Cabinet Office
5
December 2025
Paid appointment with Aspire Defence Ltd: Application
under the Business Appointment Rules from Sir Gareth Rhys Williams Bt CB, former Government Chief Commercial Officer at the
Cabinet 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
Gareth Rhys Williams Bt CB, formerly Government
Chief Commercial Officer at the Cabinet Office. The application is for a part
time, paid role as Non Executive
Chairman with Aspire Defence Ltd (Aspire Defence). Further detail on the
content of the application is in the Annex. The Commission’s advice is required
as Sir Gareth is a former civil servant at SCS Pay Band 3. His last day of
service was 5 July 2024.
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 this
appointment should be subject to the following conditions:
- Privileged
information – Sir Gareth should not draw on (disclose or use for the
benefit of himself the persons or organisations to which this advice
refers) any privileged information[2] available to him from
his time in office.
- Lobbying –
For two years from his last day in office, until 5 July 2026, Sir Gareth
should not become personally involved in lobbying[3] the UK government or
its arm’s length bodies on behalf of Aspire Defence (including parent
companies, subsidiaries, partners and clients). 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 Aspire Defence (including parent companies,
subsidiaries, partners and clients).
- Bids and
contracts – For two years from his last day in office, until 5 July 2026,
Sir Gareth must not provide advice to Aspire Defence on any bid or
contract relating to the UK government or its arm’s length bodies. He can,
however, draw on his skills and experience to advise Aspire Defence on the
subject matter of the Project Allenby/Connaught contract with the Ministry
of Defence, provided he does not draw on any privileged information or
contacts from his time in the civil service.
Sir Gareth confirmed to the
Commission his intention to fully comply with the conditions that apply to his
role. Aspire Defence also confirmed its understanding of, and adherence to the
conditions that apply to Sir Gareth’s role as Non Executive Chairman.
The Rules set out that civil servants must abide by the
Commission’s advice. It is Sir Gareth’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 Gareth must seek advice if he proposes to extend or
otherwise change his role with the organisation. This includes involvement in
any renegotiation of the terms and requirements of the Project
Allenby/Connaught contract while he is subject to the Rules. Once this
appointment has been publicly announced or taken up, the 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
- Aspire Defence Ltd (Aspire Defence) is a special
purpose vehicle that was set up in 2006 to deliver the 35-year Project
Allenby/Connaught. Until 2041,
Aspire Defence is responsible for building, improving and maintaining
soldiers’ single living and working accommodation on several Army
garrisons. Aspire Defence holds the contract with the Defence
Infrastructure Organisation, an arm’s length body of the Ministry of
Defence (MOD). It sub-contracts to Aspire Defence Capital Works for
delivery of the construction programme and to Aspire Defence Services for
a broad range of facilities management services delivered over the 35
years of the contract. As a private finance initiative[4], funds were raised
through a combination of bond funding and equity to complete the initial
construction phase of the project. Aspire Defence is owned by three
shareholders: KBR Inc. (as majority shareholder), Innisfree and InfraRed.
Both Aspire Defence Capital Works and Aspire Defence Services are owned by
KBR Inc.
- As Non
Executive Chairman, Sir Gareth stated his roles and
responsibilities at Aspire Defence will be to:
● Guide the Executive and Board of
Shareholder Directors, ensuring the company is governed effectively and in the
best interests of its shareholders and stakeholders.
● Resolve company matters to avoid
escalation to the Board wherever possible.
● Act as a ‘sounding board’ for the CEO
and aim to keep the Executive acting on the owner’s intent.
- Sir Gareth stated that he is unlikely to have
contact with his former department, the Cabinet Office. However, given
Aspire Defence’s business with Project Allenby/Connaught he expects that
he will attend meetings at MOD barracks with other Aspire Defence officials
to check on the delivery of its contract and he may be contacted by MOD
officials in the event of delivery issues. He stated that contact with
government will be at their request: specifically
the contract manager and/or officials of the Defence Infrastructure
Organisation. He also noted that this contract is a PFI, meaning its terms
and requirements are agreed and scheduled. He added that concerns relating
to lobbying for business or contract negotiation are not present in this
case.
- Sir Gareth stated he did not meet with Aspire
Defence during his time in post, nor did he have involvement in commercial
or contractual dealings with the company. He stated that whilst it may be
possible that KBR Inc. may have been awarded contracts with government whilst
he was in the civil service, he is not privy to any details or specific
information, including which departments they may be with. He stated that
while any such contracts would have been led by members of the Government
Commercial Function - who were all functionally responsible to him through
their management and commercial director structures - he was ultimately
not privy to or involved in any relevant evaluation, management or
decisions on bids and contracts.
- As Government Chief Commercial Officer, Sir
Gareth was responsible for evolving and implementing the Civil Service
commercial strategy for the Civil Service, positioning the commercial
function as a key delivery partner in all commercial relationships and
helping departments realise efficiency savings. He was responsible for
leading and building strong commercial expertise across all government
departments, senior officials and leaders of government suppliers.
- Sir Gareth left the civil service on 5 July 2024.
He noted that his role was restricted in February 2024 to avoid conflicts
with his potential roles post-government service. He stated from February
2024 until his end of service, he:
● did not review, nor was exposed to
documentation naming final stage vendors;
● did not attend meetings about or with
vendors unless the discussions on commercial matters were limited to the
application of frameworks or similar publicly available information;
● did not attend meetings where vendor
bids were decided upon;
● stepped down from Cabinet Office
committees, including the Executive Committee and Performance and Risk
Committee;
● removed himself from any further
business planning; and
● arranged for any correspondence
intended for the Government Chief Commercial Officer to be re-routed to the
Chief Operating Officer mailbox.
Correspondence
with Aspire Defence
- Aspire Defence confirmed its understanding of,
and adherence to the Commission’s advice and the conditions imposed on Sir
Gareth’s appointment.
Departmental
assessment
- The Cabinet Office confirmed Sir Gareth did not
meet with Aspire Defence and was not involved in decisions specific to the
organisation or its main shareholder KBR Inc. during his time in post. The
department noted it does not hold a relationship with Aspire Defence,
though the Defence Infrastructure Organisation does.
- The Cabinet Office did not consider Sir Gareth to
possess sensitive information that may provide an unfair advantage to
Aspire Defence. It also noted that during his time in service, ‘ethical
walls’ were introduced regarding his access to information by the then
Cabinet Office Permanent Secretary to reduce potential conflict in the
event of future job offers.
- The Cabinet Office did not have concerns with the
appointment, nor with the nature of his contact with government. It
affirmed that contact of this nature would not be considered to meet the
definition of ‘lobbying’ as set out in the Business Appointment Rules. The
department recommended the standard conditions.
CSC’s
analysis
- Risk of reward. Sir Gareth did not have contact with Aspire
Defence, nor was he involved in any decisions specific to the organisation
or KBR Inc., commercial or otherwise. The risk of reward for decisions or
actions taken in office is likely to be low.
- Access to information. It is likely that Sir Gareth
had access to a wide range of information that may benefit many
organisations, though the Cabinet Office did not note anything specific
relating to this application. The risk relating to his access to
information is not specific to the work of Aspire Defence given the
organisation’s operation overlaps with the work of the Ministry of
Defence, a department he was not employed by. There is no known overlap
with the work of Aspire Defence and his former department. Further, it has
been over 16 months since he left the civil service, and information
barriers introduced during his last few months of employment will have
reduced the currency of any information he may possess.
- Improper influence. This appointment may include
contact with government at its request relating to Aspire Defence’s
operational delivery of Project Allenby/Connaught. The Commission
considered the risk limited in relation to Sir Gareth utilising his skills
and experience to work on Project Allenby/Connaught on behalf of Aspire
Defence. In considering the related risks, the Commission gave weight to
the following details:
● This work is a long
standing programme between Aspire Defence and the Defence Infrastructure
Organisation and predates Sir Gareth’s time in government. It will end in 2041,
significantly after he is subject to the Rules. Given there are agreed
government frameworks in place to govern the delivery of the programme, the
risk that one individual is able to provide an undue influence on its delivery
process is limited.
● The Cabinet Office did not flag any
privileged insight Sir Gareth may have that presents a risk, and there is no
known overlap with Sir Gareth’s responsibilities in government and anything
that relates to the work of the MOD or Project Allenby/Connaught.
- However, if while Sir Gareth is subject to the
Rules there is a change to the existing scope of Aspire Defence's work on
Project Allenby/Connaught, or if terms and requirements of the contract
demand renegotiation, this advice requires that he should return to the
Commission to seek further advice regarding his involvement.
- Whilst the Commission considered the risks
associated with Sir Gareth advising on the subject matter of Project
Allenby/Connaught to be limited, there remains a risk associated with his
contacts and influence within government. This influence could, or be
perceived to, offer Aspire Defence an unfair advantage or improper access
to government. To mitigate this risk, the Commission has imposed a ban on
advising on any other bid or contract with government and further
conditioned that any contact with government be limited to matters
concerning Project Allenby/Connaught.