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1. BUSINESS APPOINTMENT APPLICATION: Laurence James Mann CBE, former Special Adviser to the Foreign Secretary at the Foreign, Commonwealth and Development Office. Paid appointment with Finback Investment Partners, LLC聽

Mr Mann sought advice from the Advisory Committee on Business Appointments (the Committee) under the government鈥檚 Business Appointments Rules for Former Crown Servants (the Rules) on taking up appointment with Finback Investment Partners, LLC (Finback) as the Chief of Staff to Lord Cameron, a Member of Finback鈥檚 Leadership Advisory Council.

皇冠体育app purpose of the Rules is to protect the integrity of the government. 皇冠体育app Committee has considered the risks associated with the actions and decisions made during Mr Mann鈥檚 time in office, alongside the information and influence he could offer Finback. 皇冠体育app material information taken into consideration by the Committee is set out in the annex.

皇冠体育app Committee鈥檚 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.

皇冠体育app Rules[1] set out that Crown servants must abide by the Committee鈥檚 advice.聽 It is an applicant鈥檚 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. 皇冠体育app Committee鈥檚 Consideration of the risks presented

Mr Mann did not make any policy, regulatory or commercial decisions specific to Finback whilst in office. 皇冠体育appre is no known relationship between Finback and Mr Mann鈥檚 former department, the Foreign, Commonwealth & Development Office (FCDO). 皇冠体育apprefore, the Committee[2] considered that the risk that this role could be seen as a reward for Mr Mann鈥檚 decisions in office is low.聽

As Special Adviser to the Foreign Secretary, Mr Mann will have had access to a wide range of privileged information. 皇冠体育app risks are limited given there is no direct overlap between Mr Mann鈥檚 role in government and his proposed role with Finback and the FCDO is not aware of any specific information that could provide an unfair advantage to Finback.

皇冠体育appre are risks associated with Mr Mann鈥檚 influence and network of contacts gained whilst in Crown service. Part of Mr Mann鈥檚 role with Finback is supporting Lord Cameron in providing strategic advice to augment the firm鈥檚 expertise and network. Mr Mann said that his role will not involve contact with the UK government. However, in supporting Lord Cameron in the company鈥檚 business development, there is a risk that Mr Mann could draw on his contacts gained in office but outside of government to the unfair advantage of Finback.

3. 皇冠体育app Committee鈥檚 advice

皇冠体育app Committee determined the risks identified in this application can be appropriately mitigated by the conditions below. 皇冠体育appse make it clear that Mr Mann cannot make use of privileged information, contacts or influence gained from his time in Crown service to the unfair advantage of Finback.

In accordance with the government鈥檚 Business Appointment Rules, the Committee advises this appointment with Finback Investment Partners, LLC 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, he should not become personally involved in lobbying the UK government or any of its arm鈥檚 length bodies on behalf of Finback Investment Partners, LLC (including parent companies, subsidiaries, partners and clients); nor should he make use, directly or indirectly, of his contacts in the government and/or Crown service contacts to influence policy, secure business/funding or otherwise unfairly advantage Finback Investment Partners, LLC (including parent companies, subsidiaries, partners and clients);

• for two years from his last day in Crown service, he should not provide advice to Finback Investment Partners, LLC (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鈥檚 length bodies; and

• for two years from his last day in Crown service, he should not become personally involved in lobbying contacts he has developed during his time in office and in foreign governments and organisations for the purpose of securing business for Finback Investment Partners, LLC (including parent companies, subsidiaries and partners).

皇冠体育app advice and the conditions under the government鈥檚 Business Appointment Rules relate to an applicant鈥檚 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鈥� Interests[3]. It is an applicant鈥檚 personal responsibility to understand any other rules and regulations they may be subject to in parallel with this Committee鈥檚 advice.

By 鈥榩rivileged information鈥� 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.

皇冠体育app Business Appointment Rules explain that the restriction on lobbying means that the former Crown servant 鈥渟hould not engage in communication with Government (Ministers, civil servants, including special advisers, and other relevant officials/public office holders) 鈥� wherever it takes place 鈥� 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.鈥�

Mr Mann 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鈥檚 website.

4. Annex- Material Information

4.1 皇冠体育app role

According to its website, Finback is a private equity firm based in Florida that takes active minority interests in middle market and growth-stage companies. It takes non-controlling stakes alongside lead partners and provides a strategic approach, designed to accelerate the growth of its portfolio companies.. 聽

Mr Mann wishes to take up a part-time, paid role as the Chief of Staff to one member of the Finback Leadership Advisory Board. Mr Mann said his role is to support Lord David Cameron in his role on Finback鈥檚 Leadership Advisory Board. As such, he will assist him in providing the company with strategic advice to augment the firm鈥檚 expertise and network to positively impact its portfolio companies. He stated he will assist in convening and will attend meetings to strengthen relationships with key firm partners, and attend events for the firm. He confirmed his role will not involve contact with government.

4.2 Dealings in office

Mr Mann said he did not meet with Finback in his capacity as Special Adviser to the Foreign Secretary, nor does Finback have a relationship with the FCDO or the UK government. He said that he did not make any policy, commercial or regulatory decisions specific to Finback in ministerial office.

4.3 Departmental assessment

皇冠体育app FCDO said that Mr Mann did not make any decisions specific to Finback in office, nor did he meet with the company in his role as Special Adviser to the Foreign Secretary. Neither the FCDO nor government have a known relationship with Finback.

皇冠体育app FCDO did not have concerns with the appointment and recommended the standard conditions.

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[1]聽 Which apply by virtue of the Civil Service Management Code, 皇冠体育app Code of Conduct for Special Advisers, 皇冠体育app King鈥檚 Regulations and the Diplomatic Service Code

[2] This application for advice was considered by Andrew Cumpsty; Isabel Doverty; Hedley Finn OBE; 皇冠体育app Rt Hon Lord Eric Pickles; Michael Prescott; and Mike Weir. Dawid Konotey-Ahulu CBE DL and Sarah de Gay were unavailable.

[3] All Peers and Members of Parliament are prevented from paid lobbying under the House of Commons Code of Conduct and the Code of Conduct for Members of the House of Lords. Advice on obligations under the Code can be sought from the Parliamentary Commissioners for Standards, in the case of MPs, or the Registrar of Lords鈥� Interests, in the case of peers.