Decision

Advice letter: Tom Tugendhat, Advisor, Observer Research Foundation Middle East

Published 3 February 2026

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Tom Tugendhat, former Minister for Security, Home Office – Paid appointment as Advisor, Observer Research Foundation Middle East. 

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on joining the Observer Research Foundation Middle East as Advisor. 

The purpose of the Rules, as you will be aware, is to protect the integrity of government and to avoid any suspicion that those who have served in government might profit improperly from that experience or that an employer might gain unfair advantage through privileged access to government. To achieve these aims, I designate conditions that former ministers must follow.   The material information and my consideration are set out in the annex. In light of this, I consider the following conditions to be appropriate, recognising that it is your responsibility to ensure that these are demonstrably applied in practice:

• Privileged information condition – You should not draw on, disclose or use for the benefit of the Observer Research Foundation Middle East (including its related parties and clients) any privileged information available to you from your time in ministerial office. This is an ongoing duty irrespective of the time elapsed since you left office.
• Lobbying condition – For two years from your last day in office, you should not become personally involved in lobbying the UK Government or its arm’s length bodies on behalf of the Observer Research Foundation Middle East (including its related parties 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 the Observer Research Foundation Middle East (including its related parties and clients).
• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with the Observer Research Foundation Middle East (including its related parties 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.

I would be grateful if you would note the following points:

• My advice is not an endorsement of the appointment.
• The advice relates solely to your previous role in government; it is 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. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with my advice.
• By ‘privileged information’, I mean official information to which you had access as a consequence of holding office and which is not publicly available. You are also reminded that you may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code or otherwise.
• As set out in the Rules, the lobbying restriction means that former ministers ‘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’.

As soon as you take up the appointment, or if it is announced that you will do so, you are obliged under the Rules to inform my secretariat who will then publish this letter. 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.

Yours sincerely,

Sir Laurie Magnus CBE

Independent Adviser on Ministerial Standards

2. Annex – Material information and consideration of the risks 

2.1 The role

You wish to take up a paid, part-time role as Advisor with the Observer Research Foundation Middle East (ORF ME), a Dubai-based thinktank. ORF ME addresses policy challenges across the Middle East, the Indian sub-continent, Africa and these regions’ global partners, focusing on geopolitics, climate and energy transitions and emerging technology policy. ORF ME is affiliated with the Observer Research Foundation (ORF) in India and the Observer Research Foundation America. 

In your role as Advisor, you will: 

• attend in-person meetings, including the Raisina Dialogue and Raisina Middle East 
• join the High-Level Empowered Board on Green Transitions, alongside other members such as Indian politicians and thinktank representatives 
• contribute to broader discussions, policy essays and research. 

You confirmed you will not have contact with the UK Government in this role. 

2.2 Dealings in office

You said that, as a minister, you made no policy, regulatory or commercial decisions specific to, and had no access to information that could unfairly advantage ORF ME. 

2.3 Departmental assessment

The Home Office confirmed the details you provided and recommended the standard conditions.

2.4 My consideration of the risks 

In office, you made no policy, regulatory or commercial decisions specific to ORF ME, and the Home Office had no concerns over your access to privileged information – the risks here are therefore limited.

ORF ME’s primary interest will be government policy in the Middle East. However, it also aims to influence policy in the region’s global partners – which include the UK. Therefore, there is a risk you could be perceived to offer ORF ME and associated organisations unfair access to the UK Government, representatives of which may be present at events you attend, such as the Raisina Dialogue, which the UK Government has previously attended and supported. However, this risk is limited because:

• the role is focused on research and does not include lobbying 
• ORF ME’s influencing focus is outside of the UK 
• you have been clear there will be no contact with the UK Government in this role  
• contact with the UK Government at events is not contrary to the Rules – though it must not be of a nature that could reasonably be perceived as lobbying.

I also consider it of significant relevance that ORF ME has provided written confirmation of its agreement to comply with the advice and of the separation of your role from lobbying the UK Government.

In view of the above factors, I consider the risks related to this appointment to be appropriately mitigated by the standard conditions.