Decision

Advice Letter: Tom Tugendhat, Non-Statutory Board Member, United Against Nuclear Iran

Published 23 September 2025

1. BUSINESS APPOINTMENTS APPLICATION FOR ADVICE: The Rt Hon Tom Tugendhat MBE VR MP, former Minister of State for Security, the Home Office. Unpaid appointment with United Against Nuclear Iran.

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 an appointment you want to take up with United Against Nuclear Iran (UANI).

The purpose of the Rules is to protect the integrity of the government. Under the Rules, the Committee’s remit is to consider the risks associated with the actions and decisions made during your time in office, alongside the information and influence you may offer UANI. 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

UANI described itself as a US charitable non-profit and non-partisan policy and research organisation formed to combat the threats posed by the Islamic Republic of Iran.

When considering this application, the Committee^{[footnote 1]} took into account this appointment 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.

You were Minister for Security at the Home Office and therefore made decisions of and were sighted on information that is likely to be relevant to this organisation. The Home Office and the Foreign and Commonwealth Office confirmed your decision-making in office and access to information were of no particular concern in relation to this role. The unpaid nature of this appointment further limits the real and perceived risk of you making improper use of information you had access to while in office for personal benefit.

The FCDO noted, as with any recently demitted minister, that it could be misinterpreted that your membership represents the current government. The Committee noted that the organisation has several former officials and members of government from across the world, including Australia, Canada, Iran, UK and the US. In these cases, that they formally represented/worked for any particular government in the past is made clear on the website.

3. The Committee’s advice

The Committee considered the inherent risks under the Rules in this role are appropriately mitigated by the standard conditions below. In particular, they seek to prevent you from drawing on your privileged information, contacts, and influence within government to the unfair advantage of UANI.

In accordance with the government’s Business Appointment Rules, the Committee advises this role with United Against Nuclear Iran 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 United Against Nuclear Iran (including parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or ministerial service to influence policy, secure business/funding or otherwise unfairly advantage United Against Nuclear Iran (including parent companies, subsidiaries, partners and clients);

• for two years from your last day in ministerial office you should not undertake any work with United Against Nuclear Iran(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]} 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 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 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

You seek to take up an unpaid, part-time role as a Non-Statutory Board Member with United Against Nuclear Iran (UANI).

UANI is a US charitable non-profit and non-partisan policy and research organisation formed to combat the threats posed by the Islamic Republic of Iran. Its primary objective is to prevent Iran from achieving its ambition of becoming a regional superpower in possession of nuclear weapons.

UANI’s primary activities include:

• Actively campaigning for corporations to divest from Iran.

• Advocating for robust sanctions at various governmental levels.

• Educating the public about the threats posed by the Iranian regime.

• Monitoring Iran’s oil exports to enforce sanctions.

• Raising awareness of Iran’s military capabilities through exhibitions and events.

UANI has no official relationship with government, though it provides information and commentary to government, as it does to other relevant members of the public.

As a Non-Statutory Board Member, you would be involved in:

• Providing strategic guidance: contributing to knowledge and experience to shape UANI’s goals, initiatives, and overall strategy in countering the threats posed by the Iranian regime.

• Offering expert advice: providing perspectives and advice on complex issues related to Iran’s nuclear programme, regional activities, and international relations.

• Offering support and your profile: The presence of prominent figures on the Advisory Board signals their personal concern about Iran’s nuclear ambitions and other destabilising activities, lends weight and credibility to UANI’s efforts.

You stated you would have no contact with the government in this role.

You plan to lend your name and support to UANI as a patron and may speak at conferences on their behalf. You will reference separation from the current government.

There are a number of other former ministers and officials on the Advisory Board ^{[footnote 4]}.

4.2 Dealings in office

You had no contact with UANI while in office, nor access to any specific information you consider to be of risk.

4.3 Departmental Assessment

The Home Office confirmed the information you provided above. It stated you took a firm position on Iran when you were Security Minister and would have made some policy decisions relating to Iran that UANI would likely support. The Home Office did not consider you made decisions that would specifically or uniquely have benefited UANI.

The Home Office also confirmed there is no departmental relationship with UANI and you did not have access to privileged information that could offer UANI an unfair advantage.

The Foreign, Commonwealth & Development Office (FCDO) noted that the Iranian government would likely notice your involvement with UANI and it may be considered an extension of current government policy/approach to these matters. It noted that it could be made clear, if and when appropriate, that you are no longer a representative of the current government.

Both the Home Office and FCDO recommended standard conditions.

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

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 your 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. https://www.unitedagainstnucleariran.com/about/leadership ↩