Interests of independent advisers on Scottish Ministerial Code: FOI release

Information requested

Please supply all items of information in the list of professional roles supplied to the First Minister by the independent advisers on the Scottish Ministerial Code in line with their terms of reference; all information in any 'relevant changes' notified by any adviser to the First Minister; all information notified by any adviser about any 'previous connection' with a topic considered under the Scottish Ministerial Code; all information about any recusal of any adviser, including the rationale and name of substitute lead; and all correspondence between the advisers and the First Minister or his office about these specific matters.

Response

In response to the first part of your request, I enclose at Annex A the lists of professional roles that the current three Independent Advisers on the Scottish Ministerial Code have supplied to the First Minister in line with their Terms of Reference to help ensure that no conflicts of interest arise.

In response to the second part of your request, the Independent Advisers have not notified the First Minister of any 'relevant changes' to their lists of professional roles. This is a formal notice under section 17 of FOISA that the Scottish Government does not hold the information you have requested under this part of your request. It may also be helpful to note that, in light of your request, I approached the Advisers to confirm the latest position and the lists provided at Annex A are therefore current as of 19 November 2025.

In response to the third and fourth parts of your request, I can confirm that none of the independent advisers have to date notified the First Minister of any risk of a conflict of interest in relation to any matters they have considered under the Scottish Ministerial Code and they have therefore not, as yet, had to recuse themselves from any specific matter. This is a formal notice under section 17 of FOISA that the Scottish Government does not hold the information you have requested under this part of your request.

In line with the Scottish Ministerial Code and the Independent Advisers' Terms of Reference, should the Independent Advisers become aware of a risk of an actual or perceived conflict between their private interests (including those of their spouse or partner) and their role as an Independent Adviser, or should they have had a previous connection with the topic, the Independent Advisers will take steps to recuse themselves from advising the First Minister on the matter concerned. Another Independent Adviser, or Advisers, without such a conflict, will lead on the work instead.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

FOI 202500493373 - Information released - Annex A

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