Decision

Advice Letter: Stuart Skeates, commission with UK Defence Academy via King's College London

Updated 30 September 2025

1. 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 King’s College London to work with  the Defence Academy of the United Kingdom -  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 King’s College London, University of London (KCL), under your independent consultancy, Barchester Skeates Associates Limited. This proposed commission involves you being a Senior Mentor, as part of the Senior Military Mentor Programme of the Defence Academy of the United Kingdom (Defence Academy). 

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 taken during your time in government service, alongside the information and influence a former Crown servant may offer KCL and the Defence Academy. 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 risks presented

The Defence Academy is part of the UK Ministry of Defence (MOD) and delivers world-class professional defence and security education to students from the British Armed Forces, the Civil Service, industry and overseas. The Senior Military Mentor Programme provides British Armed Forces personnel with a personal mentor to offer support, advice, and constructive challenge – you propose to become a Senior Mentor. The Committee^{[footnote 2]} considered this commission to be broadly consistent with the description of your consultancy – providing generalist advisory work in the defence and security sector. 

KCL has a formal relationship with the Home Office, primarily concerning immigration and student visas. The Home Office has also worked with KCL for research;  the university has received grants from the Home Office; and  KCL has a contract with the MOD to provide  education at the Defence Academy. You did not meet with, nor were you involved in any decisions specific to KCL/the Defence Academy, whilst you were in government service. Therefore, the Committee considered the risk this work could reasonably be perceived as a reward for decisions made in office is low. 

Your role at the Home Office was focussed on UK border security, national security and international cooperation surrounding the subject matter – not broader defence. The Home Office does not consider you possess any specific information or insight that could offer KCL an unfair advantage. Further, you have experience, from prior to your recent roles at the Home Office, in leadership and command on military operations and joint operations with NATO and other allied militaries.

Given the nature of your proposed role and the pre-existing framework between KCL and the Defence Academy, it is unlikely that you will be seen to draw on your network of contacts gained in government service to KCL’s unfair advantage. Though you will have contact with the British Armed Forces, you said that in line with the expectation in the Rules, you will not be involved in any lobbying or further government contact with the MOD or its arm’s length bodies.

The Committee also took into account that it has been over three years since you worked in a broader defence role within government - where you gained extensive experience in leadership and command on military operations and joint operations with NATO and other allied militaries.

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 KCL under your independent consultancy, Barchester Skeates Associates Limited. In coming to this view, the Committee considered it significant that this advice only provides approval to work in the limited capacity described here, as a Senior Mentor with the Defence Academy, and with no responsibilities or work with KCL beyond that.

Taking into account these factors, in accordance with the government’s Business Appointment Rules, the Committee advises this commission with The Defence Academy of the United Kingdom via King’s College London, University of London, should be subject to the same conditions as your independent consultancy, Barchester Skeates Associates Limited: 

• you must not draw on (disclose or use for the benefit of yourself or King’s College London, University of London) any privileged information available to you from your time in Crown service or any ongoing contact with the UK government; 

• 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 King’s College London, University of London (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 King’s College London, University of London (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 King’s College London, University of London (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 King’s College London, University of London; 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 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 ‘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 work

You stated this is a commission under Barchester Skeates Associates Limited, which provides generalist advisory work in the defence and security sector. You confirmed that work taken up under your consultancy will not involve contact with, or lobbying of, the UK government. 

The Defence Academy delivers world-class professional defence and security education to students from the UK Armed Forces, Civil Service, industry and overseas. It is part of the Ministry of Defence. 

KCL is a public research university. KCL has a formal relationship with the Home Office, primarily concerning immigration and student visas. KCL is a licensed sponsor under the Home Office’s points-based immigration system, meaning they can sponsor international students and employees to come to the UK. This sponsorship comes with responsibilities for KCL to ensure compliance with Home Office regulations related to visas and immigration. The Home Office added that it has worked with KCL for research and provided a small amount of grants to the university.

KCL has a long-standing and multifaceted relationship with the MOD, particularly through its Defence Studies Department. This partnership focuses on research, education, and professional development for military and national security personnel. KCL is a key partner in delivering education at the Defence Academy of the UK, including the Joint Services Command and Staff Course and the Royal College of Defence Studies. KCL has a contractual agreement with the MOD to support the provision of education at the Defence Academy, specifically within UK Strategic Command.

The Senior Military Mentor Programme at the Defence Academy is a framework designed to provide personnel with a personal mentor to offer support, advice, and constructive challenge. The programme is independent of the Chain of Command and aims to enhance leadership skills and promote a mentoring culture within the military.

You stated that your role as Senior Mentor at the Defence Academy does not involve dealing directly with representatives of KCL but only with MOD personnel who are responsible for the Defence Academy Senior Mentors Programme. You stated that as the prime academic contractor for the Defence Academy, KCL is responsible for the funding of the programme. As a Senior Mentor, your role is to mentor and support members of the UK Armed Forces and Allied Armed Forces who are attending career courses.

You stated the contract is provided by KCL – which is a means of paying you.

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^{[footnote 4]} and Deputy Commander of JFC Brunssum^{[footnote 5]}.

4.2 Dealings in office

You advised the Committee that you did not meet with, nor were you involved in, decisions specific to the Defence Academy or KCL, nor did you have access to sensitive information that could provide an unfair advantage to either organisation. 

4.3 Departmental assessment 

The Home Office stated that it does have a relationship with KCL – that the university has received a small amount of grants and has been utilised for research. However, this was not for areas that you would have been involved with.

The Home Office stated that in your role as Director General, Illegal Migration Operations Command (where you were 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 did you possess sensitive information that may provide an unfair advantage to the Defence Academy, nor KCL. 

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 KCL. 

As the work of your consultancy raises risks around unknown clients, the Home Office also recommended a limitation on your role to prevent you from working on matters or with clients that you had direct involvement with in office. In this instance, as the end client was known - the Defence Academy - the Committee determined a limitation was not needed for this appointment.

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 Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE DL; Michael Prescott; and The Baroness Thornton. ↩

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 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. 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. ↩