Decision

Advice letter: Paul Scully, Chairman, All Eat

Updated 23 April 2025

1. BUSINESS APPOINTMENT APPLICATION: Paul Scully, former Parliamentary Under Secretary of State (Minister for Technology and the Digital Economy). Paid appointment with All Eat. 

You approached the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointments Rules for Former Ministers (the Rules) seeking advice on taking up a paid role as the Chairman of All Eat.

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 made during your time in office, alongside the information and influence you may offer All Eat, as a former minister. 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 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 

As Minister for Technology and the Digital Economy, you were involved in regulatory decisions in the digital space, including The Digital Markets, Competition and Consumers Act. These matters affected all companies operating in digital markets and were not specific to All Eat. The Bill, which covered matters wider than just your portfolio, reaches much wider than the takeaway app delivery market. Therefore, the Committee^{[footnote 1]} considered the risk this role, with a company you had no dealings with in office, is limited. 

You were involved in policy matters that overlap with the work of this company - as it is an online/digital platform. The risks associated with your access to information are limited because: 

• your policy involvement was broad and affected the digital sector as a whole, and was not specific to All Eat; 

• the relevant department - the Department for Science, Innovation and Technology (DSIT) said that whilst you had access to information relating to the technology sector, nothing significant remains that could provide an unfair advantage - as it is either now in the public domain, or has significantly moved on since you were in office - noting you have been out of office for over 11 months. 

As a former minister, your contacts and influence across government could offer All Eat an unfair advantage, particularly if it seeks to influence future policy on digital regulation or the gig economy. 

3. The Committee’s advice 

While there is a broad overlap with your responsibilities as a minister, the Committee agreed with the department that the risks associated are limited for the reasons set out above. The Committee considered conditions below are sufficient to mitigate the risks related to this role. These seek to prevent you from making use of privileged information, contacts and/or influence gained from your time in ministerial office to the unfair advantage of All Eat. 

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

• for two years from your last day in ministerial office, you should not provide advice to on behalf of All Eat (including parent companies, subsidiaries, partners and clients) 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 any of 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 2]} 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.” 

You must inform us as soon as you take up employment with this organisation(s), or if it is announced that you will do so. Please 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. 

4. Annex- material information 

4.1 The role 

You said that All Eat is a technology platform/app for takeaway restaurants and grocery supplies. Its focus is on a ‘lifetime 0% commission policy to ‘make UK restaurants grow and prosper together without having negative impact on the environment. It’s all about doing business for a good cause’. 

You wish to take up a paid, part-time role as Chairman of All Eat. You said that your role will include no contact with government and your responsibilities will include: 

• chairing four to six board meetings a year with ad-hoc duties 

• leadership and governance – providing leadership to the board of directors, ensuring effective governance and adherence to regulatory requirements 

• strategy and development – working with the board and senior management team to develop and approve the company’s strategic objectives and plans 

• risk management – ensuring the company has appropriate risk management strategies in place 

• stakeholder communication – acting as a key representative of the company, including some communication with stakeholders, regulators and investors 

• performance oversight – monitoring the company’s financial performance and ensuring it meets targets and remains profitable 

• relationship building– building and maintaining relationships with key clients, insurers and other industry players 

• compliance – ensuring the company operates within the legal and regulatory framework, and that internal controls are effective 

• succession planning– planning for the succession of key leadership roles within the company 

• business development- managing and mentoring staff within the company & marketing the product to restaurant owners and customers 

4.2 Dealings in office 

You said that you did not make any policy, regulatory or commercial decisions specific to All Eat, nor did you meet with the company whilst in office. You said that you met with some competitors of All Eat, to discuss the gig economy in light of the Covid pandemic, at the time. 

4.3 Departmental assessment 

DSIT said that you did not make any policy, regulatory or commercial decisions that would have affected All Eat specifically. You did make decisions affecting the tech sector as a whole: 

• Department for Media, Culture and Sport splitting from DSIT (in February 2023) you were involved in decisions related to the Digital Growth Grant3; 

• The Digital Markets, Competition and Consumers Act4 potentially has an impact on All Eat in regards to fair competition and the regulation of apps. 

DSIT said that your access to information is limited because matters have since moved on, or are in the public domain. 

DSIT recommended the standard conditions.

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

2. 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 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.  ↩