Decision

Advice letter: Elizabeth Sugg, Chair of the Board of Trustees, Plan International UK

Updated 2 June 2025

1. BUSINESS APPOINTMENT APPLICATION: The Baroness Sugg CBE, former Special Adviser to the Foreign Secretary at the Foreign, Commonwealth and Development Office. Unpaid appointment with Plan International UK. 

The Baroness Sugg 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 she wishes to take up with Plan International UK (Plan UK) as the 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 Baroness Sugg바카라 사이트™s time in office, alongside the information and influence she may offer Plan UK. 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.

Whilst there is a funding arrangement between Baroness Sugg바카라 사이트™s former department and Plan UK, this did not fall under her responsibilities as a Special Adviser. There is a general overlap between the subject matter of Baroness Sugg바카라 사이트™s role at the FCDO and this organisation바카라 사이트™s work in international development policies, including on women and girls and sexual and reproductive health and rights. In this unpaid role, the Committee agreed with the FCDO that the associated risks are limited.

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 Baroness Sugg 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 Plan International UK be subject to the following conditions:

• The Baroness Sugg should not draw on (disclose or use for the benefit of herself or the persons or organisations to which this advice refers) any privileged information available to her from her time in Crown service;

• for two years from her last day in Crown service, she should not become personally involved in lobbying the UK government or its arm바카라 사이트™s length bodies on behalf of Plan International UK (including parent companies, subsidiaries, partners and clients); nor should she make use, directly or indirectly, of her contacts in the government and/or Crown service to influence policy, secure business/funding or otherwise unfairly advantage Plan International UK (including parent companies, subsidiaries, partners and clients); and

• for two years from her last day in Crown service, she should not undertake any work with Plan International UK (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 your 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]}. You are reminded that as a Member of the House of Lords you are prevented from any paid lobbying under the House of Lords Code of Conduct. 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™Â 

Baroness Sugg must inform us as soon as she takes up employment with this organisation, or if it is announced that she will do so, and we will publish this letter on our website. She must inform us if she proposes to extend or otherwise change the nature of her role as, depending on the circumstances, it may be necessary for her to make a fresh application. 

4. Annex 바카라 사이트“ Material Information 

4.1 The role 

Plan International UK (Plan UK) is an international children바카라 사이트™s charity focused on empowering children, particularly girls, to overcome challenges like poverty, violence, and discrimination.

The Baroness Sugg wishes to take up a part-time, unpaid role as Chair of the Board of Trustees. She told the Committee that her role is to lead the Board and support the Chief Executive and senior leadership team, and act as an ambassador for Plan UK. It may involve:

• stakeholder engagement;

• income generation; and

• advocating for Plan UK missions.

Baroness Sugg also noted that the role would not involve any contact with government.

4.2 Dealings in office 

Baroness Sugg stated that: 

• she did not have any access to information that could grant Plan UK an unfair advantage;

• she worked on general international development policies, including on women and girls and sexual and reproductive health and rights, areas in which Plan UK are involved in;

• Plan UK receives funding from FCDO, but confirmed that she was not previously involved in this process during employment with FCDO;

• although she did not have any direct meetings with the organisation, it is likely that Plan UK attended some larger events (such as receptions) that she also attended and would have had conversations with Plan UK and its competitors there.

4.3 Departmental assessment 

The FCDO confirmed the details above, including that she did not have any access to information that could grant Plan UK an unfair advantage.

The FCDO did not have any concerns regarding Baroness Sugg바카라 사이트™s involvement in any policy, regulatory or commercial decisions specific to Plan UK.

The FCDO confirmed that Plan UK receives funding from the FCDO, and that Baroness Sugg was not previously involved in this process during employment with the FCDO.

The FCDO stated that Baroness Sugg has had contact with Non-바카라 사이트al Organisations and charities alike, but had no direct involvement in any grants or contracts.

The FCDO recommended the standard conditions.

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 Isabel Doverty; Hedley Finn OBE; Sarah de Gay; Dawid Konotey-Ahulu CBE DL; Michael Prescott; The Baroness Thornton; and Mike Weir. Andrew Cumpsty was unavailable. ↩

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. ↩