Business Appointment Rules advice: Kate Forbes

Former minister: Kate Forbes, Deputy First Minister and Cabinet Secretary for Economy and Gaelic 
Left office: May 2026
Appointment: Columnist, The Sunday Times
Advice provided: August 2026
Appointment start date: September 2026

Thank you for your application, under the Business Appointment Rules for Former Ministers (the Rules), for advice on taking up a paid, part-time role with the Sunday Times. You stated in your application that the role will not involve contact with government.

The purpose of the Rules, as you will be aware, is to protect the integrity of government and to avoid any suspicion that those who have served in government might profit improperly from that experience or that an employer might gain unfair advantage through privileged access to government. To achieve these aims, the Rules designate conditions that former ministers must follow.

The Scottish Government recognises that the risk to government integrity of certain roles, such as unpaid work, academic positions or journalism, can generally be managed effectively by applying a set of standard conditions. Accordingly, we consider that the standard conditions below are appropriate in this instance, recognising that it is your responsibility to ensure that all such conditions are demonstrably applied in practice:

• waiting period – The standard waiting period of three months since leaving office applies to this appointment as a former Cabinet member. For the avoidance of doubt, you may not commence this appointment in advance of 20th August 2026
• privileged information condition – You should not draw on (disclose or use for the benefit of yourself or the Sunday Times, including its parent companies, subsidiaries, partners and clients) any privileged information available to you from your time in ministerial office. This is an ongoing duty irrespective of the time elapsed since you left office
• lobbying condition – For two years from your last day in office, you should not become personally involved in lobbying the UK Government or its arm’s length bodies on behalf of the Sunday Times (including its parent companies, subsidiaries, partners and clients); nor should you make use, directly or indirectly, of your contacts in the government and/or ministerial office to influence policy, secure business/funding or otherwise unfairly advantage the Sunday Times (including its parent companies, subsidiaries, partners and clients)
• contracts and bids condition – For two years from your last day in office, you should not undertake any work with the Sunday Times (including its parent companies, subsidiaries, partners and clients) that involves providing advice on the terms of, or with regard to the subject matter of a bid with, or contract relating directly to the work of, the UK Government or its arm’s length bodies

Please note the following points:

• this advice is not an endorsement of the appointment.
• the advice relates solely to your previous role in government; it is separate from rules administered by other bodies such as the Office of the Registrar of Consultant Lobbyists, the Parliamentary Commissioner for Standards and the Registrar of Lords’ Interests. It is your personal responsibility to understand any other rules and regulations you may be subject to in parallel with my advice
• by ‘privileged information’, we mean official information to which you had access as a consequence of holding office and which is not publicly available. You are also reminded that you may be subject to other duties of confidentiality, whether under the Official Secrets Act, the Ministerial Code or otherwise
• as set out in the Rules, the lobbying restriction means that former ministers ‘should not engage in communication with government (ministers, civil servants, including special advisers, and other relevant officials/public office holders) – wherever it takes place – with a view to influencing a government decision, policy or contract award/grant in relation to their own interests or the interests of the organisation by which they are employed, or to whom they are contracted or with which they hold office’

As soon as you take up the appointment, or if it is announced that you will do so, you are obliged under the Rules to inform the secretariat who will then publish this letter. You must also inform the secretariat if you propose to extend or otherwise change the nature of your role as, depending on the circumstances, it may be necessary for you to make a fresh application.

Yours sincerely,

Business Appointments Secretariat
Propriety and Ethics Directorate
Scottish Government