Cabinet Office
3 November
2025
Paid appointment with the Benefact Group: Application under the
Business Appointment Rules from Sir Matthew Rycroft KCMG CBE, former Permanent
Secretary at the Home 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 Sir
Matthew Rycroft KCMG CBE, formerly Permanent Secretary at the Home Office. The
application is for a paid role as a Senior Adviser with the Benefact Group.
Further detail on the content of the application is in the Annex. The
Commission’s advice is required as Sir Matthew is a former civil servant at SCS Pay Band 4. His last day of service was 28
March 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. Sir Matthew should
observe a waiting period of
three months from his last day in civil service.
This concluded on 28 June 2025.
2. Sir Matthew 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 civil service.
3. For two years from his
last day in civil service office, until 28 March 2027, Sir Matthew should not become personally involved in lobbying[3] the
UK government or its arm’s length bodies on
behalf of the Benefact Group (including parent
companies, subsidiaries, partners and clients); nor should Sir Matthew 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 Benefact Group (including parent companies,
subsidiaries, partners and clients).
4. For two years from his last day in civil
service, until 28 March 2027, Sir Matthew should not provide advice to the
Benefact 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.
Sir Matthew and Benefact Group confirmed to the Commission of his
intention to fully comply with the lobbying ban that applies to him. Benefact
Group stated that ‘Sir Matthew’s duties are structurally separated from any
lobbying activities’.
The Rules set out that civil servants must abide by the
Commission’s advice. It is Sir Matthew’s 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.
Sir Matthew must inform the Commission as soon as he takes up this
work or if it is announced that he will do so. Similarly, Sir Matthew 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,
the advice letter will be published on the Civil Service Commission’s website.
Yours sincerely,
Gisela Stuart
First Civil Service Commissioner
Annex A: The application
Applicant assessment
1. According to its website, the Benefact Group is an
international financial services group that operates in specialist markets,
including insurance, investment management, and broking and advisory.[4]
Owned by the Benefact Trust, a registered charity, the group gives all of
its available profits to charities and supported causes.
2. As Senior Adviser, Sir Matthew’s responsibilities will involve
advising the CEO of the Benefact Group on future strategy, including
determining the key areas of focus work on. This should include, but is not
limited to:
●
Advising potential headline aspirational goals to monitor progress
and act as rallying calls / sources of inspiration
●
Identifying the (key) market segments in which the Group’s
business currently play (as well as potentials for the future)
●
Building a strategy to
develop intimacy - deepening its relationships and reach within each of those
sectors (and ultimately increasing customer penetration), in particular -
○
Advising how it can best help that sector (for the good of
society)
○
Identifying a potential runway of thought leadership topics and/
or events
●
Recommending options for its future giving strategy (breadth and
depth), and, crucially, how this may be amended to assist future growth
●
Recommend ways in which to move and inspire all its colleagues
●
Recommend ways in which to involve its customers and potential
customers
●
Marketing strategy – particularly ways to increase word of mouth
referrals, advising moving content for films relevant to growth areas, and its
“thank you” strategy[5].
●
Offering high-level observations on the interplay between the
Group’s brand, the Trust, and its subsidiaries.
●
Any other observations on the overarching Group strategy in
helping each segment/sector, its intention is to build the Benefact and trading
brands, helping the businesses grow so that, ultimately, it can give back more.
3. Sir Matthew confirmed his role will not involve contact with,
or lobbying of government. He stated he did not meet with the Benefact Group,
nor had involvement in policy development or decisions specific to the
organisation. He added that he was not privy to sensitive information that
could provide the Benefact Group an unfair advantage.
Departmental assessment
4. As Permanent Secretary, Sir Matthew would have had access to
significant amounts of privileged information, including unannounced changes in
government policy. However, from the available information, there is no overlap
between the work of his department and that of his proposed employer. The
department did not highlight any specific information that would be a concern.
5. The Home Office confirmed that Sir Matthew was not involved
in any regulatory, policy or commercial decisions specific to the Benefact
Group.
6. The Home Office noted that the Benefact Group has retained the
services of a registered consultant lobbyist.[6]
7. The Home Office and the Cabinet Office recommendation on Sir
Matthew’s appointment was for a three-month waiting period from his last day in
post (now elapsed) and the standard conditions.
CSC analysis
8. Risk of reward. There is no known overlap between Sir
Matthew’s role as Permanent Secretary and the Benefact Group. He did not meet
with the organisation, nor was he involved in decisions specific to the
Benefact Group. The Commission agreed with the department’s view that the risk
that he was offered this role as a reward for decisions or actions taken in
office was low.
9. Access to information. It is likely that as Permanent
Secretary, Sir Matthew had access to a wide range of information that may
benefit any organisation, including the Benefact Group. This risk is reduced by
the time passed since leaving government service (over six months) and that the
Home Office is unaware of any sensitive information he may possess that
presents a risk.
10.Improper influence. There are risks associated with a
former senior civil servant joining an organisation that may seek to influence
government. Sir Matthew stated that his role
will not involve contact with, or lobbying of, government.
However, as an organisation with a lobbying arm, there is a perception risk
that Sir Matthew may be involved in such activities. Sir Matthew and Benefact
Group confirmed to the Commission of his intention to fully comply with the
lobbying ban that applies to him. Benefact Group stated that ‘Sir Matthew’s
duties are structurally separated from any lobbying activities’.
[1] See the Business
appointment rules for Crown servants.
[2] Meaning official information to which a civil servant
has had access as a consequence of his or her office or employment and which
has not been made publicly available.
[3] As defined in the rules.
[5] Strategy that is primarily centred on converting
their commercial success into significant charitable impact, by donating all
available profits to causes.