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1. BUSINESS APPOINTMENT APPLICATION FOR ADVICE: Mr Aidan Corley, former Head of Research and Messaging, Special Adviser to the Prime Minister No. 10. Paid appointment with Cleo AI Ltd.聽

Mr Corley sought advice from the Advisory Committee on Business Appointments (the Committee) under the government鈥檚 Business Appointment Rules for Former Crown Servants (the Rules) on an appointment he wishes to take up the role as Chief of Staff for Cleo AI Ltd (Cleo AI).

The purpose of the Rules is to protect the integrity of the government. Under the Rules, the Committee鈥檚 remit is to consider the risks associated with the actions and decisions Mr Corley made during his time in office, alongside the information and influence a former Special Adviser at No.10 may offer Cleo AI. The material information taken into consideration by the Committee is set out in the annex.

The 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.

The 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. The Committee鈥檚 consideration of the risks presented

Mr Corley did not meet with Cleo AI while in office and applied to the role via an advertisement. In addition, he did not have a decision-making role on matters specific to Cleo AI or the sector it operates in.聽 Therefore, the Committee[2] considered that the risk that this role could reasonably be perceived as being offered as a reward is low.

As a former Special Adviser to the Prime Minister at the centre of government, Mr Corley would have had access to a broad range of privileged information and insight. However, the risks are limited as the Cabinet Office is not aware of any information that would offer Cleo an unfair advantage. Further, it has been over nine months since he left his role, providing a gap between his role in government and his role with Cleo AI.

As a former Special Adviser, there are inherent risks with Mr Corley鈥檚 network and contacts in government that could be seen to offer unfair access or influence for Cleo AI.

The Committee also considered it relevant to its consideration that Mr Corley previously worked in the tech industry, prior to re-joining government as a Special Adviser to the Prime Minister.

3. The Committee鈥檚 advice

The Committee did not consider this appointment raises any particular concerns under the government鈥檚 Rules, subject to the standard conditions set out below. These seek to prevent Mr Corley making use of his access to privileged information, contacts or influence gained from his time as a Special Adviser to the unfair benefit of the Cleo AI. These conditions appropriately mitigate the risks identified above.

The Committee鈥檚 advice in accordance with the government鈥檚 Business Appointment Rules is that Mr Corley鈥檚 role with Cleo AI Ltd. be subject to the below conditions:

• Mr Corley 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 Cleo AI Ltd.聽 (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 Cleo AI UK Ltd.聽 (including parent companies, subsidiaries, partners and clients);

• for two years from his last day in Crown service, he should not provide advice to Cleo AI Ltd.聽 (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.

The advice and the conditions under the government鈥檚 Business Appointment Rules relate to Mr Corley鈥檚 previous roles 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.聽 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聽鈥檚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 - 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 Corley must inform us as soon as he takes up this work or if it is announced that he will do so.聽 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 The role

Cleo AI is a technology company that provides AI solutions for financial assistance through budgeting and savings advice. It has offices in London and New York.

Mr Corley wishes to take up a paid, full-time role as Chief of Staff at Cleo AI. Mr Corley said that his role will involve strategic communication and planning, cross-functional leadership, leadership alignment and team coordination. Mr Corley said his role would not involve engagement with the UK government.

4.2 Dealings in office

Mr Corley said that he did not make any policy, regulatory or commercial decisions related to Cleo AI while in his role as Special Adviser, nor did he have access to any privileged information that could confer a particular advantage.

4.3 Departmental assessment

The Cabinet Office said that as a Special Advisor in No.10, Mr Corley had access to sensitive information and knowledge regarding the internal workings of government, but the importance of this knowledge was reduced with the change in government and nine months which have passed since he left the role.

The department also noted that Mr Corley was not responsible for the media or digital industry, nor oversaw departments that would affect the sector Cleo AI operates in.聽 Its view is that聽 his access to detailed knowledge and contacts are not likely to offer significant insight/advantage.

The department noted that Mr Corley applied via an advertisement which reduced the risks, real or perceived, of the applicant being offered the role as a reward for past favours made during their time in government.

The Cabinet Office said that Mr Corley did not make any decisions in office聽 specific to Cleo AI.

The Cabinet Office recommended standard conditions.

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

[2]聽 This application for advice was considered by Andrew Cumpsty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE DL; The Rt Hon Lord Eric Pickles; Michael Prescott; The Baroness Thornton and Mike Weir. Isabel Doverty was 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.