Decision

Advice Letter: Baroness Sugg, Charity Ambassador, Sarcoma UK

Updated 22 November 2022

December 2021

1. BUSINESS APPOINTMENT APPLICATION: Baroness Sugg, Parliamentary Under Secretary of State at the Foreign, Commonwealth & Development Office. Appointment with Sarcoma UK.

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 an appointment as a Charity Ambassador for Sarcoma UK. The material information taken into consideration by the Committee is set out in the annex below.

The purpose of the Rules is to protect the integrity of the government. Under the Rules, the Committee’s remit is to consider the risks associated with the actions and decisions made during time in office, alongside the information and influence a former minister may offer Sarcoma UK.

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 role as a Charity Ambassador 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 using privileged access to contacts and information to the benefit of themselves or those they represent; and 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.

3. The Committee’s advice

As above, the Committee recognised the risks in this unpaid appointment are limited. This role has no overlap with your time in office and the FCDO confirmed it has no concerns with you taking up this appointment. 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 Sarcoma UK 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 or its arms’ length bodies on behalf of Sarcoma UK (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 Sarcoma UK (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 Sarcoma UK (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 Committee also notes that in addition to the conditions imposed on this appointment, there are separate rules in place with regard to your role as a member of the House of Lords.

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.’ This Rule is separate and not a replacement for the Rules in the House.

I should be grateful if you would inform us as soon as you take up this role, or if it is announced that you will do so. We shall otherwise not be able to deal with any enquiries, since we do not release information about appointments that have not been taken up or announced. This could lead to a false assumption being made about whether you had complied with the Rules and the Ministerial Code.

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.

4. Annex - Material information

4.1 The role

You seek to join Sarcoma UK in an unpaid, part-time role as a Charity Ambassador.

Sarcoma UK is a national charity focused on sarcoma cancer that funds research, campaigns for better treatments and offers support to anyone affected by sarcoma. The charity’s website says it is a ‘…relatively young charity that supports a strong, caring and mutually-supportive community’. It is ‘…staffed by a growing team managed by a board of trustees (comprising a balanced mix of those with personal experience of sarcoma and those that don’t), and supported by experts in the sarcoma field’. Sarcoma UK receives ‘…no government funding’, relying solely on donations and its fundraisers.

You described this role as an ‘…honorary position to support the charity by attending events and promoting their charitable work’.

You said this appointment would not include any contact or dealings with your former department or government more generally.

4.2 Dealings in office

You said you had no contact with Sarcoma UK whilst in office.

4.3 Department Assessment

The Foreign, Commonwealth & Development Office confirmed the details you provided, stating they have no concerns with this appointment and recommended that the standard restrictions be attached.

1. This application for advice was considered by; Jonathan Baume; Andrew Cumpsty; lsabel Doverty; Sarah de Gay; Dr Susan Liautaud; The Rt Hon Lord Pickles; Richard Thomas; Mike Weir; and Lord Larry Whitty. ↩