Decision

Summary of business appointment applications - Air Marshall Sir Simon Bollom

Published 24 January 2017

Air Marshal Sir Simon Bollom left his position as Chief of Materiel (Air) (COM AIR) in Defence Equipment and Support, MOD, in April 2016.

1. Independent Consultant

Air Marshal Sir Simon Bollom sought advice on setting up an independent consultancy, offering general advisory work on business strategy, project management, and safety engineering with a particular emphasis on aviation. He also sought advice on accepting two commissions: an assignment with CH2M to conduct an independent review of the Highways England Major Projects transformation programme experience and five days consultancy with KPMG associated with Project Gateway, an Air Command project, which will provide a more efficient and effective delivery at RAF Brize Norton.

The Committee considered that given the seniority of Sir Simon’s position in DE&S, it was appropriate to apply to his consultancy a two-year ban on working in the UK Defence market although the Committee would be prepared to consider waiving the ban on a case-by-case basis if the specific circumstances of a commission warranted this approach.

When considering the commissions with CH2M and KPMG the Committee noted the factors set out in the attached letter. In relation to the commission with KPMG, the Committee took into account that this is a discrete piece of work, which is intended to find efficiencies and create value for the taxpayer and that KPMG have added a clause in their contract with Sir Simon to strictly limit the work he may undertake, to within Project Gateway. Further, whilst the MOD is not officially endorsing Sir Simon’s assignment, it sees the value in the work Sir Simon will be doing with KPMG and has no concerns about him taking up the role. The Committee concluded that it would be appropriate to waive the ban on working in the UK Defence sector for the KMPG commission given the circumstances.

The Secretary of State for Defence accepted the Committee’s advice that, in accordance with the Government’s Business Appointment Rules, Sir Simon’s independent consultancy and commissions with CH2M and KPMG be subject to the following conditions:

• For two years from his last day in post he should not provide advice on any supplier that he had dealings with as COM AIR;
• For two years from his last day in post he should not work in the UK Defence market (this condition does not apply to the commission with KMPG in the terms described in this advice);
• For two years from his last day of service he should not undertake any work as a consultant that involves providing advice to any company or organisation on the terms of a bid or contract relating directly to the work of the MOD or its trading funds;
• That he should not draw on 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 on behalf of any of his clients or those he advises, nor should he make use, directly or indirectly, of his Government and/or Crown service contacts to influence policy or secure business on behalf of his clients;
• For two years from his last day of Crown service, before accepting any new commission he should make a case directly to the Committee to confirm that each individual commission he wishes to undertake would be permissible under the approved terms of the consultancy; and
• Additionally, in relation to his work with KMPG, Sir Simon will be confined to working on project Gateway and will not attend KPMG meetings on any other work, support them in business development, or give presentations at internal knowledge-sharing events or similar.

The letter containing the final advice was sent in January 2017 and Sir Simon took up the commissions with CH2M and KPMG the same month.