Decision

Advice letter: Paul Scully, Chairman of the Advisory Board, OM Group

Updated 23 April 2025

1. BUSINESS APPOINTMENT APPLICATION: Paul Scully, former Parliamentary Under Secretary of State (Minister for Technology and the Digital Economy) at the Department for Science, Innovation and Technology.  Paid appointment with The OM Group Corporation Limited. 

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 a Chairman of the Advisory Board with The OM Group Corporation Limited (OM Group). 

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 the OM Group, 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

In your recent ministerial role, you did not meet with the OM Group, nor did you make any decisions that were specific to the company. The Committee^{[footnote 1]} considered the risk that you were offered this role as a reward for decisions or actions taken in post was low.

As a former minister, there are inherent risks associated with your general access to privileged information, contacts, and influence within government. The risks are limited given there is no direct overlap between your responsibilities in government and your proposed role. 

The unknown nature of the OM Group’s clients means that it is difficult to determine the precise work you will undertake. As a former minister, you were likely privy to a breadth of information and may have stepped into some issues in depth. Therefore, there is a risk you may be asked to advise on matters that have overlap with your responsibilities in office, or with companies you had specific involvement with in office. This could raise real and perceived risks of you offering an unfair advantage to the OM Group.

You informed the Committee that your role will focus on business development. This raises a potential risk that you could offer an unfair advantage to the OM Group by drawing on your contacts outside of government that you may have gained in your ministerial role. 

3. The Committee’s advice

The Committee determined the risks identified can be appropriately mitigated by the conditions below. These make it clear that you cannot make use of privileged information, contacts or influence gained from your time in ministerial service to the unfair advantage of the OM Group. To mitigate the risk associated with unknown clients, the Committee has imposed a restriction to prevent you from advising on work specifically overlapping with your recent ministerial role.

Taking into account these factors, in accordance with the government’s Business Appointment Rules, the Committee advises this appointment with The OM Group Corporation Limited 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 its arm’s length bodies  on behalf of The OM Group Corporation Limited (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 The OM Group Corporation Limited (including parent companies, subsidiaries, partners and clients); 

• for two years from your last day in ministerial office you should not undertake any work with The OM Group Corporation Limited (including parent companies, subsidiaries, partners 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;

• for two years from your last day in ministerial office, you should not become personally involved in lobbying contacts you developed during your time in office in external governments and organisations for the purpose of securing business for The OM Group Corporation Limited; and

• for two years from your last day in Crown service, you should not advise The OM Group Corporation Limited or its clients on any work with regard to any policy which you had a material role in developing or determining as Minister for Technology and the Digital Economy or where you had a relationship with the company or organisation during your time in this role.

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 Ministerial Code or otherwise.

The Business Appointment Rules explain that the restriction on lobbying means that you “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, or if it is announced that you will do so. Please 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

According to its website, the OM Group is a multidisciplinary consultancy and training company serving the construction industry, including building, safety, leadership and development training. It was established to provide multi-disciplinary consultancy services and training solutions to clients in the construction sector.

In your (paid) role as Chairman of the Advisory Board, you stated you will chair four to six board meetings a year with ad-hoc duties as required, and your responsibilities will be as follows:

• Leadership & Governance – providing leadership to the company, ensuring effective governance and adherence to regulatory requirements.
• Strategy & Development – working with the 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

You stated that your contract of employment will specifically reference  adherence to the Rules and confirmed your role will not involve contact with, or lobbying of government. 

You stated that you were approached directly by the CEO for this role.

4.2 Dealings in office

You stated that you met the CEO of the OM Group at an event at Aston University in Dec 20201, where you both spoke at the Centre for Ethnic Minority Research Entrepreneurship Event. 

During your time at the Department for Science, Innovation and Technology (DSIT), you stated that you did not meet with, nor were you involved in policy, commercial or regulatory decisions specific to the OM Group, nor do you possess sensitive information specific to the company. 

4.3 Departmental assessment 

DSIT confirmed the details you provided, stating:

• you were not involved in decisions specific to the OM Group;
• you did not meet with the OM Group whilst in office, nor does the department hold a relationship with the company;
• it does not consider you to possess sensitive information specific to the OM Group which may confer an unfair advantage.

DSIT did not have concerns with the appointment and recommended the standard conditions.

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

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. ↩