Advice Letter: Baroness Blackwood, Chair, Oxford University Innovation Limited
Updated 27 April 2022
You approached the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointments Rules for former ministers (the Rules) seeking advice on taking up an appointment as a Chair with Oxford University Innovation Limited (OUI). The material information taken into consideration by the Committee is set out in the annex below.
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 time in office, alongside the information and influence a former minister may offer OUI.
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 are expected to uphold the highest standards of propriety and act in accordance with the 7 Principles of Public Life.
1. The Committee’s consideration of the risks presented
The Committee[footnote 1] noted that you did not meet with OUI and there is no relationship between your former department, the Department for Health and Social Care (DHSC) and OUI. Further, the department confirmed you did not make any decisions specific to OUI. Therefore, the Committee considered the risk of this work being seen as a reward for decisions made of actions taken in office as low.
The Committee took into account there is a general overlap with your time in office - specifically with regard to your work in science, research and innovation. However, the Committee took into account there are a number of mitigating factors that help to reduce the risks associated with your access to information and insight that may be seen to offer OUI an unfair advantage:
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you are prevented from drawing on privileged information and have an ongoing duty of confidentiality;
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you were previously employed by OUI as a Board Member from 2018 to 2019 and following an open competition
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you have been asked to rejoin the organisation as Chair;
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you have been out of office for almost 20 months, reducing the likelihood that any privileged information is sufficiently up-to-date; and
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the department considered the risk associated with any specific information is low.
2. The Committee’s advice
The Committee did not consider this appointment raises any particular proprietary concerns under the government’s Business Appointment Rules. The standard conditions below, preventing you from drawing on your privileged information and using your contacts to the unfair advantage of their new employer, will sufficiently mitigate the risks in this case. The Committee would draw your attention to the below lobbying and contracts and bids ban that includes governments’ arms’ length bodies.
Taking into account these factors, in accordance with the government’s Business Appointment Rules, the Committee advises this appointment with Oxford University Innovation Limited be subject to the following conditions:
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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;
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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 Oxford University Innovation Limited (including parent companies, subsidiaries, partners and clients); 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 Oxford University Innovation Limited (including parent companies, subsidiaries, partners and clients); and
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for two years from your last day in ministerial office, you should not undertake any work with Oxford University Innovation 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.
The Committee also notes that in addition to the conditions imposed on this appointment, there are separate rules in place with regard to your role as a member of the House of Lords.
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 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’. This Rule is separate and not a replacement for the Rules in the House.
You must inform us as soon as you take up employment with this organisation, or if it is announced that you will do so. We shall otherwise not be able to deal with any enquiries, since we do not release information about appointments that have not been taken up or announced. This could lead to a false assumption being made about whether you had complied with the Rules and the Ministerial Code.
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.
3. Annex - Material information
3.1 The role
You seek to join OUI in a paid, part-time role as Chair.
OUI’s website says it is a ‘…wholly-owned subsidiary company of the University of Oxford’. It says it is a ‘…world-leading innovation ecosystem’ which seeks to ‘…maximise the global impact of Oxford’s research and expertise’. You said OUI is overseen by a board drawn from senior University staff and external members with broad industry experience. You said OUI serves as Oxford University’s Technology Transfer Office.
You said your role will be to offer strategic advice, given your former role as a politician and Chair of the Science and Technology Select Committee. You referred to your experience of both the local and national innovation landscape, stating you will draw on your ‘…knowledge in science and technology start ups and growth technologies gained from previous roles’.
You were previously employed by OUI as a Board Member from 2018 to 2019[footnote 2], so this is a return to a former career. You said you have a ‘…long standing association with the Oxford innovation ecosystem’ which predates your ministerial role and referred to your ‘…long term and continued interest in broader science, technology and innovation’.
3.2 Dealings in office
You advised the Committee you did not meet with OUI whilst in office. Further, you said you did not have any involvement in any policy development or decisions that would have been specific to OUI, and held no commercial or contractual responsibilities relating to them. You said you did not meet with competitors of the company; nor did you have access to sensitive information regarding these competitors.
3.3 Department Assessment
The DHSC confirmed the details you provided, stating they have no concerns with the appointment.
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This application for advice was considered by; Jonathan Baume; Andrew Cumpsty; lsabel Doverty; Sarah de Gay; Dr Susan Liautaud; The Rt Hon Lord Pickles; Richard Thomas; Mike Weir; Lord Larry Whitty. ↩
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https://www.gov.uk/government/publications/blackwood-bate-nicola-parliamentary-under-secretary-of-state-for-public-health-and-innovation-at-the-department-of-health-acoba-recommendation ↩