Audit and Governance Committee - Tuesday 27 May 2025, 4:00pm - Slides Tab - Cotswold District Council Webcasting

Audit and Governance Committee
Tuesday, 27th May 2025 at 4:00pm 

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  1. Julia Gibson, Officer
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  1. Councillor Nigel Robbins
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Slide selection

1 Apologies

Julia Gibson, Officer - 0:00:07
and we have apologies from Council Dale and Council Waring and absences from John Cheshire.

2 Substitute Members

Councillor Nigel Robbins - 0:00:27
Councillor Nigel Robbins - 0:00:28
Thank you.
We don't have any substitute members, but we are quarant.

3 Declarations of Interest

Are there any declarations of interest?
Nothing particular.
We have the meeting minutes of the 28th of January.

4 Minutes

I should quickly go through them page by page,
starting with page seven.
Please interrupt if you find anything that needs correction
or addition.
Page 8, this was the external auditors annual report.
Just one brief one.
Christopher Bass - 0:01:14
If I may, I'll try not to take offence but I have been omitted from the minutes so I was present at that meeting.
I won't take it personally.
Councillor Nigel Robbins - 0:01:25
I'm very sorry, that was remiss.
That happened to you before, didn't it?
And twice I won't take it personally, three times and I get offended.
Christopher Bass - 0:01:38
Councillor Nigel Robbins - 0:01:41
.
Christopher Bass - 0:02:44
I'm not sure where the appropriate place is to note it, whether it's in those minutes
or of this meeting, but there was a follow -up on whether there had been any statutory GDPR
breaches, and we received that and it was confirmed that there weren't, so we should
document that somewhere.

12 2024/25 External Audit Plan

Officer - 0:03:48
Officer - 0:03:53
Councillor Nigel Robbins - 0:04:15
So item seven is going to be the external auditors report.
So who's going to speak first?
Thanks you very much.
Could you just pronounce yourself when we're really familiar with you, then that won't
Officer - 0:04:31
be necessary. Thank you chair. Hopefully you can hear me okay. I am Alex
Walling, I'm your key audit partner from Bishop Fleming. So effectively key audit
partner basically means that I sign the accounts off when they're there and I
give the opinion on the accounts. I'm joined today by Jonathan Saunders.
Jonathan is new to your audit so you won't have seen him before. He's taken
over from the previous audit manager who has now moved on.
But Jonathan is an experienced local government auditor,
and so he knows what he's doing.
In terms of today, I was just going to take the audit plan.
I wasn't going to go through it page by page.
You'll be pleased to hear, because obviously you've had
time to digest it.
And also, I have to say the cover report probably covers
everything that I would have said anyway.
The audit plan sets out our stall for the year in terms of the work required to do under
the code of audit practice.
It is very similar to the one you received last year.
It is also very similar to ones you have had in previous years in terms of the content
of it and also the audit risks set out.
The only area I was going to draw your attention to, which is on page 114 of your papers, page
8 of our audit plan, which is to do with we have put in what we have called an other risk.
We have not called it a significant risk because we do not believe at this stage that it is
a significant risk and by calling it a significant risk under the auditing standards there are
certain things that we are required to do. But at this stage we've highlighted it as
an other risk and it's an accounting standard that's been introduced, it's been longer waited
but it's finally been introduced into local government. It's called IFRS 16 and it's to
do with leases and the authority is required to put certain leases, usually finance leases,
on the balance sheet, whereas in the past you probably haven't had to actually necessarily
do that. So in some local authorities that's been quite a big exercise and taken up quite
a lot of their time and obviously there's quite a few entries that will run through
the accounts. So obviously we will be looking at both that process and the accounting arrangements
as part of the work that we actually do. Having just spoken to my colleague from finance,
She tells me that there isn't a major impact at Cotswolds, so actually that will obviously
be reflected in the amount of work that we'll actually need to do or not need to do as the
case may be.
Other than that, Chair, I wasn't necessarily going to highlight anything.
As I say, broadly though, the areas are in there, they shouldn't be a surprise to you
and they should be areas that you've seen in previous years, but I'm more than happy
to take any questions if there are any.
Councillor Nigel Robbins - 0:07:35
Thank you very much. Members might like to turn to page 116, which is the timetable because
given that later item about government initiative in reviewing audit arrangements, there has
been such a continuing concern about the failure to hit deadlines or stop times that it would
interesting to have your comment on how things are proceeding according to that
schedule, what the difficulties might be ahead too. Thank you chair I think
Officer - 0:08:16
it would be fair to say that there has been quite a lot going on in the the
audit world in the last few years and as you quite rightly say there's quite a
lot of local authorities I forget the exact numbers that were disclaimed in
years because basically it's but they ran out of time to actually do the
audit and that is that there's a combination of factors there it isn't
just down to the auditors sometimes it's the local authorities it's the the risk
appetite of some of the auditors as well and the requirements that have been put
on us by our regulators previously. At the moment we are I think we're content
about actually hitting that timetable and just again we've just been talking
to Michelle and she assures me that the draft accounts will be available. I think you used
the word assure. On track. On track, okay. On track. So that shouldn't cause us any major
delays. So I would hope that we would hit the actual deadline this year. I can't see
any problems at this stage, I'm touching wood, as to why that wouldn't be the case. Obviously
last year we were able to give a clean opinion by the due deadline as well. So I think that
we're perhaps cautiously optimistic is probably the better phrase as an order
Councillor Nigel Robbins - 0:09:36
so I never like to say definitively yes. Thank you for that. Are there any other
comments or questions or observations? Len. Thank you chair. Could
Councillor Len Wilkins - 0:09:44
somebody
remind me what we paid last year? It's a hundred and fifty three.
Councillor Nigel Robbins - 0:09:52
You're talking about audit fees?
Audit fees, yes. I think I can tell you it was less.
Councillor Len Wilkins - 0:09:58
Yeah, I can keep going. I'm sure it's very good value for money.
The other question is proposed fee for the IFF 16. Have we got any rough idea what that's going to be?
Councillor Nigel Robbins - 0:10:12
David might know.
Thank you.
Councillor Len Wilkins - 0:10:19
Thank you, Chair.
David Stanley, Deputy CEO - 0:10:23
Just in terms of the audit fee, our work at that is about 10 % less than the current scale
fee, so that scale fee was increased.
In terms of what the additional cost this year will be, that will be dependent on any
additional work required to verify the work that Michelle and the team have already done,
assessing IFRS 16 and any work around IAS 19, which is also dependent on the audit of
the pension funds accounts, which is beyond our control and also beyond Bishop Fleming's
control because that's by a different set of auditors.
But that's part of a process with the public sector audit appointments authority where
any proposal for an increased fee has to be come through to the council to give a
view and that goes off the PSAA for assessment as to whether that is
justified in terms of the additional work and the audit trail that the
external orders are provided to justify any increase in the fee.
Councillor Nigel Robbins - 0:11:25
Thank you David. Well I don't see any other questions or challenges at this
stage, so I think that we are clearly and broadly happy with what's happening at
the moment. So it justifies us bringing that item forward to the beginning of
the meeting. So unless you'd like to stay for any other part of this challenging
and interesting meeting, you're free to go. Yes.
Officer - 0:12:05
Chair, I'm probably going to stick around until about half five and then I have to disappear
because I've got an online funeral to attend. But I know Jonathan has very kindly volunteered
to stay for the whole meeting. So I think just often we get a better flavour of how
the council's operating by staying around and not just sitting through our item, if
Councillor Nigel Robbins - 0:12:24
that's okay. Exactly so. What a good idea. Thank you.
thank you for agreeing to say Jonathan just on the previous question from
David Stanley, Deputy CEO - 0:12:34
councillor Len Wilkins I found the external audit plan for last year and
the PSA a scale fee for 23 24 was 136 thousand nine hundred forty one pounds
Councillor Nigel Robbins - 0:12:49
about fifteen thousand pounds difference this year's okay

7 Risk Management Policy

Councillor Nigel Robbins - 0:13:04
Thank you. The risk management policy, or as we now call it, the risk and opportunity
management strategy, I guess the change of name is designed to encourage people to think
that councils are not merely risk averse, but are also seizing opportunities within
an appropriate assessment of risk framework.
And you should note that under the annual governance statement,
item six is precisely this point, and it's one of the key
points that we need to review the risk management or risk
and opportunity management strategy on a regular basis.
This is the strategy rather than the detailed assessment of risk
report, the register, which will come to us on a subsequent
occasion, but if I can just ask Angela to...
I think, shall I leave Anne to present, or would you like me to?
Well, I don't mind.
If you're here, Cheryl, please.
Thank you very much.
Thank you, Chair.
Officer - 0:14:15
I think you've done my job for me, actually.
She wasn't going to say much more.
So this is the latest version of the Risk and Opportunity Management Policy.
So it basically sets out how we manage risk and opportunities within the Council.
In terms of what's updated, there's been very little update actually in terms of
the previous version, but what it does now reflect is how the Council's services
and how everything's structured following the transition of services.
There's been a review in terms of roles and responsibilities in Appendix 1 that
now reflect what the Council is doing at the moment. So I'll just take questions.
Councillor Nigel Robbins - 0:14:53
In reviewing the paper, I noticed that there is an assessment of our appetite to risk on
page 24 of your papers or page 4 of the report that says the
council's risk appetite level is cautious.
And I thought, I wonder who has come up with this view.
Is there some kind of independent, standard,
and poor agency that independently and objectively
assesses the risk appetite of a council?
I think the answer is no, but I'm going to ask David to comment.
Thank you, Chair.
David Stanley, Deputy CEO - 0:15:45
So in terms of the risk appetite of the council, I think if you take the current level of uncertainty
there is around both internally within the council as we transfer services from publica
to this authority and the prospect of local government reorganization in Gloucestershire,
I think in discussions I have with the chief executives, we both arrived independently
at a view that our risk appetite going forward should be cautious.
And that recognizes inherent risk there is around organizational change, that increased
risk appetite of being creative and aware, I don't think is appropriate given where the
authority is, its financial sustainability position, the challenges it's got in terms
being able to demonstrate that on an ongoing basis.
And the change in both members and officers over the course of the next two years as the
council looks to both make decisions in the short term to support its financial position,
but also in the longer term as it grapples with LGR and those prospects.
I think that leads to the position of a more cautious approach on risk than one where we're
ready to have a wider set of options in front of us, because I think that time limit around
LGR, given this council may not exist on the 1st of April 2028, does mean we've got to
assess those risks more carefully and make informed decisions not just for this council,
but more widely for the residents of the Cotswolds that will continue to be served by a council
in the future.
Councillor Nigel Robbins - 0:17:25
Thank you, David. Does anybody wish to comment on that?
No, I'm sorry.
You're okay. A different question. Okay.
Members will notice on page 29 of this particular report in Annex A, Roles and Responsibilities,
that internal audit and counter -fraud and enforcement
have a direct line to this particular committee.
I do think that's very important because it means those are
areas where we can really exercise an influence.
They will, of course, report to Angela and to David,
But there is a direct line there between those aspects of
investigation and this particular committee.
Yes, hello.
Councillor Helene Mansilla - 0:18:30
Yes, so I have two questions regarding page 29,
that is the annex, roles and responsibilities.
One of them is linked to just the comment that you made about fraud and internal audit,
that is that I couldn't see the reporting lines going to the audit and governance committee.
I know that they are in the same fraction of the page, however there's no reporting
lines, so perhaps maybe reporting lines will be flowing from them to audit committee, but
that's a suggestion.
In terms of fraud, are we saying that fraud is independent? You know what I mean by saying
independent? Do you not report to senior management? Is it a functional reporting line, administrative
reporting line?
Councillor Nigel Robbins - 0:19:40
Councillor Helene Mansilla - 0:19:45
In terms of my line manager, that is David, and at the general partnership that would
be each council I report into the chief finance officer because there is a duty of the chief
finance had to look after public funds and that includes in terms of fraud and error.
So that's who I report into. But I also clearly come to Audit Committee twice a year so it's
completely transparent in the activities that we undertake and if I had concerns about anything
within the organisation I would firstly talk to David as the Chief Finance Officer unless
he was implicated in which case I'd have to go elsewhere and if we had concerns we would
to the chair of audit committee, audit and governance committee together.
So it is independent in that we clearly should be reporting to you directly,
but there has to be some management of who we're dealing with,
what issue we're covering.
I mean, if it was fraud in terms of, I think you're probably focusing more
on internal matters rather than external matters.
If it's external, then it could be any aspect of the council
and any of the services we provide.
So that would be working with each of the service managers.
If it's internal, again, that would be an HR implication,
that would be a risk implication,
that would be a financial implication.
So it's being sensible about who we talk to.
And we've got to manage reputational risk,
we've got to manage financial risk.
But there's absolutely nothing non -transparent about what I do,
and I would always report it back to the committee.
Yeah. Because that will take me to actually
It was going to be my first. It's kind of my opinion or a suggestion.
I can see that, I mean we can all see that some of those functions like the full council, the cabinet, the leadership team,
they are described as having a governing body and also they are engaged in risk management.
So I don't know whether it will be more helpful to clarify these hybrid roles, because
they are a bit hybrid, perhaps by aligning this appendix or, you know, diagram more closely
with the three lines to improve transparency and role clarity.
That is my question in a way.
David Stanley, Deputy CEO - 0:22:14
Councillor Nigel Robbins - 0:22:15
David Stanley, Deputy CEO - 0:22:16
David. Thank you chair. So in terms of what Annex A is setting out is on the left hand side you've got those
areas of the organization, the member side in terms of this committee, the senior management in terms of
the monitoring officer's role, director of governance and development that has that overall responsibility for
risk management and the independence that's provided through
through Southwest Audit Partnership and the Counter
Fraud and Enforcement Unit are two very distinct but separate
parts of that process.
And the council has a statutory obligation to make sure that the
funds it administers on behalf of the public is we're
preventing that risk of fraud.
In terms of the other side of that annex,
that's how in effect the risk management policy,
if I drop the word opportunity, if I just refer to risk
management is effectively managed.
So what we have in place within this diagram, feeding from the
bottom up, is the way in which those risks are identified, how
they're evaluated, and what mitigation measures are in
place.
That all then feeds up to the overall council leadership team
through the strategic risk register.
And that's what comes through to this committee once a year as
the risk scoring, but you're getting updates at other points
in terms of what are the risks that have been identified,
how have they been scored, what's the target risk that
we're aiming for, and are you, as a committee, satisfied that
the mitigation measures that are both in place and could be put
in place to mitigate that are adequate to reduce that risk
towards the target score that's been assessed?
If we're saying as a risk of a particular event, it's been
scored is 20, which is a high risk, but the target score is zero.
But there isn't really much detail in the mitigation.
You as a committee, I would expect to challenge that target
score, and that gives you, I suppose, that assurance that
those operational and strategic elements of risk management
are working effectively.
So the role for this committee on the left -hand side is, does
what's on the right -hand side give you that assurance?
And what the right -hand side is showing you is how that feeds
from the bottom up.
Because if I just said the key risks for the authority are
this, that, and the other, that's done from a sort of
up here level.
You need the benefit from individual service areas that
are working with risk all the time to start raising that
profile of actually there's this particular risk that I
think should be on the strategic risk register.
There's an escalation process for that to go through, and
that's where getting that risk identified and onto the risk
register and understanding what those options are really early
on is part of that assurance that comes through here.
So I think as it stands, to me it's clear where that
responsibility lies.
It's for the right -hand side to manage the risk
management process.
It's for the left -hand side on understanding how that's
working, is that effective, is it providing you as a committee
with enough assurance that that is being managed effectively.
Councillor Nigel Robbins - 0:25:33
I hope that helps.
The fact that internal audit on this diagram, it is only a diagram, and counter -Ford and
enforcement units seem to be floating independently is suggestive that they do have a degree of
independence.
They don't have to operate through the directorate.
And nor do we, if we want to call them in, we can do so,
and they can express their views quite independently.
Not that there should ever be reason to do that,
but that is the, that's the kind of guarantee of independence
that we're talking about.
So it would be wrong if we put lines here, because that,
the lines do imply some kind of control.
Councillor Helene Mansilla - 0:26:20
I can see that they are clear, you know, I can identify the
roles myself, I mean, it's not, you know, big here or anything,
you know, I can see the first line's roles of defense,
you know, project managers, control managers,
service managers.
Those are your first guys.
And I can see the second guys as well, you know,
probably director of governance, council leadership.
But they also counsel the leadership.
It has another role, which is the government role,
because it's setting the, you know, like what he's saying here,
sorry, the tolerance levels, no, sorry, no tolerance,
the risk appetite.
So that is what I was trying to say, that, you know,
they do have those two hybrid roles, you know,
that come together.
And it's not only undoing this, but not managing risk.
And I can see that on managing the risk as well there.
Councillor Nigel Robbins - 0:27:09
Final comment from David.
I think there's one other aspect to the way we manage risk.
So on the right -hand side, on the chief finance officer,
It sets out what my role or the CFO's role in risk is.
So part of that role is I need to assess the financial impact of the
David Stanley, Deputy CEO - 0:27:27
risk position the
Council's got and ensure that we've got those identified, quantified and mitigated.
That effectively involves making sure we've got enough resources set aside to deal with
the risk that we're prepared to tolerate, that risk appetite that the Council sets.
So if the risk appetite was on that far right -hand box where we're taking extraordinary risks,
prepared to lose money, prepared to be challenged around some of that, I would have to ensure
that there's adequate balances set aside to manage that.
Given the Council's financial position, given I suppose we've got limited reserves that
are in place to manage that risk, that's why the risk appetite's been set as more cautious.
and with significant organizational change that plays a part.
But essentially, the CFO role is to have that oversight because actually risk is about money,
be it through fraud, be it through corruption, be it through bribery, or be it through actually
quality of governance, the decision -making processes exposes the council to additional
financial risks.
So that's, I suppose, the support to that is that whilst there are individual officers,
managers, parts of the senior leadership team that will have oversight of risk, there is
that additional role I've got, which is the statutory role that says in order to ensure
we've got adequate resources set aside, that's why I need to have a good oversight of where
risk is.
Councillor Helene Mansilla - 0:29:01
That is the result I was making, that suggestion.
and are we making sure that everybody understand that there
is not only, you know, risk management, you know,
they do have this oversight role, yeah.
Thank you very much.
Councillor Nigel Robbins - 0:29:17
I think we can move on to the next item,
which is the annual governance statement

8 Annual Governance Statement – Action Plan Update

and the action plan there.
I've already referred to item six.
I don't know whether there are any other further comments that need to be made about this.
Who would like to lead on this?
Cheryl, good, thank you very much.
Officer - 0:29:51
Yes, this is the latest version of the annual Government Statement Action Plan for 2425.
So it's color -coded, so grey denotes that the action has been completed and you'll
just see there's a couple of ambers in there and that's not necessary because
the action hasn't been completed it's just it hasn't been completed in its
totality so there's a couple of those bits that will be going into next year's
or this financial year's action plans or carryover. So the two bits around
carryover are relating to business continuity plans so whilst they've been
reviewed annually. We're going to do some more development around that and
reviewing the policy and some of the templates. So we'll roll that out for
next financial year. And then procurement with the new procurement rules going
live. There's training that's scheduled moving forward and that will happen
again this financial year. And then there's ongoing actions in
relation to the peer review. So that it's just that they'll carry over into next
financial year as opposed to they haven't been completed as such. And that's
I was going to add, Chair.
Thank you very much.
Councillor Nigel Robbins - 0:30:54
Could you give us a bit of a refresher on the peer review
and what actions we are still outstanding from the most
recent peer review?
Thank you, Chair.
Angela Claridge - 0:31:11
So the peer review, which members might recall for those
of you on the council at the time, we had a peer review
at the end of 2022.
review. That resulted in a number of actions including one of them being that this committee
was renamed Audit and Governance Committee. There were several actions that came out of
that affecting various kind of services and functions across the council. The peer review
undertook a follow -up. That's a kind of regular thing that they will do. Come back a little
bit later. That was at the end of last year, at the end of 2024. From an officer perspective,
pleased to say that there was some really, really good feedback in terms of
governance particularly, because that's what this committee is interested in.
We have some great feedback around governance but there is actually a report
coming to cabinet in July, so that's July the 10th from memory, so that will give
you an opportunity then to see, you know, in its totality, but just to pull out
some of the headlines on governance which obviously are in my mind. The peers
when they came back were very positive about, I could say, the renaming and the focus of
this committee. They were positive about the training that is put in place for members.
They were positive about scrutiny and how scrutiny interacts and is involved in pre -decision
making. And, you know, the involvement, of course, I believe the best to last, the involvement
of the independent person now with Chris and John when he's in attendance joining us on
committee. So some good, really good feedback, but July cabinet you'll see the report and
its entirety.
Thank you, Jeff.
Thank you, Angela.
Councillor Nigel Robbins - 0:32:47
Do we have any comments or further questions?
Glenn.
Thank you, Jeff.
Councillor Len Wilkins - 0:32:52
It's page 37 at the bottom.
It's got procurement.
And it's just we've got training is scheduled for the new
financial year.
And we've got a toolkit being developed.
So I'm just a little bit worried we've got people out there who
haven't been trained and haven't got a toolkit to help them,
Or am I just worrying unnecessary?
Which I'm sure I am.
Councillor Nigel Robbins - 0:33:15
Angela.
Can I ask you to turn your mic off? That's brilliant.
Thank you. Yes, if I can help with that one, thank you, Councillor Wilkins.
Angela Claridge - 0:33:24
So the legislation changed in February.
So the procurement team, who were the absolute specialists on this,
and they've had all of their training,
Council, you might recall, in March, agreed an updated set of contract procedure rules for our Constitution.
And I know from talking to procurement colleagues, there was a program of training rolling out
for all of us managers.
So like you say, those people who are making decisions coming up in June.
Councillor Nigel Robbins - 0:33:53
Thank you.
Councillor Mansour.
Councillor Helene Mansilla - 0:34:05
I guess that overall in general, by looking at the actions, the ones that have the early
number saying carry over, what measures are in place to ensure that these actions do not
become deprioritised in the next cycle?
Councillor Nigel Robbins - 0:34:28
So, Cheryl, would you like to go ahead?
The action plan is brought back to this committee on, I think it's either quarterly basis, so
that makes sure that we are keeping on top of those actions.
We also do an annual review in terms of compliance, so we do an annual governance statement that
goes out to all managers and staff, and that again assesses whether we're compliant with
governance, and as part of that, that would feed into next year's annual governance statement
an action plan so there's ongoing processes and I say is presented to
yourselves to make sure that we are you know keeping on track and these items
are carried over and delivered
Thank you.

9 Internal Audit Plan and Charter

Councillor Nigel Robbins - 0:35:16
Which is the internal audit. We're starting I think with the action plan.
So, Lucy?
Officer - 0:35:33
Thank you, Chair. Your first item from us this afternoon is the 25 -26 annual plan, which came to the last committee for information.
So really today it's just for committee to sign off, please.
And attached to this report, you've also got a copy of the internal audit charter, which I need to bring to the committee for approval as well.
Councillor Nigel Robbins - 0:35:49
Can I just interrupt say apologies to members who didn't receive the right
annex attached to this particular item they had been swapped around with the
following item online the correction was in fact correct but you do now have the
annual action plan under that particular item okay.
Officer - 0:36:16
Nothing else to add, chair, unless there are any questions to that item on the agenda.
David Stanley, Deputy CEO - 0:36:28
If I can, chair, so for members benefit, pages 73 of their printed copies have the annex
in relation to the proposed internal audit plan which relates to agenda item 9.
So that's where you need to move to, to see the detail for Agenda Item 9, page 73 of your
printed packs.
For those that are using the online version, that has been corrected, so it will follow
online straight after Agenda Item 9.
Thank you.
Councillor Helene Mansilla - 0:37:31
I will refer to the online version. It was page 47. I don't have it on me or with me
because I am not connected to the internet. I believe it was page 47. The plan said something
about being agile, risk assessed and agile, I think, in one of the comments.
And my question was how are we assured that high risk areas like the public art transition
will be delivered early enough to inform decision making and oversight,
rather than being deferred as new risk emerge?
because obviously we are agile.
So when drawing to this, public gun might be the top priority,
but if the audit arrives after key decisions have been made,
you know, the value could be reduced or lost in a way.
Thank you.
Councillor Nigel Robbins - 0:38:40
I think that really gets to the nub of how an internal audit
plan is constructed, doesn't it?
What are the priorities and how are they established?
Would you like to say a little bit about it? It could be you, some of us do understand that, but there are one or two new members here, so that might be really helpful for them if you could explain that.
Officer - 0:39:02
Of course, Chair. When we bring an audit plan together we go through consultation with David, members of the committee, officers, and it's also based on what we know and horizon scanning.
In the audit plan you have in front of you, public a transition is there because I am
a member of a lot of the projects that are already happening.
So that is in our plan and that will remain in the plan for the whole year and for however
long it needs to remain in there because as you say it is high priority.
If something else, there is a big team now below me, so if there is a high priority area
that David wants to bring to my attention or you might want to, I have someone that
can pick that up but the public a transition will remain in the plan until it finishes.
David and I have regular catch -ups on where we are with the plan as well and regular catch -ups
with all officers.
Councillor Nigel Robbins - 0:40:00
David.
Thank you, Chair.
David Stanley, Deputy CEO - 0:40:03
In terms of reassurance, whilst the plan sets out the intended direction that internal audit
will work in in terms of covering off those key audit
areas and risks that have been identified.
If I use the public transition as an example, now LGR is,
local government reorganisation, is going to be an emerging area
around governance and decision making.
So in the regular monthly catch -ups that I have with Lucy
as part of her reporting into the senior officer in the council.
Part of what we do is look to make sure that the internal audit plan and the emerging risks are aligned,
because if there is an emerging risk around LGR, and actually that's around the quality of the decision -making
and governance that the council needs to undertake over the next 12 months,
it would be foolish to stick to the plan and say, well, we said we were going to do the public transition.
So, it's part of an ongoing discussion, and clearly if there was a significant event,
let's say there was a cyber attack on this council, I would expect Lucy to almost stop
doing what they're doing and support that, and that would be reporting back to this committee
in terms of any lessons learned and so on.
So, depending on the nature of what emerges during the course of the 12 months, there's
can we cover that within an existing plan or is it something so significant
it requires a rejigging of the plan to say well actually we're not able to
support this aspect which is seen as a lower risk lower priority because of
this thing coming along but it's in the context I suppose of there is a limited
amount of audit days available but should those risks be significant there
is an ongoing conversation if you had with Lucy around whether or not it is so
significant that necessitates additional audit resource coming in. That's not that
straightforward because Lucy may not have the availability to bring a hundred
extra audit days in to deal with a particular issue, but it's part of that
ongoing regular contact that I have with Lucy.
Councillor Helene Mansilla - 0:42:14
Thank you Lucy, thank you David. So it has to respond to that question, is that
something so significant?
Councillor Nigel Robbins - 0:42:24
I have one comment and one question.
I think the grid or quadrant of risk assessment on page 48
is extremely helpful.
It does help to explain why some items of a wider,
more regional, national issues do get into the mix.
So it's not just concentrating on local issues.
there is a broad attempt to deal with all the things we're
concerned about and worried about.
I think that's very helpful.
The one thing that does concern me is the lack of precision
about the plan, particularly when it comes to ICT audits.
We're already into the new financial and planning year,
And I don't know how far discussions have got,
but ICT and the risks associated with that seem to be so serious.
They have such serious implications that I would like
to see a little bit more detail about what you're actually going
to be looking at and trying to offset in the audits
you carry out.
Officer - 0:43:43
I'm due to speak to John Shorten very shortly,
and it's similarly to conversations with David.
I discussed with John the audits that we might like to do or where he feels there's a, I
hope to say this, a risk in their service provision if you like.
So that's a discussion that I'm going to have with John very shortly.
But we have just completed an audit on the disaster recovery of one of the council systems,
which was successful.
So I'm hopeful that that report will come to the next committee.
Councillor Nigel Robbins - 0:44:15
Thanks very much.
Thank you, Lucy.
David?
Thank you, Chair.
Just in terms of that balance between the internal audit plan
setting out where the coverage will be and having enough detail
for members to get that assurance.
At the last meeting of this committee, there was an exempt
item brought forward on cyber security.
So there is that balance between providing you with the details
within the plan to say this is what we're going to audit, but not providing
too many details to advertise to the wider cyber world that we're about to do
a deep dive into our implementation of particular ICTs. So I think that's where
the internal audit plan needs to be a bit more fluid in terms of understanding
what those emerging risks are as you would have understood from the exempt
the last meeting, those risks are changing almost every day in terms of councils that
have been subject to cyber attacks or there are other retailers, for example, that have
been subject to cyber attacks and there is lessons that the sector as a whole can be
learning from that. So that is a very fast -moving environment where there needs to be that agility
from the internal audit plan to respond to that. So that's where I would probably err
on the side a caution of providing too much detail in the plan but getting that
reassurance from the regular reports that you'll get from Lucy to this
committee that this is what the plan is doing this is how we're addressing those
Councillor Nigel Robbins - 0:46:02
particular issues around ICT. Thank you. We haven't said anything about the about
the about the charter and the mandate I guess not much has changed here has it
Officer - 0:46:18
sorry chair I think we probably I probably didn't bring a charter last year
because we knew there were changes of foot because of the changes in the
standards that we work to so this is now the charter that gives our roles and
responsibilities and yours as a committee and I think you need to sign it
off please chair if you're happy on behalf of the committee.
Councillor Nigel Robbins - 0:46:42
Personally I'm happy with it. Are there any other comments or observations? I know
I think it provides the right sort of framework that we need.
Now as we come to the end of this item, we have to approve the internal audit plan and
the charter and mandate.
So unless there are further comments or questions, I'm going to ask you to raise your hands to
approve what is now actually item 10 of course. Are you willing to do that? Sounds
like it. Thank you very much. Can I also comment that I've been a little bit
remiss because we should have approved the risk management policy of the
call it, back under what became item eight. If you can remember that far back,
and I have difficulty sometimes, then could you also show your support for
that particular strategy?
Well done, thank you very much. I'm sure you were going to kick me under to the
Councillor Nigel Robbins - 0:48:15
table if I didn't get that agreed. This report is the next one which normally excites quite
a lot of interest because you couldn't get your teeth into it. You can understand a lot

10 Internal Audit Progress Report

of the issues especially under the reviews. Over to you again please.
Officer - 0:48:32
Thank you Chair as you say this is the quarterly report that comes to this committee. It gives
an update of the work that the internal audit team have done for Cotswold
District Council. Although it doesn't look as though we've done this much this
last quarter but we have and there's a lot in progress. So you've got two final
reports in your pack tonight which were the procurement card follow -up and a taxi
licensing safeguarding follow -up of which have now been given reasonable
assurances. The summary of those reports are attached and we also continue to
follow up all the agreed actions. Happy to take any questions, Chair.
Councillor Nigel Robbins - 0:49:10
I was concerned originally last year to see that members allowances and expenses
had turned up and it had a middle or limited description. Can you advise us that the system
has now been improved? That would be encouraging if you could.
Officer - 0:49:41
Yes, we continue to follow up with the agreed actions and I know that one of the team members
spoken to the Democratic Services Manager and I'm sure that's not his
proper title but processes big processes being implemented based on our agreed
actions with him at the time of the audit.
Councillor Nigel Robbins - 0:50:05
Could you confirm that please?
I can chair they most definitely have.
And we have two fairly full review reports here, which you did mention.
In earlier discussion, we did notice that there were some incomplete bits of work to
do with procurement card follow -up.
I think David had a comment to make on that, didn't you?
It is happening, I think, but one did notice that there was
some lack of contact, I think, with Lloyd's in the research.
So thank you, Chair.
Just in terms of the procurement card follow -up,
David Stanley, Deputy CEO - 0:50:58
there's a note towards the bottom of page 57 of the
printed PAC, or page 79 of the PAC that's online,
around the trialing the use of virtual procurement cards.
Now, this is tied into another internal audit recommendation
that was made some time ago that I did make a commitment
to this committee that we would follow through on,
which is the position of not having a purchase order,
you won't get paid, and that is being followed through
with the interim head of finance,
with Publica in discussions with Michelle Bird
as the chief accountant in terms of how that's rolled out.
The virtual procurement cards is a service that's offered by
Lloyd's Bank where effectively they provide you or the
individual with a 16 -digit number that acts as a real
procurement card but can only be used for one time.
So if an individual wanted to acquire or procure goods and
services to the value of 100 pounds, 100 pounds put onto this
virtual card, once it's used it's then not required.
It's linked to the no PO, no pay option around ABW because the use of procurement cards sometimes
is because getting the invoice through the system is so difficult.
So I think we're still reviewing that and I know from previous experience,
Lloyds have been changing the way in which those virtual procurement cards work.
I would want to look at this in relation to the no PO, no pay option as part of a package
around how we improve the way the Council procures goods and services.
My preferred route, because it gives additional benefits in terms of commitment, accounting
and understanding what actually the Council might be spending its money on, is to go down
the no PO, no pay route with some limited support from procurement cards.
That's going to give much more in terms of internal controls for us because of the authorisation
route through ABW for requiring goods and services, but also greater visibility of that
spend.
So whilst progress has been slow, and some of that is around Lloyd's as well as us, I
would bring this back into a future committee with an update on the no PO, no pay option,
and how that could be implemented and what the timescales are.
Councillor Nigel Robbins - 0:53:19
Thank you, David.
Thank you, Chair.
Councillor Len Wilkins - 0:53:32
Being on Luddite, I'm on page 77, and the written papers.
I notice we do work on Publica, and I'm intrigued.
Does that mean that we've got all five district councils doing the same thing or do we do
this on behalf of the other district councils or is this just on the public a bit of CDC?
Councillor Nigel Robbins - 0:53:59
That's the first section on core financials.
That's one.
Councillor Len Wilkins - 0:54:04
So thank you chair.
David Stanley, Deputy CEO - 0:54:12
So in terms of page 77 of the printed pack, that's the proposed internal audit plan that
was the previous item.
But what that sets out is that whilst Publica operate and maintain and administer the key
financial system being for us aggressive business world, but there are other elements of that
that are in terms of the wider systems that feed into that, it is only providing assurance
on the Council's side of the ledger and those transactions on the public side of the ledger
that are ours. But it's looking at the way in which ABW, to give its abbreviated name,
is operating and whether the controls in terms of access, authorization, are working effectively.
But that will be for CDC only. Some of the challenge that Lucy has got around doing that
is actually a lot of those pieces of work on core financials apply equally across the
three key partner councils and public as well. But purely the report that comes to this committee
will be specifically around the controls in place for CDC elements of that.
Councillor Nigel Robbins - 0:55:24
Are there any further comments or questions? If not, then we can thank you, Lucy, for your
very good work and your contributions. Thank you very much.

11 Update on Government overhaul of local audit in England

We now move on to the new item 12, update on government overhaul of local audit in England,
for which we've received a briefing paper, much of which reported on a consultation that
the government had with sector bodies and indeed auditing firms.
I'd be very interested because I think it would be unfair for me to ask officers who
are supposed to be independent and neutral for their views about what is being proposed
here, but I'd be interested to hear not only Chris's view about what you think is going
to happen, but also Bishop Fleming.
I assume you were involved in this consultation. Do you understand where the government is
coming from in wishing to take back some of the control that used to be there before the
what was it the audit what was the audit commission the audit commission was abolished which I
recall. I don't know whether you have any any particular views about it. Let's
start in a neutral way by asking you why is this being proposed? What's the
problem? And the next one is will it solve the problem?
Thank you chair. I think I can answer some of that but not necessarily
Officer - 0:57:16
all of
So my understanding is why it's been proposed is because I think everybody
recognised that the local audit system was broken and has been for several
years now. And that's why there are hundreds of audits that have been
disclaimed. We only have a small number of audits that have been
been displaying for a year, but there are some audit firms that have got some that will
go back for many, many years. And that's for a variety of different reasons. Some of it
is because you've got particularly difficult councils who have got lots and lots of issues
that the auditor needs to look into. There's also a lack of capacity in the local audit
regime. I think it's fair to say, I mean we often use the, as audit suppliers, we
use the analogy about moving the deck chairs around. So my background is ex -audit
commission, moved to Grant Thornton and moved to Bishop Fleming. So Jonathan came
from Deloitte. So in effect we are classic examples of how, you know, we're not new
into the local audit sphere,
we've just moved our deck chairs around, if you like.
So, and I think it's probably fair to say
that maybe local audit isn't a sexy area
for people to kind of get into these days.
I think it's seen as perhaps being a bit dry
and a bit narrow.
So, there's a whole host of reasons
as to why the whole system has failed.
And what the government are trying to do
as I understand, is to try and come up with ways to fix it,
and hence what the consultation was actually seeking to do.
Now, we did go back on the consultation,
as I'm sure perhaps Cotswold did,
and I know a lot of local authorities did,
other audit firms did, other interested parties have as well,
and gave our views on whether this would work or not.
I think our view generally is we were very supportive
of what's actually in the consultation,
because I think if we can find a way forward,
it's got to be better.
You know, I've done audit, as people like Michelle will know,
I've done audit for nearly 35 years,
and to be in this situation is, quite frankly,
in my view, disgraceful,
the fact that, you know, audits are just not being signed off.
It's not why any of us got into doing local audit.
We don't want to be in that position
where we're not giving, you know,
not giving the taxpayer the assurance
that public money has been spent in the correct way.
So this is why, as I say, the consultation is trying
to actually address that.
Will it work?
I think we're all hopeful that it will do, and actually,
it will move us forward.
Is it going to be quite complicated to do that?
In my personal opinion, this isn't necessarily
Bishop Fleming's opinion.
Yes, it will be.
I think there are quite a few hurdles.
I think if you then crunch it together
with local government reorganisation,
there's quite a lot going on in the sector,
and it is going to be quite an interesting few years
to get to the other side of it.
But the fact that actually something is happening
and the issues are being tackled,
I think is very positive.
Councillor Nigel Robbins - 1:00:49
That's very helpful, actually.
Very helpful and really quite interesting.
I wonder if the responses from councils mirrored the responses from the accounting firms or
the auditing firms. I suspect there's a lot of overlap but they weren't exactly the same
in terms of assigning responsibility for the problems or indeed looking at the solutions.
From my point of view I would say yes, the system is broken, it needs fixing, but I would
thought set up the machinery to get it fixed and then back off a bit, whereas I suspect
this could be just another permanent layer of accountability and bureaucracy, but we
shall see.
David.
David Stanley, Deputy CEO - 1:01:51
Thank you, Chair. I'll just give you a perspective. So I think more widely, the system wasn't
working. So there were about 1 ,000 public sector audits where an opinion hadn't been
given that at the backstop date of the 28th of February 2025, some of those councils got
quite significant audit bills for the auditors not reviewing their accounts
and providing an opinion that the factory said we've not looked at those
accounts. So clearly something needed to be done. What has been put in place is a
series of measures that transfers some of the responsibility for the way in
which local audit operates to the new local audit office which is in no way
bears any resemblance to the Audit Commission that might have existed in
some format several years ago.
That will make a significant change in terms of how the
auditors approach the financial statements and the
value for money judgment, because up until the
establishment of the local audit office, that has been
determined by, and effectively, the regulator
that oversees the whole of audit for both the public and
the private sector.
So that's kind of tied the hands of auditors.
But if I link this back to an earlier question of what do we
pay our auditors and we pay 150 ,000. Go back four or five years we were probably
paying something close to 40 ,000. So the answer to this is perhaps the backlog
and I suppose the capacity within the system is because with the abolishment
of the Audit Commission there was reduction in the cost of audit that may
have led to the position we're in. That can't go forward and I've spoken to
other CFO colleagues over periods of time and would sooner have a higher audit fee payable
from the outset and the certainty, for want of a better way of putting it, that those
audits will get completed than paying a relatively low fee and being in a position where an audit
might take two, three years to complete because those audit firms haven't got that resource
available because they're not able to reward staff and show career progression
if actually all they're gaining out of that is a relatively modest fee. So I'd
sooner pay more upfront and have the certainty that comes through. So part of
the response has got to be investment into the local audit sector and part of
that response from MHCLG was establishing principles for some in -house
provision which of course isn't like what we had with district audit and the
the Audit Commissioner at all.
Councillor Nigel Robbins - 1:04:38
Thank you. Further clarification. I mentioned you, Chris, because you only have, you work
in the private sector, and I imagine that you'd be aghast if audits were never completed
year on year.
Christopher Bass - 1:04:57
Yeah, no, you're quite right. I mean, coming into this independent role was my first insight
into public sector finance and aghast is a good word. So it's not surprising that there
is a level of reform. So I now suppose we watch closely and try and influence where possible to
make sure that the reform not only approaches or attacks that from a high level perspective,
but actually works on the ground as well. Otherwise, what we don't want is additional
layers of governments that aren't actually adding any value. So yeah, I want to watch.
Councillor Nigel Robbins - 1:05:36
Thank you for that. I think that statement should be written down in stone or marble,
actually. Well done.

13 CFEU Update Report (RIPA and IPA annual update)

Officer - 1:06:24
Thank you, Chair.
Yes, this is the update from my team regarding the overview of the work that was delivered last year.
I outlined at 1 .3 what our focus was regarding last year and that was around grants because the Council now administer a number more grants than we ever used to before.
So that policy is just about finished,
but the supporting toolkit for the staff is finished.
So we're starting to roll that out to teams
who are putting grants, applications, policies,
new schemes, et cetera, together.
So supporting them with some general verification tips,
things that we should have in our application forms, et cetera.
This year at 1 .4, we're looking at supporting the procurement
team because of the new act, the significant risks around procurement, so how we can better
support that need for more transparency around how we procure everything. Whoever is touched
by that area, we need to make sure that they understand their obligations, et cetera, so
we'll do a bit of work with procurement for that.
At 3 .2 the Gloucestershire webpage, that's the webpage that we're working on with the
NHS, with the police, trading standards, victim support about fraud generally.
So trying to bring together all the ways in which you can report the different types of
fraud, how as a resident or a member of staff, anybody can get advice on support if they
are a victim but also it will be rather localized so the sorts of things that we
are seeing within Gloucestershire so we can better inform our residents about
how to avoid those scams etc nearly finished so we should have a launch date
and then that can be rolled out. 3 .3 I touch on business grants as I always do
five years in the in the making we're still transferring the debt over that we
that we have recovered and I have put in there that the liability transfer debt
date has been extended so what I will do is clarify that that isn't going to
affect anybody that defaults on a payment plan after that date because
clearly we don't want to have liability for those debts if somebody does stop
paying so we'll make sure that's sorted. 3 .5 touches on the work we do
around the National Fraud Initiative, so that's your matches relating to council tax anomalies,
housing anomalies, so some figures there for revenue and for loss avoidance. We completed
a round of training to support all of the enforcement officers across the whole six councils,
all the partnerships, so that's making sure that they're happy in terms of criminal investigations,
good evidence gathering, witness statements, disclosure and also RIPA, so surveillance and
how we undertake that, the rules and regulations.
We undertake a review of everybody's housing waiting list,
so your results are in there,
Cotswold has been recently completed.
And then I've given some more detail this time
around why we do that, what that means,
and the figures across Gloucestershire for the housing list,
and why it's important that we make sure
that the housing list is only those that need housing
to avoid emergency housing costs,
and to make sure that the families that need the houses get it.
3 .12 onwards refers to our reactive work, so that's our supported bless you.
Bless you.
Bless you.
Oh bless you.
Good day, I'm doing alright.
That is relating to our work with all the regulatory enforcement teams where they refer
matters to us.
We undertake a review, the investigations relating to your council tax reduction scheme
independently of the Revs and Vens team, so they refer and we work on those.
Also details around any staffing matters and code of conduct investigations at 3 .18.
So that's all of the reactive enforcement that we receive.
And then 3 .19 onwards is your annual update regarding Ripper and IPA,
that is around surveillance and how we acquire communications data. We do have
the 3 .26, the figures around what applications have been put in, but they
relate to overt activity. So whilst that wouldn't be Ripper, our internal
procedures dictate that the staff still complete a form and go through the same
checks and balances for any activity, be it covert or overt. Happy to take any
questions.
Councillor Nigel Robbins - 1:11:20
You mentioned 3 .18 Emma, tantalising but I think we're going to be discussing that later
aren't we?
Tantalising indeed.
Indeed yes, that will be under item 15.
item 15. Do we have any questions of Emma while she's here? I will say I attended a
meeting I was invited to when Emma and some other members of the team I guess
had a visit from the cabinet office from a an extremely senior
a senior person called Mark Fiesman, who is chief executive of the Public Sector Fraud Authority.
So a very important person and we had some quite interesting discussions but
omitted to mention that he was very complimentary indeed about the CFEU
unit that operates on our behalf.
So I don't know whether you found that encounter useful
or helpful, but it was, I felt much better after it
than before, so I was really rather impressed by the
reputation you seem to be gaining.
Did you find it useful or helpful?
Officer - 1:12:54
Yes.
I think it's leading a bit of a way with, for myself
and colleagues who also run units like ours across local government to raise
the profile and the requirement for a counter -fraud provision in local
government. It's not mandated, I believe strongly it should be, so we're feeding
into the Public Sector Fraud Authority which is the Cabinet Office on areas
that affect local government and how they can better support and oversee and
manage that. So yeah, really really positive for our area in local
government.
Councillor Nigel Robbins - 1:13:31
Councillor Helene Mansilla - 1:13:35
Just as a general overview of the report, but in particular you are taking points 3 .4
and 317 and lastly 3 .1. We have recovered over 100 ,000 through fraud investigations
and dismissed a staff member not facing prosecution. That one there.
We said that we are confident that our internal controls and whistleblowing systems are strong
enough to catch these diseases early and stop them before they close, or lose.
In terms of that particular case, that was about somebody with multiple jobs and there
are lots of processes in place. This actually was generated by the National Fraud Initiative,
so every member of staff's payroll data is sent to the Cabinet Office each year for every
council and their data is compared. So if you have two jobs in two councils, that will
create a match and we'd get it back to have a look at. What I want to do is have a look
at how we also include agency and contractor payroll data to give an even more robust delivery.
However, that clearly involves a lot of work with those agencies
because of privacy.
We've got to update privacy notices, et cetera.
But I think it's important because it is becoming a much
higher risk.
You've probably seen in the press there's been more and more
cases of that being undertaken.
And the world where we can use laptops at home obviously adds
to the risk.
However, there's also work we can do internally to make sure
that we're managing our staff and we know that they're there
doing a job for us and they're not off doing other things.
So yes, there are things in place.
But what I also always say about generally
is you can't mitigate dishonesty.
If somebody is going to be dishonest,
they will be dishonest.
We can just do the best we can to robustly go after cases
and proactively detect.
And in that case, as you say, it's listed in court.
So we are pursuing it.
Councillor Nigel Robbins - 1:16:01
David would like to add a comment, I think.
David Stanley, Deputy CEO - 1:16:05
Just in terms of the position of counter -fraud enforcement unit, so it's counter -fraud.
So, there's an anti -fraud and corruption policy that they're responsible for.
It's on the Council's web page.
So, our approach is to prevent fraud from taking place in the first instance.
But if fraud is identified, there is a rigorous process that that team follow to investigate and ultimately lead to prosecution if that's required.
Part of that role is for Emma's team to, I suppose, educate the
wider counselors to where those fraud opportunities might exist.
Emma probably won't mind me saying so.
There's an excellent slide in some of the presentations she
gives about a character called Dodgy Dave, no relation to me.
Dodgy Dave might start doing something in terms of fraud, but
then when you follow all the things that Dodgy Dave has been
involved in, there's all sorts of things, and Emma will probably give you a better illustration
than me, but say Dodgy Dave is identified as having committed housing benefit fraud,
but in doing so he's living in a property that he shouldn't be living in because it
turns out permission, which is then sublet, turned into an HMO, it spirals.
So that education of the types of fraud that an individual can commit is part of that prevention
measure, so it's just ensuring that all staff and the council are aware where those risks
are, and particularly on earlier items, one of the big areas
where fraud can be prevalent is around procurement fraud,
and that's one of the key risks that all organizations have got.
And it's not just fraud, it's also the cybersecurity
positioning.
So if we haven't got robust controls in place to prevent
fraud, we might not have robust controls in place to prevent
that type of activity where an external supplier is used as the
into the Council, so it's making everyone aware that there's multiple issues, that
fraud covers not just the bit we're working on in our individual service areas, it extends
much further.

14 Whistleblowing Policy

Officer - 1:18:44
Thank you, to try to make it easy to see amendment wise and not provide
a ghastly track change document, which you can imagine doing this
across six councils is like Joseph's Technicolour Dreamcoat. We
therefore bring all the amendments together and give you the new stuff
that will be read and that will be deleted is struck through. So it
It hasn't had a huge change. A lot of it is spelling or wording or just explaining some areas in a more rounded fashion.
We have got rid of that acting in good faith, so it's just now about reasonably believing that you're reporting something of concern.
And then the attachments hopefully will be more helpful to, one, the staff so they don't have to read a 14 -page policy
if they just want to see very quickly what would happen to a referral.
But what we've also introduced is that helpful information for those that
receive a whistle -blowing allegation, because I think that's sometimes a bit that's
misunderstood. Is it whistle -blowing and how do you deal with it and what do you do?
So trying to educate those that may receive a whistle -blowing allegation
and how they deal with the matter. So yes, it's
had a refresh and obviously is now going through the
motions of the six councils and public for approval and adoption. Happy to take any questions.
Councillor Nigel Robbins - 1:20:16
Councillor Len Wilkins - 1:20:18
Councillor Wilkins. Thank you, Chair. Sorry, I'm nit -picking.
Page 138, sorry, 139, you've got the headings of Publica, CDC, Forest, West Oxfordshire.
Is this just for us or are we sharing this across our former colleagues?
So it's for the three councils and Publica as per the bit at the top, yes.
Okay, fine.
And the other thing, top of 141, occurring with this council or its wholly owned company Publica, do we own Publica?
Councillor Nigel Robbins - 1:20:59
I think we do.
It's what's called a tech company.
We do.
We do.
It's a public company, but we own it.
We are one of the shareholders.
We are one of the key shareholders.
The most important shareholder.
Naturally.
Councillor Nigel Robbins - 1:21:29
I guess, Emma, the key to any successful whistleblowing policy is the security of anonymity you can
offer to the whistleblower.
I mean, so often cases don't come to court in the police, not necessarily to do with
company or council behaviour, but sexual violence in particular, where people are afraid of
reprisals or they don't think they're going to be believed so very few
prosecutions in fact take place that would you agree that really is one of
the keys to the success of a policy is giving that real absolute reassurance
Officer - 1:22:14
which is mentioned on page 143 yes I think it's really important that we
support staff to raise any concerns and not fear the repercussions of doing that.
But also to be realistic about sometimes we will need them to identify themselves to gather
more information and it may be that we can't protect their anonymity for whatever reason
if we wanted to pursue matters, but where we can, I mean, clearly a whistleblowing referral
would never be disclosed to anybody and it's only as the matter progresses that we would
always liaise with any whistleblower about what happens next and what we would need to
do, et cetera. But yeah, it absolutely encourages people to come forward.
Councillor Nigel Robbins - 1:22:55
Councillor Helene Mansilla - 1:22:58
Hi, Len. Thank you, Chair. Are we assured that the
policy is actually being used and the staff feels informed and safe enough to speak up?
I think so, yes. I mean, I have certainly received
whistleblowing allegations.
What I am really careful about is promoting and publicising
Officer - 1:23:24
that because my view is that even that starts to undermine
the anonymity of what we are receiving and what we are doing.
So, yes, I have received whistleblowing allegations
and would deal with them appropriately.
And we have just done the promotion,
the campaign to all staff internally
about where the policy is and that flow chart, et cetera,
to support them.
I think it's about who, it's the confidence in who you're
reporting to.
That's the key for me.
It's making sure people have confidence in who they talk to
and that things do happen as a consequence
of disclosing concerns.
Councillor Nigel Robbins - 1:24:00
Yes, of course, there will be occasions where information is
given about somebody's behavior and that person draws
a conclusion that they know who it was from because they worked
so closely, only they could have known about it.
That's, in that case, anonymity is not possible.
David?
David Pembroke.
Thank you, Chair.
I was just going to, in terms of that particular question,
David Stanley, Deputy CEO - 1:24:24
point out on page 149, a very minor change that's been made
to the language, but I think helps members understand why
it's important, language is important in the policy.
So it says, a whistleblower, in red, previously was an
I think that subtle change is about giving staff the
reassurance that they're being treated as a
whistle -blower, not someone that's grassing someone up
or putting someone in.
And it's the treatment and the culture that then
creates that actually whistle -blowing is part of
every employee and every manager's responsibility to
treat properly.
And those roots into whistle -blowing has set out
the policy of really important, that it gives
those staff members the confidence that those referrals will be taken in confidence, will
be looked at and assessed. But really that language change is really important because
it's indicating that you're not informing on someone, you are whistleblowing, which
is part of the whistleblowing policy and process.
Councillor Helene Mansilla - 1:25:27
Definitely, thank you David. The tone at the top.
Councillor Nigel Robbins - 1:25:42
If there are no further questions or comments, could we have your support, please, members,
for this to approve this new policy, this revised policy?
Thank you very much.

15 Annual Standards Update

I'm going to hand over to Angela now for the annual standards update.
I will read out, however, if I can find it.
If it is checked, that helps you.
That's the one? Thank you very much.
I can leave this still afterwards.
Oh, sorry, Len. I beg your pardon.
Councillor Nigel Robbins - 1:26:34
You do have an interest. You declared it.
And you can stay in the room, Councillor. Thank you.
And I don't think we'll be voting on the behaviour of those particular councils either.
Shall I read this now? If you don't mind.
Yes, this is about the earlier council wasn't able to make an appointment as it were for
the Standards Subcommittee, the Hearings Subcommittee.
The recommendation here is that Audit and Governance appoint three members of its committee
to the Standards Hearings Subcommittee in accordance with political proportionality
and the wishes of political groups. Now, this would be two Liberal Democrat members and
one Conservative member. The Liberal Democrat members, as evidenced, are myself and Helene
Mansella. And the Conservative member is Len Wilkins. So I thought you'd find that information
useful does it need to be approved you can certainly yes yes without without
that there would be only one person voting okay please proceed thank
Angela Claridge - 1:28:07
you
Thank you very much, Chair.
Committee, this is your annual standards or code of contact update report that you receive.
Essentially, it covers a number of points.
I'll just draw out some of the key themes for you and then happy to take any questions.
It provides you with the numbers of complaints and some headings around where those complaints
are coming from and the allegations relating to them.
It also gives you a general update on what has been happening in the last year.
First thing to point out is that for the second year in succession there are a considerable
number of Code of Conduct complaints.
Now the report that is way below the number of, let me call them, grumbles and grievances
and inquiries that I and other colleagues receive in relation to code of conduct allegations
against Councillors, but these are the ones that actually make it through as a formal
complaint. So 39 last year it was 40, the year before that it was two. So it gives an
indication of how, just what an increase there has been in code of conduct complaints. Now,
what I should say is these are predominantly against town and parish Councillors of which
we've got about 600 and odd in the district so there are a lot. Now I always
sit here and talk to you about you know the bad examples and I wouldn't wish to
color everyone's judgment there is some fantastic work going on there about town
and parishes going on in town and parish councils. And so first of all picking out
the numbers secondly the themes so I just talked very generally about the
So bullying and harassment continues to be a theme.
This is both allegations from counselor to counselor,
from members of the public and from staff.
As I say, predominantly town and parish council staff.
Failure to treat individuals with respect.
Failure to declare interests.
And I suppose the other theme that we've started to see
more and more of is the increase in the complexity
and multiple allegations.
So, it's not just one allegation against a counselor, it's multiple allegations and complaints
are becoming more lengthy.
I think another couple of points I'd want to update is that, you know, the code of conduct
applies.
It doesn't matter if you're a district counselor, a county counselor, or a town or parish counselor.
Only applies when you're acting in your official counselor capacity.
But that can be a really gray area.
And many members of the public will think you are a Councillor 24 -7.
So you'll see on the, in the table that there are a lot of allegations that come in as a
formal complaint but are then dismissed and don't go past any further than the initial
assessment stage.
And that is predominantly because that individual who was subject to the complaint wasn't in
their Councillor capacity at the time that whatever it was happened, the incident.
But it's grey.
It really is grey.
And when counselors sometimes go on social media,
it's very difficult to know what hat they're wearing.
I think the other point that I would say is I'm increasingly
seeing code of conduct complaints used as a weapon.
So what I mean by that is that if somebody wishes to put
no finer point on it, have a go.
Sometimes they will, complaints that I've seen might be
tit for tat or, you know, used in that sort of way.
So that's a kind of whistle -stopping you can see in the report in terms of the year ending
31st of March 2025.
As Emma and the counter -fraud update in her tantalising update, I think it was the word
the chair used, there are more and more complaints that are going through to the counter -fraud
team.
With the numbers that we're receiving, the numbers that are going for investigation,
and the length and complexity of some of these, this is very resource intensive now.
Okay, so then moving on to what else has been going on in the last 12 months.
So I pull out a few headlines.
So something called Operation Forward, which is a government initiative about the personal
safety for councillors.
It includes those in public office and it is aimed at councillors.
and some of you will have attended the briefing that we had earlier on this
month which with Inspector Simon Elson of the Gloucestershire Constabulary who
covered a number of areas of interest in relation to policing. And I'd also like
to pull out at section 6 I talk about the government consultation on reforms
to the standard system. So the current system that we've got has been in place
so when I say we this is not Cotswold this is across all of local government
It has been in place since 2011 and it came in with the Localism Act.
The government issued a consultation just before Christmas when they asked a number
of questions that would have gone to the political parties.
It went to lots of organisations who had the chance to respond to that.
So what I have included to give you a flavour of the responses, we haven't seen a summary
of them all.
the consultation closed at the end of February,
is I've included the response from the Committee
for Standards in Public Life.
They are independent to central government,
but they do advise the Prime Minister,
so they're in an absolute key position to respond
on how they feel about how we currently manage standards
in the public sector.
So I thought that might be helpful background for you,
because they raise a number of recommendations.
And just to say whether this is going to turn into some work, some legislation changes,
I would envisage so.
But we've got no news or timescales regarding when that might happen.
You'll see that in the consultation response from the Committee for Standards in Public
Life, they talk about a standards committee.
Now, at the moment, all of those responsibilities sit with yourselves, Disorder and Governance
Committee.
So a lot going on and this is increasingly an area of concern.
You've heard me say this before, anything you can do as district councillors, sometimes
you are double -hatted as Councillor Wilkins has raised, anything you can do to just help
improve when you're talking to your town and parishes if you have any in your district,
Anything you can do to work with them improving conduct is fabulous.
But as I say, I always come to you and talk about the cases and the increasing cases,
but there is also an awful lot of really good work going on.
I just see in here some of the stuff that's not so good.
Jeff, happy to take any questions?
Councillor Nigel Robbins - 1:35:05
Thank you, Angela, very much.
Councillor Wilkins.
Sorry, it's not a question.
I just want to say thank you to Angela for her help this year.
It's been greatly appreciated.
Thank you very much.
Yes, I would expect the members of the Standards Subcommittee, wherever possible, to pour oil
on troubled waters to suggest mediation where perhaps not necessarily anything
other than personal matters which divide people on councils. It's often not, as you
suggested, it's often not, it's their personal behavior when they're not
actually councillors that is the cause. People say, well you're a councillor, you
ought to behave in that particular sort of way. Well sometimes that's reasonable,
sometimes it isn't but it's off the cause I think of conflict but yeah
that's got to be our watchword I think trying to pour oil on troubled waters.
I'm pleased you're willing to take part then obviously not in your own particular
local circumstance that wouldn't be right but in some of the others that
would be really helpful and then also.
Yes.
Councillor Helene Mansilla - 1:36:26
Just to make a comment, I mean 4 .6 is extremely worrying as it says.
When you read revenge or to disrupt processes because of planning or personal related issues,
This is page 4 .6 of page 162.
The word revenge is extremely boring.
Considering that this is not a paid role, the councillors don't get a salary.
Councillor Helene Mansilla - 1:37:13
Councillor Nigel Robbins - 1:37:20
Please.
Angela Claridge - 1:37:24
I mean, revenge is a strong word.
You're absolutely right.
But I think if you saw some of the complaints that I see and hear about, you would realize
that it's perhaps, I feel that, as I say, it's increasingly being used as a weapon.
And we know that particularly in Cotswold District, planning is a very emotive subject.
It is in all parts of the country.
And I do see it used to I mean, they're completely separate processes.
If there's an issue how planning is handled is completely separate to the code of conduct.
But I think sometimes there is a view that and I'm talking about as I keep saying a very
small number, but if there is an issue with a planning application, maybe a way of derailing
it is to raise a code of conduct complaint. Maybe it's right to raise a code of conduct
complaint, you know, but I see both used.
Councillor Helene Mansilla - 1:38:23
Thank you, Anja. That is what is worrying, but it's coming from you. You're using those
And for you, as a very composed officer, to use those words is worrying me because I know
that you basically have to use them because you're forced to use those words because that's
the reality and that's worrying.
Councillor Nigel Robbins - 1:38:53
I don't know if you've read the letter from Jim McMahon.
To Jim McMahon.
To Jim McMahon, no, that's right, from the chair of the committee, that's correct, yes.
I must say there's an awful lot of good sense in that, and there's some very good recommendations.
One of which is the question of how many councils in our area have not actually adopted a code of conduct
and if there is any kind of correlation between that and the incidents you're seeing.
Angela Claridge - 1:39:26
Every council, town or parish, they've all got a code of conduct.
So, I believe over, I mean, we've had to have them since
2011, and I believe that, got no reason to think that they
haven't all got one.
I suppose what I might say is that perhaps some of them
haven't been looked at for a while, but they've all got one,
you know, I can 99 percent say they've all got one.
Councillor Nigel Robbins - 1:39:55
What we do in this council when new members come in is we have
compulsory training on the code of conduct,
quite lengthy as it is, nevertheless,
I wonder if that is one of those things
that just doesn't happen when there's a recirculation
of members, new co -opted people come on to parish councils,
they don't go through any kind of induction in that way.
Because I suspect you're right, they have,
In some cases, they've not been looked at since 2011.
Councillor Nigel Robbins - 1:40:31
And we encouraged parish councils to adopt the Gloucestershire model, didn't we, I think?
Angela Claridge - 1:40:42
And some, you know, some, now, you know, the National Association of Local Councils, who are the professional body for town and parish councils,
They have their own model code as well, which is very similar, and some have adopted that,
and that's a really good policy.
So I suppose perhaps the plea here is for any of you when you are visiting your town
on parish councils, as you do periodically, is, you know, if the code of conduct, if you
can't recall it being updated in the last perhaps three or four years, maybe it's time
to have a review.
Councillor Nigel Robbins - 1:41:20
Any other comments colleagues? Thank you very much. Thank you chair. We need to we need to approve don't we?
No we just we voted on it and we've noted it that's quite right okay.
Councillor Nigel Robbins - 1:41:38
So over to David I think for the
draft accounting policies to accompany and support the statement of accounts.
Thank you, Chair.
David Stanley, Deputy CEO - 1:41:47
I'll just do a very brief introduction to the report.

16 2024/25 Draft Accounting Policies

Michelle Burge, the chief account has worked very closely with Andrew Moran on these accounting
policies, and I'm sure she'll be more than happy to answer any detailed questions members
have on those policies, which are reproduced in full in Annex A of the PAC.
Very briefly, the Council must set its accounting policies to
enable us to provide our auditors and the general public
with a set of accounts for the financial year 24 -25.
It's best practice that this committee, i .e.
those charged with governance, receive a report that sets out
what those accounting policies are, what's changed, give you
an opportunity to review and challenge those and ask
questions and then ultimately to approve those.
So in terms of what's changed since last year, Handley, section four of the report on page
176 sets out three main changes that I'm sure will help RUDAs of the Council to understand.
Employee benefits is essentially a change because of the public review.
employee benefits in terms of the accrual that we need to make to recognise the value of unused leave.
So, a staff member has got unused leave at the end of the financial year and has a value attached to it.
That accounting adjustment was made in the public balance sheet in 23 -24, bringing some of those members of staff across to the council under phase 1.
Some of that will now take place on the Council's balance sheet.
So that's that change in the first bullet point.
Second bullet point is what I refer to in previous Treasury Management reports as the IFRS 9 statutory override.
That's effectively been extended for a period for historic investments the Council's made in pooled funds prior to the 1st of April 2024.
So that's extending the treatment of that in the accounting policies.
The third and final point refers to everyone's favourite new IFRS, IFRS 16 and accounting
for leases.
And you would have heard Bishop Fleming in their introduction to the external audit plan
make reference to understanding the extent to which the council might have leases that
need to be accounted for in a particular way.
So that's set out in that change.
but the entirety of accounting policies are set out in Annex A that do run on for quite a few pages,
but happy to take any questions members have.
Councillor Nigel Robbins - 1:44:33
Do I take it, David, from reading that paragraph about leases,
that if we had a lot of visas, it would actually be quite a
complicated procedure, because it seems to me, if they're
analyzed to determine whether they convey the right to
control the use of an identifier, there's an awful
lot of subjectivity in that, isn't there?
It could be very time consuming.
Am I right?
Am I a lot?
Officer - 1:45:12
I think most of the work is around just deciphering the rules and trying to identify any leases
or contracts, even if it doesn't have to be a lease, that we have and then deciding whether
they have any impact.
So for us a lot of the work was just emailing out to managers, reviewing our accounts at
the moment and just identifying any potential leases like that.
And actually, after going through all that work, I think there was only one for a printer.
So that's the... And that probably would... It's only because it was a new lease actually,
and it probably would have been under the old arrangements anyway, recognised on our balance sheet.
So it just means that a printer will now sit on our balance sheet under our property, part and equipment,
and then there'll be a correspondence of liability on the lower half of the balance sheet.
So it's quite simple for us.
There's not that much to consider.
It's a fairly straightforward lease.
But I imagine in larger authorities it's probably more
around identifying things that they don't know about or leases
where there's not actually a payment.
There might just be a peppercorn rent.
Councillor Nigel Robbins - 1:46:17
Officer - 1:46:18
I mean, I'd echo that.
And prior to a number of local authority schools turning into
academies, some of the challenge when the IFRS standards were
David Stanley, Deputy CEO - 1:46:30
first introduced the touch -down leases was that a number of local authority schools had
leases they didn't know anything about at the center.
And that's particularly around multifunction devices, printers, IT equipment.
So actually where we are now with the introduction of IFRS 16, some of that work was done in
2009, 2010 when we moved to an IFRS basis of accounting.
And some of those questions were at the time, if you take the waste and recycling fleet,
if that's effective, what's the effective control of that fleet and does shoving a Cotswold
District Council badge, logo, coat of arms on it create the conditions for a lease, the
way in which that lease is managed through, you know, the council owns the vehicles and
lease them through to UBCO and then that gets charged back to us.
But you've got to put the work into understanding the nature of the relationship.
So even if you end up saying there's only one item, there is a lot of work in the process
of identifying that, that then Bishop Fleming will come along and test in their usual way
as part of their work on the financial statements.
Councillor Nigel Robbins - 1:48:13
I always find depreciation an interesting issue.
Could you explain to me, because I don't know,
why investment property is not depreciated?
Are you able to, yeah?
Councillor Helene Mansilla - 1:48:54
Let me take you to the relevant pages first.
Page financial instruments, that is page 186.
referring to is on page 186.
And Lisa's on page 190.
Are we confident that the changes, especially those two, obviously, the new lease accounting
rules and then of the pooled investment override had been fully considered into our 24th, 25th
statement.
I think we have been through a really thorough process in identifying all the arrangements
in terms of leases and our ballots from the Commission and Jonathan will be unsure of
I'm not going to say any more mention of the common diaphragm that seems to be recognised.
And then, sorry, the other questions around that?
Well, one is the financial statement, sorry, I'm sorry.
Councillor Helene Mansilla - 1:50:21
The one is the financial instruments, that is the pooled investment override.
Thank you.
Councillor Nigel Robbins - 1:51:01
David Stanley, Deputy CEO - 1:51:02
David. Just in terms of the statutory override on pooled fund investments
that's something that's been included as a risk in the council's medium -term
financial strategy for the past two years because the date that was
originally scheduled for that override to end was the 31st March 2025 which
would have meant for the accounts that close this time next year we would have
had to have made provision for whatever that loss would be.
And that was mitigated by the council transferring
some of the additional treasury management income
we were earning on our treasury management investments
to an EMR reserve to mitigate the position that
could have happened, which is if those pooled funds,
the assessment of their value was half a million less,
we would have had to put half a million of reserves
into the general fund to balance that out.
So, by the extension of that statutory override, that takes out that risk.
But if the Council decided to undertake a new set of pooled funds and buy some new ones,
that wouldn't be covered by the statutory override and we would have to make that provision.
But that would be part of any Treasury management decision that the Council would undertake.
And there is no plans currently to increase our holding of pooled funds, given the risk
there is a statutory override not applying. I think we're comfortable that
given the date that that statutory provision has been extended to that
doesn't put the authority into a difficult position so the accounts can
be produced with that in mind and we're not then having to recognize that
through a transfer from earmark reserves back into the general fund should there
have been a loss at the point the balance sheet was prepared.
That's being considered given the extension that's
being made by the government.
Councillor Nigel Robbins - 1:53:03
Can I ask you what the consequences would
be if we didn't approve the statement of accounting
policies at this point?
David Stanley, Deputy CEO - 1:53:19
I'm asking a very difficult question.
As the committee decided that you hadn't received adequate explanation of why the accounting
policy said what they were, that would make it very difficult for officers to produce
a set of accounts.
And I think it would be something that we would need to reassure you in this meeting
to get you to a position to approve the policies, because in a sense, the policies have been
drawn up, drafted by Michelle and the team based on CITFAs guidance, any legislation
in place from MHCLG.
There is some discretion in those policies in terms of where we might set the limits
in terms of, for example, we seek to capitalize expenditure above 10 ,000. The view might be,
well, why is that 10 ,000 and not 11 ,000? But generally the accounting policies are based
on what the SITFA code, to give it a shortened title, is the SITFA code on local authority
accounting sets out, which whilst is guidance we must have due regard to, and that's where
our external auditors would be looking, are we, are our counting policies
complying with that code and mindful of anything MHCLG. So I think it would be
difficult if this committee said no we're not approving those policies but I
would be encouraging further discussion to understand where those issues were
and trying to resolve that in the meeting.
Councillor Nigel Robbins - 1:54:55
It might seem perverse because I can be quite perverse but I think in asking
that question, I'm really suggesting to the committee that this is quite important. In
other words, you can't really prepare the statement of account and you certainly can't
submit it for approval or receive the audit findings and send off the letter of representation
unless we have actually done this first step of approving the policies.
Michelle.
Councillor Nigel Robbins - 1:55:47
But the other significant change, Isabella, is that the personnel of the committee changed
And that could change the whole dynamic of it really.
Councillor Nigel Robbins - 1:56:31
I imagine they're online, are they?
Is that true?
Or...
I think it would be useful to know, yes.
I mean, on the face of it, this was quite a long agenda, but so a short agenda doesn't
necessarily mean that it will be a short meeting, but if you could just tell us, that would
be useful, I think.
And then perhaps you can just post it to us.
Yeah, absolutely.
Because we don't appear to have it.
Do you want to pop off your mic?
So, sorry.
And I'll pop off.
Angela Claridge - 1:57:27
So for the next meeting, which is the 14th of July, we currently have on the work program
the treasury management out turn, the draft annual governance statement, the internal
audit annual opinion and the 2425 draft statement of accounts.
I don't know if any officers present know of anything else that should be added.
So a shorter agenda, chair, but who knows by the time we get to July.
Thank you.