Decision

Advice Letter: Lord Cameron, Chair of the Advisory Council, Oxford-Harrington Rare Disease Centre

Updated 10 December 2024

1. BUSINESS APPOINTMENT APPLICATION: The Rt Hon The Lord Cameron of Chipping Norton, former Secretary of State for Foreign, Commonwealth and Development Affairs and previously Prime Minister. Unpaid role with the Oxford-Harrington Rare Disease Centre.

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 unpaid role as Chair of the Advisory Council with the Oxford-Harrington Rare Disease Centre (OHC).

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 OHC. The material information taken into consideration by the Committee is set out in the annex below.

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

When considering this application, the Committee^{[footnote 1]} took into account this appointment as Chair of the Advisory Council is unpaid.^{[footnote 2]} Generally, the Committee’s experience is that the risks related to unpaid roles are limited. The purpose of the Rules is to protect the integrity of government by considering the real and perceived risks associated with former ministers joining outside organisations.  Those risks include: using privileged access to contacts and information to the benefit of themselves or those they represent.  The Rules also seek to mitigate the risks that individuals may make decisions or take action in office to in expectation of rewards, on leaving government. These risks are significantly limited in unpaid cases due to the lack of financial gain to the individual.  

The Foreign, Commonwealth and Development Office confirmed that there is no overlap between your role as Foreign Secretary and your proposed role with the OHC. There are inherent risks associated with your access to information, network and influence in government. You  confirmed that you will not have contact with government in this role. 

3. The Committee’s advice

The Committee did not consider this appointment raises any particular propriety concerns under the government’s Rules. The risks are appropriately mitigated by the standard conditions below, and further limited by the unpaid nature of this role. In particular, they prevent you from drawing on privileged information,contacts and influence within government to the unfair advantage of the OHC.

As a former member of the Cabinet you are subject to a standard three month waiting period. 

Taking into account these factors, in accordance with the government’s Business Appointment Rules, the Committee advises this appointment with the Oxford-Harrington Rare Disease Centre be subject to the following conditions:

• a three-month waiting period from your last day in 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 Oxford-Harrington Rare Disease Centre (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 Oxford-Harrington Rare Disease Centre (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 Oxford-Harrington Rare Disease Centre (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 from rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists, the Parliamentary Commissioner for Standards and the Registrar of Lords’ Interests.^{[footnote 3]} You are reminded that as a Member of the House of Lords you are prevented from any paid lobbying under the House of Lords Code of Conduct. 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 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.”

You must inform us as soon as you take up employment with this organisation(s), or if it is announced that you will do so. 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.

4. Annex - Material information

4.1 The role

You informed the Committee you wish to take up an unpaid, part-time role as a Chair of the Advisory Council for the Oxford-Harrington Rare Disease Centre. 

You told the Committee the following: 

• The Council aims to support the Rare Disease Centre in its mission to deliver 40 new medicines to clinical trials in the next ten years. 

• You will lead the Council in its functions of:

  • strategic guidance
  • development and fundraising
  • external engagement to drive awareness
  • building a venture fund to support the later stages of drug development for rare diseases.

You confirmed this role would not involve contact with government. 

You said that you have previously held this role before returning to government service in November 2023. At that point your engagement with OHC was paused. This role will be a resumption of your previous duties. You said that the role was declared with the Permanent Secretary at the Foreign, Commonwealth and Development Office (FCDO) and to the Prime Minister’s Independent Adviser on Ministerial Interests.

4.2 Dealings in office

You did not meet with the OHC while in office and there is no relationship between the OHC and your former department. You also confirmed you did not make any policy, regulatory or commercial decisions specific to the OHC while in office. 

4.3 Department Assessment

The FCDO confirmed the details in your application.   The FCDO recommended the standard conditions.

1. This application for advice was considered by Andrew Cumpsty; Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE DL; The Rt Hon Lord Pickles; Michael Prescott; and Mike Weir ↩

2. By unpaid the Committee means that no remuneration of any kind is received for the role.  Applicants must declare where it is agreed or anticipated they may receive remuneration or some other compensation at some stage in the future. ↩

3. 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. ↩