Decision

Advice Letter: Patrick Sanders, Member of the Malam Jabba International Advisory Board, Samsons Group

Published 21 May 2025

1. BUSINESS APPOINTMENT APPLICATION: General Sir Patrick, former Chief of the General Staff at the Ministry of Defence. Paid appointment with Samsons Group.

General Sir Patrick sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Crown Servants (the Rules) on his proposal to work with Samsons Group as a Member of the Malam Jabba International Advisory Board.

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 General Sir Patrick made during his time in office, alongside the information and influence he may offer Samsons Group. The material information taken into consideration by the Committee is set out in the annex.

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 Rules^{[footnote 1]} set out that Crown servants must abide by the Committee’s advice. It is an applicant’s personal responsibility to manage the propriety of any appointment. Former Crown servants 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 risk presented

There is no relationship between the MOD and Samsons Group. General Sir Patrick did not make any policy or regulatory decisions affecting the company. Therefore, the Committee^{[footnote 2]} considered the risk that he could be seen to have been offered this role as a reward for decisions made or actions taken in office is low.

There is no overlap with General Sir Patrick’s proposed role with Samsons Group and his responsibilities at the MOD, limiting the risks associated with his access to information. The MOD confirmed General Sir Patrick did not have access to privileged information that could offer Samsons Group an unfair advantage; further, it has now been ten months since he left his role as Chief of the General Staff at the MOD.

The MOD stated General Sir Patrick has contacts and influence at the highest levels of UK Defence though the Committee considered the risk he offers unfair access to or influence within the UK government/the MOD is limited.  There is no known overlap between Samsons Group and the UK government and General Sir Patrick confirmed he will have no contact with the UK government in this role.

The MOD acknowledged that General Sir Patrick has contacts and influence at the highest levels of international governments; adding that Samsons Group appears to be a prominent company in Pakistan, and General Sir Patrick has developed relationships with the top level of Pakistan’s Armed Forces by virtue of his role. There is a risk General Sir Patrick’s contacts and influence gained externally to government could be seen to offer an unfair advantage if used to secure future business for Samsons Group.

3. The Committee’s advice

The Committee determined the risks identified in this application can be appropriately mitigated by the conditions below. These make it clear General Sir Patrick cannot make use of his access to privileged information, contacts or influence gained from his time in Crown service to the unfair advantage of Samsons Group.

The Committee advises, under the Government’s Business Appointment Rules, that General Sir Patrick’s role with Samsons Group should be subject to the following conditions:

• he should not draw on (disclose or use for the benefit of himself or the persons or organisations to which this advice refers) any privileged information available to him from his time in Crown service;

• for two years from his last day in Crown service, he should not become personally involved in lobbying the UK government or any of its arm’s length bodies on behalf of Samsons Group (including parent companies, subsidiaries, partners and clients); nor should he make use, directly or indirectly, of his contacts in government and/or Crown service to influence policy, secure business/funding or otherwise unfairly advantage Samsons Group (including parent companies, subsidiaries, partners and clients);

• for two years from his last day in Crown service, he should not provide advice to Samsons Group (including parent companies, subsidiaries, partners and clients) on the terms of, or with regard to the subject matter of, a bid or contract with, or relating directly to the work of the UK government, the Ministry of Defence or its trading funds; and

• for two years from his last day in Crown service, he should not become personally involved in lobbying contacts he has developed during his time in office in external organisations (including other governments) for the purpose of securing business for Samsons Group (including parent companies, subsidiaries and partners).

The advice and the conditions under the government’s Business Appointment Rules relate to General Sir Patrick’s 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]}. 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’.

General Sir Patrick must inform us if and when he takes up employment with this organisation, or if it is announced that he will do so. He must also inform us if he proposes to extend or otherwise change the nature of his role as, depending on the circumstances, it may be necessary for him 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

General Sir Patrick wishes to take up a part-time, paid role with Samsons Group as a Member of the Malam Jabba International Advisory Board.  Samsons Group, headquartered in Lahore, Pakistan, is a conglomerate which operates across multiple industries; these include agriculture, hospitality and tourism, textiles, education and healthcare. Its website and LinkedIn profile states it is engaged in the fast-moving consumer goods sector (products that sell quickly and at relatively low cost), with an established distribution network in parts of Eastern Europe, South and West Africa, Central and South Asia and the Middle East.

Samsons Group invests in The Malam Jabba Ski Resort and aims to drive growth in the tourism industry. This resort was previously destroyed by Taliban militants in June 2008, reducing a large portion of the resort to ashes, including the hotel, several houses and the chairlift.

General Sir Patrick said that in his role as a Member of the Malam Jabba Advisory Board he will provide advice to help tell the resort’s story, shape future strategy and engage internationally to attract tourism and protect the natural beauty of Swat, the area it lies within. He said that his role will not have any contact with the UK government.

4.2 Dealings in office

General Sir Patrick advised the Committee he did not meet with Samsons Group whilst in office. He said he did not have involvement in any policy development or decisions that would have been specific to the company, and held no commercial or contractual responsibilities relating to it. He said he did not meet with competitors of the company, nor did he have access to sensitive information regarding these competitors.

4.3 Departmental assessment

The MOD confirmed the details General Sir Patrick provided and confirmed there is no known overlap with his responsibilities in office. He made no decisions in office specific to the company and he did not have access to privileged information that could offer Samsons Group an unfair advantage.

The MOD stated that General Sir Patrick will have contacts and influence at the highest levels of UK Defence and international governments; adding that  Samsons Group appears to be a prominent company in Pakistan, and General Sir Patrick has developed relationships with the top level of Pakistan’s Armed Forces by virtue of his role.

The MOD recommended standard conditions.

1. Which apply by virtue of the Civil Service Management Code, The Code of Conduct for Special Advisers, The King’s Regulations and the Diplomatic Service Code. ↩

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

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 Commissioners for Standards, in the case of MPs, or the Registrar of Lords’ Interests, in the case of peers. ↩