Decision

Advice Letter: Michael Gove, Keynote Speaker, JLA Speaker Bureau

Updated 28 October 2024

1. Business Appointment Rules Application: The Rt Hon Michael Gove, former Secretary of State for Levelling Up, Housing and Communities and Minister for Intergovernmental Relations (DLUHC). Paid appointment with JLA Speaker Bureau.

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 appointment as a keynote speaker with JLA Speaker Bureau (JLA Speakers). 

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 JLA Speakers. 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

The Committee^{[footnote 1]} noted you did not meet with nor have any official dealings with JLA Speakers in office, and therefore the risk this role could reasonably be seen as a reward for decisions made, or actions taken, in office is low.

3. The Committee’s advice

The Committee does not consider joining a speaking agency raises any particular concerns under the government’s Business Appointment Rules, provided it is subject to standard conditions which prevent improper use of information and influence.  

It is an individual’s responsibility to manage the propriety of the specific pieces of work undertaken. In particular, as the former Secretary of State for Levelling Up, Housing and Communities and Minister for Intergovernmental Relations (DLUHC), you must be careful not to offer any unfair insight as a result of your access to information and potential influence in government - which the conditions below seek to mitigate.

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 JLA Speaker Bureau 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 JLA Speaker Bureau (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 JLA Speaker Bureau (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 JLA Speaker Bureau (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 2]} 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 he takes up this work or if it is announced that you will do so.  Similarly, you must inform us if you propose to extend or otherwise change your role with the organisation as depending on the circumstances, it might be necessary for you to seek fresh advice. 

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 in the annual report.

4. Annex - Material information

4.1 The role

You informed the Committee you wish to take up a paid, part-time role as a Keynote Speaker with JLA Speakers - a speaking agency. You said JLA may provide you with opportunities to speak at various events and engagements. 

You confirmed this role would not involve contact with government. 

4.2 Dealings in office

You did not meet with JLA Speakers while in office and there is no relationship between JLA and your former departments. You also confirmed you did not have any involvement in policy, nor did you make any decisions relevant to JLA while in office. 

4.3 Department Assessment

DLUHC confirmed the details you provided in this application.

DLUHC did not have any concerns with regards to this application and recommended the standard conditions and the standard three-month waiting period that applies to all Cabinet Ministers.

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 Eric Pickles; Michael Prescott; and Mike Weir. ↩

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