List of ministers' interests

Introduction

The Scottish Ministerial Code sets out in Part B, Chapter 3 the standards expected of Ministers in the handling of their private interests.

The overriding principle, as set out at paragraph 3.1 of the Code, is that “Ministers are appointed to serve the public and must ensure that no conflict arises, or could reasonably be perceived to arise, between their public duties and their private interests, financial or otherwise. This is an ongoing duty that applies throughout a Minister’s period in office”.

At paragraph 3.2, the Code makes clear that “It is the personal responsibility of each Minister to decide whether and what action is needed to avoid a conflict or the perception of a conflict, taking account of advice received from the Permanent Secretary and the Cabinet Secretariat”.

The Code stipulates that, “On appointment to each new office, Ministers must provide the Permanent Secretary with a full declaration in writing of private interests which might be thought to give rise to a conflict in relation to their Ministerial office, actual or perceived. The declaration should also cover interests of the Minister's spouse or partner, and close family members which might be thought to give rise to a conflict. The Permanent Secretary will also seek confirmation from Ministers, at the time of their appointment, as to whether they are aware of any close acquaintances or advisers who have a contractual relationship with the Government or are involved in policy development.”  

Paragraphs 3.9 to 3.12 of the Code set out some of the steps that may be advised so that interests that are retained can be managed in a way which does not give rise to a conflict of interest. That may include, for example, a Minister being recused from decision-making on a particular issue.

The current version of the Ministerial Code, published on 17 December 2024, notes that “A list of each Ministers’ declared interests will be published on the Scottish Government website within a reasonable period following their appointment and in line with Freedom of Information and Data Protection legislation. It goes on to say that “Each year, during Parliament’s summer recess, the Cabinet Secretariat will remind all Ministers to review their interests in the light of their portfolio or other ministerial responsibilities, to consider any possible conflict issues, and to seek advice where necessary". While the published lists of Ministers' interests will be reviewed and, where necessary, updated on at least an annual basis, Ministers are expected to notify the Permanent Secretary as soon as they are aware of any relevant change and the published list of interests will be updated promptly once any required action has been agreed.

The 2024 edition of the Code also introduced a new process, set out at paragraph 3.8: “At each annual review of Ministers’ declared interests, the First Minister’s Independent Advisers will be invited to provide independent assurance about the process followed by the Cabinet Secretariat to support Ministers in managing their private interests.”

The published list is not a register of interests and does not therefore necessarily include every interest or detail that a Minister has declared in relation to themselves and their family members. To do so would represent an excessive degree of intrusion into the private affairs of Ministers that would be unreasonable, particularly in respect of their family members. The list instead documents those interests, including of close family, which are, or may be perceived to be, directly relevant to a Minister’s Ministerial responsibilities. The list also provides details of charities where a Minister is a trustee, patron or member. 

Personal information relating to third parties, as well as personal financial information which Ministers disclose, is treated in confidence and may not be disclosed without their permission.

Information held on Ministers’ private interests is still subject to the Freedom of Information (Scotland) Act 2002 (FOISA). Any request for information will be subject to case-by-case consideration. Information may be exempt from release if it is already in the public domain (for example, in the Minister’s government declaration of interests or their MSP Register of Interests) or if its release would contravene data protection principles under section 38(1)(b) of FOISA.

Information on Ministers’ private interests has been released previously in response to information requests. For example, information was released in March 2023.

As a general principle, all list entries should be read alongside the relevant Member of the Scottish Parliament’s Register of Interests.