Audit & Governance Committee - Thursday 9 April 2026, 4:00pm - Cotswold District Council Webcasting
Audit & Governance Committee
Thursday, 9th April 2026 at 4:00pm
Speaking:
Agenda item :
Start of webcast
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Councillor Helene Mansilla
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Councillor Helene Mansilla
Agenda item :
1 Apologies
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Nickie Mackenzie-Daste, Officer
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Councillor Helene Mansilla
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Nickie Mackenzie-Daste, Officer
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Councillor Helene Mansilla
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Angela Claridge
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Councillor Helene Mansilla
Agenda item :
2 Substitute Members
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3 Declarations of Interest
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Agenda item :
4 Minutes
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Councillor Paul Hodgkinson
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Councillor Paul Hodgkinson
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Councillor Helene Mansilla
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Councillor Helene Mansilla
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Helene Mansilla
Agenda item :
5 Public Questions
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6 Member Questions
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Agenda item :
7 Audit and Governance Committee Work Plan
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Angela Claridge
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Councillor Helene Mansilla
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Angela Claridge
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Officer
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Councillor Helene Mansilla
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Officer
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Councillor Helene Mansilla
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Councillor Helene Mansilla
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Councillor Helene Mansilla
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Councillor Helene Mansilla
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Councillor Helene Mansilla
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Councillor Helene Mansilla
Agenda item :
8 Procurement Action Plan - Follow-Up
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Helene Mansilla
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Guest
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Councillor Helene Mansilla
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Craig Thurling
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Officer
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Councillor Helene Mansilla
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Councillor Craig Thurling
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Councillor Helene Mansilla
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Craig Thurling
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Councillor Helene Mansilla
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
Agenda item :
9 Annual Governance Action Plan 25/26 Update
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Angela Claridge
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Officer
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Councillor Helene Mansilla
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Guest
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Councillor Helene Mansilla
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Guest
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Councillor Helene Mansilla
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Officer
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Councillor Helene Mansilla
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Guest
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Councillor Helene Mansilla
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Guest
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Angela Claridge
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Councillor Helene Mansilla
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Councillor Helene Mansilla
Agenda item :
10 Strategic Risk Register and Risk Management Policy
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Paul Hodgkinson
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Nick Bridges
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Craig Thurling
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David Stanley, Deputy CEO
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Councillor Craig Thurling
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Guest
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Len Wilkins
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Councillor Helene Mansilla
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Councillor Len Wilkins
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Councillor Helene Mansilla
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Councillor Len Wilkins
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Guest
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Helene Mansilla
Agenda item :
11 Internal Audit Progress Report - April
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Officer
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Councillor Helene Mansilla
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Officer
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Councillor Helene Mansilla
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Councillor Paul Hodgkinson
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Councillor Helene Mansilla
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Officer
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Councillor Paul Hodgkinson
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Officer
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Councillor Helene Mansilla
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Guest
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Councillor Helene Mansilla
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Officer
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Councillor Helene Mansilla
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Councillor Helene Mansilla
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Councillor Helene Mansilla
Agenda item :
12 CFEU Update Report (Including RIPA and IPA annual update)
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Officer
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Councillor Helene Mansilla
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Councillor Paul Hodgkinson
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Councillor Helene Mansilla
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Councillor Paul Hodgkinson
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Councillor Helene Mansilla
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Councillor Paul Hodgkinson
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Officer
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Councillor Helene Mansilla
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Craig Thurling
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Officer
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Councillor Helene Mansilla
Agenda item :
13 Statement of Accounting Policies 2025/26
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Officer
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Councillor Helene Mansilla
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Councillor Craig Thurling
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Officer
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Councillor Helene Mansilla
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Councillor Craig Thurling
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Councillor Helene Mansilla
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Councillor Craig Thurling
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Officer
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Councillor Helene Mansilla
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Craig Thurling
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
Agenda item :
14 Q3 Treasury Management Prudential Indicators
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Helene Mansilla
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Councillor Craig Thurling
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Councillor Helene Mansilla
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Craig Thurling
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Councillor Helene Mansilla
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Councillor Craig Thurling
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Guest
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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David Stanley, Deputy CEO
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Councillor Craig Thurling
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Councillor Helene Mansilla
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Councillor Craig Thurling
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David Stanley, Deputy CEO
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Councillor Craig Thurling
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David Stanley, Deputy CEO
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Councillor Helene Mansilla
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Councillor Helene Mansilla
Agenda item :
15 2025/26 External Audit Plan
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Officer
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Councillor Helene Mansilla
Agenda item :
16 Proposal to Appoint New Member of the Standards Hearings Sub-Committee
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Councillor Nick Bridges
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Councillor Helene Mansilla
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Councillor Paul Hodgkinson
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Councillor Helene Mansilla
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Councillor Helene Mansilla
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Councillor Helene Mansilla
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Angela Claridge
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Councillor Helene Mansilla
Agenda item :
17 Proposal to Change Audit & Governance Committee date
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Councillor Helene Mansilla
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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 Helene Mansilla - 0:00:14
Councillor Helene Mansilla - 0:00:24
There is a three hour time limit.but after three hours we can vote with them to a fourth. I expect we can finish within
two hours.
Before we begin giving the recent changes to the committee, I will take a moment to
welcome and introduce members. We welcome Councillor Turling, recently elected to the
and joining this committee.
We also welcome Nick Craxton, Independent Member, appointed at full council in March,
and former Chair of the Independent Remuneration Panel.
Welcome to the committee, Nick.
I also note that the term of our other Independent Member, Chris Bass,
has been extended also by full Council in March through to 2028.
Congratulations, Chris.
I would also like to congratulate Emma Cutcott,
Assistant Director of the Council Fraud and Enforcement Unit,
who was recently recognised as Female Pioneer of the Year
at the Public Sector Counter Fraud Awards.
Congratulations Emma.
For completeness, I will briefly recognise members present this afternoon.
Council Coleman, our Cabinet Member for Finance.
Councillor Wilkins, former Chair of Audit and Governance Committee.
Councillor Hockinson, former cabinet member and current cabinet member for Health Communities
and Fire, across the South County Council.
I note that Councillor Bridges just entered the room.
Welcome to you all.
I can see that there is no public present, so we will move on to the first item of the
1 Apologies
agenda. Let's begin with apologies for absence. Nicky, could you please confirm any apologies
have been received?
Nickie Mackenzie-Daste, Officer - 0:02:59
We have apologies today from Councillor John Waring who was sent as apologies in advanceCouncillor Helene Mansilla - 0:03:06
Nickie Mackenzie-Daste, Officer - 0:03:06
Councillor Helene Mansilla - 0:03:07
and Councillor Jeremy Thayer. Members might have noticed that there is a document thathas been introduced today. I will pass it over to our Director of Governance and Development,
Angela Clerich to provide you an update.
Angela Claridge - 0:03:34
Yes, thank you very much everybody present members. Our apologies, theinternal audit plan and the audit charter was left out of today's pack and
it's also only been circulated today and wasn't added to the website until later
on today. Now, with the Chair's agreement, what we've said is when we come to that item,
which would have been following item 11 on the agenda, Lucy will present on the audit
plan as she does normally and then Lucy will take you through what the objectives are of
this particular paper. We do need a vote, but just to give you comfort, this is an annual
report and we come back on a quarterly basis with the internal audit updates. So I don't
want members to feel disadvantaged in any way. My apologies again, Chair.
2 Substitute Members
Councillor Helene Mansilla - 0:04:27
Continue with the agenda. Any substitute members? No noted. Next, are there any declarations3 Declarations of Interest
4 Minutes
basis of interest. We have a set of minutes from the previous meeting to approve. I will
go through them page by page. Please do interrupt me if you have any corrections.
So we're starting with page 5.
Councillor Paul Hodgkinson - 0:05:16
Councillor Paul Hodgkinson - 0:05:17
Yeah, sorry, I'm struggling to find the pages on my digital copy, but I can say early onin the minutes that my attendance isn't recorded for the last meeting in January, so I was
here and I can confirm that Tony Dale wasn't here so if the record could be
changed please then that'd be great. It's page six. Thank you.
Councillor Helene Mansilla - 0:05:47
Thank you. Page six.page 7, page 9.
On page 9, it appears that there is a misalignment between the headers of item 60 and 61.
Councillor Helene Mansilla - 0:06:37
Are we all alright with page 10?Page 11.
And finally, page 12.
Yes, sir.
Thank you, Chair.
David Stanley, Deputy CEO - 0:06:59
Just on page 6 of the minutes, running over to page 7, there was a question at the lastcommittee meeting from Councillor Hodgkinson regarding the original
purchase price of some of those investment properties so we've got an
update we can circulate to all members of the committee via email in terms of
those original purchase prices what we don't have is the complete picture for
investment property within the Cotswold district because they were acquired at
varying points in time and some may have been passed over to the council from
predecessor councils many many years ago but for the record for those where we do
have an original purchase price against the value in the accounts at the end of
March 2025 there is a downward valuation movement of just under 4 .2 million
pounds but we'll circulate that to all members of the committee after the
Thank you.
Councillor Helene Mansilla - 0:08:04
Any further comments or corrections?Thank you.
Can I ask the committee to confirm the minutes as an accurate record?
Councillor –
Councillor Helene Mansilla - 0:08:22
Short hands please. Thank you. In that case we will move to the next item.5 Public Questions
You can see that there is no public questions, so thank you.
None noted. Thank you.
6 Member Questions
Are there any members questions? None noted. Thank you.
7 Audit and Governance Committee Work Plan
Moving on to the next item, the Audit and Governance Committee Work Plan.
This item asks the committee to review and note the Work Plan for the year.
I will invite the Director of Governance and Development, Angela Clarage, to introduce the item and take us through the key dates.
Angela Claridge - 0:09:18
Thank you chair. So members will see that they've got the programme in front of them.I suppose really the question is, are there any items that members would expect to see
or would like to see added to our work programme? This isn't your final opportunity because
we always look at the work programme, but if there's anything there that you feel you would
like an update on or you feel is missing. Other than that you can see what's
coming through. As ever a little bit top loaded with today, lots of items today
and less so coming up later on the year but I'm sure that will get populated as
the as the year goes on and I think this is a good opportunity to say I believe
we've had a request through to move the meeting of the 8th of June. Chair is it
It's appropriate to cover it now.
According now.
Councillor Helene Mansilla - 0:10:09
So I believe the date that we would like to move to is in July.27th of July.
27th of July.
So I believe that change has been requested to align with some of the accounting practises and the timescales for that.
Angela Claridge - 0:10:25
So that will be updated on the website and I'll be seeking members agreement for that today.David.
Yes.
David Stanley, Deputy CEO - 0:10:34
Councillor Helene Mansilla - 0:10:35
Can I ask the committee if it is content to approve their chains, please?Officer - 0:10:57
Councillor Helene Mansilla - 0:10:58
Officer - 0:10:59
I need to liaise with Democratic Services but there's no internal audit progress reportsin the work plan and there's no plan for 27, 8 listed but I'll liaise with Dem Services
and get those plugged in.
Councillor Helene Mansilla - 0:11:13
Councillor Helene Mansilla - 0:11:29
Councillor Helene Mansilla - 0:11:37
Thank you, Chancellor.Councillor Helene Mansilla - 0:11:52
Councillor Helene Mansilla - 0:11:56
Thank you, Chair.Councillor Helene Mansilla - 0:12:02
Thank you.Thank you.
So that's agreed.
Moving on to the next item, the Procurement Action Plan follow -up.
8 Procurement Action Plan - Follow-Up
Members would recall that this follows the Procurement Action Plan agreed in September 2025.
This report provides an update on progress.
This afternoon, members are asked to consider and comment on their report and to note that
a further update is proposed for October 2026.
I will pass it over to the Deputy Chief Executive and Section 151 David Stanley to introduce
the report and take us to the key points.
Thank you David.
Thank you Chair.
David Stanley, Deputy CEO - 0:13:01
So, this report is an update following the report that was presented to this committeeat the end of September 2025 into the procurement matter that was investigated by the Counter
Foreign Enforcement Unit.
Part of that report included an action plan to improve the internal controls around procurement
and to provide members of this committee and members of the Council more widely with assurance
that those controls were effective.
This report sets out what has taken place in terms
of those actions since September.
Section 2 of the report covers that in terms of actions 1, 2,
3, and 4 were considered closed for this meeting.
So the actions had taken place pretty much on or around the end
of September if not a bit later and therefore no longer need an update. Actions 6, 7, 8
and 9 are on target. Significant progress has been made. But I felt that it would be important
for members to receive a further update on those particular actions in October. And that's
largely around making sure the review of the terms of reference is signed off. That's going
through Commissioning and Procurement Board in May.
Improved financial reporting,
which is around the aggressive business world system.
We've made some changes to the way in which we
structure cost centres and have a hierarchy
to make it easier for budget holders and directors
and heads of service to understand
how their costs are working through.
Implementation of purchase to pay,
which is also known as no PO, no pay,
but that's a bit more negative.
That's been a longstanding wish of internal audit and others to have that in place.
That is progressing.
We're due to communicate with both internal stakeholders and suppliers in the coming weeks
on the timescale for making that change.
And finally, the other action is action nine, mandatory member training.
So a mandatory training session was held on the 18th of March in person, shortly before
the full council meeting. Unfortunately, a small number of members were unable to attend.
Those members will be receiving an email shortly from the chief executive's office inviting
them to watch a recording of that meeting by the end of April. That will ensure that
we've captured every member with that training. I suppose on reflection, arranging another
session was always going to be difficult and it always would lead to that risk
that members wouldn't be able to make that additional session so the decision
was taken today to effectively provide the recording for members to watch at
their leisure. It's a 47 minute recording which should allow you to plan that in
over the last few weeks of April. Action 5 on the action plan which is included
included in the annex you'll note has been removed.
That's largely because action two,
the mandatory E form that is required to be completed
by those undertaking procurement is already providing
an effective internal control.
Action five was around implementing further system
improvements to aggressive business world that was
in effect enabling the procurement module.
that would have required quite significant officer input to get that in
a go -live position and given the timescale involved and with two years or
just under two years to the date at which this council won't exist and the I
suppose limited additional assurance that would provide in the internal
controls the decision was taken that that was no longer required because that
and Action 2 is providing that mitigation. But happy, Chair, to take any member questions
there are on the report.
Questions, comments?
Councillor Helene Mansilla - 0:17:25
Christopher, please.Councillor Helene Mansilla - 0:17:34
Guest - 0:17:37
Thank you very much. Thanks for the update, David. I mean, this was a significant governancechallenge for the organisation, so it's really pleasing to see all the actions
being completed on time and looks like there's been some really nice progress
made. I just had a couple of clarifying questions. One was on the procurement
toolkit because I noted that the action was on the implementation of a toolkit
and I suppose implementation can be defined in a couple of different ways. So
it's nice to have a toolkit, so I suppose I'm interested in a little bit more
in how the toolkit is used in practical terms.
So I'm just trying to make sure that the action wasn't just about designing a toolkit
and placing it somewhere to gather dust.
So just trying to ensure how it's actually being used in practical terms
and how the council ensures that it is used by officers and members alike.
And then a quick follow -up, it's well documented on this committee,
my love of training and my disdain of people not attending training. So just wanted some
reassurance that I think you alluded to in your comments but some reassurance that any
members who have not completed that training that there'll be an appropriate follow up
to ensure that they do.
Thank you, Christopher.
Councillor Helene Mansilla - 0:18:55
David Stanley, Deputy CEO - 0:18:57
Yes, thank you, Chair. So in terms of the training, yes, the video will be is made available.I've shared the link with the CEO's office email address.
That video is due to expire in 38 days,
so watch it before it drops off our catch -up service.
And we'll be ensuring that we follow up
any non -compliance with that.
So there's been quite a concerted effort
from the chief executive to ensure
that members have received that communication to say,
this is mandatory.
you are expected to either have attended the training or if you weren't able to attend
the training to watch the video.
In terms of the toolkit, so yes, that toolkit has been made available on the Council's intranet
site but through the work that is conducted by the Commissioning and Procurement Board
that is chaired by Andrew, the Monitoring Officer, that is a toolkit that is not optional,
if I put it that way.
So when individual officers are looking to undertake procurement, they are to contact
Kieran and the team, and Kieran and the team will say, unless you've used the toolkit,
we're not going to process that procurement request.
So it is a toolkit that is being used widely, and the work that commission and procurement
do is to ensure that we're ironing out any issues.
There may be some of the documentation, making sure it's as user -friendly as it can be.
Councillor Helene Mansilla - 0:20:34
Councillor Craig Thurling - 0:20:37
This might have been addressed before this is my first committee meeting.So action two where it says purchases above £5 ,000 would require an e -form to be filled
in.
I get that.
What's the process for under £5 ,000 and how many are there?
Is it like the Pareto principle, or is it like an 80 -20,
there's more below 5 ,000?
And if so, what protections are in place to prevent fraud,
et cetera?
Thank you, Chair.
David Stanley, Deputy CEO - 0:21:08
So in terms of the mandate reform,this is to allow the financial system to track contract spend.
So the contract that's being let for particular goods
and services wasn't reflected in the financial system.
So there would be spend undertaken with the supplier, but you wouldn't know whether that
spend was part of a contract or non -contract.
The spend below that level, that's generally one -off time -limited goods, works, services.
That's covered in the procurement process through the route that procurement officers
are revised to take to obtain two or three quotes, depending on the value.
So that's seen as lower risk in terms of tracking the contract spend.
But I take your point, procurement fraud is quite prevalent and we do need to be aware
of that.
Members have had as part of that mandatory training a set of slides that was prepared
by Emma Cathca and her team on the risks around procurement fraud and particularly highlighting
to officers as part of the training that officers have received on procurement, the risks around
procurement fraud.
You have now got, I'm sure Emma will correct me if I get the terminology slightly wrong,
the economic crime position on the new legislation of the failure to prevent fraud so the council
has a duty to ensure it has adequate measures in place to prevent fraud and that includes
procurement fraud.
Councillor Helene Mansilla - 0:22:48
Officer - 0:22:50
Thank you, Chair. I was just going to add as well, we have done this year, so you'llget the results in your next report, a review of all small payments for exactly that reason.
So to ensure that somebody isn't paying 5 ,000, 5 ,000, 5 ,000, 5 ,000 and avoiding any procurement
process. So we have done that review. So a report will be provided, first of all, to
David for review, and then it will come to committee so you'll know. But what will probably
happen is we'll build in a process with internal audit who already undertake a review of duplicate
payments every quarter to ensure that we're not paying somebody twice. So we'll probably
just expand that piece of work. So when they're doing the duplicate payment cheques, they'll
be doing a small supplier is it the same thing cheque at the same time so that
that will follow as well and and yeah there's a I've just sent you actually a
briefing note on the Economic Crime and Corporate Transparency Act and we're
working with Kieran to expand the toolkit to include more information on
Councillor Helene Mansilla - 0:23:54
Councillor Craig Thurling - 0:23:57
procurement fraud. Yes so just to follow up on that so I appreciate this might belike a one -to -one relationship so you go out to somebody and you procure it from
somebody and there's processing in place. Is that also give protection in terms of
if they need to go to somebody to procure it like a third party in the
supply chain or is it literally just between the one -to -one relationship that
you're between the council and the person you're or company you're
Councillor Helene Mansilla - 0:24:24
procuring it from or do you look at the wider supply chain as well? I'll takeDavid Stanley, Deputy CEO - 0:24:27
that one away because I think we have in place, depending on the type of contract, the abilityfor that supplier to subcontract or not, and it will depend largely on the nature of the
contract. But particularly for those lower value spends, that will be on a one -to -one
relationship. So we tend to say, supplier A is providing us with services to the value
of that and that is that supplier providing it.
But larger contracts, for example, in social housing,
which we don't get involved in, there may be a supplier
that provides bits of it but they then subcontract
but there will be clauses within that contract
to monitor and evaluate that.
Just going back to the lower value spend,
in action seven around improved financial reporting,
You'll note at the bottom of page 24, spend analysis.
That's already undertaken as part of the regular reporting
into commissioning and procurement boards.
What we do is get the data and performance team
to provide Kieran, who's the senior business partner,
information on who has the council been spending money with
and aggregating that up across the three publica partner
councils and publica as well and looking at that
and determining is that on contract,
that, should it be on contract, and that starts to pick up some of those aggregation of smaller
spends that could creep through.
But part of that spend analysis would be to identify non -contracted spend where you've
got, let's say, five individual managers each purchasing from the same supplier, £5 ,000
worth of goods and services.
There might be a better solution of having a single contract in place.
And some of the work that's being undertaken across Gloucestershire in preparation of local
government reorganisation in two years' time is starting to look at that from a Gloucestershire
wide perspective.
So there's a lot of work going on to understand the procurement position and those options,
but also there is a very much within the finance workstream overview around the counter fraud
and the internal controls that need to be in place around procurement to avoid
that issue.
Councillor Helene Mansilla - 0:26:45
Councillor Craig Thurling - 0:26:48
Please, Councillor Turley. And presumably that would also then cover trend analysis as well.So you might have a hundred individual, less than five thousand
amounts, that does add up, but if you're looking at individually it wouldn't
necessarily show up a pattern. So presumably you run trend analysis to look at over a
of time, if there's a particular company that has a lot of these in place, you might just
slip under the radar on a one -to -one, but over time it would pick up.
Councillor Helene Mansilla - 0:27:14
David Stanley, Deputy CEO - 0:27:16
Yes, exactly that. So the Commissioning and Procurement Board receive that on an aggregatedbasis throughout the year, so it's not just looking at spend per month, it's aggregating
that over the course of the financial year. So we tend to look at it for the current financial
but we've been looking at 24, 25 and 25, 26 on an integrated basis.
And then that's also then compared between the partner councils.
So we're looking at that commonality as well from a best value point of view between the
spend at Cotswold District Council, Forest and Dean District Council and West Oxfordshire,
because there might be an opportunity for a joint contract.
Although we need to be mindful of the LGR position that whatever happens with the government's
decision where stotch is going to go in one direction and costach is going to go in another.
Councillor Helene Mansilla - 0:28:06
Any further comments? Thank you. The report and comments are noted.9 Annual Governance Action Plan 25/26 Update
Moving on to the next item, annual governance action plan 2025 -2026 update. This report
report provides an update on progress against the annual Governance Action Plan, which members
will recall.
Suppose delivery of the Council's governance arrangements identified in the annual governance
statement and actual plan approved in July 2025.
The item asks the Committee to note the report.
I will pass over to Angela to introduce the report.
Angela Claridge - 0:28:59
Actually, I am going to pass the baton on again. If I can introduce my colleague Sandrineat the end. Sandrine, I think this is your first time at this committee. Sandrine was
going to present the item, Chair. Thank you, Sandrine.
Officer - 0:29:12
Thank you, Chair. This is end of year report made against the AGS action plan, the magicmajority of the actions have been completed and are showing
grey.
There was eight actions, seven have been completed.
The business continuity plan remains in amber and will be
carried over to next year.
Loads of good progress were made by the team.
The business impact assessments have been completed and they
will feed into the new business continuity plans.
Ongoing actions such as LGR internal audits,
CDC policies and service plans will be carried over to 26 -27.
And finally, we are looking at the annual government statement 25 -26, which is backward -looking,
and the action plan 26 -27, which we're planning to bring to the committee in the summer.
Councillor Helene Mansilla - 0:30:10
Do you have any questions?Any questions?
I just wanted to ask about the business continuity plans because in my experience business continuity
Guest - 0:30:24
when it happens doesn't wait for things to be carried over.I don't know if this committee has had the opportunity historically to review the existing
business continuity impact assessments or plans or if we are waiting for a new one to
arrive, is there the opportunity to in the meantime look at what's in place and potentially
Councillor Helene Mansilla - 0:30:45
comment on any gaps that might exist?Guest - 0:30:47
Councillor Helene Mansilla - 0:30:49
André, would you like to take that?I'm going to go with it.
Officer - 0:30:52
The current plans remain in place.There was a new business impact assessment introduced this year, so we all went through
a training, then we all completed that business impact analysis or assessment, depending on
The team is feeding that feedback into our new business continuity plans which we are
going to review and then test and then implement.
In the meantime, the existing ones remain in place as they should be.
Councillor Helene Mansilla - 0:31:27
Any further comments?Guest - 0:31:37
Sorry, is it in the scope of this committee to review the business continuity plans anddo we, is it appropriate for us to in the meantime look at the existing ones?
Thank you.
Councillor Helene Mansilla - 0:31:50
Guest - 0:31:50
Angela Claridge - 0:31:52
So thank you Nick for the question.So I would say that what's the responsibility of this committee is ensuring that we have
up -to -date business continuity plans and arrangements in place rather than reviewing them all.
There's a lot, I have to say.
There is a lot.
But as Sandrine mentioned, we've been doing a very recent piece of work around them to
ensure that our business continuity plans are up -to -date and that we test basically
as Sandrine has outlined with a number of issues including shortage of petrol and that
type of thing being considered. So I think from your perspective you need to be reassured
that we are doing what Sandrine has just said, that we are updating our plans and that they
are in place rather than reviewing them all.
Thank you.
Councillor Helene Mansilla - 0:32:39
Any further comments?Thank you.
The report is now taken.
10 Strategic Risk Register and Risk Management Policy
Councillor Helene Mansilla - 0:32:49
The next item presents the Strategic Risk Register following its preview review in December2025 and the Risk Management Policy.
Members are asked to review and register and approve the policy.
I will pass it on to David to introduce both reports.
Thank you, Chair.
David Stanley, Deputy CEO - 0:33:18
This is one of the now regular updates that this committee gets on risk management.So annually we bring the risk management policy,
risk management strategy to this committee for review
that was last considered in May 2025.
It's attached as Annex B.
No changes are being proposed to that policy
in the next review day would be next year.
So that policy is generally reviewed every other year.
What has changed, and you'll see in section three,
is there's been a review of, by the corporate leadership team,
which for those of you that might not be as familiar with the corporate leadership team,
that's Jane, the Chief Executive, myself, Angela, the monitoring officer,
and Helen as the director of communities in place.
Every two months we have quite a detailed review planned in of the strategic risk register.
I'm following that review by CLT.
We take that to the extended management team, which is heads of service,
for them to review our review, but also for that group
of managers to have the opportunity to escalate risks
that they've got on their individual service risk
registers for inclusion on the strategic risk registers.
There's quite a good robust process in place around making
sure that risks are being adequately reviewed.
But section three sets out there are 15 risks.
One, possibly two new risks since the previous risk register
was updated.
I say one, possibly two, because there was, it was flagged at the
last time that there should have been a risk around fraud.
It wasn't included in the PAC that went to members in December
but was added into the risk register.
But for the purposes of this report, there are two.
But there are also, in paragraph 3 .5,
some upward revisions to risk scores, particularly around the local plan, but also around civil
contingency, which touches upon the question in relation to business continuity plans.
I was going to come in on that item, but I'll cover it here. So you'll see on page four
or five of the Strategic Risk Register, page 46 of the pack, at the very top of the table
on page 46, there is a risk around civil contingency
major event.
The council is not adequately prepared
to deal with a major civil contingency leading
to harm of life.
And you'll see that has been increased in score.
The residual risk is the same as the initial risk.
And the reason for that increase in score
is as a CLT, given the significant governance issue
that was flagged in the annual governance statement
last year that you've just had the update on,
that hasn't progressed at the pace it needs to,
to provide adequate mitigation.
So we are working through that.
The intention is to have an updated business continuity
plan in place for the council,
including all the services it provides
and those provided by publica by the end of May.
But we have only just really started that process
with the business impact assessments
and that's recognised in the red element of the update on the controls.
But aside from that, it would be remiss not to say that as an organisation, we are prepared
for a civil contingency.
We do have gold, silver and bronze people trained.
We've been through various operations, as I've called them, Operation Pegasus and Mighty
which are national planning scenarios that are put in front
of Gloucestershire as a whole, we play our part in that.
Operation Pegasus, for those of you that are wondering
what that was, that was around what would happen
in the event of a new strain of a horrible disease,
not dissimilar to COVID, and Operation Mighty Oak
was what would happen if there was a national power outage,
not just for a short period of time,
but for a prolonged period of time.
That was quite a testing scenario
that I know Andrew was part of.
But I think where we have got to in terms of scoring this,
we felt that particularly on reflection on the local plan,
until we get to the Reg 19 consultation stage in August,
the underlying risk hasn't gone away.
So getting to the Reg 19 is the key issue.
So regulation 19 is a particular planning phrase
which I won't intend to explain, but that to us
as a corporate leadership team was the risk.
The failure to get to the Regulation 19 stage puts
at risk the whole delivery of an updated local plan.
But happy to take questions members might have on any
of the risks or the report in general.
Councillor Helene Mansilla - 0:38:29
Yeah, thank you.Councillor Paul Hodgkinson - 0:38:31
I wanted to delve in a bit more into the civil contingency major event risk, which as you'vesaid is risen, has gone up.
And I wanted to particularly sort of talk about RAF Fairford and, you know, obviously
with the backdrop of an increasingly unstable world.
We have the war in the Middle East going on.
We have American planes using the base at Fairford.
I've had constituents starting to raise with me
concerns around that and community safety in the
event of, and obviously, God forbid, some kind of
attack on that air base from someone, from, you
know, a hostile power of some sort.
So what sort of reassurances can you give in terms of how the council's
thinking about that? It's on our doorstep, it's very close to large populations.
What is the council doing to ensure that if there was something awful that
happened that we would be well placed to to deal with it with our partners?
David Stanley, Deputy CEO - 0:39:47
So I think it's best to provide members with a full answer to this in writing because therehas been briefings provided by the Gloucestershire Local Resilience Forum around the particular
situation that you've set out in Fairford.
There is already in place an action plan to deal with RAF Fairford more generally, but
given the particular scenario that you've set out with the position in the Middle East,
that risk is slightly heightened.
But I, rather than trying to give you a verbal update, I think it would be best if that's
provided as a written update, because certainly Jane as chief executive has been part of those
briefings around RFF, because that involves multi -agency.
So not just us as a district council, also involves the county council, involves the
RAF, the US Air Force, but also will involve other parties as well.
And we'll give you some reassurance through that formal response.
Thank you David.
Councillor Helene Mansilla - 0:40:49
Before we continue, Councillor Bridges, I note Councillor Thalya in the room.Welcome Councillor Thalya.
Councillor Bridges.
Councillor Nick Bridges - 0:41:02
Oddly enough, my question was the same as Paul's.But my second question would be, we had a power cut here in Sire and Cessna, which threw
me by surprise.
I've also had outages on mobile phones and we're always at risk of flooding here.
I don't feel I've actually seen much to do with how we would deal with that.
Could I be sent an up -to -date answer to that question as to how Sire and Cessna deals with
problems?
David Stanley, Deputy CEO - 0:41:37
So in terms of flooding, there is a flood risk management process in place.Flood wardens already work collaboratively across the district.
I'll provide that information.
In terms of the issue around a power outage, loss of mobile phone signal, the work that
we're undertaking on the business impact assessments,
and I'll use the finance as an example,
because it's one that Michelle's drafted
that I've been reviewing,
that looks at what would happen
should there be a significant outage of IT.
So that could be the loss of power,
which reduces, you know, you lose the internet.
It's how the council can continue to function
in the event of a significant outage.
So a short reduction in power for a short period of time is probably an irritation for
some if it's out for 10, 20 minutes, but a prolonged outage or a cybersecurity hack,
the internet more generally goes down.
That's what we're currently working through those business impact assessments for.
And working with John Shorten, who's the chief technology officer, to work through the prioritisation
of the council systems and in what order they would need to come back online and what the
time scale is for those systems to come back online to either ensure the council can provide
day -to -day services and so on.
But there isn't a specific plan in place for localities around a power outage.
That would be one that I would expect the power operator to be providing in terms of
how they would mitigate that impact on residents but there would be an impact on us and businesses.
Councillor Helene Mansilla - 0:43:30
Councillor Craig Thurling - 0:43:32
Just to follow up on that one, two things, is there a redundancy to these contingencyplans?
For instance, if there is a fuel issue, petroleum, etc, and it triggers one part of your plan,
But then inadvertently it also triggers another part and another part and another part.
Are there redundancies in place to ensure that one thing doesn't then contribute to and compound issues on somewhere else?
So that's part one and then secondly
Are the public aware of this and I suspect the answer is probably no.
That if there's an issue within the district who do they contact?
Most likely if it's an emergency they would contact emergency services.
but what would be the expectation that you would see potential members and then also
how would you communicate these plans to the wider public in terms of, in times of civil
issues?
David Stanley, Deputy CEO - 0:44:27
So again, I think it's probably best I give you a formal written answer because therewill be as part of, if there was a major event, and that was various parts of the local resilience
forum are stood up, so there would be a gold commander, silver, a bronze. Part of that
would be to stand a comms sell up and part of that is to ensure that residents and those
affected by that major event are receiving the right communication at the right time.
So there is a process in place that sits behind our own business continuity plans in terms
of how we would communicate that if it was a district -wide or a locality -based issue.
But for a major event, there is a protocol in place through the Gloucestershire local
resilience forum that ensures that communication is there.
In terms of, I suppose, understanding the linkages between how services might impact
one another with their business continuity, a good example would be, as you said, a fuel
shortage.
That happened 20 -odd years ago, probably a bit longer ago than that.
That had quite a significant impact on individuals at the time.
One of the things we're monitoring at the moment is the availability of fuel, given
we have 508 ,000 litres of fuel to buy in any given year to ensure that the council can
run its waste fleet to collect the waste and recycling, given that position, part of the
in this continuity consideration, regardless of the climate impact, was to consider the
provision of a fuel bunker at the depot in South Cerny. That fuel bunker would have 20 ,000
litres of fuel in it, which would provide some continuity for a short period of time.
It might not provide full continuity, but it would enable the service to still run.
But that would also have an impact if there was a fuel shortage on the ability of staff
to travel in or out to work. I think where we have started to discuss that is we have
successfully been able to operate a hybrid working model since COVID. That's kind of
where we would gravitate towards, but there would need to be a clear steer from the organisation
as to how that would work because there would still be a need for certain offices to be
present and certain services to be provided in a particular way. That is part of the business
impact assessment we're working through because one of the questions that's
being asked is what would happen if there was no fuel and how would you
provide that service and what's the risk?
Councillor Craig Thurling - 0:47:04
Yes just follow up on the communication part so covering quite a wide rural areathere's a lot of sort of the residents within my ward don't necessarily have or
can afford the internet usage social media and all of that etc so I'm just
wondering how would you update them accordingly if there was a power outage
for instance how would you let them know or would it be better to produce some
documentation like that of a European countries have in terms of being
prepared this might happen these are the things that we would be doing if that
happened rest assured we're on it sort of thing just to provide confidence
because there's a lot of elderly residents that might not be able to have
that communication directly because they don't have that sort of internet
technology, et cetera.
Thank you.
David Stanley, Deputy CEO - 0:47:54
I think there is a role for ward members in this, a part of thecommunication cell that would be stood up, is how does that
information get disseminated to those particularly digitally
excluded groups.
So I don't have that detail to hand, but I will follow that up
and provide assurance around how that communication, those
communications would flow, particularly for those that
don't have access to the internet, don't have a mobile phone or where that signal disappears
completely in parts of the district. So that is part of the particular characteristics
we've got in parts of the district, particularly in ward areas that have more remote village
locations. Nick, please.
Councillor Helene Mansilla - 0:48:38
Guest - 0:48:40
Hi. I just had a clarification question on how I should be reading your risk register,please it's my first meeting obviously. So you've got initial risk and residual
risk current. Is this intended to be the risk the initial risk is the risk
absent of risk treatment and the residual risk is the assessment following
the controls and mitigations that have been put in place or is it the initial
risk is at the time it was entered onto the register and the residual risk
current is the latest view.
David Stanley, Deputy CEO - 0:49:17
So the initial risk is the unmitigated position.That can change.
So it's not necessarily when the risk was first identified,
because the nature of that might be redefined
and there has been some redefinition of the risks
in this particular update.
The residual risk is taking into account the columns that
follow that which talk about the control mitigation and continuances already
there and then you've got an assessment of what else could we do. What we don't
have on here is the target risk so where are you trying to get that to but what
we do have is over on the far side the risk acceptance level. Are we tolerating
the risk? Are we trying to treat the risk? Are we trying to remove the risk entirely?
Councillor Helene Mansilla - 0:50:06
Thank you.Councillor Len Wilkins - 0:50:09
On page 46 item 3 we look at resilience and democracy saying if we lose our council membersat the end of 27 May we could have a problem.
But I also note with page 44, the bottom item, staff,
you've got the inability to recruit and retain staff.
Did you take into account the fact that we've had this
on the parish council recently?
You go to people and you say, look, we'd like you to join,
and you're here till May.
Is there the same problem with staff,
that you could have a member of staff leave,
Councillor Helene Mansilla - 0:50:50
Councillor Len Wilkins - 0:50:51
and then you're trying to recruit and saying,well you're okay till May 28th,
but after that we're not sure.
David.
Councillor Helene Mansilla - 0:50:58
Councillor Len Wilkins - 0:51:00
Thank you, Chair.So just, I suppose, dealing with the staff issue,
David Stanley, Deputy CEO - 0:51:04
this Council has less than two yearsbefore local government reorganisation makes a change.
So being able to recruit and retain staff
in a competitive environment,
we need to be aware of the fact that,
saying to someone, come and join Cotswold District Council, but by the way, we might
not exist, well, we won't exist beyond the 31st of March, 2028, but they could go to
an already established unitary where that isn't an issue.
That's part of that risk.
So part of the mitigation for that is your note going through cabinet next week is the
council's retention strategy that's trying to address that particular issue.
So if you look at some of the skilled professions we've got now, and we use planners as an example
because it always seems to be planners that are a good example to use, they're a finite
resource.
Not, we are currently trying to get a local plan over the line.
There are other local authorities not in a dissimilar position because of changes that
were made to the national planning policy framework.
Those planners have skills that other authorities would like.
However, we might want to retain those planners for the duration of this council to ensure
we get the local plan over the line.
So what the retention strategy is setting out is how would we do that?
And that's setting out in some detail around what the measures are.
Some of that covers pay, some of it covers some of the wider benefits that accrue to
those in local government employment.
but we need to be mindful of that risk that as we get closer to the local
government reorganisation date staff may be worried about their future employment
and may seek to sort that out for themselves so we've got to as part of
any retention strategy ensure we communicate honestly openly and
frequently with staff to keep them informed of what LGR means.
Councillor Helene Mansilla - 0:53:10
Guest - 0:53:14
comments. Just a couple of questions if I may. So two topics. I need some help withsome acronyms. PCI DSS compliance where the council has chosen not to be fully
compliant. So that was just some comments and context around that one would be
really helpful. And then the second part is on health and safety. I fear I might
have brought this up before because I don't think there's been a particular change in
the status, but it presents oddly to me that on the
compliance health and safety risk, we have an initial risk
score of 15 and a residual or post -mitigation score,
which is the same.
And the mitigations that are listed are things like having
an NHS team and risk assessments in place, which I might expect
to bring, although it may not change the impact, might bring
the likelihood down.
So, just wondering about that.
Thank you, Chair.
David Stanley, Deputy CEO - 0:54:09
So, in terms of PCIDSS, payment card industry data security standard, there are four levelsto that depending on the amount of transactions an entity undertakes.
Local authorities are in the fourth level.
They're the lower tier who have the Amazons of the world,
the general supermarket retailers.
They're doing thousands every hour.
We process a number of payments,
not all of which are through our website.
So there's a number of payments received,
I'm just looking at John Chalkman's note,
which he helpfully provided me,
of card not present, so the payment is taken over the phone.
We are not in a completely compliant position with that because in a sense that payment
is taken over the phone, it's a customer relaying a card number to a person on the end of the
phone and that person on the end of the phone putting that detail into a system.
That is not an end -to -end secure process.
So there are some options that need to be worked through.
Some of them can be very expensive.
What we need to assess is are we comfortable with the level
of transactions that are processed in that way
to be not compliant or do we actually want to get
to a position where we are 100 % compliant.
The PCI DSS standard is most relevant
to those level one, tier one retailers
that process thousands and thousands of transactions every time.
But it's a useful point.
And on the second point on health and safety, whilst we have in place a position around
a health and safety team that's provided by Publica, we have had an outstanding internal
audit action that hasn't been closed off around demonstrating compliance with some of the
health and safety inspections around asbestos,
Legionella and so forth in our property estate.
That is being worked on as priority by Alan Hope,
strategic head of strategic housing and property estates.
But we're not in the position where we can say
to Lucy's head of internal audit, we are compliant,
we have recorded this.
So the inspections are being undertaken,
but we can't demonstrate should there be an issue if the health and safety executive were to investigate
that that's recorded in the system.
So that's why the risk has been scored that way because we don't feel
we're in a position to say the risk has been mitigated because we couldn't demonstrate it has been mitigated.
Any further questions?
Councillor Helene Mansilla - 0:57:10
Councillor Helene Mansilla - 0:57:16
I know the inclusion of the Traveller Direction in the report and the update to the annexroles and responsibilities.
Thank you David.
If there are no further comments or questions, can I ask the Committee if it is content to
approve the risk management policy.
We now come to the Internal audit progress report.
11 Internal Audit Progress Report - April
This report provides a summary of internal audit work completed since January, and gives
the Committee assurance on the effectiveness of the Council's internal controls.
Members are asked to note the report.
In addition, delivered today, we have the internal audit plan and internal audit mandate.
date, this item has been introduced today. This is the first opportunity that we have
to see the complete document. I suggest Lucy take members to it slowly. Thank you.
We are joined today by the Head of Internal Audit, Lucy Carter, who will present and take
through the internal audit plan and internal audit mandate.
Thank you, Lucy.
Officer - 0:59:06
Thank you, Chair. I feel happy I'll do these reports one at a time.So if we run through the progress report first, which is the report that was included in your pack,
as the Chair has alluded to, it gives you an update on the audits that the team have conducted since the last meeting of this committee.
You have four final reports in your pack this afternoon,
There are two reports that are with SLT that we will be following up in due course.
We continue to follow up all agreed actions which is shown in your appendix B.
I am happy to take any questions on any element of this report.
chair.
Councillor Helene Mansilla - 0:59:44
Any questions, please?On that report, Lucy, if nobody has any questions, on the first report, I note that there are
some reports, let me get to the page. On page 69, I know that there are some reports that
are not showing any progress in the pack. So I wanted to ask, are the managers for those
business areas responding in a timely manner? If not, are you getting support from the C
CL team in chasing them down. CL team is the corporate leadership team. Thank you Lucy.
Officer - 1:00:46
We do get support from CL2, ER2. Everything has escalated through them. If we don't getresponses from the officers as we would like, then we will escalate everything through ER2.
but this is the 2526 plan so there's not necessarily any work for 2526 in
progress at this point in time although the biodiversity net game report audit
has started so that is in progress and we have commenced the health and
well -being audit at the time I wrote this report they were ready to start but
now they are in progress.
Councillor Helene Mansilla - 1:01:24
Councillor Paul Hodgkinson - 1:01:28
So just in terms of the audit plan progress where you have the colour coding ranging fromNA advisory to high substantial, so I am kind of interested in those that are substantial.
and where I mean obviously is a relatively new person on this committee
what I'm really interested to know is how does this compare to other times
that this has been reported have there been as many substantial opinions
there's three here isn't there four actually five in fact is that typical is
has it changed from the last time as it got better worse just kind of trying to
Councillor Helene Mansilla - 1:02:18
Officer - 1:02:20
get a sense cheque really on where we are. You're a bit early on the dataCouncillor Hodge could say and all of that information will come in the opinion
report which will be presented this committee in July so that will give you
an idea of what we what we reported on last year so as you say you're limited
and your substantials and we'll compare that to what we've reported on this
year and you'll also have a comparison on the number of agreed actions and the
priorities that we've done in both years as well. So what you're saying is you're
Councillor Paul Hodgkinson - 1:02:45
I'm just recording what happened last time here in terms of the substance.You could just say I'm ahead of the game or whatever.
But the opinion here that's listed, these opinions, these are the historic opinions, you're saying?
Or -
Officer - 1:02:59
No, these are the opinions and the audits we've conducted during 25, 26.So these are each individual audit.
You don't have an overall opinion at this point in time because that opinion report isn't ready yet.
That is drafted in accordance in conjunction with the annual governance statement and the
annual statement of accounts.
That will be ready for this committee in July when all of this is brought together.
My question is, would you like an amendment to this report whereby you compare last year
to this year at that point in time?
Personally I would, yes.
Okay.
Thank you.
Thank you, Lucy.
Councillor Helene Mansilla - 1:03:37
Any further questions?Kristin.
Guest - 1:03:46
Just on page 75, so there was an update to the internal audit activity that had beenconducted previously on members' allowances.
So it looks like some progress has been made, but feels like that process still isn't quite
where we would like it to be is that a fair statement? No it's not because the
the agreed action that says in progress has now been complete because I checked
this before the meeting because it's not sitting in the list of open agreed
actions in Appendix B so we are happy with the members allowances now. Okay
Excellent. Okay. Thank you
Councillor Helene Mansilla - 1:04:27
Thank youOfficer - 1:04:42
Thank you chair, so the second report is the paper version that you have in front of you this eveningThis is the report that comes to the committee on an annual basis. It's the annual report
that we've drafted in consultation with yourself as members, with officers, with public as
staff based on historic information. We've got audits when we've conducted them and what
we do is draught a plan to come to this committee and it comes to this committee for approval
which is why we need to run through it this evening. So some of the pages are standard
template wording. The most important page is I suppose for you to concentrate on
are page 14 onwards where we have the draught annual plan for 26 -27. When we
compile a plan we always keep core financials in there, they're a key
control system, we need to undertake audits in those areas every year. So
we've got core financial testing, we always look at an element of human
resources, we always look at revenues and benefits and we always include ICT. We've
got some governance audits in there this year, so to your point of earlier we've
got emergency planning and business continuity this year. We also want to
look at some health and safety and we also want to look at some safeguarding
this year because we think they're big risky areas at the moment. We have
some continuous, what we call continuous annual reviews, so as David and
Emma alluded to earlier, we do a duplicate payment analysis every quarter on all payments
made. We're also going to do some work with the procurement review unit and building control
because there was a new external assessor coming in. So we're going to work with those
two services to make sure they're where they need to be for any external assessors come
in. So we're going to do a quarterly review, which is being planned at the moment. And
What you've also got in the plan under the proposed audit areas section are the audits
that are more specific to the council.
This was in discussion with David, Angela and Jane.
We've got some areas that we're going to look at specifically for the council, which includes
some areas in planning.
We need to do some follow -up audits in respect to data retention, leisure and culture and
digital exclusion, which are audits that you saw either earlier in the year or in 24, 25.
On page 17 is a list of all the extra little bits we do as an audit team.
Page 19 onwards is the internal audit charter with mandate which again needs to come to
the committee for approval.
It's a standard swap template that explains the roles and responsibilities as yourself,
as members, as myself, as your head of internal audit, the internal audit team and with officers.
I don't propose to go through that because I had to write it.
I am happy to take any questions on any element of that report but I appreciate you having
had time to look at it fully.
Any questions?
Councillor Helene Mansilla - 1:07:46
Councillor Helene Mansilla - 1:08:04
Can I ask the committee if it is concerned to approvethe internal audit plan and internal audit mandate.
All those in favour?
Thank you.
Councillor Helene Mansilla - 1:08:33
Moving on, I think we can now move to the Con -To -Fraud and Enforcement Unit report.12 CFEU Update Report (Including RIPA and IPA annual update)
This report provides an annual update on counter -fraud activity, including RIPA, the Regulation of
Investigatory Powers Act 2000, and IPA, the Investigatory Powers Act.
The Committee is asked to consider and comment on the report.
We are joined today by the Assistant Director, Counter Fraud and Enforcement Unit, Emma Caff,
Emma, who will present the report and take any questions.
Officer - 1:09:14
Thank you chair. This is the update from my service area about theactivities that we've undertaken for 25 -26. It's also an opportunity to give
you your annual update in terms of Ripper and IPA which is surveillance
activity or us acquiring communications data and there's a couple of extra bits
in there just for information about the whistleblowing policy but I'll go
through them. The 2 .3, 2 .4 just gives you the detail around what we are focusing on.
So 2 .3 added on to earlier, we were talking about procurement, so we are still going to
continue with some work in that area. On the intranet sites with the procurement toolkit
we intend to put a specific area about procurement fraud so information will be there to detail
what types of fraud that is and how to mitigate for it.
The new specific procurement fraud risk register will also be there,
which will detail all of the risks.
So more information will be available to the staff.
Mandatory training will be put in place again for next year,
so there's a lot of work ongoing in that particular area
across the whole partnership.
For this year, what I wanted to do is expand the workstream on fraud awareness.
It's become enormous to try and explain what fraud is, and it's very, very different depending
upon what officer I'm talking to or a member or a resident or a colleague, et cetera.
So what we've decided to do is look at specific workstreams for those different areas and
then add on and expand in those areas.
So for staff, for example, the fraud awareness training that we would be giving to the revenue
staff would be very, very different to the staff that procure large things.
So unequally, the residents, they're going to be very much interested in scams and how
to avoid such things, as well as information that affects the council.
So it's trying to make it much more relatable to the people that we're talking to.
At 2 .5, I detailed the new failure to prevent fraud offence.
The important thing about this is it's fraud that benefits the council, it's not fraud
against the council.
So it's an important area, again, relating to procurement because where we're not following
the rules, even if we were looking for value for money, if it looks as though we have circumnavigated
rules to obtain a contract, we could be accused of failing to prevent fraud. I have just issued
a much fuller briefing note to you all via democratic services, so you should have that.
If you have any questions, you have only got to email me and I will follow it up with you.
From three onwards, there is information on the activities that have been ongoing. I have
put the website in there again because that launched and it is now live, so it is a good
tool for any residents in terms of how to report fraud, where to report fraud,
what types of things they can do to prevent each area, the different types of fraud. So emails, texts,
rogue traders, etc. There's lots of information on there and we do intend to expand it. So there's a repository of
leaflets and details so that when we do our
campaign with town and parish
Councillors they could go to the site and print off information and use it for their meetings etc
3 .6. I've referenced the business grants so six years after the event we are now just about finished
I think that deserves a cheer because it's been
lengthy and the final debt which we are
Collecting dbt have agreed to take but to take that off us and to continue to to collect the payments, so we won't have any further
administrative burden of monitoring that collecting it and sending it back so
yeah been a large undertaking but it's just about done. At 3 .7 is your usual
update in terms of the National Fraud Initiative matches that we look after
for us colleagues so most of the ones that we focus on are in revenues and
relate to council tax or the housing waiting list anomalies but we also look
after the payroll matches so that's where there's concerns about staff
having additional employment or failing to declare conflicts of interest, things like
that.
3 .8, your housing waiting list has been slightly delayed, but that should be kicking off this
financial year.
And I've given you at 3 .10 just some general information about why that piece of work is
really important for loss avoidance.
Temporary accommodation is clearly expensive, so if we can make sure the right people are
being put in that, that's important.
3 .12 onwards is the specifics in terms of our reactive casework so those that
we get referred in terms of your council tax support or help with other
enforcement officers across the council and we have undertaken here a review of
your council tax reduction scheme claims and that's detailed at 3 .17. It has
generated quite a high value of council tax debt and I will be doing a report
after that's finished in terms of learning what we can do to mitigate that moving forward,
et cetera.
3 .19 talks about any staff matters that we've undertaken.
At section 4, it's your update in terms of surveillance activity.
The key point in here is policy updates.
So I've detailed those for you at 4 .3, 4 .4 and 4 .5 what we've updated since you last
had a report.
Those policies will be reviewed probably the back end of this year thoroughly and
as a consequence the whole policy will come back to you at some point.
Section 5 is just a brief note about the whistleblowing policy. You approved that
in May 25 but we've just made a very small amendment following the
Employments Rights Act so just making a note so that you're aware of that
inclusion at section 1 .5 in the policy. Happy to take any questions.
Councillor Helene Mansilla - 1:15:38
Councillor Paul Hodgkinson - 1:15:41
I wanted to just look at 3 .6 because I found these figuresabsolutely staggering I have to say with regard to COVID and what was paid out.
75 .5 million pounds that this council paid out.
It's incredibly, incredible figure.
I had no idea it was so big.
But, you know, worryingly, there was this one million,
which according to the report was paid due to fraud and error.
So my question there, and I've got another question as well,
is what specific fraud are we talking about
and what specific error are we talking about?
And then secondly, we're still left with over half a million pounds that hasn't been recovered,
which is taxpayers' money, isn't it?
So how you've said that debt is transferred liability to DBT.
I'm not sure who DBT is.
But how is it we've ended up with so much then?
which is again, it's a huge amount of taxpayers' money, isn't it?
Councillor Helene Mansilla - 1:16:55
Councillor Paul Hodgkinson - 1:16:56
I mean, I'd start by saying fraud is the most prevalent crime in the UKand it affects absolutely everything and grants is one of those areas.
I think Covid was a prime example of fraud risk
and there's been lots of learning that came out of it,
including the central government creation of the Public Sector Fraud Authority
because of all the bounce back loan issues, etc.
In terms of what we found, you know, 75 and a half million versus one is
relatively low I think in terms of the overarching amount. We did a complete
review of all the mandatory grants so as an audit after we had paid them we then
reviewed everything we had paid so it's a really really thorough piece of work
which is why we've identified such high figures because we went back and did
that review and not many councils did undertake that.
In terms of fraud and error, it's the usual false information provision.
People were saying they weren't directors, but they were, so they weren't eligible under
some of the schemes.
Some were duplicate applications through error.
It wasn't actually fraud, it was simply that the system was hideously complicated.
And if you recall, there were nine million different schemes over different periods and
It was awful.
People were putting in applications,
thinking that they'd not processed it,
putting in another one. Payments were getting made.
So it wasn't just fraud or dishonesty.
It was genuine error as well.
In terms of debt, that that we've recovered,
we have returned because the money came
from central government in the first place,
so it's their funds to take back,
and the schemes were reconciled.
The outstanding debt they've taken on,
and they will then pursue the recovery
through legal routes and have made quite good inroads with those.
Councillor Helene Mansilla - 1:18:50
Councillor Paul Hodgkinson - 1:18:53
If I can just come back on something.Thank you for that explanation.
So the error, you've sort of implied that the error is from those who have sought the
loans and grants.
Were there any errors from CDC staff which led to some of those figures?
Officer - 1:19:16
There's going to be an element of human error.We had a number of temporary staff in to help administer those schemes,
and there was many schemes running concurrently at different times.
So there was an element of they got an open scheme payment when they shouldn't have done,
or they received a pub closure payment and they shouldn't have done. They were mandated to close,
they got a mandated payment but actually they were a garage and they weren't. So it was very
complicated. There will be an element of human error in there. We administered hundreds and
Councillor Helene Mansilla - 1:19:52
David Stanley, Deputy CEO - 1:19:55
hundreds of grants and a lot of money went out. David. So if it helps that Councillor Hodgson,I wasn't at Cotswold District Council at the time, I was at another authority. The scale of what
Councils had to take on in administering not both business rate grants but also the council
tax side was immense.
The government gave very little guidance to local authorities to how to design those local
schemes and it was down to revenues officers, the likes of Emma and her team, to do that
at pace.
At the same time, the government was trying to publish league tables on how quickly local
authorities were getting rid of that cash that they had promised businesses and individuals.
It was a very difficult position for local authorities to be in with the government saying,
we're going to support businesses, here's a shed load of cash, but it won't give you
the guidance or the support on how to allocate that in a way that reduces, mitigates that
risk of fraud and error. At the same time, you were getting very desperate individuals,
desperate businesses saying, well, if I don't get this 20 ,000 grant the government's promised
me, I will go out of business, my livelihood be ruined. That was a really challenging environment
for staff to work in. It's not surprising that at some part of that process, individual
members of this staff here or all up and down the local authorities of the country would
have made an error. But the error rates and the fraud rates on locally administered schemes
were much, much lower than the bounce -back loan schemes that were provided by central
government. The write -off that central governments had to do on those is significantly above
the debt level that you're seeing reported in here.
Other questions?
Councillor Helene Mansilla - 1:21:43
Councillor Craig Thurling - 1:21:46
Yeah, just one point about the image about how residents can report fraud. Is there anysort of social media friendly posts that we could put out to the community to say
if you see this then you can do that etc. It would just be really helpful that
people might not be aware of how to do it. A lot of the time when I put contact
it is how do I do this and how do I do that and the information isn't always
Officer - 1:22:17
clear so that would be quite useful if possible. So that's exactly why we created thewebsite because there was so many different places you could go for so
many different reasons and to try and research what you were reporting and why
and who was the body that had jurisdiction for looking at it. So the
website brings all of that together. It doesn't reinvent the wheel, it points you
to the right places. We did launch it and we did a comms campaign so I will
revisit that and send it to you but essentially the site is a one -stop shop
so it provides all of that information on how you would report a rogue text
message, how you would cheque if it is your bank calling you, how you would report a rogue
trader, what sort of fraud you should report to county councils or district councils. It
is a one -stop shop. I will forward you the comms that went out and we launched it and
then that can just be provided.
Councillor Helene Mansilla - 1:23:11
David, any further comments?Thank you. From my side, thank you and I congratulate on a unique initiative, the Glass Jar. Supportive
is involved. So congratulations Emma, thank you.
Right, so there is nothing to approve there. So Niki, thank you and the report has been
13 Statement of Accounting Policies 2025/26
considered. Thank you. The NERSC report sets out the accounting policies to be used in
preparing the 2025 -2026 statement of accounts. Approving this in advance is considered best
practise and supports transparency and consistency in financial reporting. Members are asked
to consider and approve the draught policies. I will pass it over to Michelle to introduce
the report. Thank you, Michelle.
Officer - 1:24:32
Thank you chair. Yeah, as you laid outThis is our draught accounting policies for inclusion in our 25 -6 statement of accounts, which we're currently working on
So today is an opportunity for you to just provide any comments or feedback
Or ask any questions on those policies that are set out in our next aid to the report
So the accounting policies really it just as it says in the summary it sets out the principles the basis the conventions the rules
That the accounts have been prepared and presented in line with
and we've reviewed the current policy from last year
and updated it to reflect the updated SITF for guidance
for 25, 26.
And really the only thing I probably want to draw
your attention to is the main change,
which is set out in section four is around the policy
around the valuation of property, plant and equipment.
So there's a change this year where indexation
can now be applied to assets annually.
So we're only required to value assets every five years.
And in those intervening years, we're able to apply an index.
So the main sort of challenge for us this year in preparing the accounts
is making sure we select the correct index in discussion with our internal valuer
and also in turn making sure our auditors are happy with the choice.
So we'll be liaising with auditors ahead of producing the final accounts
just to make sure we're all in agreement on that. But yeah obviously happy to take
Councillor Helene Mansilla - 1:26:05
any specific questions on anything around the policy. Any questions? Thank you Michelle.Councillor Craig Thurling - 1:26:11
Councillor Tilding. Yeah it's just over the indexation measure. Which one is used?Because obviously depending for instance CPI, RPI there's quite a delta between
the two which could obviously undo penalisation and some residents
you can't afford it for instance or if it could be too low and it's not taking
Officer - 1:26:34
into account the wider inflation. I think that's what we're looking at currentlywhat will be the most appropriate index there's a number of BCIS building
indexes that we can apply so there are regional versions there are national
versions so we'll just be considering and discussing with the value which he
feels as the expert would be the most appropriate for our asset portfolio and
it will probably there'll be different indices that we apply to different
classes of assets obviously got like the leisure centres, council buildings but
some assets like our investment properties for example which we've
mentioned earlier they will be fully valued like a full valuation rather than
Councillor Helene Mansilla - 1:27:17
Councillor Craig Thurling - 1:27:19
Councillor Helene Mansilla - 1:27:20
in depth too. Any follow up? Yeah sorry again and does that include, would that have an impact onCouncillor Craig Thurling - 1:27:21
business rates valuation as well? I don't know if it's relevant for here but certainly you can get businessrates exemptions which then socialises that cost onto everybody else. I'm just wondering would that
be within scope here or outside? No that would be separate this is just purely about providing a valuation to
including our statement of accounts for our property.
Officer - 1:27:43
There you go, please.Councillor Helene Mansilla - 1:27:47
David Stanley, Deputy CEO - 1:27:48
So just, I suppose for clarity,so the index is applied to the assets the council has,
so it's largely for us operational assets,
so car parks, this building, the leisure centres,
the investment properties we've got, which aren't many.
It doesn't apply to anything,
to things within the district that we don't own,
So it won't apply to the way businesses work or the way residential properties work.
So it's only those assets the council is in control of and owns.
So it won't have any impact on businesses or residents.
That's completely outside the scope of what the indexation will do.
It's purely to give a valuation at a point in time of all the things the council owns.
Please.
Councillor Helene Mansilla - 1:28:39
Councillor Craig Thurling - 1:28:40
So and this is probably just my ignorance. So that valuation would that mean thenSo for instance car parks would that be the value of the actual property or the the capex of it involved with it?
So for instance you would then have to increase the
What you're charging people to park there accordingly, or is it just purely on the value of the property itself?
David Stanley, Deputy CEO - 1:29:00
It would be on the value typically the value of the land and the value of the land will bedetermined by a number of factors including
the amount of income that car park generates.
So there's a number of different ways
in which the asset can be valued,
but that in itself doesn't determine
what the charge should or shouldn't be.
Councillor Hodgkinson, in his previous guise
as cabinet member who had responsibility for car parks,
would have assessed alongside officers
the way in which the car park fee operates
to ensure the smooth flow of traffic around our
destination towns, but also recognising there is a cost providing parking in off -street locations of the council loans.
But the valuation of the land does not have a direct or even an indirect impact on those fees.
Any further questions?
Councillor Helene Mansilla - 1:29:56
Can I ask the Committee, if it is content, to approve the accounting policies? All thosein favour? Thank you. That's agreed.
14 Q3 Treasury Management Prudential Indicators
The next report presents the Quarter 3 Treasury Management Indicators in line with the CIPFAR
the Church Institute of Public Finance and Accountancy Code. Members are asked to note
the report and provide any comments to Council. I will pass it over to David to present the
report.
David Stanley, Deputy CEO - 1:30:41
Thank you, Chair. I will keep this relatively brief. This is the in -between report, so youget a number of reports on Treasury management. In the January Committee, you received the
Treasury management strategy for the financial year we are currently in. In the December
Committee, it was the mid -year, half -year report. But also in the July Committee, members
will also get the out -term for the financial year that has just ended. They are the three
reports we are mandated by the SITFA code to produce.
SITFA updated that code and said, well, in between those,
it's best practise if you gave members of your audit committee
or those charged with governance a more regular update.
This is one of those.
So the quarter one and the quarter three sort of fill the
gap between those bigger, more substantial reports.
The trouble with Treasury management is we're reporting
on the previous quarter.
However, things have moved on somewhat since the end of December, so this may be a little
bit of a history lesson as to where things were.
But what this report sets out is pretty much has the Council been compliant with its Treasury
management strategy?
So Section 3 shows you around our investment limits that the Council has at given points
in the year a varying amount of surplus cash that it seeks to invest under the principles
of security, liquidity and yield. The Treasury Management Strategy set out the investment
limits that the Council set itself. Have we complied with those? And the answer is a clear
yes.
Section 4 then moves on to the Treasury Management Prudential Indicators. Probably the least
favourite Prudential Indicator that I have to explain is the Liability Benchmark. What
What that sets out is over a longer term period, a liability benchmark is either negative or
positive.
In previous years, that liability benchmark has moved from being negative in the initial
years to being a positive, indicating the council would need to borrow externally to
finance its capital programme.
But you'll note from this update that that is now negative.
So given the changes that we've made to the way in which the waste fleet is being financed,
that would indicate that our direction of travel is that we are not going to be looking
to borrow externally and that we're able to maintain internal borrowing using our own
resources to finance that capital programme.
In terms of where we weren't compliant, that's around paragraph 4 .6, interest rate exposure.
There had been up to the end of December a number of interest rate reductions, but because
of the level of surplus cash the council was holding, we weren't compliant with the target
of only having a movement of 1 % having a particular impact.
The direction of travel now on interest rates is somewhat different.
Those interest rates have not been reduced further.
and the mood music from commentators, Bank of England, is they might need to go up before
they come back down. And you'll notice paragraph 4 .9 sets out the bank rates that are achieved
from PWLB if we needed to go and make maturity loans. A 50 -year maturity loan today is closer
to 5 .97 per cent, so you can see what's happened in the interim period with the uncertainty.
So Treasury management is in a much more uncertain position currently and probably will remain
so for the majority of the next quarter or two.
That said, with interest rates remaining above, I suppose, market expectations and might be
appreciating, we should see some beneficial impact of that on Treasury management income
during the current financial year because when we set the budget back in
February that was on the back of an expected reduction in interest rates
during the course of 2026. That seems more remote in the current climate but
things can change relatively quickly but happy to take questions on the report.
Councillor Helene Mansilla - 1:35:08
Before I give away to any questions I would like just to note thepresence of the leader of the council Mike M. Evamy and to welcome him
to the committee. Thank you.
Councillor Helene Mansilla - 1:35:23
Councillor Toole.Councillor Craig Thurling - 1:35:28
Thank you. It is a general split in terms of how far out you are looking to keep cashreserves. Is it one year, five year, 10 year, 20 year? Depending on that, determining what
investment strategy you follow and given that inflation rates were high and then they came down and then it's an expectation that they may
go up again towards the end of this year with the energy impact
Will that adjust your strategy accordingly?
Councillor Helene Mansilla - 1:35:57
David Stanley, Deputy CEO - 1:35:59
So there are a number of factors that go into I suppose our investment strategylargely based on when the council gets cash and when it might need that cash, so
So, if you pick up, I suppose, our Treasury Management Strategy, what we have is a set
of cash that would be starting to turn up now because we've issued new council tax bills.
So, people will be paying their council tax bills and business rates bills.
They're paying the whole bill, not just the district's element of that.
But you will see from table 1 on page 125, the third line from the bottom, strategic
pooled funds.
They are longer -term investments.
The Council in its cash flow forecasting and its treasury management position has placed
an investment for a long period of time.
We've held those strategic pool funds for, I think, about six or seven years, and the
intention is to continue to hold those in the current climate.
The Council has got adequate cash balances because we've made investments in much more
short -term institutions, such as the UK government through the Debt Management Office, money
market funds which are generally very short term, but we have made some other deposits
with banks that have slightly differing terms. So our cash flow forecasting that supports
our treasury management strategy will take into account the money we're getting in and
when we might need that money. So as an example, the council approved in its capital programme
for the current financial year the purchase of some new waste fleet vehicles that are
going to cost around about £6 million. Those will be ordered and it's likely that we'll
need to pay for those sometime around February, March. That's fed into our cash flow forecast
and to determine the way in which we might be able to make and place surplus cash. In
Inflation is more of an issue in terms of service cost pressures.
So if you take the example that I gave earlier of needing to purchase during the course of the year,
508 ,000 litres of diesel for our waste fleet, a 40, 50 pence premium on that diesel over what was assumed in the budget,
because we assumed a pump price of £1 .44.
It's not £1 .44, it's close to £1 .90.
that would place 220, 230 ,000 pounds of additional financial pressure on the council.
Escalate that up and look at all the other energy pressures the council's got through its leisure contract, through its own buildings.
Does that have a material impact on our investment decisions?
Do we need to keep more cash relatively short, relatively liquid to pay those bills?
So that's the type of dynamic forecasting that we'll need to do over the course of the
next few weeks as we work through the impact of those higher energy prices.
But there's also other factors that come into play.
So if those waste vehicles aren't able to be delivered this side of April next year
and that falls into another financial year, that's £6 million won't be leaving the council's
bank accounts until a later period.
Councillor Helene Mansilla - 1:39:39
Councillor Craig Thurling - 1:39:41
So, if I am reading this correctly on that table, the investment limits, you have got£3 million sitting in cash. If that interest, inflation goes up to 5 % with the interest
rates accordingly, you will be losing the best part of 150 grand a year in cash, in
Councillor Helene Mansilla - 1:39:59
Councillor Craig Thurling - 1:40:00
real cash. And then the other one is around the, you mentioned £1 .49 a litre or somethinglike that. How far out do you hedge that? Do you hedge that? Do you buy that over a
period of weeks or because if you do it over you will see cyclical trends going
up and down which is just the nature of even outside of extreme energy issues
you will always see cyclical trends so you look you you're looking to hedge
that as an average potentially rather than I don't know if you do it month ahead
day ahead or how do you do that?
David Stanley, Deputy CEO - 1:40:30
So on, I'll deal with the second part first.So on our fuel usage in the waste vehicles, we are 100 % exposed to the pump price.
We don't have a depot with a fuel bunker in.
That is currently being put through the capital programme.
So they've identified where to put the bunker.
They need to do some of the civil works to ensure that goes in and then make a decision
around whether that's diesel or HVO because part of the decision to put bunker in was
that.
We do on our wider energy purchases, particularly gas and electricity for our properties, we're
part of a consortium, Cheltenham, Cotswold, Forestedine, West Oxfordshire.
We use an energy broker and we have forward purchased a lot of our energy
needs for the first quarter of this financial year because the broker got in
contact with us about two days after the events at the end of February and said
price is going up I suggest you hedge those prices and forward buy. But that's
quite a dynamic environment so we will give them I suppose the experience we
had back in 2023, 24 with the Ukraine issue.
We were far more exposed to those energy cost pressures
because we were, in effect, spot purchasing all our energy.
We've since put in place that consortium position
with the broker where we are far more hedged on that.
But we are far more exposed on diesel prices
because there's only a certain amount of diesel
that the truck can hold.
and we don't have a bunker to put 20 ,000 litres of diesel in.
In relation to the first point, we will keep a certain amount of cash in the bank account,
but that is managed on a day -to -day basis, so we do try and sweep that cash into money
market funds.
So we do have, during the course of a given week, month, year, various payments that we
make out.
So whilst we collect the council tax in, staff need to be paid, suppliers need to be paid,
where we're collecting the council tax on behalf of our colleagues at the County Council and the
Police and Crime Commissioner. They do like to receive that cash when they do it, so we do need to
plan for having a certain amount of cash available for the shortest amount of time. So what you've
got here is a snapshot position. It won't necessarily have been the same the day before or the day after.
Any other questions?
Councillor Helene Mansilla - 1:43:10
Guest - 1:43:14
Just a quick clarification on table 1, David, if I may.Lime 1, I want to make sure I am reading the table correctly.
If I am, maybe I have misunderstood it.
The UK government, we had maximum in our strategy of zero.
But we actually invested 17 .18 million.
and yet we are compliant.
I must be misunderstanding how to read that.
That is a very good point.
I looked at that and thought the very same thing.
We have an unlimited counterparty limit.
Because the UK government is considered the least risky placement of cash, risk -free is
David Stanley, Deputy CEO - 1:44:03
probably difficult to argue, the least risky placement cash. We have an unlimited abilityto place that with the debt management office. I will come back with a fuller answer as to
why it says zero in maximum. I think that's more around the maximum level that was in
place during the preceding period, but I'm guessing and I don't think a guess is a good
answer, so I'll provide a written response.
Councillor Helene Mansilla - 1:44:27
Thank you, Chris. Any further questions?I do have a question, David.
Page 127 on table 3, long -term treasury management investments.
The 12 .5 million in the last column appears to be an amount currently tied up in investments
beyond year -end with a not fixed date.
Can I ask what it represents and why there is no date?
It doesn't seem to link to any other figures.
Thank you.
David Stanley, Deputy CEO - 1:45:12
So that refers to the long -term investments in strategic pool funds and real estate investmenttrusts.
So we haven't set an end date for those investments, but they're kept under review as part of the
Treasury Management Strategy.
So we have bought into those at the level that's indicated in the no -fix date column
12 .5 million, that will have a fluctuating capital valuation
that we've reported through the Treasury Management training
and through the Treasury Management report.
But we don't put a maturity date on that.
But there is the option with each of those investments
to make decisions to change those investments.
But we tend to keep them for a much longer period of time.
Any further questions?
Councillor Craig Thurling - 1:46:04
Councillor Helene Mansilla - 1:46:04
Councillor Craig Thurling - 1:46:06
Just on that point then, what timescales are you talking about?For instance, if you look at the long -term S &P return, 500 return is about 9 % nominal
and about 5 -7 % real return, do you target an annualised real return over say 20, 30
years?
Or is that kept under review?
and if it doesn't perform as you expect, would you then look to go to a different provider or broker?
David Stanley, Deputy CEO - 1:46:40
So there's something called SLI, security liquidity yield, which is in the SIPF guidance as to how we make investment decisions.So we've got to make sure that money is secure, it's available when we want it, and yield is the last thing that we look at.
But when we do and have made longer term investment decisions, particularly around the pooled funds,
We do look for a diversified portfolio that spreads some of that risk of some performing
better than others.
So some sectors if a property might be doing really well one particular year, it might
be doing really badly another particular year, but then we've got a diversified portfolio
with equities and other elements included in that.
We do through the Treasury management reports report that performance periodically to members
and that does raise questions as to you're still investing in this particular fund. It's
only averaging 2 .3 per cent if I'm making that number up over the last year. There's
this other one that seems to be performing much better. We're mindful that with pooled
funds past performance is not a good indicator of future performance, but there is also,
So, depending on the nature of the fund, either a cost of exiting or a timescale in exiting.
So, one of the investments we've got is in a property fund.
In order to exit that, we'd have to write to the property fund and the property fund
would have to sell an asset to give us our money back.
So, that's a process that would take a period of time if they've got a willing buyer for
that.
So, it is something that's mentioned in the Treasury Management Strategy because members
on this committee have in previous meetings and in the training session posed that very
same question you've posed, how are we ensuring that the council is getting an adequate return
on its investments. One of the issues on that is understanding the risk that the authority
is taking with those investments. So one of the bits of information that Arlene Close
provide us is to assess our rate of return against the average weighted credit risk that
we've got on those investments. And that's a better way of, I suppose, looking at the
performance. So are we performing in line with other local authorities that our Treasury
Management Advisors support when taking the same level of capital risk? But we can provide
much more information to members through that quarterly reporting that we get from our Link
close, it does require a little bit of interpretation because it's a number of dots on a graph.
But I'm sure Councillor Thirring, you're more than qualified to interpret that than others
will be.
So we're quite happy to provide that, that there is a lot of information that they provide
and we are able with Arling Close to ask them to undertake for a small fee a review of the
performance of our poor funds but mindful that there will be a cost of exiting an entrance.
Councillor Craig Thurling - 1:49:49
Yeah I think that would be useful exercise and I think the percentage return is an importantfactor and it goes along with the risk which is why I asked what sort of time scales you're
looking at. So if you invest for one day you've got a 50 -50 % chance of losing money or making
money. The longer that time scale that risk reduces accordingly. So if you're only investing
for two or three years, and I appreciate there are a lot of risk, if you're
investing for the 10, 15, 20 years, that risk, although it doesn't always go away,
it reduces. So you could afford to take more risk in your portfolio to
chase these more global funds for instance. But if you're only investing in
the short term you might consider bonds for instance, government bonds. So again
it really depends on the timescales of your investment versus the expectation
of your return. So if you're doing a medium term performance plan and you're projecting
five, ten years time of what you think your returns will be, it really depends on what
time scale you're investing for. And that's sort of the point. I'm not suggesting to go
ahead and change the whole strategy. I'm just saying we need to be mindful of the fact that
if you're looking for, say, a 6 % return on an annual basis over 15, 20 years, that is
more achievable than achieving the 6 % return over two to three years?
David Stanley, Deputy CEO - 1:51:10
Understood. I think it's probably fair. It's probably worth picking this up off line outsidethis meeting if we can sort of go through, I suppose, the process we've got to ensure
that when we're making those investment decisions, we do not pursue yield. So it's the third
part of that consideration. So we're mindful more of the opportunity cost. So for example,
the decision that was taken to enter into pooled funds was taken at a time when the
Bank of England base rate was very, very low, 0 .25, 0 .1%. So any investment the council
was making in money market funds was probably going to pay 0 .08%. It had surplus cash. It
But part of that consideration is what's the risk of capital loss?
So when we make short -term decisions in many market funds, they are very highly rated institutions
with very, very low capital loss risk, and that duration also helps with that.
When we're making decisions for the longer term, and they're generally five to 10 years,
I'm not aware of councils that will make Treasury management decisions for that period of time
other than through pension fund investments.
And then we get into the territory that the county council is in with the pension fund
because one of the things we need to do is ensure that we've got adequate liquidity for
when we need it.
And we're generally doing medium -term financial plans for a three to four -year period.
The other factor that will play into that is the aforementioned local government reorganisation.
So we currently have investments, as do all the councils in Gloucestershire.
Part of the work that is being undertaken in preparation of LGR is to understand which
council has got which investments, to understand what a unitary will be inheriting, and then
the unitary will need to set its own treasury management strategy, taking into account all
those factors about when it might need cash, how it might need to generate investment returns
but understanding that security liquidity yield principle.
Councillor Helene Mansilla - 1:53:35
Councillor Helene Mansilla - 1:53:41
Thank you. The report and comments are noted.15 2025/26 External Audit Plan
The next item presents the external audit plan for 2025 -2026. We are joined today by
our external auditors, Bishop Fleming's key audit partner, Alex Wallinck, who will
introduce the plan and take any questions. Over to you, Alex.
Officer - 1:54:08
Thank you, Chair. So I'll take the plan largely as read. I appreciate some of the memberson the committee are perhaps new, so just a brief appraisal, if you like, in terms of
the Ex -
So our role is set out in the National Audit Office's Code of Practise. It's very defined
in terms of we give an opinion on the financial statements, and we also provide the VFM commentary
as well. So there's two key aspects if you like in terms of our role. What
you've got in front of you is the audit plan for 25 -26 and that's built on some
initial planning work that we've done to date. Also thinking about obviously the
risks, looking at things like your risk register, any changes that are going on
but also backward looking in terms of what we found previously. We'll also
think about any any findings from internal audit work as well and whether
that poses issues for the work that we're actually doing. Our plan sets out
our materiality that we're working to, so we use 2 % of gross revenue expenditures
and that comes out just over a million pounds. That's fairly consistent with
other audit suppliers unless they're the bodies that are auditing a higher risk.
So for example, some of the disclaimed audits may have a lower materiality because they're perhaps
perceived to be more risky.
The significant risks are set out on page 140 onwards.
They're largely the same as previous years and from being honest,
they're largely similar to other audit surprises versus fair consistency around those significant risks.
The one I was going to pull out, which Michelle has stolen my thunder slightly in terms of
property plans and equipment, so the valuation of land and buildings, SIPF has code, so SIPF
determine what your accounts look like and they're the guidelines of actually, the Bible
I suppose for you actually producing your accounts.
They've changed for this year and they've said that going forward you can only revalue
your land and buildings every five years and use indexation in between.
The argument for that is that lots of local authorities were revaluing their full asset
portfolio every year and clearly there's a cost to that.
But the reason they did that often, I'm going to be honest, is to satisfy the external auditor
and the external auditor's regulator.
So perhaps it's our fault that this was actually happening, but CIFRA now said, no, that cannot
happen, so that's what's happening going forward.
So what we've done is we've amended our audit approach very slightly because obviously some some of your assets may be being revalued this year
And obviously we need a certain audit approach for those those that have been indexed will also have slightly different
audit approach around those as well, so we've reflected that in the audit plan and
Going over the page then on top 142
We've talked a little bit about this. So in terms of so this is around the value for money
arrangements. So as part of our Valley for Money arrangements work, we have to consider
whether there are any risks of what we call significant weakness. Significant weakness
is defined by the national audit office and that's looking at the arrangements that you've
got in place in three key areas, financial sustainability, governance and the three E's,
economy, efficiency and effectiveness. And those of you that were at the previous committee
will remember that I think it was me that came and actually presented our
previous report which said that we'd raised a significant weakness around
your governance arrangements around the procurement issues which we've already
talked about earlier in the meeting. So in terms of the five six work that we're
actually pulling together we've highlighted it at this stage as a risk
of significant weakness. It may not come to fruition but we're just saying it's a
our work this year and obviously some of the discussion that's been held earlier is actually
really helpful in terms of the arrangements being much improved going forward. On page 144
we set out our timetable which we've obviously discussed with the finance team. That's largely
about when we'll come in and do particularly the final accounts audit but also bearing in mind the
backstop date, which is the end of January next year. It's being brought forward each
year and obviously that poses pressures both for the finance team but also quite frankly
for the audit team as well. So we want to try and be quite clear about what our expectations
are and how we'll work with you because I always see audits being very much a partnership.
We don't audit you, we work with you to do that actual audit. On page 145 we've set out
audit fees and having been grilled as a pre another client early in the week the
audit fees are set by PSAA as auditors we do not set those fees so those fees
are set nationally because you have opted into PSAA's framework
contract around procuring external auditor however the fee variations if
there are any which we'll bring back to you obviously we will discuss with the
finance team as well. They may be for additional work that we need to actually do. At the moment
we have a TV scene there because it is likely from what we have just said we will have to
follow up the procurement issue and that will have an additional fee potentially as a result
of that. As I say, we will discuss that with the finance team and it does go to PSAA for
final approval as well. The only other thing I was just going to mention at the back of
the plan on page 149 onwards. We have put in a little bit of a sector update. It is
probably stuff you are fully aware of but we thought it would be helpful to pull it
together for yourself. Happy to take any questions, Chair.
Councillor Helene Mansilla - 2:00:13
Thank you, Alex. Any questions?Thank you. The plan is not it.
16 Proposal to Appoint New Member of the Standards Hearings Sub-Committee
This item, item 16, proposes to appoint a new member of the Standards Hearing Subcommittee.
This item proposes the appointment of Councillor Bridges to the Standards Hearing Subcommittee.
Any comments?
Councillor Bridges.
Councillor Nick Bridges - 2:00:47
With the proviso that it's up till May of this year.That's correct, Councillor Bridges.
Councillor Helene Mansilla - 2:00:53
Can I ask the committee if it is content with the appointment?All those in favour?
Councillor Paul Hodgkinson - 2:01:08
Sorry, can I just clarify, May this year is literally three weeks away, isn't it?Yeah, and we have an annual meeting.
Why are we doing that then for just three weeks?
Councillor Helene Mansilla - 2:01:16
Councillor Helene Mansilla - 2:01:22
Councillor Helene Mansilla - 2:01:29
Angela Claridge - 2:01:33
come through all the time there's always a possibility but I think you're off thehook for the next three weeks if I'm honest but thank you for putting yourself
Councillor Helene Mansilla - 2:01:54
forward anyway. If we can proceed with the vote please all those in favour17 Proposal to Change Audit & Governance Committee date
Councillor Helene Mansilla - 2:02:24
Thank you to all members, officers and members of the public for your time and contributionstoday and safe journeys home.
This meeting is now closed.
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