OFFICE OF THE ADVISORY COMMITTEE ON BUSINESS APPOINTMENTS
G/7 Ground Floor, 1 Horse Guards Road SW1A 2HQ
Telephone: 020 7271 0839
Email: acoba@acoba.gov.uk
Website: http://www.gov.uk/acoba
September
2025
BUSINESS APPOINTMENT
APPLICATION: General Sir Patrick Yardley Monrad
Sanders KCB CBE DSO OBE, former Chief of the General Staff at the Ministry of
Defence. Paid appointment with STARK.
1. General Sir Patrick sought advice
from the Advisory Committee on Business Appointments (the Committee) under the
government’s Business Appointment Rules for Former Crown Servants (the Rules)
on his proposal to work with STARK as a Strategic Advisor.
2. 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 taken by General Sir Patrick during
his time in office, alongside the information and influence he may offer STARK.
The material information taken into consideration by the Committee is set out
in the annex.
3. The Committee's 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.
4. The Rules[1]
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.
The Committee’s consideration of the
risks presented
5. There is significant overlap between
General Sir Patrick’s responsibilities at the Ministry of Defence (MOD) and the
role at STARK, as the company operates in the defence and security sector.
General Sir Patrick will have made decisions at the MOD that broadly impact the
sector STARK operates in. It is significant that this company was formed as
General Sir Patrick was leaving office and he did not meet with the company,
nor did he make any decisions specific to the company during his time in
service, nor is there a relationship between STARK and the MOD. The Committee[2]
therefore considers the risk this appointment could be reasonably perceived as
a reward for decisions made, or actions taken, in office is low.
6. As former Chief of the General Staff,
General Sir Patrick will have had access to a broad range of sensitive information
around the UK’s defence requirements and capabilities for operations, which
could provide an advantage to any company operating in the defence and security
sector. The MOD said he would have knowledge of long-term strategic thinking of
applications of technology (i.e., drones and AI). He also had oversight, and
therefore knowledge of, capability requirement setting and deployment of
tactical drones, such as those marketed by STARK.
7. There are a number of mitigating
factors that help reduce the risks associated with his access to information
and insight that may be seen to offer STARK an unfair advantage:
● Whilst General Sir Patrick had
oversight of capability requirement setting and deployment of tactical drones,
the MOD confirmed he was not involved in specific commercial or financial
arrangements with suppliers – and therefore he did not have access to
information on competitors that would provide an unfair advantage.
● General Sir Patrick left his role as
Chief of the General Staff in June 2024 and his last day in Crown Service was
31 December 2024. This provides a gap of 12 months between his access to
privileged information and decision-making at the MOD, and his taking up of
this work – reducing the currency of his access to information.
● Given the change of government and
publication of The Strategic Defence Review 2025,[3]
which outlines the overarching framework for drone and AI use in UK defence, it
is likely matters concerning the use of these technologies in UK defence have
moved on since General Sir Patrick’s departure from government.
● The speed of the development of
artificial intelligence is also relevant, given capabilities and products will
have progressed significantly in the last 12 months.
8. Given STARK’s business is defence
drones and AI software, it is difficult to demonstrate that General Sir
Patrick’s wide access to information at the MOD and his proximity to decisions
and other senior decision-makers at the heart of government could not benefit
STARK unfairly. This risk is most likely to arise if he were to advise on
UK-based defence issues. General Sir Patrick said his role with STARK would be
focused on non-UK markets and would involve no contact with the UK government.
9. The MOD acknowledged that General Sir
Patrick has contacts and influence at the highest levels of international
governments and in UK defence, and the Committee considered he undoubtedly has
contacts in the wider defence industry and within NATO militaries and allies.
Whilst explicit business development is not part of his role, it does have a
focus on growth. There is therefore a risk that he could be seen to offer STARK
unfair access to business opportunities as it grows its presence across Europe
and seeks business with NATO militaries and their allies, should he make use of
such contacts gained in office as Chief of the General Staff.
10. There is also a significant risk that
General Sir Patrick could be seen to offer unfair access and influence within
the UK government. The Committee considered it relevant that STARK is a partner
with the UK-based All-Party Parliamentary Group on Defence Technology,[4] and
likely has an interest in the UK defence market. Whilst General Sir Patrick said his role
will not involve any contact with government, the Committee agreed that given
STARK’s work and the above factors, any contact he has with the UK government
or the MOD would risk being seen as lobbying for the purposes of gaining
business. Any contact
initiated by the government would not be contrary to the Rules or the
Committee’s advice.
11. The MOD also suggested that General
Sir Patrick may offer an unfair advantage to STARK in relation to the UK MOD’s
involvement in and funding of international defence programmes given his
seniority and access at the MOD until relatively recently. The Committee
agreed.
12. The Committee asked STARK to confirm
its adherence to the Committee’s advice.
The Committee’s advice
13. The Committee recognised that General
Sir Patrick’s ability to offer an unfair advantage to STARK through any
specific piece(s) of information was limited, but considered General Sir
Patrick’s role in the MOD to present real and perceived risks associated with
his access to information. This is most likely to arise in relation to the
company's potential business in the UK defence market. The Committee has
therefore imposed a condition which prevents him from advising on the UK
defence market – which is in keeping with the role as he describes it.
14. The MOD separately recommended that
General Sir Patrick be prevented from advising on UK government funding of
defence programmes for other nations. The Committee has agreed this to be a prudent course of
action and to impose an additional condition which prevents him from
advising on UK government funding of defence programmes for other nations.
15. It is significant that STARK has
confirmed its adherence with the Committee’s advice. In particular, that
General Sir Patrick would not be involved in any lobbying of the UK government
or advise STARK on the UK defence market and on UK government funding of
defence programmes for other nations.
16. The remaining conditions below are
considered to appropriately mitigate the risks associated with his access to
privileged information, contacts and influence gained as a result of his time
in Crown service.
17. The Committee advises, under the
Government’s Business Appointment Rules, that General Sir Patrick’s role with STARK should be subject to the
following conditions:
● he 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, the MOD or their arm’s length bodies on behalf of STARK (including
parent companies, subsidiaries, partners and clients); nor should he make use,
directly or indirectly, of his contacts in government and/or Crown service to
influence policy, secure business/funding or otherwise unfairly advantage STARK
(including parent companies, subsidiaries, partners and clients);
● for two years from his last day in
Crown service, he should not provide advice to STARK (including parent
companies, subsidiaries, partners and clients) on the terms of, or with regard
to the subject matter of, a bid or contract with, or relating directly to the
work of the UK government, the MOD or their arm’s length bodies;
● for two years from his last day in
Crown service, he should not become personally involved in lobbying contacts he has developed during his time
in office and in foreign governments and external organisations (including NATO
and its allied nations’ governments and/or militaries) for the purpose
of securing business for STARK (including parent companies, subsidiaries and
partners);
● for
two years from his last day in Crown service, he should not advise STARK on the
UK defence market and UK government funding of defence programmes for other
nations; and he must not directly engage with the UK government, the MOD or
their arm’s length bodies on STARK’s behalf (including parent companies,
subsidiaries, partners and clients).
18. The advice and the conditions under
the government's Business Appointment Rules relate to General Sir Patrick’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[5]. 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.
19. 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.
20. 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’.
21. General Sir Patrick must inform us if
and when he takes up this role 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.
22. Once the appointment has been
publicly announced or taken up, the advice letter will be published.
Yours sincerely,
Emily Gillman
Committee Secretariat