Decision

Advice letter: Viscount Camrose, Advisor, StratXion Limited

Updated 10 March 2026

1. BUSINESS APPOINTMENT APPLICATION: Viscount Camrose, former Parliamentary Under Secretary of State, Department for Science, Innovation and Technology – Paid appointment as Advisor, StratXion. 

Thank you for your application, under the Government’s Business Appointment Rules for Former Ministers (the Rules), for my advice on taking up a paid, part-time role as Advisor at StratXion Limited.

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 StratXion Limited (including its related parties) 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 StratXion Limited (including its related parties); 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 StratXion Limited (including its related parties).
• Contracts and bids condition – For two years from your last day in office, you should not undertake any work with StratXion Limited (including its related parties) 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.
• Role restriction – For two years from your last day in office, you are prevented from advising StratXion Limited (including its related parties) on any matter in which you were materially involved during your time in office. You are also prevented from advising related parties of StratXion Limited where you had material dealings with the related party or client in office.
• Business development restriction – For two years from your last day in office, you should not become personally involved in lobbying contacts you acquired during your time in office in other governments and organisations for the purpose of securing business for StratXion Limited (including its related parties). 

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 governing the registration of consultant lobbyists, from the Code of Conduct and Rules of the House of Commons and from the House of Lords Code of Conduct. 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.
• By ‘related parties’, I mean any parent companies, subsidiaries, clients and/or other partners as may be relevant.
• 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 StratXion Limited (StratXion), a provider of advisory services to help scale-ups, large enterprises, private equity and venture-capital backed firms grow and governments to build tech-first services.

You said that as an Advisor, you will help make short-term plans for companies acquired by private equity groups. You confirmed there will be no contact with the UK Government in the role.

2.2 Dealings in office

You confirmed that you neither met with nor made any policy, regulatory, or commercial decisions specific to StratXion. You said that you had no access to information that could unfairly advantage the company.

2.3 Departmental assessment

The Department for Science, Innovation and Technology (DSIT) confirmed you neither made decisions specific to, nor met with, StratXion in office. 

DSIT considered you not to have access to information specific to StratXion that could offer an unfair advantage, but noted your access to general information on artificial intelligence (AI) and cybersecurity from your time as minister. Additionally, DSIT said you may have access to privileged information on AI and cybersecurity policy – which could be beneficial to StratXion’s clients. DSIT also noted you met with multiple companies that could be interested in StratXion’s services and that you have contacts in UK AI and cyber businesses from your time in office. 

DSIT recommended the standard conditions and an additional restriction to the role preventing the use of privileged knowledge from your time in office in advice to clients. 

2.4 My consideration of the risks 

In office, you made no policy, regulatory or commercial decisions specific to StratXion – the risks here are therefore limited.

Nevertheless, as StratXion’s clients are unknown, there is an inherent risk that your work could overlap with any of the responsibilities you had as minister. Additionally, there is a specific risk of unfair advantage associated with your access to privileged information on AI and cybersecurity policy. It would be inappropriate for a former minister in possession of privileged policy information to take up, without restriction, a role involving advice to potential clients for whom the information may be relevant. This risk cannot be accurately assessed as the clients you may advise in your role with StratXion are not known. I consider the appropriate mitigation of these risks to be twofold: first, to restrict the role to prevent you from advising StratXion or its clients on any matter in which you were materially involved while in office, and second, to restrict the role to prevent you from advising StratXion’s clients where you had material dealings with the client during your time in office. 

It is important to note that StratXion’s clients include governments – there is a risk you could be perceived to offer StratXion and the companies it advises unfair access to the UK government. This risk is limited as the proposed role does not involve lobbying and you confirmed the role will not involve contact with the UK government. I also consider it of significant relevance that StratXion has provided written confirmation of its agreement to comply with the advice and the separation of your role from lobbying.

You will likely have a wide network from before you entered government. However, in respect of contacts in other governments and organisations acquired only as a result of your ministerial role, there remains a risk you could be seen to advantage StratXion unfairly by drawing on such contacts to secure business on its behalf. I have therefore applied a restriction to prevent you from lobbying any contacts you acquired solely during your time in office for the purpose of securing business for StratXion.