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1. BUSINESS APPOINTMENT APPLICATION: Adam Smith, former Chief of Staff, Special Advisor at the HM Treasury. Paid appointment with the Good Growth Foundation.

Mr Smith approached the Advisory Committee on Business Appointments (the Committee) under the government’s Business Appointment Rules for Former Crown Servants (the Rules) on a paid appointment as a Senior Economic Advisor with the Good Growth Foundation.

The purpose of the Rules is to protect the integrity of the government. The Committee has considered the risks associated with the actions taken and decisions made during an applicant’s time in office, alongside the information and influence he may offer the Good Growth Foundation. The material information taken into consideration by the Committee is set out in the annex.

The Committee’s^{[footnote 1]} 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 ^{[footnote 2]} set out that Crown servants must abide by the Committee’s advice. It is an applicant’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 Committee’s consideration of the risk presented

The Good Growth foundation was formed in September 2024, after Mr Smith had left office. Whilst there is an obvious overlap with its interest in government policy, he made no decisions specific to the organisation in office. Therefore the Committee considered the risk this appointment could reasonably be perceived as a reward for decisions or actions taken in office is low.

As an economic think tank, the Good Growth Foundation has an interest in government policy. Mr Smith’s access to privileged information as a Special Adviser at HMT would have included relevant information which could be perceived to provide an unfair advantage to the Good Growth Foundation. There are a number of mitigations that reduce the risks associated with Mr Smith’s access to information:

• Since Mr Smith was in office there has been a change in government and significant shifts in the economic climate that the current government has had to respond to. Numerous economic decisions have been made under the new administration that evidence this, for example in the Autumn Budget 2024 and the Spring Statement 2025.

• It has now been 11 months since Mr Smith last had access to information, creating a significant gap and reducing its currency.

• HM Treasury (HMT) confirmed it is not aware of any specific access to information that would offer an unfair advantage and considers it is no longer sufficiently up to date.

The Committee considered the risks associated with Mr Smith’s influence and network of contacts gained whilst in office. The Good Growth Foundation is a think-tank that inevitably has an interest in influencing government policy. Whilst it is not his intention as set out in his application, there is a risk that Mr Smith could be seen to offer privileged contacts and influence gained in office to the organisation’s unfair advantage. Given the focus of his role on the subject matter of the organisation’s policy work; and its influencing agenda the Committee asked the Good Growth Foundation to confirm that Mr Smith’s role will be separated from its lobbying of government whilst he is subject to the Rules. This would not prevent him carrying out the role as described. It is significant that the Good Growth Foundation confirmed its adherence with the Committee’s advice.

3. The Committee’s advice

The Committee considers the main risk raised by this appointment to be the risk that Mr Smith is seen to be actively lobbying government in this role, which is prevented from two years on leaving office. To mitigate this risk the Committee has imposed an additional condition preventing Mr Smith from initiating contact with government on behalf of the Good Growth Foundation in this role. This would not prevent him from responding to a public consultation, or a request from government to engage.

The remaining, inherent, risks associated with Mr Smith’s access to sensitive information and contacts are appropriately mitigated by the standard conditions below. In particular, they seek to prevent him from drawing on his privileged information and using his contacts and influence within government to the unfair advantage of the Good Growth Foundation. As set out in the Annex, the Good Growth Foundation confirmed his limited role, will be in compliance with the conditions below.

In accordance with the government’s Business Appointment Rules, the Committee advises that this appointment with The Good Growth Foundation be subject to the following conditions:

• for two years from his last day in Crown service, he must not have any direct engagement with the UK government and ALBs on behalf of The Good Growth Foundation or its clients;

• Mr Smith 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 arm’s length bodies on behalf of the Good Growth Foundation (including parent companies, subsidiaries, partners and clients); nor should he make use, directly or indirectly, of his contacts in the government and/or ministerial office to influence policy, secure business/funding or otherwise unfairly advantage the Good Growth Foundation (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 Good Growth Foundation (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 arm’s length bodies.

The advice and the conditions under the government’s Business Appointment Rules relate to an applicant’s 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’ Interests ^{[footnote 3]}. It is an applicant’s personal responsibility to understand any other rules and regulations they may be subject to in parallel with this Committee’s advice.

By ‘privileged information’ 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 Civil Service Code or otherwise.

The Business Appointment Rules explain that the restriction on lobbying means that the former Crown servant/minister ’’should not engage in communication with government (ministers, civil servants, including special advisers, and other relevant officials/public office holders) – 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.’

Mr Smith must inform us as soon as he takes up employment with this organisation, or if it is announced that he will do so. 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.

Once the appointment has been publicly announced or taken up, we will publish this letter on the Committee’s website, and where appropriate, refer to it in the relevant annual report.

4. Annex - Material Information

4.1 The role

The Good Growth Foundation is an economic think tank founded in 2024. Its website describes itself as‘…a campaigning think tank that wants to see smart, just and popular solutions to grow the economy’. It also says that it is a non profit organisation formed in September 2024.

Mr Smith described his part-time paid role as Senior Economic Advisor to have the following responsibilities:

• Providing advice to the team on crafting compelling policy cases to the government primarily focused on economic and growth policies.
• Providing advice to the team on financial, economic and process considerations regarding government policy making.
• Providing advice and support to the team on economic analysis,policy costings and other relevant factors.
• General strategic advice on the think tank’s overall aims.

Mr Smith said his role would not involve contact with government.

4.2 Dealings in office

Mr Smith said he did not meet with the Good Growth Foundation when in office, He stated he had no involvement in any commercial or contractual decisions regarding the organisation. He also had no commercially sensitive information on the Good Growth Foundation or their competitors.

4.3 Correspondence with the Good Growth Foundation

The Good Growth Foundation confirmed in writing its agreement to comply with the Committee’s advice, stating that it confirms that all rules and conditions will be adhered to. The Good Growth Foundation confirmed that Mr Smith’s role will not involve engaging in lobbying or any contact with Government and that his responsibilities will be ring-fenced in this way.

4.4 Departmental Assessment

HMT confirmed the details in Mr Smith’s application and said that they have no relationship with the Good Growth Foundation. They said that Mr Smith had no access to privileged information that was relevant to the organisation.

HMT recommended standard conditions.