Decision

Advice: Lord Sharpe, Advisor, Vindo Technology Limited

Published 28 October 2025

The advice below was considered and provided by ACOBA before it closed on 12 October 2025, but taken up by the applicant on or after 13 October and therefore published after the ACOBA’s closure. The Independent Adviser has not had a role in this advice.

1. BUSINESS APPOINTMENT APPLICATION: Lord Andrew Sharpe of Epsom OBE, former Parliamentary Under Secretary of State at the Home Office. Paid appointment with Vindo Technology Limited.

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 Vindo Technology Limited (Vindo Technology) as an Advisor.

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 Vindo Technology, 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

Vindo Technology provides business development, brand, and customer service advice to technology companies looking to bring their technology to market. It works for private sector firms as well as the US, Five Eyes^{[footnote 1]} and NATO-member technology companies.^{[footnote 2]} It is expanding its business into the UK, particularly in defence and national security. You said that your role as an Advisor will involve providing advice on business strategy and business development.

Your former department, the Home Office, does not have a relationship with Vindo Technology, and you neither met with, nor made any decisions specific to the company while in office. The Committee^{[footnote 3]} therefore considered that the risk this role could reasonably be seen as a reward for decisions you made in office was low. 

As a minister, you were responsible for national security legislation, digital and technology, and data and identity, all of which overlap with Vindo Technology’s expertise. This broad overlap raises a risk that you may be seen to have had access to a wide range of information, some of which could potentially grant Vindo Technology or its clients an unfair advantage. The Home Office is not aware of any specific information you have access to that could benefit Vindo Technology, therefore the risk is broad rather than anything that directly overlaps with the company’s work.  Further, it has been over 14 months since you left office and last had access to any privileged information, limiting its relevance.

Your role as an Advisor will involve gaining clients for Vindo Technology. This raises risks associated with your privileged contacts and influence gained in ministerial office, particularly if it looks to gain contracts with government. If this is the case, you could be seen to offer unfair access to, and influence within, government, particularly as national security was an aspect that fell within your ministerial portfolio. Additionally, you may have developed contacts and external organisations or foreign governments that could be seen to be useful in securing business/clients for Vindo Technology. You said you will not have any contact with government in this role, and Vindo Technology has confirmed that you will not be involved in any lobbying of the government in keeping with the Rules.

It was also relevant to the Committee’s consideration that you had a career in investment banking before you entered government and you no doubt amassed a network of contacts during this time.

3. The Committee’s advice 

The main risk in this case is that you may be seen to provide Vindo Technology with unfair access to government as Vindo Technology expands its services within the UK. It is significant that Vindo Technology confirmed that your role would be separated from any work it may undertake with the government in the future, and confirmed its compliance with the advice in this letter. The Committee considered that the remaining risks can be appropriately mitigated by the conditions below, which seek to prevent you from making improper use of privileged access to information, contacts and your influence to the company’s unfair advantage. 

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

• for two years from your last day in ministerial office, you should not provide advice to or on behalf of Vindo Technology Limited (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; and

• 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 and in other governments and external organisations for the purpose of securing business for Vindo Technology Limited (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 4]} You are reminded that as a Member of the House of Lords you are prevented from any paid lobbying under the House of Lords Code of Conduct. 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, 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.

Once the appointment has been publicly announced or taken up, this advice letter will be published.

Isabel Doverty

Interim Chair

ACOBA

4. Annex - material information

4.1 The role 

Vindo Technology provides strategic advice and business development services to technology companies, helping companies to bring their technology to market. You said that its clients are either established overseas entities looking to break into the UK or small domestic start-ups. You said that Vindo Technology advises on the creation of the business structure based on how and when the principals wish to exit, the type of fund-raising rounds that will be required, who and where likely purchasers may be etc. Vindo Technology works for private sector tech firms, servicing companies such as DIAS (an engineering firm), Anomaly Six (a media intelligence firm) and Matroid (a computer tech company). It also works for the public sector, where it specialises in defence and national security, working for the US, Five Eyes^{[footnote 5]} and NATO-member technology companies,^{[footnote 6]} and is expanding into the UK in defence and national security. 

You told the Committee that your paid, part-time role as an Advisor would include:

• providing strategic advice to Vindo Technology on small/medium company management and routes to market (utilising your investment banking and finance network);
• making potential business client introductions to Vindo Technology;
• advising the company on their clients’ context, culture, structure and use cases – advising on the type of product or service – on how such products and services might be used to best effect. You gave the example of a drone manufacturer who has identified a military niche for their product, but may not have considered all other potential users and uses; and
• arranging international introductions for the company’s clients.

You said that the role would involve no contact with government, and will be internal to Vindo Technology – that you will not be advising any clients.

You have had a former career in the financial services industry, at Morgan Stanley, UBS, and Redburn Partners. 

4.2 Correspondence with Vindo Technology

Vindo Technology told the Committee the following:

• that it understands the necessity and is supportive of the conditions imposed in this advice;
• that your role will not involve any lobbying and will be separated from any government work it seeks to undertake, while you are subject to the Rules;
• that it will put in place all reasonable and appropriate measures to support you in adhering to the restrictions. This may include:
  • ethical walls
  • team briefings to ensure an understanding of the restrictions (subject to relevant confidentiality and data protection considerations), and 
  • managing the allocation of work with full regard to the restrictions.
• you will be actively encouraged to work with the Vindo Technology team in identifying any potential conflicts with these conditions so that these can be addressed and managed at the earliest opportunity.

4.3 Dealings in office 

Of your time in office, you said the following:

• you did not make any policy, commercial or regulatory decisions specific to Vindo Technology;
• you did not have any contact with Vindo Technology;
• there is no departmental relationship between Vindo Technology and the Home Office; and
• you did not have access to sensitive information in your ministerial role that could grant Vindo Technology an unfair advantage.

4.4 Departmental assessment 

The Home Office confirmed the details above. It recommended the standard conditions.

1. An intelligence alliance comprising Australia, Canada, New Zealand, the United Kingdom, and the United States, who are party to a multilateral agreement for joint cooperation in signals intelligence. ↩

2. Technology companies operating in defence such as BAE Systems and Airbus. ↩

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

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

5. The Five Eyes is an intelligence alliance comprising Australia, Canada, New Zealand, the United Kingdom, and the United States These countries are party to the multilateral UKUSA Agreement, a treaty for joint cooperation in signals intelligence. ↩

6. For example BAE Systems, Airbus and Leonardo. ↩