Decision

Advice Letter: Natalie Evans, Senior Advisor - Policy & Ethics, Changeblock

Updated 11 July 2024

1. BUSINESS APPOINTMENT APPLICATION: Baroness Evans of Bowes Park, former Lord of the Privy Seal and Leader of the House of Lords. Paid appointment with Changeblock.

You sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointments Rules for Former Ministers (the Rules) on an appointment you wish to take up with the Changeblock as Senior Advisor - Policy & Ethics.

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 your time in office, alongside the information and influence a former minister may offer Changeblock. 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 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 risk presented

You did not meet with Changeblock during your time as a minister; nor did you make any decisions specific to the company whilst in office. Therefore, the Committee^{[footnote 1]} considered the risk this appointment could reasonably be perceived as a reward for decisions made or actions taken in office is low.

As a former minister, there are inherent risks associated with your access to privileged information and knowledge. The Cabinet Office noted you would have had access to information relating to the legislative programme for 2022-23 (including some bills relating to technology) however this information is now in the public domain and out of date. Further, it has been 11 months since you left office.

As with any application, your contacts and influence across government could offer your employer an unfair advantage. You confirmed that your proposed role would not involve any contact with government, maintaining full compliance with the House of Lords Code of Conduct.

3. The Committee’s advice

The Committee did not consider this appointment raises any particular proprietary concerns under the government’s Business Appointment Rules. The standard conditions below will sufficiently mitigate the risks in this case. These prevent you from drawing on your privileged information, contacts and influence gained in ministerial office to the unfair advantage of Changeblock.

Taking these factors into account, in accordance with the government’s Business Appointment Rules, the Committee’s advice is this appointment with Changeblock 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 become personally involved in lobbying the UK government or its arm’s length bodies on behalf of Changeblock (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 Changeblock (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 Changeblock (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. It is your personal responsibility to understand any other rules and regulations you 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 stated that Changeblock is a global carbon market technology company that develops innovative technologies for creating high integrity tradeable offsets from trustworthy and transparent sources. Its website states it is an environmental credit exchange, actionable data and insight provider for the transition to a global net-zero economy. It states ‘Changeblock increases environmental asset investment by enhancing credit integrity, transparency and trading options. We provide new risk management tools, risk-rated returns and regulatory compliance and enable more efficient transactions and quantifiable environmental impacts’.

You stated in your paid, part-time capacity as Senior Advisor - Policy & Ethics, that your responsibilities will be to:

• Provide senior counsel and advice to Changeblock’s CEO and leadership team on UK policy and regulatory developments relevant to the company.

• Be involved in the company’s internal ethics discussions to help ensure their commitment to transparency, efficiency and advanced functionality are maintained and enhanced.

You stated your role would not involve contact with government, stating you would not undertake any advocacy on behalf of the Group towards UK government ministers or officials, maintaining full compliance with the House of Lords Code of Conduct.

4.2 Dealings in office

You advised the Committee that you did not meet with Changeblock whilst in office. You said you did not have any involvement in policy, regulatory or commercial decisions that would have been specific to the company.

4.3 Departmental Assessment

The Cabinet Office confirmed the details you provided and added: [Baroness Evans]…would have had access to material relating to the legislative programme for 2022-23 (including some bills relating to technology). However, that material is (a) now in the public domain and (b) out of date.

The Cabinet Office did not have concerns regarding the appointment and recommended the standard conditions.

1. This application for advice was considered by Andrew Cumpsty; Isabel Doverty; Sarah de Gay; The Rt Hon Baroness Jones of Whitchurch; The Rt Hon Lord Pickles; Richard Thomas; and Mike Weir. Jonathan Baume was unavailable. ↩