Has Caroline Spelman broken the Ministerial Code?

New Secretary of State for Farms ‘n’ Stuff, Caroline Spelman, has become the first member of the new administration to be Guido’d. The Right Honourable Member for Meriden cut her teeth as a food and bio-technology lobbyist and was – until less than twelve months ago – director and shareholder of a company responsible for lobbying the department she now runs.

Scrapbook headed straight for the Ministerial Code of Conduct. Former ministers must seek advice from the independent Advisory Committee on Business Appointments on any prospective employment undertaken within two years of leaving office. Were there any provisions for roles performed shortly before appointment to a relevant government portfolio?

A five-minute read soon threw up issues. As Guido reports, Spelman’s lobbying was undertaken in partnership with her husband Mark Spelman, to whom her shareholding in their company Spelman Cormack Associates was transferred less than one year ago. Page 13 of the code may prove unlucky for the happy couple:

The new minister’s interests in this area are well known. Did she raise them with DEFRA Permanent Secretary Helen Ghosh?

Or has Spelman broken the Ministerial Code of Conduct in record time?