Decision

Advice Letter: Charlotte Vere, Vice President – International Relations, CORE POWER (UK) Limited

Updated 13 May 2025

1. BUSINESS APPOINTMENT APPLICATION: Baroness Vere of Norbiton, former Parliamentary Secretary at HM Treasury and, prior to that, Parliamentary Under Secretary of State (Minister for Aviation) at the Department for Transport. Paid appointment with CORE POWER (UK) Limited.

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 appointment as Vice President – International Relations with CORE POWER (UK) Limited (CORE POWER).

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 CORE POWER. 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

CORE POWER is a UK-based maritime and technology innovation company. It operates in the nuclear energy technology market and advanced floating nuclear technology solutions. The Committee understands that the UK nuclear energy market is regulated by the Office for Nuclear Regulation^{[footnote 1]}, a public corporation of the Department for Work and Pensions sponsored by the Department for Energy and National Security.

There is no known overlap between your ministerial responsibilities and CORE POWER. You did not meet with, nor were you involved in, policy, regulatory or commercial decisions specific to CORE POWER. Therefore, the Committee^{[footnote 2]} considered the risk that this appointment could reasonably be perceived as a reward for decisions or actions taken in office to be low.

As a former minister, there are inherent risks that you may have had access to sensitive information that could benefit a range of organisations, including CORE POWER. The risks are significantly limited because:

• your portfolio in office had no direct overlap with the work of CORE POWER;
• as a company operating in nuclear energy technology, the relevant policy areas of interest are held outside the scope of your responsibilities in office – by the Department for Energy and National Security, and independent regulators including the Office for Nuclear Regulation^{[footnote 3]}; and
• your previous departments are not aware of any specific information you had access to that could offer CORE POWER an unfair advantage.

As with any former minister, there are risks associated with your contacts and influence within government – with the potential for CORE POWER to gain unfair access or influence as a result. You noted that there may be instances in which you may have contact with the government, via briefing for officials or through consultation. Contact with government instigated by government is entirely in keeping with the lobbying ban that applies to all ministers on leaving office for two years. The Committee considered there to be a significant risk that, should you have any engagement with government initiated by you (directly or indirectly), it would reasonably be seen as you seeking to influence government policy or regulation. Regulation and policy in nuclear energy, particularly technological advancement, safety and security are all of major importance to the UK government. The Committee therefore considered it significant that in this role you will not instigate any contact with the UK government on CORE POWER’s behalf. Further, CORE POWER confirmed that any of its activity that involves lobbying the UK government will be separated from your role.

The role of Vice President – International Relations will involve leading on relationship-building with external stakeholders on CORE POWER’s behalf. As such, there are risks associated with your influence and network of contacts external to government gained during ministerial office – particularly, the risk that you could make use of those contacts to obtain new business on your employer’s behalf.

3. The Committee’s advice

The Committee considered the main risk to be that CORE POWER might reasonably be seen to gain an unfair advantage as a result of your contacts gained in ministerial office. As noted above, it is significant that CORE POWER confirmed its adherence with the Committee’s advice and, in particular, that your role will be separated from any activity focused on lobbying the UK government.

The Committee determined the risks identified in this application can be appropriately mitigated by the conditions below. These make it clear that you cannot make use of privileged information, contacts or influence gained from your time in ministerial office to the unfair advantage of CORE POWER.

The Committee advises, under the government’s Business Appointment Rules, that your appointment with CORE POWER (UK) Limited 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 CORE POWER (UK) Limited (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 CORE POWER (UK) Limited (including parent companies, subsidiaries, partners and clients);
• for two years from your last day in ministerial office you should not undertake any work with CORE POWER (UK) Limited (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; 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 CORE POWER (UK) Limited.

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 4]}. You are reminded that, as a Member of the House of Lords, you are prevented from any paid lobbying under the House of Lords 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 employment with this organisation, or if it is announced that you will do so. Please 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 stated that CORE POWER is a developer of floating advanced nuclear technology solutions. According to its website, CORE POWER is a private UK-based maritime and technology innovation company. The company states that its market is that of advanced nuclear energy technology for ocean transportation and heavy industry, partnering with leading international power, engineering and innovation companies to deliver durable zero-emission energy for floating industrial production and deep-sea shipping.

You described your paid, part-time role as Vice President – International Relations as leading relationship-building outside the US, to support the introduction of offshore advanced nuclear technologies. You will work with industry, trade associations, academia, governments, and their relevant agencies, and international bodies. You said that you will:

• establish and maintain positive, professional, and ethical relationships with external stakeholders, including industry, academia, governmental entities and regulatory bodies;
• actively monitor, analyse, and shape regulatory, legislative, and public policy developments relating to advanced nuclear technologies internationally – this will include those emerging from member states and international bodies represented at the International Atomic Energy Agency in Vienna, the International Maritime Organisation in London and the Organisation for Economic Cooperation and Development in Paris;
• lead engagement efforts through CORE POWER’s Convoy Program with industry and Academic Resources Program with academia to educate and inform stakeholders about floating nuclear power and related opportunities and prepare the industry for its introduction;
• represent CORE POWER at industry conferences and other forums to increase awareness and understanding of the company’s mission and technical developments;
• participate in the leadership of CORE POWER UK by contributing to strategic decision-making, workforce development, and stakeholder relationships.

You stated that contact with the UK government is conceivable, for example to provide briefings for officials about the company’s progress. You suggested that such contact might involve setting out or responding to questions about how changes to regulations would benefit all players in the nuclear sector, and the UK economy. You considered that the issues at this stage of development were most likely to be sector wide rather than company specific.

4.2 Correspondence with CORE POWER

CORE POWER (UK) Ltd confirmed that it had seen and reviewed this advice and that it will comply with the conditions. Further, any responsibility for lobbying the UK government on the company’s behalf will be separate from your role.

4.3 Dealings in office

You stated that you did not meet with, nor were you involved in, any policy, commercial or regulatory decisions, nor did you possess sensitive information, specific to CORE POWER.

4.4 Departmental assessment

Your former departments, the Department for Transport and HM Treasury, confirmed the details you provided and that:

• you were not involved in decisions specific to CORE POWER
• neither department has any specific relationship with CORE POWER
• they do not consider you to possess sensitive information that may provide CORE POWER an unfair advantage.

The Department for Transport added that the majority of policy that was under development during your time in office is now either in the public domain or out of date due to the time elapsed since you left office (over 14 months) and the change in government.

The departments did not have concerns with the appointment and recommended that the standard conditions apply.

1. www.gov.uk/government/organisations/office-for-nuclear-regulation ↩

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

3. www.gov.uk/government/organisations/office-for-nuclear-regulation ↩

4. 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. ↩