Decision

Advice letter: Jim Harra, Vice-Chair of the Board of Trustees, Royal National Institute of Blind People

Published 2 June 2025

1. BUSINESS APPOINTMENT APPLICATION: Sir Jim Harra KCB, former First Permanent Secretary and Chief Executive. Unpaid appointment with the Royal National Institute of Blind People.

Sir Jim Harra KCB (Sir Jim) sought advice from the Advisory Committee on Business Appointments (the Committee) under the government바카라 사이트™s Business Appointment Rules for Former Crown Servants (the Rules) on an unpaid role he wishes to take up with the Royal National Institute of Blind People (RNIB), as Vice-Chair of the Board of Trustees.

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 Sir Jim바카라 사이트™s time in office, alongside the information and influence he may offer RNIB. The material information taken into consideration by the Committee is set out in the annex.

The Committee바카라 사이트™s advice is not an endorsement of the appointment 바카라 사이트“ it imposes a number of conditions to mitigate the potential risks to the government associated with the appointment under the Rules.

The Rules^{[footnote 1]} set out that Crown servants must abide by the Committee바카라 사이트™s advice. It is an applicant바카라 사이트™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 Committee바카라 사이트™s consideration of the risks presented

When considering this application, the Committee^{[footnote 2]} took into account that this appointment is unpaid^{[footnote 3]}. Generally, the Committee바카라 사이트™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 Crown servants joining outside organisations. Those risks include using privileged access to contacts and information to the benefit of themselves or those they represent. The Rules also seek to mitigate the risks that individuals may make decisions, or take action in office, 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.

There is no known overlap between Sir Jim바카라 사이트™s former role in office and his proposed role at the RNIB. There remain inherent risks associated with any former Crown servant바카라 사이트™s access to information, network of contacts and influence in government. In this unpaid role, these risks are limited.

Under the Rules, as a former Permanent Secretary with access to a wide range of sensitive information, Sir Jim is subject to a minimum waiting period of three months between leaving paid Crown service and taking up an outside role.

3. The Committee바카라 사이트™s advice

The Committee did not consider this unpaid appointment to raise any particular concerns under the government바카라 사이트™s Business Appointment Rules. The standard conditions below sufficiently mitigate the inherent risks. These seek to prevent Sir Jim from making improper use of privileged information, contacts and influence to the unfair advantage of the organisation.

Therefore, in accordance with the government바카라 사이트™s Business Appointment Rules, the Committee advises that this appointment with the Royal National Institute of Blind People be subject to the following conditions:

• a waiting period of three months from his last day in Crown service;

• Sir Jim 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 its arm바카라 사이트™s length bodies on behalf of the Royal National Institute of Blind People (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 to influence policy, secure business/funding or otherwise unfairly advantage the Royal National Institute of Blind People (including parent companies, subsidiaries, partners and clients); and

• for two years from his last day in Crown service, he should not undertake any work with the Royal National Institute of Blind People (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 arm바카라 사이트™s length bodies.

The advice and the conditions under the government바카라 사이트™s Business Appointment Rules relate to his 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 Lords바카라 사이트™ Interests^{[footnote 4]}. It is an applicant바카라 사이트™s personal responsibility to understand any other rules and regulations they may be subject to in parallel with this Committee바카라 사이트™s advice.

By 바카라 사이트˜privileged information바카라 사이트™ 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 바카라 사이트˜should not engage in communication with government (ministers, civil servants, including special advisers, and other relevant officials/public office holders) 바카라 사이트“ wherever it takes place 바카라 사이트“ 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.바카라 사이트™

Once the appointment has been publicly announced or taken up, we will publish this letter on the Committee바카라 사이트™s website - Sir Jim must inform us as soon as he takes up employment with this organisation or it is announced.  He must also inform us if he proposes to extend or otherwise change the nature of his role as, depending on the circumstances, it may be necessary for him to make a fresh application.

4. Annex 바카라 사이트“ Material Information

4.1 The role

Royal National Institute of Blind People (RNIB) is a charity that offers support to blind and partially sighted people, their families and carers. It also raises awareness of the experiences of blind and partially sighted people and campaigns to make society more accessible for their needs.

Sir Jim wishes to take up a part-time, unpaid role as Vice-Chair of the Board of Trustees. Sir Jim told the Committee that his role would involve:

• acting as the Board바카라 사이트™s Senior Independent Trustee;

• acting as the lead trustee for governance and providing assurance the Trustees regarding the effectiveness of their governance;

• acting as the Chair of the Governance, Nominations and Remuneration Committee;

• taking responsibility for the process to recruit and appoint the Chair of the Trustees;

• conducting an annual review of the performance of the Chair;

• assisting the Chair by providing independent leadership and strategic advice;

• acting for the Chair when they are unavailable and undertaking assignments at the request of the Chair; and

• acting as an intermediary if there is unresolved conflict between the Chair and the CEO.

Sir Jim also noted that the role would not involve any contact with government.

4.2 Dealings in office 

Sir Jim said that he did not make any policy, regulatory or commercial decisions specific to RNIB, that he did not have any access to information that could grant RNIB an unfair advantage, and that there was no relationship between RNIB and HMRC.

4.3 Departmental assessment 

HMRC confirmed that he did not make any policy, regulatory or commercial decisions specific to RNIB, and that it was unlikely there was any contact between Sir Jim and RNIB.

HMRC noted that Sir Jim may have had a wide range of access to information that may be seen as relevant or valuable to RNIB. However, given the nature of the unpaid role, and the fact that the organisation is a charity, HMRC considered the risk of unfair advantage was significantly limited.

HMRC recommended standard conditions, including the waiting period that applies to all former Permanent Secretaries. 

1. Which apply by virtue of the Civil Service Management Code, The Code of Conduct for Special Advisers, The King바카라 사이트™s Regulations and the Diplomatic Service Code. ↩

2. This application for advice was considered by Andrew Cumpsty; Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE DL; Michael Prescott; The Baroness Thornton; and Mike Weir. ↩

3. By unpaid the Committee means that no remuneration of any kind is received for the role. Applicants must declare where it is agreed or anticipated they may receive remuneration or some other compensation at some stage in the future. ↩

4. 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 Lords바카라 사이트™ Interests, in the case of peers. ↩