Decision

Advice Letter: Anne-Marie Trevelyan, Strategic Advisor, Babcock International Group Plc

Updated 10 October 2025

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1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Anne-Marie Trevelyan, former Minister of State for the Indo-Pacific at the Foreign, Commonwealth and Development Office. Paid appointment with Babcock International Group Plc.

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 your role as a Strategic Advisor with Babcock International Group Plc (Babcock).

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 Babcock. The material information taken into consideration by the Committee is set out in the annex.

The Committee’s advice is not an endorsement of this appointment in any other respect – 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

Babcock is a British aerospace, defence and nuclear engineering services company that operates globally. It specialises in managing complex assets and infrastructure, offering marine, nuclear, land and aviation solutions. For example, it provides through-life support for naval vessels, land vehicles, aircraft, nuclear facilities as well as designing and manufacturing specialist equipment such as naval ships and weapons handling systems. Babcock holds several contracts with the UK government and Ministry of Defence (MOD). You seek to join the company as a Strategic Advisor, and describe the role as advising on geopolitics and business strategy.

The Committee[footnote 1] considered the information provided by the Foreign, Commonwealth and Development Office (FCDO) in relation to you having personal contact with, or on behalf of, Babcock while in office, including in relation to potential commercial opportunities in Australia. Overall, it agreed with the FCDO that the risk is limited given that there is no evidence that Babcock commercially gained as a result of this engagement. Further, while you maintained contact with Babcock from bilateral meetings and engagements to accepting hospitality – you made no decisions specific to Babcock as a result.

The FCDO also referenced your ministerial responsibility for export control licence applications in the Indo-Pacific. Babcock has made a number of applications for export control licences over the years, including, but not limited to: securing an export licence for its Arrowhead-140 frigate to Indonesia in 2021, and again in 2023 for the same frigate in Poland. There is no evidence that you were specifically involved in, or made any decisions on, licences specific to Babcock during your time as Minister for the Indo-Pacific (between 2022 to 2024). It is also relevant that any such applications are made in line with publicly available, standardised criteria;[footnote 2] and are the overall responsibility of the Department for Business and Trade, based on recommendations from the Export Control Joint Unit (with advice from the MOD and the FCDO).

The Committee determined that the risk that you were offered this role as a reward for decisions or actions taken in office is limited. The Committee considered a waiting period to place a gap between your contact and dealings with and on behalf of Babcock and this role. In the circumstances, while you did have contact with Babcock and took actions on its behalf, there was no obvious commercial benefit to Babcock. Therefore, the 12 months that have passed since you were in office is considered a sufficient gap, given the limited risk of reward in this case.

As the former Minister for the Indo-Pacific, it is likely that you had access to a range of information relating to your geographic region, including on defence intelligence and foreign policy, which could be of benefit to any organisation, including Babcock. As your role at Babcock will involve advising on geopolitics, it is likely that there will be some overlap with your ministerial role. Overall, the Committee considered that there are several factors that limit the risk of your general access to information:

  • much of the information to which you had access was general, and not specific – it would apply to any organisation that might have an interest in the areas you had responsibility for in office, and the FCDO is not aware of any specific information that would grant Babcock an unfair advantage.
  • you have been out of office for over 12 months – creating a significant time gap between when you last had access to sensitive information and taking up this role. This helps reduce the likelihood that information is sufficiently up-to-date to be commercially advantageous.
  • the changes in government and foreign policy landscape since you left office mean that foreign and defence/security matters you were involved in are likely to have moved on.

In addition, the FCDO flagged two areas in which you had access to information that could potentially offer Babcock an unfair advantage.

  • Export control licensing: Whilst there is no specific piece of information at risk, the FCDO considered there is a risk your knowledge of the export control process may be seen to offer Babcock an unfair advantage in future applications for export control licences. Decisions for applications are made according to publicly available, standardised criteria. Babcock has previously applied for, and been granted, several export licences and is experienced in navigating this system. There is no evidence that you will offer any unfair insight or information on the process.

  • The acquisition of GE Oil and Gas Marine Ltd and GE Steam Power by GEAST, a subsidiary of the French state-owned energy company EDF: While in office you were sighted on information around the government’s views on possible security risks relating to this acquisition, including other possible investors at the time. This information is no longer sensitive as it is in the public domain – EDF having finalised its acquisition in 2024. The  Competitions and Markets Authority (CMA) investigated this acquisition, leading to the UK government issuing a Final Order under the National Security and Investment Act 2021 prior to finalisation, which set out various conditions during the process to protect UK national security risks.

For the reasons set out above, the Committee agreed with the FCDO that this information could not reasonably be seen to offer an unfair advantage to Babcock.

As a UK minister operating internationally, you amassed a network of contacts both across the UK government, and in other countries. There is a reasonable concern that you may be able to offer Babcock unfair access to the UK government, both within the UK and where it operates abroad. In addition, should you have contact with the UK government on Babcock’s behalf, it would be difficult to manage the risk you may seek to influence the government on the company’s behalf. 

For the same reason, there are risks associated with your contacts within foreign governments, particularly in the geographical areas you had responsibility for.  As you will be advising on future business strategy, you may be seen to offer contacts from your time in office that could grant Babcock an unfair advantage in securing new business with governments and other organisations abroad – contacts to which it otherwise may not have access. 

3. The Committee’s advice 

The Committee determined that the greatest risk in this application is your closeness to Babcock in office and that you may now be seen to offer unfair access to, and influence over, UK officials at home and abroad; and that in expanding its business, you could be seen to offer Babcock  access to foreign government ministers and officials, particularly in the Indo-Pacific. This is also why the Committee considered it would be inappropriate for you to initiate any engagement with the UK government on behalf of Babcock, even where this is not for the purposes of influencing actions or decisions.

Babcock has confirmed that it will adhere to the conditions set out in this advice letter and that your role will not involve any lobbying. 

The Committee determined that the remaining risks can be appropriately mitigated by the conditions below. These make it clear that you must not make use of privileged information, contacts or influence gained from your time in ministerial service to the unfair advantage of Babcock. 

The Committee advises, under the government’s Business Appointment Rules, that this appointment as Strategic Advisor with Babcock International Group Plc should 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 government or its arm’s length bodies on behalf of Babcock International Group Plc (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 Babcock International Group Plc (including parent companies, subsidiaries, partners and clients); 

  • for two years from your last day in ministerial office, you should not undertake any work with Babcock International Group Plc (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 government or its arm’s length bodies; 

  • for two years from your last day in ministerial office, you must not become personally involved in lobbying contacts you developed during your time in office and in other governments and external organisations for the purpose of securing business for Babcock International Group Plc (including parent companies, subsidiaries and partners); and

  • for two years from your last day in ministerial office, you must not directly engage with the UK government or its arm’s length bodies on behalf of Babcock International Group Plc (including parent companies, subsidiaries, partners and clients).

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 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 role, 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.

4. Annex - Material Information

4.1 The role

Babcock Ltd (Babcock) is a UK-based engineering company that operates in defence, aviation and nuclear. It works closely with the MOD and Network Rail. Examples of its services are as follows:

  • It is involved in shipbuilding, including the construction of the new Type 31 frigates for the Royal Navy.

  • It provides support and maintenance for submarines, including the Vanguard class carrying Trident nuclear missiles. 

  • It delivers military flying training, air station support, and integrated engineering services to various branches of the armed forces. 

  • It provides engineering support for critical infrastructure, including aviation emergency services (search and rescue, medical evacuation, etc.), and aerial firefighting. 

Babcock has several contracts with the UK MOD:

You told the Committee that you will take up a paid, part-time role with Babcock as a Strategic Advisor. You said that your role will involve advising on geopolitics, future business strategy, and chairing the Babcock Strategic Advisory Board which is set up to provide a range of expertise to support Babcock globally. You said that you will neither lobby the government nor have any contact with government in this role. 

Babcock confirmed that it does not ask or expect its employees that are former government officials to undertake any form of lobbying, and that it will adhere to the conditions in this advice note.

4.2 Dealings in office 

You told the Committee that as Minister for the Indo-Pacific at the FCDO:

  • You did not make any commercial, policy or regulatory decisions that specifically benefited Babcock.

  • You had no access to sensitive information that could give Babcock an unfair advantage.

  • You had contact with Babcock while in office, in the context of meeting with stakeholders from the whole of the UK defence sector, as well as  representatives from every prime and many SME defence and security companies – both in the UK and internationally.

    • You met with senior Babcock personnel, along with all the other major UK defence companies that work closely with government to discuss trade and economic security across the Indo-Pacific. 

    • You had contact with Babcock’s senior leadership in Australia & New Zealand as part of wider UK government exports work, led by the Department for Business and Trade (DBT) and supported by British High Commissions.

    • You met Babcock personnel at round tables in Canada, Poland, and in the UK to support UK economic security matters.

4.3 Departmental assessment 

The FCDO provided the following information to the Committee: 

  • There is no contractual relationship between Babcock and the FCDO.

  • Babcock has applied for export licences, which could overlap with your responsibilities in office:[footnote 4]

  • Controlled goods (such as military items, firearms, etc, and  goods subject to trade sanctions) are regulated through a system of export controls and licensing. The Export Control Joint Unit (ECJU) administers the UK’s system of export controls and licensing for military and dual-use items. Part of this process involves seeking advice from the FCDO.[footnote 5]

  • There is no evidence that you made decisions on export licences involving Babcock while you were Minister of State for the Indo-Pacific.  Neither the FCDO, nor ACOBA are aware of any export licence that fell under your ministerial portfolio for Babcock while you were at the FCDO.

  • The FCDO has previously informed the Committee that these decisions are made using publicly available and standardised criteria with input from the MOD/FCDO and DBT, meaning no single person should be able to influence these decisions. 

  • You maintained personal contact with, or on behalf of, Babcock while in office on some matters, including in relation to a potential commercial opportunity in Australia. The FCDO said that the risk of reward is limited given that there is no evidence that Babcock made commercial advantage as a result.

  • You had contact with Babcock at various events alongside maintaining direct relationships and contact with the CEO of Babcock and members of its Executive Board. For completeness, your official contact with Babcock is listed at the end of this annex.

As regards your access to information, the FCDO said the following:

  • Whilst it is likely that you had access to information on defence intelligence and foreign policy material as it related to your geographic brief, the FCDO is not aware of any specific information that could grant an unfair advantage to Babcock.

  • You were previously the Secretary of State at the Department for International Trade, and, having promulgated the current Strategic Export Licence Controls framework in 2022, you have good knowledge about export licensing. It would not be improper to draw on this as the process is in the public domain.

  • You had access to privileged, high sensitivity information on defence, intelligence, and foreign policy material during your time in office, but as it related to your geographic brief, and the FCDO is not aware of any specific information that could grant an unfair advantage to Babcock.

  • EDF’s acquisition of GE Oil and Gas Marine Ltd and GE Steam Power: You were sighted on information related to the National Security and Investment Act (NSIA) regarding the proposed purchase of GE Oil & Gas Marine & Industrial UK Limited, and GE Steam Power by GEAST, a subsidiary of French state-owned energy company EDF.

  • You were sighted on relevant decisions given your responsibilities  for economic/investment security.

  • This acquisition began in early 2022 and was later approved following the CMA’s investigation in May 2023. The acquisition triggered a review under the NSIA, and a risk to national security was identified due to the critical national security and defence capabilities related to naval propulsion systems delivered through the GE facilities. To mitigate these risks, the government issued the notice of Final Order under the NSIA which outlined the security conditions, in August 2023.

  • The acquisition was completed in May 2024.

Overall, the FCDO’s view was that while your experience in the FCDO, combined with your wider ministerial experience, offer you significant insight on matters of commercial interest to Babcock, it does not consider that Babcock can gain an unfair advantage. The FCDO considered that this appointment is a good fit for your skills and general experience.

The FCDO recommended the standard conditions.

The MOD was also consulted on this application, given its strategic relationship with Babcock. It recommended the standard conditions apply to this appointment. 

List of ministerial engagements with Babcock:

Events

  • Royal International Air Tattoo (RIAT) – 15 July 2023: A meeting between you and Babcock in the margins of this event.

  • Defence and Security Equipment International (DSEI) – 13 September 2023: You held a bilateral meeting with Babcock at its stand at the event.

  • MoU signature in Australia – December 2023: You met with Minister Papalia in Western Australia. The meeting coincided with the signature of an MoU between Australia and Babcock, that you witnessed.

  • Shangri-La Dialogue 2024 – 31 May–2 June: A meeting with Babcock’s CEO in the margins of this event. The briefing noted that Babcock UK had asked the UK government to directly intervene in the Australian selection process for their general-purpose frigate requirement.

Hospitality

  • Dinner in Sydney – 7 November 2023: You were there for Indo-Pacific International Maritime Exposition. You accepted a dinner invitation from Babcock. Also in attendance at the dinner was a rep from Bechtel, HiII and McKinsey & Company. FCDO officials were also present.

  • Business News Lunch Event: The Future of Defence in Western Australia – 8 December 2023: You sat on a panel to discuss the UK’s role in the Indo-Pacific and AUKUS.[footnote 6] There was no bilateral meeting with Babcock at this event; however, the event was co-hosted with the Chamber of Minerals and Energy Australia and Curtin University with Babcock.

  • Army v Navy Rugby – 4 May 2024: You were invited by Babcock as hospitality. You were not accompanied by officials.

  1. 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. ↩

  2. https://www.gov.uk/guidance/standard-individual-export-licences ↩

  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. Israel: Between 2008 and 2021, Babcock applied for 12 arms export licenses to supply weapons, components, or military technology to Israel. Indonesia and Poland: Babcock has secured export contracts for the Arrowhead 140 frigate design to both Indonesia (in 2021) and Poland in 2023. Other Countries: Babcock has also applied for export licenses to 14 other countries, including the United States and Russia. ↩

  5. More information can be found here: https://www.great.gov.uk/learn/categories/selling-across-borders-product-and-services-regulations-licensing-and-logistics/get-your-good-out-uk/understand-export-licensing/  The Department for Business and Trade (DBT) has overall responsibility for the statutory and regulatory framework of export controls, and for decisions to grant or refuse an export licence. The FCDO and the MOD are DBT’s principal advisers on the Strategic Export Licensing Criteria, which are used to assess license applications. The criteria: https://questions-statements.parliament.uk/written-statements/detail/2021-12-08/hcws449#:~:text=Spring%20of%202022.-,The%20Strategic%20Export%20Licensing%20Criteria,-This%20statement%20of ↩

  6. AUKUS is a trilateral security partnership between Australia, the United Kingdom, and the United States intended to “promote a free and open Indo-Pacific that is secure and stable.” Initially announced on 15 September 2021, the partnership involves two lines of effort referred to as pillars. ↩

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