Decision

Advice Letter: Grant Shapps, Member of the Strategic Intelligence Council, 9Yards Capital

Updated 16 September 2025

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Sir Grant Shapps, former Secretary of State for Defence. Paid Appointment with 9Yards Capital.

You approached the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Ministers (the Rules) seeking advice on taking up a paid appointment with 9Yards Capital as Member of the Strategic Intelligence Council.

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 taken during your time in office, alongside the information and influence you may offer 9Yards Capital as a former minister. The material information taken into consideration by the Committee is set out in the annex below.

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

9Yards Capital is a technology investment firm that invests in venture capital and growth-stage capital. It specialises in diversified software, cyber/defence technology, fintech, insurtech and supply chain tech. As a Member of the Strategic Intelligence Council, your role would be to act as an independent, non-executive consultant, providing occasional high-level strategic advice on market conditions, governance and organisational development. 

You did not meet with, nor did you make any policy, regulatory or commercial decisions specific to 9Yards Capital. Therefore, the Committee^{[footnote 1]} considered the risk that this role could reasonably be seen as a reward for decisions made in office was low.

As the former Secretary of State for Defence and previously Secretary of State for Energy Security and Net Zero, you would have had access to a wide range of sensitive information. There is a broad overlap here, given 9Yards Capital invests in a variety of companies, including those which operate within the defence, environmental and energy technology sectors. There are mitigating factors:

• The risk is broad rather than specific to this company and its investment portfolio.

• The Department for Energy Security and Net Zero (DESNZ) considered that the information, which you last had access to two years ago within the department, would no longer be sufficiently up to date to offer unfair insight.

• This MOD considered this risk was limited, given the passage of time.

There is a risk that remains in relation to your general access to information, particularly given the MOD previously informed ACOBA you had insight into potential new defence technology that would require investment to scale.

There are also risks associated with your influence and network of contacts gained whilst in office – both internally to government, and within other governments and industry. In particular, the Committee considered the risks associated with a network you might be seen to make unfair use of for investment purposes and/or facilitating the scaling of companies in which 9Yards Capital invests. You confirmed that your work with 9Yards Capital excludes any lobbying of the UK government – which all former ministers are prevented from doing for two years under the government’s Rules. 

3. The Committee’s advice 

The main risk in this case is associated with the potential overlap between your work at 9Yards Capital and the information you had access to at the MOD. In order to mitigate the risks associated with specific privileged information that could be relevant from your time in office, the Committee has imposed an additional condition which prevents you from advising 9Yards Capital on defence technology you had privileged insight into.

The Committee considered that the remaining risks associated with this application can be appropriately mitigated by the conditions below. These make it clear that you must not make use of your access to privileged information, contacts or influence gained from your time in ministerial office to the unfair benefit of 9Yards Capital.

In accordance with the government’s Business Appointment Rules, the Committee advises that this appointment with 9Yards Capital 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 service;

• for two years from your last day in ministerial office, you should not become personally involved in lobbying government or any of its arm’s length bodies on behalf of 9Yards Capital (including parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in government and/or Crown service to influence policy, secure business/funding or otherwise unfairly advantage 9Yards Capital (including parent companies, subsidiaries, partners and clients); 

• for two years from your last day in ministerial office, you should not provide advice to 9Yards Capital (including parent companies, subsidiaries or partners) 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, NATO allied militaries, the MOD and its trading funds, or their arm’s length bodies; 

• for two years since your last day in office, you should not advise 9Yards Capital (including parent companies, subsidiaries, partners, investees, and clients) on specific defence technology trials that you were involved in or had sight of during your time as Secretary of State for Defence; and

• for two years from your last day in ministerial office, you should not become personally involved in lobbying contacts you have developed during your time in office and in other governments and external organisations for the purpose of securing business/investment for 9Yards Capital (including parent companies, subsidiaries and partners).

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 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, or if it is announced that you will do so. 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.

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

9Yards Capital is a technology investment firm based in New York, with offices in Los Angeles and London. It invests in venture capital (financing for startup companies and small businesses with long-term growth potential) and growth-stage capital (companies with established revenue streams looking to scale their operations and achieve rapid growth. It specialises in diversified software, cyber/defence technology, fintech, insurtech and supply chain tech. The company has invested in companies across various sectors that hold contracts with government. 

As a Member of the Strategic Intelligence Council, you said your role would be to:

• act as an independent, non-executive consultant, providing occasional high-level strategic advice on market conditions, governance and organisational development; and

• that the work will be confined to private written, virtual or in-person briefings with no managerial authority, therefore largely being an internally-facing role. 

You confirmed that you would have no contact with, or lobby, government. You also said that you will not draw on any privileged information from your time in office for the purposes of this role. 

4.2 Dealings in office

You said you had no involvement in policy, contractual and/or commercial decisions specific to 9Yards Capital. You also said that you did not have official dealings/ contact with 9Yards Capital during your time in office and that the MOD does not have a relationship with the company. 

4.3 Departmental Assessment 

Both the MOD and DESNZ were consulted on this appointment.

The MOD provided the following information:

• you did not make any significant decisions specific to 9Yards Capital;

• you did not have any contact with 9Yards Capital or any competitors, but the department does have a relationship with Anduril – a company that is part of 9Yards Capital’s investment portfolio, which you did not make any decisions in relation to; 

• in light of your seniority and interactions with suppliers, you did have access to privileged information that could provide insight on relevant policy and capability areas  which could be beneficial to 9Yards Capital, but the department noted nothing specific in this respect.  Previously, the MOD told the Committee that you had access to privileged information regarding a trial of potential new defence technology that would require investment to scale. 

The MOD recommended the standard conditions, alongside a limitation to the role to avoid any overlap with your time in office.

DESNZ provided the following information: 

• you did not make any decisions specific and/or relevant to 9Yards Capital; 

• you did not have any contact with 9Yards Capital or any competitors, but the department does have a relationship with Sylvera –  a company that is part of 9Yards Capital’s investment portfolio and began after you left office; 

• you may have had access to privileged information regarding government policy that could provide an unfair insight to 9Yards Capital and/or its investees and that this could also be the case for other companies within 9Yards Capital’s investment portfolio, but the risk is limited and would not amount to an unfair advantage – given the time elapsed since you left office and the subsequent changes in government; and 

DESNZ recommended the standard conditions.

1. This application for advice was considered by Isabel Doverty, Sarah de Gay; Hedley Finn OBE; Dawid Konotey-Ahulu CBE DL; Michael Prescott; and The Baroness Thornton. ↩

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. ↩