1. BUSINESS APPOINTMENT APPLICATION: Vice Admiral Sir Richard Charles Thompson, KCB, CBE, FRS, CEng, FRAeS, former Director General Air, Defence Equipment & Support at the Ministry of Defence- Paid appointment with Manufacturing Technology Centre Limited 

Vice Admiral Sir Richard Thompson (VAdm Sir Richard) sought advice from the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointments Rules for Former Crown Servants (the Rules) on taking up an appointment as a Director with the Manufacturing Technology Centre Limited (MTC).

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 VAdm Sir Richard’s time in office, alongside the information and influence a former senior member of the MOD may offer MTC. The material information taken into consideration by the Committee is set out in the annex.

The Committee’s^{[footnote 1]} advice is not an endorsement of the appointment - it imposes a number of conditions to mitigate the potential risks to the UK government associated with the appointment under the Rules.

The Rules set out that Crown servants must abide by the Committee’s advice. It is an applicant’s personal responsibility to manage the propriety of any appointment. Former Crown servants are expected to uphold the highest standards of propriety and act in accordance with the 7 Principles of Public Life.

2. The Committee’s advice 

MTC is a not-for-profit company established by academia in 2011 with the specific and limited purpose of undertaking research, development and sharing innovative manufacturing processes/technologies working in partnership with industry, academia and other institutions.  MTC is a ‘not for profit’ organisation which seeks no commercial advantage, as detailed in its Articles of Association governing ownership and management of the organisation. Any income and property of the company is applied solely towards promotion of its research, development, and scientific work with no portion of company profit being paid as dividends, gifts or bonuses to the research partners of the company.  

MTC is part of a confederation of research centres appointed to run the High Value Manufacturing Catapult (HVM Catapult) that was initiated and supported by the UK government.  HVM Catapult is a strategic research and innovation hub for industry, commercialising the UK’s most advanced manufacturing ideas.  It has seven centres (including MTC) which help businesses to transform the products they sell, the way they make them and the skills of their workforce to remain competitive in a global marketplace.  

VAdm Sir Richard wishes to take on a role with MTC as Director. He said the role will involve providing additional capacity, resilience and strategic leadership within MTC to support sustainable growth as it experiences increased demand. This will include strategic leadership; governance, policy and process advice on company structure; aiding MTC’s understanding of relevant research and industrial challenges; overseeing engineering teams within his portfolio; and helping ensure MTC is compliant with legal and financial requirements.

Though MTC has contracts with the MOD, these sit outside of VAdm Sir Richard’s procurement responsibilities within Defence Equipment and Support (DE&S). MTC’s contracts with the MOD sit with Defence Science and Technologies Laboratories (DSTL), the Defence Nuclear Organisation (DNO), and Strategic Command.  MTC is not involved in the delivery of defence equipment and support from VAdm Sir Richard’s previous portfolio within DE&S. He was not responsible for decisions specific to MTC and the Committee considered there is a low risk that this prospective role is, or could reasonably be perceived to be, offered as a reward for decisions or actions taken in office.

VAdm Sir Richard’s role was to oversee the procurement of aircraft, aviation equipment and associated support services to the Royal Air Force (and less so the other two services). This position offered him access to privileged information related to defence and security matters.  The Committee agrees with the MOD that the risks associated with VAdm Sir Richard’s access to information are limited for the following reasons: - It has been seven months since he left his role and had access to information and decision making at the MOD.  The MOD confirmed it is not aware of any specific information he has which would unfairly advantage MTC. - This role will not be focused on the procurement of defence equipment and support from his previous MOD portfolio, but on wider research and development and the structure and governance of MTC’s operations. - Whilst MTC works within defence and security (alongside other industries such as energy) it is not a commercial defence industry company, nor does it provide air defence equipment or services specifically.  - It is a non-commercial research and development vehicle supported by the UK government to deliver for the UK in respect of technology and innovation, including that within defence. It solves problems brought to them as opposed to seeking commercial contracts per se. - Any income is used to further its objectives to commercialise UK innovation and accelerate technologies, techniques, processes and best practise from across academia and industry - not paid to shareholders or partners.

The Committee’s view is that there remain risks in relation to his access to information despite these mitigating factors. In particular, MTC works with industry partners. The real or perceived risk of any unfair advantage conferred to industry (eg, Boeing, Airbus, Raytheon, BAES etc) is most likely to arise if VAdm Sir Richard was to work on matters that fell within his portfolio at DE&S.  As set out in the annex, matters he got involved in, in some detail included, but are not limited to, specific industry suppliers where he led the strategic relationship and some major projects associated with: the A400M fleet which is replacing the previous large transportation craft, and the E-7 Wedgetail and Shadow MK 2 projects in relation to the UK’s provision of surveillance planes.

There are risks associated with VAdm Sir Richard’s influence and the network of contacts he has gained from his time in government/the UK MOD. It would be improper for VAdm Sir Richard to get involved in obtaining or negotiating on work with the government. Unusually, given the nature of MTC and its work, the risks associated with him advising on UK defence work including that involving the MOD are limited, provided it is initiated by the MOD/ the UK government and has no direct overlap with his responsibilities as Director General at DE&S.  

3. The Committee’s advice

The Committee noted the mitigating factors above that help to reduce the risks associated with VAdm Sir Richard’s access to information and contacts. There are standard conditions which prevent individuals from making improper use of privileged information and contacts gained in office, which are set out below and the Committee would draw his attention to these. 

In addition, the Committee would also draw VAdm Sir Richard’s attention to the condition preventing him from advising on matters that relate to his portfolio at DE&S, particularly where MTC may work with industry partners that could risk a potential conflict with his involvement in those matters in office. 

It is significant that MTC confirmed its adherence with the Committee’s advice. 

The Committee advises under the government’s Business Appointment Rules that VAdm Sir Richard’s role with Manufacturing Technology Centre Limited should be subject to the following conditions: 

• he should not draw on (disclose or use for the benefit of himself or the persons or organisations to which this advice refers) any privileged information available to him from his time in Crown service;
• for two years from his last day in Crown service, his should not become personally involved in lobbying the UK government or any of its arm’s length bodies on behalf of Manufacturing Technology Centre Limited (including parent companies, subsidiaries, partners and clients); nor should he make use, directly or indirectly, of his contacts in the government and/or ministerial contacts to influence policy, secure business/funding or otherwise unfairly advantage Manufacturing Technology Centre Limited (including parent companies, subsidiaries, partners and clients);
• for two years from his last day in Crown service, he should not provide advice to Manufacturing Technology Centre Limited on the terms of a bid or contract with, or relating directly to the work of, the UK government or any of its arm’s length bodies;
• for two years from his last day in Crown service, he should not advise:
  • MTC or its partners on contracts he had material involvement in as Director General Air, Defence Equipment & Support (DE&S), including but not limited to: delivery of the A400, the Wedgtail E-7 and the Shadow Mk2 project; nor  
  • industry partners and clients where he had specific responsibilities for the MOD’s strategic relationships with companies as Director General Air, Defence Equipment & Support, including but not limited to Airbus and Leonardo.

The advice and the conditions under the government’s Business Appointment Rules relate to an individual’s 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. 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/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’.

VAdm Sir Richard must inform us as soon as he takes up this work or if it is announced that he will do so. Similarly, he must inform us if he proposes to extend or otherwise change his role with the organisation as, depending on the circumstances, it might be necessary for him to seek fresh advice. 

Once this appointment has been publicly announced or taken up, we will publish this letter on the Committee’s website.

4. Annex - material information

4.1 The organisation

Manufacturing Technology Centre Limited (MTC) is a not-for-profit company established by academia in 2011.  MTC provides in-house experts, secure facilities, and training to its customers to enable them to build the industrial capabilities they require, with a focus on sustainability, and net-zero carbon outcomes. This includes process innovation, digital transformation,  supply-chain management and sustainable manufacturing.

MTC is part of a confederation of research centres appointed to run the High Value Manufacturing Catapult (HVM Catapult) that was initiated and supported by the UK government.  HVM Catapult is a strategic research and innovation hub for industry, commercialising the UK’s most advanced manufacturing ideas.  It has seven centres (including MTC) which help businesses to transform the products they sell, the way they make them and the skills of their workforce to remain competitive in a global marketplace. 

MTC receives funding via Innovate UK and UK Research and Innovation (ALB’s of DSIT) which invest in science and research in the UK.  As part of the government sponsored Catapult Network it is required to support business, academia, and government in transforming ideas and concepts into viable products and services.  

VAdm Sir Richard described it as mainly a research and development organisation, aimed at taking on projects/work that make the biggest impact for the UK(plc).  He said its role is to help accelerate and ‘pull through’ technologies, techniques, processes and ‘best practise’ from academia and/or across industry, at the request of its members and with government.  He noted it is not in competition with industry or private sector consultancies.

It works with the MOD and other government departments.  In respect of defence, MTC describes itself as the UK defence industry’s ‘Manufacturing Centre of Expertise’, working closely with the MOD and industry.  It has three current research partnerships with the MOD, Defence Science and Technologies Laboratories (DSTL);  the Defence Nuclear Organisation (DNO) and Strategic Command.  

MTC’s commitment and guarantee to remain a not-for-profit organisation and seek no commercial advantage are detailed in its Articles of Association which govern the ownership and management of the business. The Articles state the income and property of the company shall be applied solely towards promotion of the objectives of research, development, and scientific work, with no portion of company profit being paid as dividends, gifts or bonuses to the research partners of the company. 

4.2 The role

VAdm Sir Richard wishes to take up a paid role as a Director at MTC. He said this is a new post within MTC’s senior leadership team created to provide additional capacity, resilience and strategic leadership to support sustainable growth. He said that much of the role will also focus on academic research as their methodology is firmly grounded in R&D. 

He described the role as:

• providing strategic leadership, greater capacity, and resilience within the senior leadership team. 

• ensuring the company is structured for sustainable growth (governance, policy, process) and has the capability and capacity to support a growing portfolio.

• ensuring that the company fully understands the research and industrial challenges being placed on MTC by customers (civilian, defence, other government departments, academia).

• overseeing the activities of the engineering teams within his portfolio, to ensure that contracts are delivered to performance, time, and cost, with the outcomes required by the customer.

• ensuring the company remains compliant with legal and financial requirements.

• ensuring that the company’s manufacturing technology roadmaps and pipelines are coherent across the company and are correctly targeted to support the UK.

VAdm Sir Richard said he would be overseeing the work of others, including those managing MOD contracts -  a small team of engineering specialists and programme managers who are already leading these activities and will continue to do so.  He said any engagement with the MOD would be very limited, in his capacity of overseeing the activities of his team of experts at MTC and he will not have engagement with ministers or particularly senior officials, unless initiated by the senior officials.  MTC and he have agreed his role will not involve:

• lobbying of the government, including the MOD and/or the DE&S. 

• submission of bids/contract negotiation etc to the MOD. 

• direct contact with MOD officials associated with his previous role and programmes, unless initiated by the officials.

• providing any advice or guidance to MTC on previous roles or programmes.

Further, MTC told VAdm SIr Richard that in order to ensure there is no ‘conflict of interest’ and to protect MTC’s reputation, his activities will be under the constant and independent review of MTC’s Audit and Risk Committee who provide advice to the CEO and the Board on all aspects of governance, compliance, and risk management for the company. MTC confirmed in writing its understanding of and agreement to comply with the Committee’s advice. 

4.3 Dealings in office 

VAdm Sir Richard said the following about any possible overlap with his time in office - at DE&S which is the MOD’s arm’s length body for negotiating and managing defence contracts on behalf of the UK Armed Forces:

• His role as DG Air was to support the MOD and the various armed forces via the procurement and delivery of aviation related programmes (specifically excluding Helicopters).  His role in understanding the requirements and expectations of MOD customers was split about 85% to the RAF but with some delivery to the navy and army.

• Whilst not readily available to him in his day to day role, had he asked for them, his project teams would have provided details of the contracts in his area, their values and the outputs being procured.  Any specific commercial negotiations would be the responsibility of Project Teams & Directors. His access to detail was therefore limited. 

• There were some areas where increased oversight and involvement were required and  identified two issues where he had deeper than usual involvement:

The A400M is planned to provide ‘tactical and strategic mobility’ to all three services, to replace the C-130K Hercules fleet.  He was the strategic relationship lead between the Airbus (the relevant supplier) and the MOD,  overseeing the A400M maintenance, repair and upgrade contracts). He noted the scrutiny this project has been under, including by the House of Commons Defence Committee. ACOBA noted the Defence Committee found reliability issues with A400M, and this transition had ‘significantly reduced the overall capacity of the air mobility fleet, undermined the Integrated Review’s “Global Britain” objective, and created a capability gap which could hamper Special Forces.’ It also criticised the government for failing to be transparent and using the secrecy which covers Special Forces to limit meaningful scrutiny of its capability decisions.  This paper was published in November 2023 and the government was asked to provide six-monthly updates on the A400M fleet. The Defence Committee’s comments were not specifically related to the Vice Admiral’s role, conduct or any decisions he made.

Surveillance planes - The Shadow Mk2 project, replacing Shadow MK1, which provides the MOD with battle-winning intelligence gathering.  This upgrade was due to enter service in 2024 under a £110M contract placed with Raytheon UK in 2021. In March 2023 there was also a new £11.5M contract placed by DE&S with Raytheon to train on a full flight simulator for Shadow Mk2 on home soil, rather than travelling outside the UK to do so.   The Wedgetail E-7 - the retirement of the E-3D Sentry left the UK without a land-based fixed-wing ‘Airborne Early Warning & Control’ (surveillance/spy planes) capability. The service date for the previous spy plane E-3D Sentry was extended and delivery of its replacement, the Wedgetail E-7, slipped by 3 years.  The Defence Committee has also criticised the reduction in fleet size and considered the cost saving disproportionate to the ‘the significant reduction in capability’. The Defence Committee’s comments were not specifically related to the Vice Admiral’s role, conduct or any decisions he made.

• He had one official meeting with MTC in office, visiting the organisation in August 2023 to understand how it was supporting industry and the MOD, at the suggestion of the former Chief of Defence Logistics, Lieutenant General Richard Wardlaw, who had been working with MTC and the high value manufacturing catapult network.  
• MTC provides some services to the Future Combat Air System (FCAS) programme indirectly, as a supplier to BAE Systems and Rolls Royce.  He was not responsible for FCAS.
• He owned the strategic relationship between the MOD and Leonardo and met with other industry partners to discuss company performance, such as Rolls-Royce and BAE Systems.
• He has no knowledge of MTC’s work with the Nuclear Enterprise, Strategic Command or DSTL as they did not overlap with his work or responsibilities. 

4.4 Departmental assessment

The MOD confirmed the details provided by VAdm Sir Richard in his application, and also provided the following additional information:

• MTC does not provide services within VAdm Sir Richard’s area of work, nor within DE&S. 
• He had no influence over policy, strategy and operations in the area of the business MTC has with the wider department. 
• MTC is a sub-contractor in some aspects of MOD’s work.  As a supplier to BAES and Rolls Royce for the FCAS programme (estimated overall value of c£3m).  These are matters for industry partners and the MOD has had no influence on these selections and will continue to rely on the prime-contractors on this programme. For completeness, these companies were contacted about whether this appointment raised any concerns and confirmed no objections to the appointment. 
• He made no decisions specific to MTC and its relationship with the MOD is outside his area of responsibility.
• It does not consider he has any information that would offer an unfair advantage, given the nature of the role and the company - MTC is a not-for-profit company.

The MOD recommended standard conditions.  It advised that it was unnecessary to prevent him from working on the UK defence market given the nature of the company and that the role does not overlap with areas for which he had previous responsibility while at the MOD.