Decision

Advice letter: Tom Tugendhat, Member of the Leadership Council, Fortify Rights

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. Unpaid appointment with Fortify Rights.

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 unpaid role as a Member of the Leadership Council at Fortify Rights.

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 made during your time in office, alongside the information and influence you may offer Fortify Rights. 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

When considering this application, the Committee^{[footnote 1]} took into account that this appointment as a Member of the Leadership Council at Fortify Rights 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 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 no direct overlap between your ministerial responsibilities and your role with Fortify Rights as a Member of the Leadership Council. There remain inherent risks associated with any former minister’s access to information, network of contacts and influence in government.

3. The Committee’s advice

The Committee did not consider this unpaid appointment to raise any particular concerns under the government’s Business Appointment Rules. The standard conditions below sufficiently mitigate the inherent risks. These seek to prevent you from making improper use of privileged information, contacts and influence to the unfair advantage of the organisation.

In accordance with the government’s Business Appointment Rules, the Committee advises this appointment with Fortify Rights 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 office;

• 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 Fortify Rights (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 to influence policy, secure business/funding or otherwise unfairly advantage Fortify Rights (including parent companies, subsidiaries, partners and clients); and

• for two years from your last day in ministerial office you should not undertake any work with Fortify Rights (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 the advice letter will be published. You must also seek advice if you propose to extend or otherwise change the nature of your role.

Isabel Doverty Interim Chair ACOBA

4. Annex – Material Information

4.1 The role

Fortify Rights is a human rights campaigning organisation registered in the US and in Switzerland. You said that it is a charity with no role in the UK and supports human rights around the world. Its website states: it works to defend human rights and investigates human rights abuses in affected communities. It has held audiences with senior government officials in the countries where it works, the U.N. Security Council, the White House, UK and EU members of parliament, and others.

You wish to take up a part-time, unpaid role as a Member of the Leadership Council at Fortify Rights. You stated that through this role, you will be a listed member of the organisation and will support campaigns where you feel necessary.

You said you will have no contact with government in your role.

4.2 Dealings in office

You said that you did not make any policy, regulatory or commercial decisions specific to Fortify Rights, and that you did not have any access to information that could grant the organisation an unfair advantage. You also stated that there was no relationship between Fortify Rights and the Home Office.

4.3 Departmental Assessment

The Home Office confirmed the details provided in your application.

The Foreign, Commonwealth & Development Office confirmed that you did not make any policy, regulatory or commercial decisions specific to Fortify Rights, and that you did not have any access to information that could grant the organisation an unfair advantage.

The Foreign, Commonwealth & Development Office noted that its Myanmar desk and colleagues in British Embassy Yangon regularly meet Fortify Rights.

The Home Office and the Foreign, Commonwealth & Development Office recommended the standard conditions.

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

2. 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. ↩

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. ↩