Decision

Advice Letter: Lord Darren Mott, Non-Executive Director, SW1 Media / Millbank Global

Updated 5 March 2025

1. BUSINESS APPOINTMENT APPLICATION: Lord Darren Mott OBE, former Government Whip in the House of Lords. Paid appointment with SW1 Media Limited.

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 a paid role as a Non-Executive Director (NED) of SW1 Media Ltd, which trades as Millbank Global. 

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 Millbank Global. 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 risks presented

Millbank Global is a political and public sector communications firm. It provides services in videography, photography, graphic design, and digital branded content to allow better communication from public bodies to its audiences. In your role as a NED you said that you will be helping to grow and strategically shape the business.

You did not meet with Millbank Global while in office, nor did you make any decisions that were specific to the company. The Committee^{[footnote 1]} considered the risk that you were offered this role as a reward for decisions made or actions taken in office was low.

As a former minister, there are inherent risks associated with your general access to privileged information, contacts, and influence within government. The risks are limited given there is no direct overlap between your responsibilities in government and your proposed role. It is also relevant that you have been out of office for 11 months, providing a gap between your access to information and you taking up this role.

The Committee considered there is a significant risk you could offer an unfair advantage to an organisation which seeks to influence governments,  particularly in light of the lobbying ban that applies to all former ministers for two years on leaving office. It is relevant in mitigating this risk that Millbank Global  has confirmed your description of this role as having no involvement in lobbying.

You told the Committee that your role will focus on growing the business. There is a risk that you could offer an unfair advantage to Millbank Global by drawing on your contacts in external organisations gained in your ministerial role.

Millbank Global’s clients are unknown and you may be asked to advise onsignificant campaigns or clients in your strategic role. This raises the unknown risk that you could advise on matters that conflict with your time in office.

3. The Committee’s advice

Taking into account these factors, in accordance with the government’s Business Appointment Rules, the Committee advises this appointment with SW1 Media Limited, trading as Millbank Global 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 SW1 Media Limited/Millbank Global (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 SW1 Media Limited/Millbank Global (including parent companies, subsidiaries, partners and clients);
• for two years from your last day in ministerial office you should not undertake any work with SW1 Media Limited/Millbank Global (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;
• for two years from your last day in ministerial office, you should not become personally involved in lobbying contacts you developed during your time in office in other governments and organisations for the purpose of securing business for SW1 Media Limited/Millbank Global; and
• for two years from your last day in ministerial office, you should not advise SW1 Media Limited/Millbank Global or its clients on any work with regard to any policy which you had a material role in developing or determining as Government Whip in the House of Lords, or where you had a relationship with the company or organisation during his time in this role.

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]} You are reminded that as a Member of the House of Lords you are prevented from any paid lobbying under the House of Lords Code of Conduct. 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 Ministerial Code or otherwise.

The Business Appointment Rules explain that the restriction on lobbying means that you “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 you take up employment with this organisation(s), or if it is announced that you will do so. Please 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(s) 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.

The Rt Hon Lord Pickles

4. Annex - Material Information

4.1 The role

You described SW1 Media Limited/Millbank Global as a strategic communications consultancy. Its website states that it specialises in public affairs, crisis comms and reputation management. 

In your role as Non-Executive Director, you said that you will be helping to grow and strategically shape the business. You confirmed your role will not involve contact with government. The CEO of Millbank Global confirmed to the Committee that you will not undertake any direct or indirect lobbying in this role.

4.2 Dealings in office

You advised the Committee that you did not meet with Millbank Global 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 recommended the standard conditions.

1. This application for advice was considered by Andrew Cumpsty; Isabel Doverty; Hedley Finn OBE; Dawid Konotey-Ahulu CBE DL; The Rt Hon Lord Eric Pickles; Michael Prescott; and Mike Weir. Sarah de Gay was absent. ↩

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