Recommendation 10

At least some of the criticism of the appointment of Lex Greensill to advise on the use of Supply Chain Finance is made with the benefit of hindsight and knowledge of events that were to take place some years later. His appointment appeared to entail the usual declaration of interests and there were no obvious conflicts at that time. The Pharmacy Early Payment Scheme appears to have been compliant with normal commercial practice by Government. That Lex Greensill had been involved in the design and implementation of the scheme might raise eyebrows. Indeed, we recognise that the public perception of this may give rise to legitimate concerns regarding the robustness of the existing arrangement relating to conflicts of interest. However, it was compliant with his contractual obligations as an adviser and, had they been applicable, would also have been compliant with the Business Appointment Rules. Whether the Business Appointment Rules are sufficiently broad or stringent is a theme we shall be considering in the next phase of this inquiry. (Paragraph 45) 26 Propriety of Governance in Light of Greensill: An Interim Report Lord Heywood’s involvement