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Audit & Governance Committee
Monday, 27th July 2026 at 4:00pm

 
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  1. Councillor Helene Mansilla
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  1. Councillor Craig Thurling
  2. Tyler Jardine, Officer
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  1. David Stanley, Deputy CEO
  2. Councillor Helene Mansilla
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  5. Councillor Paul Hodgkinson
  6. David Stanley, Deputy CEO
  7. Councillor Helene Mansilla
  8. Councillor Jon Wareing
  9. David Stanley, Deputy CEO
  10. Councillor Jon Wareing
  11. David Stanley, Deputy CEO
  12. Councillor Helene Mansilla
  13. Councillor Craig Thurling
  14. Councillor Helene Mansilla
  15. David Stanley, Deputy CEO
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  19. Councillor Craig Thurling
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  23. Councillor Claire Bloomer
  24. Councillor Helene Mansilla
  25. David Stanley, Deputy CEO
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  27. Councillor Craig Thurling
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Councillor Helene Mansilla - 0:00:00
Welcome to this meeting of the Audit and Governance Committee.
I welcome members, officers and anyone joining us here in the chamber or online.
This meeting has been streamed live and all the papers are available on the Council website.
There is a three -hour limit.
If necessary, members may vote to extend it by up to one further hour.
Today, we have a full agenda, but I intend to finish within two and a half hours, so
I ask everyone to try to keep questions and answers focused.
I can see that there is no public present, so we will move on to the next item on the
agenda.

1 Apologies

Let's begin with the apologies for absence.
Councillor Helene Mansilla - 0:00:56
Thank you, Chair.
We have had apologies from Councillor Nick Bridges and independent member Nick Cragston.
Thank you.
Apologies noted.

2 Substitute Members

Any substitutes?
Yes, Councillor Clare Bluma is present substituting for Councillor Nick Bridges.
Thank you.
Are there any declarations of interest?

3 Declarations of Interest

Thank you.
None noted.

4 Minutes

We now have a set of minutes from the previous meeting to approve.
I will go page by page.
Please do interrupt me if you have any corrections or comments on them.
Page 1.
Page 2.
3.
Page 4.
Page 5.
I have noticed something.
On item 73, the strategic risk register was reviewed and the risk and opportunity management
policy approved.
Also, on page 5 and 6, item 74, so distinguished between the progress report being noted and
the internal audit plan and charted being approved.
Page 7, Page 8, 9, 10, 11.
I have on page 11, item 78, to record that the external audit plan was noted and the
attendance record should also be completed.
Also on page 11, item 80, should be deleted.
If members recall the committee agreed the 27th July under item 70 and no separate vote
was took place at the end of the meeting.
Councillor Turling.
Councillor Craig Thurling - 0:03:39
Yeah, so on the portal where all these documents are stored, the minutes is from the one in
January rather than the one in May, April, May.
I've just opened it up and it's 27th of January.
Tyler Jardine, Officer - 0:04:04
I'll circulate a copy of the correct minutes to members of the committee if that's alright.
.
Councillor Helene Mansilla - 0:04:48
Can members approve the minutes as an accurate record?
In that case, we will move on to the next item.

5 Public Questions

I can see that there is no public, so no public questions. So, none noted. Are there any member

6 Member Questions

7 Strategic Risk Register

questions? Thank you. None noted. Next item, item 7. Item 7 presents the Strategic Risk
register following his previous review in April 2026. Members are asked to review the
risk and the mitigation measures. I invite the Deputy Chief Executive and Section 151
Officer David N. Stanley to introduce the report and take us through the key points.
David Stanley, Deputy CEO - 0:05:55
Thank you, Chair. I'll do a relatively short introduction but leave time for members to
ask any questions they have on the report.
So this was considered by Cabinet at their meeting
earlier this month, and the strategic risk register is
received on a quarterly or four times a year basis,
either by Cabinet or this committee, with this
committee also receiving the risk management policy
on an annual basis to review.
The review process in terms of strategic risks is
embedded within the council.
So there is a regular, i .e.
every two months review by corporate leadership team and
the extended management team as a strategic risk register
including whether the risks have been adequately defined,
adequately scored, whether the mitigation measures and
follow -on actions need to be updated.
And those scores are then taken through the extended management
team with the opportunity for the extended management team
to cheque and challenge that, but also for escalation as
appropriate from individual service risk registers for risks
that they feel as a service need to be included on the
strategic risk register.
So paragraph 3 .3 of the report, which is on page 22, and Annex A,
which is on pages 25 and 29, contains sort of either a
summary or the detailed run -through of the
strategic risks.
In red, so the highest scoring risks are local plan,
cyber security, health and safety compliance, and our
preparedness for a civil contingency.
There's no significant or material change in the risk
score since this was last presented to this committee.
A high AMBA, it's a scoring 12, is financial sustainability,
with the direction of travel indicated in Annex A,
with the blue arrows going up, down, or sideways,
depending which direction it's going,
to make it easier to see where those changes have taken place.
Annex A also updates on the controls, mitigations,
and any follow -on actions, and that's shown in red,
or for those reading in black and white, black probably,
or a shade of black.
So it works best on screen where you can see the red,
so we've colour coded where those changes are coming
through, but happy for any questions that members may have
on the risk register.
Thank you, David.
Just one second.
Councillor Helene Mansilla - 0:08:37
Before I bring members in, I have two brief points.
On civil contingency and major events, RAF FERF has since been publicly identified as
a legitimate target by Iran.
Have CDC and the Gloucestershire Local Resilience Forum reviewed the development?
Has it changed any local contingency arrangements?
and when will members receive the written response promised in April 2026?
That's the first point.
My second point, very quickly, is on the financial stability risk.
They showing at 12.
The pack shows 1 .489 million gaps in 2027 -28 after planned savings.
But in light of the 889 ,000 out -term surplus for 2025 -26 and the AGR recent decision, are
forecast gap and the risk score still current.
Thank you.
David Stanley, Deputy CEO - 0:09:59
So if I may, Chair, just in terms of preparedness for civil contingency and the recent statement
by Iran that RFF would be a legitimate target, my expectation, having been on leave for last
week is that this would be a multi -agency response led by
RAF at the U .S. Air Force with significant input from central
government of which the Gloucestershire LRF would also
have a part in.
So I'm not aware of whether that declaration has triggered
any change.
I shall look into that and find out, but I would be surprised if
there would be an individual council response because it is
part of a multi -agency position.
In respect to the discussion that was had in April, I think
there was communications provided to members in relation
to the Fairford, RFF points that were raised that reiterated
some of those points I've just made around it being a multi -
agency response led by RFF.
So I will recirculate that email that went around to all members
because it was picked up as a point of significant concern
that the committee had.
And in terms of the financial sustainability risk, so at the
time this was drafted, I saw no change to that forecast gap.
So despite, in spite of the positive out -term position,
we are collectively as a senior leadership team with finance and
EMT, reviewing I suppose what the longer term implications of
that out -term position was.
Some of that will continue to provide a positive impact
on the current year.
For example, car park fees in the current quarter
are ahead of budget.
So some of that benefit that accrued in the out term
will carry through.
But in the absence of any changed position
in terms of government support,
that gap remains as I see it
because there are other pressures
that will detract from that positive position. So fuel prices, energy prices, general inflation
has been higher. That's going to put more pressure on costs during the course of this
financial year. So I still see the score as being appropriate, but no doubt that will
be reviewed in early September as we prepare for Cabinet the budget strategy for 27 -28
and an update to the medium -term financial strategy position.
Councillor Helene Mansilla - 0:12:37
Councillor Hopkinson and Wayne after.
Councillor Paul Hodgkinson - 0:12:41
Yeah, I mean, actually you asked part of the question which I was going to ask about Fair
for Great Minds Think Alike. I mean, thank you for your answer David. I think the issue
still for me is given that this is a public forum and, you know, at some point this will
get out to the public and the public can access this.
It is very worrying what has happened around Fairford
recently in terms of what Iran has said.
And in fact, I was reading a report in the media where a few
months ago Iran actually fired a missile to Diego Garcia,
which is actually apparently the UK is closer to Iran than
Diego Garcia.
So I'm not saying that that's going to happen but it is a concern that it could
happen and it's such a concern that I think I want to know more about what
this council is going to do with its partners. You've talked about
contingencies but what would happen? What would happen if a missile was was
launched? If a missile got through somewhere what would happen in terms of
response. You've talked about a multi -agency response but what would
that actually look like? I think the public do actually want to have some
answers to this because I think it's really worrying quite honestly. And so even
if you can't answer it today David I think this committee would be great to
have something sent to us to say that the various authorities are on this. This
council is will do its bit and that we can be reassured at least that there is
their plan in place should that awful thing happen.
David Stanley, Deputy CEO - 0:14:30
Just in terms of a response I've had come into my team's chat,
helpfully from Nicky, who's forwarded me some of the
comments made by South Cotswolds MP, Ros Savage,
which members may be aware of.
And that provides some reassurance as to how Ros as the
MP for that area is raising those concerns and what the
sponsors be. I'm happy to circulate that after the meeting or during the meeting
to members of this committee but what that says is RFF it is home to the
headquarters of the 501st combat support wing in a statement published by the
Islamic Revolutionary Guard on Thursday the 23rd they said RFF it may be a
legitimate target and Dr. Savage has said she received an update from
Gloucestershire Constabulary on Friday and she said the force confirmed they're
working closely with the Ministry of Defence Police responsible for security
of the RFF base and so on. So this is an emerging property position. I'll get
an update in terms of what the LRF position is and what is planned in terms
of communications. We are part of the warning and informing groups, a part of
the any response. Officers here that part of the comms team will do that piece of
work to ensure that members and members of the public are fully informed of
what's going on should there be any imminent danger or threat to that
particular site. But I take points made by Councillor Hodgkinson that given that
heightened security risk given that what was said by Iran that we need to provide
that extra reassurance.
Councillor Helene Mansilla - 0:16:13
Councillor Jon Wareing - 0:16:15
Councillor WYNDHAM. Thank you, Chair. Given the Strategic Risk
Register identifies staff capacity, recruitment and retention, service standards and corporate
plan delivery as separate amber risks, all of which are likely to be influenced by LGR,
what assumptions underpin the Corporate Leadership Team's assessment that taken together these
do not constitute a materially greater risk to maintaining
services for residents.
David Stanley, Deputy CEO - 0:16:46
So in terms of the different risks, what we're looking at is
assessing what the nature of the risk is, but also what the
mitigation measures are.
And broadly speaking, when I look at the risk there is to
service delivery, that may involve slightly different
mitigation measures, so for example,
ensuring that the UBCO can provide a resilient
and robust waste and recycling collection service
puts more emphasis on UBCO, but may involve
officers from the council to ensure
that performance is being met.
LGR will ultimately affect the council's ability
to deliver aspects of service continuity
if the individual concerned is providing both support to LGR
and support to business as usual service delivery.
What we've been discussing as a corporate leadership team is
understanding what mitigations can we put in place,
what protection can we put around those service areas.
So, for example, we've got the established building capacity
reserve, which is all about having a pot of money to address
concerns there are in the ability to deliver those
services, but there is also a separate consideration as part
of LGR is, is there a requirement to backfill
individuals because they're spending more of their day -to -
day time supporting LGR.
So the mitigation may be broadly similar in terms of provide some
additional resource, i .e., take on extra agency staff, or have
conversations with cabinet in terms of the deliverability of
some of the corporate priorities and understanding through the
service performance reporting framework whether things are
drifting away from target.
So using that mechanism to report through.
Ultimately you could look at this and say the mitigation to
service delivery pressures and LGR pressures is the
availability of staff and the availability of money to pay
for staff.
So part of that is looking at that through the financial
sustainability lens and if you look at the out turn report that was presented
to cabinet earlier in the month that was taking the surplus on the general fund
from the out turn and pushing that entirely into the building capacity
reserve to mitigate some of that risk we've got because as we get closer and
closer to the 31st of March 2028 staff may have a view that their future isn't
in a unitary authority in Gloucestershire,
they'd sooner take the more certain future
in an already established unitary authority.
How do we keep planners,
how do we keep valuable members of staff?
Ultimately, what we've got is both financial resource
but also, I think a couple of cabinets ago,
there was the retention policy that was taken through
and approved by cabinet that provided some additional
manoeuvrability for the chief executive
to vary the pay of individuals where there was a significant
risk of them leaving the authority.
So there is within the wider retention policy a mechanism
for making sure we recruit and retain suitably qualified
experienced staff to deliver services.
Also through the building capacity reserve,
a funding mechanism to ensure that we can keep services going,
we can backfill where those pressures are highest, but clearly that will largely depend
on the availability of that resource and the availability of people, because we can put
as much money into things as we may want to, but if there isn't the resource out there,
then we're chasing a market that doesn't exist. So we've got to have one eye on that and trying
to find planners at the moment. We can pay planners twice as much money, but if there's
a national shortage of planners, that's where we'll be.
Councillor Jon Wareing - 0:20:55
Thank you, David. Given the potential for particularly that circumstance that you can't
actually recruit enough people for whatever reason, has the council identified which activities
would be consciously reduced, deferred or reprioritised in order to protect critical
statutory services?
David Stanley, Deputy CEO - 0:21:19
There's a piece of work that's ongoing with Cabinet to ensure that we can deliver on the
Cabinet's priorities as set out in the corporate plan, but also we are reviewing our ability
to deliver some of those priorities within the timescale that's being looked at.
So as an example, as a hypothetical example, if the Council had a priority to deliver 500
homes by the end of 2028, that might be something that's more
difficult to achieve given the time scale and the resource
requirement than it would be maintaining a waste and
recycling service through partnership with UBCO.
So we are, through our regular reviews as part of CLT,
of service performance and service priorities,
understanding what is it that would need to change to keep
those critical services, those statutory services running.
Part of that is that ongoing review.
So at this point in time, I couldn't say to members of this
committee, yes, there is a piece of paper that exists that has
set out if this happens, then we do this, this and this.
So it will be more reactive than proactive.
But one of the things we are working with Cabinet on is
setting out plan on a page style, what is it we've got to
achieve between now and the 31st of March, 2028?
What are those critical milestones in terms of BAU?
Where are those pinch points going to be?
And starting to map that out and understand, well,
if this doesn't happen by such and such date,
an example of a local plan would be if we couldn't have
published the local plan detail by the back end of last week,
would have been in a more difficult situation with the
Reg 19 consultation, is understanding how the flow of
those decisions will be.
So it's going to be more dynamic and hopefully by later in this
month when we've had that session with Cabinet, we'll be
in a position to start feeding that through more widely to
members to set out what that starts to look like and where
members might then understand where are we going to see some
of those trade -offs.
Because inevitably, I think over the course of the next 20 -odd months,
there will be trade -offs in terms of what we can do.
Please.
Councillor Helene Mansilla - 0:23:45
Councillor Craig Thurling - 0:23:47
Yeah, just a point of clarification for myself.
On this risk register, are the risks for a risk of it likely happening
or the risk of it sort of being an impact?
Because if it was the latter, a lot of the red risks have not reduced by the looks of it.
And I'm just wondering what sort of time scales would you expect
for those risks to be reduced over the next months or year?
And then the second question, if I may, is going back to the
civil contingencies risk, which is quite a large risk given the
issues that, potential risks at Fairford and also the issues we
had with the water actually in the Simon Cessna last week.
There was a lot of confusion around where people go to
collect water.
Now, and that's in a town such as Simon Cessna.
If you're in a rural village in each ward, where do the people
go and not only that, people might be vulnerable, they might not have access to
the internet, social media etc. Would it not be worthwhile the council producing
literature on a ward basis and say what if in this happens is a ward strategy
you go to this area or if there's a food outage you go to this area or X Y and Z
risks because I think at the moment a lot of it is confusion and I'm just
thinking if I go to one of my villages which is extremely rural where will they
go? I wouldn't be able to tell them where to go so just a bit of a request really.
Councillor Helene Mansilla - 0:25:07
And in just one second David, it's not only where did they go, it's some
residents cannot literally go anywhere so the water needs to be taken to them.
David Stanley, Deputy CEO - 0:25:24
Thank you chair. Just and I'm aware that Cheryl from May want to come in on
particular aspect of the emergency planning response.
But just to deal with the score on the risk, so we use the five
by five matrix which is set out in the report.
And what that looks like is the likelihood, so it ranges from
one being improbable, so it's not occurred before, has not
occurred at similar organisations, extremely unlikely
to five, almost certain, has occurred in the last two years,
has occurred at many similar organisations,
more than 80 % chance.
That's the likelihood.
And the impact is essentially both in terms of
reputational impact, operational impact,
risk to life, financial impact,
and is that insignificant all the way up to extreme.
So the score is a combination of one times the other,
and there are red risks.
So it doesn't necessarily mean red in terms of the acceptability of that risk and what's
missing from the risk register is the target risk score.
So where would the Council want to see that risk score and in what period of time?
So if I take the financial sustainability risk, because it's one I can talk about more
readily, that's been assessed as an initial risk as a 16, as a red, if the Council was
not able to be financially sustainable would have a massive impact on its
ability to deliver services to residents, be of significant reputational risk.
The council would be setting an illegal budget that puts it into Section 114
territory and so on, so quite a significant risk. That's then reduced
down through the residual scoring by looking at what mitigations are in place
to a 12. So it's a major impact still but it's moved from being probable to
So with a one and a half million pound funding gap for next year, the ability to balance
the budget at the moment is entirely reliant on the council utilising its reserves or finding
savings and cost reductions over the next few months to get to that balanced position.
It's unlikely to come from additional funding from the government.
That's the assumption I'm making in that judgement.
Where the Council would want to be is when you look at the follow -on actions, what that
says is for 27 -28, reviewing the out -term positions, was there any benefit from last
year's out -term that carries through into this year and into subsequent years, and what
other actions have we taken to start engagement either with members or with partner agencies
around that budget gap expectation. So what this doesn't show is where would
the council be comfortable with that risk being but what you see to the
column to the right of the follow -on action is the risk acceptance level we
want to reduce that risk. So getting it down from a 12 is where we want it to go
but at this point I couldn't say with any certainty to members what that
target risk score.
So do I want it as a four, a six, an eight?
And what's realistic to achieve?
Because there's certain things that are in our control.
There are certain things that are completely outside
our control.
So we have no control over some of the inflationary pressures.
We don't control the rate of inflation.
We can control how much of that we want to be exposed to.
So one of the mitigation measures here is understanding,
particularly on fuel prices, we buy 508 ,000 litres
of fuel, be it HVO or diesel, a year, pretty much on the spot market because the drivers
of the vehicles turn up at the local co -op or Tesco's site and fill up their vehicles
with whatever the price of diesel is at the time. By putting in a fuel bunker that can
hold 20 ,000 litres, the council will be able to, through UBCO, bulk buy, forward purchase
by either HVO or diesel to get a better price.
And one of the things we can do then is look at other ways we
can manage that fuel price risk by the budgeting system.
So at the moment the budget has been set for the current year
based on a pump price.
I've allowed within the contingency budget a degree of
manoeuvrability of that.
Unfortunately that degree of manoeuvrability was judged prior
of the 28th of February, so didn't include some of those
challenges that have come with the Iran war and what's happened
with fuel prices since then.
But that's essentially what the budget setting process will do,
is look to reduce that risk, but it's how much you put into your
contingency budget, how much you want to reflect some of those
costs going forward, because we can all say, well,
we can set a balanced budget by only allowing for 59 pence
for diesel.
That's unrealistic.
We're not going to be in that position.
So it's around the acceptability of the risk.
But overall, with this particular risk on financial
sustainability, the ability to set a balanced budget will be
dependent on us being able to identify and deliver on further
savings efficiencies, cost reductions,
to take some of the advantage from prior year additional
income underspends and so on, being clear with our delivery
partners such as Publica, UBCO, Freedom Leisure, what our
expectations are, and also utilising our funding in the
most economically advantageous way, be that utilising some
reserves to mitigate some of that in -year risk.
So I can understand that we're not showing when or how that
would do, but you would see that through the risk scoring each
quarter, but we're not, I'm not in this table setting out what
the target risk score is, but it is a useful question to ask. Are we tolerating a 12, no,
we want to reduce that down. So that column would say if we were happy with that risk
and it was scored a 6 and we were tolerating it, there would be no further mitigation measures
to follow through on. But I believe Cheryl might want to say something about your wider
point on emergency planning.
Lucy Young, Cheryl.
Councillor Helene Mansilla - 0:31:51
Thank you chair. I was just going to respond to your question about last week and the water
Officer - 0:31:57
outage in Syrinsister because I was the duty officer for the council that week. I had a
phone call at seven o 'clock to say that the houses there are about up to 6 ,000 properties
that have no water. It ranged from up to Bournton down to South Cerny and across to Kemble.
Thames water lead on this. It's not for the council to lead on. And what the chap advised
at that point in time was that bottled water was going to be distributed in the area, it
probably wouldn't be here until about 9 o 'clock but he asked if we would be able to help with
any distribution which some officers said they would. Do we want officers to go out
at 9 o 'clock at night and deliver water? Do we want to get people out of bed to answer
the door? The houses that what the chap from Thames Water said was there were 200 tier
properties so these were the critically dependent properties where the bottled
water would be distributed to and 900 tier twos so again these people are
likely to be in bed at that time of night we don't want to go and disturb
them Thames water were then going to set up stations at Tesco in Sire ancestor
and two other places throughout the district of which they would have
advertised and water was available to anyone that wants to pick it up.
Councillor Helene Mansilla - 0:33:15
I don't want it to sound like I was being critical.
Councillor Craig Thurling - 0:33:17
I appreciate all the hard work that was going on.
It was more of a case that in the future, in a town like Sion says,
I imagine there's quite good places where you could go and have these designated collections.
It's more also a case where if you've got two or three rural villages
and they're quite small, maybe 30 or 40 houses in a village,
where would they go? What would they do?
I appreciate it's Thames water but people wouldn't be thinking at that time, well who
do I contact?
And if they already had the information to say in this village at a pre -designated place
if there was a water or food issues or whatever, you could go to this point.
That's what I think people would be wanting reassurance for.
Officer - 0:33:58
What happened last week, because the majority of it was Simon Sester, the local council
of Simon Sester were advised by the chief executive, so I guess if it happened in a
or a rural area, you as members would receive
that phone call to say, this has happened,
this is what Tameswater are going to do,
or this is what we will do as a council for you.
And do you want, can you get that message out
to your residents?
Councillor Craig Thurling - 0:34:19
Again, thank you for that.
And I would be clustering all over social media.
However, there's a lot of vulnerable people,
a lot of elderly people, a lot of people on their own
who do not access social media or internet or whatever.
And these people don't speak to people for like weeks
on end as it is which is a separate issue but they won't be I can't go around
two and a half thousand houses asking them you need to go here you need to go
there if they already had a leaflet to say in this scenario in a civil
contingency case this is what you do and I think it's more around the reassurance
rather than sort of saying well if this happens like speak to your district
council because best way in the world you're not going to get around everybody
he was affected by this I think. So I think it's more of a more of a council
point rather than a specific location issue. I think it's more strategic than
Councillor Helene Mansilla - 0:35:09
that I think. Councillor Rumer. Yeah thank you I think it's quite a challenge. I was
Councillor Claire Bloomer - 0:35:16
very much involved with the shortage of water last week and I must say Thames
Water did not give any updates whatsoever. I was on site at 8 a .m. at
They're not actually informed anywhere in this.
Craig has just spoken about, you know,
people that have not got access to that.
I think one of the points that the councils could work with
is maybe some contingency planning with parish and towns.
I know that Syrins has to town council
or approach to supply land
or be able to use the Kings Hill skate park
as another place for distribution.
I do think it's very challenging
for the council to be involved,
but I must praise the council
because when we had COVID I know that officers produced lists for those most vulnerable in our
wards that we were as members able to contact so maybe we could look at being able to do that for
Councillor Helene Mansilla - 0:36:11
David Stanley, Deputy CEO - 0:36:13
a contingency plan. David. Something we'll take away I think there's a balance between
providing assurance to members that there are contingency plans in place for major
civil emergencies but also the issue around particular outages of let's say
power water utilities in very local areas wouldn't necessarily be something
that the council would have a detailed plan for. What's important is
communicating whatever that is with whoever it needs to be communicated with
in the most appropriate manner. So there is a warning and informing
communications group.
So I'll pick that up with Matt Abbott in terms of how are they
through that making sure that those residents are affected or
aware of who the lead body is.
In the issue of Thames Water, we've got to be mindful that
Thames Water have a responsibility to do
certain things.
We have a responsibility to do certain things.
And whilst we may want to encourage Thames Water to do it
in a particular way, that's something we need to think about
because ultimately there will be vulnerable residents
that we'll all be aware of that might need
some extra support that Thames Water won't be aware of.
I think Cheryl's indicating that she wants to add
some additional comments to that.
Officer - 0:37:36
I was gonna say, it's worth as well encouraging
where you know you have vulnerable residents
to make sure they are registering with things like
the electricity, the gas, the water,
because then they do get the priority because they will have the list and they
have that straightaway on that occasion to make sure the water was getting
distributed to those vulnerable residents so if you are aware then make
sure that those people are registering because then it takes that loop out and
they're going straight to those individuals.
Councillor Craig Thurling - 0:38:08
Councillor Turdling. I think that's a great idea but the only caveat with that
is for instance my own mum she recently had a stroke and I signed up to the
Thames Water priority list and it's quite a convoluted process. She initially
trying to do it she was getting confused so I came in and did it. So I was able to do it
for her there's a lot of vulnerable people out there who are who haven't got
somebody to do it for them whether it's water, energy, whatever and I think there
may be a duty of care not necessarily district council or council council but
it's a cross agency approach that I think these people need to be updated and
maybe contacted via a leaflet and say do you need help and there's a free post on
there to say yes I need help please help me and then somebody from the council
can then contact them to help enable them to register these priority services.
I think there's a will here that people want to help but we're not
reaching the people that need the help and that's my concern.
Any further questions?
Councillor Helene Mansilla - 0:39:11
Thank you, Chair.
Guest - 0:39:16
At the last meeting when we discussed the strategic risk register, we had some discussion
around the red rated health and safety risk.
My interpretation of the outcome of that discussion was that the red represented a compliance
concern rather than a specific safety concern to any staff,
members or people using services.
Having re -reviewed the strategic risk register, I still have some
questions around how it's documented in the risk register
itself, I think might represent some risk to the organisation.
If you look on page 26, it's read before mitigation and read
after mitigation on the health and safety risk.
And whilst the header of the risk is compliance, the text
below that specifically says there's a risk, talks about a
risk of death or injury to service users or staff.
So I think the intention is that it's a red compliance risk.
But I think it could be misunderstood as a red safety
risk, and I think that represents some risk in itself.
David Stanley, Deputy CEO - 0:40:28
That's a valid point and looking at that risk what this has been around is that the council
if there was a major incident of Legionella wouldn't be able to provide suitably adequate
documentation of when those tests were done.
That was an outstanding action from an internal audit report that I believe has now been closed
of and where we are there's a regular quarterly health and safety board that
meets the documents through all those near misses major incidents and that
testing compliance framework that we need to have in place. But I suppose that
risk will reduce once the proof is there. So that has only just been closed off
from an internal audit point of view. I would expect as we move through the rest
of the year that risk will reduce because we are able then in light of some
inspection that was undertaken at West Oxfordshire by the HSE around asbestos,
before they come to us we're learning the lessons from what that inspection
around their asbestos policies were and trying to get that in place so that it's
less about risk of death and risk of being able to demonstrate compliance and
Guest - 0:41:42
maybe the wording needs to be timed up. Absolutely, on the wording I might
suggest recording a date at which you'd expect their risk to be reduced. I would
just hate for there to be an accident or for somebody to suffer some ill health and as
part of an HSE investigation, you look back at this and the accusation could be that the
management decided they didn't want to further mitigate that risk.
Councillor Wilkins.
Councillor Helene Mansilla - 0:42:08
Councillor Len Wilkins - 0:42:10
Thank you, Chair. Just a minor bit of nit -picking. On the bottom of page 10, we've got a risk
saw the six green and yet I understood six was amber and the same item is the
second item sorry the same thing is the second item on page 13 should it be six
Councillor Helene Mansilla - 0:42:34
five plus a coin. David. That's probably my fault when you look at the when you
David Stanley, Deputy CEO - 0:42:40
the table of colours on page 22 of the PACS. We've scored previously risks up to eight
as green, the risks above eight below 15 as red, but that wasn't in accordance with the
risk position that we've taken of cautious. So I have changed the picture under paragraph
3 .1 but not amended the conditional formatting on the spreadsheet that allocates the colours.
So that's my mistake and I shall correct that in the published version.
Any further questions?
Councillor Helene Mansilla - 0:43:26
Councillor Helene Mansilla - 0:43:53
This is regarding the RAF Fair Four.
I am liaising with the Gloucestershire Police and they have informed me that additional
police activity in Fofor area.
Police have increased high visibility patrols and residents may have noticed an increase
in police presence with dedicated officers patrols in these areas to offer reassurance
and identify any concerns.
At present, I am informed that there are no specific issues or concerns that the local
community needs to be aware.
However, any suspicious activities should be reported through the 101 or online reporting
channels.
And obviously, if there is an emergency, always call 999.
In addition, I know that RAF Fairfour and USAF are also undertaking their own community
engagement at CBT as they are responsible for the site.
Thank you.
Councillor Helene Mansilla - 0:45:32
Thank you.
Now moving to item number 8.

8 Annual Governance Statement (With Information Governance Update & Senior Information Risk Owner (SIRO) Annual Highlight Report 2025/26)

This is one of the committee's main annual assurance report.
Members are asked to approve.
I agree on approve.
I know the recommendation currently says endorsed rather than approve.
the 2025 -26 Annual Governance Statement and the 2026 -27 Action Plan, and to note the zero
report.
I invite David and Isangela online, maybe she wants to come in, the Director of Governance
and Development, Angela Carrij, to present the report.
Thank you.
would you be available to...
David Stanley, Deputy CEO - 0:46:25
Thank you, Chair. I will do a very short introduction and explain why, I suppose, in the published papers the word endorse was used.
So, the annual governance statement is signed by the Chief Executive and the Leader of the Council.
Now, if the leader of the council and the chief executive had signed that off and that
signed copy was presented to you in these papers, the ability for this committee then
to challenge or ask for clarification on some aspects of the AGS might be a bit more limited
if those two individuals had signed it off and indicated that they were content, that
the governance arrangements were fit for purpose and adequate.
So that's why the word endorsed was used, but the word approved
was used in the same report this time last year.
So happy that for purposes of decision making of this
committee that that is amended to approve.
What the annual governance statement does do is it's a
backward looking review of the arrangements that are in place
against our local code of corporate governance that was last approved by this committee back
in September of last year, against the principles A through to G that are spelt out in quite
significant detail in the annex to the report. The annual governance statement does conclude
that the arrangements for the council are fit for purpose and will continue to be reviewed
during the course of the year as events may dictate
alongside the local code of corporate governance
which will be coming to this committee
for review in October.
Paragraph 3 .5 on page 35 and pages 77 to 78 of the pack
contain the action plan for 26, 27.
There are three areas of focus, what I would call significant
governance issues that we're bringing to your attention that
an action plan is needed to address.
First is around financial sustainability,
and I don't think there will be significant debate on whether
that should be included or not.
And that is around identifying and implementing an efficiency
and savings programme to close that budget gap that we've been
talking about and also to ensure that we're leaving
the council in a positive financial position
ahead of the council not existing on 31st of March, 2028
and the unitary council for Gloucestershire
starting on the 1st of April, 2028.
Now you can tell from the drafting this was written
before the decision was taken.
Business continuity, so this is a carryover action.
So in our assessment as a corporate leadership team
and in consultation with the leader,
we didn't feel that there had been significant progress
during the course of the previous year
and as you'll see from the strategic risk register
that we were content that that wasn't
a significant governance issue.
So that's a carry forward item
and you'll note that the carry forward item
is around completing the business impact assessment
processes, having the business continuity plans in place
and testing those out.
Those have been, we've had the first set through
corporate leadership team in terms of the draught business
continuity plans, but we weren't in a position where
this was being put in front of members and forming
part statement accounts to say actually those actions
from last year were largely complete.
It was still a carry over item.
The third item is on procurement.
So that is in relation to specific actions that were
in the Procurement Action Plan around review of purchase order to pay implementation that
went live in July. But also given the new corporate act around failure to prevent fraud
as defined in the Economic Crime and Transparency Act 2023, there is a need to ensure that all
officers and staff have received their mandatory training on this additional measure to ensure
that we're mitigating that potential risk of failure to prevent forward as a corporate
offence. Also included as an annex to the annual governance statement is the Senior
Information Risk Officer, the CIROs annual report, and that was following the review
earlier in the previous civic year of that being included as an AGS item. And in terms
of next steps, comfortable with feedback coming through to this committee and for
us to take that back to the Leader and Chief Executive. Is there any issues that
you feel need to be tightened or addressed before that is formally signed
by the Leader and Chief Exec and then incorporated into the annual statement
of council that was subject to external audit. But happy to take questions that
members may have.
Councillor Helene Mansilla - 0:51:43
Angela, can you hear me? Yes, Chair, I can. Good evening, members.
Would you like to add something to David's comment on this item?
Just thank you, Chair. Just a couple of items, if I may. So as David said, I'll just touch
on the CSIRO, the Senior Information Risk Officer item. As David's already mentioned,
it's a nice to have. It's not something that we are obliged to do, but it's absolutely
best practise within a local authority to have an annual CSIRO report. At this meeting, I think it
was in January this year, the committee agreed it would make sense because of the nature of the
areas that it covers to incorporate it as an annex to the annual governance statement. And it's
essentially there to provide independent assurance and oversight that as committee members you can be
reassured that we're looking at those items around information governance,
cyber security, data protection and information risk.
And you'll also notice, if I may, that unlike the AGS,
which is predominantly backward looking,
but with some forward looking recommendations,
the CIRA report does look back, but also looks forward.
So happy to take any questions, Chair.
Thank you.
Thank you, Angela.
Councillor Helene Mansilla - 0:52:58
I note the reasonable assurance opinion
given by the head of audit, Lucy.
and the improvements reported in information governance.
I understand that there has been a significant amount of collaborative work
and peer review by officers and the corporate leadership team.
Any questions from members, please?
Councillor Trueling.
Councillor Helene Mansilla - 0:53:28
Yes, more of a logic question, really.
Councillor Craig Thurling - 0:53:32
So the governance procedures are fit for purpose,
but then it's also then mentioned that there's three areas where there's action
plans in place. Does one not contradict the other? If you fit for purpose you
wouldn't necessarily need action plans for three quite important areas or
is it just to...am I missing something?
David Stanley, Deputy CEO - 0:53:59
In terms of the assessment, it's a bit like an overarching assessment of the governance
arrangements, they're fit for purpose, but there is a focus on three particular areas
where the council needs to strengthen the governance arrangements in relation to particularly
around procurement and business continuity, but also around decision making around ensuring
financial sustainability. But the overall assessment, and given there's three on our
members can take some assurance from the internal audit
opinion that will follow and from our external auditors
who also look at matters that concern governance,
that we have a reasonable level of governance in place
around decision making.
So I'm not concerned that we've got an overall assessment
that says they're reasonable and fit for purpose,
but also putting in front of members a need to improve
three specific areas.
I think that's absolutely right to highlight significant governance concerns.
I would be more concerned if the action plan was blank, because that to me isn't a realistic
assessment of any control weakness or strength.
So the fact that there are three significant governance concerns that the Council needs
to address is a positive, because that's being looking at your principles, making assessments
of the evidence you can demonstrate that you're complying with those principles, but actually
say there are three areas that we feel that needs to be more done.
Thank you, David.
Councillor Helene Mansilla - 0:55:35
Further questions, please?
Councillor Helene Mansilla - 0:55:43
I have three brief points.
The first one is on page number 21, paragraph 2 .2, and it refers to the regulation 4 of
the 2011 regulations. I understand that those regulations were replaced in 2015.
Angela, can we confirm the correct provision? Can you confirm the correct provision?
Councillor Helene Mansilla - 0:56:15
or David? The second point is on page 58 and it refers to the 2024 -2025 internal audit
Before we approve, can we confirm that the 2025 -2026 opinion and its findings were considered
and correct the reference?
And finally, can we confirm whether progress against the AGS action plan will return to
this committee. We can then add the appropriate date to the work plan under item 15. Thank
you.
David Stanley, Deputy CEO - 0:57:07
If I take two of those, you have to remind me of the first question. In terms of the
audit opinion, at the time the annual governance statement was drafted, we only had the audit
opinion for 24, 25. Lucy was still in the process of assessing the audit opinion for
25, 26, so it wasn't included in here, and I wouldn't recommend making the amendment
to the AGS to reflect that, but of course progress during the course of 25, 26 with
audits that had been completed and the emerging opinion were part of the overall assessment.
but at the time this was drafted we could only say the audit opinion given the 24 -25 was this.
In terms of progress against the action plan that will be a regular standing item for this
committee and will be added to the work plan for October, meeting in December and subsequent
Councillor Helene Mansilla - 0:58:09
meetings in the course of the year as we address those particular items. The first one, I don't
David, just to repeat, is there a reference to the 2011 regulations, because I understand
that those regulations were replaced by the 2015 regulations and then that regulation
4 maybe is not the correct provision.
David Stanley, Deputy CEO - 0:58:36
I will have to take that one away and provide a written response.
I will liaise with Andrea and come back to you on that.
Angela, please.
Councillor Helene Mansilla - 0:58:46
Yes, chess, sorry.
I was going to say similar to David.
I just wanted to clarify which page you were looking at.
I may have misheard, but I thought you said page 21.
Just one second.
Councillor Helene Mansilla - 0:59:03
I am confirming this on the pack.
On the printed pack, and I believe it is the same on the online pack, it is page 21, item
2 .2.
So in brackets, regulation 4 of the accounts and audit regulations 2011.
Thank you, Chair. As David said, we will collaborate on a response which we can provide to yourself
and the other committee members. Thank you, Angela. I am happy with that.
Councillor Helene Mansilla - 0:59:35
David Stanley, Deputy CEO - 0:59:38
I think so if it helps I'll take that so in terms of that particular paragraph it refers
to regulation for the council and audit regulations 2011 that was replaced by the accounts and
order regulations of 2015 which subsequently be were amended in terms of the dates for
covid what I don't know is whether regulation for of the 2015 audit regulations applies
or whether we go back to 2011, but we'll clarify that and get you an answer.
Councillor Helene Mansilla - 1:00:09
Thank you. If there are no further comments, can members approve the AGS and action plan
subject to the corrections agreed today or the comments made today and note the zero
report. All those in favour, thank you.

9 Annual Standards Update

Okay. Thank you. Let's carry it. Moving on to item 9. Item 9 is the annual
standards update for 2025 -26. The report records an increase in code of conduct complaints,
mainly involving town and Paris Councils, members are asked to note the report.
I invite Angela to present the key points before I bring it in to members.
Thank you, Chair.
Thank you, members.
Yes, this is my annual report for the year ending March 2026.
Very sadly, and this has been the trend at Cotswold in recent years, we are seeing a
significant increase in code of conduct complaints, particularly around town and parish
councillors. And this ties in with item 14, which is later on your agenda, which refers to some minor
changes in our procedures. Sadly, the situation that we're experiencing in our district does fit
in with the national position around complaints particularly about town and parish councillors.
and you'll see for the second year I've actually named some of the Town and Parishes for which
the bulk of the complaints are generated from. And you know I always say when I present this
item every year I know there is so much great work going on in Town and Parishes. It's disappointing
that we do have so many complaints. I think another couple of points I'd just like to
highlight is that, and I go into more depth in the report, we are seeing more and more
AI generated complaints now, and I know this also ties into an item that is later on on your agenda
that Cheryl Sloan will report. AI generated complaints are often more lengthy and more complex.
And I suppose the other thing I'd like to pull out is about the sort of weaponizing
of code of conduct complaints. I'm seeing them being used perhaps sometimes if somebody thinks
this might derail a planning application or you know it they are a former
councillor and perhaps they left in unhappy circumstances. So all in all in
some corners or some town and parishes we are sadly seeing an increase. It does
tie in with the national position and we are seeing more lengthy and more
complicated complaints coming in. Really as I say it's for here it's here for you
tonight to note but happy to take any questions or any brilliant ideas that any of you have
got in terms of how we can reduce the number of complaints that are coming forward. Thank you,
Councillor Helene Mansilla - 1:03:22
Chair. Thank you, Angela. Thank you. Before I bring in members, I recognise the work of the
Councillor Hopkinson.
Councillor Paul Hodgkinson - 1:03:41
Yeah, thank you. I mean, I think it's a very interesting report and also quite sobering really
given what's in it. I think, I mean, I wanted to just make a couple of points and then ask a question around it.
If you look at the table on page 83, you know, the total complaints and what's happened with them,
A substantial number have had no action.
No action was needed.
Another substantial number had the complaint dismissed
completely.
Very few then got beyond that point.
In fact, none at all got to sanctions applied
or recommended.
So you kind of wonder really what is going on here.
And you've alluded to some of those things.
is it becomes, I know from other people who've had complaints
against them and people who've complained, it gets, it can get
very, very personal and it can have a big impact not only on
the people who are complained about but actually the person
complaining.
There's a big impact I think on both parties in that.
And I also was concerned to read in 4 .6 it refers to the worrying
theme is a system used as a weapon against others is horrible isn't it? It is horrible
and I know it can get to that human life is such that people fall out with each other
but it's really I think very sad. So a couple of questions how much of your time Angela
of your total time is spent sorting out these complaints and then secondly I'm not really
clear as to whether there's going to be any change from the government or maybe
we're talking about the new government, Andy Burnham's new government, as to
whether there's going to be any change in this to try and somehow get to grips
with so many complaints that never get anywhere.
Councillor Helene Mansilla - 1:05:42
Shall I respond at this point? So thank you Councillor Hodgkinson. In terms of
much time and I suppose I would say it's not just me. I'm supported by colleagues in democratic
services who will often do the initial acknowledgement of a complaint, who will sometimes take some
of the calls and inquiries and act as in some of the liaisons. So it isn't just me. It's
very easy to think that this takes perhaps, I don't know, a day, a week of my time. I
complaints came in in one week on one occasion. Now that can just gobble up an enormous amount
of time. And I think I don't, what you've said, which is very important about the emotional
toll it takes on the person being complained of, and also the complainant. And I think,
you know, the complainants will often think that I can achieve things or by making a complaint,
that things can be achieved by... I think the most common thing is that by making a complaint
about a town or parish council, that means that in some way I've got some authority to remove them
from the town or parish council. And unfortunately, as much as I might like to think I could,
unfortunately that isn't the case. Sometimes somebody's subject to a complaint, even if it
event or perhaps just a falling out that could be dealt with through an apology,
it will often be seen that the town or parish councillor will say,
I'm not going to do this anymore. This is a voluntary role. I don't need it.
So in terms of how much of my time, I'm going to say 20 to 25%.
There is also a lot of other kind of background activities.
There's a lot of inquiries from town or parish councillors that don't actually come to a complaint.
So, or, you know, some, a member of the public phones in, they want to, they find it's not
going to get the desired result.
So you know, it's, let's, let's land on 20, 25%, but I haven't done a particularly forensic
examination.
And I suppose the other, the other point to say is we can't charge for any of this.
So we have no mechanism to recharge town parishes for cost of investigations if it goes that
far.
And I think your other point was around what are the government doing?
Now last year, or in the last 18 months or so, there'd been a lot of emphasis put on
various consultation exercises, asking other local authority monitoring officers and other
interested stakeholders in the sector, you know, things needed to change.
They recognised that the standards regime, as we call it, doesn't have much in the way
of teeth.
And all the direction, all the mood music was, we were going to see something in the
King's speech, which unfortunately we didn't.
So as it stands at the moment, the regime that initially came in in 2011 with the Localism
Act is the same one with nothing on the horizon to change the situation, unfortunately.
Just come back briefly.
Councillor Helene Mansilla - 1:08:56
Councillor Paul Hodgkinson - 1:08:57
I mean, thank you very much for a very comprehensive answer.
I thought one of the interesting things you said is obviously that the system
doesn't have many teeth really and also that there's probably no
change coming. So I think with regard to that given the sheer volume of
complaints in town and parish councils, how much communication has there
been with town and parish councils to explain the system? In other words to say
if you put a complaint in this would be the process but at the end of the day
you know, getting a sanction against someone is very, very, you know, is minimal chance
of that happening. Because I wonder whether if people knew what the process was and what
the outcome is likely to be, that actually they wouldn't then put complaints in. But,
you know, I'm being hopeful, but I just wanted to understand if that communication has gone
out.
So at various points, Chair, if I can respond. At various points, we've done training sessions,
content in newsletters and sessions with clerks about this,
but we can always do more.
I mean, as I've outlined in the report,
I've seen more and more counsellor to counsellor
or counsellor and ex -counsellor having a fallout.
Members of the public,
it's hard to get the message over to them
and there are expectations
that are just way outside of my remit,
but it's a useful point
and I'll make sure we take away in action
to do another reminder with our town and parish colleagues.
This is how it works.
This is what the process is.
This is what we can and cannot do,
that type of feedback.
So thank you for that point.
Councillor Helene Mansilla - 1:10:38
Angela, you just mentioned that we can do more.
Is there any preventive work planned with those councils?
Thank you.
In terms of the five that I've named,
which are in the report. All of those... Now, some town and parishes will take on board what we say.
Sometimes they won't, and they'll have various reasons for that. It might be,
I'm putting something forward from my perspective, and actually I don't understand a local nuance or
something like that, or they're not so... They think things can be dealt with in a different
way. So all of the ones named in the report have either had lengthy correspondence from me,
or numerous calls or virtual online calls about actions that they might be able to take.
A couple of times I've had to write to town councils in the last year and point out how
deteriorating it is because it's no good for them. If you've got fallings out or complaints
coming in, it stops them getting in the way of doing all of their good stuff.
I always say when I present this every year, anything that ward members can do to help improve the situation,
because there are, there's, you know, many Town and Parish Councils signed up for what is called the Civility and Respect Agenda,
which is a pledge that you make. That's good at re -informing or reinforcing, but good behaviours.
but you know as I say any other thoughts in the same way that Councillor Hodgkinson said you know good to remind everybody
actually this isn't going to probably get you the outcome that you want and
And you know any other any ideas very happy to listen to them
Angela any further questions?
Councillor Helene Mansilla - 1:12:35
I have a pick up on the same points that Councillor Hopkinson and
And in regards to the complaints, you know, the complaints process that may be used to disrupt planning matters,
how do officers distinguish misuse from a genuine complaint?
So to respond, Claire, Chair, they're completely different processes.
So if I talk hypothetically, you know, if a planning application has gone in and a member
of the public has a view that they don't like that planning application, they want to object
for some reason, you know, we have a very clear process by which you object to then
raise a complaint against a council or a council or councillors, you might not like the parish
Council's feedback on it, for example, is a separate process.
So they're two defined separate processes.
So for me, I handle it as a code of conduct.
If there's issues coming that relate to a planning matter, they're handled separately.
So this is where I think some of the education comes in that is similar.
I've dealt with, even today, I can give you an example.
I've dealt with something where there's clearly a public rights of way issue, which can be
very sensitive and controversial.
and that has now turned into a code of conduct complaint.
Now, it might be that there is a link,
that there's something here about harassment or intimidation,
but more often than not,
it's different processes getting confused.
So for me, I'm clear what our process is,
and as I say, that touches on what's item 14,
but it's about being clear what process
and what policy we're taking these complaints through,
regardless of what the nature of them is.
Councillor Helene Mansilla - 1:14:42
Any further questions? Thank you. Unless any member objects, the report and the comments

10 Annual Complaints Report and Annual Local Government Ombudsman Report 2025/26

are noted. Next item, item 10. Item 10 reviews the Council's
complaints, performance and proposed changes to the complaints policy concerning AI -generated
complaints. Members are asked to note the report and the Ombudsman annual letter and
to approve the proposed policy changes. I invite Cheryl Luslan, Executive Director of
Workplace Strategy and Transformation to introduce the report.
Officer - 1:15:35
Thank you Cheryl. Thank you chair. So you say this is covering the annual
complaints performance for 25 -26 and the annual ombudsman's letter and then we're
also seeking approval for some policy changes to cover AI generated complaints.
So report that's set out here so it's compliant with the new ombudsman
complaints handling codes that was something that we introduced on the
1st of April 2025. There was a requirement to be compliant from the
of April 2026, so we're ahead of the game in terms of that.
And this report sets out what we have to do in terms of that code.
So the first part is we have to undertake a self -assessment,
so we have to assess whether we're compliant with the code.
So the self -assessment is set out within the report.
So we are compliant.
The only area where we're going to do some improvement is to
collect information and data around any complaints that we
have received that we have exempted from the process.
So that's something we'll be able to report on next year.
And in terms of improvements, and it touches on what Angela's just said about complaints
relating to planning, we're also going to make sure that we use that exemption process.
So currently we do take a lot of complaints through that we shouldn't do.
So we may have a complaint around planning.
Nine times out of 10 that will be relating to the decision.
We can't remedy that through the complaints process.
It has to go through an appeal process.
So we will stop and we'll push back on those.
Now they can take it to the Ombudsman and the Ombudsman
make a decision that we have to investigate, but we will be
pushing back in terms of those exemptions this year.
So in terms of performance, you'll see that we had 84 % that
were responded to the stage one complaints within 10 working
days.
So we had eight complaints or 60 % that missed that deadline.
What we have got the ability to do under the Ombudsman code
is that we can extend by further 10 days.
So what we need to do is make sure that where services aren't
going to hit that first 10 -day target, that we do write
to the complainant and request that 10 -day extension
so we are meeting that target.
And our stage twos, all of those were answered within the 20 days
or what our couple were extended to.
Again, we can extend by further 20 days
when responding to stage twos.
You'll also see within the report that there's a breakdown
in terms of where you get those complaints from.
So the key service areas where we get the most complaints.
So we had a total of 50 complaints,
but the highest numbers we tend to receive are where there's
decisions made, so revenues and benefits, plannings, et cetera,
where people aren't necessarily satisfied with the response or
the decision that's been made.
You'll also see that we had, of the 50 complaints,
we had 14 that we upheld.
And there's a summary there in terms of lessons learned.
So that's another thing that we have to report on now is any
lessons learned that we've taken from complaints are upheld to
any things that we've introduced to make sure that we don't get
those same complaints again.
So in terms of the Ombudsman we had 11 complaints referred to
the Ombudsman last financial year for will not for us.
So they tend to be things that maybe with a County say a
highways complaint or or something else six that were
assessed by the Ombudsman and then closed so that tends to
be where we may have a complaint planning complaint that's gone
all the way through.
You know, the long and short of it,
they're not happy with the decision.
The Ombudsman won't investigate that.
And then one that was investigated and upheld,
and that was regarding there was some impact
from a neighbouring business.
Whilst we could handle the complaint fine,
there were some delays with it.
And when I look back at the complaint,
it was to do with it did have some crossover
in terms of highways.
So we had to do some liaising with the highways department
so there were some delays.
So the only remedy we had to provide was an apology to the complainant, but nothing else.
And then we are requesting some changes to the policy.
So we want to cover AI -generated complaints, because what we're seeing is we're seeing
a lot of complaints come through now that are generated through AI.
They're lengthy.
They're often quite misguided, so they may quote law or case law that nine times out
of 10 is often incorrect.
So it gives us that ability to see that it is an AI -generated
complaint and respond only to the pertinent parts,
but also to provide some guidance to complainers,
because people are using AI.
They are going to continue to use AI,
so it's about making sure that if they are using it,
they get the best out of it.
So we put some information in there and how to prompt and how
to get the best complaint that they can get using AI so they're
not getting it lengthy, they're not quoting the wrong
information and it is clear and succinct in terms of what they want for a
complaint so that's something they were requesting is approved by the Ombudsman
so we are seeing other councils go down this route as well so we're not the
first but it is good practise to cover it off and give some guidance or a hand
at how people can use it as well as how we can respond. So I wasn't going to say
I will take any questions.
Councillor Helene Mansilla - 1:20:34
Councillor Wilkins.
This is an absolute minefield.
Councillor Len Wilkins - 1:20:41
I am looking at page 92.
We have got one, two, three, four, five statements in italics.
The third one we have got, we rewrite the text below as clear,
polite complaint using the information I have provided. Why? Is that the council or
is that the complaint? It's the third bullet point.
Page 92.
2 .6?
8 .3.
I've got...
Okay, so which...
Okay, going back.
Okay, you've got first italic, second italic, third italic, it's the fourth one.
Rewrite the text below as clear, polite complaint.
Use only the information I have provided.
Oh so that is us giving guidance on what the complainant should
instruct AI to do. So it's what they're asking AI to do to make sure that
response that they get back is what they're asking for basically. So it's us
giving them guidance on how to prompt AI. Okay it's the I that I object to.
I being the counsel or I being the complainant.
But anyway.
I can cheque the wording on it.
Okay.
And the next one, do not ask AI to add legal arguments, use format.
Once you say to a complainant, you can't do this or do not do this, you are possibly
infringing their human rights to put forward arguments.
Could we change that slightly to we suggest or we feel or whatever?
In other words, don't say, don't do it.
So, yeah, you can do it, but...
Certainly make it a bit softer, if you wish.
As I say, it's things that councils are using now
because they're quoting laws coming back and it's incorrect.
I had one back from an FOI actually this week
where we said we'd come back, they'd asked for an internal review,
we said we'd respond within 20 days.
They then put it into AI and said,
wall where you don't have to respond within 20 days because you can have an extension.
I thought, oh great, thank you.
So there are some suggestions.
There are suggestions.
I've been on the other end of this, so I know exactly what you're going through.
We have had other problems with not so much the complainer, but if they've got a legal
representative saying wall, no, they shouldn't be sending that.
So it's just a form.
Councillor Craig Thurling - 1:23:53
Yeah it's just more of an observation really. Is there a particular reason why it's increased
from 7 to 11 referrals or is that typically cyclical but year by year you're concerned
Officer - 1:24:06
or is it within expectations? Yeah I mean I'm not overly concerned. You can tend to see the
ones that are going to go all the way through.
And we only had one that was actually reviewed by the
Ombudsman, and one of which was upheld, which you knew it would
be because we'd already given an apology.
So I'm not concerned.
And that's where we may see a reduction, where we're pushing
back on the exemptions, because you'll see they're planning one.
So we know that they'll go all the way, and the Ombudsman will
say, no, I'm not going to investigate, because the route
is the other route of appeal.
also so by not taking them through the complaints process and saying no you
need to follow the planning appeal process might reduce the number that
are going to the Ombudsman but they still have the right to go to the
Ombudsman if they're not satisfied that we've declined that complaint anyway so
I am not concerned.
Any further comments?
Councillor Helene Mansilla - 1:24:58
I have two comments.
One of them we have spoken about and you can go ahead and explain to the rest of the members.
but my first comment is the report says that the officers are seeing more lengthy and inaccurate
AI -assisted complaints. But if that doesn't quantify the problem or explain why guidance
alone will not be sufficient, what evidence shows that the policy change is needed?
Thank you.
I haven't got data that sits behind.
Officer - 1:25:46
I can certainly create, I can certainly look at the number that we're receiving in terms
of AI generated complaints.
And it's something we'll also look at FOIs because we're seeing a huge number that are
coming through that AI generated in FOIs.
So I can certainly come back with data, but we are, you know, it is, it's a sign of the
times that people are using AI.
So we can't stop that from happening, but what we want to
do is try to encourage customers to use it effectively.
So, you know, when they do put a complaint in, it is actually
summarising what their complaint is, because often they'll put
something in AI, they won't read it, and actually will respond to
something that isn't their complaint in the first place.
So it is about trying to aid people to use the tool, but to
get the best out of it.
So I think it's just guidance for people.
Councillor Helene Mansilla - 1:26:37
We will just be interactive in the absence of...
Thank you.
Councillor Helene Mansilla - 1:26:50
...explain to everybody else in the room why the change is needed.
Why should the requirement for a currency, relevance and proportionality that you mentioned in the report
not apply to all complaints, however prepared, with separate guidance dealing with a particular risk of AI?
Officer - 1:27:16
So I think we don't see that issue when somebody's writing their own complaint.
We do see some very lengthy ones, don't get me wrong, we do see some lengthy ones,
but people in their own words, they tend to be shorter and more succinct to the point,
Whereas when somebody pops in an AI, then it generates, it can generate reams of information.
So I think yeah, you're absolutely right that the proportionality is across, you know, all complaints.
It needs to be to the point, etc. But we're not seeing the issue of those that are written themselves.
We're seeing the, you know, the issue is around those that are generated through AI.
So we can definitely put something at the start of the policy that says,
you know, when you're, you know, make sure that you're succinct
and to the point in terms you can play, but this is just
around guidance when creating your complaint through AI.
Councillor Helene Mansilla - 1:28:08
What you're asking effectively is the specific policy for AI?
No, it's just literally an addition into the current complaints
Officer - 1:28:16
policy that said if you're using AI to produce your complaint,
please take this guidance on board.
So it's about just encouraging people if they're going to use AI that they use the right prompt
so they get the best out of it.
So it is part of our, it will be part of the normal complaints process, policy and then
we'll probably just put on the internet as well some guidance around using AI.
Thank you, Cheryl.
Any further questions?
Thank you.
Councillor Helene Mansilla - 1:28:49
If there are no further comments, there are no complaints reported and there is almost an annual letter, and not it.
And on the policy, do members agree on a revision presented? All those in favour?
Thank you. Revision.

11 Internal Audit Opinion 2025/26

Councillor Helene Mansilla - 1:29:16
Moving to Item 11 is the Internal Audit Annual Opinion for 2025 -26.
This is one of the Committee's key sources of independent insurance
and informs the Annual Governance Statement considered today under Item 8.
The head of Internal Audit has given an overall opinion of reasonable assurance
and no assurance reviews were issued during the year.
Members are asked to consider the report and make any comments they consider necessary.
We are joined today by the Head of Internal Audit, Lucy Carter, who presents the report.
Thank you, Lucy.
Officer - 1:30:06
Thank you, Chair. I think you've just done my job well.
The report for myself tonight is the report of the work that we have undertaken as your
internal auditors for the year of 2025 -26.
We have offered a reasonable opinion over the controls for the year, but you will probably
notice that the dial in the box has gone up slightly, so it's better than last year.
Better than 2024 -25, I should say.
I am not sure where we are on page numbers now but online I am on page 113.
Michelle has got it on 118 which is the key page of information.
It gives you some comparisons of the number of audits we concluded in 2526 compared to 2425.
You will also see a significant improvement of the number of agreed actions that have been agreed
agreed during 25 -26 compared to 24 -25. Going through the report it's also
pleasing to note that the four priority one actions that we reported during the
year have already been actioned this year so they're not outstanding, no
concerns in those areas and of the actions that we raised in 25 -26 there
are only four that are outstanding at this moment and we'll follow those up
and we undertake those next audits.
You have three final reports in your pack tonight,
which include the follow -up report for data breaches
and data protection, of which we've given a substantial.
You've also got bank reconciliations,
which again are substantial,
and along with our continuous analysis on accounts payable,
which again is a substantial assurance.
And you have a summary of the agreed actions
that remain open, of which there are only six.
Happy to take any questions chair
Councillor Helene Mansilla - 1:32:03
Council to link
Councillor Craig Thurling - 1:32:11
Yeah, sorry it's um, so I just might be looking at me notes
Yeah
Assurance it stayed at reasonable despite having reported improvements at what point would it thing go up a level?
Councillor Helene Mansilla - 1:32:28
It's an overall assumption of the year and what you've also had, perhaps I should have
Officer - 1:32:34
mentioned it in the table, which lists all the audits. There were a number of advisory
reports of data retention and digital exclusion, plus you also had a middle limited for the
leisure services. We will now go in and do follow -up audits of those, which will hopefully
increase the assurance levels for each of those service areas. But because controls
in those areas were not great at the time we undertook the audit, that has to bring
my assessment of the overall control down. You are right, because in my page 142, it
looks probably more green than yellow and grey, but those greys would have brought the
assurance level down as well.
David.
Thank you, Chair.
David Stanley, Deputy CEO - 1:33:26
Just for reference, there's a 12 -page difference between the printed pack and the online packs.
If you're looking at the online pack, take 12 off when you're talking about page numbers
for the benefit of those with printed packs.
In terms of the overall level assurance, I am delighted with Reasonable.
That's a really good place to be.
and having spent many a committee saying,
don't look at where the arrow is,
do look at where the arrow is in this instance,
because the arrow has moved a little bit
over towards substantial.
That said, if I had a limited assurance overall,
I would also be happy, disappointed but happy.
What is important is what is being identified
by internal audit during the course of the year,
what recommendations are being made, what action is being taken
against those recommendations that then feed into the annual review.
Now, if during the course of the year Lucy and her team are
identifying significant weaknesses in the Internal
Controls Reporting Act through the ends up with a limited
assurance audit opinion, that won't be great, but at least it
would give me and you as committee members something
to work from.
So whilst I'm delighted with reasonable, which in other
language can be satisfactory good enough. That is a really strong performance and is
just a hair's breadth away from substantial.
Councillor Helene Mansilla - 1:34:57
Councillor Coleman.
Thank you David, thank you Lucy.
Councillor Helene Mansilla - 1:35:04
But looking at the printed pack 118 and the online pack is 118 as well.
Or mine, I don't know.
Maybe I got a different copy.
With one review, we have one review still in draught stage, four in progress and two deferred.
Is SWOP satisfied that sufficient work has been completed to support a reasonable assurance
opinion?
Yes, otherwise I wouldn't have written an opinion report.
Thank you, Lucy.
Thank you.
Councillor Helene Mansilla - 1:35:47
A further question I have is Annex C. So six open actions.
This is the last page of the item.
Six open actions, five of which are overdue.
Can management confirm the completion dates and how any further delay will be escalated?
Thank you.
David Stanley, Deputy CEO - 1:36:29
So I'll take that away in terms of looking at the timescales, the timescales that are
highlighted. 30th June 2026 saying they're in progress. I know some of the progress particularly
on some of the bank reconciliations requires that to be undertaken as part of the year -end
processes but will provide a written response to the committee as to what
their current state of those are given the several weeks have passed since
those time scales of the 30th of June although there is one that has been
extended until the 30th of September around suspense accounts for West
Oxfordshire and Cotswold District Council.
Councillor Helene Mansilla - 1:37:13
Any further questions? Thank you. If there are no further comments, the report has been considered.

12 2025/26 Statement of Accounts (Draft)

Councillor Helene Mansilla - 1:37:25
12 is the draught and audited statement of accounts 2025 -26.
Members are asked to note the draught accounts and the key financial highlights.
The audited accounts and the external auditor's opinions are expected to return to this committee
in December for formal approval.
I encourage members to read through the accounts and to ask officers between now and September
any questions, however they may seem.
I invite David to present the report.
David Stanley, Deputy CEO - 1:38:08
Thank you chair. I think I'll hand over to Michelle who's going to run through the
annual statement of council. Michelle and the team have spent many many a week
preparing your council. We'll be able to give you a much more fuller picture of
Officer - 1:38:25
those accounts than I will. Thank you chair, thank you David. Yes as you've
mentioned this report presents the council's draught unaudited statement of
accounts for the financial year ending 30th March 26th. These have now been
published on the council's website and they've been prepared in accordance with
the CITFAR Code of Practise guidance and the statutory requirements. So the report
here today that you've got in front of you is just asking you to note the
accounts at this stage and it highlights some of the key sort of highlights
from the year prior to that audit being undertaken by Bishop Fleming which will
start in September. So overall the accounts show a positive financial
position. The net worth on the balance sheet has increased this year from 96 million to
106 million and that's largely been driven by increases in property values
and investment balances as well and an improved pension position so the pension
liability is reduced. The comprehensive income and expenditure account reports
an accounting surplus of 4 .5 million so if you look probably the easiest way to
I will show this is on paragraph 2 .2 and 2 .3 in your report.
So that just reconciles the surplus that you can see in the
comprehensive income and expenditure statement,
which just summarises CIES.
You'll see there you've got $4 .5 million.
And then there's adjustments there,
what we call technical accounting adjustments of $1 .1
million, which are outlined in paragraph 2 .3 below.
So that's things like the effects of depreciation,
any revaluation gains or losses on the council's property,
capital grants, or any sort of adjustments
to the pension reserves.
So we can go into that in more detail if you wish to,
and we have the training session in September,
but that's what those differences are there.
And then there's also a transfer to earmark reserves,
which nets to 2 .4 million.
So that brings you back down to that 889K surplus
that the chair mentioned earlier,
which was reported to cabinet earlier in the month.
So the balance sheet also reflects the continued
investment in council assets and services.
So within that is the impact of capital expenditure of just over
two and a half million and that includes things like the
disabled facilities grants or EV charging infrastructure,
investment in waste and recycling containers and
improvements to IT infrastructure across the council.
As I said before, the external audit will be starting in September.
They hope that according to their audit plan to complete by November.
So subject to the conclusion of that audit, we hope to be bringing back to you the final audited statement of accounts with their auditors' opinion to this committee in December for approval.
And as I said, we'll be offering a training session to hopefully see quite a few of you there.
We'll get the dates out soon but yeah probably mid to late September.
David and I will deliver.
But yeah as the chair said we'd encourage you to you know appreciate it's a 100 page plus document.
Probably not the most exciting document in the pack.
It takes up quite a big chunk of this pack.
But yeah please read through and come back to myself or David with any specific questions however small they might seem.
But happy to take any questions today as well if you've got any. Thank you.
Councillor Helene Mansilla - 1:41:49
Thank you Michelle. It's a nice week for the summer. Any questions please for members?
Councillor Wilkins.
Councillor Len Wilkins - 1:42:01
I'm probably going to regret asking this. It's page 145 in front of me. It's 4 .7 and we're told the pension
surplus has increased by three and a half million nearly. We're about to go
through LGR. Has anybody any thoughts what that might do to the surplus or is
it just too early? So there will be a number of different pension fund
positions across Gloucestershire and part of the work that Michelle is
leading on with Andrew Knott who's the CFO over at Forest of Dean is working
with our colleagues in the pension fund at Gloucestershire County Council to start
thinking about what is going to happen.
David Stanley, Deputy CEO - 1:42:48
Essentially, the actuary and the pension fund will need to take
evaluation of all those individual different pension
funds before they're amalgamated into one.
It would depend on, and it was at the time this was prepared,
what the decision was going to be.
And with a single unitary for Gloucestershire,
that kind of makes it a little bit easier because you will have
an administering body for the pension fund that is likely to
be the unitary authority.
And then they'll need to collapse the admitted bodies,
as they currently are, which we are one of,
and transfer the assets and liabilities
into the single unitary position.
That will take some time to do.
But currently, you'll understand that our position
is relatively positive.
When we had the last triennial review,
we've seen a reduction in the level
of ongoing employer contributions.
we need to make to the pension fund and that was broadly replicated across
Gloucestershire but there will be another triennial review that will take
place in 2028 that will take effect from 29 30 that will help largely inform that
some of those early discussions are taking place but it's too soon to be
able to give members here or members more broadly across Gloucestershire any
indication of what the pension fund position will be for that new unitary
because there will be some disentanglement of pensions between
Publica and the council as well to contend with so it's not quite as
straightforward as taking what we've got what everyone else has got adding it up
together and going that's the job done there's a lot of moving around to do
within that
Councillor Helene Mansilla - 1:44:39
Councillor Craig Thurling - 1:44:42
Councillor Toole. Just more of a comment on the silver money that's just over a
million pounds that you've received from developers but it's not being applied to
finance capital schemes. Is a particular reason for that or is it just typical of
these things or are the projects in waiting that for it to be assigned to or
just not quite sure what what's going to go on next with that. So in terms of the
David Stanley, Deputy CEO - 1:45:11
community infrastructure levy and those contributions there collected at the point the planning
decision is made subject to certain legislation that determines the way in which those payments
are made. Council collects those and then through its infrastructure funding statement
and the annual process it goes through in terms of allocating that, the Council hasn't
been able to award the full amount that it's held to qualifying schemes. So there will
we have another opportunity for interested infrastructure providers to submit bids to
the seal pot and to the council then through its usual process to assess those bids and
make recommendations to council as to whether those bids are funded or not. It's not for
want of trying to get those interested bids through. We have had a number of bids through
that we have unfortunately not been able to support and it's around the timing of when
that infrastructure be delivered at the time when the payments would be made and
the assessment that's been made by the multidisciplinary team in terms of both
from a planning aspect or a financial aspect of the deliverability of that
infrastructure. There's a number of bits of criteria that are set out in the
prospectus that is issued to bidders but there'll be another round that will
report back over the coming months.
Guest - 1:46:38
Thank you, Chair. Just curious if any assessment has been made yet following the announcement
on LGR, whether that could have any meaningful impact on the financial statements as a post -balance
sheet event?
David Stanley, Deputy CEO - 1:46:55
Off the top of my head, I don't think it would be a post -balance sheet event because the
local authority will continue to be a sovereign council that has its responsibility for producing
a set of accounts up until the end of the 27 -28 financial year. It doesn't give rise
to a going concern issue that we had around Covid and that was a particular issue. Could
we, given the cash flow implications of Covid, demonstrate that? I'm sure it will be something
that Bishop Fleming will be considering. Does the decision fundamentally alter anything
at this early stage? I don't think it does in terms of the authorities accounts. It probably
has more of an impact on the financial sustainability position for the unitary on day one, given
the level of aggregation, disaggregation that may have been required if it hadn't been
a single unitary.
Councillor Helene Mansilla - 1:47:56
The 250k budget position that has been transferred to the capacity of revenue reserve, how much
of that improvement is recurring and already reflected in the medium -term financial strategy.
Michelle, thank you. Or David.
David Stanley, Deputy CEO - 1:48:26
That's part of what we're working through in terms of understanding the options for
the 27 -28 budget, and I'll give you an indication. So we reported quite a significant overachievement
of income on car park fees during the course of the previous financial year. So far in
this quarter we've seen car park income hold up particularly strongly. We're running somewhere
I would imagine around 15 % up to 20 % depending on the period of time you're looking at above
the budgeted level. So clearly there is a surplus of car park income that hasn't been
built into the MTFS because what we weren't certain of during the course of
25 -26, how much of that improved position was one -off, how much of it was going to
continue and appreciate there are certain areas of the district that are
seeing that increased number of tourist visits more than other areas. So it
wasn't building that into the base budget but I think given we've seen that
continuation. It's one of the assessments we're making to try and mitigate that
budget gap over the MTFS period but we'll report that back through cabinet
in due course probably in the October meeting as part of the budget strategy.
Councillor Helene Mansilla - 1:49:48
David Stanley, Deputy CEO - 1:49:52
In a gut is possible? Other things being equal and if nothing else changed there
would be a potential reduction in gap but as I referred to earlier there are
other pressures emerging, particularly around fuel and energy prices, the risk of pay inflation
being slightly higher than we budgeted for, and other demand -led pressures that may come
through. So my broad assessment so far this financial year in terms of prospects is we
had a million and a half gap reported in February of this year. My best guess is that million
and a half gap is still there to be closed. So there have been some positives and also
been some negatives in that sense.
Councillor Helene Mansilla - 1:50:35
So my next question is, given that the general fund balance remains at 1 .7 or nearly 1 .8
million, how much, if any, of the 5 .9 million or nearly 6 million increase in usable reserves
provides additional flexibility against the budget gap for 2027 -28 rather than being a
marked or capital related or one off. Thank you.
David Stanley, Deputy CEO - 1:51:11
Thank you, Chair. So a broad answer on the general fund balance of 1 .76 million, that
is a risk assessed balance in accordance with guidance set out in what used to be that Bulletin
I think it's sit for bulletin 13,
that sets out the ways in which the council should assess
the minimum level of balances it should set aside
for unplanned expenditure unforeseen events.
So I'm comfortable that level hasn't changed
as a result of the out term.
There has been an increase in the level of earmarked
reserves, some of that would be a timing difference,
so some change comes through in terms of the way
the business rates flows through.
So we may see some Section 31 grant provided to the authority
to compensate the authority for loss of income because the
government has provided release at a national level.
But that's money we're receiving in one year that will hit the
collection fund of the business rates account in the following
year, so that's a pure timing difference.
Some of the other changes to EMR reserve balance levels have
been to mitigate risk.
So we did see, and you'll see in the report that follows, the Treasury management out -term
was positive.
The entirety of that positive out -term position has been put into an earmark reserve to mitigate
the risk of the statutory override on IFRS 16 or 9.
I keep getting them confused.
I'll be correct, which is where we have to account for pooled fund losses, whether realised
or not.
That's due to end in 2029.
The other significant change to earmarked reserves was a result
of additional planning fee income that came during the
course of the year, over $700 ,000.
And in the quarterly reporting to members, it was recommended
that initially 50 % of any additional income, which was
then increased to 100%, be set aside in an earmarked reserve to
mitigate the risk of costly planning appeals being lodged,
the cost of defending planning appeals, engaging with
KC advice runs into the tens if not hundreds of thousands so for the time
being the view has been to maintain a planning appeals reserve at that level
but also mindful that we are just about to start the reg 19 consultation we do
need to submit local plan we do need that examined there may be costs that
need to be incurred that we need to fund from that so in short at this early
stage I would not be advising members to assume that the increase in earmark reserves balances
mitigates the budget gap that is currently forecast across the MTFS.
Councillor Helene Mansilla - 1:53:58
The following points are just drafting corrections, or apparent drafting corrections. So the first
one is on, I believe, page 143 of the printed pack, paragraph 2 .1 describes the 4 .529 million
surplus as the net cost of services. And the second one is that the cash balance differs
by 350 between the balance sheet and the cash flow statements. So if somebody could have
looked back and correct those figures, that would be great if they need correcting of
this law. Any further comments? Thank you. There are no further comments. The draught accounts
and key financial highlights are noted. Thank you.

13 Treasury Management Outturn 2025/26

Item 13 is the Treasury management upturn report for 2025 -26. It sets out the Council
investment and borrowing performance for the year. Members are asked to consider that performance
and agree any comments to be passed to full Council. I invite David to present the report.
David Stanley, Deputy CEO - 1:55:32
Thank you. Thank you chair. As indicated in the previous item and in the
out -turn report the cabinet considered earlier in the month has been a positive
position on investment income so as set out quite early on in the report in the
executive summary paragraph 1 .2 the council achieved 1 .5 million of
of investment income for the year,
just over 367 ,000 above its budgeted position.
No borrowing was undertaken during the course of the year.
The Council is predominantly debt free
aside from the remaining balance
of the community municipal investment.
Half a million was raised in funding in 2022
and the outstanding balance is 161 ,000,
so that's still classed as debt,
but the council hasn't, unlike some other councils,
undertaken quite significant external borrowing
to fund its capital programme.
The other highlight is the council converted
the development loan with Cotswain Housing Association
into a longer term loan at a rate of 4%,
so that is quite a positive position,
given the original agreement was for a lower
interest rate from that.
And in terms of compliance, aside from the interest rate exposure, which is set out in
section 7 of the report in terms of the financial indicators the Council has complied with the
Treasury management indicators, but happy if members have got any questions on the report,
I would say Annex A is probably a history lesson rather than useful.
that sets out where the economic background was during 25 -26. I think a lot has changed
Councillor Helene Mansilla - 1:57:29
since the beginning of that financial year. Thank you David, an always interesting history lesson.
Councillor Helene Mansilla - 1:57:35
Any questions? Councillor Hopkinson please. Thank you. Yeah, no thank you for taking us through
Councillor Paul Hodgkinson - 1:57:39
David. I mean it's obviously there's lots of there's some good very good stuff some good
stuff in here I mean I think in particular the council should be
praised for the note you've said no borrowing mostly debt -free I mean very
few councils can really say that so I think that that's really something
that's very important to say equally the four point zero four percent return is
pretty good actually knowing you know I've got money little bits of money in
various places and that's pretty good in terms of the future you know you're very
prudent and you know you like to be risk -averse etc at the moment it's very
difficult isn't it to predict where things are going financially because we
have a war that stops and starts which we referred to earlier we have you know
numerous changes of Prime Minister and government etc etc so it's very volatile
isn't it so in terms of your planning at the moment from now until the new
takes over on the 1st of April. What's your, in terms of the assessment you're making around
what the council will get, where are you kind of trying to position that in terms of what
you think we're going to get?
David Stanley, Deputy CEO - 1:58:55
So I'll give you a general answer. So what determines the decision making is the sly
principle of security, liquidity and yield. So we need to make sure whatever we invest
is secure, that it's available for when the council needs it and the yield is the last
thing on that list that we would consider. So we don't reverse it and try and chase a
level of return to achieve a particular outcome. That said, broadly speaking, my expectation
of treasury management performance between now and the 31st of March 28 is we will see
lower levels of investment income. So we've had the benefit probably over the last two
to three years of a relatively stubborn interest rate environment and also a relatively stubborn
from our positive point of view level of cash balances. So we've not spent the cash that
we've accumulated and we've been able to invest that at reasonably good rates of return either
through the pulled funds or increasingly it's been through the debt management office which
is an arm of the treasury which is considered a risk free investment where they've been
and paying above 5 cent in years gone by.
As you will note from our capital programme
for the current year and the subsequent year,
we're going to spend quite significant amount
on new waste and recycling vehicles.
That will be using some of those cash balances
because the council isn't borrowing
to undertake that activity.
So in short, cash we've got today will reduce by,
let's say, six million this financial year
as we buy those vehicles and probably further
two million the following year.
Timing is kind of everything because it depends
when those vehicles are ready.
They might not be ready when we think the else
of some of that six million may slip.
But broadly speaking, as we utilise the cash backed balances
the earmarked reserves, be it capital revenue,
we'll see our level of investment
over the course of year four.
Interest rates is a bit more difficult to predict.
I think if you looked at Arlene Close's projection on interest
rates back end of last calendar year, beginning of this calendar
year, they were expecting interest rate reductions to a
low of about 3 .25 percent by the end of the calendar year.
It's really difficult to judge whether Bank of England will
actually put those interest rates up in the short term to
reduce some of those inflationary pressures from the
cost of energy price of oil.
But overall, the MTFS has assumed a declining level of return from investment income.
So we've got a prudent level of budget in for this year that I think early indications
are will just about achieve maybe a small surplus or deficit.
But in future years, we're then reducing that down, recognising that the direction of travel
on interest rates was lower, the direction of travel on cash balances was lower.
And beyond 31st of March, 2028, then it will be for the new
authority to determine how it wants to use its treasury
management balances.
But we're mindful that we've got both short and long -term
cash needs.
We have got some money in pooled funds that's generating a level
of stable return over the longer term.
But we are, to an extent, exposed to those short -term
interest rate movements.
But we are engaged with Arlene Close,
who send us regular updates and we do pay attention to what the MPC voting
pattern may be as to whether that gives a glimmer of hope one direction or the
other.
Councillor Helene Mansilla - 2:02:36
Councillor Craig Thurling - 2:02:37
Yeah it's just more of a observation on the cash of the total investments it's
So around about a third of your total investments is cash.
Now, given the volatility around interest rates and returns,
you see about 4 % return.
Interest inflation is about 2 .6 % at the moment.
So the marginal delta is relatively small in terms
of the return itself.
And also, if you look at, say, on table 1 .9 in the report,
around the sort of cash and cash equivalence,
which is 9 .1 million.
Around 2 .6 % of that is 238 grand.
So having a large amount of cash sitting there
losing against inflation,
you're losing 240 grand a year at the moment on inflation.
So I'm just wondering what the plan is
in terms of ensuring that you're getting more of a return.
So you're getting 4 % in the poor funds,
but you're losing 238 grand or 2 .6 % on the cash equivalent.
David Stanley, Deputy CEO - 2:03:43
So probably needs a more detailed answer than I can give you on the spot.
The table gives you the average available balances for investment or borrowing during
the course of the year.
So it all fluctuates.
So there's a timing difference, particularly with council tax.
The bills go out, we collect ten instalments, we've generally got more council tax in the
early part of the year before either we've spent it or we've passed it over to our major
preceptors which are the County Council and the Police and Crime Commissioner. We
also then need to be mindful of the regularity of payments that go out so
there's a will be a more positive cash position in the early part of the year
and a more constrained cash position during the second probably quarter four
of the year. I'll work on some numbers of Michelle and the team as to how we're
managing the cash on a daily basis because whilst the overall picture may
be exactly as you've explained there'll be some nuances in terms of what we've
actually got available on a day -to -day basis so we do do daily cash reviews in
terms of understanding what we've got in the bank what's due to come back what's
due to go out and then manage within that the aim has to been to not keep an
awful lot in the council's current account because that doesn't earn any
interest at all, we don't operate a significant overdraft facility, so we do
need to manage that cash. So having it liquid and available when we might need
it and there might be a delay of a few days depending on payments of major
suppliers. That ability to call on that cash without penalty is really important
but I'll provide a more detailed answer that's had some consideration from
Michelle and Sian who are far more engaged in the day -to -day cash management
than I am but that will cover off any how we manage that inflation risk that
Councillor Craig Thurling - 2:05:44
you've outlined. Yeah I mean I think that sounds reasonable I think it's more to see
what the exposure is I mean even looking at the the year ending 31st of March
20 and 25, you're looking at around 40 -ish percent of figures, but that was in cash equivalent,
so that has come down about 5 or 10 percent. It'd just be interesting to know what the
target is in terms of what your, how much you normally target and how much cash equivalent
is, and with the risk that, with the Iran war, energy prices may go up, inflation may
go up accordingly, you're sitting on a bigger liability than what you're going to get back
in your investment rewards. So it's just knowing sort of working out what that
trigger is in terms of what you keep in cash versus medium to longer term
investments really.
Yes.
Sorry.
David Stanley, Deputy CEO - 2:06:49
I was taking it as read.
I was nodding going, yes, yes.
Clearly, my week's leaves damaged the brain cells, but yes, absolutely.
Councillor Colvin.
Councillor Helene Mansilla - 2:07:01
Councillor Helene Mansilla - 2:07:13
Councillor Helene Mansilla - 2:07:29
Councillor Helene Mansilla - 2:07:34
Any further comments? I do have a couple of comments, David, if you don't mind. The
first one is on paragraph 7 .3, page 270. As we can see, I know that the interest rate
exposure has improved but remains above the approved limit. Now, the table does indicate
It records the interest rate exposure indicator that was not complied with.
However, if we go to paragraph 1 .2, it says that all limits and potential indicators were
met.
So can we confirm the correct position and whether the executive summary is correct?
Thank you.
David Stanley, Deputy CEO - 2:08:27
So the correct position is with the exception of the one around interest rate exposure they
were all met, so the executive summary would need to be updated to reflect that.
Councillor Helene Mansilla - 2:08:40
My following question is regarding table 5 on page 266 of the printed pack. Table 5 shows
whose pull -up funds remained around 737k below their original cost. As the Council is expected
to cease before the statutory override ends, planning is taking place for the transfer
of those investments, the associated valuation exposure and the Treasury management risk
could be served to their new shadow or unitary authority.
Thank you.
David Stanley, Deputy CEO - 2:09:23
So in terms of the immediate position,
statutory override protects the council
on any unrealised gains or losses on those called funds.
So in the immediate short term, the 737 ,000
that's indicated in table five is a number on a table.
But in recognition of the statutory override coming to an
end and a view that I think MHCLG would give us, that they
are unlikely to extend that statutory override, we have set
aside an amount within the risk reserves to cover a degree
of that loss.
Arlene Close, when they do present to us and they do
provide a training and development session for members on an annual basis have said that the
direction of travel on a lot of those investments has to be to recover some of those unrealized
losses and that they're going to return to a more stable position over that medium term. So in the
immediate short term the council has made those longer term investments and at the moment there
isn't, as far as I'm aware, a plan to disinvest from the
pooled funds, but there is, as part of the LGR preparations,
a work stream or a project as part of the finance programme to
understand that wider exposure that Gloucestershire as a whole
may have to either pooled funds, pooled fund unrealized losses,
and whether there is a balanced portfolio that the unitary
authority would inherit.
That would need to take some time to understand the decision -making process
because I gave a hypothetical answer. We amalgamated everyone's position and said
we've got too much in Paul Fund X. The Unitary Authority would like
that position mitigated. That would be down to the Sovereign Council, i .e. asked
to make that decision. So the Unitary Authority can take a view and state that
view but until the 31st of March 28 it will be for this council to determine
whether its current investments are adequate or not including whether or not
the pulled from position in totality for this council or across Gloucestershire
needs to be mitigated so it's going to be an emerging position and one that I
suspect will change because there's still 20 odd months to go until the
day and those pulled fund positions may change anyway but at this stage I think
we've mitigated that immediate risk through holding a balance on the reserve
and the intention I believe will be for this council to leave a financially
sustainable position for its successor councils which would include passing
that risk reserve across to mitigate our position.
Councillor Helene Mansilla - 2:12:29
Thank you. Do members wish to make any comments to be passed to full council? I take that,
Councillor Helene Mansilla - 2:12:42
I say no. Thank you. The committee has considered the treasury management performance for 20,
25, 26 and has no comments to pass to full council. Thank you. So moving to item 14.

14 To approve minor amendments to the Code of Conduct Complaint Handling arrangements

In 2014, concerns proposed minor amendments to the Code of Conduct complaint handling
arrangements. Members are asked to note, although the PACS is approved, I have since the beginning
of this meeting verified that with the Director of Governance, Angela, and the changes shown
in red at pages 275 and 286. Are those the correct pages now? 275, yes I believe so, of the printed
pack. The pack contains the amended procedure itself but not covering report explaining the
reasons for the changes or the practical effect. So therefore I invite Angela to take members to
the proposed amendments. Angela, are you with us?
I am, yes, thank you very much, Chair. So just to say, as you said, this is very much
a for information only item. So the Code of Conduct complaints handling arrangements are
reviewed every three years and they were last looked at and approved by full council in
2024, so we will be looking at them again next year. But I have authority within the
constitution to make minor changes as things occur that we don't need to put through members
such as that you'll notice there's a change to a name, there's a change to an email address.
So it's not really seeking your approval today, it's just very much, it's always good to remind
you of what our arrangements are, particularly in light of my earlier report this evening,
but just seeking to advise members of those few tweaks that I've made, but doesn't change
anything substantially. Any questions?
Councillor Helene Mansilla - 2:14:45
Councillor Helene Mansilla - 2:14:56
Right. Thank you. The report, so we can take that as a report noted. Yeah, thank
Thank you.

15 Audit and Governance Committee Work Plan

Moving into Item 15, 287 to 290 of the printer pack.
Is the committee's report planned for the period?
It says 1 August, I will read 27 July, to 26 -30 April 2027.
Members are asked to review and approve the work plan.
Angela, could you briefly highlight any changes or additions before I bring in members?
Thank you.
I can, Chair. Thank you. Apologies for the small delay there. So I think the Annual Government
Statement Action Plan needs to be added, and I know David will be able to advise on that.
David, possibly every meeting that should come forward, I can see some nods, Chair,
so we need to add to that. But essentially, it's all the standing items that you see.
Is there anything else that members feel that they would like added on to the committee work programme?
Otherwise, it's just there for you to endorse.
Councillor Wilkins.
Councillor Helene Mansilla - 2:16:35
David Stanley, Deputy CEO - 2:16:48
So in terms of the work programme,
will run a training session mid -September. We can bring back the
statement of accounts unaudited in October if members would prefer as
another agenda item but the meeting in December which is due to receive the
external auditors report would provide members with the audited statement of
accounts. So it's I suppose it's whether the committee members feel there is
benefit in terms of public scrutiny in you reviewing the statement of accounts
before they're audited or rather receiving the amended accounts with the
auditors opinion for you to approve. So can do it either way but that would
require I suppose an additional agenda item for the October meeting.
Councillor Helene Mansilla - 2:17:45
Thank you, Councillor Williams. Any further questions? Councillor Turling and then Councillor
Councillor Craig Thurling - 2:17:56
Wayne. Yeah, just going back to what we were discussing
earlier and the contingency issues, given sort of things going on out there, for the
Thames Water, etc. I'm just wondering whether it would be worthwhile having a bespoke report
around the risks associated with those civil contingencies, just so we can track them as
as a separate thing going forward.
It might be just a short term thing over the next
six to 12 months, but I think it's quite an important thing
going on at the moment in the wider society.
Would it be worth, not just from a CDC point,
but also then tracking it across to the different agencies
and reporting back accordingly.
And that's proposed?
Councillor Craig Thurling - 2:18:39
Well, for the next one at the very least,
and then I think we could then review it at that stage
in terms of the frequency after that, depending on what's going on globally at the time.
David Stanley, Deputy CEO - 2:18:51
Yeah, in terms of, we'll probably need to understand the scope of what the audit committee
are looking to do. So there will be in the update on the annual Government Statement Action Plan,
a focus on business continuity. It's whether or not that can be expanded as part of that report
to include some of the elements you're referring to or whether there is a broader need that
the Audit Committee is identifying around the governance or the internal controls around
emergency planning and its effectiveness.
I suppose there's a risk without reference to the constitution as to whether this is
an Audit Committee function or whether it's an overview and scrutiny function, but that's
something I'd have to take away and consult with the monitoring officer, but there's certainly
scope within the annual governance action plan update and the four times a year report
on the risk management position. To expand on that, it's just whether or not it's within
the remit of this committee to look at that or whether it would be over -inscribing. But
we'll take that away and come back to members of the committee with a response without checking
the Constitution it's not my area of expertise. So just to follow up, I think
Councillor Craig Thurling - 2:20:12
that's great I'm happy to defer to the expertise of the officers to do it I
just think in general whoever is monitoring that I think it needs to be
picked up I think it's quite an important one at the moment so thank you.
Councillor Jon Wareing - 2:20:33
I wonder whether we might consider looking at the strategic risk risk just
twice a year rather than once given some of the things we were talking about
particularly David's answers in response to my questions. Over this the time up to
vesting there I think it's really important that that is given close
Councillor Helene Mansilla - 2:20:55
consideration. Very good point, Councillor. The strategic risk should be
included in each quarter. It's missing from the timetable but very good point.
Thank you. Thank you for highlighting that you've got that.
Councillor Helene Mansilla - 2:21:15
So what we have as a summary, so we need audited accounts in the December
timetable. The annual governance statement action plan is going to be included quarterly.
The strategy of risk register is going to be reflected in the timetable. I can see that
treasury management time is missing a meeting date. That can be sorted. Then we got the
point that Councillor Turling is made and is going to be verified by David, Angela and
go back to Councillor Turling. Thank you. Thank you. So subject to those changes and
updates, can members approve the work plan? All those in favour, please? Yeah, are you
Thank you to all committee members, officers and members of the public for having joined us today.