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1. BUSINESS APPOINTMENT APPLICATION: Cassian Horowitz, former Head of Strategic Communications and Digital at No.10 Downing Street. Paid role, providing digital communications services to The Office of Akshata Murty & Rishi Sunak under his independent consultancy.

You 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 your proposal to work with The Office of Akshata Murty & Rishi Sunak under your independent consultancy.

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 your time in office, alongside the information and influence the former Special Adviser could offer The Office of Akshata Murty & Rishi Sunak. 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 鈥� 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 Committee鈥檚 advice. 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

The Committee^{[footnote 2]} considered this commission to be consistent with the description of your consultancy 鈥� providing digital content services to brands and CEOs, using experience originally gained prior to your joining government. You stated these services include:

• Helping brands with their positioning. For example, their tone of voice online, which social channels they should use and how they should present themselves.
• Creating branding for business like logos or brand names. Helping them with their overall look and feel online.
• Running social media accounts on an ongoing basis. This could include writing the words, creating graphics and posting on a variety of platforms like LinkedIn or X or TikTok.
• Creating large scale content like videos or digital advertising boards, helping to both come up with the ideas and produce the content.
• Setting up websites including the design and the implementation as well as SEO.
• Working with the creator community to introduce them to businesses and inviting them to events, organise interviews etc.
• Running paid digital ads across a variety of social media platforms as well as search.

As Head of Strategic Communications and Digital at No.10 Downing Street, there are inherent risks associated with your access to information and influence. It is significant that the Cabinet Office does not consider you to possess sensitive information that may confer the Office of Akshata Murty & Rishi Sunak an unfair advantage; you did not work on commercial matters or in procurement during your time in office; nor did you make any decisions relating to the organisation. Further, you joined government with experience and skills gained within the digital communications sector.

3. The Committee鈥檚 advice

In the circumstances, the Committee鈥檚 advice in accordance with the government鈥檚 Business Appointment Rules is that this work with The Office of Akshata Murty & Rishi Sunak should be made subject to the same conditions attached to your independent consultancy. This includes the conditions below which prevent you from lobbying the government and being involved in contracts and bids with the government.

In accordance with the government鈥檚 Business Appointment Rules, the Committee advises this commission with The Office of Akshata Murty & Rishi Sunak be subject to the following conditions:

• you should not draw on (disclose or use for the benefit of yourself or the persons or organisations to which this advice refers) any privileged information available to you from your time in Crown service or in any capacity in which you continue to represent the UK government;

• for two years from your last day in Crown service, you should not become personally involved in lobbying the UK government and its arm鈥檚 length bodies on behalf of The Office of Akshata Murty & Rishi Sunak (including parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in government and/or Crown service to influence policy, secure business/funding or otherwise unfairly advantage those you advise under your independent consultancy (including parent companies, subsidiaries, partners and clients);

• for two years from your last day in Crown service, you should not provide advice to on behalf of The Office of Akshata Murty & Rishi Sunak (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

• 聽 for two years from your last day in Crown service, before accepting any commissions for your independent consultancy and/or before extending or otherwise changing the nature of your commissions, you should seek advice from the Committee. The Committee will decide whether each commission is consistent with the terms of the consultancy and consider any relevant factors under the Business Appointment Rules.

The 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.^{[footnote 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.

The 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�

You must inform us as soon as you take up this commission or if it is announced that you will do so. Similarly, you must inform us if you propose to extend or otherwise change your commission with the organisation as depending on the circumstances, it might be necessary for you 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 鈥� Material Information

4.1 The role

The Office of Akshata Murty & Rishi Sunak is a private office company set up to administer and support the former Prime Minister, Rishi Sunak and his wife Akshata Murty with managing their portfolio of interests.

You stated that this role is to provide ongoing digital communication support to The Office of Akshata Murty & Rishi Sunak. You also mentioned that your commission is reliant upon the skill set you have in digital marketing which is an area you worked in prior to your time in Crown service.

4.2 Dealings in office

You stated that you did not make any policy, regulatory or commercial decisions specific to The Office of Akshata Murty & Rishi Sunak whilst in office.

4.3 Departmental assessment

The Cabinet Office confirmed the details provided by yourself as noted above and recommended the standard conditions.