Letter of Advice: Baroness Sugg, Charity Ambassador, Sarcoma UK

December 2021

1. REQUEST FOR BUSINESS APPOINTMENT: Baroness Sugg, Parliamentary Under-Secretary of State, Foreign, Commonwealth and Development Office. Appointment with Sarcoma UK.

You have contacted the Professional Appointments Advisory Committee (the Committee) under the Government’s Rules for Professional Appointments for Former Ministers (the Rules) for advice on taking up an appointment as a Charity Ambassador for Sarcoma UK. Important information considered by the Committee is presented in the appendix below.

The purpose of the Rules is to protect the integrity of government. Under the rules, the committee’s mandate is to consider the risks associated with actions and decisions taken while in office, and the information and influence a former minister can offer Sarcoma UK.

The Ministerial Code stipulates that ministers must comply with the advice of the Committee. It is the candidate’s personal responsibility to manage the merits 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. Committee review

When examining this request, the Committee[footnote 1] taken into account this role of charity ambassador is not remunerated. Overall, the Committee’s experience is that the risks associated with unpaid roles are limited. The purpose of the Rules is to protect the integrity of government by taking into account the real and perceived risks associated with former ministers using privileged access to contacts and information to benefit themselves or those they represent; and to mitigate the risks that individuals may make decisions or take actions expecting rewards, by leaving government. These risks are considerably limited in cases of non-payment due to the absence of financial gain for the individual.

3. Committee advice

As above, the Committee recognized that the risks associated with this unpaid appointment are limited. This role does not overlap with your mandate and the FCDO has confirmed that it has no concerns about you taking this position. The Committee did not consider that this appointment raised any particular property rights concerns under the Government Business Appointments Rules. While there are inherent risks associated with your access to sensitive information and contacts, the standard terms below, preventing you from leveraging your privileged information and using your contacts to unfairly benefit your new employer, will sufficiently attenuated in this case.

In view of these factors, in accordance with government rules on professional appointments, the committee recommends that this appointment at Sarcoma UK be subject to the following conditions:

  • you must not take advantage of (disclose or use for your benefit or that of the persons or organizations to which this notice refers) privileged information that you have had since your ministerial mandate;
  • for two years from your last day in office, you must not personally engage in lobbying the UK or its independent bodies on behalf of Sarcoma UK (including parent companies, subsidiaries, partners and customers) ; you must also not use, directly or indirectly, your government and/or Crown Service contacts to influence policy, obtain business/funding or otherwise unfairly advantage Sarcoma UK (including parent companies, subsidiaries, partners and customers); and
  • for two years from your last day in office, you must not undertake any work with Sarcoma UK (including parent companies, subsidiaries, partners and customers) which involves advising on the terms or in in respect of the subject of a tender with, or a contract relating directly to, the work of the UK Government or its independent agencies.

The Committee also notes that in addition to the conditions imposed on this appointment, there are separate rules in place regarding your role as a member of the House of Lords.

By “inside information”, we mean official information to which a Minister or Crown servant has had access by reason of his office or employment and which has not been made public. Candidates are also reminded that they may be subject to other confidentiality obligations, whether under the Official Secrets Act, the Civil Service Code or otherwise.

The corporate appointment rules explain that the restriction on lobbying means that the former Crown official/minister “shall not engage in communication with government (ministers, civil servants, including special advisers, and other officials/relevant public office holders) – wherever it occurs – in order to influence a government decision, policy or contract/grant award related to their own interests or the interests of the organization through which they are employed, with whom they are under contract or with whom they exercise a function. This Rule is separate from and does not replace the House Rules.

I would be grateful if you would inform us as soon as you take office or if it is announced that you will. Otherwise, we will not be able to process any requests, as we do not release information about appointments that have not been made or announced. This could lead to a false assumption about whether you followed the rules and departmental code.

Please also let us know if you plan to extend or change the nature of your role as, depending on the circumstances, you may need to reapply.

Once the appointment is publicly announced or accepted, we will post this letter on the Committee’s website and, where appropriate, refer to it in the relevant annual report.

4. Appendix – Material Information

4.1 The role

Looking to join Sarcoma UK in a part-time unpaid role as a Charity Ambassador.

Sarcoma UK is a national sarcoma cancer charity that funds research, campaigns for better treatments and provides support for anyone affected by sarcoma. The charity’s website states that it is a “…relatively young charity that supports a strong, caring and supportive community”. It is ‘…composed of a growing team managed by a Board of Directors (including a balanced mix of people with personal experience of sarcoma and those without), and supported by experts in the sarcoma domain. Sarcoma UK receives “…no government funding”, relying solely on donations and its fundraising.

You described this role as an “… honorary position to support the charity by attending events and promoting its charitable work”.

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

4.2 Business in the office

You said you had no contact with Sarcoma UK during your tenure.

4.3 Department evaluation

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