Decision

Advice Letter: The Rt Hon Suella Braverman KC MP, Columnist, The Telegraph

Published 27 March 2024

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon Suella Braverman KC MP, former Secretary of State for the Home Department and prior to this, the Attorney General. Paid appointment with The Telegraph.

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 paid role as Columnist with The Telegraph.

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 your time in office, alongside the information and influence you may offer the The Telegraph. 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 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.

2. The Committee’s consideration of the risks presented

The Committee ^{[footnote 1]} noted you meet with The Telegraph and many other media outlets when  briefing the media as part of your ministerial duties.  The Home Office and Attorney General’s Office confirmed you made no decisions specifically related to The Telegraph. The Committee considered the risk you could be seen to have been offered this role as a reward for decisions made, or actions taken, in office was low.

As a former Cabinet Minister, there are inherent risks associated with your privileged access to information and contacts which may be seen to be of general use to any media company. The risk associated with your access to information is limited given the transparent nature of this role as a regular columnist.  Further, you are not working on commercial business matters for the media outlet.

3. The Committee’s advice 

The Committee did not consider this appointment raises any particular proprietary concerns under the government’s Rules. The standard conditions below appropriately mitigate the risks associated with withdrawing on privileged information and making improper use of contacts and influence within government to the unfair advantage of The Telegraph.

As a former Cabinet Minister you are subject to a three month wait before taking up appointments as set out in the Rules.

In accordance with the government’s Business Appointment Rules, the Committee advises this role with The Telegraph be subject to the following conditions: 

• a waiting period of three months from your last day in ministerial office; 

• 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;

• 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 The Telegraph (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 The Telegraph (including parent companies, subsidiaries, partners and clients); and

• for two years from your last day in ministerial office, you should not undertake any work with The Telegraph (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 advice and the conditions under the government’s Business Appointment Rules relate to your previous role in government only; they are separate to rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists or the Parliamentary Commissioner for Standards ^{[footnote 2]}. You are reminded that all Members of Parliament have a separate ban on paid lobbying under the Parliamentary Code of Conduct, whilst they remain a sitting MP. 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 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. You must 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.

The Rt Hon Lord Pickles 

4. Annex - Material information 

4.1 The role 

You wish to take up a paid, part-time role as columnist for The Telegraph. The Telegraph is a  national British daily broadsheet newspaper published in London by Telegraph Media Group. You stated your role will not involve contact with government. 

You informed the Committee that you have done one-off pieces of work for the Telegraph but now wish to take up, sign a contract, for a regular appointment with the Telegraph as a columnist.

4.2 Dealings in office

You advised the Committee that during your time in office, you periodically did interviews/briefings with The Telegraph, as you did other media outlets. You stated you did not make any decisions specific to the newspapers nor do you have access to sensitive information specific to them. 

4.3 Departmental Assessment 

The Home Office and Attorney General’s Office confirmed the details above and added the following:

• You gave interviews to the Daily Telegraph and several media outlets. 
• You made no decisions relating to the Daily Telegraph or other media outlets
• As Attorney General and the Home Secretary you had access to confidential and legally privileged information which if disclosed inappropriately (eg in articles or interviews) could be considered to offer an unfair insight/advantage to The Telegraph.

The Home Office and Attorney General’s Office recommended the standard conditions and the standard 3 month waiting period applied to all Cabinet Ministers would be appropriate.

1. This application for advice was considered by Andrew Cumpsty; Isabel Doverty; Hedley Finn OBE; The Rt Hon Baroness Jones of Whitchurch; The Rt Hon Lord Pickles; Michael Prescott; and Michael Weir. Dawid Konotey-Ahulu was unavailable and Sarah de Gay was recused. ↩

2. All Peers and Members of Parliament are prevented from paid lobbying under the the House of Commons Code of Conduct and the Code of Conduct for Members of the House of Lords. Advice on your 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. ↩