Decision

Summary of business appointment applications - General Sir Richard Barrons

Published 16 July 2018

General Sir Richard Barrons, former Commander, Joint Forces Command (JFC), retired from the army in August 2016.

1. Independent consultancy

2. Kellogg Brown & Root Ltd

3. CAE (UK) plc

Sir Richard sought advice on establishing an independent consultancy offering consultancy in digital operations, innovation and strategy, spanning: data, processing, connectivity, artificial intelligence, robotics, space, bio-science, cyber, virtual reality, augmented reality and autonomy.

Sir Richard also sought advice on to taking up advisory appointments with the following companies:

• Kellogg Brown & Root Ltd (provider of services to the oil and gas industry, governments and defence worldwide). 2 days per month.
• CAE (UK) plc (provider of training for the civil aviation, defence and security, and healthcare markets). 4 days per month.

When considering the application to set up an independent consultancy the Committee took into account that it will be commercially focused, with the most likely sectors to be insurance, infrastructure, oil and gas, banking and manufacturing. The Committee further noted that will be required to seek advice from the Committee for each commission that he proposes to accept.

Under the Government’s Business Appointment Rules the Committee must have regard to whether there is a risk that an employer or client may gain an unfair advantage by virtue of the contacts or privileged information held by the former Crown servant. This risk is partly mitigated in this case by the following factors:

• Sir Richard will not be involved in contracting with the UK MOD or working in the UK Defence market for the remainder of the period under which he is subject to the Business Appointment Rules.
• Sir Richard will not have any contact with the MOD or the UK Government for the same period.
• 16 months have passed since his last day in post and 12 months since his last day in Crown service. This lessens the risk of him having access to relevant and sensitive information.

The Committee must also consider whether there is a risk of any appointment being perceived as a reward for decisions made while in office. While the Committee noted that Sir Richard’s responsibilities as Commander JFC included areas of relevance to the business of the companies he seeks to work for, the MOD has confirmed that he would have had no direct involvement in the management of any MOD contracts with these companies. This, together with the minimal prior contact he had with the companies and the time lapsed since his last day in office, reduces the potential for these roles to be seen as a reward.

The Committee took into account the recommendation of the MOD Business Appointments Panel, endorsed by the Permanent Secretary at the MOD: that the consultancy and appointments be subject to restrictions incorporated in the conditions set out below. As Sir Richard is forming a consultancy with partners and employees, the Committee would expect the consultancy as a whole to respect the conditions set out below.

The Prime Minister accepted the Committee’s advice that the consultancy and appointments be subject to the following conditions:

• that he should not draw on (disclose or use for the benefit of himself or the 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 of service he should not become personally involved in lobbying the UK Government on behalf of the organisations to which this advice refers, their subsidiaries, partners or clients, or those he advises under his consultancy. Nor should he make use, directly or indirectly, of his Government and/or Crown Service contacts to influence policy or secure business on their behalf;
• for two years from his last day in post he should not work in or advise on the UK Defence market;
• for two years from his last day in Crown service, he should not provide advice to any company or organisation on the terms of, or with regard to the subject matter of, a bid or contract relating directly to the work of the UK Government; and
• for two years from his last day in Crown service, before accepting any commissions and or/before extending or otherwise changing the nature of any commission, he should seek advice from the Committee. The Committee will decide whether each commission is consistent with the terms of his consultancy and consider any relevant factors under the Business Appointment Rules.

The letter containing the Committee’s advice was sent in September 2017.