Decision

Summary of business appointments applications - Dame Lin Homer

Updated 4 July 2018

Dame Lin Homer left her role as Permanent Secretary and Chief Executive, HMRC, in April 2016.

1. Board Member, Centre for Ageing Better; Board Member, the Stefanou Foundation

Dame Lin Homer sought the Committee’s advice about taking up positions on the Boards of the Centre for Ageing Better and the Stefanou Foundation.

Dame Lin explained that she would attend four meetings a year of each Board and occasionally carry out other duties such as attending strategy away days.

The Cabinet Secretary advised the Committee that he does not think that the proposed appointments could be seen as improper and has no reservations about them.

The Committee noted that these appointments are unpaid and that there is no connection between them and Dame Lin’s previous role as Permanent Secretary and Chief Executive at HMRC. Consequently, the Committee concluded that there is no risk of them being perceived as a reward.

The Committee took into account Dame Lin’s statement that both organisations are doing work in which Government has an interest and that there is an intention that the findings of their research will be shared with Government. In light of this the Committee considered it appropriate to clarify the lobbying ban to make clear that Dame Lin is not precluded from reporting to Government on the activities of the Centre for Ageing Better or the Stefanou Foundation but should not make use, directly or indirectly, of her contacts in Government to influence policy or secure funding.

When considering this application the Committee was also mindful that 16 months had passed since Dame Lin left Government.

The Prime Minister accepted the Committee’s advice that, in accordance with the Government’s Business Appointment Rules, these appointments be subject to the following conditions:

• She should not draw on (disclose or use for the benefit of herself or the persons or organisations to which this advice refers) any privileged information available to her from her time in Crown service; and
• For two years from her last day in service, Dame Lin Homer should not become personally involved in lobbying the UK Government on behalf of the Centre for Ageing Better and the Stefanou Foundation. This is not intended to prevent her reporting to Government on the activities of the Centre for Ageing Better or the Stefanou Foundation but it would prevent her from making use, directly or indirectly, of her contacts in Government and/or Crown service to influence policy or secure funding on their behalf.

The letter containing the final advice was sent in August 2017 and Dame Lin took up these appointments in September 2017.

2. Public Interest Member, Council of the Institute of Chartered Accountants to Scotland

Dame Lin Homer sought the Committee’s advice about taking up a paid, part-time role as a Public Interest Member on the Council of the Institute of Chartered Accountants to Scotland (ICAS).

In considering this application the Committee took into account that ICAS accredits chartered accountants who represent taxpayers so there is regular interaction between ICAS and HMRC. ICAS is one of a number of representative bodies, all of whom Dame Lin met on an occasional basis as CEO of HMRC. The Committee is aware that Dame Lin was responsible for staff in the Commercial Directorate who let training contracts to ICAS but neither she nor the CEO Office had any direct involvement in these contracts.

The Committee felt that it was an important consideration in this case that eight months had passed since Dame Lin had left Crown service. It also placed weight on Dame Lin’s assurance that she would not lobby or interact with HMRC on behalf of the Institute.

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

• she should not draw on any privileged information available to her from her time in Crown service;
• for two years from her last day in service, she should not become personally involved in lobbying the UK Government on behalf of ICAS or its members, or make use, directly or indirectly, of her contacts in Government and/or Crown service to influence policy or secure business on behalf of ICAS or its members; and
• for two years from her last day of service, she should not have any contact with HMRC on behalf of ICAS, or provide advice to ICAS on any matter, or the terms of any bid or contract, relating directly to the work of HMRC.

The letter containing the final advice was sent in December 2016 and Dame Lin took up the appointment in April 2017.

3. Suffolk County Council

Dame Lin sought the Committee’s advice about taking up a part-time role to undertake a review of members’ remuneration at Suffolk County Council.

The Committee noted that as Chief Executive of HMRC Dame Lin had been involved in the development and administration of departmental tax policy. However, this impacts on all organisations and her appointment would not therefore afford any an unfair advantage.

The Committee also took into consideration that Dame Lin had no official dealings with Suffolk County Council whilst in office and Dame Lin’s former department had no concerns about this appointment.

The Prime Minister accepted the Committee’s advice that, in accordance with the Government’s Business Appointment Rules, the position be subject to the following conditions:

• she should not draw on (disclose or use for the benefit of herself or the organisation to which this advice refers) any privileged information available to her from her time in Crown service; and
• for two years from her last day in service, she should not become personally involved in lobbying the UK Government on behalf of Suffolk County Council.

The letter containing the final advice was sent in December 2016 and Dame Lin took up the role later that month.

4. Non-executive board member, Community Action Suffolk (CAS)

Dame Lin Homer sought the Committee’s advice about taking up a part-time role as a non-executive board member of Community Action Suffolk (CAS).

In considering the application, the Committee took into account that this is an unpaid position. Dame Lin has informed the Committee that the appointment is not likely to include any contact or dealings with her former department or government more generally.

Dame Lin has declared that she had no contractual dealings with her prospective employer over her last two years of service and that she had no access to commercially sensitive information about any of its competitors.

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

• she should not draw on (disclose or use for the benefit of herself or the organisation to which this advice refers) any privileged information available to her from her time in Crown service; and
• for two years from her last day in service, she should not become personally involved in lobbying the UK Government on behalf of CAS or those it represents or supports.

The letter containing the final advice was sent in October 2016 and Dame Lin took up the appointment soon after.

5. Member of the University of Birmingham Council

Dame Lin sought the Committee’s advice about becoming a member of the University of Birmingham Council.

When it considered this application, the Committee took into account that this is an unpaid position. It was also mindful that Dame Lin’s relationship with the university is longstanding and predates her move to the civil service.

It noted that as Chief Executive of HMRC Dame Lin had been involved in the development and administration of departmental tax policy. However, this impacts on all organisations of this nature and her appointment would not therefore afford the University an unfair advantage.

The Committee considered that the standard three-month waiting period between leaving paid civil service employment and taking up an outside appointment that usually applies for Permanent Secretaries, should apply in this case.

The Prime Minister accepted the Committee’s advice, that in accordance with the Government’s Business Appointment Rules, this appointment be subject to the following conditions:

• She should not take up this appointment until 29 June 2016;
• She should not draw on any privileged information available to her from her time in Crown service;
• For two years from her last day in service, she should not become personally involved in lobbying the UK Government on behalf of the University of Birmingham.

The letter containing the final advice was sent in May 2016 and Dame Lin took up the role at the end of June 2016.

6. Saïd Business School, Oxford University

Dame Lin sought the Committee’s advice about taking up a role at Saïd Business School, Oxford University (SAID).

When considering the application, the Committee noted Dame Lin confirmed she had previous contact with SAID and some involvement with an existing contract with it, but noted that this was limited to placing employees on the Government’s Major Projects Leadership Academy (MPLA) - a contract managed by the Cabinet Office and widely supported by Government.

The Committee took into account that Dame Lin did have broad access to sensitive information, but considered it is not a risk specific to this appointment as she would have had access to information on all commercial entities, including universities; and that it had been approximately 17 months since she left office.

The Committee considered that given Government has a relationship with SAID in relation to the MPLA; and Government funding an policies that may affect Oxford University, there is a chance Dame Lin may have contact with Government. As such, the Committee made clear that any use of Dame Lin’s contacts for the benefit of SAID or Oxford University, would be inappropriate.

The Prime Minister accepted the Committee’s advice that, in accordance with the Government’s Business Appointment Rules, this appointment be subject to the following conditions:

• she should not draw on (disclose or use for the benefit of herself or the organisation to which this advice refers) any privileged information available to her from her time in Crown service; and
• for two years from her last day in Crown service, she should not become personally involved in lobbying the UK Government on behalf of SAID Business School, the University of Oxford or its students, nor should she make use, directly or indirectly, of her contacts in Government and/or Crown service to influence policy or secure funding on behalf of SAID Business School, the University of Oxford or its students.

The letter containing the final advice was sent in September 2017.