Decision

Correspondence from ACOBA to Ms Pow regarding a breach of the Rules (Hestercombe Gardens Trust)

Published 2 April 2025

Dear Rebecca, 

Thank you for your correspondence to the Advisory Committee on Business Appointments (ACOBA) about your role with Hestercombe Gardens Trust.

Under the Ministerial Code and the government’s Business Appointment Rules (the Rules) all former Ministers are obligated to seek advice for two years after leaving office. The Code states that ‘Former ministers must ensure that no new appointments or employment are taken up, before ACOBA is able to provide its advice’.

You informed ACOBA you took up an unpaid role with Hestercombe Gardens Trust in October 2024, prior to seeking the Committee’s advice in January 2025. You said that commencing the role without advice was unintentional and that, once you realised that unpaid roles were subject to the Rules, you sought to remedy the situation by contacting ACOBA. 

You acknowledged the error on your part and apologised. You added that the role in question is unpaid and for a local charity that you were closely involved with for many years prior to entering Parliament. 

In ACOBA’s experience, the risks under the Rules in unpaid appointments are limited. These cases will normally be subject to a standard set of conditions preventing individuals from drawing on privileged information; and lobbying the UK government.Failing to await advice before announcing the role is a clear breach of the government’s Rules and the requirements of the ministerial code. ACOBA’s established practice is not to provide advice in these circumstances.  

Please see the correspondence enclosed, reporting this matter to the government, as owner of the Rules. In line with ACOBA’s commitment to transparency, the exchange of correspondence will be published on our website. This letter will be copied to the Cabinet Office, as the owner of the Rules; ACOBA’s letter to the Cabinet Office is enclosed.

The Rt Hon Lord Pickles

Copied to:
The Rt Hon Pat McFadden MP, Chancellor of the Duchy of Lancaster and Minister for Intergovernmental Relations;
The Rt Hon Nick Thomas-Symonds MP, Minister for the Cabinet Office;
Darren Tierney Director General, Propriety and Ethics, Cabinet Office.


0.1 Enclosure:

  • ACOBA’s letter to the Cabinet Office