1. BUSINESS APPOINTMENTS APPLICATION FOR ADVICE: The Rt Hon Chloe Smith MP, former Secretary of State for the Department of Science, Innovation, and Technology. Paid appointment with PA Consulting Group Ltd. 

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 Strategic Adviser for PA Consulting Group Ltd (PA Consulting). 

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 PA Consulting, as a former minister. 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

Whilst your former department, the Department for Science, Innovation and Technology (DSIT), has contractual relationships with PA Consulting, you had no involvement and made no policy, regulatory or commercial decisions that specifically affected PA Consulting. Therefore, the Committee^{[footnote 1]} considered that the risk is low, that this role could be seen as a reward for your decisions in office.

There is a general overlap between your role as Secretary of State for Science, Innovation and Technology and your proposed role with PA Consulting, given that both focus on innovation and technology. As such, there is a risk related to your access to sensitive information. However, there are mitigating factors that limit the real and perceived risk that the information you possess could provide PA Consulting an unfair advantage: 

• you were at the department for only three months covering maternity leave;
• policy matters that you worked on have now been published in the AI white paper;^{[footnote 2]} 
• there is now a different administration in place and the direction of policy is changing; 
• you have now been out of office for 15 months, creating a significant gap between your access to information and your role with PA Consulting. 

Given that PA Consulting’s clients and the precise pieces of work that you will undertake are unknown, there is also a risk related to a potential overlap with your time in office. The Committee considered this was limited given your role with PA Consulting is internal.

You told the Committee that it is not your intention to have contact with government in this role, nor lobby on the behalf of PA Consulting or its clients.

3. The Committee’s advice 

The Committee considered the risks associated with your access to information to be limited for the reasons above. To address the risk associated with PA Consulting’s unknown clients, the Committee has imposed a further condition as is standard in such cases. This makes it clear, you should not advise on work with regard to any policy you had material involvement in or responsibility for in your recent time as Secretary of State for Science, Innovation and Technology.

PA Consulting has confirmed to the Committee in writing its adherence to the conditions set out in this advice. In particular, PA Consulting said it will not ask you to advise on matters with regard to any policy you had involvement in or responsibility for when Secretary of State for Science, Innovation and Technology.

The remaining conditions below adequately mitigate the risks of  improper use of privileged information, contacts and influence to the company’s unfair advantage. 

In accordance with the government’s Business Appointment Rules, the Committee advises that this appointment with PA Consulting Group Ltd 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 any of its arm’s length bodies on behalf of PA Consulting Group Ltd (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 PA Consulting Group Ltd  (including parent companies, subsidiaries, partners and clients); 

• for two years from your last day in ministerial office, you should not provide advice to or on behalf of PA Consulting Group Ltd (including parent companies, subsidiaries, partners and clients) 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 any of its arm’s length bodies; and

• for two years since your last day in office, you should not advise PA Consulting Group Ltd or its clients on any work with regard to any policy decisions which you had a material role in developing or determining, or where you had a relationship with the relevant client during your time as Secretary of State for Science, Innovation and Technology. 

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 3]} 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 Civil Service Code or otherwise.

The Business Appointment Rules explain that the restriction on lobbying means that the former Crown servant/Minister “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 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.

Once the appointment 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 

PA Consulting is a professional services firm that works with public, private and third-sector organisations. PA Consulting provides services across various industries: Consumer and manufacturing, defence and security, energy and utilities, financial services, government and public services, health, life sciences, and transport. PA Consulting has contractual relationships across government through the Crown Commercial Services frameworks. 

You wish to take up a paid, part-time role as a Strategic Adviser with PA Consulting. You said you will be providing strategic advice to PA Consulting.  This is an internal role to PA Consulting and will span UK and international sections of the firm’s global market.  You said that your day to day dealings will be with senior management of the firm, including:

• providing advice on innovation and transformation and how PA Consulting can help clients to accelerate innovation adoption and diffusion
• shaping PA Consulting’s approach to new technologies including applied AI
• shaping strategies for meeting complex challenges with ingenuity
• supporting research, collaboration and thought leadership
• delivering internal training and speaking events

You said for the two years after leaving office, the role will not include:

• contact with the UK government, nor its arm’s length bodies; 
•  use of contacts, influence policy nor secure business for PA Consulting including parent companies, subsidiaries, partners and clients;  
• advising on the subject matter or terms of a bid to the UK government; nor will it
• engage at a relevant level with areas for which you had responsibility in government.

4.2 Dealings in office 

You said that you did not make any decisions specific to PA Consulting in office, nor did you meet with the company. You said that although you were responsible for AI and innovation policy, your access to information was limited because: 

• You were in post under time-limited circumstances to provide maternity cover.  
• It was agreed that you would leave a number of key decisions for the return of the permanent Secretary of State and you left post before an update was decided upon, drafted and published in the form of the AI White Paper.
• You led early definition and governance for policy relating to how DSIT could be an innovative department, and how the public sector could be more innovative, but later direction was left to the returning Secretary of State.   
• You were not involved in  regulatory decisions related to innovation.
• You did not make any funding decisions relating to innovation at DSIT. 
• Your responsibilities in office were at ‘extremely strategic levels and your proposed role with PA Consulting is at a different, applied level’.  For example, you said your decisions on AI focused on global safety and cross-government risks rather than application in organisations
• A new government is now in office and changing significant elements of policy on AI, including changing spending plans and proceeding with primary legislation.

4.3 Departmental assessment 

DSIT said you were exposed to making regular policy and regulatory decisions which affected many companies. It is unlikely that any decisions affected PA Consulting directly. There is now a new administration in place and the direction of policy has changed. Your role at the department was time-limited and relevant information from your time in office is now in the public domain. 

DSIT said that PA Consulting is on a number of government frameworks for consulting, including the Management Consulting Framework. However, you did not have involvement in this matter. 

DSIT recommended standard conditions.