Audit and Governance Committee - Tuesday 30 September 2025, 4:00pm - Cotswold District Council Webcasting
Audit and Governance Committee
Tuesday, 30th September 2025 at 4:00pm
Speaking:
Agenda item :
Start of webcast
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Councillor Nigel Robbins
Agenda item :
1 Apologies
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Councillor Nigel Robbins
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Tyler Jardine, Officer
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Councillor Nigel Robbins
Agenda item :
2 Substitute Members
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Agenda item :
3 Declarations of Interest
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Councillor Nigel Robbins
Agenda item :
4 Minutes
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
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Officer
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
Agenda item :
5 Public Questions
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Agenda item :
6 Member Questions
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Agenda item :
7 Local Code of Corporate Governance
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Officer
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Councillor Nigel Robbins
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Officer
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Councillor Nigel Robbins
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Councillor Jon Wareing
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Councillor Nigel Robbins
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Officer
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Councillor Nigel Robbins
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
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Councillor Helene Mansilla
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Councillor Nigel Robbins
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Councillor Ian Watson
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Councillor Nigel Robbins
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Councillor Nigel Robbins
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Christopher Bass
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Councillor Nigel Robbins
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
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Officer
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Councillor Nigel Robbins
Agenda item :
8 Internal Audit Progress Report
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Officer
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Councillor Len Wilkins
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Councillor Nigel Robbins
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Councillor Len Wilkins
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Councillor Nigel Robbins
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Councillor Jeremy Theyer
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Councillor Nigel Robbins
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Councillor Ian Watson
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Officer
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Christopher Bass
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Councillor Nigel Robbins
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Councillor Nigel Robbins
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Officer
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Councillor Nigel Robbins
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Councillor Jon Wareing
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Officer
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Councillor Nigel Robbins
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Christopher Bass
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Officer
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Christopher Bass
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Councillor Nigel Robbins
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Christopher Bass
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Officer
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Councillor Nigel Robbins
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
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Councillor Jeremy Theyer
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Councillor Nigel Robbins
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Officer
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Councillor Jeremy Theyer
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Officer
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Councillor Nigel Robbins
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Councillor Helene Mansilla
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Councillor Nigel Robbins
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
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Councillor Len Wilkins
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Councillor Nigel Robbins
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Councillor Len Wilkins
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
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Councillor Nigel Robbins
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Officer
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Councillor Nigel Robbins
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Officer
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Councillor Nigel Robbins
Agenda item :
9 Q1 Prudential Indicators (Treasury Management)
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Councillor Nigel Robbins
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
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Councillor Ian Watson
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
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Councillor Ian Watson
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David Stanley, Deputy CEO
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David Stanley, Deputy CEO
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
Agenda item :
10 Counter Fraud and Enforcement Unit Update Report
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- CDC Audit & Governance Committee Report September 2025
- CFEU Partnership Fraud Risk Strategy A - August 2025
- CFEU Fraud Risk Compliance Report B - August 25
- Compliance Report - Appendix 1 B 2- FFCL Checklist
- CFEU Fraud Response Plan - C August 2025
- CFEU Fraud Response Plan - Summary C2 - August 2025
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Officer
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Councillor Nigel Robbins
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Councillor Jeremy Theyer
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Councillor Nigel Robbins
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Officer
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Officer
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Councillor Nigel Robbins
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Councillor Nigel Robbins
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Councillor Ian Watson
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Officer
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Councillor Nigel Robbins
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Councillor Helene Mansilla
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Officer
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Christopher Bass
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Officer
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Councillor Nigel Robbins
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Officer
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Councillor Nigel Robbins
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
Agenda item :
11 Procurement Investigation - Counter Fraud and Enforcement Unit
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Councillor Nigel Robbins
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David Stanley, Deputy CEO
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Councillor Nigel Robbins
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Councillor Michael Vann
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Councillor Nigel Robbins
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Councillor Jeremy Theyer
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Councillor Nigel Robbins
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Councillor Jeremy Theyer
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David Stanley, Deputy CEO
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Councillor Jeremy Theyer
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Councillor Nigel Robbins
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Nigel Robbins
Agenda item :
12 Audit and Governance Committee Work Plan
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Councillor Nigel Robbins
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Councillor Nigel Robbins
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David Stanley, Deputy CEO
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Webcast Finished
Disclaimer: This transcript was automatically generated, so it may contain errors. Please view the webcast to confirm whether the content is accurate.
Councillor Nigel Robbins - 0:00:00
Well, if I can call everybody to order, then we can probably start this meeting of theAudit and Governance Committee of Cotswold District Council.
And welcome to those people who might be watching online.
We are now being observed by the great public.
It's my pleasure to be back here and I must thank Helen for ably managing the meeting that I couldn't attend in the summer.
Thank you very much.
Do we have any apologies?
1 Apologies
We do have apologies.
Councillor Nigel Robbins - 0:00:50
Tyler Jardine, Officer - 0:00:52
Thank you, yeah we do have some apologies. We've received apologies from Councillors2 Substitute Members
Councillor Nigel Robbins - 0:00:58
Nick Bridges, Tony Dale and John Cheshire. Thank you very much for that. And we havesubstitutes. Ian is a substitute. Yes. And Michael Vann. Yes, we've had Ian Watson and
3 Declarations of Interest
4 Minutes
Councillor Nigel Robbins - 0:01:29
Michael van der Substitut. Thank you so much. Good. Fine. Thank you very much. Let's haveSo these are number pages 5 to 15 in our papers
Page 6
Page 7 please comment if you discovered anything difficult erroneous or omitted
It did say on page 9 that the Deputy Chief Executive and S151 officer would provide members
with a report concerning the Council's exposure to investments in sectors like fossil fuels
and military equipment.
I do know that's a question that has been raised before.
Are you able to do that?
Thank you, Chair. Yes, I am able to do that.
David Stanley, Deputy CEO - 0:02:46
I haven't provided that. I shall get an update from Arlene Close,who did provide some information to all members
probably about a couple of years ago on our ESG position.
I don't think it's changed materially since then, as most of our
Treasury Management investments in pooled funds haven't changed since that point,
but I know there are some other concerns that are being raised,
in particular, given the Middle East.
Thank you very much.
Councillor Nigel Robbins - 0:03:38
moving on I didn't know it on page 12this is for Lucy I think she confirmed that an update would be presented at the
next committee meeting in September it's relating to financial reports if you
About the third paragraph or so from the bottom of the page.
Do you think it's a misstatement?
You don't recall it?
I don't recall that chair but it must have been something that Angela was talking about.
David's got his hand up.
Officer - 0:04:48
David Stanley, Deputy CEO - 0:04:52
I have a view which I think the internal audit update report might cover off.Five three four six without checking I think is referring to an outstanding action in relation to members
allowances and the budget monitoring of those there's an update in Lucy's report
that the gender item on this committee okay that's the case it certainly is
Councillor Nigel Robbins - 0:05:16
there in the the current report we're going to be looking at thank you I thinkI think that's it is there anything else that we need to raise about it if not
Those who were present, could you indicate you accept these minutes?
Thank you very much.
Very good.
Okay.
Let's now move on to public questions.
5 Public Questions
Do we have any public questions?
Who do you look to?
Tyler, perhaps?
No public questions?
There's no public here.
Well, no.
Do we have any member questions?
6 Member Questions
We do not.
No, we don't have any member questions.
7 Local Code of Corporate Governance
In that case, we can move to item 7, and that's the local code of corporate governance.
You will notice that whereas in most cases on the agenda we note, observe, comment, criticise
if we like, we actually have to, we are expected to adopt the latest version of the code of
corporate governance, a paper has come out which is attached to the current code from
SITFA and SOLIS, which is the Society of Local Authority CEOs, which has recommended some
additional approaches which have been included and those are included in for the most part in blue
if you've got a colour version or on your screens. So those recommendations have been included
although we may still wish to comment on them as we go through. Who would like to introduce this?
Cheryl, I thought it would be. Thank you Cheryl. Thank you chair. So yeah so you'll
Officer - 0:07:28
find including your pack the latest version of the local code of corporategovernance. So as the report says it sets out the principles the overarching
principles of the governance framework for Cotswold. So a previous order and
governance we presented the annual governance statement so that's a
backward -looking document so that will detail how we've actually delivered
against the local code of corporate governance and then you also receive the
Governance Action Plan which is your forward -looking document which then sets
out how we're going to improve our governance arrangements again looking
against local code of corporate governance. So as the Chair stated you've
got two versions in your pack, one's a clean version and one that just shows
the edits so it's clear in terms of what changes have been made. What you will see
this time is often we don't see a lot of changes in the document but with the new
solid stock we have updated it so there's quite a few edits in this version and if
you refer to the appendix which has the new delivering good governance in there, whilst
the principles have remained the same, the bullets underneath have changed. So what we've
done is we've just included the bullets from the addendum in the left -hand column, so under
principles, and then we've then updated in terms of how we were going to deliver them
in the right -hand column. So that was all I was actually going to say, Chair, so I'll
Councillor Nigel Robbins - 0:08:58
open up for any questions. Open to questions. You would say in some casesthat the text on the right hand side which is about actions and behaviour
doesn't necessarily tally with what appears in the left hand column but
that's because sometimes what appears in the left hand column is too prolix, too
wordy to be able to match up with what has to go in the right hand column but
it's all there I can assure you because I've had a look at it. Yes please
Councillor go ahead. So I'm new to auditing governments so I'm kind of coming at this probably pretty much like a resident.
I'm really curious to understand how do officers get to grips with this? What's the mechanism by which
people sort of absorb all this information?
Officer - 0:09:59
I say it is sort of three documents.So this sort of sets out the overarching principles of how,
you know, how we're going to deliver our good governance.
But what you will say that comes to audit committee moving
forward and has recently come is how we deliver it.
So that I think is the more easy to understand because it's the
delivery elements, the saying that we have committee meetings,
They are open to the public.
You know, people can ask questions.
Our minutes are on the portal, so it makes it more real and live.
And then the actual action plan is around how we are going to improve what we do already.
So what you would have seen in the latest action plan, there is the same example, would be the new procurement legislation.
So within there is how we are going to comply with that.
So I think whilst this is probably harder to understand because it is the overarching principles,
the actual what we do and how we deliver against it is probably the more tangible things that
people would be able to relate to.
Councillor Nigel Robbins - 0:10:55
Go ahead, have a supplementary, please do.Councillor Jon Wareing - 0:11:00
So just, I mean we're probably with all of the documents, so if I'm an officer workinghere am I expected to kind of read and absorb these and you know have them pretty much in
Councillor Nigel Robbins - 0:11:15
working memory? Is that how it works? It probably depends on the level that youhave. I certainly think the senior officers they do need because they're
responsible in most cases for amending and updated these kinds of document but
the expectation is that the council will review its activities not just in
performance but in terms of behaviours every year which is what the annual
government statement is about and this is all designed to assist that process
even though it looks rather detailed and cumbersome.
Officer - 0:11:54
And everything then we have what we have in place or policies, how they willprocedures etc then underpin how we deliver this as well so it's all
philtres down from how we set up the council to how we then deliver things
from finance to governance across the piece. It all philtres down through the organisation.
Councillor Nigel Robbins - 0:12:17
David Stanley, Deputy CEO - 0:12:19
David. Thank you, Chair. If it helps, I suppose theway I approach this is the Local Code of Corporate Governance sets out what the Council should
be doing in terms of how it behaves.
As the CFO, I look at the local code of corporate governance as part of the annual governance
statement and work through how have I or how has my team been able to demonstrate that
we've behaved with integrity and demonstrating strong commitment to ethical values.
What do I do that contributes to that?
What can I evidence?
So a lot of the things will be what's in the constitution.
So is there an up -to -date set on the financial procedure rules?
Are the contract rules up -to -date?
Is the constitution up -to -date?
Are there controls within the financial system that prevents people doing silly things with
the financial system?
So all those things that probably become second nature to officers, the difficulty is then
getting that across to members like yourself that are unfamiliar with those terms.
but what the annual governance statement would do is I would be setting out, particularly
in relation to some of the principles, because they're more focused on financial risk, how
the measures that are in place contribute to that. But I'd also be highlighting where
you need to improve. So part of the annual governance statement process, which is from
the local Code of Corporate Governance, is identifying areas of significant governance
concern or those weaknesses. So if, for example, the financial procedure rules hadn't been
reviewed for 20 years, you should expect as a member that to be flagged as a, in the annual
governance statement, as a potential area for improvement and you want an action plan
around it. If, however, they were up to date, have been updated in the last year, been through
constitution review working group adopted by the council, that should give you some
assurance that they are fit for purpose.
Councillor Nigel Robbins - 0:14:23
Councillor Helene Mansilla - 0:14:25
Just to add a clear example from the members, for instance, how it underpins everythingthat we do at council level and in relation to the members. If we look at the members
and the Code of Practise for the members and we look at the Principle A, Behaving with
integrity, demonstrating strong commitment to ethical values and respecting the rule
of the law. That's embedded in a code of conduct for members.
And then we're looking at the sub -principle that is behaving with integrity and then we're
going under the third column that is behaviour and actions that demonstrate good governance
and practise. Officers make sure that we have the tools and the medium to report any action
any gifts and hospitalities that we receive. That's what officers are enabling us to do.
And we do so by reporting it online and by using those tools.
So this underpins everything that this Council does in a way. Thank you.
Thank you, Helen. I think people will find that helpful. Ian.
Councillor Nigel Robbins - 0:15:36
Councillor Ian Watson - 0:15:40
Thank you, Chair. I'm looking at the principles, it is section G, implementing good practiseand transparency reporting. And I welcome the fact that we've got audit and peer review
included there, but I don't see any time scales in there. I'm not sure if this document is
a place for it, but are we talking about annual review, six monthly, five yearly, is that
information?
Councillor Nigel Robbins - 0:16:15
Well, I think it's now been agreed that we report on the progress towards achieving theobjectives on a twice yearly basis. This was confirmed at the last audit and governance
meeting. I'm not sure that time scales are really appropriate in this particular case.
It's a bit too deep.
.
.
Councillor Nigel Robbins - 0:18:12
So that is actually in your annual governance statement.So this is your overarching and then your annual governance statement will then give
you the detail of the how.
So in there we'd have details around CFEU, we'll have details around our internal audit,
will have the Constitution, the Code of Conduct, all of that will be detailed within your,
the next level down.
Well, that's a very neat answer. Thank you. Yes, I'm sure you're right. But you confirmed
it's the generality of these statements. And I'm thinking, actually, we do that already.
This is how we do it, that particular institutional arrangement. But yes, okay, it's another level
down but at the same time he does answer the questions quite satisfactorily.
Christopher Bass - 0:19:08
Thank you chair. Just looking through some of the additions, one thing that I noted whichI thought was quite interesting was there's a minor reference on page 48 to AI. When I
looked across to the room, which is very on trend across all industries to be thinking
about adoption of AI. I didn't see anything specific on the right -hand side
so I just wondered if there is or generally what the approach is that's
being taken to governance around the topic of AI, whether they're worthy of
Councillor Nigel Robbins - 0:19:39
inclusion somewhere. David please. Thank you, that's a reallyDavid Stanley, Deputy CEO - 0:19:41
pertinent point. So the council is through John Cholton and his leadershipof the ICT service has been developing an AI policy for want of a better expression.
What that sets out is the ground rules to which AI would be appropriate to use and where
it wouldn't be appropriate to use, but also recognising that because of the way in which
the council operates in a quite sensitive area, how data that goes into AI must be in
a sandbox type approach.
So that's being through the internal sort of governance group, which has given it a
review that came back to the last meeting.
What we're working through as a leadership team is the appropriate route for that to
go through the council.
Because whilst it could be an officer -led policy and it's dictating how officers work,
I'm fairly sure members would be quite interested to understand how AI could be of benefit,
but also some members might be using AI.
So I think there's a process we're going through to understand the decision route and how that gets recognised
Councillor Nigel Robbins - 0:21:00
Please EmmaThank You chair
Officer - 0:21:08
I was also going to add we're making sure we put in our service specific fraud risk registers if there's any AI concernsSo it won't affect every area in the same way but where it could.
So job applications, for example, things like that.
If it's higher risk, we'll make sure it goes
in the service specific fraud risk registers because the policy
that David is referring to is very much about what the staff can
and can't do, it's not necessarily about the external risk of it.
Councillor Nigel Robbins - 0:21:54
That is carried.Good.
Thank you very much.
8 Internal Audit Progress Report
Item 8 is the progress report on internal audit and you will have received four reports
from Lucy, prefaced by the usual introductions which are very much about procedures and approaches.
So I know members normally want to dive into these so who's going to be first to
look at the progress reports from page... where are we?
page 79 onwards.
Officer - 0:22:47
We continue to follow up all agreed actions which is in your appendix B. Back to your5346 which was on page 12. We've closed that one off so it doesn't appear on the list anymore
because we've been advised there's a lot of work that the CFO is working on with Business
World so that action has been incorporated in a bigger piece of work. So there will be
new processes coming out with respect to that. So I know you all like to read my report so
I'm just going to open it up and ask if anyone's got any questions.
Councillor Len Wilkins - 0:23:48
Thank you. The one that worried me was the leisure and culture facilities finalreport which managed to get three priorities all at the same time. We do have a
number of leisure centres, so was each leisure centre visited or was it just one combined
report?
Councillor Nigel Robbins - 0:24:14
My reading is that the other leisure centres are involved and have some compliance issuesbut Lucy's going to give the detail I think.
Councillor Len Wilkins - 0:24:23
For the purposes of this audit we only looked at the Syrinsester Leisure Centre and theinformation that came from the Carina museum but what we're planning to do is
look at the other leisure centres during this year so that in we'll have full
picture going forward. Thank you.
Councillor Nigel Robbins - 0:24:41
Councillor Jeremy Theyer - 0:24:46
Councillor Thayer. Is it when you report on the other leisure centres will theywill it be just all combined or will it still stay as individual so that we get
an accurate reading of which ones aren't. We can keep it as individual or we can
be specific in the reports. Yeah it'd be better if it was for us because I think
we get a firmer feel of where it would be going wrong because it could be
management installing these things into the system.
Councillor Nigel Robbins - 0:25:18
Councillor Ian Watson - 0:25:23
Councillor Watson. Thank you chair. Yeah my eyes are also drawn to theleisure and culture facilities, it's got an operational risk assessment of being high.
Could I get an idea of why it's put at high, what are the real top three or top four issues
that we see there?
I think part, well mainly the compliance cheques and that there were, or there was non -compliance
with a lot of areas within the lecture centre.
This is the health and safety risks?
Yes, this is health and safety risks.
And you're talking about safeguarding CCTVs.
It's those kind of things that brought the auditor back
to say this was a high operational risk for the council.
Of course.
And Ruth, follow up, Chair.
And are there plans in place to correct this?
Is there ongoing work?
Officer - 0:26:24
There are also officers here that can help answer this question for you, but the twoPriority 1 Agreed Actions have already been actioned. If you read further into the paperwork,
the next two pages you have got, you will see that we have put an update in there to
say that we have received all the evidence that we needed to close those two Priority
1 actions off. So there is a lot of proactive work happening in this area now.
Christopher Bass - 0:26:52
Thank you. Just while we're on that topic, I'll continue on that one if that's OK. So,yeah, I noted that the follow up actions have been completed, which on the topic of health
and safety is what I'm always looking for straight away. Have we taken the immediate
action to make sure that there's no health and safety risk that exists, which is which
is great. I suppose my question on this, I'm not sure if it's for you, Lucy, it might be
a broader question, but in terms of the management of the supplier, do we have KPIs in place
to ensure that there aren't, that basically there's a commercial impact to the supplier
from breaching the health and safety or compliance regs?
Councillor Nigel Robbins - 0:27:35
Well, Lucy, we might ask Joseph, who has been involved, I think, with this whole processof looking at their compliance or their non -compliance.
Joseph.
Councillor Nigel Robbins - 0:27:56
By all means, move to somewhere where you can be fully heard online.Officer - 0:28:21
Thank you, Chair, Members. Sorry for the reshuffle whilst we found a functioning microphone.Just to note then, so the audit inspection actually took place in November, December
over the turn of the year and the report came out in July,
members will be aware that the leisure contract management
transferred from Publica into direct function
of this council delivered directly at the start of July.
So we've had a transition period
in terms of who's been responsible.
So the three of us here today,
weren't dealing with leisure back when this took place
in the same roles that we are now.
But just to note clearly,
having the audit in that context
has been particularly useful.
It's given us an opportunity to see what was happening.
At the time it took place in December
and to reflect on those findings
as we take the service forward from July.
So Lisa, who's now in post as of July
as our Leisure and Culture Manager
has been able to take those audit findings
and factor them into her work plan
to take forward in this year.
So as you'll have seen from the report
and from Lucy's mentioned earlier,
we've been able to action those straight away.
The key thing really on compliance was making sure
that we've got that process in place with the contractor
to pick up any issues.
And that has been done historically,
I suppose through exception,
whereas now it's a sort of standard agenda item
to make sure we're fully on board
and have that kind of robust trail in place.
So yeah, I mean, no concerns from us
in terms of taking it forward from this point,
but happy to answer any further questions.
John.
Councillor Nigel Robbins - 0:30:03
From what you said, Joseph, is there an implicationCouncillor Jon Wareing - 0:30:06
that if the transfer to the council from publichadn't taken place, these things would not have come to light?
No, I don't think so.
Officer - 0:30:17
I mean, as I say, the process was ongoing.we've had regular meetings through the public contract, the public contract managers with
our leisure supplier were meeting regularly and making sure that they were on top of this.
The compliance is more really an issue of process and whether the paperwork was there
to really support the case that those things have been covered. We haven't uncovered anything
that gives us cause for concern in...
Chris.
Councillor Nigel Robbins - 0:30:52
Thank you.So yeah, just want to go back to some specifics on my question.
Christopher Bass - 0:30:58
So my question was more around the contractual status with the company delivering their service.So are they contractually obliged to ensure compliance and are their KPIs in place in terms of that contract
contract to ensure that if they are not complying, there is a commercial impact to them.
Officer - 0:31:20
So yes, there are KPIs in place with the contractor. In terms of the specifics around sort of punishments,measures around how we would deal with that, clearly this is a contract where it's a sort
of profit share with the contractor. So we pick it up from that. It's not a sort of an
Opportunity to withhold payment because we're not paying them for the contract. It's a profit share arrangement with the leisure provider
Christopher Bass - 0:31:49
Councillor Nigel Robbins - 0:31:51
Christopher Bass - 0:31:53
Okay, I suppose the root of my question is do they have a shared interest in ensuring compliance are they motivatedOfficer - 0:31:58
Yes, absolutely. I mean particularly on many of the issues hereIt's a direct legal expectation on them as the operator rather than indeed on us as the building owner
Councillor Nigel Robbins - 0:32:12
David, do you wish to add something?I'm not sure I'll add huge amounts of value, but in terms of, I suppose, the significance
David Stanley, Deputy CEO - 0:32:21
of the internal audit report and its findings, that's been communicated to portfolio holder,Freedom Leisurely Operator are fully aware that this is being discussed at this committee
tonight and are completely on board with putting those things right. I think it's fair to say
that the issue around whether or not there's a KPI in place around compliance, my view
would be you're either compliant or you're not compliant. If they're not compliant, they
need to demonstrate how they're going to get to that position as quickly as possible.
I am aware from previous authorities that you have the type of contract where there
are lower level health and safety incidents, there's a points deduction from the contract
and a financial penalty. That is not what's in place for this particular contract. And
As Joseph said, it's a partnership arrangement, so it is in both the council's interest and
Freedom Leisure's interest as the operator to ensure that the reputational impact of
non -compliance is minimised.
Jeremy?
Councillor Nigel Robbins - 0:33:24
Councillor Jeremy Theyer - 0:33:26
I think David's answered my question, but I've just, all I want to know is are thereprotocols in place by the leisure centre now to carry on with this work of fire
alarm checking and safety and or surveillance it should be a weekly if
Councillor Nigel Robbins - 0:33:45
not daily on some some of the cases that's where I'm just for the generalpublic so I think there are regular liability of that I don't know whether
Lisa wants to say anything
Officer - 0:34:24
So in answer, yes, they do all regularly.it's with the systems that they have in place so they haven't say freedom
leisure have an external provider pH water who come in they provide regular
testing across all kind of microbiologists etc that's done very
frequently their poor waters are tested regularly and it's reported back if
there's any concerns but we've not had any but on the fire alarm on fire alarms
Councillor Jeremy Theyer - 0:34:56
and things like that that's an ongoing for the management in situ whoever'srunning the show there should we say but I'm not just aiming at siren test
domain in all leisure centres really within the CDC. Yeah they all have
Officer - 0:35:12
external contracts where they come out and get tested frequently no differentCouncillor Nigel Robbins - 0:35:22
to most. Thank you and then. Thank You chairCouncillor Helene Mansilla - 0:35:25
If I can take you to page 91 and all the relevant information. The second sentence says, wewere unable to confirm how CCTV is managed in school owned facilities and officers commented
that there has previously been confusion and compliance responsibility. May I ask somebody
Councillor Nigel Robbins - 0:35:58
to elaborate further on that please. I'm sure we can. Who would be the best person?I think David, I know David has some input into this, yes, because he was talking to
David Stanley, Deputy CEO - 0:36:18
me about it earlier. So I'll preface my response with, I thinkwe'll get a detailed written response to members of this committee on the specifics, but the
issue around dual use facilities is whether or not the dual use is within the control
of the school or in the control of the local authority. Particularly around CCTV, you understand
there's some sensitivities around the operation of CCTV on a school site, and the school would
want to ensure that CCTV is only operational under their guidelines. So that can lead to,
as it's stated here, some confusion on whether the school are demonstrating their CCTV is
compliant and whether that information is passed through to Freedom Leisure as the operator
on our behalf of the dual use site in the public hours that that dual use site is available.
So I think the best response is to get a full written response to you but I would
expect I would say there are some challenges with schools and safeguarding
and the operation of such things like CCTV where it does become much more
difficult to provide a clear response to members in an audit report that we can
say yes it's working exactly how the council would want it to work when it's
actually there for the benefit of the wider school and subject to their
particular safeguarding concerns, but we'll follow up with a more detailed response.
Thank you, David. Yes, I think we can see that the
Councillor Nigel Robbins - 0:37:44
objectives of the schools and the council might be rather differentand that although there is some shared
interest and information, some of the information just the schools would not wish to share with us anyway,
so I can see the difficulties there.
Sorry, Lisa, did you have your hand up? No.
Len, you've got a question.
Councillor Len Wilkins - 0:38:14
Right, thanks, Chet. I understand that Sarencess has got the second best collection of Romanartefacts outside London, so I was a bit worried on page 93 where it says, in 2023 we said get some
new cameras, in 2025 we're saying yeah we've got to get those new cameras haven't we. Is there
no chance of anybody turning up on Antiques Roadshow saying I've got this
Councillor Nigel Robbins - 0:38:42
Councillor Len Wilkins - 0:38:46
lovely Roman artefact. I agree with you there it is a matter of concern. ThankDavid Stanley, Deputy CEO - 0:38:51
you chair. So chair had raised a similar question prior to the meeting with me interms of the CCTV action. I think this is another one that we'll need to provide a
response on, and I'll give you sort of my understanding
of the issue.
So what is the CCTV camera, what are they there for?
Are they there to monitor individuals?
Are they there to protect the priceless artefacts that we
don't want turning up on a future episode of Antiques
Roadshow?
I'm aware that there can be some GDPR issues with the
way CCTV cameras record those images, the way in
which that data is retained and where that data is retained.
And I'm fairly sure Emma Cathcart
as head of the corporate enforcement,
Counter Fraud Enforcement Unit would advise me
that there is a CCTV usage policy in place for the council.
And it's making sure that where we got CCTV,
it's compliant with that.
And I know we have installed additional CCTV cameras
around the North Leech Resource Centre,
following the loss of some of the artefacts,
about 18 months ago.
So I will follow this up.
I wasn't aware of that until both yourself and the chair
had pointed that out,
but we'll follow that up with a written response.
Councillor Nigel Robbins - 0:40:11
Thank you for the question.Councillor Nigel Robbins - 0:40:25
I did think this report might excite more interestthan payroll, for example.
There is one other report, is there not, which is the report on the counter -fort unit.
So it's nice to know that in the old style of things, Chris Castodias, that somebody
does look at the gatekeeper and see how they're performing.
That's quite encouraging.
Lucy, do you want to lead on this?
There's nothing to add, Chair.
Officer - 0:41:02
Emma asked for an audit and we undertook an audit for her.It's a glowing report, as you'd probably expect.
Emma, comment?
Councillor Nigel Robbins - 0:41:15
Relief.Officer - 0:41:22
I did ask, I thought it was important considering what we do and how we do itand for how many different councils that and that there is an awful lot of
attention in terms especially data sharing, data access, data security, one
of my pet peeves, so I thought it was important that that was looked at
objectively by internal audit so that I could then provide that back to our
partnership councils to show that there is lots of stuff in place that we are
ensuring our data is protected and shared in the right way,
and that the teams have access to an awful lot of information,
and that they're not abusing that in any way.
So Lucy said I was the only person to ever have asked
for an audit, so.
Well, perhaps it's the beginning of a trend.
Councillor Nigel Robbins - 0:42:05
I do feel that sometimes heads of department,if they've got any anxieties, should ask internal audit to
just have a good, close look at them.
9 Q1 Prudential Indicators (Treasury Management)
Councillor Nigel Robbins - 0:42:44
I'll just let him try and enliven a subject that's beenDavid Stanley, Deputy CEO - 0:42:54
might leave some of us a little bit cold. Thank you chair. I would set out quiteearly on I'm not going to enliven the topic area much more than is printed.
This is a quarterly report so in the grand scheme of Treasury management we
produce five reports during the course of a cycle so we set out in the January
We then do the audit and governance committee meeting, which then moves on into Council
what the treasury management strategy is.
We then do the quarter one report, which is this.
The next report is the half year report, which is another one of the must read reports.
That's got more information in it than this one.
A quarter three report, which will be an update similar to this, and then an out turn report.
This being quarter one, it's more about is the Council compliant with the treasury management
strategy that it approved, adopted back in February of 2025.
So section one is the executive summary,
section two summarises why we produce the report.
Section three is about compliance on investment limits
and you'll note on the table on investment limits,
the complied column is a full yes.
The point that I would draw members attention to
is this can be a useful tool to understand if we were struggling to be
within those investment limits when the mid -year half -year report is considered
by this committee and the Treasury management strategy for the following
year do some of those limits need to be updated and for you to ask why those
limits might need to be updated so is it that the limits are too low because we've
too much cash.
Is it that we have relatively tight limits?
So we've made it quite difficult for us to invest
money in a particular way because we're taking very
little risk and we don't want to have that exposure.
So compliance is we set a policy that says this is
what we're going to do, a strategy that sets out what
those limits are.
We're in compliance with that.
But the more interesting conversation will come, the
half year report in terms of what those issues are.
Section 4 then moves into something called the liability benchmark, which if you ask
finance professionals up and down the country about the relative benefit of the liability
benchmark, they'll say it doesn't give much benefit at all. What it is meant to illustrate
is based on a set of assumptions that you don't change from the point of today, what
would be the underlying need to borrow for the council in future years.
So when you look at the second from bottom line on the liability benchmark table, where
it's got brackets, that's indicating we're okay.
Where it doesn't have a bracket in that final column, we do have an underlying need to borrow.
For those of you that want to tie up this report with other financial reports, that's
because during the course of 26, 27 and 27, 28, we are budgeting for and planning for,
but not necessarily committed to at this moment, replacing parts of our waste and recycling
fleet that will cost five, six million pounds.
That will require the council to undertake some prudential borrowing based on what's
in the capital programme.
But we are reviewing that position to ensure that we're making sure that the Council only
acquires what it needs to acquire in the most economically advantageous way.
So there's no point going to buy 15 new waste recycling trucks because they have to be seven
years old if we can keep them running for another two or three years.
So that's part of the work that's going on.
Over the page on page 106 is table three, which sets out whether our longer term treasury
management investments are compliant. That's generally around the pooled funds. We have
an upper limit of 13 million. We have a principal of 12 .5 million that's invested. Although
those of you with a fond memory of previous reports will understand that with pooled funds
the value of that capital investment can go up as well as down. But we are compliant with
that. There are some additional indicators around the relative security of our investments.
So we set out the type of counterparty and the average credit rating that we would seek
to expose the council to.
And then finally towards the end on page 107 is another indicator that indicates what a
1 % increase or decrease in interest rates would do and are we compliant with that.
In an earlier draught it said in the middle column it was minus 0 .02 which indicated it
was two pence, it was missing the M, so that has been corrected. And for information, interest
rates during the quarter were still stubbornly high. In fact, they've gone higher than the
rates that were indicated on the 30th of June. Currently 50 -year PWOB maturity loans are
tracking around about 6 .1%. So the cost of external borrowing is relatively high. The
cost of short -term borrowing is relative high.
So those interest rates that are forecast to reduce
are reducing in a relatively sticky way.
So although the Bank of England base rate
has reduced to 4%, the cost of borrowing,
and those of you that may be paying close attention
to what the Chancellor has to do
towards the end of November,
given guilt yields are at record highs,
that's translated into PWLB rates.
So whatever the guilt price is,
that determines the PWLB price.
so we do pay some attention to what's going on in the wider economic environment.
But happy to take any questions that you may have on the report.
Councillor Nigel Robbins - 0:48:49
Thank you, David. So the longer we can use our own money, our own reserves,the more investment the better, quite clearly.
Are there any questions to David?
Councillor Watson.
Thank you, Chair.
Councillor Ian Watson - 0:49:06
David, do we measure forecast accuracy? I mean, looking back, how accurate was our forecasting?David Stanley, Deputy CEO - 0:49:16
We do. Well, I would suggest, and this is being brutally honest, that our accuracy withour forecast for Treasury management investment returns has been below what we have achieved.
So, one way of looking at that is we set a prudent budget expectation on the basis that
our cash balances would over the medium term reduce and the interest rates will reduce.
As those cash balances haven't reduced as quickly as we thought they would and interest
rates haven't reduced as quickly as we assumed they would, we've achieved more.
I would sooner, as your Section 151 officer be in that position of reporting an overachievement
investment income, then reporting to you that we'd set an overly optimistic position and
had to come and say, well, we've underachieved and we've got a £250 ,000 hole in the budget.
It will become particularly important, this is the more serious point, when the council
is undertaking external borrowing, because that accuracy in estimating the cost of borrowing
will become really important.
Now you can achieve that accuracy by fixing your interest rate for 50 years, but that
comes at a cost.
And the council in order to balance that, particularly with the purchasing of short
life assets like waste and recycling vehicles that only have a life of seven to 10 years,
you don't want to tie your borrowing up for 50 years.
So you might take shorter term borrowing, which is going to be more volatile.
So, in answer to your question, we don't measure it.
I would say we've not been accurate, but we've been not accurate in the right way.
But as that position becomes tighter, where those cash balances shrink and our need to
borrow becomes greater, then I would expect this committee to be challenging those estimates
and making sure they're robust and reasonable.
but I would sooner be prudent and underestimate Treasury management income based on advice
from Arlene Close than having to report an underachievement.
Councillor Nigel Robbins - 0:51:30
Thank you. I have a question. We are now doing our own credit rating. Who is standing upand doing that for us. I mean, we're not standard and poor. So who does our own credit rating
as on page 106 as additional indicator? So in terms of credit rating, that's the exposure
we have to our investments. The council isn't separately credit rated. There are, I think
off the top of my head, no more than four or five local authorities that have decided
to become, to have their own credit rating. Some of them might not have liked the outcome
of that credit rating. So I think off the top of my head, Aberdeen Council, Glasgow
Council, Warrington and others went through that particular process. So what this indicator
is looking at is the average credit rating of our investment portfolio rather than a
credit rating of us as an individual sovereign authority. What we are rated as, in effect,
is as an arm of government, so whatever the government's credit rating is applies to local
David Stanley, Deputy CEO - 0:53:05
authorities. Some local authorities where they've sought to raise external borrowingthrough the issuing of a bond where that bond is of a particular value, usually 100 million
plus. There's some advantage in being separately credit rated because that might knock a few
basis points off the interest that they would have to pay on that bond. But conversely,
they can get credit rated and it doesn't give them the answer they were hoping it would
give. So this is purely about are we investing in effectively junk bonds, subprime mortgage
they would have a much lower credit rate.
And we've set a target of A-, we wouldn't go lower than that.
And when we use Arlene Close's investment guidance,
it's tailored to that.
They will only provide us with information
on that type of investment to ensure
that we're within that compliance and tolerance level.
Thank you.
Councillor Nigel Robbins - 0:54:00
I've got it.Ian.
Thank you, Chair.
Councillor Ian Watson - 0:54:05
David, I think you might have just answered my supplementary to my first one is we havea strategy where we're in fact, obviously we don't want a super safe 50 year bond because
it costs us money, but at the same time we don't want to, as you say, jump bond or sub -prime.
We come up with a strategy and that is guided by the A -. Do we seek external advice on that?
David Stanley, Deputy CEO - 0:54:36
David Stanley, Deputy CEO - 0:54:37
So we have Arlene Close as our Treasury Management Advisors. They would be keen to stress theyprovide advice and it's down to officers to make those decisions, but it would be foolish
of me as the 151 to not take into account that advice. So particularly when we're looking
to make investments, the Treasury Management Strategy will set out the counterparty limits
David Stanley, Deputy CEO - 0:55:11
in terms of how much should we invest with a particular institution, B, in terms of itscredit rating. That would also then determine how long we would make that investment for.
On the flip side, when we are undertaking external borrowing, I would be seeking separate
advice nearer the time of that borrowing decision from Arleigh Enclosed because you can set
out a borrowing strategy in the Treasury Management Strategy that say we will be looking to ensure
the Councillor is making best use of his internal resources first and then access external debt.
That is quite a volatile market in terms of the difference between the cost of short -term
debt and the risk that you're taking on.
So if you said you were buying an asset that had a
10 -year life and you wanted to reduce the cost of that
borrowing, you'd take very short -term lending and
refinance that, say, every six months, every year.
But you can get caught out because, as we've seen over
the last four or five years, the interest rate that was
nice and stable at 0 .1 percent for a number of
years suddenly went up and up and up. So a number of authorities that had very short -term
loans couldn't then convert that short -term lending into longer -term or secure lending.
So the issue here is what risk does the Council want to take on its borrowing? Does it want
to maximise the security, the long -term certainty of that borrowing, or does it want to take
slightly more risk approach to it and have lower potential costs but have
that exposure to interest rate risks where the interest rates may rise. I am
old enough to remember Black Wednesday where the interest rate went up not
once but twice in the day peaking at 14 .9 percent. That could still happen. So
that's what we're mindful of. Now we are in a slightly lower interest rate
environment and you would argue the current interest rate is probably where
it's been on average over the last 30 years but I do remember four or five
years ago you could borrow 50 year PW or B money for about 1 .6 percent it's
currently at 6 .1 percent so that change can fundamentally alter the
affordability of your financing position. Thank you David.
Councillor Nigel Robbins - 0:57:42
Well, I think we've squeezed every little bit of juice out of this particular pieceof fruit.
Well done.
Thank you very much.
10 Counter Fraud and Enforcement Unit Update Report
So let's move on to item 10, counter -forwarding enforcement unit update report.
We've got Emma here.
You have three reports.
What if I can ask Emma to sort of explain how these three reports link together to each
Officer - 0:58:20
Thank you, Chair. Yes. So ordinarily I would provide you with a mid -year update, but whatI decided to do was to stick to giving you the full update of our annual activities from
the previous year in your first audit committee, which is the one you have usually in April,
and then mid -year be a focus on fraud risk. So what areas are we looking at? What are
more operational corporate sort of strategic delivery items and what things
are affecting the council moving forward. So rather than giving you we've
done a couple of this or that all goes into the first report and then this one
would mid -year would be about our higher risk areas and stuff we're doing. I
therefore took the opportunity to say right well we need to refresh a load of
documents that go in line with that so we've looked at the fraud risk strategy
and updated that. So you did have a fraud risk strategy, it came here in 22 I think,
but so that has been updated and is obviously attached to your information. It gives an
overarching, hopefully it was a relatively straightforward, overarching idea of what
things affect the council, how we mitigate that, why people commit fraud, etc. In addition,
when we had delivered the original strategy, we had committed to providing
you with an update in terms of our compliance against the government
checklist. So the fraud compliance report does exactly that. We've gone through
what best practises as put together by the LGA and said how do we meet that how
do we not and then you can see where we are completely compliant, partially
compliant or not compliant.
That's also attached to the report.
I was pretty pleased because we're doing the majority
of stuff that they recommend.
One of the items where we're not compliant is to do with data,
having a separate piece of software for data matching,
et cetera.
We're not compliant because we don't have a piece of software.
So it's not that we wouldn't utilise it.
it's that we don't particularly have one for that purpose.
But we obviously take part in national exercises
with the Cabinet Office.
And if there was more profiling that came out
of the central government Public Sector Fraud Authority,
we would obviously use that,
where we could target any particular areas
affecting local authorities.
So, you've got that to look at.
And then you've also got a new Fraud Response Plan,
plan, which was we put together as a quick fire document for staff members, external
bodies, on what to do if they think there is an alleged fraud.
So the summary document, that do's and don'ts and the flow chart will be what we will send
to staff, but it's ultimately about protecting the integrity of any investigation we are
undertaking to make sure that people understand who to report to, what types of things to
and what to do and not to do in those circumstances.
So that's the documents attached to the report.
I've then taken the opportunity to update you on the areas
we were focusing on, the high -risk areas.
So that was grants.
So clearly, we now administer a number more grant schemes
than we ever did in the past.
So we've put together a new grant management policy.
That will come here at some point.
or at least go to cabinet for approval,
but you'll be able to access that.
And that is also supported by a grants toolkit for the staff.
So if they are now putting together a new grant scheme,
there's information there that they would use
to build their application form,
think about putting in the policy,
how they verify applications, et cetera,
again to mitigate fraud within the grant scheme systems.
We also committed to looking at polygamous working, so that is staff that have multiple jobs that are undeclared.
It's not legitimate declared secondary jobs.
We're not saying people can't have secondary employment.
It's those that have additional jobs that they don't declare.
And I took the opportunity to update you in terms of the case that we had on of the ex -member of staff who we recently prosecuted and the outcome of that.
from that work there's a management report with a number of recommendations
and we're now working with HR in terms of how we make sure that all our
documentation is robust, do we have to update our contracts, what are we doing
about vetting and recruitment risks etc. So that's all been built in as a process
behind the the recent prosecution. Bit of a walkthrough but happy to take any
Councillor Nigel Robbins - 1:03:16
questions. Thank you very much chairman. Yes questions. Jeremy. Just getting on toCouncillor Jeremy Theyer - 1:03:27
page 114 part 2 .23 it says it will be the math which means a lot somethingtotally different to me because that was Ministry of Agriculture and Farms and Fisheries or
something years ago but they changed names into something else. And that's coming into
practise in October, is that early or later October? What's the date?
This is the new website. So it's just we've been sent out to all the members of the group
That is victim support, crime stoppers, police, etc.
We have a test site to look at.
We have a meeting on Monday.
We can all feed in and say if there are any anomalies or anything extra.
Is it working?
Then we will be able to work on the campaign to launch it and how we make sure everybody
is aware that it exists and how we start signposting residents, etc. to it for information.
That looks really good.
Sooner rather than later, obviously.
Councillor Nigel Robbins - 1:04:36
Emma, I note that in your checklist, which is very detailed, you say in a number of,in many cases, this is an area that may benefit from further consideration or this is an area
that warrants further consideration. How do you prioritise what your ongoing action plan
is to improve the service.
Officer - 1:05:03
A lot of the partial compliance was about updating councillors and specifically moreabout having a portfolio holder for counter fraud provision. But my view is that actually
counter fraud provision should be thought about by all members. It affects absolutely
everything that we all do in every different way. So what has been suggested
is that when an Audit Committee report is put together by me that then goes to
Officer - 1:05:35
an informal member meeting so that they can understand what we're up to, look atthe work plan, think about the high -risk areas we've targeted. So it's a little
bit wider than Audit Committee and it's therefore you know a bit more ingrained
in every aspect of the council's portfolios because it isn't just about
finance and it isn't just about governance it can be about absolutely
anything but also it's then important that everybody knows about the website
for example for all of the residents of the whole district so that's that's the
plan I've just got to and it doesn't matter particularly if it's before or
after an audit and governance committee the report comes to you but then my view
would be that I then go to an informal meeting and talk about what we've
delivered and what we've got up to. Well I think we have here the member of the
Councillor Nigel Robbins - 1:06:24
cabinet who's going to be the linked person is that correctCouncillor Coleman.
Councillor Nigel Robbins - 1:06:32
Councillor Ian Watson - 1:06:36
Councillor Watts. Thank you chair. If I was to go downstairs and pick an officerat random or let's say somebody's been here for six months, would they know about the
whistle -blowing process and how it works?
Officer - 1:06:57
So that should be part of their induction. So there are slides within the induction forall new starters that touch on our team and fraud provision but also whistle -blowing.
Then I do, I'm not sure about six months, depends when they start, but if they started
six months that included April. I always do an annual refresher to all staff. It
goes out in all the comms in all the different councils to remind everybody
about whistleblowing, how to do it and then they are signposted to the web page
which has all the internal policies plus the summary, the flowchart for
whistleblowing and how and who and what it is and what it covers. But more
generally I'd hope they'd be able to understand they can come and talk to
any member of the team internal audit their managers about any concerns they
Councillor Nigel Robbins - 1:07:50
Councillor Helene Mansilla - 1:07:54
have.May I take you to page 141, please?
And the item, the third item, which says not compliant.
Emma, when it's coming to third parties, I suppose that the only thing that we can do is to hold them contractually accountable,
because obviously, you know, we have no power.
Officer - 1:08:42
It is. I think there is a lot of work going on in terms of contractors. So we are lookingat paperwork in terms of what they sign up to, what the provision is, et cetera, ensuring
that if a contractor committed fraud,
how we manage that in the same way.
Because sometimes if it's through an agency
there are difficulties around that
because we're paying the agency
who pay that member of that contractor.
But what this is,
is I don't think anything other than paperwork really.
We should be signposting them to the whistleblowing policy
because they could be whistleblowers
and they could notify something.
So I think it's just a case of ensuring
that when we take on a contractor
they're given information that includes where is the whistle -blowing policy and
who should they alert to any concerns that they have and we just treat them
like we would a member of staff for that purpose.
Christopher Bass - 1:09:41
Yeah just a quick question on the checklist really and more about likethe future of the checklist so I think first of all it's like it's really
pleasing to see a lot of green on there so it looks like we're in a really nice
places I think we probably all would have guessed as well so it's nice to see that.
Confirmed in writing, I'm just wondering about the next time this comes to committee if you've
got any ideas on how you're able to show progress so rather than bringing a new version of the
checklist without a reference back to history what that might look like?
Officer - 1:10:09
Yeah I think that's probably a good idea to almost extract what's partially compliantor not compliant and just give you updates on that so we don't want to reinvent the wheel
or send another six pages for you to read unnecessarily.
I mean, obviously, if something went from compliant
to partially compliant, that equally would need to come back.
But yeah, I think next year, same report will be about risk,
and I can go back to the checklist
and give you an update on exactly that.
Councillor Nigel Robbins - 1:10:36
I was very impressed by the risk register.It's very like what internal audit does
in terms of likelihood and impact.
I'm just wondering how you apply it.
I mean, it looks like a rather complicated game of draughts.
How do you actually apply it to individual risks?
Officer - 1:11:06
So, Mark, who works within my team,has a lovely project regarding the service -specific
fraud risk registers,
because as we I've spoken to you before most of the council's had an entry and
still do in the corporate risk register that just says fraud is a risk which it
is and we recognise that's the most prevalent crime in the UK but it's not
relatable particularly for all the different activities that the council
undertakes so what we've committed to doing is those individual service risk
registers Mark is drafting them and working through the higher risk areas
first. So that's how he'll apply it and he'll have to apply it individually to
the different service areas and the different risks within those different
service areas and they're going to be hugely different depending upon what
service area we're looking at for obvious reasons. So it is a bit of a
game of chess but by working with the service leads in the different areas we
should be able to identify what's most risk, what we need to mitigate for, what
needs to be done.
David.
Thank you.
Councillor Nigel Robbins - 1:12:14
Thank you, Chair.David Stanley, Deputy CEO - 1:12:16
I was just to say on fraud risk, from a service point of view, it should be something thatisn't seen as a negative.
So being aware of what those fraud risks are, having that in your service risk registers
and understanding where that weakness could be is really important.
So I could give you a hypothetical example.
Because in finance we deal with the Treasury management, there is a risk that a rogue member
of staff could make an investment with a counterparty, let's say £1 million. And in doing so, provides
a new set of settlement instructions to the counterparty saying, upon maturity of said
investment, please pay it to my Swiss bank account number 1234. That's a fraud risk,
and it's the mitigation to that that's really important. But being aware that it's a fraud
risk is half the battle. The service bearing its head in the sand and going, there's no
for all risk because we're all honest public servants,
isn't a mitigation policy in itself.
Councillor Nigel Robbins - 1:13:21
Are there any further comments or questionsto Emma or David?
Or indeed to Mark?
No?
Okay, thank you.
.
11 Procurement Investigation - Counter Fraud and Enforcement Unit
.
Councillor Nigel Robbins - 1:14:46
which we don't know about, nevertheless it certainly is an indication, these particularinstances are an indication of really poor value for money, which is after all one of
the purposes of having these procurement policies. I'm going to hand over to David who knows
much more about this than I do.
Thank you, Chair.
David Stanley, Deputy CEO - 1:15:10
This report is split into two parts.The first part sets out what happened.
Most importantly, the second part sets out what we have done and are doing about it.
So the first part of the report summarises the findings of an investigation that was
Council during 2024.
Section 1 of the report provides a summary of the overall whole report in terms of an
executive summary.
Section 2, supported by further details in Annex A, outlines the key governance issues
highlighted by the investigation.
Paragraph 2 .2 of that report or that section is probably the most pertinent, particularly
around why this report has been brought to this committee.
So, Audit and Governance Committee have a number of responsibilities around the Council's
control environment, around the effectiveness of the responsibility I have as the Council's
as Chief Finance Officer for maintaining an adequate
internal control environment around monitoring arrangements
for the identification and control of strategic
and operational risk, and around the adequacy
and effectiveness in terms of the arrangements
that are in place for combating fraud and corruption.
Sections 3, 4, and 5 of the report cover in detail
the findings relating to each of the procurement activities
that was undertaken.
And I will not cover those individually.
Section 6 of the report, however,
pulls all those individual findings together
and highlights some common themes and then issues.
And that section effectively outlines some weaknesses
in the control environment and the implications
of those weaknesses and around how that impacted
the council, particularly around reputational damage,
legal and financial risk, what breaches of governance and accountability meant, and the
risk around corruption.
As I said earlier, I think the focus of members of this committee should be directed to Section
7, and in particular Annex B, the action plan.
And I'll run through those in order of the points in Annex B. So the Constitution was
action one, making sure the contract rules are updated.
That has been completed following the new procurement app
that became effective in February, 2025.
mandatory e -form for purchases over 5 ,000 pounds.
So this is to ensure that the procurement team
are aware of what's going on.
That was completed at the end of August, 2025.
So that form collects a certain amount of information
that ensures the council's contracts register can be maintained as relatively
up -to -date and accurate as it can be and the council is able to meet its
requirements under the Transparency Act. Item 3 is ensuring that officers receive
mandatory procurement training. That piece of work is due to complete by the
end of December and that will have different levels of training depending
on the level of the employee and their exposure to procurement.
So different levels for senior managers, new employees, and budget holders and those that
are actually undertaking procurement.
Part four was implementing a procurement toolkit.
So that is something that is being worked on in October.
And that will have a standard set of templates that will be used by all those undertaking
procurement to ensure that the evaluation and the documentation of procurement is in
place.
Section 5 is some system improvements around the procurement module of the Egresso Business
World system, which is our ERP financial system.
There's a procurement module in there, and that is to ensure that we're collecting spend
data on our suppliers and that is providing greater accountability to and
visibility to what we're spending our money on. So that will be in testing
phase that's being implemented over the course of the next few weeks that will
be tested during November with full implementation expected by the end of
this financial year and in place for beginning of next financial year. The
The next set of actions around reviewing the terms of reference for the officer commissioning
and procurement board.
So that's a board that's existed for a number of years under the guise of publica.
So that's run by publica because publica provide the procurement support to the councils, be
it ourselves, West Oxfordshire or Forrester Dean.
So just reviewing the terms of reference to ensure that reflects the changes that took
place with phase one and phase two services transitioning back to the
council. Section seven is the long overdue improvements to financial
reporting which those of you who have been on the committee for some time will
recognise that there have been some audit reports that have been
recommending that we improve our ABW financial reporting. What we've been
doing is working with Karen Bass who's the interim finance manager within
Publica who is also an ex unit for employee who unit for being the parent
company of ABW to ensure that the set of reports that are available to directors
heads of service and those responsible for budget management are fit for
purpose at the moment there's too many reports to wade through we want to
simplify that so those reports are summarised at the appropriate level and
That will also include spend analysis that will be available to support the procurement
and commissioning board to ensure that we are capturing all spend, not just those that
are notified through.
Implementation number eight of our no purchase order, no pay or PO to pay.
Again, I think the independent member on this committee, Christopher Bass, will recognise
the importance of that.
I know that's been stressed before.
That's looking at a deadline of the 30th of June,
if we can achieve that earlier,
because implementing that around the turn of
financial year is going to be a challenge.
But the sooner we can get that in place
and scoped out, the better.
It's the scoping out of that process that takes the time,
the actual implementation.
I'm led to believe from a conversation with Unit 4
can take a few weeks.
But if you don't scope it out effectively,
it can take a lot longer than a few weeks.
And finally, on that list is in progress, because we're still not yet past the deadline
of the 30th of September, is Council Awareness Resource.
So adding the LGA SITFA guide to the member portal and then arranging a member briefing
later in October to ensure that's happening.
But I believe that's now been completed.
A live update is it's now complete today.
And importantly on the action plan is the need to follow up and review those actions.
And the suggestion here is that's tabled in for the Audit and Governance Committee in
April 2026.
And just as final, so it's final comments from me, stressing the importance of good
governance.
So it's to reassure members as a corporate leadership team, the corporate leadership
team for those that don't know is the chief executive, myself as the chief
finance officer, Helen Martin as the director of communities in place and
Angela Clarage as the monitoring officer, that's your CLT. We have reviewed in
detail the findings outlined in the report and provide the committee with
this action plan that's being carefully considered in terms of what the actions
are and the deadlines and who the accountable officer is. So I hope that
That gives members reassurance that having identified the issue, we've put in place a
robust action plan that should give you adequate assurance that the issues that have been identified
are not going to happen again or very unlikely to happen again.
Thank you, David.
Councillor Nigel Robbins - 1:23:54
That's very thorough and it's good to know that there has been a very detailed responseand improved procedures.
But I'm looking at point nine here on the action plan,
counter -awareness and resource.
I'm thinking that with the best processes in the world,
you won't necessarily stop somebody who wants to break
the rules, especially if they have some authority.
They will do that despite the rules.
So I think as part of the briefing,
and I hope Angela will stress this, knowing the consequences of being caught out.
The sanctions that would be applied, whether it's a slap across the wrist,
or gross mismanagement leading to dismissal should be understood by people,
because these are really quite serious issues.
I'm glad they've been caught and the processes are good,
but I think people still need to know that there are very serious consequences
that will happen to them if they're discovered,
as I rather suspect they will be in the future.
Who's next?
Councillor Michael Vann - 1:25:22
Very briefly, I'd like to salute the one -one, page 155, those people who came forward withtheir multiple whistle -blowing concerns, as I think was an important, if not a key part
of getting this dealt with.
Thanks.
Thank you, Michael.
Councillor Nigel Robbins - 1:25:45
Ian.Yeah, following up on that point that Michael just meant, I think it's, I hope it's a sign that this
process works, so people felt able to come forward. I'd also like to thank the officers
for compiling this report, which is very clear and very thorough.
Oh, Councillor Thang, I'm sorry, I was looking down my papers, I didn't see you raise your hand.
Councillor Jeremy Theyer - 1:26:35
I was just more worried, sorry I keep resorting back to Ty.Was there any costs involved in any of these actions from, because there's some big numbers
being pouted there saying how much they were quoting to do the jobs and all the rest of
it.
Was there any money ever left in the pockets as such?
Or is it war?
Councillor Nigel Robbins - 1:27:02
I can't answer that.I wouldn't let...
Councillor Jeremy Theyer - 1:27:05
There's no records of anything, so I presume not that I'm just asking the question.So if I may, Chair.
David Stanley, Deputy CEO - 1:27:10
So the report sets out the cost of the procurement activities that were undertaken.Clearly there was, with that procurement activity, some concerns about the value for money of
what was procured but it would be fair to say that would be difficult to retrospectively
prove that an alternative way of procuring would have delivered a lower cost.
However, I would say the cost of putting in place the investigation and the action plan
is significant but needed as a response.
So the amount of officer time spent investigation, as you can see in paragraph 1 .1, that started
in October 2024.
Within a day or almost a year since that process started, a considerable amount of officer
time has been spent reviewing, interviewing and compiling.
That I think is recognised as serious as the issues.
Councillor Jeremy Theyer - 1:28:19
The question was more about how much, I know all that costs money of course, but how muchleft the council to pay for any of these, we didn't pay any of these contractors any
money, that's what I was sort of aiming at.
Councillor Nigel Robbins - 1:28:43
I would say if contracts were not issued but the work was done, which I think in most casesthe work was done and in some cases quite effectively, we have no way of judging at
all whether it was good value for money and therefore there may have been a waste.
David Stanley, Deputy CEO - 1:29:07
I can confirm that the amounts reported in here was what was spent on those three pieces of procurement.So those contractors received the amounts that are stated in this report.
Councillor Helene Mansilla - 1:29:25
Thank you, Chair. This is not a question, it's just to make a brief comment and probably very obvious,It is just to highlight the importance of procedures, the importance of cheques and balances,
the importance of the internal audit unit, the importance of the fraud unit, because
when procedures are missing, there are gaps in the procedure, and when cheques and balances
are not carried out as they should be, because for whatever reason they are individuals that
left to their own devices, for the reasons that probably Emma has mentioned in her report,
I think it is on page 120 where it says why people normally commit fraud, they will take
a shot and just commit fraud and suddenly that will happen.
So it is very important, the procedures and cheques and balances.
Thank you.
Councillor Nigel Robbins - 1:30:56
Thank you Lucy and Emma for your valiant work and the time spentuncovering these nasty things in the woodshed.
It's a literary reference, I'm sorry.
12 Audit and Governance Committee Work Plan
If we conclude that, then we can go on to the work plan of the audit committee
and whoever it was needed to get away by six with a bit of luck.
I hope you'll do that comfortably.
Thank you.
Councillor Nigel Robbins - 1:31:49
The next meeting in DecemberCouncillor Nigel Robbins - 1:31:50
is primarily about moneyDo you want to say something about that David? I think you know
Cheryl has a very important item, but I think most of it's about the
Treasury estimates doesn't it at the
financial estimates
Thank You chair so just in terms of December a
meeting of audit and governance committee the two
Significant items on there is the Treasury Management media report, which will be a little bit more detailed
and follow a prescribed route in terms of reporting
on the Treasury management activities.
That report is considered by this committee
but is recommended on to full council.
So included in your work programme is the date
that it would go on to full council.
The next sort of two items get grouped into one
because one can't turn up with the other.
The external auditors annual report
and the statement of council audit opinions.
So we are working closely with Bishop Fleming, our external order, to ensure the audit opinion
can be delivered in a timely manner.
We were hoping that it could be at this committee, but clearly you can see it hasn't yet been
concluded.
We are making good progress and there are some resourcing issues with Bishop Fleming
that's led to a slight delay, but we're confident that can be resolved over the next few weeks.
So, that should be able to be reported to the committee when in advance of the 4th of
December but given, I suppose, the need to show public scrutiny of the external auditor's
report and the statement of accounts, it would be appropriate to maintain that on the work
plan for the committee rather than trying to receive that audit opinion under a delegation.
So, if it's not available on 4th of December, there is another meeting on the 27th of January
that would be well in advance of the backstop date, which is the 27th of February 2026.
Thank you for that. Our previous orators, Grant Thornton, blamed resourcing issues on us.
It's pleasing to know that the boot's on the other foot.
David Stanley, Deputy CEO - 1:34:13
I'm sure if Bishop Fleming were in the room they would also be highlighting resourcing works both ways.I just took advantage of the opportunity.
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