Decision

Advice Letter: Syed Kamall, Trustee, Intergenerational England

Updated 21 August 2023

1. BUSINESS APPOINTMENT APPLICATION: Lord Syed Kamall, former Parliamentary Under Secretary of State at the Department for Digital, Culture, Media and Sport (DCMS) and former Parliamentary Under Secretary of State for Technology, Innovation and Life Sciences at the Department of Health and Social Care (DHSC). Unpaid appointment with Intergenerational England as a Trustee 

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 as Trustee with Intergenerational England. 

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 Intergenerational England. 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

When considering this application, the Committee^{[footnote 1]} took into account this appointment as Trustee^{[footnote 2]} is unpaid. 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 to 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 minister, this proposed role has some overlap with your time in office. Your former departments^{[footnote 3]} confirmed it did not consider you have access to particular information that raises risks under the Rules.  The unpaid nature of this appointment also limits the real and perceived risk of you making improper use of information and contacts from your time in ministerial office for personal benefit. 

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 Intergenerational England 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 Intergenerational England (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 Intergenerational England (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 Intergenerational England (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. 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.

4. Annex - Material information

4.1 The role 

Intergenerational England is an innovative initiative that aims to address age segregation in British society and ‘promote intergenerational connections for the betterment of communities across the nation’.

You wish to take up an unpaid, part-time role as Trustee. You stated the responsibilities of a Trustee will include: 

• Provide Strategic Guidance: Offering your insights and expertise to help shape the long-term vision, goals, and strategies of Intergenerational England.
• Governance Oversight: Participate in supporting governance decisions, ensuring that the initiative operates in alignment with its mission and objectives.
• Advocacy and Promotion: Support in advocating for the importance of intergenerational connections and the work of Intergenerational England.
• Policy and Program Development: Contribute to the design, development, and evaluation of programs, policies, and initiatives that promote intergenerational engagement and wellbeing.
• Community Engagement: Engage with diverse communities and stakeholders to gather insights, ensure inclusivity, and promote the benefits of intergenerational activities.

You stated your role will not involve contact with government and you informed the organisation you are unable to contact government ministers or departments for a period of two years since you ceased being a minister.

You noted Intergenerational England was not yet formed whilst you were in office. You also stated that when you were a minister, you became interested in social prescribing and the impact of music on health. After you left office, you were invited to speak at a conference organised by the charity Intergenerational Music Making and have supported the charity since. Intergenerational Music Making has now set up Intergenerational England. 

4.2 Dealings in office 

You advised the Committee that did not meet with; did not make any policy or regulatory decisions; nor have access to sensitive information specific to Intergenerational England. 

4.3 Departmental Assessment 

DHSC and DSIT confirmed the details you provided and stated:

• that you were not involved in any decisions specific to Intergenerational England; and
• that they did not consider you to have had any access to particular sensitive information that raises risks under the Rules.

The departments did not have any concern with the appointment and recommended the standard conditions.

1. This application for advice was considered by Andrew Cumpsty; Sarah de Gay; Isabel Doverty; The Rt Hon Baroness Jones of Whitchuch; The Rt Hon Lord Eric Pickles; and 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. ↩

3. Following the recent Machinery of Government Changes, your former role as Your role as Parliamentary Under Secretary of State at the Department for Culture, Media and Sport now sits with the Department for Science, Innovation and Technology (DSIT). ↩