General counsel | Whitbread
Clare Thomas
General counsel | Whitbread
What are the key projects you have been involved in over the past twelve months?
Over the past twelve months, the Whitbread legal team has been closely involved in a broad range of strategic, operational and governance projects, working alongside stakeholders across virtually every part of the business.
One of the most significant areas of focus has been supporting Whitbread’s continued growth and transformation agenda. The team has played a central role in major technology and digital initiatives, advising on complex commercial arrangements, data protection, intellectual property and technology matters. This has included supporting the ongoing deployment and optimisation of business-critical systems that underpin our guest experience and operational efficiency across the Premier Inn estate. The legal team has worked collaboratively with technology, operations, procurement and information security colleagues to help deliver these programmes at pace while maintaining appropriate risk management and governance.
The team has also been heavily involved in Whitbread’s property and investment programme, supporting hotel developments, estate optimisation projects, asset transactions and strategic initiatives designed to drive long-term growth. Working alongside property, finance, HR and operational teams, lawyers have provided practical and commercially focused advice from project inception through to implementation.
Alongside these strategic projects, the legal team has continued to support the business in managing a range of complex disputes, regulatory developments, corporate governance matters and emerging legal risks. In particular, the team has worked closely with senior leadership and business stakeholders to navigate evolving areas such as AI regulation, sustainability-related requirements, consumer law developments and data governance.
Across all of these matters, our role has been to act not simply as legal advisers but as trusted business partners, helping colleagues make informed decisions, achieve commercial objectives and deliver outcomes that support Whitbread’s long-term success.
Please provide a brief description of any internal transformation/development projects within your legal team over the last twelve months, such as AI usage, new legal panels, expansion/restructuring of legal team, DE&I initiatives etc.
The past twelve months have seen a significant focus on improving how the legal team operates, with particular emphasis on technology adoption, knowledge sharing and ensuring the team remains closely aligned with the evolving needs of the business.
A key area of activity has been the introduction and practical application of generative AI tools within the legal function. Rather than viewing AI as a standalone initiative, the team has focused on identifying targeted use cases that improve efficiency while maintaining appropriate governance and legal professional standards. This has included using AI to support document review, policy development, horizon scanning, meeting preparation, board and committee administration, knowledge management and first drafts of routine legal documents. The emphasis throughout has been on enabling lawyers to spend more time on strategic and high-value advisory work while maintaining robust oversight and quality control.
The team has also invested in improving legal know-how and self-service resources for the wider business. This includes simplifying policies and guidance, developing more accessible legal resources and increasing engagement with stakeholders through training and proactive horizon-scanning activities. These initiatives have strengthened the team’s role as an embedded business partner and helped colleagues access legal support more effectively.
We have expanded the legal team to include our first ever Property lawyer, Chris Jones, who is playing a pivotal role working alongside our estates and acquisitions teams with the high volume of property legal work associated with our 850 hotel estate and strong growth pipeline.
What are the most important attributes of the modern GC and what advice would you give to those aspiring to be an in-house lawyer?
The role of the modern General Counsel extends far beyond providing legal advice. Technical expertise remains essential, but the most effective GCs are commercially aware, curious about the wider business and able to build trusted relationships across the organisation, particular with the CEO, the rest of the Executive Committee, the Chair and the Board. They need to understand strategy, risk, operations and culture, and be able to communicate complex issues in a simple and practical way. Increasingly, GCs are expected to help organisations navigate change, whether that relates to regulation, technology, reputation or stakeholder expectations.
For aspiring in-house lawyers, my advice would be to spend as much time understanding the business as the law. Be interested in how decisions are made, how customers experience the business and what challenges your colleagues are trying to solve. Strong legal analysis is important, but the ability to provide pragmatic, actionable advice is what makes an in-house lawyer truly valuable. Above all, focus on building credibility and trust; the best in-house lawyers are seen as business partners who help enable success, not simply identify risks.
In which areas does compliance most commonly break down, and how do you address these risks?
In my experience, compliance is most likely to break down when processes are complicated, policies are difficult to find or understand, or colleagues are unclear about what is expected of them in practice. Most people want to do the right thing; the challenge is making that the easiest option. The right approach is therefore based on simplicity and accessibility. Policies should be easy to locate, written in clear, plain language and designed to be practical rather than theoretical. We should aim to remove unnecessary complexity and provide straightforward guidance on what colleagues should do in real-life situations.
Policies alone are not enough to address the risk of compliance breaking down – colleagues need access to the right training, tools and support to make informed decisions. This means combining targeted training with practical resources and clear routes to seek advice when needed.
Lastly, accountability is important – compliance should be recognised and rewarded; the consequences of non-compliance must be clear and consistently applied.
Ultimately, strong compliance comes from creating an environment where people understand what good looks like, have the resources to achieve it and feel supported in doing so. When compliance is simple, accessible and embedded into everyday decision-making, it becomes part of the culture rather than a separate obligation.
How do you help drive strong governance and ethical decision-making across your organisation?
I believe strong governance is most effective when it enables good decision-making rather than simply creating controls and oversight. The role of my team across Legal and Secretariat is to help colleagues understand not only what they can do, but what they should do, taking account of legal, ethical, operational and reputational considerations.
We work closely with stakeholders across the business, often at an early stage of projects and strategic decisions, to provide practical and balanced advice. By building trusted relationships and maintaining a good understanding of the business, we are able to support decision-making in a way that is proportionate, commercially informed and aligned with Whitbread’s values.
Good governance also depends on clarity and transparency. We focus on maintaining clear policies, robust delegation frameworks, effective board and committee processes, and straightforward routes for escalation and challenge when required. Equally important is fostering a culture where people feel comfortable seeking advice and raising concerns.
Ultimately, we see governance and ethics as part of everyday business rather than a standalone compliance exercise. By combining clear frameworks, constructive challenge and strong stakeholder partnerships, we help create an environment where responsible decision-making is embedded throughout the organisation.
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