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Cameron’s role with Greensill Capital has called the UK’s lobbying regulations into question

David Cameron broke no rules on lobbying, but that may say more about the UK’s ethical standards system than the propriety of his conduct, argues Dr Hannah White

The former prime minister is facing questions about the way he has used his political connections to lobby ministers on behalf of Greensill Capital – the now-collapsed Anglo-Australian financial services company. Although Cameron only started working for the company two years after leaving office, his connection with Lex Greensill stretched back into his time as premier, during which the financier was brought into No.10 as a business adviser by the then cabinet secretary, Jeremy Heywood.

Scrutiny has focused on the fact that Cameron lobbied the current chancellor, Rishi Sunak, to allow Greensill to access Covid-related business support (unsuccessfully as it turns out). Separately, his decision to help Greensill woo the de-facto leader of Saudi Arabia, Mohammed bin Salman, just a year after the murder of the journalist Jamal Khashoggi, has raised questions about his judgment. Cameron himself has not responded to these challenges but his former colleagues – including the business secretary, Kwasi Kwarteng – have emphasised that he followed the rules governing the interests of former ministers.

Cameron’s actions were permissible under UK rules on lobbying

It is correct that nothing Cameron has been criticised for is against the UK’s rules on lobbying. Once he had left office, he was no longer bound by the rules on disclosure of financial interests that govern MPs, or by the Ministerial Code, which precludes ministers from conflicts between their official position and their personal financial interests. As more than two years expired between his resignation as PM and starting work for Greensill, he was not required to bring the role to the attention of the Advisory Committee on Business Appointments (ACOBA) – the body tasked with advising ministers and senior civil servants on whether appointments they take on after leaving government might give rise to any justified public concern, criticism or misinterpretation.

Because Cameron was employed by Greensill, rather than contracted as a consultant, he was not required to register his lobbying activity with the Office of the Registrar of Consultant Lobbyists (ORCL), the body established in 2014 during his first term as prime minister. In a fudge agreed between the Conservative and Liberal Democrat coalition partners, the ORCL was given a limited remit – to introduce transparency only to the activities of consultant lobbyists, not those employed by firms in-house.

Some have argued, in response to the furore that has blown up over Cameron’s actions, that after the two-year ACOBA cooling off period (which it has no powers to enforce), former politicians should be allowed to take whatever employment opportunities present themselves. They make the case that this has become even more important since political careers have shortened. This is what the rules currently allow. 

Cameron’s actions should be judged against the principles of conduct in public life

But just because no rule has been broken it does not necessarily follow that Cameron’s actions were well judged. It is precisely because it is difficult to write ethical rules that will account for every possible situation, that the UK’s system for regulating ethics in public life is underpinned by a set of principles – the ‘seven principles of conduct in public life’ first formulated by Lord Nolan in 1995 and overseen since by the Committee on Standards in Public Life. While the Nolan principles have no independent enforcement mechanism, they are incorporated into numerous codes of conduct (including the Ministerial Code) and are generally agreed to form the basis of the ethical standards expected of public office holders in the UK. They include integrity, objectivity and openness.

Technically, of course, Cameron is no longer a public office holder, and so under no obligation to act in accordance with the principles. But he remains one of the best-known politicians in the UK. One would hope that he would have made decisions about what post-government employment opportunities to pursue in an awareness of how they would appear to the public – and what that might do to public confidence in politicians.

Had he tested his decision to take a job from Lex Greensill after working closely with him in government against the principles of conduct in public life, Cameron might have anticipated the consequences we have now seen. The stories that have been reported in the press are fuelling public perceptions of the venality of politicians, enhancing concern about the role of business figures in advising government, raising questions about the adequacy of rules surrounding the conduct of people in public life and damaging Cameron’s own reputation. 

Cameron’s involvement with Greensill is a reminder of the importance for public figures of continuing to consider how their actions will appear to the public after leaving office. The Nolan principles should be a powerful guide to making such judgements, but there is also a case for tightening the rules – to increase transparency about appointments taken up, and to extend the period after leaving office during which such transparency is required. 


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