Decision

Advice Letter: Earl of Courtown, Chairman of The Feathers 90 Club, The Feathers Association

Published 26 March 2025

1. BUSINESS APPOINTMENT APPLICATION: The Earl of Courtown, former Deputy Chief Whip, House of Lords (Captain of The Queen’s Bodyguard of the Yeomen of the Guard). Paid appointment with The Feathers Association. 

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 Chairman of The Feathers 90 Club for The Feathers Association (TFA).

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 TFA as a former minister. 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

You did not meet with, nor have any involvement in any decisions specific to TFA during your time in office. The Committee[1] considered the risk this appointment could reasonably be perceived as a reward for decisions made, or actions taken in office, is significantly limited.

As a former minister, there are inherent risks associated with your access to privileged information, given that your time in office involved promoting and helping move a wide range of policies through the legislative process. As such, you will have had access to privileged information that could benefit many organisations, including TFA – though your former department is not aware of anything specific that could offer an unfair advantage. The risks are therefore considerably low given there is no policy or commercial overlap between TFA and your former department.

Given your former position, there are risks associated with your contacts and influence within government and the potential for TFA to gain unfair access and influence as a result. The Committee considered it significant that you confirmed your role will not involve any contact and/or dealings with government.

3. The Committee’s advice 

The Committee did not consider this appointment to raise any particular propriety concerns under the government’s Rules, subject to the conditions below. The risks noted above in relation to your access to information and influence are appropriately mitigated by the standard conditions. In particular, they prevent you from drawing on your privileged information, contacts and influence within government, to the unfair advantage of TFA.

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

• 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 undertake any work with The Feathers Association (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;

• 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 Feathers Association (including parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or Crown service to influence policy, secure business/funding or otherwise unfairly advantage The Feathers Association (including parent companies, subsidiaries, partners and clients); and

The advice and the conditions under the government’s Business Appointment Rules relate to an individual’s 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.[2] 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.”  This Rule is separate and not a replacement for the Rules in the House.

You must inform us as soon as you take up this role, 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.

4. Annex- material information

4.1 The role 

You said you have been offered a paid, part-time appointment with The Feathers Association (TFA) as Chairman of The Feathers 90 Club. You have stated that The Feathers Association is a “charity whose mission is to provide aspirational youth and community programmes that empower and inspire the lives of others”. According to TFA’s website it is a charity that aims to provide opportunities for children, young people and communities to develop in a positive way through informal education, sporting, cultural and recreational activities provided by the charity. In your (paid) role as Chairman you will: - lead and embody the mission of The Feathers 90 Club as a fundraising entity for The Feathers Association;

• develop and implement strategic objectives that align with the club’s goals, focusing on growing the club’s membership and fundraising success;

• represent The Feathers 90 Club at public events, networking functions, and media engagements to enhance visibility and attract potential members; and

• advocate for The Feathers Association’s mission and the club’s role within the community, strengthening its brand and impact.

You have confirmed that you would have no contact with, or lobbying of, government.

4.2 Dealings in office

You said that as a former minister you did not have any involvement in policy, contractual and/or commercial decisions specific to TFA. You also said that you did not have any official dealings/ contact with TFA during your time in office, and that there is no departmental relationship with TFA. You stated that you did not have any access to privileged information.

4.3 Departmental assessment

The Cabinet Office was consulted on this appointment. The department confirmed the above information and provided the following: - You did not make any regulatory, policy or contractual/commercial decisions that would have affected TFA. - You did not meet with TFA during your time in office. - There is no relationship between the Cabinet Office and TFA. - You do not possess sensitive information that would confer an unfair advantage to TFA.

The departments recommended the standard conditions.

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[1]  This application for advice was considered by Andrew Cumpsty; Sarah de Gay; Isabel Doverty;

Hedley Finn OBE;The Rt Hon Lord Pickles; Michael Prescott; and Mike Weir. Dawid Konotey-Ahulu CBE DL and The Baroness Thornton were unavailable.

[2] All Peers are prevented from paid lobbying under the Code of Conduct for Members of the House of Lords. Advice on your obligations under the Code can be sought from the Registrar of Lords’ Interests.