Mark Fullbrook, Liz Truss’s former chief of staff has been given the go-ahead to resume leading his lobbying firm – and has been spared the usual two-year ban on post-government lobbying because his former employer’s tenure in Downing Street was so short lived.
The former aide returned to Fulbrooke Strategies in January – just three months after he departed Downing Street along with Truss.
Acoba has imposed only a six-month ban on Fullbrook lobbying the government – just a quarter of the usual two-year ban for departing senior officials – despite saying that leading a lobbying firm would usually be an “unsuitable” job under the anti-corruption rules.
It has signed off on the appointment on the basis that Fullbrook was only in office for 49 days – and that the policy decisions underpinning the disastrous mini-budget that was the focus of Truss’s administration have since been “significantly altered”.
“As a result the Cabinet Office considered it is highly likely the currency of information Mr Fullbrook had access to is degraded and the risk any matters he advises future clients on will overlap with his work in office is limited,” Acoba said in a letter to the former chief of staff.
For these reasons, the committee said there could be no “reasonable suspicion” that Fullbrook would be able to gain clients or unfairly influence the government as a result of his chief of staff role six months after leaving.
The period is therefore “proportionate” and sufficient to mitigate any advantages he may have gained during his seven-week stint in Downing Street – which the committee said would likely be limited to “general insight” and access to information “across a broad spectrum of issues”.
Fullbrook announced the company had resumed business in a LinkedIn post last week.
Fullbrook Strategies halted its commercial activity when Truss appointed its chief exec as her chief of staff after becoming prime minister in early September. It had been founded just a few months earlier in Spring 2022 by Fulbrooke himself.
His appointment quickly came under scrutiny, after it emerged he was being paid through the consultancy – an arrangement that could enable him to pay less tax.
No.10 initially defended the arrangement, which had been signed off by the Cabinet Office’s propriety and ethics team, saying it was “not unusual for a special adviser or civil servant to join government on secondment” and that Fullbrook would be “subject to the usual special adviser or civil service codes”.
However, he was later moved onto a special adviser contract to avoid "any ongoing speculation".
During the six months Fullbrook is subject to Acoba’s advice, he must ensure there is “no reasonable cause for concern that he is lobbying the UK government” – especially given that some of his firm’s previous lobbying activities would not be allowed under the appointment rules.
This means taking “all necessary steps to ensure that no person working with or for Fullbrook Strategies engages in any activity that could be construed as lobbying the government for a period of six months”, it said.
Acoba’s advice also prevents the former aide from advising any other clients on work related to “matters he had a material role in developing or determining” during his time at No.10.
“The committee considers the circumstances of this appointment highly unusual given Mr Fullbrook’s tenure was limited to 49 days; the limited exposure he therefore had to government policy and decision making; and the policy changes that occurred before and after he was in service,” the letter said.
“The Cabinet Office, as owner of the government’s rules, described it as disproportionate to the risks in this case to apply conditions for the two years that the rules apply. The committee agreed with the Cabinet Office and determined there were exceptional circumstances in the specifics of Mr Fullbrook’s application.”