Financial statements

Statement of comprehensive net expenditure

All amounts relate to continuing activities.  There have been no gains or losses other than those recognised in the Statement of Comprehensive Net Expenditure.

The accompanying notes to the financial statements form an integral part of these financial statements.

Independent auditor's report

to the Commissioner for Ethical Standards in Public Life in Scotland, the Auditor General for Scotland and the Scottish Parliament

Reporting on the audit of the financial statements

Opinion on financial statements

I have audited the financial statements in the annual report and accounts of the Commissioner for Ethical Standards in Public Life in Scotland (Ethical Standards Commissioner) for the year ended 31 March 2025 under the Scottish Parliamentary Commissions and Commissioners etc. Act 2010. The financial statements comprise the Statement of Comprehensive Net Expenditure, Statement of Financial Position, Statement of Cash Flow, the Statement of Changes to Taxpayers’ Equity and notes to the financial statements, including material accounting policy information. The financial reporting framework that has been applied in their preparation is applicable law and UK adopted international accounting standards, as interpreted and adapted by the 2024/25 Government Financial Reporting Manual (the 2024/25 FReM).

In my opinion the accompanying financial statements:

• give a true and fair view of the state of the body’s affairs as at 31 March 2025 and of its net expenditure for the year then ended;
• have been properly prepared in accordance with UK adopted international accounting standards, as interpreted and adapted by the 2024/25 FReM; and
• have been prepared in accordance with the requirements of the Scottish Parliamentary Commissions and Commissioners etc. Act 2010 and directions made thereunder by the Scottish Ministers. 

Basis for opinion

I conducted  my audit in accordance with applicable law and International Standards on Auditing (UK) (ISAs (UK)), as required by the Code of Audit Practice approved by the Auditor General for Scotland.  My responsibilities under those standards are further described in the auditor’s responsibilities for the audit of the financial statements section of my report. I was appointed by the Auditor General on 3 April 2023.  My period of appointment is five years, covering 2022/23 to 2026/27. I am independent of the body in accordance with the ethical requirements that are relevant to my audit of the financial statements in the UK including the Financial Reporting Council’s Ethical Standard, and I have fulfilled my other ethical responsibilities in accordance with these requirements. Non-audit services prohibited by the Ethical Standard were not provided to the body. I believe that the audit evidence I have obtained is sufficient and appropriate to provide a basis for my opinion.

Conclusions relating to going concern basis of accounting

I have concluded that the use of the going concern basis of accounting in the preparation of the financial statements is appropriate.

Based on the work I have performed, I have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the body’s ability to continue to adopt the going concern basis of accounting for a period of at least twelve months from when the financial statements are authorised for issue.

These conclusions are not intended to, nor do they, provide assurance on the body’s current or future financial sustainability. However, I report on the body’s arrangements for financial sustainability in a separate Annual Audit Report available from the Audit Scotland website.

Risks of material misstatement

I report in my separate Annual Audit Report the most significant assessed risks of material misstatement that I identified and my judgements thereon.

Responsibilities of the Accountable Officer for the financial statements

As explained more fully in the Statement of Accountable Officer's Responsibilities, the Accountable Officer is responsible for the preparation of financial statements that give a true and fair view in accordance with the financial reporting framework, and for such internal control as the Accountable Officer determines is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, the Accountable Officer is responsible for assessing the body’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless there is an intention to discontinue the body’s operations.

Auditor's responsibilities for the audit of the financial statements

My objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes my opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the decisions of users taken on the basis of these financial statements.

Irregularities, including fraud, are instances of non-compliance with laws and regulations. I design procedures in line with my responsibilities outlined above to detect material misstatements in respect of irregularities, including fraud. Procedures include:

• using my understanding of the central government sector to identify that the Scottish Parliamentary Commissions and Commissioners etc. Act 2010 and directions made thereunder by the Scottish Ministers are significant in the context of the body;
• inquiring of the Accountable Officer as to other laws or regulations that may be expected to have a fundamental effect on the operations of the body;
• inquiring of the Accountable Officer concerning the body’s policies and procedures regarding compliance with the applicable legal and regulatory framework;
• discussions among my audit team on the susceptibility of the financial statements to material misstatement, including how fraud might occur; and
• considering whether the audit team collectively has the appropriate competence and capabilities to identify or recognise non-compliance with laws and regulations.

The extent to which my procedures are capable of detecting irregularities, including fraud, is affected by the inherent difficulty in detecting irregularities, the effectiveness of the body’s controls, and the nature, timing and extent of the audit procedures performed.

The extent to which my procedures are capable of detecting irregularities, including fraud, is affected by the inherent difficulty in detecting irregularities, the effectiveness of the body’s controls, and the nature, timing and extent of the audit procedures performed. Irregularities that result from fraud are inherently more difficult to detect than irregularities that result from error as fraud may involve collusion, intentional omissions, misrepresentations, or the override of internal control. The capability of the audit to detect fraud and other irregularities depends on factors such as the skilfulness of the perpetrator, the frequency and extent of manipulation, the degree of collusion involved, the relative size of individual amounts manipulated, and the seniority of those individuals involved.

A further description of the auditor’s responsibilities for the audit of the financial statements is located on the Financial Reporting Council's website www.frc.org.uk/auditorsresponsibilities. This description forms part of my auditor’s report.

Reporting on regularity of expenditure and income

Opinion on regularity

In my opinion in all material respects the expenditure and income in the financial statements were incurred or applied in accordance with any applicable enactments and guidance issued by the Scottish Ministers.

Responsibilities for regularity

The Accountable Officer is responsible for ensuring the regularity of expenditure and income. In addition to my responsibilities in respect of irregularities explained in the audit of the financial statements section of my report, I am responsible for expressing an opinion on the regularity of expenditure and income in accordance with the Public Finance and Accountability (Scotland) Act 2000.

Reporting on other requirements

Opinion prescribed by the Auditor General for Scotland on audited parts of the Remuneration and Staff Report

I have audited the parts of the Remuneration and Staff Report described as audited. In my opinion, the audited parts of the Remuneration and Staff Report have been properly prepared in accordance with the Scottish Parliamentary Commissions and Commissioners etc. Act 2010 and directions made thereunder by the Scottish Ministers.

Other information

The Accountable Officer is responsible for the other information in the annual report and accounts. The other information comprises the Performance Report and the Accountability Report excluding the audited parts of the Remuneration and Staff Report.

My responsibility is to read all the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or my knowledge obtained in the course of the audit or otherwise appears to be materially misstated. If I identify such material inconsistencies or apparent material misstatements, I am required to determine whether this gives rise to a material misstatement in the financial statements themselves. If, based on the work I have performed, I conclude that there is a material misstatement of this other information, I am required to report that fact. I have nothing to report in this regard.

My opinion on the financial statements does not cover the other information and I do not express any form of assurance conclusion thereon except on the Performance Report and Governance Statement to the extent explicitly stated in the following opinions prescribed by the Auditor General for Scotland.

Opinions prescribed by the Auditor General for Scotland on Performance Report and Governance Statement

In my opinion, based on the work undertaken in the course of the audit:

• the information given in the Performance Report for the financial year for which the financial statements are prepared is consistent with the financial statements and that report has been prepared in accordance with the Scottish Parliamentary Commissions and Commissioners etc. Act 2010 and directions made thereunder by the Scottish Ministers; and
• the information given in the Governance Statement for the financial year for which the financial statements are prepared is consistent with the financial statements and that report has been prepared in accordance with the Scottish Parliamentary Commissions and Commissioners etc. Act 2010 and directions made thereunder by the Scottish Ministers.

Matters on which I am required to report by exception

I am required by the Auditor General for Scotland to report to you if, in my opinion:

• adequate accounting records have not been kept; or
• the financial statements and the audited parts of the Remuneration and Staff Report are not in agreement with the accounting records; or
• I have not received all the information and explanations I require for my audit.

I have nothing to report in respect of these matters.

Conclusions on wider scope responsibilities

In addition to my responsibilities for the annual report and accounts, my conclusions on the wider scope responsibilities specified in the Code of Audit Practice are set out in my Annual Audit Report.

Use of my report

This report is made solely to the parties to whom it is addressed in accordance with the Public Finance and Accountability (Scotland) Act 2000 and for no other purpose. In accordance with paragraph 108 of the Code of Audit Practice, I do not undertake to have responsibilities to members or officers, in their individual capacities, or to third parties.

Anne MacDonald CA
Senior Audit Manager 
Audit Scotland
Woodhill House Annexe
Westburn Road 
Aberdeen 
AB16 5GB

25 September 2025

The audit process

Auditor

The accounts are audited by the Auditor General for Scotland in accordance with section 22(1) of the Scottish Parliamentary Commissions and Commissioners etc. Act 2010. The Auditor General appointed Audit Scotland as external auditors for a period of five years starting with the year to March 2023.

Auditor's Fees

The external auditor’s remuneration for the year is £19,260 (2023/24: £18,552).  External audit received no fees in relation to non-audit work.

Statement of losses and special payments

We are required to disclose any losses or special payments where the amounts incurred are over £300,000. These include such items as losses due to fraud or overpayment or extra-contractual payments made to contractors. The ESC incurred no such losses and made no such payments above or below the limit in 2024/25 (2023/24: None).

Gifts made and received

We are required to disclose any gifts made with a value over £300,000 and gifts received of any value where there is a special need to report them. The ESC neither made nor received such gifts either above or below the limit in 2024/25 (2023/24: None).

I authorised these financial statements for issue on 3 October 2025.

Authorisation
 

Ian Bruce
Accountable Officer
Date: 03 October 2025

Parliamentary accountability and audit report

Staff report

Staff numbers

The number of full time equivalent (FTE) persons employed by the Commissioner at the end of the reporting year was as follows:

The number of persons employed by the Commissioner at the end of the reporting year, disaggregated by sex, was as follows:

As at the end of the reporting period, all staff members were employed on a permanent contract (2023/24: all permanent contracts).  At 31 March 2025, the organisation had no vacancies.

Staff costs (Audited)

Salaries include a provision covering the value of outstanding leave (the leave accrual). Staff costs increased by 16.1%. This reflects the first full year with all vacancies filled following recruitment to new posts in 2023/24, as well as incremental increases as staff move up through their payscales.

Severance payments

No exit packages were required in 2024/25 (2023/24: None). 

Staff pension arrangements

Employee pension benefits are provided through the Civil Service pension arrangements. The Commissioner’s remuneration, including pension contributions, is arranged by and paid through the Scottish Parliamentary Corporate Body (SPCB).

The Civil Service pension arrangements are unfunded multi-employer defined benefit schemes in which the Commissioner’s office is unable to identify its share of the underlying assets and liabilities. The scheme actuary valued the Civil Service pension arrangements as at 31 March 2020. You can find details on the Scheme Valuations page of the Civil Service Pensions website.

During 2024/25, the Commissioner paid employer’s contributions of £278,200 to the Civil Service Pension arrangements (2023/24: £233,500) at a flat rate of 28.97% on pensionable earnings across all salary bands (2023/24: one of three rates in range 27.1% to 30.3%, based on salary bands).

The Scheme Actuary reviews employer contributions usually every four years following a full scheme valuation.

The contribution rates are set to meet the cost of the benefits accruing during 2024/25 to be paid when the member retires and not the benefits paid during this period to existing pensioners.

Outstanding scheme contributions at 31 March 2024 amounted to £25,333 (2023/24: £22,562). Employer contributions for 2025/26 for the Commissioner and employees is budgeted to be £300,600 (2024/25: £298,000).

No persons (2023/24: No persons) retired early on ill-health grounds; the total additional accrued pension liabilities in the year amounted to nil (2023/24: Nil).

Average sickness absence

The average sickness absence per person was as follows:

The average sickness absence increased mainly as a result of two extended periods of leave in the year.

Staff turnover

The figures include any agency staff and employees on fixed term contracts. 

Diversity, equality and inclusion

The Commissioner supports the principle of equal opportunities in employment and operating practices.

It is the Commissioner’s policy to treat all job applicants and employees equitably regardless of age, disability, sex, gender reassignment status, marriage or civil partnership status, maternity or pregnancy, race, religion or belief or sexual orientation.

The Commissioner is committed to recognising and valuing what everyone has to offer. We are aware of our equality duties under the Equality Act 2010. In our policy development and our decision making we consider the implications for all staff in line with the Equality Act. 
 

Employee participation

The new Strategic Plan for the period 2024 to 2028 has a range of actions designed to improve and develop employee relations. It has a specific objective stating:

“We value people and recognise that unless we have staff who are valued and supported to maintain their wellbeing, feel happy in and proud of our work and the way in which we do it, we will have failed.”

A suite of HR and operating policies and procedures are developed and maintained with staff input and consultation. Formal staff surveys on key topics are regularly undertaken.

Organisation wide staff meetings are held regularly, to supplement those for individual teams. The minutes of all Senior Management Team meetings are published, with updates provided to staff at their monthly meetings. Longer, quarterly meetings allowing for in depth training and consultation sessions began in 2024.

The Commissioner has introduced cross-functional working groups to encourage all staff to participate in the wider work of the office and have a stake in the development of policy and procedures. The first of these, an FOI Panel, was launched in January 2024 and was followed by the Accessibility Working Group in September 2024.

Learning and development

Over the years, the organisation has developed a comprehensive annual performance review process, where individuals are encouraged and supported to plan for their own development needs and career plans. This performance management system ensures that staff members receive informal and formal external and internal training. During 2024/25, as well as attending a range of internal training sessions and webinars and conferences, staff were given the opportunity to attend 22 external training sessions. Topics ranged from application of Article 10 of the European Convention on Human Rights to attending a mock employment tribunal.

Health, safety and wellbeing

The Commissioner is committed to promoting the health, safety and wellbeing of all staff, and to ensuring that our working environment supports this. The Commissioner has moved to a fully hybrid working environment. Appropriate equipment and furniture has been provided to staff. All staff must complete Health and Safety risk assessments of their remote working arrangements. The Commissioner operates a confidential counselling support service for all staff that wish to access it and engages with staff as appropriate in the making of reasonable adjustments to enable everyone to achieve their full potential.

Authorisation
 

Ian Bruce
Accountable Officer
Date: 03 October 2025

Remuneration report

The Commissioner for Ethical Standards in Public Life in Scotland is appointed by the Scottish Parliamentary Corporate Body (SPCB) with the agreement of the Scottish Parliament. The Commissioner’s remuneration is set by and paid through the SPCB and recharged to the Commissioner’s accounts.  

Members of the Senior Management Team are employees. Their terms of employment are set by the Commissioner, are analogous with those of Scottish Parliamentary staff and, in line with the Scottish Parliamentary Commissions and Commissioners etc. Act 2010, are approved by the SPCB.

Single total figure of remuneration (Audited)

Notes

1. Salary covers both pensionable and non-pensionable amounts. It includes gross salary and, if awarded, overtime, recruitment and retention allowances, taxable allowances and any ex-gratia payments. It does not include employer’s national insurance or pension contributions. 
   
   The SPCB does not award performance pay or bonuses to office-holders, nor does the Commissioner operate a performance pay or bonus scheme for staff members. No benefits in kind were awarded to the Commissioner or members of the SMT.
    
2. The value of pension benefits accrued during the year is calculated as the real increase in pensions and applying the HMRC methodology multiplier of 20 plus the real increase in any lump sum. The real increases exclude increases due to inflation (6.7%) and are net of contributions made by the individual.
   
   Accrued pension benefits included in this table for any individual affected by the Public Service Pensions Remedy have been calculated based on their inclusion in the legacy scheme for the period between 1 April 2015 and 31 March 2022, following the McCloud judgment. The Public Service Pensions Remedy applies to individuals that were members, or eligible to be members, of a public service pension scheme on 31 March 2012 and were members of a public service pension scheme between 1 April 2015 and 31 March 2022. The basis for the calculation reflects the legal position that impacted members have been rolled back into the relevant legacy scheme for the remedy period and that this will apply unless the member actively exercises their entitlement on retirement to decide instead to receive benefits calculated under the terms of the Alpha scheme for the period from 1 April 2015 to 31 March 2022.
    
3. The Hearing and Investigations Officer was appointed in May 2023. The salary and pension details for the year 2023/24 in the table above reflect the actual period of employment from May 2023 onwards. The full year equivalent salary for 2023/24 is in the band £50k - £54k.

Pension benefits (Audited)

Notes:

1. A Cash Equivalent Transfer Value (CETV) is the actuarially assessed capitalised value of the pension scheme benefits accrued by a member at a point in time. The benefits valued are the member’s accrued benefits and any contingent spouse’s pension payable from the scheme. A CETV is a payment made by a pension scheme or arrangement to secure pension benefits in another pension scheme or arrangement when the member leaves a scheme and chooses to transfer the benefits accrued in their former scheme. The pension figures shown relate to the benefits that the individual has accrued because of their total membership of the scheme including any benefit transferred from another scheme and not just their service in a senior capacity to which the disclosure applies. The real increase in CETV reflects the increase in CETV effectively funded by the employer. It does not include the increase in accrued pension benefits due to inflation, contributions paid by the employee and uses common market valuation factors for the start and end of the period.
    
2. All the above are members of the Civil Service and Others Pension Scheme (CSOPS) and/or the Principal Civil Service Pension Scheme (PCSPS). Under these Schemes there is no automatic lump sum on retirement.
    
3. Accrued pension benefits included in this table for any individual affected by the Public Service Pensions Remedy have been calculated based on their inclusion in the legacy scheme for the period between 1 April 2015 and 31 March 2022, following the McCloud judgment. The Public Service Pensions Remedy applies to individuals that were members, or eligible to be members, of a public service pension scheme on 31 March 2012 and were members of a public service pension scheme between 1 April 2015 and 31 March 2022. The basis for the calculation reflects the legal position that impacted members have been rolled back into the relevant legacy scheme for the remedy period and that this will apply unless the member actively exercises their entitlement on retirement to decide instead to receive benefits calculated under the terms of the Alpha scheme for the period from 1 April 2015 to 31 March 2022. 

Fair Pay Disclosure (Audited)

Reporting bodies are required to disclose the relationship between the remuneration of the highest-paid director in their organisation, that being the Commissioner, and the lower quartile, median and upper quartile remuneration of the organisation’s workforce.

Total remuneration includes salary, non-consolidated performance related pay and benefits-in-kind. It does not include severance payments, employer pension contributions or the cash equivalent transfer value (CETV) of pensions. It is based on annualised, full-time equivalent remuneration as at the reporting period date.

The ESC applies the SPCB’s grading structure and pay scales to its own staff.  Variations can be attributed to:

• remuneration for the Commissioner increased by 13.4%.  The Commissioner’s remuneration is set by the SPCB.  This increase reflects an incremental increase as well as changes to the SPCB’s pay scales.
• remuneration for staff increased by 9.9%. A cost of living increase was awarded from 1 April 2024 ranging from 5.2% for the lowest grades to 4.2% for the highest grades.
• the remainder of the increase reflects staff members moving up through their payscales.
• variation from 2022/23 to 2023/24 was unusually low due to a change in grading structure and payscales that applied from 1 February 2023 to 31 March 2024.  This meant that there was no difference between payscales at the snapshot dates of 31 March 2023 and 31 March 2024.

During the 2024/25 accounting period, the Commissioner maintained Living Wage Accreditation status. In addition, all employees hold permanent appointments which are open-ended until they retire. Early termination, other than through misconduct, would result in the individual receiving compensation.

Remuneration and staff reports

The sections marked (Audited) in this Remuneration and Staff Report are subject to external audit. The other sections of the Remuneration and Staff Report were reviewed by the external auditors to ensure they were consistent with the financial statements.

Governance statement

As Accountable Officer, I have responsibility for maintaining a sound system of governance and internal control that supports the Ethical Standards Commissioner (ESC) to successfully achieve its objectives, policies and aims. I am also responsible for safeguarding the public funds and assets assigned to the organisation, in accordance with the responsibilities set out in the Memorandum to Accountable Officers for Other Public Bodies. 

System of governance and internal control

A system of governance and internal control should both ensure and demonstrate that an organisation is operating effectively, efficiently and economically. The ESC’s system of governance consists of a number of elements.

It is my responsibility to ensure that the functions of the office are fulfilled.

I am supported by the Senior Management Team (SMT), which comprises the Public Appointments Manager, the Head of Corporate Services, the Senior Investigating Officer and the Hearings & Investigations Officer. During the year, the SMT met on 10 occasions to discuss operational and strategic matters. Its actions and decisions are recorded in minutes published on our website.

A Scheme of Delegation relating to the running of the office is in operation. Under the scheme, members of the SMT and individual staff members have delegated authority to make decisions on my behalf. It is available to all staff members and is published on our website.

During the year, the office has been working to our Strategic Plan for the period 2024-2028 launched on 1 April 2024. This plan set out our purpose and strategic objectives as well as the values the ESC will work to.

We operate a biennial business plan. This sets out the actions we will take to achieve the organisation’s strategic objectives. Biennial business plans and associated progress updates are available on our website.

Each function prepares action plans to support the biennial business plan. These outline the specific steps required to complete each action, capture key operational requirements and address recommendations arising from external and internal audit and risk assessment.

The ESC operates a set of standing orders. These describe the organisation’s key operating requirements. 

Managing finances

The ESC is funded through the Scottish Parliamentary Corporate Body (SPCB) and, each year, submits an evidence-based budget bid for scrutiny and approval. The budget is based on the requirements of strategic and biennial business plans as well as projections of anticipated activity and prior year performance. The budget bid is scrutinised and approved by the SMT.

Performance against budget is analysed and reviewed on a monthly basis. Key issues are raised with the Head of Corporate Services and myself, as they occur and at SMT meetings. This allows any financial concerns to be promptly identified and resolved.

The Scheme of Delegation provides clear guidelines for the ESC’s financial management and is supported by a set of financial instructions.

Managing staff

A performance management system fully underpinned by the Strategic Plan, biennial business plans and annual action plans is in operation. Staff members agree a series of specific objectives directly related to and designed to achieve the organisation-wide objectives outlined in these plans. As a result, staff objectives are aligned to business plans.

As well as the performance management system, the ESC maintains a number of staff policy documents. These reflect both statutory duties to staff, as well as terms and conditions and HR-related procedures. A full suite of updated HR policies, fully reflecting ESC’s values, are regularly reviewed. Staff members are consulted on and informed about any revisions and also trained on their responsibilities. This ensures that staff members are fully aware of the rights and responsibilities they have.

The ESC maintains a register of interests. The Commissioner, all staff members, members of the Advisory Audit Board and key contractors must complete a declaration of interests form. No significant company directorships or other interests were held which may have conflicted with their responsibilities.

The ESC operates a whistle-blowing policy. The Commissioner recognises that the underlying structure of the organisation, with power concentrated in a single individual, may make it difficult for staff to report concerns. The policy requires staff to first report internally but with the additional option of reporting issues directly to the Chair of the Advisory Audit Board (AAB).

The Commissioner has developed and published a set of core organisational values. These are incorporated into strategic and business plans and into all policy development. Staff members are actively encouraged to consider and work to them when interacting with colleagues and stakeholders. Staff members are encouraged both formally through the performance management system and informally to build strong internal and external networks. The whole team meets on a regular basis, both online and in person, where organisational decisions, challenges and successes are shared. Organisational information and plans are widely shared and staff are encouraged to contribute to them.

Managing risk

We operate a full risk management system. The Risk Management Policy is available on our website. Its key principles are:

• ESC will foster a culture that embeds risk management into all aspects of its business.
• Risk management should be a key feature of corporate decision-making processes to ensure that the impact of policy decisions on risk is considered each time a strategic decision is taken or a policy is approved.
• Risk management should be embedded in strategic, financial and business planning.
• Risk management policies will be clearly communicated to all staff.
• All processes and procedures should be designed to take account of, manage, treat or tolerate risk and the impact of risk, in a manner that is proportionate and affordable.
• ESC will maintain, review and update the risk register regularly.
• ESC’s risk management policy and procedures will operate without prejudice to the statutory functions of the Commissioner.

All staff members are encouraged to identify risks on an ongoing basis and at key points in the business cycle. These are documented in our risk register along with any mitigating actions. The risk register is reviewed on a quarterly basis by the SMT, at each AAB meeting and by internal audit.

The key risks to the organisation are detailed in the Key Issues and Risks section of this report.

External scrutiny

Our AAB provides advice on governance and financial issues.  Members of the AAB are drawn from the independent members of the SPCB’s Advisory Audit Board. The AAB met formally on three occasions during 2024/25 and otherwise provided advice and support.

The ESC contracts for the services of an internal auditor. Work undertaken during the year comprised a review of our financial controls, recording and use of precedents in the public appointments process and business continuity arrangements. The systems of control in respect of the first two was considered strong and in respect of the last it was given a rating of substantial.

External oversight of our work is provided by the Auditor General for Scotland, the Standards Commission for Scotland (SCS), the SPCB and two standing Committees of the Scottish Parliament. Additionally, during this year, the ESC was subject to the scrutiny of the SPCB supported bodies landscape review committee. Extensive work has been undertaken to build relationships with these bodies and a range of other stakeholders.

We actively seek further external oversight of our working arrangements, including from equivalent regulators operating within the other administrations in the UK. 

Fraud, bribery and corruption

The ESC requires all staff at all times to act honestly and with integrity and to safeguard the public resources for which they are responsible. I will not accept any level of fraud, bribery or corruption; consequently, any case alleging such conduct will be thoroughly investigated and dealt with appropriately. The ESC is committed to ensuring that opportunities for fraud, bribery and corruption are reduced to the lowest possible level of risk.

The ESC’s policies and procedures on fraud, corruption and bribery include the anti-fraud policy, code of conduct (which applies also to the Commissioner), terms and conditions for the supply of goods and services and broader financial governance arrangements. 

The ESC’s standard procedure is to declare any fraud, whistleblowing or control failure incidents to the AAB and this forms part of the annual assurance process. 

In 2024/25 and 2023/24 there were no instances of fraud or bribery identified or detected.

Information security

Sound management of the information we hold is essential to our business.

The ESC operates a programme to maintain its Cyber Essentials Plus accreditation ensuring that cyber security arrangements are assessed externally. The ESC also subscribes to the National Cyber Security Centre’s early warning system which flags security gaps and potential threats.

During the year the ESC reported no data breach incidents to the Information Commissioner (2023/24: One; no further action). 

Effectiveness of governance arrangements

The system of internal control is designed to manage rather than eliminate the risk of failure to implement policies and achieve aims, and objectives; therefore, it can only provide reasonable and not absolute assurance of effectiveness.

I am satisfied that an effective system of internal control for ensuring that finances are managed appropriately was in place during 2024/25. I am satisfied that overall an effective system for ensuring appropriate governance of the organisation was in place during the year.

Authorisation
 

Ian Bruce
Accountable Officer
Date: 03 October 2025

Statement of Accountable Officer's responsibilities

Under paragraph 22 of the Scottish Parliamentary Commissions and Commissioners etc. Act 2010 the Commissioner must prepare annual accounts for each financial year, in accordance with any directions given by the Scottish Ministers. The Scottish Ministers have directed the Commissioner to prepare accounts in the form and on the basis set out in the Accounts Direction (Appendix 1).

The annual accounts are prepared on an accruals basis and must give a true and fair view of the state of affairs of the Ethical Standards Commissioner, its income and expenditure, statement of financial position, changes in taxpayers’ equity and cash flows for the financial year.

The Scottish Parliamentary Corporate Body (SPCB) has appointed the Commissioner as Accountable Officer, with responsibility for preparing the accounts of the Ethical Standards Commissioner and for submitting them for audit.

In preparing the accounts, the Accountable Officer is required to comply with the Government Financial Reporting Manual (FReM) and has:

• observed the Accounts Direction issued by the Scottish Ministers, including the relevant accounting and disclosure requirements, and applied suitable accounting policies on a consistent basis
• made judgements and estimates on a reasonable basis
• stated whether applicable accounting standards, as set out in the FReM, have been followed; and disclosed and explained any material departures in the accounts
• prepared the accounts on a “going concern” basis; and

The Accountable Officer confirms that so far as he is aware, there is no relevant audit information of which the Commissioner’s auditors are unaware and that he has taken all the steps that he ought to have taken to make himself aware of any relevant audit information and to establish that the Commissioner’s auditors are aware of that information.

The Accountable Officer confirms that this annual report and accounts taken as a whole is fair, balanced and understandable. The Accountable Officer takes personal responsibility for the annual report and accounts and the judgements required for determining that it is fair, balanced and understandable.

The full responsibilities of an Accountable Officer are set out in the Memorandum to Accountable Officers of other Public Bodies.