Decision

Summary of business appointment applications - Sir Julian Brazier

Updated 20 June 2018

Sir Julian Brazier left his role as Minister for Reserves at the MOD in July 2016

1. Non-Executive Director at Samson DVM Limited (Samson)

Sir Julian sought the Committee’s advice about a paid, part-time, role as Non-Executive Director at Samson. Samson is a start-up which will focus on digital, virtual and augmented reality solutions to a number of training and maintenance areas, mainly in Defence.

Sir Julian said the role will be to help the Board of Samson identify areas not currently considered, where digital, virtual and augmented reality can substitute for expensive and time-consuming physical procedures; identify areas where Samson’s products can save money; and navigate the field of defence and compliance issues. He explained that his role may involve contact with Government, though not likely with Ministers or officials he met whilst in ministerial office.

When considering the application, the Committee took into account the MOD’s confirmation there was no evidence Sir Julian had any contact with Samson, or its parent company during his time in ministerial office; and that he has no commercially sensitive information that would give Samson an unfair advantage over competitors.

The Committee also noted that Samson is a relatively new business, incorporated on 2 November 2017; the MOD confirmed it has no contracts with Samson or its parent company; Sir Julian’s ministerial portfolio had no direct relationship to this role and the work of Samson; and it had been approximately 17 months since he left ministerial office.

The Committee advised that, in accordance with the Government’s Business Appointment Rules, the appointment be subject to the following conditions:

• he should not draw on (disclose or use for the benefit of himself or the persons or organisations to which this advice refers) any privileged information available to him as a Minister;
• for two years from his last day in Crown service, he should not provide advice on the terms of a bid or contract relating directly to the work of the UK MOD or its trading funds; and
• for two years from his last day in Crown service, he should not become personally involved in lobbying the UK Government on behalf of Samson Ltd, its partners, parent company or subsidiaries, nor should he make use, directly or indirectly, of his contacts in Government and/or Crown service to influence policy or secure funding or business on behalf of Samson, its partners, parent company or subsidiaries.

The letter containing the final decision was sent in December 2017 and the appointment was taken up later that month.

2. Chairman at Pathway Risk Management (Pathway)

Sir Julian sought the Committee’s advice about his role as Chairman at Pathway.

The Committee wrote to Sir Julian and noted with concern that he sought advice after he had taken up the appointment. The Committee refused to give retrospective advice.

However, the Committee did wish to put into the public domain that:

• Pathway is a company which provides counter terrorist and related services for organisations responsible for crowded events and spaces.
• He told the Committee this is a paid, part-time role, in which he will provide strategic direction and accountability; chair meetings; provide contacts in a range of areas; and assist with media communications. He noted this role will not include any contact with Government.
• He stated he had no contact with Pathway during his last two years in office; that he had no contractual dealings with the company or its competitors; and had no access to any commercially sensitive information.
• He also noted that as an MP, he had “discussions and briefings on security issues from a range of experts and through a range of fora. This occurred at a national level and sometimes at a regional of constituency level (via Kent Police).”

The Committee also drew Sir Julian’s attention to the normal restrictions it would impose prohibiting the misuse of privileged information obtained while in public office; and that it would expect him to refrain from making use, directly or indirectly, of privileged access derived from his role as a Minister to influence Government policy, or seek business on behalf of Pathway. The Committee also reminded Sir Julian that advice should be sought on all appointments, paid or unpaid, before they are taken up or announced.

The letter containing the Committee’s views was sent in January 2018. In a second letter with regard to this role, the Committee clarified that it does not consider it would be appropriate for Sir Julian to have any contact with Government, including the Home Office, to discuss issues relating to the private security industry.

3. Member of a Reference Group at the Royal United Services Institute for Defence and Security Studies (RUSI)

Sir Julian sought the Committee’s advice about the part-time, unpaid role as a Member of a reference group at RUSI, the independent British defence and security think tank, to support a study on MOD Accommodation.

The Committee wrote to Sir Julian and noted with concern that he sought advice after he had taken up the appointment. The Committee refused to give retrospective advice.

However, the Committee did wish to put into the public domain that:

• Sir Julian said he was invited to join an informal reference group for a RUSI (the independent British defence and security think tank) study on MOD Accommodation in April 2017, carried out by RUSI staff led by Dr John Louth and sponsored by Nationwide Building Society as part of their Corporate Social Responsibility Programme. This followed on from a pamphlet ha had written jointly with Dr Louth, which was published by the Centre for Social Justice in February 2017.
• He said the outcome of the study is likely to be published in the spring of 2018 and its purpose is to launch a major lobbying effort to persuade MOD to change its accommodation strategy.
• He said his role involves attending occasional meetings, reviewing draft text and will involve attending and assisting the launch event, which representatives of the MOD are likely to attend.
• He said this work did not involve matters he had direct oversight of whilst in ministerial office, but he did have some knowledge of the issues and potential solutions. He said this was a part-time role and he was not being paid for this work.

The Committee also drew Sir Julian’s attention to the normal restriction it would impose prohibiting the misuse of privileged information obtained while in public office and that it would expect him to refrain from making use, directly or indirectly, of privileged access derived from his role as a Minister to influence Government policy on behalf of RUSI. The Committee noted this would include having no involvement in lobbying of the MOD on changing its accommodation strategy.

The Committee also reminded Sir Julian that advice should be sought on all appointments, paid or unpaid, before they are taken up or announced.

The letter containing the Committee’s views was sent in January 2018.

Baroness Helen Liddell recused herself from this application.

4. Member, at the South East Reserve Forces’ and Cadets’ Association (SERFCA)

Sir Julian sought the Committee’s advice on taking up an appointment, as a Member, at South East Reserve Forces’ and Cadets’ Association. The Reserve Forces’ and Cadets’ Association (RFCA) is comprised of 13 individual, regional, associations across the UK, which are publicly funded. Sir Julian said his role will be to attend meetings; occasionally visit Reserve and Cadet Units; and attend the annual meeting in Parliament.

The Committee noted the MOD confirmed Sir Julian had overall responsibility for the RFCA; but that he would not have had direct responsibility for its funding or policy issues. Rather the RFCA’s work is directed by the three Services, and some of the MOD’s agencies, through statutory agreements; and funding is agreed and authorised at official level. As Sir Julian had no direct involvement in decisions affecting the RFCA and is an unpaid position, the Committee considered there was little risk this role could be seen as a reward.

The Committee noted this role is directly related to the area for which Sir Julian had ministerial responsibility; and the MOD stated he would have had access to confidential information about Reserves; RFCAs; and the recruitment of military personnel. However, the MOD also confirmed this information is no longer current - as it has now been approximately 19 months since he left ministerial office.

The Committee took into account there is a chance Sir Julian might have some contact with Government throughout his role at SERFCA, given its function and reporting regime; but considered that, if any possible contact is in line with the statutory and routine reporting responsibilities of SERFCA, this would not be improper. Whilst each RFCA has its funding agreed and allocated by the MOD, it would be improper if there was any suggestion he could influence these funding agreements. The Committee therefore imposed the conditions below to make clear that any use of his contacts across Government/Whitehall to lobby Government on behalf of SERFCA, or its partner associations, would be inappropriate.

The Committee advised that, in accordance with the Government’s Business Appointment Rules, the appointment be subject to the following conditions:

• he should not draw on (disclose or use for the benefit of himself or the persons or organisations to which this advice refers) any privileged information available to him as a Minister; and
• for two years from his last day in ministerial office, he should not become personally involved in lobbying the UK Government on behalf of the South East Reserve Forces’ and Cadets’ Association or its partner associations. Nor should he make use, directly or indirectly, of his contacts in Government and/or Crown service to influence policy or secure funding on behalf of the South East Reserve Forces’ and Cadets’ Association or its partner associations.

The letter containing the Committee’s views was sent in February 2018 and the post was taken up in March 2018.

5. Trustee at the Summer Camps Trust (the Trust)

Sir Julian sought the Committee’s advice about an unpaid role as a Trustee at the Trust, an organisation which works with several others, including the National Citizens’ Service, and promotes outdoor residential camps for children and young people, especially from disadvantaged backgrounds.

The Committee wrote to Sir Julian and noted with concern that he sought advice after he had taken up the role. The Committee refused to give retrospective advice.

However the Committee did wish to put in the public domain that:

• He became a Trustee at the Trust in 2017;
• He noted that it is possible this role will include future contact with Government, but that he had not had any thus far and that there are no plans to at present; and
• The Trust was not in existence whilst he was in ministerial office - he stated this appointment is not connected to his role as a Minister.

The Committee also drew Sir Julian’s attention to the normal restriction it would impose prohibiting the misuse of privileged information obtained while in public office. It also noted that as it is possible that Sir Julian may have contact with Government in this role, the Committee reminded him that it would expect him to refrain from making use, directly or indirectly, of privileged access derived from his role as a Minister to influence Government policy or secure funding on behalf of the Trust or its partners.

The letter containing the Committee’s views was sent in January 2018.

6. Member, Council of the Air League

Sir Julian sought the Committee’s advice about an unpaid role as a Member of the Council of the Air League.

The letter containing the Committee’s consideration and the conditions imposed on the appointment was sent in April 2018 and the post was taken up in May 2018.