Advice: Rishi Sunak, Member of the Bloomberg New Economy Forum Advisory Board, Bloomberg
Published 16 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: The Rt Hon Rishi Sunak MP, former Prime Minister of the United Kingdom. Unpaid appointment with Bloomberg.
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 an appointment as a Member of the Bloomberg New Economy Forum Advisory Board at Bloomberg.
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 Bloomberg. 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
The Bloomberg New Economy Forum Advisory Board is a group of senior advisors, providing the Bloomberg New Economy leadership team with input and feedback on vision, strategy and content for the annual Forum.
When considering this application, the Committee[footnote 1] took into account this appointment as a Member of Bloomberg New Economy Forum Advisory Board is unpaid[footnote 2]. Generally, the Committee’s experience is that the risks related to unpaid roles are limited. The purpose of the Rules is to protect the integrity of the government by considering the real and perceived risks associated with former ministers joining outside organisations. Those risks include: using privileged access to contacts and information to the benefit of themselves or those they represent. The Rules also seek to mitigate the risks that individuals may make decisions, or take action in office, in expectation of rewards on leaving government. These risks are significantly limited in unpaid cases due to the lack of financial gain to the individual.
There is some overlap with the government and Bloomberg’s work. For example, The Cabinet Office subscribes to a contract for Bloomberg’s Financial and Economic Market Data and Analysis, and previously partnered on gender disparity reporting and COP26. During your time in office, you met with members of Bloomberg and its proprietor, Michael Bloomberg, on three occasions. You also attended roundtables and were engaged by media from competitor organisations as part of your duties as Prime Minister. You did not make regulatory or policy decisions specific to Bloomberg or as a result of any of these engagements. As the role is unpaid, the risk of reward is inherently low.
There are inherent risks with your general access to information, influence and contacts in office, given your former role as the Prime Minister. In this unpaid role, these risks are limited.
3. The Committee’s advice
The Committee does not consider taking up an unpaid role raises any particular concerns under the government’s Business Appointment Rules, provided it is subject to standard conditions which prevent improper use of information and influence.
It is an individual’s responsibility to manage the propriety of the specific pieces of work undertaken. In particular, as the former Prime Minister, you must be careful not to offer any unfair insight as a result of your access to information and potential influence in government - which the conditions below seek to mitigate.
Taking into account these factors, in accordance with the government’s Business Appointment Rules, the Committee advises this appointment with Bloomberg be subject to the following conditions:
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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;
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for two years from your last day in ministerial office, you should not become personally involved in lobbying the UK government or its arm’s length bodies on behalf of Bloomberg (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 Bloomberg (including parent companies, subsidiaries, partners and clients) and;
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for two years from your last day in ministerial office, you should not undertake any work with Bloomberg (including parent companies, subsidiaries, partners and clients) that involves providing advice 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 its arm’s length bodies.
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 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 or otherwise.
The Business Appointment Rules explain that the restriction on lobbying means that you ‘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 and we will publish this letter on our website. You must 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.
Isabel Doverty
Interim Chair
ACOBA
4. Annex - Material information
4.1 The role
Bloomberg is a private company that operates in the financial information, software, data, and media sectors. The company’s main business involves providing financial software and data to clients, primarily within the finance and capital markets industries. Its principal product is the Bloomberg Terminal, a computer system that delivers real-time market data, news, and analytics, which is used by many professionals in the financial sector. Alongside its data services, Bloomberg operates a large media division. This includes Bloomberg News, a global news agency, Bloomberg Television, a 24-hour news channel, and various digital platforms. Bloomberg New Economy is an annual conference with several hundred attendees to explore challenges to global prosperity with a focus on emerging economies and markets.
As a Member of the Bloomberg New Economy Forum Advisory Board, you will become a member alongside 20 other people. This is a specific group within Bloomberg. You will be required to attend two advisory board meetings per year (in person or virtual). You will be part of a group of senior advisors, providing the Bloomberg New Economy leadership team with input and feedback on vision, strategy and content for the annual Forum. The only other requirement is that you attend the New Economy Forum in person at least once over the next three years. You confirmed your role would not involve contact with the government.
4.2 Dealings in office
You said that you did not make any policy, regulatory or commercial decisions specific to Bloomberg, and that you did not have any access to information that could grant the organisation an unfair advantage. You also stated that there is no known relationship between Bloomberg and the Cabinet Office.
You stated that you met with Michael Bloomberg on three separate occasions during your time in office and that you also had contact with Bloomberg’s competitors. You also attended roundtables and were engaged by media from competitor organisations as part of your duties as Prime Minister.
4.3 Department Assessment
The Cabinet Office confirmed you did not make any policy, regulatory or commercial decisions specific to Bloomberg.
The Cabinet Office stated:
- it has a subscription contract worth £85,000-£120,000 for Bloomberg’s Financial and Economic Market Data and Analysis between 2024-2026.
- it has previously partnered with the company on gender disparity reporting and COP26.
- Michael Bloomberg is the UN Special Envoy on Climate Ambition and Solutions.
- you would have had a wide range of information with regard to financial data on the United Kingdom. However, the currency of this information is likely to have significantly diminished considering the change in economic outlook and the change in government since you left office over a year ago.
The Cabinet Office recommended the standard conditions be applied to this role.
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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. ↩
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By unpaid the Committee means that no remuneration of any kind is received for the role. Applicants must declare where it is agreed or anticipated they may receive remuneration or some other compensation at some stage in the future. ↩
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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. ↩