Scottish National Investment Bank: review of performance 2026

The relationship with the Scottish Government

20. While it was not my main purpose to look at the relationship between the Bank and its Scottish Government shareholder, I heard positive feedback from the Bank side about the support it receives at working level from the shareholder team, and at political level from Scottish Ministers.

21. In particular, I heard appreciation for the way in which the Scottish Government had respected in practice the Bank’s requirement for operational independence and the need for commercial confidentiality around individual investment propositions. Both of these are essential for the Bank to establish and maintain credibility in the marketplace, and to provide the necessary assurances to the Financial Conduct Authority.

22. In formal terms, the framework is set out in the Shareholder Relationship Framework Document (SRFD), which describes the rules of engagement and reporting requirements. This is supplemented by broad guidance on relevant policies issued by Ministers to the Bank - as to other public bodies - each year.

23. The SRFD has not been amended since it was first agreed in November 2020. Now would be a good time to review and update it in the light of experience, particularly as it relates to information flows and the rhythm and form of strategic steers from the Scottish Government and formal reporting by the Bank.

24. I would note in passing that the Bank has a wider set of current and potential relationships with the Scottish Government going beyond the shareholder dimension; and that it has an important broader potential contribution to make to the Scottish Government’s understanding of market conditions and to its policy-making on a number of fronts. I saw practical evidence of this in relation both to housing and to offshore wind. There might be a case to look more systematically at how such dialogue could be structured to best effect.