The First Minister’s response states that, as per the updated code, those advisers can begin investigations into alleged breaches of the code without a referral from him, and that when a breach is established, the advisers can recommend appropriate sanctions. 09:45 The petitioner’s response welcomes the changes that enable independent advisers to initiate investigations and to recommend sanctions and changes to the code, but highlights concerns that the code has not been put under statute and that there is no requirement on ministers to make a public commitment to abide by it.