david - no, I don't think it is. There is a resemblance, certainly, but there are a couple of things against.
Firstly, I can't think what Fraser would have been doing with a bunch of aircrew officers at (probably) either Daedalus or Condor.
Secondly, the dates are wrong. The OM was commissioned in 1942 with seniority back to 1st. Feb 1941. He made Lt. Cdr just after the war ended. He's quite clearly wearing a Lt's bars in this pic, one promotion after being commissioned. So the pic has to be sometime 43-ish onwards. Fraser was already a Vice Admiral in May 1940, and the bloke in the pic is quite clearly a Rear.