Cabinet Office
10 November
2025
Paid appointment with the Gerson Lehrman Group: Application under the Business
Appointment Rules from Mr James Lyons, former Director of Strategic Communications at the Prime Minister’s
Office.
Thank you for submitting an application for advice under the
Business Appointment
Rules[1] (the Rules) to the Civil
Service Commission (the Commission) on behalf of James Lyons, formerly Director of
Strategic Communications at the Prime Minister’s Office. The application is for a paid role as
a Speaker and Adviser with the Gerson Lehrman Group. Further
detail on the content of the application is in the Annex. The Commission’s advice is required as Mr
Lyons is a former special adviser at Special
Adviser Pay Band 4. His last day of service was 1 September 2025.
The purpose of the Rules is to protect the integrity of the
government. They aim to
avoid any reasonable concerns that: a civil servant may be
influenced in their official duties by
the risk of reward; a civil servant may improperly exploit access to information; and an organisation may gain an
improper influence through the
employment of a civil servant.
The Commission’s advice is
that the appointment should be made subject to the following conditions:
1. Mr Lyons 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[2] available to him from his time in office.
2. For two years from his
last day in office, until 1 September 2027, Mr Lyons should not become
personally involved in lobbying[3] the UK government or its
arm’s length bodies on behalf of the Gerson Lehrman Group. He should also not
make use, directly or indirectly, of his contacts in the government and/or
civil service to influence policy, secure business/funding or otherwise unfairly
advantage the Gerson Lehrman Group. These restrictions apply to parent
companies, subsidiaries, partners and clients.
3. For two years from his last day in office, until 1 September
2027, Mr Lyons should not provide advice to the Gerson Lehrman Group, 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 or its arm’s length bodies.
4. For two years from his last day in office, until 1 September
2027, Mr Lyons is prevented from advising GLG or its clients on work regarding
any policy or operational matter he had a material role in developing or
determining, or where he had a material relationship with the company or
organisation, in his former role.
The Rules set out that special advisers must abide by the
Commission’s advice. It is Mr Lyons’ personal responsibility to manage the
propriety of any appointment and to understand any other rules and regulations
they may be subject to in parallel with the Commission’s advice.
Mr Lyons must seek advice if he proposes to extend or otherwise
change his role with the organisation. Once this appointment has been publicly
announced or taken up, Mr Lyons is obliged under the Rules to inform the
Commission who will publish this letter on its website.
Yours sincerely,
Gisela Stuart
First Civil Service Commissioner
Annex A: The application
Applicant assessment
1. According to its website, Gerson Lehrman Group (GLG) is a large
financial and global information services consulting company.
2. As Speaker and Adviser at GLG, Mr Lyon’s responsibilities will
involve speaking at GLG events and giving strategic advice to GLG clients. He
said that advice and insight offered would be based on his experience
predominantly acquired before entering government.
3. Mr Lyons confirmed his role will not involve contact with
government. He stated he had no official dealings with GLG, nor any involvement
in policy development or decisions specific to the organisation, during his
time in office.
Departmental assessment
4. As Director of Strategic Communications at the Prime Minister’s
Office, Mr Lyons was exposed to some privileged information about the
government’s legislative and policy programme, though the Cabinet Office
confirmed that Mr Lyons's insight into major announcements was unlikely, as
communications discussions had not begun when he left.
5. The department noted the two month gap
between Mr Lyons leaving government and starting this role would likely
diminish the currency of any information still retained. The Cabinet Office
also said GLG operates a policy requiring members and clients to not divulge,
reveal, or request any non-public information or confidential material from
their previous employment.
6. The Cabinet Office confirmed that Mr Lyons was not involved in
any regulatory, policy or commercial decisions specific to GLG.
7. The Cabinet Office
recommended standard conditions.
CSC analysis
8. Risk of reward. Mr Lyons had no official dealings with
GLG and was not involved in policy, regulatory, or contractual decisions
affecting the organisation during his time in post. The risk of the appointment
being a reward for decisions made in office is therefore low.
9. Access to information. As a Special Advisor at the
centre of government, Mr Lyons would have been exposed to some privileged
information about the government’s legislative and policy programme. However,
the Cabinet Office confirmed he was not aware of anything detailed about
unannounced plans. Further, GLG policy requires members and clients not to
request or divulge non public information. The
standard privileged information ban mitigates any remaining risks around his
access.
10. Improper influence. There is a risk that Mr Lyons'
appointment could offer an unfair influence to GLG and its clients. As a former
Special Advisor, he would have had significant political contacts and knowledge
of the inner workings of government, which clients could seek to leverage. This
perception that he could secure an unfair advantage, influence government
policy, or improve success in government bids and contracts, is mitigated by
the standard lobbying condition. Mr Lyons stated he would not have contact with
government in the role.
11. Unknown clients. The Commission considered that there
are risks associated with the unknown, ad-hoc nature of GLG's clients. The
Commission recognised that his role in government was communications-focused,
which limits his material involvement in policy and operational decisions and risks
involved. A condition is applied to mitigate any remaining risk, preventing him
from advising GLG or its clients on work regarding any policy or operational
matter he had a material role in developing or determining, or where he had a
material relationship with the company or organisation, during his time in
government.