Decision

Advice Letter: Gaven Smith, Technology and Security Advisor, Sayari Analytics, LLC

Updated 9 April 2025

1. BUSINESS APPOINTMENT APPLICATION: Gaven Smith CB FReng, former Director General of Technology at the Government Communications Headquarters. Paid appointment with Sayari Analytics, LLC. 

Mr Smith 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 taking up an appointment with Sayari as a Technology and Security 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 made during Mr Smith’s time in office, alongside the information and influence he may offer Sayari. 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

Sayari is a technology company specialising in supply chain risk intelligence and global corporate transparency. Mr Smith did not make any policy, regulatory or commercial decisions specific to Sayari, nor did he meet with the company whilst in office. The Government Communications Headquarters (GCHQ) confirmed it does not hold a relationship with Sayari, commercial or otherwise. Therefore, the Committee^{[footnote 2]} did not consider this role could reasonably be perceived as a reward for decisions made or actions taken in office.

As the former Director General Technology at GCHQ, Mr Smith would have had access to a range of sensitive information, including that which relates to risk intelligence and other areas in which Sayari operates. GCHQ confirmed it was not concerned about any specific access to information Mr Smith had that could offer an unfair advantage to the company. Further it is significant that Mr Smith has been out of office for over 12 months which puts a considerable gap between his last having had access to information and taking up this role; and he has over 30 years of experience in the technology sector. 

There remains a risk regarding his access to information, which is most likely to arise should he advise Sayari on the UK intelligence agencies and/or matters he had specific responsibility for in his most recent role at GCHQ. Sayari’s clients and the precise advice he will be asked to provide are unknown. Whilst this role is not client facing, there remains a limited risk this overlap may occur. 

There are risks associated with Mr Smith’s contacts and influence within government and the potential for Sayari to gain unfair access or influence as a result. He confirmed his role as Technology and Security Advisor excludes any dealings with government, reducing the risk he could be perceived to be lobbying government - which all former senior Crown servants are prevented from doing for two years after leaving office.

3. The Committee’s advice

While the Committee recognised the opportunity to offer an unfair advantage is limited given the views from GCHQ, it is difficult to demonstrate this where Mr Smith advises Sayari on matters directly overlapping with the UK national security and intelligence communities. The Committee has therefore imposed a ban on him advising Sayari on matters relating to UK security or intelligence agencies.

The Committee determined the remaining risks identified in this application can be appropriately mitigated by the conditions below. These make it clear Mr Smith must not make use of information or influence gained from his time in Crown service to the unfair advantage of Sayari. 

The Committee advises, under the government’s Business Appointment Rules, that Mr Smith’s appointment with Sayari Analytics, LLC 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 government or any of its arm’s length bodies on behalf of Sayari Analytics, LLC (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 Sayari Analytics, LLC (including parent companies, subsidiaries, partners and clients);

• for two years from his last day in Crown service, he should not provide advice to Sayari Analytics, LLC (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 or its arm’s length bodies; and

• for two years since his last day in office, he should not advise Sayari Analytics, LLC and/or its clients on any matters relating to the UK security or intelligence agencies.

The advice and the conditions under the government’s Business Appointment Rules relate to Mr Smith’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 Ministerial Code/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.”

Mr Smith must inform us as soon as he takes up this work or if it is announced that he will do so. Similarly, he must inform us if he proposes to extend or otherwise change his role with the organisation as depending on the circumstances, it might be necessary for him to seek fresh advice. 

Once this appointment has been publicly announced or taken up, we will publish this letter on the Committee’s website.

4. Annex - Material Information

4.1 The role 

According to its website, Sayari provides global corporate transparency and supply chain risk identification for government and industry – its clients and partners include top financial institutions, Fortune 100 corporations and government agencies. Mr Smith described Sayari as a “supply chain risk intelligence provider that supports transparency around the relationships between businesses and individuals”.

In his paid, part-time role as Technology and Security Advisor, Mr Smith stated his role entails:

• Strategic advisor to senior teams
• Technology and business strategy formulation
• Technical support to implementation and delivery
• Executive leadership support, leadership development and advice.

Mr Smith confirmed his role does not involve contact with the UK government. 

4.2 Dealings in office

Mr Smith advised the Committee he did not meet with Sayari while in service. He was not involved in any commercial or contractual decisions relating to Sayari He also told the Committee he did not have any involvement in any relevant policy development or decisions that would have affected Sayari and did not meet with its competitors; nor did he have access to sensitive information specific to the company. 

Mr Smith said that as Director General Technology at GCHQ, he was responsible for very little technology policy. That is because policy is either owned by the operational policy team in GCHQ or by other departments in government e.g. DSIT, and ultimately set by the Council for Science and Technology^{[footnote 4]}. Mr Smith said his role in office was heavily leadership and delivery focused – being responsible for GCHQ’s technical capability that enables it to deliver its mission and for driving the innovation to meet future technological challenges – rather than policy based.

4.3 Departmental assessment

GCHQ confirmed the details ias provided by Mr Smith and stated: 

• he was not involved in decisions specific to, nor did he meet with Sayari; and
• it did not consider him to possess any sensitive information that may provide Sayari an unfair advantage. 

GCHQ recommended the 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; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CB DL; The Rt Hon Lord Eric Pickles; The Baroness Thornton; Michael Prescott; and Mike Weir. Isabel Doverty was unavailable. ↩

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. ↩

4. https://www.gov.uk/government/groups/national-security-council ↩