the S&A Transform Group as Chief Strategy Officer/Director of Public Sector & Government Practice.

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 the S&A Transform Group, 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 the S&A Transform Group (including related parties 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 of the S&A Transform Group (including related parties and clients).

• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with the S&A Transform Group (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 the S&A Transform Group (including related parties and clients) on matters in which you were materially involved, or where you had a relationship with the client(s) during your time in office.

• Engagement restriction – For two years from your last day in office, you should not initiate any engagement with the UK Government on behalf of the S&A Transform Group (including related parties and clients).

• 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 the S&A Transform Group (including related parties and clients).

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, full-time role as Chief Strategy Officer/Director of Public Sector & Government Practice with the S&A Transform Group (S&A Transform), a management consultancy offering services to private and public sector clients. The role involves strategy development and implementation, business growth and building the company’s public sector and government practice, which could include working on areas for which you were responsible in office. You stated S&A Transform does not, and has no plans to, engage in lobbying.

You confirmed that you will not lobby government. You stated that you will have contact with government but not your former department as part of S&A Transform client work.

2.2 Dealings in office

You said you did not meet with, nor make any policy, regulatory or commercial decisions specific to, S&A Transform. You stated that you met various management consultancies but had no access to information that could unfairly advantage the company.

2.3 Departmental assessment

Your former department, now the Ministry of Housing, Communities and Local Government (MHCLG), considered that the policy insight you may give S&A Transform offered no unfair advantage due to the change in government since you left office.

In addition to the standard conditions, MHCLG suggested that there should be a restriction on engagement, particularly should your client work cover areas for which you had responsibility as a minister.

2.4 My consideration of the risks

You made no policy, regulatory or commercial decisions specific to S&A Transform, and MHCLG has no concerns over your access to privileged information – this limits the risks.

Nevertheless, as the clients of S&A Transform are unknown, there is an inherent risk that your work could overlap with the responsibilities you had as minister. I have therefore applied a limitation to the role, preventing you from advising clients on matters in which you were materially involved during your time in office. You are not prevented from using publicly available information, or from applying general knowledge, skills, and experience gained from your professional background.

As a consultancy operating in both public and private sectors, S&A Transform and its clients will have an interest in government policy and in relationships with government. You have stated the role excludes lobbying, and I note your commitment not to contact your former department. However, you could reasonably be perceived to offer S&A Transform and its clients unfair access, especially as your role will be to lead its public sector and government practice, which involves developing new business opportunities and client relations. Where this work involves engagement, this could be construed as seeking to influence the UK government, particularly in relation to maintaining current, or securing future, contracts with it. In view of this perception risk, I have applied a condition preventing you from initiating any direct engagement with the UK Government on behalf of S&A Transform and its clients. Your proposed employer has provided written confirmation of its agreement to comply with the advice and the separation of your role from lobbying.

Your role involves developing S&A Transform’s business. There is a risk that you may leverage your network of contacts outside government to unfairly advantage the company. I have therefore applied a condition preventing you from lobbying external contacts acquired only as a result of your time in office to secure business.