Decision

Advice Letter: Rupert Yorke, Senior Director, Forward Global (United Kingdom) Ltd

Published 7 May 2025

1. BUSINESS APPOINTMENT APPLICATION: Mr Rupert Yorke, former Deputy Chief of Staff at No.10 Downing Street. Paid appointment with Forward Global (United Kingdom) Ltd.

Mr Yorke sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Crown Servants (the Rules) on taking up a role with Forward Global (United Kingdom) Ltd as a Senior Director.

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 Mr Yorke’s time in office, alongside the information and influence he may offer Forward Global (United Kingdom) Ltd. 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 Rules set out that Crown servants must abide by the Committee’s advice[1]. It is an applicant’s personal responsibility to manage the propriety of any appointment. Former Crown servants 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

Forward Global (United Kingdom) Ltd is a risk management firm, specialising in cybersecurity, critical intelligence, illicit trade, and strategic communications. It offers services to help businesses and institutions manage digital, economic, and information risks. Mr Yorke is being appointed as part of expanding the London office, with a view to bridging the US and EU offices. His role as Senior Director would involve senior leadership, public affairs, corporate communications and policy advice, among other responsibilities. 

During his time at No.10, Mr Yorke was not involved in decisions specific to Forward Global (United Kingdom) Ltd, nor did he meet with the company. Therefore, the Committee[2] considered the risk that this appointment could reasonably be perceived as a reward for decisions made or actions taken in office to be low.

Given Mr Yorke’s former role at No.10, he would have had access to general sensitive information that could benefit many organisations, including Forward Global (United Kingdom) Ltd. There are factors limiting this risk:

• it has been nine months and there has been a change of government and general policy direction since Mr Yorke’s time in government – providing a gap between his access to information and him taking up this appointment.
• the Cabinet Office did not consider Mr Yorke to possess any particularly sensitive information that may confer an unfair advantage to Forward Global (United Kingdom) Ltd.

While limited, the risk regarding Mr Yorke’s access to information is greatest should he advise Forward Global (United Kingdom) Ltd or its clients in relation to matters he had specific responsibility for. Further, the company’s clients and the precise pieces of work he will be asked to undertake are unknown, which raises the risk of giving such advice.

The Committee considered there are risks associated with Mr Yorke’s influence and network of contacts in government. Particularly, as he seeks to take up a role that operates in public affairs – which could be construed as seeking to influence the UK government on behalf of Forward Global (United Kingdom) Ltd. This would be contrary to the lobbying ban which applies to all former senior civil servants for 2 years on leaving office.

Mr Yorke said he will not contact the government and it is significant that Forward Global (United Kingdom) Ltd confirmed that:

1. it will adhere to the Rules and the conditions of this advice;
2. Mr Yorke will not lobby the government whilst subject to the Rules; and
3. lobbying activity would fall to others already employed by the company.

3. The Committee’s advice

The Committee considers the main risk here is a reasonable concern Mr Yorke may offer this company and its clients unfair access to the government, especially as it is expanding within the UK and the role involves some aspects of public affairs. Therefore, the Committee’s advice is that he should have no direct engagement with the government on behalf of Forward Global (United Kingdom) Ltd and its clients whilst he is subject to the Rules. This helps to mitigate the risk that may be seen to be making improper use of his time and contacts gained in office to the unfair benefit of your employer/ its members.

The Committee determined the risks identified can be appropriately mitigated by the conditions below. These make it clear that Mr Yorke cannot make use of privileged information, contacts or influence gained from his time in Crown service to the unfair advantage of Forward Global (United Kingdom) Ltd. Alongside the standard conditions, to mitigate the risk associated with him advising unknown clients and areas which may overlap with his time in government service, the Committee has imposed a restriction which makes it clear that Mr Yorke should not advise on work that arises where it relates to matters he had a specific role in developing or determining during his time at No.10 Downing Street.

It is significant that Forward Global (United Kingdom) Ltd confirmed its adherence with the Committee’s advice and in particular that Mr Yorke would not be involved in any lobbying of the UK government, which would fall to others within Forward Global (United Kingdom) Ltd.

The Committee’s advice in accordance with the government’s Business Appointment Rules is that Mr Yorke’s appointment with Forward Global (United Kingdom) Ltd be subject to the below conditions:

• he should not draw on (disclose or use for the benefit of himself or the persons or organisations to which this advice refers) any privileged information available to him from his time in Crown service;

• for two years from his last day in Crown service, he should not become personally involved in lobbying the UK government or any of its arm’s length bodies, on behalf of Forward Global (United Kingdom) Ltd (including parent companies, subsidiaries, partners and clients); nor should he make use, directly or indirectly, of his contacts in the government and/or Crown service contacts to influence policy, secure business/funding or otherwise unfairly advantage Forward Global (United Kingdom) Ltd (including parent companies, subsidiaries, partners and clients);

• for two years from his last day in Crown service, he should not provide advice to Forward Global (United Kingdom) Ltd (including parent companies, subsidiaries, partners and clients) 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 any of its arm’s length bodies;

• for two years from his last day in Crown service, he should not advise Forward Global (United Kingdom) Ltd (including parent companies, subsidiaries, partners and clients) or its clients on any work with regard to any policy he had specific involvement in or responsibility for as Chief of Staff at No.10 Downing Street nor where he had a relationship with the relevant client during his time in his role;

• for two years from his last day in Crown service, he should not become personally involved in lobbying contacts he developed during his time in Crown service in other governments and organisations for the purpose of securing business for Forward Global (United Kingdom) Ltd (including parent companies, subsidiaries and partners); and

• for two years from his last day in Crown service, he should not have any engagement on behalf of Forward Global (United Kingdom) Ltd (including parent companies, subsidiaries, partners and clients) with the UK government.

The advice and the conditions under the government’s Business Appointment Rules relate to an individual’s previous role in government only; there are separate 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[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/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.’

Mr Yorke must inform us as soon as he takes up this work or if it is announced that he will do so. Similarly, he must inform us if he proposes to extend or otherwise change his role with the organisation as, depending on the circumstances, it might be necessary for him to seek fresh advice.

Once this appointment has been publicly announced or taken up, we will publish this letter on the Committee’s website.

4. Annex – material information

4.1 The role

Forward Global (United Kingdom) Ltd is a risk management firm, specialising in cybersecurity, critical intelligence, illicit trade, and strategic communications. It offers services to help businesses and institutions manage digital, economic, and information risks. It has four main offices in Paris, Brussels, London and Washington D.C. It is part-owned by Bridgepoint Group, a private market growth investor.

Forward Global (United Kingdom) Ltd has been registered with the Office of the Registrar of Consultant Lobbyists since 14 November 2024.

Mr Yorke stated he would be joining as part of the expanding London office, with a view to bridge the US and EU offices (Paris and Brussels). He said the role will involve travel to US and EU, and provision of political intelligence advice for clients.

In his paid, full-time role working as a Senior Director, Mr Yorke stated his responsibilities would be in:

• senior leadership and counsel
• litigation resolution support
• public affairs
• corporate communications
• policy advice
• research
• intelligence
• cyber security
• IP protection.

Mr Yorke said he will have no contact with the UK government nor dealings with his former department. He also said that with Forward Global (United Kingdom) Ltd being headquartered in France, most client work would be outside of the UK.

4.2 Dealings in office

Mr Yorke said he did not meet with Forward Global (United Kingdom) Ltd during his time in Crown service and had no involvement in policy, funding or regulatory decisions specifically affecting Forward Global (United Kingdom) Ltd.

4.3 Correspondence with Forward Global (United Kingdom) Ltd

Forward Global (United Kingdom) Ltd confirmed in writing its understanding of, and agreement to, comply with the Committee’s advice. It provided the following in writing:

‘Thank you for your email of 23 April 2025 regarding ACOBA’s advice in relation to Rupert Yorke’s proposed appointment as a Senior Director at Forward Global (United Kingdom) Ltd UK. We welcome the opportunity to provide written confirmation of our full commitment to the conditions set out by ACOBA and to outline the steps we will take to ensure compliance with the relevant Business Appointments Rules. Forward Global (United Kingdom) Ltd UK recognises the critical purpose of the Rules: to protect the integrity of the government and uphold public trust in the movement of former Crown servants into the private sector.

Nature of Forward Global (United Kingdom) Ltd’s Business and Mr Yorke’s Role

It is important to clarify that Forward Global (United Kingdom) Ltd UK is a risk management and strategic communications advisory firm. Our core business is to assist clients in identifying, assessing, and mitigating risks in complex environments, as well as advising on reputation management and crisis communications.

We do not generally undertake lobbying activities on behalf of our clients, and Mr Yorke’s role will be strictly focused on providing risk management and strategic communications advice to our clients, not on engaging with government or influencing policy decisions.

While Forward Global (United Kingdom) Ltd is registered on the Registrar of Consultant Lobbyists, this registration is a matter of regulatory compliance due to recent work carried out on behalf of one client and does not reflect the day-to-day activities or priorities of Mr Yorke’s role.

If Forward Global (United Kingdom) Ltd does in the future take on new clients or work streams with a U.K. public affairs element, we will ensure that other appropriate members of the London office are solely responsible for that work, in order to protect Mr Yorke’s position and fully abide by the stipulations set out by ACOBA.

Our registration is reflective of our corporate compliance responsibilities in all jurisdictions we operate. I would point you to our global ethics and compliance policies which are shown on our corporate website: https://forwardglobal.com/en/our-commitments

Much of Mr Yorke’s work will be conducted outside the UK, working with colleagues in our New York, Paris and Brussels offices and any UK-based work will be managed to avoid any risk of breaching ACOBA’s conditions or creating a perception of inappropriate influence.

Acceptance of ACOBA Conditions

Forward Global (United Kingdom) Ltd UK confirms that we will adhere strictly to all conditions imposed by ACOBA and as a firm we will not do anything that encourages or induces Mr Yorke to breach these obligations in carrying out his role.

Ensuring Robust and Practical Compliance

Forward Global (United Kingdom) Ltd UK is acutely aware that it is not sufficient to simply state our acceptance of these conditions; we must also provide clear evidence of how we will ensure they are met in practice.

Drawing on the approach taken by other organisations in similar circumstances we will implement the following measures:

Role Design and Segregation

Mr Yorke’s responsibilities will be clearly delineated to ensure he is not involved in any activities that could reasonably be perceived as lobbying or as leveraging privileged information or contacts gained during his time in government. We will ensure that his work is focused on risk management and strategic communications advice, not on government relations or policy advocacy.

Internal Controls and Oversight

We will maintain comprehensive records of Mr Yorke’s client engagements and project assignments. This will ensure that he does not advise on matters related to UK government policy, contracts, or clients with whom he had a relationship during his Crown service.

Training and Guidance

Ongoing training and guidance will be provided to Mr Yorke and relevant Forward Global (United Kingdom) Ltd team members regarding the scope and application of the ACOBA conditions, reinforcing the boundaries of his permitted activities.

Compliance Officer

[A barrister employed by Forward Global (United Kingdom) Ltd] will act as a compliance officer and will be designated to oversee adherence to these conditions and to serve as a point of contact for any queries from ACOBA or other authorities.

Ongoing Engagement and Transparency

Forward Global (United Kingdom) Ltd UK is committed to transparency and ongoing engagement with ACOBA. We will keep the Committee informed of the steps we are taking to ensure compliance and will notify the Committee promptly should Mr Yorke’s role change in any way that might require further advice or review.

We are committed to upholding the highest standards of propriety and acting in accordance with the Seven Principles of Public Life, as expected under the Rules.

Conclusion

We are confident that, through the measures outlined above and our ongoing engagement with ACOBA, we will fully uphold the integrity and intent of the Rules throughout Mr Yorke’s tenure. Should the Committee require any further information regarding our arrangements or wish to discuss our compliance processes in more detail, we would be pleased to provide additional detail or meet at your convenience.’

4.4 Departmental assessment

The Cabinet Office said that as a Special Advisor for No.10, Mr Yorke had access to sensitive information and knowledge regarding the internal workings of government, but the importance of this knowledge was reduced with the change in government and nine months having passed since the role.

The Cabinet Office confirmed that Mr Yorke was not involved in policy, commercial or regulatory decisions specific to Forward Global (United Kingdom) Ltd. The department stated that, as a Special Advisor, his role would preclude direct responsibility or decision-making on contractual or commercial work which reduces the perceptive risk of reward for past favours as does the fact that this role has come about following an open advertisement and fair competition.

The Cabinet Office stated there is some risk, real or perceived, of Mr Yorke retaining privileged knowledge of the inner workings of government to an external organisation and its clients for the purposes of influencing UK government policy. However, the department stated this risk is somewhat diminished as there has been a complete change in political leadership since he left government over nine months ago, and it is unlikely that all retained information will be of significant benefit to his prospective employer. Therefore, it considers the risk relating to his access to information to be limited.

The Cabinet Office noted the perceived risk of lobbying on the behalf of Mr Yorke’s proposed employer, given his proposed role as Senior Director involves public affairs, its recent registration on the Registrar of Consultant Lobbyists and his former senior position within the centre of government at No.10.

The Cabinet Office recommended the standard conditions.

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[1] Which apply by virtue of the Civil Service Management Code, The Code of Conduct for Special Advisers, The King’s Regulations and the Diplomatic Service Code

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

[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 the 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.