Decision

Advice Letter: Boris Johnson, Center for European Policy Analysis

Updated 2 May 2024

1. BUSINESS APPOINTMENTS APPLICATION FOR ADVICE: The Rt Hon Boris Johnson, former Prime Minister and Foreign Secretary. Unpaid appointment with the Center for European Policy Analysis.

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 unpaid role you want to take up with the Center for European Policy Analysis (CEPA).

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 the Foundation. 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 risk presented

When considering this application, the Committee ^{[footnote 1]} took into account this appointment 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 the 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 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.  

As a former Prime Minister, this proposed role overlaps with your time in office.  The Committee noted there could be a perceived risk you had access to relevant privileged information and knowledge, which could unfairly benefit CEPA. However, the Committee noted the department’s comments of the factors that mitigate this risk:  1. that you have been out of office for 13 months; 2. there is much information in the public domain regarding the government’s policies on Ukraine; 3. You had no involvement with CEPA whilst in office.

Furthermore, the unpaid nature of this appointment limits the real and perceived risk of you making improper use of information you had access to while in office for your personal benefit.

There may be circumstances where you may be in contact with government officials as part of your role. Where contact is instigated by government departments/officials it would not be contrary to the lobbying ban - which is imposed on all former senior officials for 2 years on leaving office.

3. The Committee’s advice

The Committee did not consider this appointment raises any particular proprietary concerns under the government’s Business Appointment Rules. Whilst there are inherent risks associated with your access to sensitive information and contacts, the standard conditions below, preventing you from drawing on your privileged information and using your contacts to the unfair advantage of your new employer, will sufficiently mitigate in this case.

Taking into account these factors, in accordance with the government’s Business Appointment Rules, the Committee advises this appointment with the Center for European Policy Analysis 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 arms’ length bodies on behalf of CEPA (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 CEPA (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 CEPA (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 arms’ 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/House of Lords Commissioners for Standards. It is an individual’s personal responsibility to understand any other rules and regulations they may be subject to in parallel with this Committee’s advice.

You must inform us as soon as you take up employment with this organisation, or if it is announced that you will do so and we will publish this letter on our website. Any failure to do so may lead to a false assumption being made about whether you had complied with the Rules.

You must 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

4. Annex - Material Information

4.1 The role

You are applying for advice on taking up an appointment at the Center for European Policy Analysis, as a member for the International Leadership Council.  You state that you will be called upon ad hoc to contribute to their work on Ukraine. 

CEPA’s website describes itself as a non profit, not partisan foreign policy think tank, based in Washington DC, USA.  It states that they aim to strategically ensure strong and enduring transatlantic alliances by using research, analysis and engagement to identify trends affecting democracy, security, defence to government officials.  They aim to help transatlantic businesses navigate changing landscapes and build a network of future leaders.

You state that you were approached by the President and CEO, Alina Polyakova. She is listed as your contact at CEPA on your application form. In May 2023, an article in Politico reported that you had visited Texas where you spoke to a number of organisations, including CEPA, about the ongoing war in Ukraine. It was following this visit that you were approached by CEPA. A link to article has been provided: https://www.politico.eu/article/send-for-agent-bojo-boris-johnson-dispatched-to-texas-to-boost-republican-support-for-ukraine/ 

You said that there will not be any engagement with the government in this role.

4.2 Dealings in office

You said that: 

1.  As Foreign Secretary and Prime Minister you had dealings with various foreign policy think tanks, though none of these dealings included discussions around the development of policy affecting the sector, or regulatory work.
2. You had no contact with CEPA whilst in office.
3. You did not have access to privileged information pertaining to this role whilst in office.
4. No contracts or commercial decisions were taken regarding CEPA.

4.3 Departmental Assessment

The Cabinet Office provided their views on this application.

Cabinet Office confirmed that:

1. You made no policy decisions affecting CEPA.
2. You did not have any contact with CEPA while in office.
3. There was no formal departmental relationship with CEPA (although think tanks are stakeholders in the sense that their publications can inform a wider discussion on government policy).
4. As Prime Minister you would have had access to a rage of policy advice and in-depth knowledge of government processes. The department considers this to be mitigated by the amount of time (13 months) that have passed since you left office, as government policy has moved on and so this is unlikely to offer an unfair advantage to CEPA. 
5. There were no other issues or concerns with this appointment.

The Cabinet Office had no concerns with the appointment and approved the appointment subject to standard conditions.

1. This application for advice was considered by  Andrew Cumpsty, Isabel Doverty, Sarah de Gay, The Baroness Jones of Whitchurch, Rt Hon the Lord Pickles, 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. ↩