Decision

Advice Letter: The Rt Hon Karen Bradley MP, Member of the Parliamentary Advisory Board, House Magazine.

Updated 12 July 2021

June 2021

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 a role with the House Magazine (House). The material information taken into consideration by the Committee is set out in the below annex.

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 House.

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, and Members of Parliament, 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

The Committee ^{[footnote 1]} took into consideration that you did not have any official contact with House whilst in office other than providing interviews and you did not make any policy or contractual decisions that would have specifically affected House. The risk that this work is perceived as a reward for actions taken in office is therefore low.

The Committee noted there is a general risk that you may offer an unfair advantage by virtue of the sensitive information you had access to whilst in office. However, the Committee gave weight to the departments’ confirmation it did not consider there to be risks relating to overlap from your time in office and noted the 23 months that have now passed since you left ministerial office. Alongside these mitigating factors and the condition below preventing you from drawing on your privileged information the Committee considered the risk is sufficiently limited.

The Committee would like to draw your attention to the below conditions which prevent you from lobbying the UK government, making improper use of your contacts, advising on contracts and bids related to the UK government.

In accordance with the government’s Business Appointment Rules, the Committee advises this role with the House Magazine be subject to the same conditions as your independent consultancy:

• that you should not draw on (disclose or use for the benefit of yourself or the organisations to which this advice refers) any privileged information available to you from your time in office;

• for two years from your last day in ministerial office, you should not become personally involved in lobbying the government on behalf of the House Magazine (including clients, parent companies, subsidiaries and partners). Nor should you make use, directly or indirectly, of your government and/or ministerial contacts to influence policy, secure funding/business or otherwise unfairly benefit the House Magazine (including clients, parent companies, subsidiaries and partners); and

• for two years from your last day in ministerial office, you should not provide advice to the House Magazine (including clients, parent companies, subsidiaries and partners) 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.

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 Commons

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.”

I should be grateful if you would inform us as soon as you take up this work 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 Ministerial Code. Similarly, I should be grateful if you would inform us if you propose to extend or otherwise change your role with the organisation as depending on the circumstances, it might be necessary for you to seek fresh advice.

Once this 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.

2. Annex

3. The role

You informed the Committee that House magazine is the “in-house” publication of parliament, produced by Dods Group. The magazine has a new editor – Rosa Prince – and is setting up a board of MPs and Peers to form a Parliamentary Advisory Board.

You said your role will be as a member of the Parliamentary Advisory Board. The board will work with the Editor (Rosa Prince) and Editor-in-Chief (Alan White) to advise the editorial team on how best to serve Westminster. It will help the Editor to continue to produce non-partisan political coverage, while maintaining editorial independence and unique links to parliament.

You do not expect your role to involve contact with government.

4. Dealings in office

You stated the only contact you had with House while you were in office were limited to providing interviews to its journalists. You stated that you had no involvement in policy or contractual decisions whilst in office that would have specifically impacted House. You also said while you gave interviews to journalists in other magazines, you did not have contact with or access to sensitive information about competitors of House.

5. Department Assessment

The Northern Island Office was consulted on this appointment and confirmed the details you provided. It said, as expected, there is a relationship between the magazine and the department’s communications team as standard. It has no concerns with your appointment.

1. This application for advice was considered by Andrew Cumptsy; Sarah de Gay; Isabel Doverty; Jonathan Baume; The Rt Hon Lord Pickles; Dr Susan Liautaud; Richard Thomas; Mike Weir; and Lord Larry Whitty. ↩