Decision

Advice Letter: Stuart Skeates, Commission with the Government of Bahrain

Published 18 June 2025

1. BUSINESS APPOINTMENT APPLICATION: Lieutenant General Stuart Richard Skeates, CB, CBE, former Director General, Illegal Migration Operations Command and Senior Responsible Officer for the UK/Albania Migration Agreement, Migration and Borders Group at the Home Office. Paid commission with the Government of Bahrain under your independent consultancy - Barchester Skeates Associates Limited. 

You 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 a commission with the Government of Bahrain under your independent consultancy, Barchester Skeates Associates Limited.

The purpose of the Rules is to protect the integrity of the government. Under the Rules, the Committee’s remit is to consider the risks associated with the actions and decisions made during your time in government service, alongside the information and influence a former Crown servant may offer the Government of Bahrain. 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[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 risks presented 

The Committee[2] considered this commission to be broadly consistent with the description of your consultancy – providing generalist advisory work in the defence and security sector. You stated this proposed commission with the Government of Bahrain involves providing advice on Bahrain’s national security and border security.

There is no relationship between the Government of Bahrain and your former department and you did not meet with, nor were you involved in any decisions specific to, the Government of Bahrain whilst you were in government service. Therefore, the Committee considered the risk this commission could reasonably be perceived as a reward for decisions made in office is low.

By virtue of your roles in government, you would have had involvement in, and access to information on matters relating to national security matters - including international collaboration and cooperation. The risks are limited as there is no direct overlap with your responsibilities in government. Your former department, the Home Office, confirmed you were not involved in Bahraini security issues whilst you were in government and does not consider you possess any specific information or insight that could offer the Government of Bahrain an unfair advantage.

There is a risk that you might be seen to offer unfair access to, and influence within, government. You confirmed that your independent consultancy and work with clients excludes any dealings with the UK government, reducing the risk you could be perceived to be lobbying the UK government - which all former senior Crown servants are prevented from doing for two years after leaving government service.

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 contacts, information or influence gained from your time in government service to the unfair advantage of the Government of Bahrain under your independent consultancy, Barchester Skeates Associates Limited.

Taking into account these factors, in accordance with the government’s Business Appointment Rules, the Committee advises this commission with the Government of Bahrain, should be subject to the conditions below and similarly applied to your independent consultancy, Barchester Skeates Associates Limited:

• 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 Crown service;

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

• for two years from your last day in Crown service, you should not provide advice to or on behalf of the Government of Bahrain (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;

• for two years from your last day in Crown service, you should not become personally involved in lobbying contacts you developed during your time in office and in other governments and organisations for the purpose of securing business for the Government of Bahrain; and

• for two years from your last day in Crown service, before accepting any commissions for Barchester Skeates Associates Limited and or/before extending or otherwise changing the nature of your commissions, you should seek advice from the Committee. The Committee will decide whether each commission is consistent with the terms of the consultancy and consider any relevant factors under the Business Appointment Rules.

The advice and the conditions under the government’s Business Appointment Rules relate to an applicant’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 forbStandards and the Registrar of Lords’ Interests[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  ‘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 this work or if it is announced that you will do so. Similarly, you must inform us if you propose to extend or otherwise change your role with the organisation as depending on the circumstances, it might be necessary for you 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

You stated this is a commission under Barchester Skeates Associates Limited, which provides generalist advisory work in the defence and security sector. You stated you will be advising the Government of Bahrain on national security and border security advice and mentoring to senior government officials.

You stated it has been over three years since  you worked in defence. You have leadership experience from military operations and in joint operations with various coalitions - the US Marine Corps and NATO.  You also previously held the role of Commandant of the Royal Military Academy Sandhurst[4] and Deputy Commander of JFC Brunnsum[5]

5. Dealings in office

You advised the Committee that you did not meet with, nor were you involved in decisions, nor had access to sensitive information specific to the Government of Bahrain. 

6. Departmental assessment 

The Home Office stated that, in your role as Director General, Illegal Migration Operations Command (where you was also Senior Responsible Officer for the Sovereign Borders Programme; Senior Responsible Officer for the New Detained Accommodation Programme; and Senior Responsible Officer for the UK/Albania Migration Agreement), you were not involved in decisions nor possessed sensitive information that may provide an unfair advantage to the Government of Bahrain. 

The Home Office did not have concerns with the appointment provided it is subject to the standard conditions and a restriction on lobbying contacts gained in external governments and organisations for the purpose of securing business for the Government of Bahrain.

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[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; Isabel Doverty; Hedley Finn OBE; Dawid Konotey-Ahulu CBE DL; The Rt Hon Lord Pickles; Michael Prescott and Mike Weir. Sarah de Gay and Baroness Thornton were unavailable. 

[3] All Peers and Members of Parliament are prevented from paid lobbying under the House of

[4] https://www.gov.uk/government/people/stuart-skeates

[5] The Allied Joint Force Command (JFC) Brunssum is a NATO headquarters that includes the United Kingdom as a framework nation. The JFC Brunssum is responsible for planning, executing, and supporting military operations in its assigned area.