Business Appointment Rules advice: Shona Robison

Former minister: Shona Robison, former Cabinet Secretary for Finance and Local Government
Left office: May 2026
Appointment: Strategic Adviser; Dundee and Angus College 
Advice provided: August 2026 
Appointment start date: September 2026

Thank you for your application under the Business Appointment Rules for Former Ministers (‘the Rules’) in relation to your prospective appointment to Dundee and Angus College as a part-time Strategic Adviser. 

The purpose of the Rules is to protect the integrity of government, while enabling individuals to move to roles outside of government, by seeking to ensure that those who have served in government do not profit improperly from that experience and that their future employer does not gain unfair advantage through privileged access to government. 

Section 12.2 of the Scottish Ministerial code sets out the process that former Ministers must follow, including seeking advice from the Independent Advisers before taking up any appointments or employment. 

We have carefully considered your application, and consider that the following conditions should be applied. It is your responsibility to ensure that these are demonstrably applied in practice:

• waiting period – the planned commencement date of 14 September for this role falls outside the standard waiting period of three months since leaving office which applies to applications from former Cabinet members. For the avoidance of doubt, we would reiterate that you may not commence this appointment in advance of 20th August 2026. Should a change to planned timings occur you must let the secretariat know. We do not consider that the standard waiting period needs to be extended
• privileged information condition – you should not draw on (disclose or use for the benefit of Dundee and Angus College, including its related parties 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 Government or its arms-length bodies on behalf of Dundee and Angus College (including its related parties 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 Dundee and Angus College (including its related parties and clients)
• contracts and bids condition – for two years from your last day in office, you should not undertake any work with Dundee and Angus College (including its related parties and clients) that involves providing advice on the terms of a bid with, or contract relating directly to the work of, the Government or its arm’s length bodies

We would be grateful if you would additionally note the following points:

• this advice is not an endorsement of the appointment
• this 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 this 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 us 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,

Claire Loftus, Sir Ernest Ryder and Sir John Manzoni, 
The First Minister’s Independent Advisers on the Ministerial Code 

Annex – Material information and consideration of the risks

The role 

You wish to take up a paid, part-time role as a Strategic Adviser (SA) on the Transformation and Regeneration Vision, at Dundee and Angus College (DAAC) a Scottish further education college providing vocational, further and higher educational opportunities to the people of Dundee and Angus.  

Your role would include 

• strategic advice and challenge by providing independent, high-level advice to the Principal and senior leadership team on the strategic development, positioning and delivery of the Transformation and Regeneration Vision
• advice on their stakeholder engagement strategy, supporting effective engagement with key local, regional and national stakeholders, including public bodies, civic partners, employers, community partners and wider system leaders
• provide support in navigating, understanding and managing the strategic, political, civic and delivery complexities associated with a large-scale transformation and regeneration programme
• help strengthen the articulation of the programme’s public value, particularly in relation to skills, employability, social mobility, public service reform, economic regeneration and place-based renewal
• provide advice on governance, partnership alignment, stakeholder confidence and risk management, ensuring the programme is positioned credibly and responsibly. 
• support the college to refine key messages, briefings and strategic narratives for different audiences, ensuring the project is understood as a transformation programme rather than solely an estates project
• act as a trusted adviser to the Principal and senior team, providing constructive challenge, insight and perspective on next steps, risks, opportunities and stakeholder dynamics

Departmental assessment

The Scottish Government (SG) confirmed that your role as Cabinet Secretary for Finance and Local Government included financial decision making at sector level for education budgets but that you did not have influence or involvement in onward allocations at institutional levels, as these responsibilities sit within the Education and Skills portfolio with an independent NDPB supporting decision making in the tertiary education landscape. The Scottish Government’s Propriety and Ethics directorate have recommended that the standard conditions apply to the appointment.

Our consideration of the risks

The risks relating to your involvement in policy, regulatory or commercial decisions specific to DAAC are limited because:

• you were not responsible for Policy, regulatory or commercial decisions relating to the institution while in your previous Ministerial Appointments 
• you were not responsible for funding decisions at an individual institutional level, though did have overall budget responsibility for Scottish Budget setting, which included Education budget allocations
• announcements of funding increases in this financial year are already in the public domain, following announcements made in March 2026 supported by the Scottish Funding Council (SFC)
• SG had no concerns over your access to privileged information in relation to this appointment, subject to your ongoing obligations under the Ministerial code

We have noted that DAAC is a local further education institution in your local authority and your desire to support this local institution to deliver its transformation and regeneration programme.

We note DAAC’s main interactions with Government, are delivered via Scottish Funding Council alongside Ministers and officials in the Education Portfolio, these connection routes will be maintained after your advisory role commences.  

Your role with DAAC highlights your advisory capacity on effective engagement with wider system leaders alongside support to understand and navigate the complex landscape of a significant transformational programme, which will include political attuite.  You have confirmed this will not include direct engagement personally with Scottish Government or government more generally.  

In respect of contacts in other governments and organisations acquired only as a result of your role as a minister, there is therefore a risk you could be seen to advantage DAAC unfairly by drawing on such contacts on its behalf to secure funds or opportunities for new income streams. We have therefore applied a restriction to prevent you from lobbying these contacts for the purpose of fundraising or prospecting for new income streams for DAAC.

We also consider it of significant relevance that DAAC has provided written confirmation of its agreement to comply with the advice and of the separation of your role from lobbying. These factors significantly limit the risk of a reasonable perception that you are being appointed to influence the Government on the organisation’s behalf.