Decision

Advice letter: Tom Tugendhat, Advisor, Brox.ai

Updated 23 February 2026

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 Tom Tugendhat MBE VR MP, former Minister for Security at the Home Office. Paid appointment with Brox.ai.

You sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Ministers (the Rules) on taking up an appointment with Brox.ai (Brox) 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 Brox as a former minister. 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 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

You did not meet with Brox, nor did you make any decisions specific to the company whilst in office. Therefore, the Committee^{[footnote 1]} considered the risk that this appointment could reasonably be perceived as a reward for decisions or actions taken in office is low.

As a former minister, there are risks associated with your access to privileged information within government – as the areas within your purview use AI tools extensively, you may be seen to have information on AI policy and regulation that could benefit Brox. This is limited by the fact that the Home Office said you did not have access to any privileged information which may unfairly advantage Brox, and by the period of 14 months since you left office, which reduces the currency of any information you hold.

There is a risk associated with your contacts and influence in government and the potential for Brox to gain unfair access or influence as a result. This includes drawing on any contacts you may have gained while in office, in external organisations, for the purposes of assisting Brox with its business development. It is significant that you said that your role will not involve contact with the UK government.

3. The Committee’s advice

The Committee did not consider this appointment to raise any particular propriety concerns. It considered that the risks associated with this application can be appropriately mitigated by the conditions below. These seek to prevent you from drawing on privileged access to information, contacts and influence to unfairly advantage Brox.

In accordance with the government’s Business Appointment Rules, the Committee advises that this appointment with Brox.ai 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 service;

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

• for two years from your last day in ministerial office, you should not provide advice to Brox.ai (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 and 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 in other governments and organisations for the purpose of securing business for Brox.ai.

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 2]} You are reminded that as a Member of Parliament you have a separate ban on paid lobbying under the Parliamentary 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 this employment, or if it is announced that you will do so. You must 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, we will publish this letter on the Committee’s website, and where appropriate, refer to it in the relevant annual report.

Isabel Doverty

Interim Chair

ACOBA

4. Annex – Material Information

4.1 The role

Brox is an AI-powered insights platform that provides businesses with real-time consumer data. It functions as a market research tool, offering features like brand tracking, audience segmentation, and competitor analysis. Brox essentially creates “digital twins” of consumers, allowing businesses to test ideas and get insights at a faster rate than traditional non-AI methods. These digital twins are behavioural replicas that predict actual human decisions with validated accuracy. In aggregate, it creates a parallel universe where clients can run unlimited experiments, ask questions, test ideas, without the risk, cost, or time of traditional research. It operates in the US, UK, Japan and Turkey, and is launching in the Middle East and APAC. It lists Google, Amazon, Sony and YouTube among its clients.

You seek to take up a paid, part-time role as an Advisor. You said that it would involve advising on possible areas for improvement and business expansion, and would not involve contact with government.

4.2 Dealings in office

Of your time in office, you said the following:

• you did not make any policy, commercial or regulatory decisions specific to Brox in your role as Minister of State for Security at the Home Office;
• you had no contact with Brox;
• Brox has no relationship with the Home Office; and
• you did not have access to sensitive information through any of your ministerial roles that could grant Brox or its clients an unfair advantage.

4.3 Departmental assessment

The Home Office confirmed the details in your application as set out above. It recommended the standard conditions.

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

2. 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. ↩