Agenda Document Pack - Audit and Scrutiny Panel - 20/08/2026
North Lanarkshire Council · 20 August 2026
Back to Audit and Scrutiny Panel — 20 August 2026 and its agenda
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11 August 2026 Members of the Audit and Scrutiny Panel Chief Executive’s Office Rachel Blair Chief Officer (Legal, Democratic and Strategy) Civic Centre, Windmillhill Street, Motherwell ML1 1AB www.northlanarkshire.gov.uk Notice is given that a Meeting of the Audit and Scrutiny Panel is to be held in the Council Chamber, Civic Centre, Windmillhill Street, Motherwell, ML1 1AB on Thursday, 20 August 2026 at 14:00 PM which you are requested to attend. The agenda of business is attached. Rachel Blair Chief Officer (Legal, Democratic and Strategy) Members : Clerk Name: Karen Swan Clerk Telephone: 07919 730272 Clerk Email: committee@northlan.gov.uk S Watson, P Kelly, C Costello, M Hughes, J Hume, D Johnston, J Leckie, M McCulloch, J McLaren, P Patton, G Robinson. Page 1 of 124
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Agenda 1 Declarations of Interest In Terms of the Ethical Standards In Public Life Etc. (Scotland) Act 2000 Performance 2 Building Standards Performance – Response to Audit and Scrutiny Committee Enquiry Submit report by the Chief Officer (Community Operations) providing information on Building Standards performance, the factors which contributed to the 2025/26 performance position and the actions being taken to support improvement. 5 - 12 3 Housing Performance Update Submit report by the Acting Chief Officer (Housing and Communities) providing an update on the factors contributing to the Red RAG status. 13 - 18 4 Roads and Infrastructure Maintenance and Improvement Services Contract: Road Network Condition Report by Chief Officer (Community Operations) - Copy to follow 5 Bargeddie Cross Road Safety Junction Improvements - Interim Report Submit report by the Chief Officer (Place) providing information in response to a request for a report regarding the delivery of the Bargeddie Cross road safety junction improvement project which is currently on site. 19 - 28 Audit Related Items 6 Investigation: Business Growth Grants Applications Submit report by the Chief Officer (Audit and Risk) providing a summary of a recent Internal Audit investigation into Business Growth Grants Fund claims. 29 - 40 7 Internal Audit: Progress Report Submit report by the Chief Officer (Audit and Risk) providing an overview of Internal Audit activity and audit reports issued since the last update to the Panel. 41 - 68 Page 3 of 124
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8 Internal Audit: Follow-up implementation of audit recommendations Submit report by the Chief Officer (Audit and Risk) updating the Panel on the progress made by management in the implementation of Internal and External Audit recommendations. 69 - 80 9 Risk Management Update Submit report by the Chief Officer (Audit and Risk) seeking to support the Panel in the discharge of its remit to monitor the effective development and operation of risk management in the Council. 81 - 88 Scrutiny Related Items 10 Performance reporting Schedule - quarterly performance assurance review Submit report by the Chief Officer (Legal, Democratic and Strategy) providing a summary of the Council's performance reports into one composite assurance overview. 89 - 112 11 North Lanarkshire Council Response to Accounts Commission Findings on Cyber Resilience Submit joint report by the Chief Officer (Legal, Democratic and Strategy) and Chief Officer (Finance and Technology) providing North Lanarkshire Council's response to the Accounts Commission report arising from the cyber-attack experience by Comhairle nan Eilean Siar (Western isles Council) . 113 - 124 Page 4 of 124
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North Lanarkshire Council Report Audit and Scrutiny Panel Does this report require to be approved? ☐ Yes ☒ No Ref MM/LR Date 20/08/26 Building Standards Performance – Response to Audit and Scrutiny Committee Enquiry From Lyall Rennie, Chief Officer (Community Operations) E-mail RennieLy@northlan.gov.uk Executive Summary This report has been prepared in response to a request from the Audit and Scrutiny Committee on 14 May 2026 regarding Building Standards performance, the factors which contributed to the 2025/26 performance position and the actions being taken to support improvement. Whilst performance remained below target for the two building warrant indicators during 2025/26, there was improvement in the timeliness of first reports issued within 20 working days during the latter part of the year and performance in relation to completion certificates requests responded to within 14 days remained above target. A range of factors contributed to performance pressures during the reporting period, including staffing challenges, vacancies, both long and short-term absences, pressures within admin support, workforce development commitments and organisational change. Actions have been taken to address these issues and performance continues to be closely monitored. The service remains committed to continuous improvement and considers that the measures currently in place provide an appropriate basis for further improvement. Recommendations It is recommended that the Audit and Scrutiny Panel: (1) Acknowledge the performance position for Building Standards during 2025/26. (2) Acknowledge the factors which contributed to performance remaining below target for the building warrant indicators. (3) Acknowledge the actions being taken to improve performance and strengthen service resilience. (4) Acknowledge that no additional budget provision or permanent staffing resources are currently being sought and that performance will continue to be monitored through established management arrangements. Item 2 Page 5 of 124
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1. Background 1.1 Following scrutiny of the corporate quarterly performance assurance review report presented to the Audit and Scrutiny Panel on 14 May 2026, the following question was raised: "Building warrant performance had previously shown signs of improvement following a prolonged period of decline; however, recent figures indicated a deterioration. Given the number of enquiries being received from constituents regarding building warrants, what further action is being taken by the service to improve performance in this area and what additional support or resources, if any, are required to assist the team?" 1.2 This report has been prepared in response to that request and provides information on current performance, factors which have influenced performance and the actions being taken to support service improvement. 1.3 Building Standards services in Scotland operate within a national performance framework administered by the Scottish Government Building Standards Division (BSD). All 32 local authorities act as independent verifiers and are assessed against a range of Key Performance Outcomes (KPOs). 1.4 Locally, Building Standards performance is monitored against three Key Performance Indicators: • Building warrant first reports - % issued within 20 working days • Completion certificates - % requests responded to within 14 days • Building warrants - % released within 6 working days 1.5 Performance information is reported quarterly and annually through established Council performance management arrangements and through returns submitted to the Scottish Government. The Building Standards, Annual Verification Performance Report is published online (link) 1.6 The service utilises a range of management and monitoring systems, including Idox Enterprise reports and time recording systems, to support workload management, performance monitoring and continuous improvement. 1.7 Customer satisfaction is monitored through the National Customer Satisfaction Survey administered on behalf of the Scottish Government Building Standards Division. During 2025/26 the Council’s Building Standards service achieved an overall customer satisfaction score of 9.1 out of 10, exceeding the national average of 8.5. 2. Report Performance Overview The Plan for North Lanarkshire Priority All priorities Ambition statement All ambition statements Programme of Work Statutory / corporate / service requirement Item 2 Page 6 of 124
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2.1 Building Standards performance during 2025/26 was mixed across the three locally reported Key Performance Indicators (KPIs). 2.2 The performance report considered by Audit and Scrutiny Committee on 14 May 2026 presented year to date results to the end of Quarter 3, Link to file. At that time, performance for Building Warrant First Reports issued within 20 working days was 84.1% against a target of 95%, while performance for Building Warrants released within 6 working days was 85.8% against a target of 90%. 2.3 By year end, performance for building warrant first reports issued within 20 working days had improved to 86.7%. Whilst this remained below the target of 95%, Quarter 4 performance reached 90.4%, demonstrating a significant improvement compared with earlier quarters. Appendix 1 provides the breakdown of Building Standards Performance Indicators 2025/26. 2.4 Performance for Building Warrants released within 6 working days was 84.5% at year end, remaining below the KPI target of 90%. Whilst the target was not achieved, performance improved during the course of the year, increasing from 81.3% in Quarter 1 to 87.9% in Quarter 4. Further detail is provided in Appendix 1. 2.5 Performance for Completion Certificates responded to within 14 days remained consistently strong throughout the year. The year-end result of 97.3% exceeded the KPI target of 95%. Factors Affecting Performance 2.6 The performance position for both building warrant indicators reflects a number of factors which impacted service capacity and workflow during the reporting period. No single issue accounts for the shortfall against target. 2.7 The service experienced staffing challenges during the reporting period, including vacancies which proved difficult to fill and both short and long term staff absences. These factors reduced operational capacity and increased workload pressures across the team. 2.8 The service also continued to invest in workforce development through its Graduate Apprenticeship Programme. During the reporting period four members of staff were supported through the programme, requiring significant mentoring and supervision from experienced officers. This investment forms an important part of the service's succession planning and workforce development strategy and is intended to support the long term resilience of the service. 2.9 One member of staff has now successfully completed the programme, while two have progressed to Inspector posts and are expected to complete their degree courses within the coming months. A fourth member of staff is commencing year two of the programme in September. The service intends to continue supporting workforce development initiatives to assist future recruitment, retention and succession planning. 2.10 Administrative support services experienced staffing pressures during the reporting period. Whilst these functions are delivered through a central support structure and are not managed directly by the Building Standards service, vacancies within the support team impacted processing times at key stages of the application process. Concerns regarding admin capacity were raised with the relevant management team and improvements have recently been observed following recruitment to vacant posts and additional training input. Item 2 Page 7 of 124
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2.11 During the reporting period the service also continued to support several complex and strategically significant development projects as part of the Plan for North Lanarkshire, requiring substantial officer input and careful management of available resources. Improvement Activity 2.12 The service continues to monitor performance through regular management meetings, workload reviews, performance reporting arrangements and case management systems. 2.13 Recruitment is planned to fill existing vacancies to further strengthen service resilience. Discussions with colleagues responsible for admin support functions will continue to ensure appropriate support arrangements are maintained. 2.14 On 16 July 2026, officers from the Scottish Government Building Standards Division (BSD) undertook an engagement visit with Building Standards managers and the Regulatory Services Manager. The visit included discussion of recent management changes following the integration of Built Environment and Protective Services, together with service performance and governance arrangements. BSD officers expressed satisfaction with the overall performance of the service and confirmed that the Council has not previously been subject to a formal improvement plan under the national Building Standards performance framework. 2.15 No additional budget provision or permanent staffing resources are currently being sought. The service considers that the actions already implemented, together with planned recruitment activity and improved admin support capacity, provide an appropriate basis for improving performance. This position will continue to be monitored. 2.16 Whilst performance remained below target for both building warrant indicators during 2025/26, there was a significant improvement in the proportion of first reports issued within 20 working days during the final quarter of the year. Performance in relation to completion certificates also continued to exceed target. 2.17 Performance will continue to be monitored by the service with improvements reflected in the six-monthly Chief Officer performance report to the Environment and Climate Change Committee. 3. Measures of success 3.1 Performance will continue to be monitored through quarterly performance reporting arrangements and returns submitted to the Scottish Government Building Standards Division. 3.2 Recruitment to vacant posts, continued investment in workforce development and improved administrative support capacity will strengthen service resilience and support future performance improvements. 3.3 Ongoing monitoring and management oversight will ensure that emerging issues are identified and addressed at the earliest opportunity. 4. Supporting documentation Item 2 Page 8 of 124
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4.1 Appendix 1 - Building Standards Performance Indicators 2025/26. Lyall Rennie Chief Officer (Community Operations) Item 2 Page 9 of 124
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5. Impacts 5.1 Public Sector Equality Duty and Fairer Scotland Duty Does the report contain information that has an impact as a result of the Public Sector Equality Duty and/or Fairer Scotland Duty? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? If Yes, has an assessment been carried out and published on the council’s website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality- and-fairer-scotland-duty-impact-assessments Yes ☐ No ☐ 5.2 Financial impact Does the report contain any financial impacts? Yes ☐ No ☒ If Yes, have all relevant financial impacts been discussed and agreed with Finance? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.3 HR policy impact Does the report contain any HR policy or procedure impacts? Yes ☐ No ☒ If Yes, have all relevant HR impacts been discussed and agreed with People Resources? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.4 Legal impact Does the report contain any legal impacts (such as general legal matters, statutory considerations (including employment law considerations), or new legislation)? Yes ☐ No ☒ If Yes, have all relevant legal impacts been discussed and agreed with Legal and Democratic? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.5 Data protection impact Does the report / project / practice contain or involve the processing of personal data? Yes ☐ No ☒ If Yes, is the processing of this personal data likely to result in a high risk to the data subject? Yes ☐ No ☐ If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e- mailed to dataprotection@northlan.gov.uk Yes ☐ No ☐ 5.6 Technology / Digital impact Does the report contain information that has an impact on either technology, digital transformation, service redesign / business change processes, data management, or connectivity / broadband / Wi-Fi? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? Item 2 Page 10 of 124
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Where the impact identifies a requirement for significant technology change, has an assessment been carried out (or is scheduled to be carried out) by the Enterprise Architecture Governance Group (EAGG)? Yes ☐ No ☐ 5.7 Environmental / Carbon impact Does the report / project / practice contain information that has an impact on any environmental or carbon matters? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.8 Communications impact Does the report contain any information that has an impact on the council’s communications activities? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.9 Risk impact Is there a risk impact? Yes ☐ No ☒ If Yes, please provide a brief summary of the key risks and potential impacts, highlighting where the risk(s) are assessed and recorded (e.g. Corporate or Service or Project Risk Registers), and how they are managed? 5.10 Armed Forces Covenant Duty Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it relate to healthcare, housing, or education services for in-Service or ex- Service personnel, or their families, or widow(er)s)? Yes ☐ No ☒ If Yes, please provide a brief summary of the provision which has been made to ensure there has been appropriate consideration of the particular needs of the Armed Forces community to make sure that they do not face disadvantage compared to other citizens in the provision of public services. 5.11 Children’s rights and wellbeing impact Does the report contain any information regarding any council activity, service delivery, policy, or plan that has an impact on children and young people up to the age of 18, or on a specific group of these? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact and the provision that has been made to ensure there has been appropriate consideration of the relevant Articles from the United Nations Convention on the Rights of the Child (UNCRC). If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been carried out? Yes ☐ No ☒ Item 2 Page 11 of 124
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Appendix 1 - Building Standards Performance Indicators 2025/26. Indicator Target Q1 Q2 Q3 Q4 Year End Building warrant first reports issued within 20 working days (%) 95% 86.42% 82.3% 87.97% 90.4% 86.7% Completion certificates responded to within 14 days (%) 95% 96.6% 97.1% 97% 96.7% 97.3% Building warrants released within 6 working days (%) 90% 81.3% 83% 86.7% 87.9% 84.5 Item 2 Page 12 of 124
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North Lanarkshire Council Report Audit & Scrutiny Panel Does this report require to be approved? ☐ Yes ☒ No Ref GW/KMcG Date 20/08/26 Housing Performance Update From Gillian Whitehead, Acting Chief Officer (Housing & Communities) E-mail WhiteheadG@northlan.gov.uk Executive Summary This report provides the Audit and Scrutiny Panel with an update on the factors contributing to the Red RAG status for the following two performance indicators within the Council’s quarterly performance assurance review report: • the percentage of anti-social behaviour cases reported in the previous year that were resolved; and • the percentage of tenants satisfied with the standard of their home when moving in. The report also outlines the actions being taken to improve performance against these indicators, where appropriate, and provides assurance that future performance reports will include explanatory narrative on the causes of underperformance and the corrective measures being implemented to address them. Recommendations It is recommended that the Audit and Scrutiny Panel (1) Acknowledge the reasons contributing to the Red RAG status for the following indicators: • Percentage (%) of anti-social behaviour cases reported in the last year that were resolved; • Percentage (%) of tenants satisfied with the standard of their home when moving in (2) Acknowledge the remedial actions being taken to improve performance in these indicators where appropriate; and (3) Acknowledge the assurance that future performance reports will include narrative commentary explaining the causes of performance issues and remedial measures being implemented. Item 3 Page 13 of 124
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1. Background 1.1 Panel Members will recall the ‘quarterly performance assurance review’ report presented to the Audit and Scrutiny Panel on 14/05/26, which set out the outcomes of the assurance review of reports submitted to Council Committees during cycle 1 of 2026. 1.2 The composite report presented included performance information in relation to all services of the council, including the housing service, who have twenty-two indicators in the Strategic Performance Framework, covering all aspects of the council’s social landlord role. 1.3 The report presented on 14/05/26 identified two red indicators within the housing report, however no narrative was included within the comments section relating to these indicators and no reference was made to either of them within the narrative commentary under the section ‘Areas of Performance requiring improvement’. 1.4 At the meeting on 14//05/26 members of the Audit and Scrutiny Panel asked “In relation to the indicators showing a Red RAG status for the percentage of anti-social behaviour cases reported in the last year that were resolved, and the percentage of tenants satisfied with the standard of their home when moving in, could further information be provided on the reasons for the underperformance and the actions being taken to improve these indicators?” 1.5 Members also asked for future reports, where indicators are assigned a Red RAG status, to include narrative commentary explaining the causes of the performance issues and the remedial measures being implemented. 1.6 In response to this request the panel were advised that a report would be submitted to the August 2026 meeting of the Audit and Scrutiny Panel to provide a detailed response, in line with the established approach for enquiries arising from the panel. 2. Report 2.1 This report provides an explanation for the red RAG status of the two indicators noted and also provides information on remedial action being taken by the service, where appropriate, to improve this performance. 2.2 For context, the two indicators with a red status recorded against them within the performance report were indicators that are reported on an annual basis and the red status related to the 2024/25 year end performance for these indicators as reported to Housing Committee in the Strategic Performance Framework - Housing Report on 27/08/25. The Plan for North Lanarkshire Priority Improve economic opportunities and outcomes Ambition statement (1) Ensure a housing mix that supports social inclusion and economic growth Programme of Work Statutory / corporate / service requirement Item 3 Page 14 of 124
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2.3 Each performance report presented to the Audit & Scrutiny Panel will include information on all performance indicators agreed for the Strategic Performance Framework, however they are not all updated at every reporting cycle due to different reporting timescales. Each report presented to the panel provides narrative only on the performance indicators where updated performance information has been provided. 2.4 As the two indicators highlighted red in the report provided to the panel on 14/05/26, are indicators that are reported annually, there was no update on this performance due until August 2026 committee, when the annual outturn for 2025/26 will be reported with comments added in respect of the performance. 2.5 While updated details on these indicators will be provided to Housing Committee in August 202, for clarification pending this update, further information is noted below. The Percentage of anti-social cases reported in the last year that were resolved 2.6 The ‘Percentage (%) of anti-social cases that were reported in the last year that were resolved’ is a Statutory Indicator that is reported to the Scottish Housing Regulator on an annual basis through the Housing Service Annual Return on the Charter (ARC). 2.7 As this indicator is statutory, its definition and calculation processes is prescribed by the Scottish Housing Regulator. 2.8 Within this indicator landlords are asked to calculate their outturn by using the total number of anti-social cases that were resolved in the reporting year as the numerator, and the sum of the number of cases taken in the reporting year plus any cases that were taken the previous reporting year and had been carried forward to the reporting year for resolution, as the denominator. 2.9 When using these figures, particularly where a case is received shortly before the year- end, it is unlikely that it will be resolved within the timescales used for calculating resolved cases. However, this does not necessarily indicate a delay in resolution, as the case may still be progressing within the Council’s agreed timescales for completion. 2.10 As a result, a proportion of cases will inevitably span reporting periods, with resolutions being recorded in a subsequent year. This means that, by its nature, this measure is unlikely to achieve the 99% performance target, as there will almost always be a number of open cases at year end which will have a negative impact on the outturn for this indicator. The percentage (%) of tenants satisfied with the standard of their home when moving in 2.11 ‘The percentage (%) of tenants satisfied with the standard of their home when moving in’ is not a statutory indicator and is an internal KPI. 2.12 The information used to report on this indicator is gathered through a survey conducted by Housing Officers at the Settling In Visit carried out to tenants approximately 4 weeks after their tenancy commenced. 2.13 In response to the fact that our 2024/25 outturn reported that levels of satisfaction with the standard of tenant’s homes when moving in was no longer meeting target, the service carried out analysis and reviewed the reasons tenants have stated for dissatisfaction. Item 3 Page 15 of 124
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2.14 On analysis it became evident that tenant’s dissatisfaction is not always directly attributed to the standard of their home, with a number of responses stating that their dissatisfaction was in response to the length of time they had been on the waiting list or with other administrative issues during the allocation process. We introduced a new collection method during 2025/26 for this survey, which enabled data to be reviewed more effectively and ensured responses are aligned with the appropriate questions. In 2025/26 the annual outturn for this indicator has shown an increase in satisfaction of over 5% at 93.5%, which will place this indicator in green. 2.15 To ensure future returns are more reflective of tenants’ satisfaction with the standard of their home, we are also developing a new briefing programme for staff undertaking the surveys, to ensure they are collecting and accurately recording relevant information. Audits on these surveys will continue on a regular basis, with any areas of dissatisfaction being actioned as appropriate. 2.16 The service has also noted that members have requested narrative be provided for red indicators in future reports to provide transparency. While past practice has required to provide narrative where updates in performance have been provided, we will ensure that all future reports contain narrative against all red indicators, including indicators where no update has been provided. 3. Measures of success 3.1 That members will have a an understanding of the reasons for the previous red status of these indicators, and have confidence that the actions being taken by the service will enable accurate and full reporting in the future. 4. Supporting documentation Gillian Whitehead Acting Chief Officer (Housing & Communities) Item 3 Page 16 of 124
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5. Impacts 5.1 Public Sector Equality Duty and Fairer Scotland Duty Does the report contain information that has an impact as a result of the Public Sector Equality Duty and/or Fairer Scotland Duty? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? If Yes, has an assessment been carried out and published on the council’s website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality- and-fairer-scotland-duty-impact-assessments Yes ☐ No ☐ 5.2 Financial impact Does the report contain any financial impacts? Yes ☐ No ☒ If Yes, have all relevant financial impacts been discussed and agreed with Finance? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.3 HR policy impact Does the report contain any HR policy or procedure impacts? Yes ☐ No ☒ If Yes, have all relevant HR impacts been discussed and agreed with People Resources? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.4 Legal impact Does the report contain any legal impacts (such as general legal matters, statutory considerations (including employment law considerations), or new legislation)? Yes ☐ No ☒ If Yes, have all relevant legal impacts been discussed and agreed with Legal and Democratic? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.5 Data protection impact Does the report / project / practice contain or involve the processing of personal data? Yes ☐ No ☒ If Yes, is the processing of this personal data likely to result in a high risk to the data subject? Yes ☐ No ☐ If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e- mailed to dataprotection@northlan.gov.uk Yes ☐ No ☐ 5.6 Technology / Digital impact Does the report contain information that has an impact on either technology, digital transformation, service redesign / business change processes, data management, or connectivity / broadband / Wi-Fi? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? Item 3 Page 17 of 124
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Where the impact identifies a requirement for significant technology change, has an assessment been carried out (or is scheduled to be carried out) by the Enterprise Architecture Governance Group (EAGG)? Yes ☐ No ☐ 5.7 Environmental / Carbon impact Does the report / project / practice contain information that has an impact on any environmental or carbon matters? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.8 Communications impact Does the report contain any information that has an impact on the council’s communications activities? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.9 Risk impact Is there a risk impact? Yes ☐ No ☒ If Yes, please provide a brief summary of the key risks and potential impacts, highlighting where the risk(s) are assessed and recorded (e.g. Corporate or Service or Project Risk Registers), and how they are managed? 5.10 Armed Forces Covenant Duty Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it relate to healthcare, housing, or education services for in-Service or ex- Service personnel, or their families, or widow(er)s)? Yes ☐ No ☒ If Yes, please provide a brief summary of the provision which has been made to ensure there has been appropriate consideration of the particular needs of the Armed Forces community to make sure that they do not face disadvantage compared to other citizens in the provision of public services. 5.11 Children’s rights and wellbeing impact Does the report contain any information regarding any council activity, service delivery, policy, or plan that has an impact on children and young people up to the age of 18, or on a specific group of these? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact and the provision that has been made to ensure there has been appropriate consideration of the relevant Articles from the United Nations Convention on the Rights of the Child (UNCRC). If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been carried out? Yes ☐ No ☐ Item 3 Page 18 of 124
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North Lanarkshire Council Report Audit and Scrutiny Panel Does this report require to be approved? ☒ Yes ☐ No Ref: PH/AR/SB Date: 20/08/26 Bargeddie Cross Road Safety Junction Improvements – Interim Report From Pamela Humphries, Chief Officer (Place) E-mail robertsonala@northlan.gov.uk Executive Summary This report provides information to the Audit and Scrutiny Panel in response to a request for a report regarding the delivery of the Bargeddie Cross road safety junction improvement project which is currently on site. The report informs the Panel of the project scope, programme, cost, and reasons for the delay. Information is provided about the contractual arrangements for the works, governance of the Infrastructure Maintenance and Improvement Services Contract and impact on bus arrangements for pupils. Recommendations It is recommended that the Audit and Scrutiny Panel Committee: (1) Note the information contained in this report. (2) Acknowledge that the delays are primarily associated with unforeseen and unavoidable issues in relation to the diversion of buried public utilities. (3) Note that improvement actions with respect to the timely provision of updated programmes by the contractor and closer collaboration between the project team and the school transport team have been identified. The Plan for North Lanarkshire Priority Improve the health and wellbeing of our communities Ambition statement (17) Ensure we keep our environment clean, safe, and attractive Programme of Work Statutory / corporate / service requirement Item 5 Page 19 of 124
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1. Background 1.1 The aim of the Bargeddie Cross junction improvement project is to improve safety for all road users and introduce enhanced pedestrian provision at the junction of A89 Coatbridge Road, with A752 Langmuir Way / Gartcosh Walk, known locally as Bargeddie Cross. 1.2 The junction improvements will introduce full traffic signal control instead of the current roundabout arrangement which is substandard in term of size and not designed to cope with the demands of current traffic. 1.3 The improvements will also introduce signalised crossing facilities for walking and wheeled journeys on their desire line at the junction. The crossings will be complimented with new widened footways creating shared-use paths linking strategic routes in the area and improved infrastructure for the schools and other attractions in the area. 1.4 A review of collision data identified Bargeddie Cross as one of the highest-risk junctions in North Lanarkshire, highlighting a clear need for road safety improvements. Between 2016 and 2021, 14 injury accidents were recorded at the junction, with the majority resulting from drivers misjudging the path or speed of other vehicles. A further review covering the period 2020–2025 identified an additional nine recorded collisions, including two serious and seven slight injuries, demonstrating that road safety concerns persisted. The accident history, together with incidents involving cyclists and the strategic importance of the junction, supported the need for targeted interventions to improve visibility, reduce vehicle conflict points, enhance facilities for active travel, and create a safer environment for all road users. 1.5 The project is fully funded by Transport Scotland through the Road Safety Improvement Fund and is being delivered by Hochtief Operations UK & Ireland Ltd. under the council's Roads and Infrastructure Maintenance and Improvement Services Contract. Enabling works commenced on site on 6 October 2025 and were due to be completed by late December 2025.The main works were anticipated to start in January 2026 with estimated completion June 2026. 1.6 This report is presented to the Audit and Scrutiny Panel to address the specific concerns raised over the performance of the Bargeddie Cross road safety junction improvement project. 2. Report 2.1 The specific concerns raised by the Audit and Scrutiny panel are addressed in turn under the headings that follow. The reasons and issues which have led to the delay 2.2 Enabling works commenced on 6 October 2025 and included utility diversions, site clearance, and other preparatory activities required to facilitate the main construction phase. These works were to divert utility services belonging to BT Openreach, Virgin Media, Scottish Power Energy Network, Zayo, Scottish Water, and Scottish Gas Item 5 Page 20 of 124
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Network. and enable the construction of the south-western footway. It was originally anticipated that the enabling works would be completed by December 2025. 2.3 Unfortunately, the service diversion works took longer than anticipated due to a combination of the quantity of services, some uncharted, challenging ground conditions precluding the use of vacuum excavation, and stringent requirements to protect high- value fibre routes. These unforeseen issues resulted in significant delays. 2.4 The utility issues encountered could not have reasonably been foreseen. Detailed asset plans and diversion requirements were acquired from the various utility providers and were followed up with ground penetrating radar surveys and trial pits at select locations in advance of the enabling works. The asset information and surveys did not reveal the full extent of unchartered services or the exact positioning of the services. 2.5 It would have been prohibitive to undertake further trial pits to other areas of concern due to the location being in close proximity to the carriageway and resulting disruption to traffic. Doing so in advance of enabling works would not have reduced the duration required to divert the utilities. 2.6 The majority of the diversion works were completed in May 2026, approximately five months later than planned, with enabling works road construction to the south eastern quadrant dependant on utility diversions being reprogrammed to the end of the main works The commencement of the main works coincided with the latter stages of the enabling works in April. The current programme indicates a completion date of 18 November 2026, however, the possibility of completing works to the carriageway and footway by mid-October 2026 is being explored with the contractor. Details of the contracted terms 2.7 Enabling and main works were instructed as a ‘task order’ through the Infrastructure Maintenance and Improvement Services Contract, a NEC4 Term Service Contract (Option A). The majority of construction works are being undertaken by Maclay (Civil Engineering) Ltd who are a subcontractor to Hochtief. 2.8 Under the contract between the council and Hochtief, the contractor prepares a quotation for consideration and acceptance by the client prior to works commencing. The quotation is compiled using the schedule of rates within the contract and the quantity of works expected. After acceptance this forms the task price list. Payment of the task price list is based on the actual amount of work carried out to date at each payment interval. 2.9 Any changes to the scope of work are managed through a formal process known as a compensation event. A compensation event is an occurrence that entitles a contractor to additional time, money, or both, due to changes or unforeseen circumstances for which the contractor is not liable. 2.10 During the enabling works, utility diversions were delivered directly by the utility providers’ contractors in coordination with Hochtief and the council. These utility works are contracted directly between the council and the utility providers in accordance with the requirements of the New Roads and Street Works Act 1991 and the associated diversionary works procedures set out within the Manual of Contract Documents for Highway Works (MCHW SA 10/05). Item 5 Page 21 of 124
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Oversight of the sub-contracting arrangement with Maclay – are they on a day rate? 2.11 Maclay are not directly managed by the council as they are a sub-contractor to Hochtief, and as such Hochtief have overall contractual responsibility for oversight of Maclay and delivery of the works as per the terms of the contract with the council. Maclay has been accepted by the council as a subcontractor to Hochtief. Hochtief - contract governance arrangements 2.12 The following contract governance arrangements are in relation to the overall Roads and Infrastructure Maintenance and Improvement Services Contract. The Bargeddie Cross road safety junction improvement project is a task order managed in accordance with NEC4 Term Service Contract (Option A) contract conditions. 2.13 The essential elements for effective contract management were established for Contract commencement, with the more advanced approaches developed and introduced, as a priority, throughout Contract Year 1. 2.14 The approach involves multiple layers of governance to provide essential scrutiny and oversight and set out clear roles and responsibilities for operational ownership, contract management and contract development activity. 2.15 The governance groups, their roles, meeting frequencies and council membership are summarised below: Governance Group Main Group Roles Meeting Frequency Council Membership Level 2 Enterprise Strategic Group • provide the strategic direction; share lessons learned; and • Identify opportunities for continuous improvement. Quarterly Depute Chief Executive Chief Officer (Community Operations) Level 3 Contract Service Management Group • take ownership of, and commitment to, the success of the Contract; • consider the overall progress being made in terms of meeting the intended Contract objectives and lead the Annual Review; • consider the overall performance of the Contract and monitor the strategies, priorities and targets; • report to each party’s senior decision- makers on the progress and performance of the Contract, • consider the levels of maturity to be obtained against the Strategic Maturity Matrix SPIs; and Quarterly Chief Officer (Community Operations) Chief Officer (Asset and Procurement) Roads and Asset Services Manager Contract Performance and Assurance Manager Item 5 Page 22 of 124
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Level 4 Contract Delivery Management Group • contribute to the development and subsequent monitoring of the Annual Service Delivery Plan and other specific commitments made by the Contractor • support the Service Management Group in ensuring progress and performance in accordance with the Annual Service Delivery Plan; • monitor the progress and performance of the Contractor against the KPIs and SPIs. Manage the Risk Register; • consider proposals for improvement and make recommendations to the Service Management Group; and • identify any lessons that can be learned or practices that can be improved upon and obtain any approvals or consents required to refine practices accordingly. Monthly Roads and Asset Services Manager Infrastructure & Transportation Manager Contract Performance and Assurance Manager Level 5 Contract Service Delivery Groups • coordinate and oversee the effective delivery of the Services. Weekly Managers & Team Leaders 2.16 As part of the council’s approach to enhanced contract management, a suite of toolkits has been developed to support and monitor key aspects of the Contract. Cost implications of the delay and cost make up for the project 2.17 Works costs and spend to date are summarised below. Compensation event notifications, including those in relation to delayed utility diversion work, are currently being assessed. The vast majority of compensation event value agreed to date are in relation to the delay associated with utility diversions. These payments cover the costs of extended traffic management and site accommodation in addition to works to assist the removal, installation and diversion of utilities. These costs would be incurred regardless of whether they were foreseen and planned for or not. 2.18 Hochtief Construction Works Total enabling and main works quotation value: £1,172,671.11 Compensation event value agreed to 21/07/26: £57,704.99 Current spend to 21/07/26: £625,661.63 Total projected outrun cost as of 21/07/26: £1,230,376.10 Item 5 Page 23 of 124
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2.19 Utility Diversions Utility diversions quotations total: £784,879.53 Additional allowable costs (over the quoted works): £63,697.04 Deductions (due to Hochtief undertaking elements of the work): £68,034.81 Current spend to 21/07/26: £682,152.69 Total projected outrun cost as of 21/07/26: £780,541.76 Additional cost implications such as the bus arrangements for the children attending St Kevin's Hub 2.20 The road will remain operational for the majority of the works, with appropriate traffic management in place to control the flow of vehicles and pedestrians through the site. This is not anticipated to impact bus operations serving the hub. Suitable pedestrian diversions will be provided on all footways to ensure safe access for children travelling to St Kevin’s Hub. 2.21 The only exception will be during the final surfacing works, when temporary road closures will be required. These closures are currently being discussed with the Contractor and will be agreed in due course. To minimise disruption to traffic, the intention is to programme these works during the October school holiday period. 2.22 To facilitate the transition to the new St Kevin’s Primary School Hub, and pending completion of the required works, the school transport arrangements previously in place for pupils attending Bargeddie Primary School and St Kevin’s Primary School have been temporarily extended until 9 October 2026. The full-year cost of these arrangements is £0.051m. Penalty clauses, scope of project, programme of work and rectifications agreed 2.23 The scope of the project is to deliver a key signalised junction at Bargeddie Cross, which is recognised as one of the highest-risk locations for road traffic accidents within North Lanarkshire. Upon completion, the junction is expected to be significantly safer for all users. 2.24 The current programme indicates a completion date of 18 November 2026. The majority of delays to date, attributable to unforeseen public utility diversionary work out with the contractor’s control, is a valid compensation event and therefore would not be subject to any penalties. The additional project costs and durations would be incurred regardless of whether they were foreseen or not. However, the council is exploring with Hochtief the possibility of completing works to the carriageway and footway by mid-October 2026, with only off-road landscaping works remaining thereafter. 2.25 With respect to improvement actions and lessons learned, it is not considered that more could reasonably have been done to foresee and address the buried utility issues encountered. However, it is recognised that timeous submission of updated programmes and compensation event claims by the contractor in the format required by the contract is an ongoing issue affecting the ability of the council to communicate accurate and up to date information on programme and cost. Item 5 Page 24 of 124
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2.26 Improvement actions agreed with Hochtief to date include the implementation of a methodology to measure key performance indicators relating to achievement of completion dates and the timely submission of programmes for future task orders, the failure of which can result in a financial penalty being paid by the contractor. 2.27 In addition, future projects will benefit from closer collaboration between the project team and the school transport team to identify impacted walked routes to school at an early stage and, where appropriate, consider the temporary provision of school transport during construction activities. 3. Measures of success 3.1 Successful delivery of the Bargeddie Cross road safety junction improvement works. 3.2 A reduction in the number and severity of road traffic collisions at Bargeddie Cross, which has been identified as one of the highest-risk junctions in North Lanarkshire. 3.3 Improved traffic management and vehicle movements through the new signalised junction arrangement, reducing conflict points and improving driver decision-making. 3.4 Safer and more accessible facilities for pedestrians and cyclists, including improved crossing facilities, footways and connections to existing active travel routes. 3.5 Continued management of contractor performance through the contractual governance arrangements, ensuring identified risks are appropriately mitigated and project outcomes achieved. 4. Supporting documentation Roads and Infrastructure Maintenance and Improvement Services Contract: Interim Report Pamela Humphries Chief Officer (Place) Item 5 Page 25 of 124
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5. Impacts 5.1 Public Sector Equality Duty and Fairer Scotland Duty Does the report contain information that has an impact as a result of the Public Sector Equality Duty and/or Fairer Scotland Duty? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? If Yes, has an assessment been carried out and published on the council’s website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality- and-fairer-scotland-duty-impact-assessments Yes ☐ No ☐ 5.2 Financial impact Does the report contain any financial impacts? Yes ☒ No ☐ If Yes, have all relevant financial impacts been discussed and agreed with Finance? Yes ☒ No ☐ If Yes, please provide a brief summary of the impact? Project remains within allocated budget and is fully funded by Transport Scotland through the Road Safety Improvement Fund. 5.3 HR policy impact Does the report contain any HR policy or procedure impacts? Yes ☐ No ☒ If Yes, have all relevant HR impacts been discussed and agreed with People Resources? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.4 Legal impact Does the report contain any legal impacts (such as general legal matters, statutory considerations (including employment law considerations), or new legislation)? Yes ☐ No ☒ If Yes, have all relevant legal impacts been discussed and agreed with Legal and Democratic? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.5 Data protection impact Does the report / project / practice contain or involve the processing of personal data? Yes ☐ No ☒ If Yes, is the processing of this personal data likely to result in a high risk to the data subject? Yes ☐ No ☐ If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e- mailed to dataprotection@northlan.gov.uk Yes ☐ No ☐ Item 5 Page 26 of 124
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5.6 Technology / Digital impact Does the report contain information that has an impact on either technology, digital transformation, service redesign / business change processes, data management, or connectivity / broadband / Wi-Fi? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? Where the impact identifies a requirement for significant technology change, has an assessment been carried out (or is scheduled to be carried out) by the Enterprise Architecture Governance Group (EAGG)? Yes ☐ No ☐ 5.7 Environmental / Carbon impact Does the report / project / practice contain information that has an impact on any environmental or carbon matters? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.8 Communications impact Does the report contain any information that has an impact on the council’s communications activities? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.9 Risk impact Is there a risk impact? Yes ☐ No ☒ If Yes, please provide a brief summary of the key risks and potential impacts, highlighting where the risk(s) are assessed and recorded (e.g. Corporate or Service or Project Risk Registers), and how they are managed? 5.10 Armed Forces Covenant Duty Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it relate to healthcare, housing, or education services for in-Service or ex- Service personnel, or their families, or widow(er)s)? Yes ☐ No ☒ If Yes, please provide a brief summary of the provision which has been made to ensure there has been appropriate consideration of the particular needs of the Armed Forces community to make sure that they do not face disadvantage compared to other citizens in the provision of public services. 5.11 Children’s rights and wellbeing impact Does the report contain any information regarding any council activity, service delivery, policy, or plan that has an impact on children and young people up to the age of 18, or on a specific group of these? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact and the provision that has been made to ensure there has been appropriate consideration of the relevant Articles from the United Nations Convention on the Rights of the Child (UNCRC). If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been carried out? Yes ☐ No ☐ Item 5 Page 27 of 124
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North Lanarkshire Council Report Audit and Scrutiny Panel Does this report require to be approved? ☐ Yes ☒ No Ref FS/ASP/BGG/Aug26 Date 20/08/26 Investigation: Business Growth Grant Applications From Francis Scott, Chief Officer (Audit and Risk) E-mail scottfr@northlan.gov.uk 1. Background 1.1 The Business Growth Fund (BGF) is a discretionary grant scheme administered by the Enterprise Team and is designed to support the growth, sustainability and productivity of small and medium-sized enterprises in North Lanarkshire. Grant funding is paid for Executive Summary This report provides a summary of a recent Internal Audit investigation into potentially fraudulent claims by external parties applying for funding from the Business Growth Grants Fund. The investigation concluded that six of these grant applications were potentially fraudulent, with three resulting in grant payments totalling £134,000. Weaknesses were also highlighted in internal processes which contributed to these potentially fraudulent claims not being identified in time to prevent the payment. This investigation was undertaken in accordance with the Council’s Corporate Fraud Policy, the Global Internal Audit Standards and the Internal Audit Charter. Recommendation It is recommended that the Audit and Scrutiny Panel note the key findings and conclusions arising from the investigation report. The Plan for North Lanarkshire Priority All priorities Ambition statement All ambition statements Programme of Work All Programmes of Work Item 6 Page 29 of 124
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eligible projects retrospectively following verification of the work completed and the relevant invoices. 2. Report 2.1 During a routine review of BGF applications, officers raised concerns over unusual patterns in relation to five individual grant applications and repeated use of the same supplier. Following a preliminary review by the Service, the details were passed to Internal Audit for further investigation. The audit work also identified one additional application which displayed similar characteristics. 2.2 The investigation found that each of the six applications included at least one quotation from a company which could not be verified as a legitimate supplier and contained misstated documentation to support the application. We consider these applications to be potentially fraudulent. Of these six applications, three received grant payments totalling £134,000. 2.3 The investigation also identified a number of weaknesses in the internal processes for appraising and approving BGF applications, reviewing claims for payment and verifying that grant funding was used for the intended purpose. These weaknesses contributed to the failure to identify the fraudulent activity at an earlier stage and the grant funding being paid to the applicants concerned. 2.4 The final internal audit report on the investigation is attached at Appendix 1. We have made a number of recommendations to strengthen the arrangements in place, and we acknowledge that the Service has already implemented improvements in these areas. 2.5 The findings of the report will be shared with Police Scotland in accordance with the Council’s Corporate Fraud Policy. As the value of the potentially fraudulent activity is more than £5,000, the report has also been shared with Audit Scotland as the Council’s external auditor. 3. Measures of success 3.1 Internal Audit reports annually on its performance to the Panel and is also subject to review annually by the Council’s appointed external auditors . 4. Supporting Documentation Appendix 1 – Final Report – Business Growth Grants Investigation Francis Scott Chief Officer (Audit and Risk) Item 6 Page 30 of 124
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5. Impacts 5.1 Public Sector Equality Duty and Fairer Scotland Duty Does the report contain information that has an impact as a result of the Public Sector Equality Duty and/or Fairer Scotland Duty? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? If Yes, has an assessment been carried out and published on the council’s website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality- and-fairer-scotland-duty-impact-assessments Yes ☐ No ☐ 5.2 Financial impact Does the report contain any financial impacts? Yes ☐ No ☒ If Yes, have all relevant financial impacts been discussed and agreed with Finance? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.3 HR policy impact Does the report contain any HR policy or procedure impacts? Yes ☐ No ☒ If Yes, have all relevant HR impacts been discussed and agreed with People Resources? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.4 Legal impact Does the report contain any legal impacts (such as general legal matters, statutory considerations (including employment law considerations), or new legislation)? Yes ☒ No ☐ If Yes, have all relevant legal impacts been discussed and agreed with Legal and Democratic? Yes ☒ No ☐ If Yes, please provide a brief summary of the impact? Discussions ongoing with Police Scotland to determine what further investigation is required. 5.5 Data protection impact Does the report / project / practice contain or involve the processing of personal data? Yes ☐ No ☒ If Yes, is the processing of this personal data likely to result in a high risk to the data subject? Yes ☐ No ☐ If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e- mailed to dataprotection@northlan.gov.uk Yes ☐ No ☐ 5.6 Technology / Digital impact Does the report contain information that has an impact on either technology, digital transformation, service redesign / business change processes, data management, or connectivity / broadband / Wi-Fi? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? Item 6 Page 31 of 124
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Where the impact identifies a requirement for significant technology change, has an assessment been carried out (or is scheduled to be carried out) by the Enterprise Architecture Governance Group (EAGG)? Yes ☐ No ☐ 5.7 Environmental / Carbon impact Does the report / project / practice contain information that has an impact on any environmental or carbon matters? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.8 Communications impact Does the report contain any information that has an impact on the council’s communications activities? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.9 Risk impact Is there a risk impact? Yes ☐ No ☒ If Yes, please provide a brief summary of the key risks and potential impacts, highlighting where the risk(s) are assessed and recorded (e.g. Corporate or Service or Project Risk Registers), and how they are managed? 5.10 Armed Forces Covenant Duty Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it relate to healthcare, housing, or education services for in-Service or ex- Service personnel, or their families, or widow(er)s)? Yes ☐ No ☒ If Yes, please provide a brief summary of the provision which has been made to ensure there has been appropriate consideration of the particular needs of the Armed Forces community to make sure that they do not face disadvantage compared to other citizens in the provision of public services. 5.11 Children’s rights and wellbeing impact Does the report contain any information regarding any council activity, service delivery, policy, or plan that has an impact on children and young people up to the age of 18, or on a specific group of these? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact and the provision that has been made to ensure there has been appropriate consideration of the relevant Articles from the United Nations Convention on the Rights of the Child (UNCRC). If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been carried out? Yes ☐ No ☐ Item 6 Page 32 of 124
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Https://nlcgov.sharepoint.com/sites/AUR-INTERNALAUDITFILES/Shared Documents/Investigations/2025-26/1000.2026.001 Business Growth Grants Investigation/A - Findings & Report/A07 20260708 Final Report - Business Growth Grant Investigation.docx 1 INTERNAL AUDIT REPORT INVESTIGATION: BUSINESS GROWTH GRANT APPLICATIONS Headlines This report presents Internal Audit’s findings in response to concerns raised by the Chief Officer (Place) regarding potentially fraudulent activity within applications submitted to the Council’s Business Growth Fund (BGF) during the 2023-25 funding programme. Work was undertaken in accordance with the Council’s Corporate Fraud Policy, the Global Internal Audit Standards and the Internal Audit Charter. Concerns were first raised by Service officers during routine review of BGF applications, where unusual patterns were observed, most notably the repeated use of the same supplier. Five BGF applications were identified at this stage. Of these, two had been approved and paid, while the remaining three were identified and investigated by the Service prior to approval and subsequently declined. A preliminary review conducted by the Service was subsequently referred to Internal Audit for further investigation. We undertook a comprehensive review of these applications and supporting documentation and assessed the extent to which they met BGF eligibility criteria and whether the appraisal process and associated controls were operating effectively. During an extended review of BGF records, we also identified one additional application displaying similar characteristics which had been approved and paid. The key findings and conclusions are detailed in sections 3 and 4 of this report. Based on the evidence reviewed, we consider that all six of the applications examined are potentially fraudulent, with three resulting in grant payments totalling £134,000 (as detailed at Appendix 1). Our work identified that each application included at least one quotation from a company which could not be substantiated as a legitimate supplier and contained materially misstated documentation, including non‑independent quotations, identical document authorship and, where the application was approved, inconsistencies in claim evidence. Additionally, we identified a number of weaknesses in the appraisal process, including insufficient scrutiny of supplier providing quotations, inadequate review of financial evidence, and a lack of monitoring to identify repeated use of the same suppliers. These issues arose due to insufficient clarity around the required checks for identifying potential fraud, combined with a failure to fully adhere to the expectations of the BGF guidance, particularly in relation to the verification of supporting evidence for applications and funding claims We consider that the arrangements in place with regards to appraising and approving applications, reviewing claims for payment and confirming that grants have been used for the intended purpose need to be strengthened, therefore we have made recommendations to that effect at section 5. We acknowledge that the Service has already implemented improvements in these areas. Given the seriousness of the findings and the indicators of potential organised fraudulent activity, Internal Audit intends to share relevant intelligence with Police Scotland in accordance with the Council’s Counter Fraud Policy. The report will also be shared with the Council’s external auditor, Audit Scotland. Report status FINAL Audit ref 1000/2026/001 Date issued 08/07/2026 Issued to Chief Officer (Place), Enterprise Manager and Enterprise Development Manager Copied to Chief Executive, Depute Chief Executive Item 6 Page 33 of 124
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Https://nlcgov.sharepoint.com/sites/AUR-INTERNALAUDITFILES/Shared Documents/Investigations/2025-26/1000.2026.001 Business Growth Grants Investigation/A - Findings & Report/A07 20260708 Final Report - Business Growth Grant Investigation.docx 2 1. Background 1.1 The Business Growth Fund (BGF) is a discretionary grant scheme administered by the Enterprise Team and governed by a comprehensive suite of guidance documents (primarily, the BGF Guidance Document and BGF Appraisal Form) which set out the required processes, controls and evidential requirements for the award and monitoring of business growth grants. These documents operate alongside the Council’s Financial Regulations, Subsidy Control requirements and internal procedures for grant administration. 1.2 The BGF is designed to support the growth, sustainability and productivity of small and medium‑sized enterprises within North Lanarkshire, with a focus on projects that deliver measurable economic benefits, such as increased turnover and job creation. To promote appropriate use of public funds, applicants are required to engage with a Business Gateway Adviser prior to submitting an application and must meet clearly defined eligibility criteria. 1.3 Applicants must submit a supporting documentation proportionate to the nature of the proposed project. This includes evidence of incorporation, confirmation of business premises within North Lanarkshire, a business plan, the latest financial accounts, current management accounts, 12-month cashflow projections and, where relevant, formal quotations from two independent suppliers 1.4 Enterprise Development Officers (EDOs) are responsible for undertaking a detailed appraisal of applications. This includes assessing alignment with BGF priorities, verifying eligibility, reviewing the completeness and accuracy of supporting documentation and evaluating financial information to determine whether the project is likely to contribute to business growth. The Appraisal Form provides a structured framework for this process, including validation of the supplier quotations, confirmation that expenditure is eligible and assessment of whether a genuine funding gap exists. All funding recommendations are subject to management review and approval, ensuring appropriate oversight and segregation of duties. 1.5 Grant funding is paid retrospectively after successful applicants have completed their project, settled supplier invoices and submitted a claim supported by formal invoices, corresponding business bank statements and where appropriate, photographic evidence of completed works. 1.6 The Council retains responsibility for ensuring that all funding distributed through the scheme is administered with appropriate stewardship. As part of this, successful applications require ongoing monitoring during project delivery and after completion, including ad-hoc site visits, review of photographic evidence and key performance indicators, where appropriate. 1.7 Overall, the BGF framework is designed to balance accessibility for local businesses with robust safeguards to protect public funds. The combination of clearly defined eligibility criteria, mandatory supporting documentation, structured appraisal processes, segregation of duties and post‑project monitoring establishes a strong control environment for the administration of the scheme. 2. Work Undertaken 2.1 Internal Audit reviewed the documentation initially provided by the Enterprise Team and held discussions with the Enterprise Manager to gain an understanding of the application and appraisal processes, including how applications are assessed, the checks undertaken at both appraisal and claim stages, and how the requirements of the BGF Guidance and Appraisal Form are interpreted and applied. 2.2 The application files for the five grants flagged by the Enterprise team were obtained and reviewed for the completeness and validity of the supporting documentation to assess the appropriateness of the decisions made, including: • Assessing the authenticity and independence of supplier quotations to ensure that suppliers were legitimate businesses, quotations contained sufficient business information and there were no apparent links between applicants and suppliers. • Reviewing the properties and metadata of documentation to confirm authorship and the timing of document creation and amendment. • Reviewing email correspondence to confirm that communications and enquiries relating to applications originated from the applicant. • Examining claim evidence for the two initial applications where grant payments had been made to confirm compliance with retrospective payment requirements and that recorded expenditure aligned with approved quotations and project descriptions. • Identifying wider patterns and trends across applications, including recurring suppliers, similarities in business plan structures and quotations and documentation created or amended by the same individuals across apparently unrelated businesses. 2.3 As a result of this analysis, we identified one further previously approved application exhibiting similar characteristics to those already identified by the Enterprise Team. This application was therefore added to the scope of our review. Item 6 Page 34 of 124
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Https://nlcgov.sharepoint.com/sites/AUR-INTERNALAUDITFILES/Shared Documents/Investigations/2025-26/1000.2026.001 Business Growth Grants Investigation/A - Findings & Report/A07 20260708 Final Report - Business Growth Grant Investigation.docx 3 3. Investigation Findings 3.1 Although comprehensive guidance exists for the administration of the BGF, our work confirmed that key elements of the required appraisal and verification processes were not consistently applied in practice. We consider that this contributed to weaknesses in the identification and challenge of irregular or potentially fraudulent applications. 3.2 From our review of the quotations submitted with the applications reviewed, we identified a number of issues as follows: • We were unable to establish the legitimacy of some of the businesses providing quotations, with several lacking business identifiers such as trading addresses, VAT registration numbers, websites and Companies House listings. • There were multiple instances where both quotations submitted for individual applications were linked through shared personnel, business addresses or document authorship, suggesting that the quotations were not independent. • A number of the suppliers providing quotations appeared repeatedly across unrelated applications and in some instances, within the same application. 3.3 Despite the BGF Guidance and Appraisal form requiring checks to ensure suppliers exist and can deliver the goods or services described, these issues were not identified by the Enterprise Team during their review of the applications. Additionally, there were no routine checks undertaken, or documentation held, to enable EDOs to easily identify the same businesses providing quotations for different applications. 3.4 Several applications contained financial accounts, management information or cashflow projections that were incomplete, outdated or not prepared by the applicant. In some cases, only partial‑year information was provided, or management accounts were missing. There was limited evidence to demonstrate that the adequacy of this information was sufficiently scrutinised and challenged before applications were progressed, contrary to the requirement to assess financial viability and expected turnover growth. 3.5 A number of applications sought grant support for large-scale infrastructure or IT investments that appeared disproportionate to the applicant’s size, operating model, premises or financial capacity. While it is recognised that assessing proportionality is not explicitly defined within the BGF Guidance, we consider that the scale and nature of some proposals should reasonably have prompted further enquiry, yet there was no evidence of challenge in cases where the level of proposed expenditure appeared inconsistent with the applicant’s business profile. 3.6 Our review of document metadata found that application forms, business plans and supplier quotations across multiple applications appear to have been created or modified by the same, small number of individuals. In some cases, the wording, structure and formatting of documents were almost identical across separate applications. We also noted attempts to disguise the identity of individuals involved by altering display names in emails or documents so that correspondence appeared to originate from the applicant businesses. While the examination of document metadata is not an activity that would ordinarily be expected of officers during the appraisal process, these findings highlight underlying irregularities that were not detected through routine checks and provide important context regarding the coordinated nature of the applications. 3.7 The BGF operates a retrospective payment basis, requiring applicants to submit supplier invoices, bank statements and, where relevant, photographic evidence of completed works. For the successful applications that proceeded to payment, we noted the following: • The applicant’s bank statements indicate that they had received significant director-funded cash injections in the period immediately before invoices were paid. The timing and scale of these injections suggest that the applicants may have lacked the financial capacity to fund the projects independently and may have been reliant on temporary transfers to demonstrate eligibility. • Only invoices and bank statements were provided to support completion of the work. We found no evidence that additional evidence was requested or received to corroborate that the improvements were delivered. 3.8 There is a requirement within the BGF Guidance for grant award decisions to be reviewed and authorised as an additional level of assurance. Although there is evidence that the decisions were authorised, we found no evidence that management had identified or challenged the deficiencies within the appraisals, including incomplete documentation, supplier irregularities, repeated suppliers, or the unusual characteristics of the projects. This indicates weaknesses in the oversight arrangements designed to ensure compliance with guidance and the robustness of appraisal decisions. 3.9 Subsequent to the payment of Application 1 (as detailed in Appendix 1), the Enterprise Team conducted a follow‑up visit to the business and confirmed that they had purchased goods and services broadly consistent with those set out in the approved application. It should be noted, however, that due to the nature of certain elements of the project (e.g. cabling upgrades and other infrastructure works), it was not possible to retrospectively evidence all elements of expenditure in full. Nonetheless, based on the information available at the time of the visit, the Enterprise Team advised that they were satisfied that the overall aims and objectives of the project for which grant funding was awarded had been successfully achieved. Item 6 Page 35 of 124
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Https://nlcgov.sharepoint.com/sites/AUR-INTERNALAUDITFILES/Shared Documents/Investigations/2025-26/1000.2026.001 Business Growth Grants Investigation/A - Findings & Report/A07 20260708 Final Report - Business Growth Grant Investigation.docx 4 4. Conclusions 4.1 Our review of the five applications highlighted by the Enterprise Team and the additional application identified by ourselves, concluded that all six applications included at least one quotation from a company which could not be substantiated as a legitimate supplier. Three of these applications were approved and paid, with the remaining three being declined. 4.2 Based on the evidence reviewed, we have concluded that each application contained fraudulent or materially misstated documentation, including non‑independent quotations, often from suppliers that could not be verified as legitimate businesses, identical document authorship and, where the application was approved, inconsistencies in claim evidence. These factors provide sufficient grounds to conclude that where payments were made, these were on the basis of false representations. 4.3 Our work also confirmed that, although comprehensive BGF guidance exists, the appraisal and verification controls detailed in the guidance were not sufficient in practice to identify or challenge high‑risk or irregular applications. Key checks relating to supplier legitimacy, independence of quotations, financial viability, proportionality of proposed expenditure and completeness of supporting documentation were not consistently undertaken or evidenced in line with the guidance. In particular, we noted that the requirement to obtain two independent quotations was, in several cases, treated as a procedural requirement rather than a control, with limited verification of supplier credibility or independence. 4.4 Weaknesses in oversight and management review contributed to the progression of higher‑risk applications and the failure to identify underlying patterns of potentially coordinated activity. Assurance processes did not detect recurring supplier names, shared document formatting or authorship, or similarities in narrative across applications. In addition, deficiencies in financial documentation or unusual project characteristics were not consistently challenged. Officers were not provided with the appropriate tools or mechanisms, such as a centralised tracker of supplier usage or recurring applicant data, to identify emerging trends or concentrations of risk. Consequently, indicators of organised submission, potentially involving external parties, were not identified or escalated in a timely manner. 4.5 At the claim stage, there was insufficient follow‑up to verify that funded works had been completed prior to payment. Although the scheme operates on a retrospective basis, assurance was limited to the review of invoices and bank statements. No additional corroborating evidence (such as photographs of completed works, delivery confirmations, contracts or site visits) was requested or obtained. This limited approach reduced the ability to confirm that grant-funded activities had actually been delivered as intended. Item 6 Page 36 of 124
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Https://nlcgov.sharepoint.com/sites/AUR-INTERNALAUDITFILES/Shared Documents/Investigations/2025-26/1000.2026.001 Business Growth Grants Investigation/A - Findings & Report/A07 20260708 Final Report - Business Growth Grant Investigation.docx 5 5. Recommendation The Chief Officer (Place) should: (1) Undertake a review of the processes and procedures governing the administration of the Business Growth Fund, to strengthen the appraisal, oversight and approval of grant applications and payment claims. This should include checks that support the identification and prevention of potentially fraudulent or irregular applications and should incorporate: • Clearly defined mandatory checks to verify supplier legitimacy and the independence of quotations, confirm that financial documentation is complete and demonstrates business viability, and assess whether proposed expenditure is proportionate and demonstrates best value. • Enhancing management information and review arrangements to enable officers and managers to identify recurring suppliers, similarities in supporting documentation or other patterns that warrant further challenge or escalation. • Establishing a risk-based approach to verification of grant claims, ensuring that the level of assurance is proportionate to the risk and value of the award, whilst providing adequate assurance that funded works have been delivered in line with the approved application. (2) Ensure that all officers involved in the administration of the Business Growth Fund are provided with the revised procedures and are advised of the need to fully comply with them. Management Response (1) A review of Business Growth Fund processes and procedures has been undertaken to ensure that the appraisal, oversight and approval of grant applications and payment claims is strengthened. The following steps in the process have been introduced, or further strengthened, to address the recommendations as follows: a) All applicants must be engaged with the Business Gateway Lanarkshire service and have a named Business Adviser or Senior Business Adviser. Speculative applications that come direct to the Council are no longer accepted. The grant application form is supplied to businesses by their adviser once an eligible project has been identified. b) Enterprise Development Officers must undertake a pre-application visit to the company to discuss the proposed project and assess grant feasibility. This visit is undertaken jointly, alongside the Business Gateway Lanarkshire Adviser, where possible. c) An Updated grant appraisal guidance document has produced and issued to officers to ensure consistency in approach and maintain focus in efforts to work individually and as a team to prevent and minimise fraud risk. d) The process for checking the two independent quotes provided with a grant application has been strengthened. The officer appraising the application must review each independent quote by checking both suppliers operate legitimate businesses and that the nature of the work/services is in line with what the suppliers would normally undertake. The appraising officer also checks on Companies House that there is no common directorship or potential other relationship between applicant companies and the supplier companies. e) The appraisal to verify that the quotes represent value for money has also been strengthened. Where expenditure does not appear proportionate, additional checks are undertaken. For example, this has included checking alignment with previous project expenditure for similar activities/spend, checking prices for similar items (e.g. check online for specific items of capital expenditure), and checking with other Council services (e.g. IT for IT projects and Quantity Surveyors for infrastructure improvements). f) All supplier quotations are now listed on a cumulative spreadsheet so that recurring suppliers can be readily identified and investigated accordingly. g) In relation to business viability, we request cash flow statements, up-to-date audited accounts and management accounts prepared within the last 3-months as standard. Officers have received further training on financial appraisal to support the analysis and interrogation of this information. h) The Assistant Enterprise Development Officer supports the appraising officers by undertaking a series of financial ratio checks on the audited and management accounts. These include net profit margin, operating expense ratio, current ratio, debt ratio and cash reserve ratio. The cash reserve ratio serves two purposes: to ensure sufficient reserves for short-term survivability and to verify the need for grant funding. Consideration of requesting a current bank balance is also underway moving forward. i) As was previously the case, a check with other council services is undertaken. Company name, address, business owners name and a short project description is sent to Planning, Building Standards, Licensing, Environmental Health, Trading Standards, Council Tax and non-domestic rates to ensure there are no concerns, compliance issues or arrears with the Council. Any responses from services are reviewed accordingly. Item 6 Page 37 of 124
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Https://nlcgov.sharepoint.com/sites/AUR-INTERNALAUDITFILES/Shared Documents/Investigations/2025-26/1000.2026.001 Business Growth Grants Investigation/A - Findings & Report/A07 20260708 Final Report - Business Growth Grant Investigation.docx 6 Management Response j) Following appraisal, all Business Growth Fund applications are now presented to a panel consisting of the appraising Enterprise Development Officers, the Assistant Enterprise Development Officer, Enterprise Support Officer and the Enterprise Development Manager. This enables full visibility and discussion on all applications submitted to the fund. It also enables officers to identify any similarities with other applications, knowledge of suppliers, previous engagement with applicant businesses, knowledge of similar projects and wider sectoral knowledge and expertise. The panel review also allows for further questions to be raised and concerns addressed. k) A final compliance check is then undertaken of all the company, application, quotations, financial appraisal and other evidence by the Assistant Enterprise Development Officer before a final check and final approval is undertaken by the Enterprise Development Manager. l) Work is in progress with Legal services to establish a protocol with Police Scotland to undertake police checks on grants which meet set criteria around values over £10K, operating in a high-risk sector and where there are any concerns flagged by other council services. Claim Verification m) There was already a robust claim verification process in place prior to payment of grant claims, which includes: • Companies return their claim form, outcomes and asset register along with their invoices and bank statements as part of the claims process. • All invoices must contain VAT details and be addressed to the applicant business/owner. The address must match the business address on the application. • The invoices are checked to ensure they have the expected supplier name, logo, address, VAT registration and description of goods; services and amount are in order and the expenditure is eligible. The date is also checked to ensure it falls after the grant award. The format of the invoice is checked to ensure it matches any previous invoices and is in an expected format. Checks are made against the quotation to ensure they match the supplier information and works quoted. • Bank evidence is also checked. Bank statements should be in pdf format, with account name, address, sort code and account number shown. Checks are undertaken to ensure the item’s date, name/reference that matches the invoice and amount are all correct. Bank statement details are checked to ensure they match the bank details used to set the company up on the Council’s creditors’ system. n) As part of the claim verification process, we also now request photos of the items in situ where capital expenditure has been supported and/or photos of the completed infrastructure works, where practicable. o) Following grant payment, officers also arrange a visit to the companies to review the project implementation and spend. This takes place within a 6-month timeframe. p) The Enterprise Team continues to mandate the right to claw back grant payments – this is written into the grant award paperwork and forms the basis of the grant agreement the business signs up to. q) The External Funding team within Place continue to undertake compliance checks on Business Growth Fund grant awards to ensure UK Government fund governance requirements, including fraud risk assessment/minimisation, is met. (2) The Enterprise team has been fully briefed on their responsibilities and the requirement to remain vigilant and alert to the risk of fraudulent activity within all grant funding programmes and ensure compliance with established procedures. During 2025/26, and into the current 2026/27 financial year, appraising officers have displayed diligence and demonstrated improved controls by continuing to flag and decline non-compliant / potentially fraudulent application cases. Responsible Officer: Caroline Brown, Enterprise Development Manager Timescale: June 2026 Item 6 Page 38 of 124
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Https://nlcgov.sharepoint.com/sites/AUR-INTERNALAUDITFILES/Shared Documents/Investigations/2025-26/1000.2026.001 Business Growth Grants Investigation/A - Findings & Report/A07 20260708 Final Report - Business Growth Grant Investigation.docx 7 Appendix A – Financial Totals of Suspected Fraudulent Grant Awards As detailed in the body of the report, Internal Audit is of the opinion that three grant awards have been made in response to applications supported by falsified quotations and overinflated costs. These applications are broken down as follows: Application Value of Grant Award 1 (Awarded July 2024) £41,000 2 (Awarded Sept 2024) £43,000 3 * (Awarded Dec 2023) £50,000 TOTAL £134,000 * This application was identified during our extended review as exhibiting a number of similar features to the applications originally reported to Internal Audit by the Enterprise Team. This application shows some similarities to cases previously identified but at a lower frequency and severity. The main area of concern relates to quotations for IT works, which account for 46.5% of total project costs. This differs from other applications where higher-risk elements made up the full award. There are also other seemingly legitimate cost components within this project. While some quotations raise questions and one linked supplier has been identified, the main supplier seen in other cases is absent and there is evidence the work was completed. Taken together, these factors indicate that, although there are identifiable risk indicators, they are not sufficiently widespread or substantive to support a conclusion of fraudulent activity at this stage. Item 6 Page 39 of 124
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North Lanarkshire Council Report Audit and Scrutiny Panel Does this report require to be approved? ☐ Yes ☒ No Ref FS/ASP/PRAug26 Date 20/08/26 Internal Audit: Progress Report From Francis Scott, Chief Officer (Audit and Risk) E-mail scottfr@northlan.gov.uk Executive Summary The purpose of this report is to provide an overview of Internal Audit activity and audit reports issued since the last update to the Panel in May 2026, namely: • Housing and Corporate Maintenance and Improvement Services Contract • Leadership and Operating Model • External Legal Fees • Debt Management This report will also provide an update on performance management. Recommendations The Panel is invited to: (a) note the content of the Internal Audit reports together with the associated management responses. (b) consider whether there are any issues raised by Internal Audit which the Panel consider are sufficiently significant to require a further report from management to be submitted to a future meeting of the Panel. (c) request that Internal Audit report to future meetings of the Panel on the progress in implementing agreed management actions categorised as ‘High’ or ‘Medium’ priority, and (d) otherwise note this report. The Plan for North Lanarkshire Priority All priorities Ambition statement All ambition statements Programme of Work Statutory / corporate / service requirement Item 7 Page 41 of 124
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1. Background 1.1 The 2026-27 Internal Audit Plan was approved by the Audit and Scrutiny Panel in May 2026. The Internal Audit Charter requires that Internal Audit Progress Reports are presented to each meeting of the Panel, providing an update on the progress against the Internal Audit Plan and any other Internal Audit activity. 2. Report Audit reviews completed in the period 2.1 The audit reports summarised below have been completed since the last meeting of the Panel in May 2026 and include the remaining three audits from the 2025/26 Internal Audit Plan. While the reports noted contain recommendations for improvement, all have been assessed as providing positive levels of assurance. Management have responded positively to these reports and satisfactory responses and commitments to audit recommendations have been received. 2.2 Appendix 1 provides detailed definitions of the priorities assigned to audit recommendations, and the factors considered when determining the level of assurance provided in the audit opinion. Full copies of these audit reports have been included in the meeting paper in line with the approved reporting protocol. Housing and Corporate Maintenance and Improvement Services Contract Internal Audit Opinion Reasonable assurance Recommendations High 0 Medium 1 Low 1 2.3 This audit reviewed the Council’s compliance with established contract management procedures for the Housing Contract, including the processes for managing and awarding Core Project works. Internal Audit continues to review this contract given its significance and value and this report is the second in a planned series of reviews designed to provide ongoing assurance over the arrangements for managing and monitoring the contract. 2.4 We are generally satisfied that the governance and contract management arrangements are effective, with appropriate processes in place, and operating to monitor quality, assess performance, and address underperformance. We also noted that expected Core Project procedures are generally being followed, with projects appropriately identified, progressed, and assessed, and we did not identify evidence of inappropriate awards or material non-compliance. Some areas highlighted for improvement include ensuring the arrangements for documenting evaluations for Core Project tenders to ensure decisions are clear, transparent and supported by robust evidence demonstrating best value. Leadership and Operating Model Internal Audit Opinion Reasonable assurance Recommendations High 0 Medium 1 Low 1 2.5 The Leadership and Operating Model (LOM) supports the delivery of the Council’s ambition statements in The Plan for North Lanarkshire by implementing an integrated place-based model centred on community hubs. This audit involved a review of the Item 7 Page 42 of 124
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arrangements for implementing and progressing the LOM and evaluating the benefits and outcomes arising from its implementation to facilitate strategic direction. 2.6 We are satisfied that there is appropriate oversight and governance arrangements in place for developing and monitoring the LOM, interdependencies with other key workstreams are considered, and performance is being assessed using the benefits realisation framework and reported to elected members and senior management through dashboards and impact frameworks. We have identified some areas for improvement, including a requirement to more clearly demonstrate the link between the outcomes of the LOM and action plans for monitoring progress. External Legal Fees Internal Audit Opinion Reasonable assurance Recommendations High 0 Medium 3 Low 0 2.7 The purpose of this audit was to assess compliance with the recently introduced process for instructing external legal advice and provide assurance that all instructions are supported by a business case and have been appropriately authorised. We are generally satisfied that the new arrangements have been successfully introduced and are operating as intended. 2.8 Areas for improvement identified include enhancements to processes and documentation, record keeping and expenditure monitoring, and governance and reporting arrangements to improve consistency, transparency and management assurance. Debt Management Internal Audit Opinion Reasonable assurance Recommendations High 0 Medium 1 Low 2 2.9 This audit aimed to provide assurance that the Council has adequate and effective arrangements in place to support the management, recovery and write-off of debt and considered arrangements for the recovery of salary overpayments relating to former employees. We noted that key elements of the debt management framework are operating effectively including the availability of documented guidance, the use of the ASH debtors’ system to support recovery activity, established write-off procedures and the provision of quarterly debt recovery reports to Service SMTs. 2.10 We have identified a few areas for improvement relating to the consistent application of debt management arrangements across Services in accordance with the Sundry Debt Recovery Guide. The audit also identified instances where debtor invoices had not been raised for salary overpayments relating to former employees. Item 7 Page 43 of 124
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Performance Management 2.11 In line with Internal Audit performance management framework, two performance indicators are subject to quarterly reporting to the Panel. 2.12 The first indicator is the implementation of agreed actions arising from Internal Audit reports by the implementation date. In the period to May 2026, 64% of agreed actions have been implemented by the implementation date (the previous update for the period to May 2026 had a 69% completion rate). 2.13 The second performance indicator measures client satisfaction. The results received in the period continue to show positive feedback, with 100% of respondents agreeing that Internal Audit added value by assisting in providing assurance, that findings were clearly and accurately communicated and that audit staff were professional and courteous, and 100% agreeing that the audit reports were relevant and constructive. Appendix 2 provides a summary of the questions we ask audit clients at the conclusion of each audit. 3. Measures of success 3.1 Internal Audit reports annually on its performance to the Panel and is also subject to review annually by the Council’s appointed external auditors. 4. Supporting documentation Appendix 1 Audit Grading Definitions Appendix 2 Internal Audit Client Feedback Results Attached Pack of Audit Reports Francis Scott Chief Officer (Audit and Risk) Item 7 Page 44 of 124
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5. Impacts 5.1 Public Sector Equality Duty and Fairer Scotland Duty Does the report contain information that has an impact as a result of the Public Sector Equality Duty and/or Fairer Scotland Duty? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? If Yes, has an assessment been carried out and published on the council’s website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality- and-fairer-scotland-duty-impact-assessments Yes ☐ No ☒ 5.2 Financial impact Does the report contain any financial impacts? Yes ☐ No ☒ If Yes, have all relevant financial impacts been discussed and agreed with Finance? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.3 HR policy impact Does the report contain any HR policy or procedure impacts? Yes ☐ No ☒ If Yes, have all relevant HR impacts been discussed and agreed with People Resources? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.4 Legal impact Does the report contain any legal impacts (such as general legal matters, statutory considerations (including employment law considerations), or new legislation)? Yes ☐ No ☒ If Yes, have all relevant legal impacts been discussed and agreed with Legal and Democratic? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.5 Data protection impact Does the report / project / practice contain or involve the processing of personal data? Yes ☐ No ☒ If Yes, is the processing of this personal data likely to result in a high risk to the data subject? Yes ☐ No ☐ If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e- mailed to dataprotection@northlan.gov.uk Yes ☐ No ☐ 5.6 Technology / Digital impact Does the report contain information that has an impact on either technology, digital transformation, service redesign / business change processes, data management, or connectivity / broadband / Wi-Fi? Yes ☐ No ☒ Item 7 Page 45 of 124
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If Yes, please provide a brief summary of the impact? Where the impact identifies a requirement for significant technology change, has an assessment been carried out (or is scheduled to be carried out) by the Enterprise Architecture Governance Group (EAGG)? Yes ☐ No ☐ 5.7 Environmental / Carbon impact Does the report / project / practice contain information that has an impact on any environmental or carbon matters? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.8 Communications impact Does the report contain any information that has an impact on the council’s communications activities? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.9 Risk impact Is there a risk impact? Yes ☒ No ☐ If Yes, please provide a brief summary of the key risks and potential impacts, highlighting where the risk(s) are assessed and recorded (e.g. Corporate or Service or Project Risk Registers), and how they are managed? Effective responses by management to the weaknesses, control issues and/or areas of improvement identified by Internal Audit will increase the likelihood of the Council achieving its ambitions by improving control frameworks and more effectively mitigating potential risks and threats to the achievement of planned outcomes. 5.10 Armed Forces Covenant Duty Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it relate to healthcare, housing, or education services for in-Service or ex- Service personnel, or their families, or widow(er)s)? Yes ☐ No ☒ If Yes, please provide a brief summary of the provision which has been made to ensure there has been appropriate consideration of the particular needs of the Armed Forces community to make sure that they do not face disadvantage compared to other citizens in the provision of public services. 5.11 Children’s rights and wellbeing impact Does the report contain any information regarding any council activity, service delivery, policy, or plan that has an impact on children and young people up to the age of 18, or on a specific group of these? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact and the provision that has been made to ensure there has been appropriate consideration of the relevant Articles from the United Nations Convention on the Rights of the Child (UNCRC). If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been carried out? Yes ☐ No ☐ Item 7 Page 46 of 124
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Appendix 1 Audit Grading Definitions Audit reports are graded with an overall assurance opinion, and any issues and associated recommendations are classified individually to denote their relative importance, in accordance with the definitions in the tables below. Definition of audit assurance and recommendation categories Assurance Confidence based on sufficient evidence that internal controls are in place, operating effectively and objectives are being achieved. Assurance opinion Substantial Assurance There are minimal or minor control weaknesses that present low risk to the control environment. The control environment has substantially operated as intended although some minor errors have been detected. Very few or no improvements are needed. Reasonable Assurance There are some control weaknesses that present a low to medium risk to the control environment. The control environment has mainly operated as intended although errors have been detected. Some improvements should be made. Limited Assurance There are significant control weaknesses that present medium to high risk to the control environment. The control environment has not operated as intended. Significant errors have been detected. Substantial improvements should be made. No Assurance There are fundamental control weaknesses that present an unacceptable level of risk to the control environment. The control environment has fundamentally broken down and is open to significant error or abuse. Immediate and major changes need to be made. Organisational impact Major The weaknesses identified during the review have left the Council open to significant risk. If the risk materialises it would have a major impact upon the organisation. Moderate The weaknesses identified during the review have left the Council open to medium risk. If the risk materialises it would have a moderate impact upon the organisation. Minor The weaknesses identified during the review have left the Council open to low risk. If the risk materialises it would have a minor impact upon the organisation. Recommendation priority High Significant control failure or weakness that, if not addressed, may lead to a major financial, operational or reputational risk to the organisation and/or significantly impact the successful delivery and achievement of the objectives of the area under review. Urgent/Immediate action is required. Medium Control failure or weakness that, if not addressed, may lead to a moderate financial, operational or reputational risk to the organisation. Weakness may be individually significant, but it is unlikely to affect the successful delivery and achievement of the overall objectives of the area under review. The risk of error would, however, be significantly reduced if corrective action were taken. Prompt action is required Low Control failure or weakness that may lead to a minor financial, operational or reputational risk to the organisation. Weakness does not appear to significantly affect the ability to meet objectives. Minor issue raised to improve the efficiency and effectiveness of controls. Item 7 Page 47 of 124
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Appendix 2 Internal Audit Client Feedback Results Responses received in this period from 2 clients related to assignments reported to the Panel. Question Strongly Agree or Agree (%) Neither Agree nor Disagree (%) 1. Internal Audit added value to my area by assisting in providing assurance and/or identifying weaknesses and/or improvements in relevant governance/business process and internal controls 100% 0% 2. Internal Audit findings were accurate and clearly communicated 100% 0% 3. The audit report made relevant, constructive and practical recommendations to help improve operations 100% 0% 4. Internal Audit staff were professional and courteous throughout the audit process 100% 0% Where management raise concerns over Internal Audit’s work, these matters are discussed with relevant senior management to fully understand the nature of any concerns and, where it is considered appropriate, to identify areas for improvement. We also seek Services’ views on what they liked or disliked about the audit process and comments received are used to inform future action plans for improving the service provided by Internal Audit. Item 7 Page 48 of 124
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1 INTERNAL AUDIT REPORT HOUSING AND CORPORATE MAINTENANCE AND INVESTMENT SERVICES CONTRACT Headlines The Enterprise Project supports delivery of The Plan for North Lanarkshire by creating an integrated approach to repairs, maintenance and investment for the Council’s housing, corporate and roads and infrastructure assets. As part of this project, in May 2024, the Council awarded the Housing and Corporate Maintenance and Investment Services contract (the Housing Contract) to Mears Ltd. Mears is responsible for Core Services, including day-to-day, reactive and routine maintenance, statutory compliance, servicing and inspections and delivers Core Projects and Programmes involving planned investment and life-cycle replacement of major components such as kitchens, bathrooms, flooring and roofs. The purpose of this review was to provide assurance on the Council’s compliance with established contract management procedures, including the processes for managing and awarding Core Project works. Internal Audit continues to review this contract given its significance and value. This audit represents the second in a planned series of reviews designed to provide ongoing assurance over the arrangements for managing and monitoring the contract. Based on the results of our work, we have categorised this audit as offering reasonable assurance. We are generally satisfied that the governance and contract management arrangements are effective, with appropriate processes in place, and operating to monitor quality, assess performance, and address underperformance. We also noted that expected Core Project procedures are generally being followed, with projects appropriately identified, progressed, and assessed, and we did not identify evidence of inappropriate awards or material non- compliance. The audit did, however, identify some areas for improvement. These are outlined in section 3 of this report and include the need to improve arrangements for documenting evaluations for Core Project tenders to ensure decisions are clear, transparent and supported by robust evidence demonstrating best value. Internal Audit Opinion Reasonable assurance Priority of Recommendations High Medium Low 0 1 1 Organisational Impact Moderate Report status FINAL Audit ref 0900/2026/011 Date issued 30/06/2026 Issued To Chief Officer (Asset and Procurement Solutions) and Chief Officer (Housing and Communities) Copied To Chief Executive, Depute Chief Executive, Contract Support Manager, Contract Performance and Assurance Manager, Repairs and Maintenance Manager (Housing) and Repairs and Maintenance Manager (Corporate) Appendix 3 Item 7 Page 49 of 124
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2 1. Executive Summary Objectives The audit sought to confirm the following: • Contract management arrangements are consistent with contractual terms, Council policies and include appropriate mechanisms for monitoring quality, assessing performance and challenging underperformance. • Arrangements for managing, awarding and reporting on Core Projects operate consistently in line with agreed procedures and corporate expectations, and are supported by appropriate documentation evidencing approvals and decisions. This engagement has been conducted in accordance with the Global Internal Audit Standards. The Internal Audit section reports formally on conformance with these standards to the Audit and Scrutiny Panel. We would like to thank officers involved in this audit for their cooperation and assistance. 2. Findings and Recommendations Good practice identified We noted the following areas of good practice during the audit: • A five-tier governance structure has been established, with defined roles, regular meetings, and formal Terms of Reference, supported by structured agendas, minutes, and clear escalation routes for overseeing both strategic and operational issues. • Comprehensive contract management arrangements are in place, supported by standardised tools and templates, including a change control register, spend tracker, risk register, service credit calculator, and social value tracker, to ensure consistency. • Independent oversight is provided by the Contract Performance and Assurance team, and all contract documents are held in a central location accessible to relevant officers from both the Council and Mears. • Detailed Key Performance Indicators (KPIs) and Strategic Performance Indicators (SPIs) have been developed and are fully documented, both within the contract and within a separately developed Performance Handbook, which includes definition sheets outlining calculation methodology, data sources and responsibilities. • Detailed quality verification arrangements are in place to ensure source data used in KPI calculations is regularly reviewed, with any issues promptly identified and addressed in conjunction with Mears. • In addition to the formal governance structure, quarterly meetings involving senior officers from both the Council and Mears are held to discuss more detailed operational issues. An Action Plan has been developed to support these meetings, ensuring that ongoing issues and those identified through verification exercises are recorded and continue to be monitored and reviewed until resolved. • Regular reporting on performance to senior officers has been established through level 3 and 4 governance groups with issues escalated to level 2 if required. Twice-yearly reporting to the Housing Committee has also been established, covering KPIs/SPIs, social value, expenditure, and service credits. • A Core Project Register and central contract management filing structure have been established to support the tracking and monitoring of progress across Core Projects, and to provide a framework for the central storage and accessibility of key documentation to evidence decisions. Key areas requiring management action (High Priority) No areas requiring urgent management action have been identified. Other areas for improvement (Medium Priority) One other area for improvement was identified: • There is scope to improve arrangements for documenting evaluations for Core Project tenders to ensure decisions are clear, transparent and supported by robust evidence demonstrating best value. Item 7 Page 50 of 124
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3 3. Action Plan Housing and Corporate Maintenance and Investment Services Contract 0900/2026/011 Ref Finding 1 There is scope to improve arrangements for documenting evaluations for Core Project tenders to ensure decisions are clear, transparent and supported by robust evidence demonstrating best value. We reviewed a sample of eight core projects, selected from the Core Projects Register, comprising four Housing projects and four Corporate Property projects. For seven of these projects, we found that although some documentation or evidence of evaluation or benchmarking was available, the assessment of contractor submissions was not clearly recorded, lacked transparency, or was not sufficiently comprehensive. This limited the evidence available to demonstrate how best value was determined and to support decisions to accept or reject bids. Where evaluations had been undertaken, they were frequently embedded within contractor pricing documents rather than recorded separately using formal or standardised templates, reducing the clarity and visibility of the assessment process. We also noted that, for three projects, assessments appeared to rely on high-level comparisons against budgets or sample properties, with no clearly documented rationale or transparent audit trail evidencing how best value had been determined. Implication Recommendation Priority Management response Implementation Date Insufficiently documented and non-transparent evaluation of contractor submissions may result in an inability to demonstrate value for money, increasing the risk of challenge, poor decision-making, and non- compliance with procurement and governance requirements. The Chief Officer (Asset and Procurement Solutions) and the Chief Officer (Housing and Communities) should ensure that the outcomes of tender evaluations undertaken on core projects are more clearly and comprehensively documented, including a detailed rationale demonstrating how best value has been assessed, supported by appropriate benchmarking and analysis. To support this, consideration should be given to introducing standardised evaluation documentation to ensure that tender assessments, decisions and benchmarking are clearly and consistently recorded. Medium Agree Siobhan Starbuck, Contract Strategy Manager and James McGlone, Group Manager Support Services We recognise the areas of good practice identified which evidence a strong governance and assurance position for the Contract. It is also recognised that continuous improvement should always be sought in the delivery of contract management. Client services who deliver core project requests will ensure clear and comprehensive documentation is in place, including a detailed rationale of best value delivery. We will review current practices and look at opportunities to standardise evaluation documentation that will enhance the core project process. August 2026 Item 7 Page 51 of 124
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4 3. Action Plan Housing and Corporate Maintenance and Investment Services Contract 0900/2026/011 Ref Finding 2 Core Project procedures need to be strengthened to ensure the Project Register is maintained up to date and all required documentation is consistently completed and retained. From our review of the eight core projects, we noted that, while key controls were generally being followed (including appropriate project identification and progression, issuing of project requests to Mears, consideration of price and value for money, and sound decisions to accept or decline submissions), for a number of the projects there were instances where expected practices were not fully adhered to or where key documentation was incomplete or missing. We noted the following: • The Core Project Register had not been updated accurately, or in a timely manner, for a number of the projects. This included instances where dates did not align with supporting documentation for key stages (such as issuing of pre-engagement documentation and project request dates), the dates of completed stages of projects had not been recorded despite supporting evidence demonstrating that these were complete, and decisions were not updated when revised quotations were received. We also noted that there was a lack of clarity over the dates when pre-engagement forms had been returned and on whether Mears had accepted or declined project opportunities. • Across the sample reviewed, there were gaps in the availability, completeness, and retention of documentation supporting key procurement and contract management stages. In some cases, documentation was missing, with feedback to Mears not formally recorded and reliance placed on undocumented verbal or informal exchanges, resulting in insufficient records to clearly demonstrate consistent and transparent communication. • Expression of interest, pre-engagement, and evaluation documents were often not appropriately signed or did not provide sufficient evidence of authenticity of signatures (such as email confirmation of approval), with several documents containing either typewritten or electronic signatures which could easily be copied and pasted into other documentation. Additionally, some documents did not include a section for formal sign off. • Project requests from Corporate Property did not consistently meet expected contract requirements, particularly we noted instances where references to internal consents and net zero expectations were not recorded. • The standard template for Project Requests for Housing sets out the project information, however, Sections 1.1 and 1.4 both refer to Section 1.6, which does not exist within the document. Implication Recommendation Priority Incomplete, inaccurate, and inconsistent retention of project records may result in a lack of audit trail and transparency, increasing the risk that procurement decisions cannot be effectively evidenced, or demonstrated as compliant with contractual and governance requirements. The Chief Officer (Asset and Procurement Solutions) and the Chief Officer (Housing and Communities) should ensure that arrangements in relation to Core Projects are strengthened including ensuring that: (1) The Core Project Register is accurate, complete, and updated on a timely basis, with periodic review to ensure alignment with project documentation and status and consideration given to including details of the date pre-engagement forms were issued and whether Mears has accepted or declined individual project opportunities. (2) Arrangements for completing and retaining all project documentation and key communications are reinforced with periodic completeness checks. (3) Documentation requiring authorisation is consistently approved, with clear evidence of authenticity and formal sign-off provided either by physical signature or email confirmation of approval. (4) Project requests meet the required minimum standards, including specific reference to internal consents and net zero considerations. (5) The Project Requests template is updated to ensure all cross-references, as outlined in the finding, are accurate. Low Item 7 Page 52 of 124
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5 Management response Implementation Date Agree Siobhan Starbuck, Contract Strategy Manager, James McGlone, Group Manager Support Services and Ross Dunn, Contract Performance and Assurance Manager We will: (1) Ensure the core project register is reviewed by client teams alongside the Contract Performance and Assurance team on a quarterly basis. The register will be fully reviewed to ensure it is complete and includes all relevant information, such as the date of request, date of completion, proposed start and end dates, and whether the proposal was accepted or declined. The review of core projects will be included in the Level 4 governance agenda on a cyclical basis. (2) We will Instruct client services to review completeness for their service area with client service leads reporting on this through the level 4 governance structure. (3) We will reinforce an enhanced sign off procedure to ensure email confirmation from the relevant Chief Officer is saved in the file with each project close off. (4) Current documentation will be reviewed with client services to ensure all minimum standards are being met. Where improvement opportunities are identified, these will be implemented and communicated to contract users by the Contract Performance and Assurance team. (5) Historical cross referencing will be removed from documentation and a general housekeeping exercise carried out across all core project documentation to ensure document appropriateness. August 2026 Item 7 Page 53 of 124
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INTERNAL AUDIT REPORT LEADERSHIP AND OPERATING MODEL Headlines The Leadership and Operating Model (LOM) is one of the Programmes of Work (POW) which supports the delivery of the Council’s ambition statements in The Plan for North Lanarkshire. It seeks to transform how public services are delivered across North Lanarkshire by implementing an integrated place-based model centred on community hubs to improve accessibility, efficiency and long-term sustainability of the services delivered. The LOM is part of the One Service workstream, which is overseen by the One Service Strategic Board. It is managed by the Operating Model Delivery Manager who is responsible for overseeing its performance, and monitoring and reporting of progress. Individual Hubs are supported by a Community Hub Delivery Board, which is led by a Hub Co-ordinator and is responsible for overseeing the development, operation and management of the Hub. This audit involved a review of the arrangements for implementing and progressing the LOM in an efficient and effective manner and evaluating the benefits and outcomes arising from its implementation to facilitate strategic direction. Based on the results of our work, we have categorised this audit as providing reasonable assurance. We are satisfied that there is appropriate oversight and governance arrangements in place for developing and monitoring the LOM, consideration has been given to interdependencies with other key workstreams, and performance is being assessed using the benefits realisation framework, with evidence for each Hub captured and reported to elected members and senior management through dashboards and impact frameworks. We have, however, identified a small number of areas for improvement, which are detailed in section 3 of this report. These include a requirement to more clearly demonstrate the link between the outcomes of the LOM and action plans for monitoring progress. Internal Audit Opinion Reasonable assurance Priority of Recommendations High Medium Low 0 1 1 Organisational Impact Minor Report status FINAL Audit ref 0300/2026/002 Date Issued 10/07/2026 Issued To Chief Officer (Asset and Procurement) and Operating Model Delivery Manager Copied To Chief Executive and Depute Chief Executive Item 7 Page 54 of 124
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1. Executive Summary Objectives The audit sought to confirm the following: • There is appropriate oversight and governance surrounding the development and implementation of the Council’s leadership and operating model. • The expected outcomes of the Council’s leadership and operating model are clear, have been agreed and have been translated into distinct plans linked to the available resources. • Relevant plans and governance structures properly reflect and link to work being undertaken in respect of key workstreams such as the development of Council hubs, asset rationalisation activities and associated workforce issues. • Benefits and impacts of expected outcomes are being appropriately measured and monitored and are on track to being achieved. This engagement has been conducted in accordance with the Global Internal Audit Standards. The Internal Audit section reports formally on conformance with these standards to the Audit and Scrutiny Panel. We would like to thank officers involved in this audit for their cooperation and assistance. 2. Findings and Recommendations Good practice identified We noted the following areas of good practice during the audit: • Strategic leadership and oversight of the LOM are provided by the One Service Board. The Operating Model Delivery Manager leads the development and implementation of the model, overseeing the overall programme, including operating systems, performance, partnership working and alignment with material drivers. • Individual Hubs are supported by a Community Hub Delivery Board, chaired by a Hub Co-ordinator and comprising representatives from other community facing Council services, the NHS and third-party providers. The Board oversees the development, operation and management of the Hub and is supported by a tailored Hub Delivery Board Action Plan containing actions that reflect the specific needs of the local community. • A project brief, outlining the aims, objectives and measures of success for the LOM, was produced at the outset of the project. • Six monthly progress updates are provided to the Corporate Management Team and Policy and Strategy Committee. These reports include information on the benefits and impacts of the LOM through dashboards showing how hubs are performing in practice, impact reports for each hub and a combined benefits register with measures of success. Key areas requiring management action (High Priority) No key areas requiring urgent management action have been identified. Other areas for improvement (Medium Priority) One area for improvement was identified: • There is scope to more clearly demonstrate the link between the outcomes of the LOM and action plans for monitoring progress. Item 7 Page 55 of 124
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4. Action Plan Leadership and Operating Model 0300/2026/002 Ref Finding 1 There is scope to more clearly demonstrate the link between the outcomes of the LOM and action plans for monitoring progress. As the LOM is one of the deliverables for the POW which supports the delivery of the Council’s ambition statements in The Plan for North Lanarkshire, the associated activities are detailed in the POW Delivery Plan. To assist with monitoring these activities, the Operating Model Delivery Manager has prepared an Operating Delivery Team plan consisting of five levels, with levels 1 and 2 replicating the POW Delivery Plan, level 3 providing a more detailed breakdown of the required tasks and level 4 aligning those tasks to each hub. Level 5 are the Hub Delivery Board action plans which detail actions tailored to the specific needs of the local community. From our review of the plans, we consider that, whilst there is a clear link between the deliverables, actions and tasks for levels 1 to 4, there is no clear and transparent link to the Hub Delivery Board action plans. We were therefore, unable to ascertain how the specific actions at hub level have impacted on the progress of the POW deliverables and tasks. Additionally, the terms of reference for the LOM POW Steering Group outlined the high-level outcomes for the LOM, and the LOM strategy outlines the aims, objectives and outcomes for phase 2, however, we were unable to confirm whether these objectives and outcomes are being achieved as they are not stated within the Operating Delivery Team plan, nor is there a separate record or report outlining how they are being progressed, their current status and whether they are on track to be achieved. It is therefore difficult to confirm that delivery of the LOM remains aligned to the objectives and outcomes. We also noted that, whilst six-monthly updates on the benefits and impacts of the LOM are reported to the Policy and Strategy Committee, these do not currently provide information on, or make reference to, progress on the objectives and outcomes for the LOM. Implication Recommendation Priority Management response Implementation Date Without a clear and transparent link between the Hub Delivery Board action plans and higher- level deliverables, there is a risk that local activities cannot be evidenced as contributing to LOM objectives or outcomes. There is a risk that, as the Model matures, the intended outcomes may become diluted, resulting in misalignment with the original objectives and an inability to clearly demonstrate whether outcomes are being achieved. Without proper oversight, elected members may be unable to effectively monitor performance and identify and challenge areas where progress and targets are not being achieved. The Chief Officer (Asset and Procurement) should: (1) Review and update the Hub Delivery Board action plans to clearly demonstrate the link of specific actions at hub level to the deliverables and tasks contained in the Operating Model Delivery Team plan. (2) Implement a formalised approach to demonstrate progress, status and the ongoing achievability of the LOM’s stated objectives and outcomes. This should include clear and transparent alignment between action plans at both hub level and Operating Delivery team level. (3) Ensure that future reports to the Policy and Strategy Committee on the LOM provide an update on the progress and current status of objectives and outcomes. Medium Agree Sara Tennant, Operating Model Delivery Manager (1) Work is currently underway to review and update Hub Delivery Board action plans to ensure a clear line of sight between hub- level actions (work breakdown structure Level 5) and deliverables and tasks contained within the Operating Model Delivery Team plan. This will provide transparent traceability between local activity and wider LOM objectives. (2) An integrated benefits framework has been developed since the audit fieldwork was completed. The framework provides transparent alignment between LOM outcomes, benefits, measures and hub-level activity. This framework will continue to mature alongside improvements in data quality, reporting arrangements and implementation of supporting systems. Hub Delivery Board action plans will be updated to strengthen and clearly demonstrate the link between actions, deliverables, outcomes and benefits. (3) Future reports to the Policy and Strategy Committee will include updates on progress against the LOM objectives and outcomes, including current status, key achievements, risks and the ongoing achievability of intended outcomes. October 2026 Part 1 - Completed June 2026 Part 2- October 2026 October 2026 Item 7 Page 56 of 124
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3. Action Plan Leadership and Operating Model 0300/2026/002 Ref Finding 2 There is scope to improve the combined benefits register and measures of success for the LOM. The report to the Policy and Strategy Committee in June 2026 contained a combined benefits register and measures of success, with the measures of success recorded reflecting those stated in previous update reports to committee and being stated in SMART (specific, measurable, achievable, relevant and timebound) terms. We noted, however, that the measures of success were not clearly linked to the outcomes for the LOM. We also noted that the benefits and measures of success were categorised as short, medium and long term, using colour coding, to illustrate when benefits are expected to be realised, with no clear explanation as to the start date and finish dates for each. We consider that the lack of a clearly defined timeframe for measuring benefits makes it difficult to determine whether the benefits are on track to achieve the intended outcomes. Implication Recommendation Priority Management response Implementation Date If benefits and measures of success are not clearly linked to outcomes, it may be difficult to determine the relevance of each measure in relation to the LOM. Benefits may not be delivered in line with expected timescales and may not therefore, be effectively monitored or challenged. The Chief Officer (Asset and Procurement) should consider: (1) Updating the benefits register and measures of success for the LOM to reference the outcome that each measure of success relates to. (2) Introducing clearly defined timeframes for each benefit and associated measure of success to allow for tracking, effective monitoring and strengthened accountability for delivery. Low Agree Sara Tennant, Operating Model Delivery Manager (1) An integrated benefits framework has been developed since the audit fieldwork was completed. The framework provides transparent alignment between LOM outcomes, benefits, measures and hub-level activity. This framework will continue to mature alongside improvements in data quality, reporting arrangements and implementation of supporting systems during 2026/27. (2) This will be actioned by the Operating Model Delivery team over Q2 2026. June 2026 September 2026 Item 7 Page 57 of 124
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10 INTERNAL AUDIT REPORT EXTERNAL LEGAL FEES Headlines In April 2025, the Council introduced a designated process for instructing external legal advice to ensure consistency and oversight across all Council services. As part of this process, a standard pro-forma business case must be completed and authorised prior to any external legal instruction being given, ensuring that all external legal instructions are appropriately justified, approved, recorded and monitored. The purpose of this audit was to assess compliance with this process and provide assurance that external legal instructions are supported by a business case and have been appropriately authorised. Based on the results of our work, we have categorised this audit as providing reasonable assurance. We are generally satisfied that the new arrangements have been successfully introduced and are operating as intended. Procedures and processes have been established, clearly communicated to relevant officers and are being followed, and appropriate governance arrangements have been developed to support oversight of external legal instructions and expenditure. We have, however, identified some areas for improvement which management should consider. These are detailed in the action plan at section 3 of this report and include enhancements to processes and documentation, record keeping and expenditure monitoring, and governance and reporting arrangements to improve consistency, transparency and management assurance. Internal Audit Opinion Reasonable assurance Priority of Recommendations High Medium Low 0 3 0 Organisational Impact Minor Report status FINAL Audit ref 0250/2026/001 Date Issued 20/07/2026 Issued To Chief Officer (Legal, Democratic and Strategy); Legal Manager (Commercial and Planning); Legal Manager (Governance and Information) and Legal Manager (People, Regulatory and Litigation) Copied To Chief Executive and Depute Chief Executive Item 7 Page 58 of 124
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11 1. Executive Summary Objectives The audit sought to provide assurance on the following areas: • The process for the instruction of external legal advice has been clearly communicated to all relevant officers. • The process is being operated consistently and in line with expectations and there is appropriate documentation to support decisions made and approval. • Regular monitoring reports on external instructions are being submitted to the Monitoring Officer for oversight and assurance. Audit testing included reviewing a sample of 15 cases where external legal advice had been sought, covering instructions after and ongoing at 1 April 2025, to ensure that a completed and appropriately authorised pro- forma and associated supporting documentation were held on file. This engagement has been conducted in accordance with the Global Internal Audit Standards. The Internal Audit section reports formally on conformance with these standards to the Audit and Scrutiny Panel. We would like to thank officers involved in this audit for their cooperation and assistance. 2. Findings and Recommendations Good practice identified We noted the following areas of good practice during the audit: • A designated process for instructing external legal advice, including a pro-forma, has been devised, communicated to relevant staff and is being used across all Legal teams. The process requires approval under the Council’s Scheme of Delegation, prior to engaging Counsel or other external legal expertise. • Invoices pertaining to external legal instructions are examined upon receipt and thereafter, recorded on a Legal Fees Tracker prior to being passed for payment. • Monthly reports on the status of external legal instructions are prepared by Systems Managers and circulated to the Legal Management Team. • A report, providing an update in relation to the Council’s use of external legal support and the associated governance arrangements, was submitted to the BMT in May 2026. This report included an analysis of the nature of external legal instructions, emerging trends and areas of operational and strategic risk. Key areas requiring management action (High Priority) No key areas requiring urgent management action have been identified. Other areas for improvement (Medium Priority) A number of other areas for improvement were also identified: • There is scope to strengthen the current procedures, guidance and pro-forma to fully reflect expected practice and promote consistency. • There is a need to improve the completeness and accuracy of records relating to external legal matters and associated expenditure. • There is scope to improve the governance, monitoring and reporting arrangements for the External Legal Fees process. Item 7 Page 59 of 124
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12 5. Action Plan External Legal Fees 0250/2026/001 Ref Finding 1 There is scope to strengthen the current procedures, guidance and pro-forma to fully reflect expected practice and promote consistency. The process for instructing external legal advice was implemented in April 2025 and continues to evolve. From our review of this process, we consider that there are opportunities to strengthen the supporting guidance and documentation and promote greater consistency across all decisions. In particular: • The roles and responsibilities of all officers involved in the process could be more clearly documented. • There is currently no documented process for closing matters and archiving files. We consider that introducing a process that records the completion date, total costs incurred and any lessons learned, as well as formalising file archiving arrangements, including file retention requirements and clear identification of closed files would further strengthen governance and recording arrangements. • The current pro-forma does not clearly and consistently capture all information required to evidence key decisions or demonstrate compliance with governance and procurement requirements, including: o No requirement to record the date that the external legal adviser was instructed. o Where there is dialogue with, or verbal approval obtained from, the Legal Manager or Chief Officer (Legal, Democratic and Strategy) before completion of the pro-forma, there is no requirement to record the date, details or outcome of these discussions. o Whilst the pro-forma requires estimated costs to be recorded, where these could not be provided, there was no explanation stating the reasons for this. o Section 6 of the pro-forma requires information in relation to the procurement approach and legal and regulatory compliance and section 7 requires confirmation that the engagement would comply with the Council’s General Contract Standing Orders (GCSOs) and procurement legislation, however, it was not always evident how compliance had been achieved. The rationale for the selected procurement route, the firms selected and the basis on which they were evaluated and selected, and how the chosen option represented best value to the Council were not always clearly and transparently documented. Additionally, where exemptions applied, there was no requirement to record the exemption or justify the reasons for its use. o For instructions awarded through the City of Edinburgh Legal Services Framework, the proforma does not prompt officers to confirm that there is sufficient framework value remaining to cover anticipated costs of the work, nor is there a requirement to record that this verification has been undertaken. Implication Recommendation Priority Management response Implementation Date If expected practice and processes are not fully documented and consistently applied, there is a risk that external legal instructions are not supported by adequate evidence to justify decisions made. The Chief Officer (Legal, Democratic and Strategy) should review and update: (1) The procedures and guidance for external legal advice to clearly document the roles and responsibilities of all officers involved and the process to be followed when closing matters and archiving files. (2) The proforma to capture all necessary information to evidence key decisions and demonstrate compliance with governance and procurement requirements, including the areas for improvement highlighted in the finding above. Any updated guidance and documentation should be circulated to all relevant officers. Medium Agree Fiona Ekinli, Legal Manager (Governance and Information) The process for instructing external legal advice has been in operation since April 2025 and has provided an effective governance framework for the approval and oversight of external legal instructions. As the process has matured, a number of opportunities for further enhancement have been identified. The procedures, guidance and business case pro-forma will be reviewed to clarify officer roles and responsibilities, strengthen procurement and governance requirements, and incorporate arrangements for the closure of matters, file retention and lessons learned. These changes will be aligned with the implementation of the new Legal Case Management System to ensure that guidance, workflows and record keeping are fully integrated and consistent across all legal teams. Updated documentation will be communicated to all relevant officers and incorporated into future training and induction materials. March 2027 Item 7 Page 60 of 124
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13 3. Action Plan External Legal Fees 0250/2026/001 Ref Finding 2 There is a need to improve the completeness and accuracy of records relating to external legal matters and associated expenditure. The Service maintains information relating to external legal instructions across SharePoint (files containing documentation relating to the instruction), Microsoft Dynamics (system recording all legal matters received and documentation held) and the Legal Fees Tracker (log of all invoices associated with external legal instructions). From our review of all three sources of information, we identified weaknesses in the arrangements to ensure the completeness, accuracy and consistency of information held and reported, including: • No comparison between SharePoint, Microsoft Dynamics and the Tracker to confirm that all matters and costs have been recorded consistently across each source, resulting in variances between the matters recorded on each source. • No reconciliation is undertaken between the Tracker and the financial ledger to confirm that all expenditure has been accurately recorded and reported, resulting in inaccuracies within the Tracker, including duplicate invoices being recorded. • Although the pro-forma and BMT reports state that estimated costs will be reviewed against actual expenditure, with variances reported and periodic reconciliations undertaken, no such reviews have been undertaken to ensure that actual expenditure is reflective of estimated costs. • Key fields within the Tracker were not consistently completed, including whether instructions were awarded through the City of Edinburgh Legal Services Framework. • No quality assurance reviews are currently in place to confirm that a completed pro-forma and all required supporting documentation is held on file for each external legal instruction. We were advised that consideration is currently being given to developing a means to support this process. As a result, we were unable to obtain assurance over the completeness and accuracy of the information reported to the Monitoring Officer and BMT. We understand, however, that a new case management system is due to be implemented later in the year, which may help address some of the issues identified. Implication Recommendation Priority Management response Implementation Date Weaknesses in reconciliation, expenditure monitoring and record management arrangements increase the risk that external legal matters and associated costs are not fully or accurately recorded, resulting in unreliable management information and reduced assurance over the accuracy of expenditure reported and monitored. The Chief Officer (Legal, Democratic and Strategy) should: (1) Establish formal reconciliations between SharePoint, Microsoft Dynamics, the Legal Fees Tracker and financial ledger to ensure that all external legal instructions and associated expenditure are fully and accurately recorded and supported by appropriate documentation. Any discrepancies should be investigated and resolved as appropriate. (2) Implement periodic reviews of the Legal Fees Tracker to ensure that all key information fields are completed consistently, any duplicate entries are identified and adjusted accordingly, variances between estimated and actual costs are identified and investigated, and all records confirm whether the matter was instructed via the City of Edinburgh Legal Services Framework. (3) Introduce documented quality assurance arrangements to verify that a completed pro-forma and all required supporting evidence are retained for each external legal instruction. Medium Agree Jane Kirkhope, Legal Manager (People, Regulation and Litigation) The Service recognises the importance of maintaining complete, accurate and reliable management information. A key element of addressing this recommendation will be the implementation of the new Legal Case Management System, which will provide a single corporate record for legal matters, improve data quality, reduce duplication and strengthen document management and reporting capability. In parallel, the Service will work with colleagues in Finance to develop formal reconciliation arrangements between the case management system, financial ledger and expenditure records, together with periodic quality assurance reviews and monitoring of estimated versus actual expenditure. Standard operating procedures will also be introduced to support consistent completion of records and ongoing assurance over data quality. March 2027 Item 7 Page 61 of 124
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14 3. Action Plan External Legal Fees 0250/2026/001 Ref Finding 3 There is scope to improve the governance, monitoring and reporting arrangements for the External Legal Fees process. Whilst the Service has implemented a process and associated governance arrangements to ensure appropriate transparency, accountability and oversight of the External Legal Fees process, these remain at an early stage of development and therefore, require further work to establish a more robust control framework, particularly in relation to monitoring, reporting and the accuracy of management information. The Service recognised these areas of improvement within its report to BMT in May 2026, identifying the need to further develop financial reconciliation, trend analysis, corporate reporting, workforce planning, training and knowledge transfer, and the monitoring of external legal spend and outcomes. Although monthly management reports are prepared and submitted to the Service Management Team, these currently provide limited information on external legal expenditure and there is no formal process in place to review, challenge or analyse the information reported. We were advised that draft governance arrangements have been developed, which include four-weekly review meetings to monitor external legal instructions and associated costs, however, implementation of these arrangements has been delayed pending the outcome of this audit. We also noted that the governance and reporting arrangements outlined in the BMT report in November 2025 have not yet been fully embedded. The report advised that quarterly monitoring reports on external legal instructions would be provided to the Monitoring Officer, however, to date only one such report from each Legal Manager has been submitted (May 2026). The information from these reports was consolidated and included in the report to BMT in the same month. Whilst this report demonstrates a positive step forward in evaluating the effectiveness of the External Legal Fees process, we consider that opportunities remain to enhance the quality and completeness of information. In particular, reporting could be strengthened through the inclusion of external legal expenditure data, including clear information on spend under the City of Edinburgh Legal Services Framework, spend by legal firm, comparison of number of instructions issued internally to externally and between years, and actions being taken to further reduce external legal spend. Furthermore, weaknesses in the completeness and accuracy of information held within Microsoft Dynamics and the Legal Fees Tracker, together with the absence of formally defined reporting parameters and reconciliation procedures, mean that information reported to the Monitoring Officer and BMT regarding the number and value of external legal instructions cannot currently be relied upon as an accurate representation of external legal instructions and spend during the year (see finding 2 for more information). Implication Recommendation Priority Management response Implementation Date Inadequate monitoring and reporting of external legal fees may lead to an increased risk that management decisions are based on incomplete or inaccurate information which could reduce the effectiveness of oversight arrangements. The Chief Officer (Legal, Democratic and Strategy) should: (1) Implement and embed the proposed governance arrangements, including regular meetings to scrutinise external legal instructions, expenditure, emerging trends and opportunities to reduce external legal spend. (2) Enhance reporting requirements, including the management information as outlined in the finding, to support effective oversight by the Service Management Team, Monitoring Officer and BMT. This should include validating the accuracy and consistency of reported information. Medium Agree Leanne Joss, Legal Manager (Commercial and Property) Governance arrangements have continued to develop following implementation of the external legal instruction process and will now be further strengthened. Four-weekly management review meetings will be formally introduced to scrutinise all external legal instructions, expenditure, trends and opportunities to reduce external legal spend. Reporting to the Monitoring Officer and Business Management Team will be enhanced through the introduction of standardised performance information, supported by improved financial reconciliation and reporting from the Legal Case Management System. The Service will continue to work closely with Finance colleagues to develop robust monitoring arrangements and management information, ensuring that governance and reporting are based on accurate, reconciled financial and operational data. March 2027 Item 7 Page 62 of 124
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15 INTERNAL AUDIT REPORT DEBT MANAGEMENT Headlines Effective debt management is a key component of the Council’s financial governance arrangements, supporting the timely collection of income, minimising financial loss and maximising resources available for service delivery. The Council aims to ensure that outstanding debt is managed and recovered in an efficient, effective and consistent manner, in line with approved policies and procedures. The purpose of this audit was to provide assurance that the Council has adequate and effective arrangements in place to support the management, recovery and write-off of debt. The audit also considered arrangements for the recovery of salary overpayments relating to former employees. Based on the results of our work, we have categorised this audit as providing reasonable assurance. We noted that key elements of the debt management framework are operating effectively including the availability of documented guidance, the use of the ASH debtors’ system to support recovery activity, established write- off procedures and the provision of quarterly debt recovery reports to Service SMTs. However, we have identified a few areas for improvement arising from weaknesses in the consistent application of debt management arrangements across Services in accordance with the Sundry Debt Recovery Guide. These are detailed in section 3 of this report and include a need to strengthen the oversight of debts referred to Legal Services to ensure that cases are appropriately progressed, monitored and concluded. The audit also identified instances where debtor invoices had not been raised for salary overpayments relating to former employees. Internal Audit Opinion Reasonable assurance Priority of Recommendations High Medium Low 0 1 2 Organisational Impact Moderate Report status FINAL Audit ref 0200/2026/002 Date Issued 06/08/2026 Issued To Chief Officer (Finance and Technology) (Recs 1.1, 2.1 & 3.2) Chief Officer (Legal, Democratic and Strategy) (Rec 1), Chief Officer (Adult Social Work Services) (Rec 2.2) Chief Officer (Audit and Risk) (Rec 3.1) and Chief Officer (People Resources) (Rec 3.2) Copied To Chief Executive and Depute Chief Executive Item 7 Page 63 of 124
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16 1. Executive Summary Objectives The audit sought to provide assurance on the following areas: • There are adequate written policies and associated guidance covering income, debt recovery, collection and write-off procedures. • Debt management arrangements are operating effectively in line with relevant written policies and guidance and are efficient and cost-effective. • All debt write-off is appropriately authorised and only considered once all avenues of debt recovery have been exhausted. • Adequate and timely management information is generated in respect of debt and debt recovery to provide a sound basis for monitoring performance and associated decision making. The audit did not consider or review the arrangements in respect of debts associated with Housing Rents, Council Tax or Non-Domestic Rates as these are subject to separate and specific arrangements and are routinely covered by individual audit assignments. Data analysis was also undertaken on debts arising from salary overpayments for previous employees. CMT agreed that, from October 2024, responsibility for raising debtors’ accounts and undertaking debt recovery on these overpayments would transfer to the employing Service, therefore additional testing was undertaken to confirm the extent to which these accounts were being raised and payments were being received. This engagement has been conducted in accordance with the Global Internal Audit Standards. The Internal Audit section reports formally on conformance with these standards to the Audit and Scrutiny Panel. We would like to thank officers involved in this audit for their cooperation and assistance. 2. Findings and Recommendations Good practice identified We noted the following areas of good practice during the audit: • The Council has an established Sundry Debt Recovery Guide, which is available on SharePoint, that clearly defines the procedures, roles and responsibilities and actions of Services, the Debt Recovery team and Legal Services. • The Council uses the ASH debtors’ system to maintain accurate records of invoices raised and document debt recovery actions taken. • The ASH system automatically issues an initial reminder within three days where invoices remain unpaid after the due date. • The write-off process is undertaken annually and follows a consistent and robust process. A detailed report is presented to both the Services’ Committees and the Finance and Resources Committee for approval, ensuring appropriate governance, challenge and transparency. • Quarterly debt recovery reports are presented to Service SMTs, providing regular oversight of outstanding debt, debt recovery action, write offs and disputes. Key areas requiring management action (High Priority) • No key areas requiring urgent management action have been identified. Other areas for improvement (Medium Priority) One area for improvement was identified: • There is a need to strengthen governance and monitoring arrangements for debts referred to Legal Services. Item 7 Page 64 of 124
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17 6. Action Plan Debt Management 0200/2026/002 Ref Finding 1 There is a need to strengthen governance and monitoring arrangements for debts referred to Legal Services. Once Services and the Debt Recovery Team have exhausted all debt recovery options, the debt is passed to Legal Services to attempt recovery using available legal powers, including decree. ASH is updated to indicate debts passed to Legal Services, and the Debt Recovery Team email Legal Services to notify them of new debts passed. Testing on a sample of 10 debts recorded on ASH as having been assigned to Legal Services identified weaknesses in the management, monitoring and progression of cases as follows: • There is currently no formal mechanism to ensure that all debts assigned to Legal Services are received, progressed and actively monitored. Legal Services place reliance on email notifications from the Debt Recovery Team of debts requiring legal action and, as a result, we identified two debts which, although had been passed for legal action, had not been progressed. • The ASH Recovery event log and workflows indicated prolonged periods of inactivity and limited evidence of communication and progression of legal action. For one debt where a decree has been obtained, the workflow had not been updated to reflect the date of the decree. • Decrees were successfully obtained for three debts, however, no payments had been received and there was no evidence of subsequent enforcement or recovery action. As Legal Services have a limited period of two years from the date of Decree to enforce recovery, we consider that accurate recording of milestone dates and a recovery follow-up process are essential. • Where legal action is unsuccessful, a Write-Off Submission requires to be completed and issued to the Debt Recovery Team. Testing identified two debts which had been marked by Legal Services as proposed for write-off on ASH (one dating back to June 2025), however, as no Write-Off Submission been completed, the debt remains with Legal Services and cannot therefore, be written off. Implication Recommendation Priority Management response Implementation Date Weaknesses in governance, case management and monitoring arrangements may result in debts not being progressed in a timely manner, recovery opportunities being missed and debts becoming unrecoverable, leading to increased write-offs and financial loss to the Council. The Chief Officer (Legal, Democratic and Strategy) should: (1) Liaise with the Chief Officer (Finance and Technology) to determine an appropriate mechanism for ensuring that all debts passed to Legal Services are appropriately recorded, allocated and progressed. (2) Review the legal debt recovery process to ensure that: • Event logs and workflows are appropriately and promptly updated to reflect all legal recovery action taken. • Appropriate and timely enforcement or recovery action is undertaken for decreed debts. • Where legal action has been unsuccessful and write-off is required, the appropriate documentation is completed, and the debt is returned to the Service, promptly. Medium Agree Jane Kirkhope, Legal Manager (People, Regulation and Litigation) (1) The Service will work with the Chief Officer (Finance and Technology) and the Debt Recovery Team to review the current referral process and introduce a more robust mechanism for ensuring that all debts referred to Legal Services are appropriately recorded, acknowledged, allocated and monitored. (2) Existing debt recovery cases will be reviewed to ensure that files are complete, legal action has been progressed where appropriate, key milestone dates are accurately recorded and any cases requiring enforcement action or write-off are identified and progressed without unnecessary delay. Enhanced supervisory arrangements will also be introduced, including regular management review of debt recovery cases by the supervising Principal Solicitor, to ensure appropriate oversight, timely progression and compliance with agreed procedures. The implementation of the new Legal Case Management System will further strengthen these arrangements by providing improved workflow management, allocation, supervision, reporting, automated task management and management information. In addition, the Service will use its self-evaluation framework to undertake a broader review of the debt recovery process, identifying opportunities to improve efficiency, consistency, performance monitoring and governance. March 2027 March 2027 Item 7 Page 65 of 124
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18 3. Action Plan Debt Management 0200/2026/002 Ref Finding 2 Debt management arrangements are not being applied consistently across Services in line with the Sundry Debt Recovery Guide. Following a previous audit, a cross-Service focus group was established to review existing arrangements and identify opportunities to strengthen debt recovery processes. Whilst management has implemented a number of improvements and refreshed debt recovery procedures, testing on a sample of outstanding debts indicates that there continues to be inconsistencies in the application and oversight of debt management arrangements across Services. Key issues identified were as follows: • Debts remained outstanding for extended periods, including instances where debts had been outstanding for over 1,000 days without evidence of effective progression towards recovery, legal action or write-off. • Recovery actions were not always undertaken in a timely manner, with prolonged periods of inactivity identified within ASH event logs. Additionally, event logs often lacked sufficient detail regarding actions taken and planned next steps. • Payment arrangements were not always effectively monitored and managed. Of the five arrangements reviewed, two were in arrears, including one with 31 missed instalments. Furthermore, income and expenditure assessments were not consistently completed to support affordability considerations and there was limited evidence that overdue instalment reports were being routinely reviewed and acted upon in line with the Sundry Debt Recovery Guide. • While disputed debts were generally coded correctly, there was a number of instances where dispute codes had been applied repeatedly without clear evidence of progress toward resolution. Additionally, Services were not always producing dispute analysis reports and reviewing debtors’ accounts with dispute codes applied on a regular basis in line with the Sundry Debt Recovery Guide. • The quarterly debt management reports to Service SMTs were not being produced for Adult Health and Social Care (AHSC). Management advised that this was due to an oversight and confirmed that reporting would commence. Our review also identified opportunities to strengthen the Sundry Debt Recovery Guide. In particular, Service responsibilities and accountabilities could be more clearly defined in relation to cases referred to Legal Services as at present, there are no formal arrangements in place for monitoring the progress and status of cases referred for legal action. Implication Recommendation Priority Management response Implementation Date Inconsistent application of debt recovery procedures may result in recovery opportunities being missed, debts remaining outstanding for extended periods, and an increased likelihood of debts becoming unrecoverable and requiring write-off. (1) The Chief Officer (Finance and Technology) should: (a) Remind Services of their responsibilities for debt recovery, particularly highlighting the issues identified in the finding above. (b) Consider updating the Sundry Debt Recovery Guide to clearly define Service responsibilities and accountabilities in relation to monitoring the progress and status of cases referred to Legal Services. (2) The Chief Officer (Adult Social Work Services) should ensure that the requirement to submit a standard quarterly debt management report to the Service SMT is implemented promptly. Low Agree (1) Veronica Roberts, Business Finance Manager (a) Finance and Technology will remind services of their responsibility for debt recovery through SMT meetings and follow this up with communication to all ASH users. (b) Finance and Technology will review the Sundry Debt Recovery Guide to update roles and responsibilities. (2) Patrick McAviney, Business Support & Operations Manager It is acknowledged that the standard quarterly debt management report was not being submitted to the AHSC SMT as required. This was due to an oversight, and management accepts the need to ensure that consistent reporting arrangements are in place. Quarterly reporting will be introduced for AHSC from the next quarterly reporting cycle. The report will provide SMT with regular oversight of outstanding debt, enabling appropriate scrutiny and timely management action where required. Arrangements will be put in place to ensure the report is included as a standing quarterly item on the Service SMT agenda, with oversight retained by the Chief Officer to ensure ongoing compliance. December 2026 October 2026 Item 7 Page 66 of 124
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19 3. Action Plan Debt Management 0200/2026/002 Ref Finding 3 There is a need to ensure that Services promptly raise debtors’ invoices for salary overpayments relating to former employees. CMT has recognised that responsibility for recovering salary overpayments relating to former employees lies with Services. As a result, it was agreed that, from October 2024, debtors’ invoices relating to these payments would be raised in ASH by Services rather than by People Resources. We obtained a report from People Resources detailing all salary overpayments relating to former employees identified during 2025/26 and undertook data analysis to assess whether invoices have been raised and recovery action progressed. We identified a number of instances where invoice had not been raised as follows: • Adult Health and Social Care – of the 12 salary overpayments identified, no invoice has been raised for five (42%) of these. • Education and Families – of the 54 salary overpayments identified, no invoice has been raised for 23 (43%) of these. • Enterprise and Communities – of the 37 salary overpayments identified, no invoice has been raised for nine (24%) of these. For the salary overpayments where no invoice had been raised, these were not restricted to the most recent quarter but spanned across the full period reviewed. We acknowledge this finding was previously reported as part of the Leavers Audit in 2025/26, and that the recommendation has been implemented by strengthening the email issued to Chief Officers each quarter containing the overpayment report. However, the results of our testing indicate that this has not had the desired effect. Consequently, we consider that Chief Officers should be reminded of their responsibility for ensuring that debtors’ invoices contained on the salary overpayments report for former employees are raised promptly. Implication Recommendation Priority Management response Implementation Date Delays in raising debtors’ invoices for salary overpayments for former employees may reduce the likelihood of timely recovery, increasing the risk of delays in recovery and potential non- recovery of monies due to the Council. (1) The Chief Officer (Audit and Risk) should present this report to CMT, outlining the finding, and remind all Chief Officers of their responsibility to review and monitor salary overpayments reports to ensure that debtors’ invoices for all salary overpayments relating to former employees are raised promptly. (2) The Chief Officer (People Resources) and Chief Officer (Finance and Technology) should liaise to determine an appropriate mechanism to be introduced to ensure Chief Officers are promptly informed of salary overpayments and the process by which Chief Officers should track and monitor the raising and recovery of these debts. Low Agree (1) Francis Scott, Chief Officer (Audit and Risk) The Debt Management report will be presented at the next CMT meeting taking place in August. At this meeting, Chief Officers will be reminded of their responsibility to ensure that invoices relating to salary overpayments are raised promptly. (2) Fiona Whittaker, Chief Officer (People Resources) & Greg Telfer, Chief Officer (Finance and Technology) The Chief Officer (People Resources) and Chief Officer (Finance & Technology) will liaise to agree an appropriate process to be rolled out to Chief Officers. This will be presented to Corporate Management Team for action. August 2026 October 2026 Item 7 Page 67 of 124
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North Lanarkshire Council Report Audit and Scrutiny Panel Does this report require to be approved? ☐ Yes ☒ No Ref FS/LM/ASP/August 2026 Date 20/08/26 Internal Audit: Follow-up of implementation of audit recommendations From Francis Scott, Chief Officer (Audit and Risk) E-mail ScottFr@northlan.gov.uk Executive Summary The purpose of this report is to update the Panel on the progress made by management in the implementation of Internal and External Audit recommendations. In the period to 30 June 2026, of the 27 High and Medium priority recommendations that were due, 14 have been fully implemented and 13 remain outstanding. Of the 13 recommendations that remain outstanding, one has an implementation date which is more than 12 months overdue. Since April 2021, 95% of all relevant audit recommendations have been satisfactorily implemented by Services, meaning that only 5% of these audit recommendations remain outstanding. In respect of recommendations from External Audit reports, 12 of the 20 agreed actions have been completed, five are partially implemented, one is no longer relevant and two are not yet due. Recommendations The Panel is invited to: (a) Note the contents of this report. (b) Consider whether there are any issues arising from this report on which they wish to receive further information from relevant management. The Plan for North Lanarkshire Priority All priorities Ambition statement All ambition statements Programme of Work All Programmes of Work Item 8 Page 69 of 124
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1. Background 1.1 This report presents an overview of the progress of all High and Medium priority Internal Audit recommendations in the period to 30 June 2026. 1.2 This report also provides an update on progress made in addressing recommendations arising from External Audit reports issued as part of the 2022-23, 2023-24 and 2024- 25 audits. 1.3 The updates from management on progress to date have been verified on a sample basis by Internal Audit as part of the preparation of this report. However, it should be noted that this review has focused on whether planned actions have been completed and has not included detailed substantive testing of whether the implemented actions have been effective in addressing previously identified weaknesses. 2. Report Internal Audit recommendations 2.1 Table 1 below summarises the progress of all High and Medium priority recommendations which were due to be completed in the period to 30 June 2026. Overall, 14 of the agreed actions have been completed and 13 remain outstanding. Table 1 Completed No Longer Relevant Outstanding Total Chief Officer Area Audit and Risk 4 0 0 4 Community Operations 3 0 3 6 Education 4 0 1 5 Housing and Communities 0 0 3 3 Legal, Democratic and Strategy 2 0 6 8 People Resources 1 0 0 1 TOTAL 14 0 13 27 2.2 For the 13 outstanding recommendations, revised implementation dates have been agreed. Appendix 1 provides detail of these recommendations with an update on progress provided by service management. Appendix 1 also references instances where the original implementation date of a recommendation was more than 12 months overdue. In this period there is one such action, referenced 1.1 in the appendix. The relevant Chief Officer has been invited to attend the Panel meeting to provide an explanation. 2.3 As at 30 June 2026, 95% of all relevant audit recommendations, where the original agreed implementation date was either due or had passed, have been fully implemented by Services, meaning that the percentage overall of all audit recommendations made since April 2021, which remain outstanding, is 5%. This shows a slight dip in performance since the last period when 97% were complete and 3% were outstanding. Item 8 Page 70 of 124
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External Audit recommendations 2.4 Table 2 shows the status of actions agreed by management in response to External Audit reports issued as part of the 2022-23, 2023-24 and 2024-25 audits. As at 30 June 2026, 12 of these recommendations are complete, five are partially implemented, two are not yet due and one is no longer relevant. Table 2 Completed Partially implemented Not yet due No longer relevant Total Report Title 2022-23 Annual Report 2021/22 1 1 0 1 3 Best Value Thematic Report 3 0 0 0 3 2023-24 Annual Report 2 2 1 0 5 Best Value Thematic Report 3 0 0 0 3 2024-25 Annual Report 2 1 1 0 4 Best Value Thematic Report 1 1 0 0 2 TOTAL 12 5 2 1 20 2.5 The action reported as no longer relevant refers to issues relating to capital processes. Two of the three points made within this action have been implemented and the third has been superseded by an action raised in the 2024-25 External Audit Annual Report. 2.6 A six-monthly tracking report of progress in implementing these recommendations will be presented to the November meeting of the Panel. 3. Measures of success 3.1 Internal Audit reports each cycle to the Audit and Scrutiny Panel on the progress made by management in implementing actions in response to Internal and External Audit reports. 4. Supporting documentation Appendix 1 Register of Outstanding Internal Audit Recommendations Francis Scott Chief Officer (Audit and Risk) Item 8 Page 71 of 124
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5. Impacts 5.1 Public Sector Equality Duty and Fairer Scotland Duty Does the report contain information that has an impact because of the Public Sector Equality Duty and/or Fairer Scotland Duty? Yes ☐ No ☒ 5.2 Financial impact Does the report contain any financial impacts? Yes ☐ No ☒ 5.3 HR policy impact Does the report contain any HR policy or procedure impacts? Yes ☐ No ☒ 5.4 Legal impact Does the report contain any legal impacts (such as general legal matters, statutory considerations (including employment law considerations), or new legislation)? Yes ☐ No ☒ 5.5 Data protection impact Does the report / project / practice contain or involve the processing of personal data? Yes ☐ No ☒ 5.6 Technology / Digital impact Does the report contain information that has an impact on either technology, digital transformation, service redesign / business change processes, data management, or connectivity / broadband / Wi-Fi? Yes ☐ No ☒ 5.7 Environmental / Carbon impact Does the report / project / practice contain information that has an impact on any environmental or carbon matters? Yes ☐ No ☒ 5.8 Communications impact Does the report contain any information that has an impact on the council’s communications activities? Yes ☐ No ☒ 5.9 Risk impact Is there a risk impact? Yes ☒ No ☐ If Yes, please provide a summary of the key risks and potential impacts, highlighting where the risk(s) are assessed and recorded (e.g. Corporate or Service or Project Risk Registers), and how they are managed? Failure by Services to address previously identified issues and/or weaknesses will impact on the effectiveness of the relevant control framework. This, depending on the nature of the issue, will be captured and should be reflected in the relevant service risk register or the corporate risk register (as appropriate). 5.10 Armed Forces Covenant Duty Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it relate to healthcare, housing, or education services for in-Service or ex- Service personnel, or their families, or widow(er)s)? Yes ☐ No ☒ 5.11 Children’s rights and wellbeing impact Does the report contain any information regarding any council activity, service delivery, policy, or plan that has an impact on children and young people up to the age of 18, or on a specific group of these? Yes ☐ No ☒ Item 8 Page 72 of 124
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APPENDIX 1 – Register of Outstanding Internal Audit Recommendations Ref. Report Details Recommendation Original & revised timescales Management update 1.1 Chief Officer (Education) School Excursions (October 2023) The Chief Officers of Education (North and South) should ensure that: (1) A comprehensive formal review of both the Council’s Educational Excursions and Outdoor Activities Policy and the Risk Assessment Guidance on Educational Excursions and Outdoor Activities is undertaken to revisit and refresh all aspects of these documents with a view to improving the robustness of the Council’s arrangements associated with school trips and excursions. This should take account of, but not limited to, the information contained in Appendix 2 and the need for roles and responsibilities of all relevant parties, including those within other Council services to be clearly documented in the revised guidance. (2) Any revised arrangements are fully communicated to all Council Services with a role in the process. (3) They explore how best to gather/record details of all school trips and excursions and thereafter monitor compliance with the Council’s expected arrangements associated with such trips and excursions. Priority: High April 2024 March 2025 September 2025 June 2026 August 2027 (>12 months overdue) Parts (1) and (3) of the recommendation have been fully implemented, with a full review of the existing policy, associated guidance and risk assessment tools having been undertaken. The updated policy has been rewritten and restructured, clearly defining the roles are responsibilities of all relevant parties and providing clearer guidance on the various aspects of the process. The delay in implementation of part (2) of the recommendation is due to the Service's preferred model for implementation being for the updated policy and management information system to be introduced simultaneously, with an expected date of August 2027. The revised arrangements will be fully communicated to all Heads of Establishment and Council Services with a role in the process, with training delivered as appropriate. In the interim, best practice advice has, and will, continue to be given to schools based on the existing policy. 1.2 Chief Officer (Community Operations) Fleet Management (October 2025) The Chief Officer (Community Operations) should: (1) Consider introducing second-officer verification for critical data inputs into Freeway, particularly during vehicle profile setup, to improve data accuracy and reliability. (2) Consider expanding the existing compliance audit process currently used in waste management to cover the wider fleet, ensuring consistent oversight and promoting continuous improvement across all service areas. Priority: Medium October 2025 August 2026 Part (1) has been implemented – all vehicle data has been assessed, and all new vehicles are subject to second officer checks by the Performance and Compliance Team. For part (2), compliance checks across the entire fleet are still in progress and have not yet been completed. The process is expected to be fully completed in line with the revised timescale. The delay in implementation is largely due to this action requiring a significant resource commitment. Item 8 Page 73 of 124
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Ref. Report Details Recommendation Original & revised timescales Management update 1.3 Chief Officer (Housing and Communities) Community Asset Transfers (October 2025) To take cognisance of the areas for improvement highlighted in the finding, the Chief Officer (Strategy and Engagement) should: (1) Ensure the guidance notes are finalised and issued, and that formal written policies are developed and implemented to guide officers in reviewing and assessing CAT applications. (2) Implement a conflict of interest declaration process for all officers involved in assessing and making decisions on CAT applications. Priority: Medium December 2025 March 2026 September 2026 November 2026 A report was presented to the Community Asset Leadership Group in April 2026, to agree the process for review of CAT assessment and decision-making processes and significant preparatory work has been undertaken in this area. Initial consideration has been given to current governance arrangements, officer responsibilities, and decision-making processes. Benchmarking work and review of national guidance have also informed consideration of potential future approaches. The requirement for formal conflict of interest arrangements has been incorporated within the approved scope of the Community Asset Transfer Improvement works and will be progressed through the officer working group. It is intended that an updated draft policy will be presented to Policy and Strategy Committee for approval in September 2026, and that the review of paperwork and processes will be complete by Autumn 2026 reflecting officer review, audit recommendations and the updated policy. The delay in implementation is primarily due to Committee timescales and the availability of Chief and Senior Officers to fully participate in the review due to competing priorities. 1.4 Chief Officer (Legal, Democratic and Strategy) Information Governance (October 2025) The Chief Officer (Legal and Democratic), in conjunction with the Data Governance Board (DGB), should continue to review/enhance the information governance arrangements. This should include, but not be limited to, ensuring that: both the reviews of the Council’s Data Sharing agreements, Third Party Processing Agreements, Retention Plans and Retention Schedules; and development and update of information on the Council’s Information Asset Register are completed within a reasonable timescale. Priority: Medium January 2026 September 2026 December 2026 Reviews of the Council’s Data Sharing Agreements and Retention Plans and Schedules have been carried out and were reported to the DGB in June 2026. The review of Third-Party Processing Agreements has still to be completed by the Information Governance Team and reported to the DGB. An improvement plan has been developed which identifies actions to be delivered with regards to the Information Asset Register. This includes refining the list, developing procedures and reviewing the role of the Information Asset Owner document. The delay in implementation is largely due to responsibility for managing the Information Asset Register only transferring to Legal and Democratic Services at the end of January 2026. Item 8 Page 74 of 124
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Ref. Report Details Recommendation Original & revised timescales Management update 1.5 Chief Officer (Housing and Communities) Community Asset Transfers (October 2025) The Chief Officer (Strategy and Engagement) should update the Policy to clearly state whether and how the Leadership Group should be notified of CAT enquiries and that submission of a risk assessment or risk management plan is a mandatory requirement for all applications. The policy should also be updated to include clear eligibility requirements and the required essential criteria to support consistent CAT applications. Priority: Medium March 2026 July 2026 November 2026 The Community Asset Leadership Group has been established to provide strategic oversight of Community Asset Transfer activity and future development work. The Leadership Group has approved the scope of a structured Community Asset Transfer Improvement Plan inclusive of an update to all paperwork. As part of this work, a review of the existing Community Ownership and Management of Assets Policy has commenced. Preparatory work has been undertaken to review Scottish Government guidance, operational learning from recent Community Asset Transfer cases and practices adopted elsewhere in Scotland. Potential areas identified for future policy development include governance arrangements, eligibility requirements, validation criteria, application requirements and risk assessment expectations. Policy amendments have not yet been finalised, and further development work will be progressed through the officer working group and governance arrangements. The delay in implementation is primarily due to Committee timescales and the availability of Chief and Senior Officers to fully participate in the review due to competing priorities. Item 8 Page 75 of 124
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Ref. Report Details Recommendation Original & revised timescales Management update 1.6 Chief Officer (Housing and Communities) Community Asset Transfers (October 2025) The Chief Officer (Strategy and Engagement) should: (1) Update the log of enquiries and applications for CATs to provide more detailed information on the progress of each CAT application, including, but not limited to, the areas highlighted in the finding. (2) Consider introducing a process for monitoring the log on a regular basis to ensure that it is fully and promptly updated for all applications and chasing up any outstanding information. Priority: Medium March 2026 September 2026 November 2026 A report was presented to the Community Asset Leadership Group in April 2026, to agree the process for review of CAT assessment and decision-making processes and significant preparatory work has been undertaken in this area. Initial review work has been undertaken to consider opportunities to strengthen monitoring and recording arrangements associated with Community Asset Transfer activity. Requirements identified through the audit have been incorporated within the approved scope of the review programme and will be progressed through the officer working group. Initial consideration has been given to how monitoring responsibilities, reporting arrangements and application oversight processes could be strengthened to support improved record keeping and application management. Further work is required to develop and implement revised monitoring arrangements and associated governance processes. It is intended that an updated draft policy will be presented to Policy and Strategy Committee for approval in September 2026, and that the review of paperwork and process will be complete by Autumn 2026 reflecting officer review, audit recommendations and the updated policy. The delay in implementation is primarily due to Committee timescales and the availability of Chief and Senior Officers to fully participate in the review due to competing priorities. 1.7 Chief Officer (Community Operations) Fleet Management (October 2025) The Chief Officer (Community Operations) should undertake a review of current data management practices within Freeway to identify gaps in vehicle-related documentation and ensure that all relevant maintenance, inspection and compliance records are complete and up to date. Priority: Medium April 2026 March 2027 A comprehensive review of the vehicle asset data management practices within Freeway has been undertaken and vehicle- related information updated for those vehicles that information has been received for. This will continue to be updated where new vehicles are delivered and where vehicles come into the Fleet Workshop for a service. The delay in implementation is due to the challenges experienced by Services in reliably identifying vehicle ownership through the associated email address, as this is subject to change depending on evolving operational requirements. Item 8 Page 76 of 124
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Ref. Report Details Recommendation Original & revised timescales Management update 1.8 Chief Officer (Legal, Democratic and Strategy) Project Management Quality Assurance (March 2025) The Chief Officer (Business and Digital) should ensure that the existing detailed quality assurance arrangements and expected practices for assessing compliance with the Project Management Framework are consolidated into a single formal document and expanded to include other areas of the process as outlined in the finding. Priority: Medium April 2026 September 2026 The Project Management Framework and Programme of Work governance document have been updated to reflect all developments around the Programme of Work that have been implemented during 2025 in relation to the governance and delivery of council projects. Such developments relate to interdependencies, lessons learned and benefits realisation in addition to the quality assurance process and these have been consolidated into a single formal document. A report on the updated Project Management Framework is scheduled to be reported to a forthcoming meeting of the BMT. This report includes a section on the process in place for lessons learned. The delay in implementation is due to scheduling of reporting to the BMT. 1.9 Chief Officer (Legal, Democratic and Strategy) Anti-Fraud Arrangements (January 2026) The Chief Officer (Legal and Democratic) should: (1) Ascertain what the provisions of the Act mean for the Council’s activities to prevent fraud and communicate this to all senior managers. (2) As part of the corporate defence against the ‘failure to prevent fraud’ offence, determine whether the eLearning module should be made mandatory to all staff. Priority: Medium April 2026 December 2026 A report was presented to BMT in June 2026, setting out the implications of the Economic Crime and Corporate Transparency Act 2023 and the introduction of the new corporate offence of failure to prevent fraud. The report outlines the Council's responsibilities, confirms the need to review existing fraud prevention arrangements against the statutory guidance and proposes a programme of work to strengthen the Council's corporate defence. This includes reviewing the adequacy of fraud prevention arrangements within ALEOs, assessing procurement and contract management controls and considering whether fraud awareness training should be mandatory for all, or particular categories, of employees. Following BMT approval, a corporate review will commence using the six principles contained within the guidance as the assessment framework. The outcomes of this work will be communicated to Chief Officers and senior managers to ensure a consistent understanding of legal obligations, organisational exposure and required control measures. In addition to the above, an OMT development session was held in June 2026 to raise awareness of the revised Counter Fraud policy and to highlight responsibilities under the legislation. The delay in implementation is due to engagement with senior managers to ensure awareness and understanding of the new ‘failure to prevent fraud’ offence before finalising the review of the fraud prevention arrangements and associated actions. Item 8 Page 77 of 124
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Ref. Report Details Recommendation Original & revised timescales Management update 1.10 Chief Officer (Legal, Democratic and Strategy) Business Continuity Planning (April 2025) The Depute Chief Executive should review the business continuity framework, including guidance and processes, to ensure that the arrangements, guidance and associated templates for business continuity planning are expanded to take cognisance of, and clearly detail, each of the points outlined at Appendix 2. Any revised guidance should be disseminated to individual services Priority: Medium May 2026 April 2027 The Council has procured a Resilience Software. The deployment of this software to Council Services is currently underway and includes a review of the business continuity framework for all Services. In addition, work is scheduled to review all timeframes provided (MTPD, RTO) for associated activities and the Resilience Team are currently creating an impact matrix to ensure a consistent process. Training and guidance for the software will be provided over the next 10-12 months as part of the deployment phase. The delay in implementation, and revised timescale, is reflective of the move from manual processes to a cloud based digital solution. 1.11 Chief Officer (Legal, Democratic and Strategy) Strategic Governance Arrangements (August 2025) The Chief Officer (Strategy and Engagement) should ensure that benefit realisation arrangements for the PoW are finalised and implemented by each of the Strategic Boards. These arrangements should include clearly identifying and documenting the anticipated benefits of individual Strategic Board deliverables, along with robust processes for their calculation, ongoing monitoring, and regular reporting of achievement against agreed outcomes to key stakeholders. Priority: Medium June 2026 September 2026 The benefits realisation approach and tracker were approved at the One Service Board in March 2025. Implementation Plans are being developed for each of the Programme of Work Boards. A report on the updated Project Management Framework is scheduled to be reported to a forthcoming meeting of the BMT. This includes an updated section on benefits realisation and also in relation the Programme of Work Boards. The delay in implementation is due to scheduling of reporting to the BMT. 1.12 Chief Officer (Legal, Democratic and Strategy) Information Governance (October 2025) The Chief Officer (Legal and Democratic), in conjunction with the Data Governance Board (DGB), should continue to review/enhance the information governance arrangements. This should include, but not be limited to, ensuring that: the mandatory eLearning modules relating to Information Governance are reviewed/updated to reflect the new/revised policies as they are approved thus ensuring that they remain up to date. Priority: Medium June 2026 December 2026 The Council’s Information and Cyber Security module has been reviewed and updated in line with policy updates. Module reviews for Data Protection and Records Management are being addressed and monitored by the Data Management and Compliance Group as per the Data Governance Board programme of work. The delay in implementation is due to prioritisation of review, update, approval and communication of new policies over review of mandatory training courses. Item 8 Page 78 of 124
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Ref. Report Details Recommendation Original & revised timescales Management update 1.13 Chief Officer (Community Operations) Roads and Infrastructure Maintenance and Improvement Services Contract (April 2026) The Chief Officer (Community Operations) should ensure that: (1) A robust process for regular quality assurance and verification is developed and implemented which ensures that all KPI figures are accurate, supported by source data, and calculated in accordance with contract requirements. This should include sample checks of KPI source data to ensure that any inaccuracies or errors are promptly identified, challenged and resolved. (2) The current work to review and refine KPI data is finalised, ensuring all required data, including KPIs 3.6 and 8.20, is available, accurate and fully reported to senior officers and elected members. Priority: Medium June 2026 March 2027 Three workshops have been completed between the Service, the Contractor and the Corporate Performance and Assurance Team to focus on the issues identified by this action. Priority was given to those indicators where data was unavailable as well as those requiring improvement and validation. A programme of continuous improvement is being developed to further strengthen the validation of all indicators going forward. The delay in implementation is due to this being a significant programme of work because of the size and complexity of the contract. Item 8 Page 79 of 124
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North Lanarkshire Council Report Audit and Scrutiny Panel Does this report require to be approved? ☐ Yes ☒ No Ref FS/ASP/RMAug 26 Date 20/08/26 Risk Management Update From Francis Scott, Chief Officer (Audit and Risk) E-mail ScottFr@northlan.gov.uk Telephone 07887 914207 Executive Summary This report seeks to support the Audit and Scrutiny Panel in the discharge of the aspect of its remit of monitoring the effective development and operation of risk management in the Council. The report provides an overview the Corporate Risk Register (CRR) and developments on Corporate Risks during the reporting period. The report also includes a high-level overview of Service Risk Registers (SRR). The report concludes with a summary of other risk management developments and the key considerations of the Risk Management Corporate Working Group (RMCWG) within the reporting period. Recommendations The Panel is asked to consider the contents of the report and note: (1) the CRR as detailed in Appendix 1. (2) the changes to corporate risk assessments in sections 2.2 – 2.7. (3) the overview of high scoring service level risks at 2.8 and Appendix 2. (4) the summary of other risk management developments as noted in sections 2.9 – 2.13. The Plan for North Lanarkshire Priority All priorities Ambition statement All ambition statements Programme of Work Statutory / corporate / service requirement Item 9 Page 81 of 124
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1. Background 1.1 The Audit and Scrutiny Panel terms of reference include the remit to monitor the effective development and operation of risk management in the Council. This report supports the Panel in discharging that aspect of its remit by providing an overview of how certain requirements of the Risk Management Strategy have been delivered during the reporting period. 2. Report Corporate Risk Register 2.1 The CRR is included at Appendix 1. This version includes any changes captured since the previous update to Panel. Risks on the CRR are subject to ongoing monitoring and review, with higher scoring risks being subject to more frequent review. Management considers factors such as changes in the operating environment, the effectiveness of existing controls, the development of additional controls and progress of agreed actions to determine whether it would be appropriate to adjust the risk assessment in line with the Risk Management Strategy. Changes to Corporate Risk Assessments 2.2 During the reporting period, 17 risks were reviewed, with controls and actions updated to reflect current management activity. Any substantive changes to the risks since the previous update to the Panel are highlighted in Appendix 1 and a summary of the notes captured in the review commentary is included in the paragraphs that follow. 2.3 The residual likelihood of the ICT Operational Capability risk was reduced (from 5 to 4). This reflects the ability of the ICT function to maintain availability and deliverability of service despite high demand. The risk causes were also adjusted to recognise the imminent addition of functions to the ICT portfolio. 2.4 A reduction in residual risk assessment was also recorded during the review of the Human Resources risk. It is considered that the risk has been lowered effectively due to the corporate wide focus on enhanced workforce planning. In addition, several service initiatives to address known workforce gaps have been established and are operating well. This is supported by the fact that a recent audit by Audit Scotland has deemed the Councils workforce planning practice to be effective at both corporate and service level. 2.5 In the previous report to Panel there was reference to the ongoing development of the Home Support to focus on current and emerging operational challenges. The revised risk focusses on being unable to deliver consistent and effective levels of Home Support, in line with health and social care standards due to potential delays in implementing the new operating model. Risk ownership has also been aligned to Chief Officer (Adult Social Work Services). 2.6 The title of the Terrorism risk has been amended to Compliance with Counter Terrorism Duties following the most recent review. Similarly, the risk context and other descriptive fields were adjusted to reflect additional duties, in particular compliance with the new guidance on Martyn's Law. 2.7 Following changes to responsibilities within the Corporate Management Team, ownership of the following risks has been assigned to the Chief Officer (Legal, Democratic and Strategy) – National Power Outage and Recovery, Business Item 9 Page 82 of 124
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Continuity Planning, Governance Leadership and Decision Making and Failure of the Councils Resilience Planning Arrangements. Service Risk Registers – risks with highest residual scores 2.8 SRRs are maintained and reviewed through the support of the Service Risk Champion and Risk Facilitator network. A summary of the changes in residual risk profile across our SRRs during the period is shown in the table below. Further detail on the high scoring risk is available in Appendix 2. Other Risk Management Developments 2.9 The RMCWG co-ordinates activities and resources to implement the Risk Management Strategy and promote good risk management practice throughout the Council. There were two sessions of the RMCWG since the last report to Panel, with the notable discussion points noted below: 2.10 The RMCWG has continued to support risk management training and awareness across the risk network. • Mandatory internal training, acting on feedback to develop service specific examples. All service examples have now been being added to the online training system NL Learn and are anticipated to go live by the end of August. • Accredited Essentials of Enterprise Risk Management training course delivered by external provider to colleagues within the Risk Network. Insignificant Low Medium High Very High Total Jan 2026 Jul 2026 Jan 2026 Jul 2026 Jan 2026 Jul 2026 Jan 2026 Jul 2026 Jan 2026 Jul 2026 Jan 2026 Jul 2026 Chief Executive Services 40 33 57 51 36 36 3 3 0 0 136 123 Education & Families 8 7 14 13 22 18 1 1 0 0 45 39 Adult Health & Social Care 0 0 7 5 13 11 0 0 0 0 20 16 Enterprise & Communities 31 36 124 123 75 77 10 9 0 0 240 245 Item 9 Page 83 of 124
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• Support has been provided to new Risk Facilitators by providing training on the corporate risk management information system Figtree. 2.11 The Risk Management monitoring process that identifies areas of focus for the Corporate Risk Team on an individual service basis has been issued to Risk Champions. This iteration included refinements suggested in the Internal Audit Report on Risk Management reported to panel earlier in the year. The results of the monitoring process will be used to target activity to support consistent risk management practice across services. 2.12 Working with the supplier on adjustments to the configuration of Figtree in relation to Risk Controls. Controls can now be linked to multiple risks, and it is envisaged that this will enable efficiencies in the review process for controls and risks. 2.13 Activity has commenced on the “Ever Present Risk” initiative that is outlined in the revised 2026-29 Risk Management Strategy. • A trial question set developed around the controls of the Health and Safety corporate risk has been issued to Chief Officers within Chief Executive Services. • Members of the Corporate Procurement Working Group have been invited to feedback on a question set developed from the controls aligned to “Contract and Supplier Management” on the Procurement corporate risk prior to issuing to services. The results of the trials will inform the next steps for the development of the process. 3. Measures of success 3.1 The Corporate Risk Team will continue to report quarterly to BMT and the Audit and Scrutiny Panel, providing an overview of key developments in risk management and updating on progress in respect of planned improvements to the Council’s risk management arrangements. 3.2 The adequacy and effectiveness of the Council’s risk management arrangements will be subject to independent review by Internal Audit, who will report directly on the results of that work to the Audit and Scrutiny Panel. 3.3 Effective risk management arrangements assist the Council in achieving planned outcomes and/or help the Council mitigate the impacts of adverse events. 4. Supporting documentation Appendix 1: Corporate Risk Register Appendix 2: Highest Scoring Service Risk Register Entries Francis Scott Chief Officer (Audit and Risk) Item 9 Page 84 of 124
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5. Impacts 5.1 Public Sector Equality Duty and Fairer Scotland Duty Does the report contain information that has an impact because of the Public Sector Equality Duty and/or Fairer Scotland Duty? Yes ☐ No ☒ 5.2 Financial impact Does the report contain any financial impacts? Yes ☐ No ☒ 5.3 HR policy impact Does the report contain any HR policy or procedure impacts? Yes ☐ No ☒ 5.4 Legal impact Does the report contain any legal impacts (such as general legal matters, statutory considerations (including employment law considerations), or new legislation)? Yes ☐ No ☒ 5.5 Data protection impact Does the report / project / practice contain or involve the processing of personal data? Yes ☐ No ☒ 5.6 Technology / Digital impact Does the report contain information that has an impact on either technology, digital transformation, service redesign / business change processes, data management, or connectivity / broadband / Wi-Fi? Yes ☐ No ☒ 5.7 Environmental / Carbon impact Does the report / project / practice contain information that has an impact on any environmental or carbon matters? Yes ☐ No ☒ 5.8 Communications impact Does the report contain any information that has an impact on the council’s communications activities? Yes ☐ No ☒ 5.9 Risk impact Is there a risk impact? Yes ☒ No ☐ If yes, please provide a summary of the key risks and potential impacts, highlighting where the risk(s) are assessed and recorded (e.g. Corporate or Service or Project Risk Registers), and how they are managed? Effective risk management arrangements will enable the Council to manage its risks more effectively, increasing the likelihood of the Council achieving its plans and ambitions by minimising or mitigating potential threats to planned outcomes. A robust risk management strategy lays out the framework and underpins all risk management activity across the organisation. 5.10 Armed Forces Covenant Duty Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it relate to healthcare, housing, or education services for in-Service or ex-Service personnel, or their families, or widow(er)s)? Yes ☐ No ☒ 5.11 Children’s rights and wellbeing impact Does the report contain any information regarding any council activity, service delivery, policy, or plan that has an impact on children and young people up to the age of 18, or on a specific group of these? Yes ☐ No ☒ Item 9 Page 85 of 124
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Appendix 1 – Corporate Risk Register CORPORATE RISKS (Operational) Likelihood Impact Rating Evaluation Change 1. Cyber Security 4 5 20 High No 2. Home support 4 5 20 Medium Risk Owner 3. ICT operational capability 4 4 16 High Was 20 4. Information governance 4 4 16 High No 5. Public protection 4 4 16 High No 6. Health and Safety 5 3 15 Medium No 7. Business continuity planning 5 3 15 Medium Risk Owner 8. Compliance with Counter Terrorism Duties 3 5 15 Medium Title 9. Information Security 4 3 12 Medium No 10. Governance, leadership and decision-making 3 4 12 Medium Risk Owner 11. Human resources (workforce planning) 3 4 12 Medium Was 16 12. Procurement risk 3 4 12 Medium No 13. RAAC 3 4 12 Medium No 14. Failure of Council’s Resilience Planning Arrangements 2 5 10 Medium Risk Owner 15. Enterprise Contract Management 2 5 10 Medium No 16. Serious organised crime, fraud and corruption 3 3 9 Medium No CORPORATE RISKS (Strategic) Likelihood Impact Rating Evaluation Change 17. Tackling poverty 5 4 20 High No 18. National Power Outage and Recovery 4 5 20 High Risk Owner 19. Digital adoption 4 4 16 High No 20. Improving educational outcomes 4 4 16 High No 21. Financial sustainability 3 5 15 Medium No 22. Digital and IT strategy 4 3 12 Medium No 23. Climate change 3 4 12 High No 24. Engagement and consultation 3 3 9 Medium No 25. Delivery of approved programme of work 2 4 8 Low No Item 9 Page 86 of 124
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Appendix 2 – Highest Scoring Service Risk Register Entries Risk Number Title Residual Risk Score Service RIA0000372 Inadequate staffing levels or expertise to provide advice and support to the council, its ALEOs and elected members. 20 Chief Executive's RIA0000039 Organisational capacity and retention of staff 16 Chief Executive's RIA0000020 Failure to implement business change / service redesign thus impacting on stated benefits realisation 16 Chief Executive's RIS0000671 Advocacy and Representation for Residents 16 Education & Families RIS0000612 General Workforce within Housing 20 Enterprise and Communities RIA0000223 Service failure due to loss in IT capability 20 Enterprise and Communities RIA0000012 HSMS Maintenance & Development 16 Enterprise and Communities RIS0000315 Management of Service Users Recorded under MAPPA within the Community (Outed Cases) 16 Enterprise and Communities RIS0000709 Impact of staffing issues on service provision 16 Enterprise and Communities RIA0000109 Failure of key unsupported business systems 16 Enterprise and Communities RIA0000170 Maintenance of street lighting 16 Enterprise and Communities RIS0000395 Inability to provide a service due to staffing/ training/ absence etc. 16 Enterprise and Communities RIS0000744 Decommissioning of B: Drive and subsequent loss of reliant databases and data 16 Enterprise and Communities Item 9 Page 87 of 124
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North Lanarkshire Council Report Audit and Scrutiny Panel Does this report require to be approved? ☒ Yes ☐ No Ref RB/SL Date 20/08/26 Performance reporting schedule - quarterly performance assurance review From Rachel Blair, Chief Officer (Legal, Democratic and Strategy) E-mail BlairR@northlan.gov.uk Executive Summary The purpose of this report is to bring together a summary of the council’s performance reports into one composite assurance overview to support the Audit and Scrutiny Panel in maintaining strategic oversight and awareness of the council’s performance reporting arrangements in line with the Panel’s remit to provide “independent review of the council’s governance, risk management, performance, and control frameworks”. It also supports the Audit and Scrutiny Panel’s governance and accountability role in terms of ensuring the council can demonstrate Best Value through the existence of robust arrangements for performance reporting and scrutiny. This process monitors reports which have been submitted to council committees (in line with the Strategic Performance Framework - Performance Reporting Schedule) during the previous cycle. This process began in 2023, with implementation of a quarterly performance assurance review report thereafter. This report herewith provides the Panel with the outcome from the latest quarterly performance assurance review that has been undertaken on performance reports previously submitted to council committees during cycle 2 of 2026 (in line with the most recent Performance Reporting Schedule which was at the Panel in August 2025). Recommendations It is recommended that the Audit and Scrutiny Panel: (1) Review the composite overview of performance reporting provided in Appendices 1 and 2 to maintain an awareness of each report within the latest Performance Reporting Schedule, and (2) Identify whether there are any significant issues arising, from the composite performance overview presented in the attached Appendices, that the Panel considers requires additional scrutiny and a further report to be submitted from the respective Chief Officer to a future meeting of the Panel (following review through the Scrutiny Assessment and Prioritisation Process). The Plan for North Lanarkshire Item 10 Page 89 of 124
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1. Background 1.1 The quarterly performance assurance review report is now well established at the Audit and Scrutiny Panel, having been in place since May 2023. It aligns to the Performance Reporting Schedule considered by the Panel each year which sets out the reporting, review, and scrutiny arrangements for a range of performance information to be considered at each cycle of committee meetings in support of the Strategic Performance Framework. 1.2 The Strategic Performance Framework comprises performance measurement at three levels. This aims to collectively provide an overview of performance to help understand the impact of council activities on improving services and outcomes for the people and communities of North Lanarkshire. The measures in this Framework allow for day-to- day activities, and progress towards achieving the long-term vision set out in The Plan for North Lanarkshire, to be regularly monitored, reported, assessed, and scrutinised. 1.3 The supporting Performance Reporting Schedule forms a key part of the Scrutiny Work Programme that underpins the Best Value governance and accountability theme by ensuring the council can demonstrate the existence of robust arrangements for scrutiny and performance reporting. It also aims to fulfil the Audit and Scrutiny Panel’s remit as per the Scheme of Administration to: • Review and monitor the performance of the council in delivering upon its priorities, outcomes, programme of work, and targets in the council plan, specifically performance in improving local services and outcomes and in demonstrating Best Value. • Review performance to assess whether intended policy outcomes have been achieved. 1.4 The Strategic Performance Framework comprises a set of non-negotiable standards which Chief Officers are required to apply in all performance reporting that supports the Framework. These standards aim to ensure that performance reporting is: • Aligned - to The Plan for North Lanarkshire to give stakeholders an insight into the performance of council activities both in the short-term and against the long-term ambitions. • Consistent - to ensure a standard, easily recognisable, and well-established process across each different audience over time. This aims to help build credibility, reliability, and a common understanding. • Transparent - to allow stakeholders to understand what is being measured, what it means, what level of performance has actually been achieved, and what difference this means in reality for the people and communities of North Lanarkshire. • In context - to avoid the So What? question and provide a coherent narrative to ensure fully informed review, reporting, scrutiny, and decision-making processes. • Balanced - to ensure reporting contains areas in which performance has improved as well as areas where performance has not improved or has declined. Any supporting narrative in this respect must add value and tell a balanced narrative. The narrative should include reasons for performance levels not in line with targets, standards, or original plans and the remedial action undertaken to address this. Priority All priorities Ambition statement All ambition statements Programme of Work Statutory / corporate / service requirement Item 10 Page 90 of 124
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1.5 The Performance Reporting Schedule highlights a significant volume of performance information scheduled for reporting to council committees throughout the year. Cycle 2 2026 reports were reviewed by the Business Management Team in July 2026 to provide assurance, in line with the Best Value duty, that performance management arrangements support the effective use of council resources, are subject to appropriate senior management scrutiny, and that performance monitoring effectively identifies and addresses areas of underperformance through agreed remedial actions. 1.6 The volume of performance information in the latest cycle has been reviewed and summarised in Appendices 1 and 2 attached - it should be noted that the performance information within these Appendices has already been reviewed by Service Committees during cycle 2 of 2026. The purpose of the information presented herewith is therefore to provide Audit and Scrutiny Panel members with a composite, but easily digestible, overview for governance and assurance purposes in line with the specific scrutiny and strategic oversight role of the Panel. 1.7 Should the Panel consider there are any significant issues arising from the composite performance overview which require additional scrutiny, these matters will be reviewed through the Scrutiny Assessment and Prioritisation Process (updated and approved by the Panel in September 2022 and further endorsed in September 2023), prior to being added to the Scrutiny Work Programme for a further report to be submitted from the respective Chief Officer to a future meeting of the Panel. 2. Quarterly performance assurance review 2.1 The Strategic Performance Framework - Performance Reporting Schedule sets out several aspects of performance reporting. As part of this, paragraphs 2.2 to 2.6 itemise the performance reports submitted to cycle 2 of 2026 committees in accordance with the timetable set out in the Schedule. (1) Chief Officer’s individual Performance Review reports at Service Committees in line with the Strategic Performance Framework. (2) Chief Officer service specific performance reporting which takes place each year to meet business and/or statutory obligations. (1) Chief Officer’s individual Performance Review reports at Service Committees in line with the Strategic Performance Framework. 2.2 The Strategic Performance Framework comprises a range of performance indicators from each Chief Officer’s portfolio and the latest results in this respect are aligned to the respective ambition statements in The Plan for North Lanarkshire. The three reports previously submitted to the relevant committee in cycle 2 of 2026 are listed in Table 1 below, along with the corresponding hyperlink for ease of access. Table 1 Report title Committee Date Latest performance results - Employability link to file Enterprise and Fair Work Committee 15 May 2026 Latest performance results - Children’s social work and protection link to file Education, Children, and Families Committee 26 May 2026 Adult social care performance - Quarter 3 (October to December 2025) link to file Adult Care and Social Work Committee 19 May 2026 Item 10 Page 91 of 124
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2.3 Each council report was produced in line with a standard template and (a) provides the reader with the current context within which the service is operating, (b) highlights areas of good performance that can be evidenced in the accompanying data, and (c) provides a summary of areas of performance requiring improvement along with narrative that gives an explanation for the level of performance achieved and summarises the remedial action implemented (or to be implemented) to bring performance back on track. 2.4 A short summary analysis for each of the reports is set out in Appendix 1 against the five non-negotiable standards. (2) Chief Officer service specific performance reporting which takes place each year to meet business and/or statutory obligations. 2.5 This aspect relates to service specific reporting which is required to meet business and/or statutory obligations. This is included in the Performance Reporting Schedule to ensure all the council’s performance reporting arrangements are captured in the one place and the Schedule reflects a one council approach to performance reporting. 2.6 The six reports previously submitted to the relevant committee in cycle 2 of 2026 are listed in Table 2 below, along with the corresponding hyperlink for ease of access. A short summary for each of these reports is set out in Appendix 2. While this summary is set out against the five non-negotiable standards it recognises there may also be statutory specific approaches or standards which require to be adhered to. Table 2 Report title Committee Date Building standards - annual performance report 2025/26 link to file Submitted to the Scottish Government Published on council website on 25 May 2026 Communications review and evaluation - annual report 2025/26 link to file Policy and Strategy Committee 11 June 2026 Licensing Board - annual functions report 2025/26 link to file Licensing Board 26 June 2026 Revenue and benefits update link to file Finance and Resources Committee 27 May 2026 Financial monitoring report - council summary (revenue) link to file Finance and Resources Committee 27 May 2026 Financial monitoring report - council summary (capital) link to file Finance and Resources Committee 27 May 2026 Next steps 2.7 Assurance reviews will continue to be undertaken and reported to the Audit and Scrutiny Panel on a quarterly basis in order to maintain the measures of success set out in paragraph 3.1. The content of the quarterly assurance review reports will continue to be informed by the Performance Reporting Schedule, most recently updated and presented to the Audit and Scrutiny Panel in August 2025. 2.8 Reports submitted to the respective committees, in line with the Performance Reporting Schedule, will continue to be kept under review by the council’s senior management Item 10 Page 92 of 124
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team to ensure adherence to the agreed timetable. This approach also provides assurance regarding the efficient and effective operation of the council and supports the ongoing delivery of the long-term ambition set out in The Plan for North Lanarkshire, underpinned by robust corporate governance arrangements. 3. Measures of success 3.1 Measures of success include: • Regular oversight and monitoring of performance across the organisation, providing assurance on effective governance, accountability, and transparency. • Regular review and challenge processes that scrutinise council performance to ensure effective use of resources, alignment with agreed policy and priorities, sound decision-making, and clear accountability for how resources are applied to achieve improved outcomes for service users and the local community. • Robust performance monitoring, management, and reporting arrangements that support the demonstration of service improvement, improved outcomes, and the delivery of Best Value. 4. Supporting documentation Appendix (1) Chief Officer’s individual Performance Review reports at Service Committees in line with the Strategic Performance Framework. Appendix (2) Chief Officer service specific performance reporting which takes place each year to meet business and/or statutory obligations. Rachel Blair Chief Officer (Legal, Democratic and Strategy) 5. Impacts 5.1 Public Sector Equality Duty and Fairer Scotland Duty Does the report contain information that has an impact as a result of the Public Sector Equality Duty and/or Fairer Scotland Duty? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? If Yes, has an assessment been carried out and published on the council’s website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality- and-fairer-scotland-duty-impact-assessments Yes ☐ No ☐ 5.2 Financial impact Does the report contain any financial impacts? Yes ☐ No ☒ If Yes, have all relevant financial impacts been discussed and agreed with Finance? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.3 HR policy impact Does the report contain any HR policy or procedure impacts? Yes ☐ No ☒ If Yes, have all relevant HR impacts been discussed and agreed with People Item 10 Page 93 of 124
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Resources? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.4 Legal impact Does the report contain any legal impacts (such as general legal matters, statutory considerations (including employment law considerations), or new legislation)? Yes ☒ No ☐ If Yes, have all relevant legal impacts been discussed and agreed with Legal and Democratic? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? The legal impact in this report is only in relation to supporting demonstration of the council’s compliance with the relevant legislation listed below. It does not introduce new legal duties or changes to the council’s statutory responsibilities in this respect. • The Local Government Act 1992 established the role of the Statutory Direction to direct councils in terms of the “publication of information as to standards of performance”. • The Local Government in Scotland Act 2003 introduced the statutory duty of Best Value which requires the council to “make arrangements which secure Best Value” and ensure “continuous improvement in the performance of the authority’s functions”. 5.5 Data protection impact Does the report / project / practice contain or involve the processing of personal data? Yes ☐ No ☒ If Yes, is the processing of this personal data likely to result in a high risk to the data subject? Yes ☐ No ☐ If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e- mailed to dataprotection@northlan.gov.uk Yes ☐ No ☐ 5.6 Technology / Digital impact Does the report contain information that has an impact on either technology, digital transformation, service redesign / business change processes, data management, or connectivity / broadband / Wi-Fi? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? Where the impact identifies a requirement for significant technology change, has an assessment been carried out (or is scheduled to be carried out) by the Enterprise Architecture Governance Group (EAGG)? Yes ☐ No ☐ 5.7 Environmental / Carbon impact Does the report / project / practice contain information that has an impact on any environmental or carbon matters? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.8 Communications impact Does the report contain any information that has an impact on the council’s communications activities? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.9 Risk impact Item 10 Page 94 of 124
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Is there a risk impact? Yes ☒ No ☐ If Yes, please provide a brief summary of the key risks and potential impacts, highlighting where the risk(s) are assessed and recorded (e.g. Corporate or Service or Project Risk Registers), and how they are managed? Implementation of the Performance Reporting Schedule, which facilitates regular reporting, review, and scrutiny processes, contributes to mitigating the risk on the Corporate Risk Register in relation to governance, leadership, and decision-making. 5.10 Armed Forces Covenant Duty Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it relate to healthcare, housing, or education services for in-Service or ex- Service personnel, or their families, or widow(er)s)? Yes ☐ No ☒ If Yes, please provide a brief summary of the provision which has been made to ensure there has been appropriate consideration of the particular needs of the Armed Forces community to make sure that they do not face disadvantage compared to other citizens in the provision of public services. 5.11 Children’s rights and wellbeing impact Does the report contain any information regarding any council activity, service delivery, policy, or plan that has an impact on children and young people up to the age of 18, or on a specific group of these? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact and the provision that has been made to ensure there has been appropriate consideration of the relevant Articles from the United Nations Convention on the Rights of the Child (UNCRC). If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been carried out? Yes ☐ No ☐ Item 10 Page 95 of 124
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Appendix 1 (1) Chief Officer’s individual Performance Review reports at Service Committees in line with the Strategic Performance Framework. Report title Summary Latest performance results for Employability May 2026 Within the service area of Employability there are 10 indicators in the Strategic Performance Framework. Driving up the employment rate in North Lanarkshire is a cornerstone of The Plan for North Lanarkshire. Through targeted employability services, partnerships with employers and education providers, and a focus on inclusive growth, the council aims to create opportunities that improve individual life chances, strengthen communities, and support a thriving local economy. Ensuring that employability support is accessible to all residents is recognised as a key contributor to both local economic development and poverty reduction. Supporting unemployed and underemployed residents into fair, sustainable employment, while also ensuring that all young people progress into a positive destination, therefore remains a priority for the council. Aligned Priority: • Improve economic opportunities and outcomes. • Support all children and young people to realise their full potential. Ambition statement: 5. Grow and improve the sustainability and diversity of North Lanarkshire’s economy. 6. Raise attainment and skills for learning, life, and work to enhance opportunities and choices. Consistent The pre-defined template was used to ensure a standard, easily recognisable, and well established process across each different audience over time. The use of this template aims to help build credibility, reliability, and a common understanding. Transparent Benchmarking indicators: https://www.improvementservice.org.uk/benchmarking/explore-the-data • Positive destinations - % pupils leaving school and entering a positive destination. • Participation rate - % 16-19 year olds engaged with an organisation for the purposes of learning, training, or work. • Employment support - % unemployed people assisted into work from council operated / funded employability programmes. • Living wage - % of people (age 18+) in employment earning less than the real living wage. • Out of work benefits - claimant count as a % of working age population. • Out of work benefits - claimant count as a % of the population aged 16 to 24. RAG indicators: Item 10 Page 96 of 124
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In context • The North Lanarkshire labour market reflects the national picture, with recruitment activity slowing over the last 12 months as employers respond to increased operating and staffing costs. Despite this, unemployment has remained relatively low. Over the past six months, unemployment in North Lanarkshire has consistently fallen below the national average for the first time, highlighting sustained improvements in the local labour market. These improvements reflect both wider economic conditions and the successful implementation of The Plan for North Lanarkshire, supported by effective business and employability services and strong education and inclusion provision. Longer-term growth in average earnings has also contributed to a stronger local economy and increased prosperity for residents. • A very positive trend over the last 12 months has been the reduction in economic inactivity across local communities. This had been a significant concern in the post-pandemic period, when North Lanarkshire had some of the highest levels of economic inactivity in Scotland. Over the last two years, however, the area has moved from being among the three highest-ranking local authorities for economic inactivity in 2024 to 16th nationally. Economic inactivity has fallen from 29.5% of the working-age population in March 2024 to 22.9% in the latest available figures, bringing North Lanarkshire broadly in line with the Scottish average of 22.7%. This improvement has been driven by fewer people citing long-term sickness or caring responsibilities as barriers to employment and has coincided with an increase in the number of economically inactive residents who say they would like to work. • This is a very positive emerging trend in North Lanarkshire, and employability programmes will continue to engage and support this group alongside those who are unemployed. The growing gap between those in work and those out of the labour market reinforces the importance of employment as a key route out of poverty. This supports the council’s approach of providing voluntary, person-centred employability support that addresses barriers relating to health, wellbeing, and financial circumstances alongside vocational training and work experience. Key programmes include community-based support delivered through Routes to Work Ltd and the Working for Families programme, which helps parents on low incomes move towards employment. Cross-service working is central to employability provision, with employability, housing, poverty, and whole- family support services working alongside partners to provide co-ordinated support for residents furthest from the labour market. Balanced Performance highlights: • North Lanarkshire Council-funded employability programmes are benchmarked against those of other Scottish local authorities through the Local Government Benchmarking Framework (LGBF). The latest 2024/25 snapshot shows North Lanarkshire ranked third out of all 32 councils for supporting residents into employment, behind only the Western Isles and Fife Councils. • In 2024/25, the Working for Families programme also expanded its reach significantly, with low-income parents now accounting for 66% of all participants supported. At the same time, council-funded programmes continue to provide targeted support for other priority groups, including people with long-term health conditions (27% of participants). Importantly, half of all individuals supported live within the 20% most deprived data zones, demonstrating the programme’s strong focus on those facing the greatest barriers to employment. • In relation to efforts to close the disability employment gap, the Supported Employment team continued to work with more than 200 disabled people each year through its person-centred model of support. This approach continues to deliver consistently higher rates of employment sustainability than mainstream programmes, with 79.4% of participants remaining in employment six months after securing a job in 2025/26. • Alongside work with adults, the council continues to deliver innovative support for young people with additional support needs as they leave school and transition into the labour market, as well as a similar programme for care-experienced young people. These programmes take an innovative approach that engages employers in a meaningful way, creating opportunities for young people with additional support needs and those facing additional barriers to securing employment. Areas of performance requiring improvement: • There are no areas requiring improvement based on current RAG status. However, sustaining the reduction in economic inactivity, particularly among residents with long-term health conditions, remains a focus. The participation of young people aged 16-24 in the labour market also Item 10 Page 97 of 124
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continues to be prioritised to support positive long-term outcomes. Report title Summary Latest performance results for Children’s social work and protection May 2026 Children’s Social Work and Protection have 8 indicators in the Strategic Performance Framework which focus on a range of statutory areas of children’s social work as well as providing national benchmarking information. This complements information on social work performance and improvement activity presented annually to committee through the Annual Report of the Chief Social Work Officer (CSWO), the most recent of which was presented to the Education, Children, and Families Committee in November 2025. As the Chief Social Work Officer holds key responsibilities for social work performance and standards, the annual report provides further assurance and oversight of service performance and improvement activity. While social work carries specific statutory responsibilities for children and young people at risk of harm, in need, experiencing care, or who have experienced care, these duties are delivered within a partnership context. Strategic oversight and direction are provided through the Chief Officers’ Public Protection Group and the Children’s Services Partnership, for which the CSWO is the lead officer. The Children’s Services Plan 2023-26 sets out the shared vision and ambitions for improving outcomes for children, young people and families across North Lanarkshire, outlining how partners will work together to deliver effective services and support and achieve agreed priorities. This provides the broader strategic context within which statutory social work responsibilities are delivered and improved. The Promise remains a key driver of improvement and transformation for both children experiencing care, as well as for children and young people in need and their families, including those at risk of harm. There is also an increasing emphasis on early family support, which is a central strand of the Resilient People Programme of Work. Aligned Priority: • Support all children and young people to realise their full potential. • Improve the health and wellbeing of our communities. Ambition statement: 7. Enhance collaborative working to maximise support and ensure all our children and young people are included, supported, and safe. 9. Invest in early interventions, positive transitions, and preventative approaches to improve outcomes for children and young people. 14. Ensure the highest standards of public protection. Consistent • The pre-defined template was used to ensure a standard, easily recognisable, and well established process across each different audience over time. The use of this template aims to help build credibility, reliability, and a common understanding. Transparent Benchmarking indicators: https://www.improvementservice.org.uk/benchmarking/explore-the-data • Looked after children - gross cost of children looked after in residential based services per child per week. • Looked after children - gross cost of children looked after in a community setting per child per week. • Balance of care for looked after children - % of children being looked after who are cared for in the community. • Looked after children - % with more than one placement in the last year. • Child protection - % of child protection re-registrations within 18 months. Wider national measures: Item 10 Page 98 of 124
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• Looked after children - number of looked after children as a % of the population (aged 0 to 17). • Child protection - number of children on the child protection register per 1,000 population (aged 0 to 15). • Child protection - average number of areas of concern recorded for each child on the child protection register. In context • The information within this indicator set is only measured annually for benchmarking purposes through national sources, including the Local Government Benchmarking Framework (LGBF) where there is a time lag in the data, most notably for statistics relating to care experience (looked after children). However, this data complements the information on social work performance and improvement activity provided to committee through the annual report of the CSWO and reporting of the council’s Resilient People Programme of Work. • Regulated care services, including adoption and fostering services and children’s houses, are subject to external scrutiny by the Care Inspectorate. Other areas of children and families social work are also reviewed through periodic strategic partnership and thematic inspections. A Joint Inspection of Services for Children and Young People at Risk of Harm, published in October 2023, evaluated the impact of services on children and young people as Very Good. The partnership is currently participating in further scrutiny activity through Phase 1 of the National Review of Group based Child Sexual Abuse and Exploitation. This reflects an increasing focus on extra-familial harm, an area where the evidence base and national data remain less developed. • More than half of the indicators in the report relate to children and young people with care experience, reflecting an area where The Promise continues to be the key national driver for transformation and improvement. Both the previous and current multi-agency Children’s Services Plans for North Lanarkshire have been shaped by the principles of The Promise and the United Nations Convention on the Rights of the Child (UNCRC). Delivery and progress are overseen by the Children’s Services Partnership Board, which includes Elected Member representation. Annual reports on progress against the statutory Children’s Services Plan are submitted to both the Board and the Scottish Government. • National Guidance for Child Protection in Scotland, first published in 2021 and updated in 2023, continues to provide the framework for multi- agency practice and the delivery of statutory children and families social work services. The guidance reflects a broader understanding of child protection, recognising it as part of a continuum that includes whole-family support, early intervention, and action to address child poverty and extra-familial harm. Working across all of these areas, Children’s Social Work is uniquely positioned to connect and drive the key strands of activity needed to deliver the ambitions of The Promise and support the transformation of systems, outcomes, and experiences for children, young people, and families. This work, however, is being undertaken within an increasingly complex legislative landscape, with a range of new duties placed on local authorities and social work services since 2020. These include responsibilities from the Children (Scotland) Act 2020, the Children (Care and Justice) (Scotland) Act 2024, and the recently passed Children (Care, Care Experience and Service Planning) (Scotland) Bill. • Taken together, the indicators in the report suggest a reduction in the number of children and young people supported through key statutory measures, most notably those subject to child protection registration. However, these measures provide only a partial picture of demand on Children and Families Social Work services. Activity in other areas continues to grow, reflecting emerging and increasingly complex patterns of need, as highlighted in the CSWO annual report 2024/25. New referrals to the service remained around 20% above pre-pandemic levels in 2024/25, although marginally lower than in 2023/24. Alongside this, the continued positive balance of care may indicate the impact of sustained investment in early family support, prevention, and relationship-based practice over recent years. However, given the ongoing challenges experienced by many children, young people, and families, it is too early to conclude that this trend will continue in the longer term. • While the direct impact of the integrated, holistic, and tiered approach to family support is not yet reflected in nationally benchmarked indicators, progress and outcomes continue to be reported to the Education, Children, and Families Committee through the reporting arrangements associated with the Resilient People Programme of Work (most recently reported in May 2026). These reports provide a broader assessment of the impact of early intervention, prevention, and family support activity, beyond that captured through national performance measures. Balanced Performance highlights Item 10 Page 99 of 124
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• Despite upward inflationary pressures on placement costs, particularly for independent and external residential and fostering provision, expenditure in both areas continues to compare favourably with national and family group averages. This reflects a strong focus on community- based placements, including the high proportion of children and young people supported through kinship care. While this remains a positive position, challenges in foster carer recruitment and retention persist. The introduction of the Scottish Recommended Allowance has provided additional support for kinship and fostering placements, although continued focus will be required to maintain sufficient placement capacity. Similarly, an early and integrated response to children and young people with the most complex needs will be vital in managing the upward pressure for specialist external supports. • Linked to the above, the council ranked first in Scotland on the balance of care measure, supporting a significantly higher proportion of young people in community settings than both the national and family group averages. Latest performance improved from 94.5% in the previous year to 94.9%, against a slight national decline. While placement decisions must always reflect the needs of individual children and young people, this demonstrates a strong commitment to supporting children in family-based settings and maintaining local community connections through integrated, relationship-based support. Most children and young people requiring residential care are also supported within in-house children’s houses, a position sustained despite increasing demand pressures, including support for unaccompanied asylum-seeking children and the growing impact of continuing care arrangements, the latter seeing an increasing number of young people remaining in placement beyond 18. • A safe, stable home and secure relationships are central to a child’s plan. In 2023/24, 11.2% of children experienced more than one placement move, compared with national and family group averages of 17.5%. The council has consistently performed in the top quartile on this measure and has ranked first in Scotland in eight of the last ten years. • At 1.0%, the proportion of children and young people (aged 0-17) who are looked after by the local authority, also remains below the national average of 1.2%, reflecting a sustained focus on strengthening family support and enabling children to remain safely within their families and communities wherever possible. Areas of performance requiring improvement • 2024/25 saw a significant decrease in the percentage of children (aged 0-15) placed on the Child Protection Register, from 1.7 to 0.9 per thousand population, compared with a national decrease from 2.8 to 2.3. While this does not in itself indicate poor performance, and North Lanarkshire has consistently remained below the national rate, the scale of the reduction warrants close monitoring to ensure robust decision- making. Falling rates may reflect early and effective support, but this will continue to be tested through ongoing audit activity. This measure does not capture the full range of public protection activity, particularly for older young people supported through contextual safeguarding approaches. • A significant rise in re-registration to the Child Protection Register (22.4% in 2024/25), above the national average, is a concern. While the smaller overall registration cohort does increase vulnerability to rate fluctuations arising from changes in circumstances with respect to a relatively small number of large families, almost 1 in 4 children were re-registered within 18 months of leaving the child protection register. This may reflect complex circumstances, but could also indicate that some children are removed too early and before positive change is sufficiently embedded. The service continues to monitor the position closely through targeted audit activity to identify any learning and improvement actions. Report title Summary Adult social care performance report - Quarter 3 (October to December 2025) The Chief Officer (Health and Social Care North Lanarkshire) holds joint quarterly performance review meetings with the Chief Executives of NHS Lanarkshire and North Lanarkshire Council. These are supported by a Chief Executive’s Performance Framework, covering key measures, targets, and trajectories across health and social work systems. In each quarter areas for improvement within the performance framework are identified through the use of a RAG rating. Measures flagged as Red or Amber are subject to improvement or corrective action, which are jointly agreed through the performance review Item 10 Page 100 of 124
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May 2026 meetings. Aligned Priority: • Improve the health and wellbeing of our communities. Ambition statement: 12. Ensure our residents are able to achieve, maintain and recover their independence through appropriate supports at home and in their communities. 13. Improve preventative approaches including self-management and giving people information and choice over supports and services. 14. Ensure the highest standards of public protection. Consistent A pre-defined Health and Social Care Partnership template is in place to ensure a standard, easily recognisable, and well established process for quarterly reporting on areas for improvement. Transparent Based on a traffic-light system there are areas for improvement identified within the performance framework each quarter for those areas that are flagged as Red or Amber. The areas for improvement identified are progressed as a matter of priority, and progress updates are reported at future meetings of the Integration Joint Board and/or the Integration Joint Board Performance, Finance, and Audit Committee as appropriate. In context • Information from the joint quarterly performance reviews has been supplemented with additional information to offer a wider overview of performance across key areas of adult social care delivery. • The new Social Work case management system continues to be implemented across services and teams. Some standard reports remain under development as new recording processes are embedded, and reporting functionality is rebuilt within the Mosaic system. Once these processes are established and validated, reports will be tested and quality assured prior to the performance reporting of data extracted from the system. • While every effort is being made to maintain continuity of reporting, the availability of some data remains affected in the short-term by the implementation of the new case management system. As a result, there is some disruption to Social Care reporting within the Scorecard, and a small number of metrics included in the report are currently unavailable where relevant Mosaic functionality is not yet operational. Balanced This report, for quarter 3 (October to December 2025), provides an update on the areas for improvement that have been identified as part of the service’s quarterly performance review. It sets out the corresponding narrative and corrective actions agreed. A summary is noted below. • Assistive technology - performance for assistive technology remains below target during quarter 3, although recent improvements to reporting through ELMS2 (the software solution that supports the management of community equipment services) have significantly improved data completeness, providing a more accurate picture of activity. - This shows that demand continues to grow, driven by hospital discharge pressures and the strategic focus on supporting people to remain safely at home. - Alongside core service delivery, a significant volume of resource intensive support is provided to people in the community, however current performance measures do not fully capture the breadth of activity undertaken by the service. - Work is ongoing to strengthen the integration of assistive technology within assessment and discharge pathways, although staffing capacity continues to impact delivery which continues to affect the pace at which assessments, installations, and reviews can be completed. - A review of performance indicators and targets is planned as part of the 2026/27 scorecard refresh to ensure measures reflect data maturity, workforce capacity, and the full scope of assistive technology activity. • Equipment and adaptations - performance continues to improve, with delivery times now slightly exceeding the 80% target following sustained improvements to operational processes. Further work is underway to strengthen stock management, equipment recycling, and ordering Item 10 Page 101 of 124
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processes, alongside a service redesign to evaluate role profiles and operational arrangements to support continuous improvement. • Reablement and rehabilitation - performance against the reablement indicators during Q3 reflects continued progress in embedding the revised operating model for assessment and support at home. - In Q3 more individuals were supported through the reablement pathway than the previous quarter, although numbers remain below target. - New or increased home support packages delivered through reablement have improved, reflecting the focus on enabling approaches. - However, the proportion of individuals requiring no or reduced home support following reablement has declined, likely reflecting the increasing complexity of need among those entering the pathway, including higher levels of frailty, comorbidity (i.e. the simultaneous presence of two or more distinct medical or psychological conditions in the same person), and age-related complexity. • Care homes - the average length of stay in care homes increased during Q3 and remains above target. This measure is influenced by a range of factors, including complexity of need, the availability of community alternatives, and wider system pressures affecting hospital discharge and community flow, and therefore short-term movement should always be interpreted with caution. - Operational activity continues to focus on strengthening home first approaches and supporting discharge pathways that enable people to return home wherever possible. - The relatively low rate of care home placements among people aged 65+ and 75+ reflects North Lanarkshire’s continued focus on independence, community-based support, and a balance of care approach that prioritises supporting people to remain in their own homes. • Adult protection - the majority of Adult Support and Protection referrals, where there is a duty to inquire, continue to progress within required timescales. During Q3, 875 referrals were received, a 33% increase on the same period last year, with care home referrals accounting for a most this. The care home sector accounts for 25% (210) of all referrals received by social work. Compared to Q3 last year, referrals from care homes have increased 26% (from 167 to 210). - Physical and emotional / psychological harm remain the most common harm types of referrals. Self-neglect also continues to be a significant area of concern, requiring a co-ordinated multi-agency response to mitigate the associated risks. Individuals also experience multiple forms of harm, which are not always fully reflected in the data. The implementation of Mosaic has improved the recording of emerging harm types, including suicidal ideation, online harm, hoarding, and domestic abuse, providing valuable insight into emerging risks and vulnerabilities. - The proportion of investigations progressing to case conference within the expected timescales remained low in Q3. This is largely attributable to ongoing recording and data quality issues, with work underway alongside operational teams to improve recording practices and strengthen data quality. Once resolved, the indicator is expected to provide a more accurate reflection of safeguarding activity. - The high proportion of adult welfare concerns requiring no further action reflects that many individuals are already receiving appropriate support from services or partner agencies. Internal audit activity has confirmed that these cases often involve people who are already known to services or supported through alternative pathways, indicating appropriate safeguarding decision-making rather than unmet need. • Sickness absence - levels increased during Q3, with local intelligence indicating that seasonal illness was a significant contributing factor, consistent with patterns seen during previous winter periods. Absence levels continue to be actively monitored and managed in line with relevant policies and procedures. Staff are offered appropriate support throughout periods of absence, including regular contact and access to wellbeing resources to support recovery and facilitate a timely and sustainable return to work. Item 10 Page 102 of 124
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Appendix 2 (2) Chief Officer service specific performance reporting which takes place each year to meet business and/or statutory obligations. Report title Summary Building standards - annual performance report 2025/26 May 2026 Local authority Building Standards teams are responsible for delivering Scotland’s building standards verification service. North Lanarkshire Council, as a verifier appointed by Scottish Ministers, is responsible for administering this service within North Lanarkshire and ensuring compliance with building regulations. This includes responsibilities for the independent checking of applications for building warrants to construct or demolish buildings, to provide services, fittings or equipment in buildings, or for conversions. The annual verification report is a strategic planning and management tool that provides information about the council’s building standards service; it communicates the vision and strategy and sets out performance against strategic goals and national targets. Produced in accordance with the national performance framework for verifiers, building standards verifiers in Scotland are required to use the performance report to manage, monitor, review, and develop strategies for their business, with a focus on the performance framework’s core perspectives and cross-cutting themes. The report also supports continuous improvement by reporting performance against national outcomes and identifying priorities for future service development. Aligned Priority: • Improve the health and wellbeing of our communities. Ambition statement: 14. Ensure the highest standards of public protection. Consistent • The report provides an overview of the statutory verification role undertaken by North Lanarkshire Council on behalf of Scottish Ministers, including the assessment of building warrant applications, verification of completion certificates, enforcement activities, and the wider regulatory functions delivered by the building standards service. • The report is produced annually in a consistent format. It includes information on service delivery, the timescales and targets to be met, and performance against these. Verifiers are required to provide returns to Scottish Government on both their performance and workload - the performance data relates to the building standards verification performance framework while the workload data relates to the number of building warrant applications (and amendments), completion certificates, certificates for design and construction, statements of sustainability, and enforcement notices and cases. • The report sets out the Building Standards Charter which provides information about the standards of service that all verifiers should meet. This gives customers the reassurance that a consistent, high-quality service will be delivered no matter which verifier provides the service. It is divided into two parts - a national Charter and a local Charter. The aim is to grant building warrants and accept completion certificates, to secure the health, safety, welfare, and convenience of persons in and about buildings and others who may be affected by buildings or matters connected with buildings, to further the conservation of fuel and power, and to further the achievement of sustainable development. • All building standards annual performance reports are required to be produced using a template provided by the Scottish Government. Transparent • The national verification performance framework is based on three core perspectives (professional competency and operational processes, quality customer experience, and financial integrity). There are also three cross-cutting themes - public interest, continuous improvement, and partnership working. The annual report is structured around this framework. • The report contains a public interest statement. This outlines that the purpose of the building standards system is to protect the public interest. The system sets out the essential standards that are required to be met when building work or conversion of a building takes place in order to Item 10 Page 103 of 124
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meet building regulations. The building standards system checks that proposed building work or conversion of a building meets standards; inspections are limited to a minimum necessary to ensure that legislation is not avoided. The control of work on site is not down to the system but is a matter for contracts and arrangements in place between a builder and client. • The report outlines six key performance outcomes within the national planning framework - covering professional competency and operational performance, quality customer experience, and operational and financial integrity - and reports performance against associated targets. • The report includes a dedicated section on performance against key outcomes and targets, supported by explanatory narrative. In context • The report sets out the place-based context within which the building standards service is delivered across North Lanarkshire as well as the operating context within the council. Work through building standards helps to support economic growth by creating safe, attractive, and well- maintained places where people want to live, work, and invest. Through the timely processing of building warrants, support for development projects, improvements in private sector housing, and proactive management of compliance and enforcement issues, the team helps facilitate investment, regeneration, and sustainable development across North Lanarkshire. • The report also provides information on the structure, staffing, and workforce profile of the building standards service, including workforce development, succession planning, competency assessment, and activity to support future service delivery. Balanced • As well as the performance results, the report highlights actions completed within the last year together with a number of continuous improvement actions which will be implemented in the forthcoming year (these cover the three core perspectives of professional competency and operational processes, quality customer experience, and operational and financial integrity). These actions are aligned to the respective outcomes and indicators to ensure improvements implemented can be assessed in terms of performance on the ground in the future. • The report highlights partnership working undertaken at both local and national levels, including collaboration with the Local Authority Building Standards Scotland (LABSS), the Scottish Building Standards Hub, and the council’s Local Housing Strategy and New Supply groups, and consortium partners to support consistency, service improvement, and delivery of the wider building standards agenda. • A summary of the 2025/26 performance outcomes set out in the annual performance report is noted below: - Performance against the six national key performance outcomes remained relatively positive overall during the year. - In respect of first reports (for building warrants and amendments) issued within 20 days, 86.5% were issued in Q1, with quarterly performance for the remainder of 2025/26 ranging between 82.1% and 87.9%, against a target of 95%. - For building warrants and amendments issued within 10 days of receiving satisfactory information, quarterly performance ranged from 82.4% to 87.8% across the year, against a target of 90%. While targets were not fully achieved, performance remained consistently high despite changes to working arrangements and support service structures. - Customer satisfaction exceeded expectations, achieving a score of 9 out of 10 against a minimum level target of 7.8 out of 10. - Financial performance remained strong, with verification fee income of £2.74m exceeding indicative verification service costs of £0.87m, demonstrating the sustainability of the service. - The building standards annual report continues to be published on the council’s website; this includes performance reporting aligned with the national key performance outcome framework. Report title Summary Communications review and evaluation - annual report 2025/26 Policy and Strategy Committee approved a five-year Communication and Engagement Strategy in June 2024. As part of the implementation of the Communication and Engagement Strategy, an annual communications evaluation is required to be presented to committee for approval. This evaluation helps to demonstrate effectiveness and performance of the service - it also demonstrates the value and benefits of a wide range of quality, multi-disciplinary communications undertaken by the service. Item 10 Page 104 of 124
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June 2026 The report informs on the programme of communications activity, campaigns, projects, and community engagement that has been undertaken over 2025/26 aligned with the Strategy to support The Plan for North Lanarkshire and Programme of Work. Aligned Priority: All priorities Ambition statement: All ambition statements Consistent • The evaluation report in the appendix to the report links the outputs and outcomes generated by Corporate Communications to improve service delivery and impact positively on residents, communities, and businesses. All activity is aligned to key themes in The Plan for North Lanarkshire (and its symbiotic corporate branding), as well as activities within the Programme of Work and regular council business. Transparent • The report summarises a significant bank of communications activity supporting The Plan for North Lanarkshire and the Programme of Work, alongside other campaigns and communications activity focussed on delivering positive outcomes for people, communities, and businesses. It includes an overview of activity undertaken during 2025/26, key highlights, and narrative demonstrating how communications has supported service delivery, council policies, and the Programme of Work. It also outlines the communications operating model and its future direction. • All major communications and engagement activity is evaluated in line with the Strategy to ensure alignment with The Plan for North Lanarkshire and demonstrate its effectiveness and positive impact on people and communities. In context • In line with the Communications and Engagement Strategy, all major activity must support either a programme of work, or an ambition statement, which aligns with the core narrative that supports the live, learn, work, invest, and visit brand strategy. • Much of the focus for communications activity over the last year has been on supporting specific projects within the seven Programme of Work priorities (Transforming Places, Invest in North Lanarkshire, Sustainable Futures, Resilient People, Brighter Futures, Digital North Lanarkshire, and One Service), as well as ongoing campaigns aligned to the delivery of The Plan for North Lanarkshire. • Communications support for committee business, civic activities, and routine service delivery forms part of business-as-usual activity and may not be included within evaluation reporting. Balanced Performance highlights in the report show that: • The volume of enquiries and demand on Communications and Engagement services continues to be high, with 265 media enquiries received and 293 news releases issued. 275 videos were posted on social media channels with 735 posts on Facebook and several hundred on other channels, which led to 30,944,318 views on social media. • The brand and creative team worked on 741 individual design projects, 45 large media projects, including 53 animations, 261 videos, 37 audio recordings, and 9 presentations with 25 websites supported. • Digital channels continue to be crucial for public engagement. The council website is firmly established as the key platform for delivering services to residents, with up to 50 online forms linked to back-office systems now in operation. Total form submissions for 2025 exceeded 109,000, more than double the submissions for 2024. There continues to be year-on-year growth in general website traffic, with more than 14 million page views compared to 13 million over the previous period (2024/25), representing a 6% increase. • With the exception of X, all corporate social media channels experienced growth in follower numbers, the highest being TikTok, where followers grew by 201% and the local My Town community social media channels with, on average, a 16.5% increase in followers. • E-mail marketing remains the most effective digital engagement platform, delivering targeted, personalised messages to residents who have registered to receive e-mail bulletins on topics of intertest. In the year registrations increased by 3% to 61,742 subscribers with a bulletin open Item 10 Page 105 of 124
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rate of 37%, above the industry average. The report indicates there were 58 campaigns evaluated and discussed with services to ensure the outputs inform service changes or improvements. Analysis and evaluation can help inform future campaigns and phases of campaigns to ensure a robust demonstration of the outcomes which can be achieved by communication activity. As a result of various promotional activities during the year, key achievements include: • Invest in North Lanarkshire website - generated 416 business enquiries, supporting 14 new business relocations/start-ups, with 46,600 clicks through to the website and click-through rates (of 1.34%) three times above the industry average of 0.4%. • Open market purchase scheme campaign - contributed to a 36% increase in property acquisitions, bringing 125 properties back into use this year, compared to 92 last year. • Promotion of Active NL - this saw memberships reach a record high of 47,000, with sports camp bookings increasing by more than 3,000 from last year and income up 33%. • Working for families - this programme saw 867 parents registered, with 306 securing employment and 159 attaining qualifications. • RUN NL success - attracting 1,048 runners, the first-ever half marathon sold out, with participation in other local running events increasing by over 20%. • Digital services - myaccount registrations reached 191,727, which covers a large proportion of all households in North Lanarkshire and reflects around 7,000 average weekly users and 67% of adults signed up. • Youth employment - through promotion of the student summer placement programme there were a record 191 young people who secured placements during the school holidays, with 1,492 applications received. • Women in business - the Hive business incubator saw an increase in registered users by 50%, 14 new businesses supported to start-up, and 113 hive users attending business events. • Campaign to recruit modern apprentices - saw applications increase by 88% with 565 applications received for 53 apprentice positions. • Promotion of the NL Employer Charter - videos and business-to-business channels contributed to the number of accredited charter members increasing to 105 (a 69% increase from last year). • Campaign to support people struggling with the cost of living - resulted in the tackling poverty team assisting 1,968 individuals who engaged, addressing £4.2m of debt and generating almost £47m in additional benefit income for local residents. • Garden waste service - a range of communications contributed to a higher number than anticipated number of garden waste uplift permits purchased (44,000). • Period products - through increased awareness, 64% of women (when polled) said they were aware of the service and 46% said they had seen it advertised through the campaign. • School attendance - a three month campaign to improve secondary school attendance rates focused on highlighting the positives of attending school every day and what’s missed when not in school, this contributed to attendance improving from 86.3% to 88.6% over the time. • Culture and tourism - campaigns to promote the what’s on entertainment programme saw Airdrie Town Hall ticket sales increase to 26,274 (a 13% increase on last year), with Summerlee attracting over 175,343 visitors (4% up on last year). • Visit Lanarkshire - off season campaigns to promote Lanarkshire as a destination resulted in users of the Visit Lanarkshire website more than doubling over the last year, with over 200,000 active users and over 400,000 page views. The innovative North Lanarkshire Stories Trail continues to draw visitors to its 10 locations. • Suicide prevention - during the year this campaign generated over 3 million impressions, achieving around 40,000 click throughs to the website from digital adverts. For the FeelWellNL initiative, there were 1,524 engaged users throughout the year with vulnerable individuals being directed to immediate support. Item 10 Page 106 of 124
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Report title Summary Licensing Board - annual functions report 2025/26 June 2026 The report provides an overview of how the North Lanarkshire Licensing Board has exercised its statutory functions during 2025/26 and demonstrates how the Board has had regard to the five licensing objectives in carrying out its responsibilities. It also explains how the Board has applied its Statement of Licensing Policy, detailing licensing activity undertaken throughout the year, and providing information relating the licences in force within North Lanarkshire. The report notes that, during 2025/26, the Board continued to discharge its statutory responsibilities in accordance with the Licensing (Scotland) Act 2005 and its Statement of Licensing Policy. It also notes that the Board remains committed to promoting the licensing objectives through fair, transparent, and evidence-based decision-making, while supporting well-managed licensed premises and protecting the interests of local communities. The Board continues to work constructively with licence holders, responsible authorities, partner agencies, and the Local Licensing Forum to ensure that licensing arrangements within North Lanarkshire remain effective, proportionate, and responsive to local needs. Aligned Priority: • Improve the health and wellbeing of our communities. Ambition statement: 14. Ensure the highest standards of public protection. Consistent • Produced annually, this report provides information on the operation of the Licensing Board for 2025/26, including how the Board has had regard to the licensing objectives and its Statement of Licensing Policy. • The Licensing (Scotland) Act 2005 established five licensing objectives which underpin all licensing decisions made by the Board. These objectives are - preventing crime and disorder, securing public safety, preventing public nuisance, protecting and improving public health, and protecting children and young persons from harm. • Throughout 2025/26, the Board continued to regulate the sale and supply of alcohol in a manner that seeks to balance the legitimate interests of businesses with the need to adhere to these five licensing objectives. Transparent The report notes that: • North Lanarkshire Licensing Board is the statutory body responsible for administering and enforcing the provisions of the Licensing (Scotland) Act 2005 within the North Lanarkshire Council area. • The Board consists of ten elected members of North Lanarkshire Council and operates independently when exercising its quasi-judicial licensing functions. In carrying out its responsibilities, the Board must act in accordance with the Licensing (Scotland) Act 2005, associated regulations, statutory guidance issued by the Scottish Ministers, and the Board's own Statement of Licensing Policy. • The Board remains committed to ensuring that licensing decisions are made fairly, transparently, and consistently, taking account of local circumstances, statutory guidance, and the views of relevant stakeholders and responsible authorities. In context • North Lanarkshire is one of Scotland's largest local authority areas with a diverse range of urban, suburban, and rural communities. The area contains a significant number of licensed premises ranging from public houses, restaurants and hotels to supermarkets, convenience stores, social clubs, and community venues. • The Board plays an important role in promoting safe and well-managed licensed premises while supporting vibrant town centres, local businesses, and community events. In doing so, the Board seeks to balance economic activity with the protection of local communities and the promotion of the licensing objectives. Item 10 Page 107 of 124
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• The Board is responsible for determining a wide range of applications under the Licensing (Scotland) Act 2005, including - premises licensing, provisional premises licences, personal licenses, transfer of licences, variations to licences, extension of licenced hours, occasional licences, premises license review proceedings, and personal licence review proceedings. • At 31 March 2026 there were 704 licensed premises operating within North Lanarkshire together with a significant number of personal licence holders and occasional licence events taking place throughout the year. Balanced The report summarises how the Board has had regard to the five licensing objectives during the year: • Preventing crime and disorder - the Board has continued to work closely with Police Scotland and other responsible authorities to ensure that licensed premises operate in a manner that minimises opportunities for crime, disorder, and antisocial behaviour. In determining applications and review proceedings, the Board considered information provided by Police Scotland regarding the suitability of applicants, compliance histories, and any concerns relating to licensed premises. The Board also considered personal licence review hearings and premise licence review proceedings where appropriate. • Securing public safety - the Board has had regard to public safety considerations when determining applications, including the nature of proposed activities, operating plans, and any representations received from statutory consultees. Particular consideration was given to premises operating late at night, premises hosting entertainment events, and applications seeking significant changes to operating arrangements. • Preventing public nuisance - the Board recognises the importance of balancing commercial activity with the interests of local communities. When considering applications, the Board has regard to matters such as operating hours, noise management, local amenity, and potential impacts on neighbouring properties. The Board’s policy on licenced hours continues to support consistency and transparency in decision- making. • Protecting and improving public health - the Board recognises alcohol-related harm remains a significant public health issue. The Board continues to have regard to information received from NHS Lanarkshire and other agencies when exercising its functions. The Board’s overprovision assessment and wider Statement of Licensing Policy assist in ensuring public health considerations remain an important part of licensing decision-making. • Protecting children and young persons from harm - the protection of children and young persons remains a key priority for the Board. The Board considered applications with regard to proposed arrangements for age verification, access by children and young persons, and measures designed to prevent underage sales of alcohol. The Board continues to support responsible retailing practices and expects licence holders to operate effective age-verification policies, including challenge 25 initiatives, where appropriate. Report title Summary Revenue and benefits update May 2026 This report provides a regular update on the payment performance for the administration and collection of all local taxation in North Lanarkshire in the form of council tax and non-domestic rates. In addition, the service is responsible for administering a number of benefits for the residents of North Lanarkshire (including housing benefits, council tax reduction, Scottish Welfare Fund, Discretionary Housing Payments, free school meals, clothing grants, and blue badges). It provides an update on performance as at 31st March 2026. Aligned Priority: • Improve North Lanarkshire's resource base. Ambition statement: 21. Continue to identify and access opportunities to leverage additional resources to support our ambitions. Item 10 Page 108 of 124
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Consistent • Produced quarterly, this report provides detailed in-year performance figures which can be compared to the same period in previous years. Transparent • The year-to-date performance set out in the report covers a wide range of service activities as well as the amount of funding paid out to help households in need in order to provide a safety net for local people on low incomes. In context • The report includes the latest context within which the service is operating; this is of particular relevance given the aforementioned administration of grants and support payments for low-income households. The report also advises of any new national grants when they are introduced, or will cease, and the qualifying conditions for receipt of such. • Specific context is also provided in relation to Discretionary Housing Payments (DHP) and the Scottish Welfare Fund (SWF), along with grants allocated to the council and paid through these supports. Balanced The report provides a high-level summary of the highlights which shows that: • As at 31 March 2026, 94.46% of council tax due for 2025/26 had been collected. This is on par with the last financial year where 94.52% was collected (0.06 percentage points decrease). • Non-domestic rates collection has shown a slight decrease of 0.14 percentage points from 94.81% last year to 31 March 2025 to 94.67% this year. • The service continues to meet statutory timescales for administering benefits applications and changes of circumstance. The latest performance shows this to be an average of 16 days for new claims and 10 days for changes of circumstances, both lower than the DWP targets of 30 and 16 days respectively. In addition, for 2025/26 to date (as at March 2026): • Blue badges - the council continues to administer the Blue Badge scheme in line with national guidance, assessing eligibility where automatic entitlement does not apply. To date 11,906 applications have been processed, with 9,571 (80.4%) awarded, compared to 89.7% over the same period last year. Although national guidance allows up to 12 weeks for decisions, the council is currently determining applications within 6 weeks. • Clothing grants and free school meal applications - 11,328 clothing grants were administered and paid out (compared to 11,895 at the same point last year), and 10,415 free school meal applications were awarded (slightly higher than the 10,617 awarded last year). • Discretionary Housing Payments - the council continues to manage housing support funding for tenants facing housing-related financial pressures. Total payments for support reached £6.109m as at 31 March 2026, up from £6.100m at the same point in 2024/25. From further funding received for wider housing and homelessness pressures, £0.565m (99.32%) has been paid or committed as at March 2026. • Scottish Welfare Fund - the council continues to manage a £2.760m annual award budget for residents facing financial hardship, with additional funding of £0.425m received in December 2025 - supporting the move to assessing applications at medium priority from January 2026. To date, 24,199 applications were assessed, resulting in 18,413 awards, compared with 25,408 applications and 18,058 awards last year. Taking into account the fully revised budget, including the 2024/25 carry forward, 88% of the total budget has been utilised in the current financial year. Consequently, £0.439m will be carried forward into 2026/27, and the fund will remain at medium priority. Report title Summary Financial monitoring report - council summary (revenue) May 2026 This report updates on the overall financial position for the General Fund Account, Housing Revenue Account, and Adult Health and Social Care. (Note, the Council set its Revenue Budget and Council Tax for 2026/27 and provided a forecast Revenue Budget position for financial years 2026/27 and 2028/29 at the committee meeting in February 2026). Item 10 Page 109 of 124
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Aligned Priority: • Improve North Lanarkshire's resource base. Ambition statement: 21. Continue to identify and access opportunities to leverage additional resources to support our ambitions. 25. Ensure intelligent use of data and information to support fully evidence-based decision making and future planning. Consistent • The report at each financial period end consolidates the budget monitoring position of all council services into one council summary, highlighting and explaining major variances as per the council’s approved Financial Regulations. • The May 2026 report presents the council’s revenue monitoring position for the financial year 2025/26 as at the end of period 12 (i.e. from 1st April 2025 to 27th February 2026). Transparent • The report highlights / explains major variances as per the council’s approved Financial Regulations which require services to remain within their approved budgeting provision, and to report all significant deviations - defined as the higher of £100,000 or 5% - within budget monitoring reports. • Following Committee agreement, this report also provides financial performance information in relation to the council’s Arm’s Length External Organisations (ALEOs) (i.e. North Lanarkshire Properties, Fusion Assets Limited, and Routes to Work Limited). In context • All activities undertaken by the council are subject to risk, and in acknowledging the council’s approved Risk Management Strategy, services manage risks as part of their overall corporate and service planning processes. The May 2026 report states that the current economic climate and pay and non-pay inflation, continuing at historically high levels, are some of the key factors that have the potential to impact on the council’s ability to provide quality services within approved budget levels. Balanced • Where significant deviations are identified, services must provide explanatory commentary, outline the action required to rectify such deviations and, where relevant, highlight any impact on other budget headings. This information is captured by Finance and summarised in the overall council report. • A summary by division for the period ending 27th February 2026 (period 12) is included in an appendix to the report, as is a note of anticipated commitments against reserves, and available general fund balances. Report title Summary Financial monitoring report - council summary (capital) May 2026 This report provides an update on the 2025/26 resources and expenditure for the council's Strategic Capital Investment Programme. The report also shows the 2025/26 projected outturn position and resultant variances. (Note, the Strategic Capital Investment Programme for 2024/25 to 2028/29 was approved by Policy and Strategy Committee in March 2024, with an update reported on March 2025 and March 2026). Aligned Priority: • Improve North Lanarkshire's resource base. Ambition statement: 21. Continue to identify and access opportunities to leverage additional resources to support our ambitions. 25. Ensure intelligent use of data and information to support fully evidence-based decision making and future planning. Consistent • The report at each financial period end consolidates the capital monitoring position of all council services into one council summary. • The May 2026 report summarises the overall council Strategic Capital Investment Programme for 2025/26 (as at period 12) in relation to Item 10 Page 110 of 124
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resources and expenditure and the 2025/26 projected outturn position and resultant variances. Transparent • The report notes that the Strategic Capital Investment Programme 2024/25 to 2028/29 was approved at Policy and Strategy Committee in March 2024, with updates provided in March 2025 and March 2026. It represents the total Community Investment Programme incorporating the General Services Capital Programme and HRA Capital Programmes. • The programme was developed in conjunction with services and led by the Strategic Capital Delivery Group (SCDG) using the principles established by the council’s Capital Strategy. In context • The report states that the General Services Capital Programme (supported by General Services resources) demonstrates to communities that the place making vision for towns remains a priority, and that the approved 5-year capital investment plan supports delivery of The Plan for North Lanarkshire. • The programme includes investment in Town and Community Hubs, the City Deal programme, and external grant funding. In addition, Housing Revenue Account (HRA) resources support several HRA Capital Investment Programmes including the mainstream programme for investment in the council’s existing estate and delivery of the ambition for additional supply through the new build and council buyback programmes. Balanced • The report notes the current financial position in respect of the 2025/26 General Services Capital Programme and the Housing Revenue Account. This reflects the approved budget and subsequent decisions made at the Strategic Capital Delivery Group (SCDG) in accordance with the SCDG terms of reference, and where appropriate by the individual service committees, Finance and Resources Committee, or the Policy and Strategy Committee (as per the Scheme of Administration). • A breakdown of the overall 2025/26 budget by service programme and associated approved budget movements is included in an appendix to the report. • In acknowledging the risks, the report recognises that the capital programme continues to face challenges in relation to the wider economic climate, linked to availability of materials, contractors, and inflationary pressures. These are managed by services and Project Boards associated with specific programme delivery and will continue to be monitored throughout the year in accordance with the SCDG Terms of Reference. Key to RAG status green Performance is on target and/or within acceptable thresholds red Performance does not meet target and is outwith acceptable thresholds blue Performance surpasses the target and exceeds expectations Item 10 Page 111 of 124
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North Lanarkshire Council Report Audit and Scrutiny Panel Does this report require to be approved? ☒ Yes ☐ No Ref RB/GT/RL Date 20/08/26 North Lanarkshire Council Response to Accounts Commission Findings on Cyber Resilience From Rachel Blair, Chief Officer (Legal, Democratic and Strategy) Greg Telfer, Chief Officer (Finance and Technology) Email BlairR@northlan.gov.uk TelferG@northlan.gov.uk Executive Summary This report provides the Audit and Scrutiny Panel with North Lanarkshire Council’s response to the Accounts Commission report arising from the cyber-attack experienced by Comhairle nan Eilean Siar (Western Isles Council). It sets out the key sector learning identified by the Accounts Commission, provides a comparative assessment of North Lanarkshire Council’s current cyber resilience posture, and highlights both areas of good practice and opportunities for further strengthening governance, assurance, and preparedness. The Accounts Commission report reinforces that cyber resilience is a core corporate governance issue, with direct implications for service continuity, financial management, audit assurance, workforce wellbeing, and public trust. While no organisation can eliminate cyber risk, the evidence demonstrates that strong governance, disciplined follow-through of audit recommendations, and sustained investment in people, processes and infrastructure materially reduce impact and recovery time when incidents occur. North Lanarkshire Council has a number of established strengths when assessed against the learning from the Western Isles incident, including a cloud-first strategy, segregated network architecture, immutable backup technologies, mandatory cyber-awareness training, and established arrangements with specialist third-party cyber response providers. The comparative assessment also identifies opportunities to further strengthen governance, assurance, testing and organisational resilience. This report therefore provides the Audit and Scrutiny Panel with assurance regarding the Council's current arrangements and outlines the continuing programme of improvement. Recommendations It is recommended that the Audit and Scrutiny Panel: (1) Acknowledge the key learning from the Accounts Commission report and the comparative assessment of North Lanarkshire Council’s current cyber resilience posture. (2) Acknowledge that cyber resilience, business continuity, and disaster recovery arrangements have been reviewed within the last 12 months and a programme of Item 11 Page 113 of 124
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1. Background 1.1 Cyber risk continues to increase across the public sector due to growing digital dependency, increasing sophistication of cyber-attacks, constrained labour markets for specialist skills, and the ongoing challenge of managing legacy systems alongside modern platforms. The Accounts Commission publication “Cyber-attack affecting operations and services: The 2023/24 audit of Comhairle nan Eilean Siar” is attached at Appendix 1 for information and context. The publication provides important sector learning on cyber resilience, governance, and organisational preparedness following a significant cyber incident affecting a Scottish local authority. 1.2 The Accounts Commission has emphasised that cyber incidents are rarely caused by a single control failure. Instead, they often reflect cumulative weaknesses in governance, preparedness, testing, and resourcing that have been identified previously through audit but not fully addressed. 1.3 In response to the Accounts Commission findings, a comparative analysis has been undertaken to assess North Lanarkshire Council’s current cyber resilience posture against the key themes and learning identified in the report. The outcome of that comparative assessment, including areas of good practice and opportunities for further strengthening, is set out at Appendix 2. 1.4 The Accounts Commission report does not seek to determine whether different technical controls would have prevented the cyber incident. Rather, it examines the effectiveness of governance, oversight, preparedness and organisational resilience work continues to ensure that arrangements align with national guidance and recognised standards; ▪ (3) Acknowledge that all outstanding internal and external audit recommendations relating to IT, cyber security, business continuity and disaster recovery are subject to clear implementation plans and timescales, with progress reported periodically to the Finance and Resources Committee and the Audit and Scrutiny Panel; (4) Acknowledge that roles, responsibilities and accountability for cyber governance, including senior officer ownership and member oversight, will continue to be reviewed to ensure these remain clear, effective and aligned with good governance practice; ▪ (5) Receive assurance that a structured programme of cyber incident response, disaster recovery and business continuity testing is in place and that lessons learned are incorporated into continuous improvement; and (6) Acknowledge that future assurance reporting will include information on IT capacity, specialist cyber capability, staff cyber-awareness training, resilience of critical systems and progress against audit recommendations. The Plan for North Lanarkshire Priority All priorities Ambition statement All ambition statements Programme of Work Statutory / corporate / service requirement Item 11 Page 114 of 124
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before, during and after the incident. As such, the report provides valuable learning for all local authorities regardless of their individual technical environments. 2. Report Governance and Oversight 2.1 Effective cyber resilience requires clear governance arrangements. Sector learning highlights the importance of: • explicit ownership of cyber risk at senior officer level; • defined member scrutiny responsibilities through an appropriate committee; • clarity around organisational risk appetite for digital and cyber risk; and • integration of cyber risk within the corporate risk management framework, rather than treating it solely as an IT matter. 2.2 Where governance is fragmented or risk registers lack specificity, audit recommendations can remain unimplemented and assurance weakened. Recent Accounts Commission findings reinforce that cyber governance failures are often contributory factors in the scale and duration of operational disruption following a cyber incident. Audit Recommendations and Implementation Discipline 2.3 A recurring theme from recent audits across local government is not the absence of recommendations, but delays or slippage in implementation. Good practice includes: • agreed, realistic timescales for each recommendation; • named responsible officers; • regular progress reporting to senior management teams and scrutiny committees; and • escalation where delivery is at risk. 2.4 Overly ambitious or undefined timelines undermine accountability and can create false assurance. Sector experience demonstrates that audit findings left unaddressed over time frequently re-emerge as material weaknesses during cyber incidents. IT Infrastructure and Resilience 2.5 Learning across the sector indicates that: • locally hosted systems and insufficiently segregated backups increase vulnerability; • cyber resilience is strengthened through appropriate use of cloud-based platforms, immutable backups, and tested recovery arrangements; and • infrastructure decisions should be guided by organisational risk appetite and service criticality, not solely cost considerations. 2.6 The Corporate Management Team is responsible for maintaining oversight of the Council's critical systems, recovery priorities and organisational preparedness. The Audit and Scrutiny Panel has an important role in receiving assurance that appropriate governance arrangements are operating effectively. Preparedness, Testing and Business Continuity Item 11 Page 115 of 124
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2.7 Documented plans alone do not provide assurance. Sector experience shows that: • cyber incident response, disaster recovery, and business continuity plans must be formally approved; • plans should be tested regularly using realistic and severe scenarios; • lessons from testing should be documented and acted upon; and • consistency of application across services is essential. 2.8 Failure to test plans at scale can lead to uneven responses across services and avoidable disruption, particularly where incidents exceed the assumptions on which plans were originally based. Staff Capacity, Capability and Wellbeing 2.9 Cyber incidents place sustained pressure on staff well beyond the initial event. Key learning includes: • ensuring adequate IT staffing levels and access to specialist expertise; • maintaining up-to-date cyber-awareness training for all staff, with completion actively monitored; and • recognising and managing staff wellbeing impacts during prolonged recovery periods. 2.10 Capacity gaps during an incident significantly slow recovery, increase operational risk, and place additional strain on staff resilience and morale. Financial, Governance and Audit Assurance 2.11 Cyber incidents can directly impair financial systems and audit trails. The sector experience demonstrates that: • loss of financial records can lead to modified or disclaimed audit opinions; • manual workarounds weaken internal controls and increase error risk; • delayed financial reporting reduces transparency and member oversight; and • rebuilding audit trails is resource-intensive and may take years. 2.12 Strong preventative controls and recovery planning are therefore essential components of financial governance. Conclusion 2.13 Recent Accounts Commission findings reinforce that cyber resilience is a core corporate governance issue rather than a purely technical concern. While it is not possible to eliminate cyber risk, organisations that invest in preparedness, governance clarity, disciplined audit follow-through, and staff capability are better placed to protect services, finances, and public confidence. 2.14 The Corporate Management Team has a critical role in setting expectations, ensuring accountability, and maintaining oversight of cyber risk as an integral part of the Council’s overall risk management and assurance framework. 2.15 The Accounts Commission report reinforces that cyber resilience must be treated as a standing corporate governance issue rather than a purely technical matter. North Item 11 Page 116 of 124
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Lanarkshire Council has a strong foundation in place, with several areas of demonstrable good practice when compared with sector experience. 2.16 The comparative assessment at Appendix 2 demonstrates that, whilst there are opportunities for continuous improvement, there are no matters arising from the Accounts Commission report that indicate a significant weakness in North Lanarkshire Council's current governance arrangements requiring immediate remedial action. 2.17 The role of the Audit and Scrutiny Panel is to provide independent scrutiny of the Council's governance, risk management and internal control arrangements. Consideration of the Accounts Commission findings, together with the Council's comparative assessment and ongoing improvement programme, provides Members with assurance regarding the effectiveness of current governance arrangements whilst supporting continued challenge and continuous improvement. 3. Measures of success 3.1 Progress and effectiveness can be assessed through: • full implementation of agreed IT and cyber-related audit recommendations within approved timescales; • regular, documented testing of cyber incident response, disaster recovery and business continuity plans; • clear reporting on cyber risk, incidents, and preparedness; • demonstrable improvement in backup, recovery, and system resilience metrics; • high and sustained completion rates for staff cyber-awareness training; • periodic review of the corporate cyber risk, including evidence that governance arrangements remain aligned with national guidance and recognised standards; and • positive assurance from internal and external audit on governance, controls, and cyber resilience arrangements. 4. Supporting documentation 4.1 Appendix 1 - Accounts Commission publication “Cyber-attack affecting operations and services: The 2023/24 audit of Comhairle nan Eilean Siar”. 4.2 Appendix 2 - Comparative analysis of North Lanarkshire Council’s current cyber resilience posture against the key themes and learning identified in the report. Rachel Blair Chief Officer (Legal, Democratic and Strategy) Greg Telfer Chief Officer (Finance and Technology) Item 11 Page 117 of 124
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5. Impacts 5.1 Public Sector Equality Duty and Fairer Scotland Duty Does the report contain information that has an impact as a result of the Public Sector Equality Duty and/or Fairer Scotland Duty? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? If Yes, has an assessment been carried out and published on the council’s website? https://www.northlanarkshire.gov.uk/your-community/equalities/equality- and-fairer-scotland-duty-impact-assessments Yes ☐ No ☐ 5.2 Financial impact Does the report contain any financial impacts? Yes ☐ No ☒ If Yes, have all relevant financial impacts been discussed and agreed with Finance? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.3 HR policy impact Does the report contain any HR policy or procedure impacts? Yes ☐ No ☒ If Yes, have all relevant HR impacts been discussed and agreed with People Resources? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.4 Legal impact Does the report contain any legal impacts (such as general legal matters, statutory considerations (including employment law considerations), or new legislation)? Yes ☐ No ☒ If Yes, have all relevant legal impacts been discussed and agreed with Legal, Democratic and Strategy? Yes ☐ No ☐ If Yes, please provide a brief summary of the impact? 5.5 Data protection impact Does the report / project / practice contain or involve the processing of personal data? Yes ☐ No ☒ If Yes, is the processing of this personal data likely to result in a high risk to the data subject? Yes ☐ No ☐ If Yes, has a Data Protection Impact Assessment (DPIA) been carried out and e- mailed to dataprotection@northlan.gov.uk Yes ☐ No ☐ 5.6 Technology / Digital impact Does the report contain information that has an impact on either technology, digital transformation, service redesign / business change processes, data management, or connectivity / broadband / Wi-Fi? Yes ☒ No ☐ Item 11 Page 118 of 124
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If Yes, please provide a brief summary of the impact? It recommends using the IT service portal to capture request information instead of using a separate form. Where the impact identifies a requirement for significant technology change, has an assessment been carried out (or is scheduled to be carried out) by the Enterprise Architecture Governance Group (EAGG)? Yes ☐ No ☐ 5.7 Environmental / Carbon impact Does the report / project / practice contain information that has an impact on any environmental or carbon matters? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.8 Communications impact Does the report contain any information that has an impact on the council’s communications activities? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact? 5.9 Risk impact Is there a risk impact? Yes ☒ No ☐ If Yes, please provide a brief summary of the key risks and potential impacts, highlighting where the risk(s) are assessed and recorded (e.g. Corporate or Service or Project Risk Registers), and how they are managed? Specific questions that gather information on the following will improve the Council’s security posture in terms of corporate information risks. ▪ duration of access, start and end dates ▪ privileged access and sensitive information Cyber risk is identified as a distinct Corporate Risk rather than a subset of information security. 5.10 Armed Forces Covenant Duty Does the report require to take due regard of the Armed Forces Covenant Duty (i.e. does it relate to healthcare, housing, or education services for in-Service or ex- Service personnel, or their families, or widow(er)s)? Yes ☐ No ☒ If Yes, please provide a brief summary of the provision which has been made to ensure there has been appropriate consideration of the particular needs of the Armed Forces community to make sure that they do not face disadvantage compared to other citizens in the provision of public services. 5.11 Children’s rights and wellbeing impact Does the report contain any information regarding any council activity, service delivery, policy, or plan that has an impact on children and young people up to the age of 18, or on a specific group of these? Yes ☐ No ☒ If Yes, please provide a brief summary of the impact and the provision that has been made to ensure there has been appropriate consideration of the relevant Articles from the United Nations Convention on the Rights of the Child (UNCRC). Item 11 Page 119 of 124
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If Yes, has a Children’s Rights and Wellbeing Impact Assessment (CRWIA) been carried out? Yes ☐ No ☐ Item 11 Page 120 of 124
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Appendix 2 North Lanarkshire Council Cyber Security Posture Summary Theme Key Strengths / Current Position Areas for Further Strengthening / Commentary Governance and Risk Management • Cyber risk is identified as a distinct Corporate Risk rather than a subset of information security. A structured approach to the identification of cyber risks is taken, aligned to the NCSC’s 10 Steps To Cyber Security. • Controls, actions, and ownership are recorded within the FigTree corporate risk management system, improving accountability and supporting informed investment decisions. • Cyber security subject to regular audit review and a number of planned improvement actions incorporated into the DigitalNL Programme of Work. • The Data Governance Board has recently completed a deep dive reassessment of cyber, information governance and information security risks to reflect the up-to-date risks and controls. • Ongoing assurance of control suite delivered through compliance with PSN Code of Connection, PCI DSS, and participating in Scottish Government’s annual cyber resiliency assessment. • Ongoing emphasis required to ensure cyber risk remains visible at corporate and elected member level and that mitigation actions progress in line with agreed timescales. • Supply chain risk management being improved through onboarding of Scottish Government’s supplier assurance software. • Security metrics to provide meaningful management insight into security capacity and capability within the Council. • Cyber security standards are being developed. IT Architecture and Protection • Cloud-first strategy reduces reliance on on-premises infrastructure. • Segregation of Corporate and Education networks, with additional segmentation of higher-risk environments. • Least privilege access controls separating standard user profiles and accounts from those requiring more privileged levels of access. • Multi-factor authentication embedded as a baseline access control. • Continued review of network segmentation and access controls is required to reflect evolving threat landscapes and service changes. • Ongoing work required to move existing on-premise infrastructure to cloud-based solutions (alternative controls in place which cloud-based solutions are developed). • Evaluation of use of privileged access workstations to enhance least privilege. • Assessment of a secondary layer of email security tooling to identify potentially malicious emails Item 11 Page 121 of 124
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missed by Microsoft Exchange Online Protection and Defender for M365. Backup and Recovery • Cloud-based and local immutable backup solutions provide protection against ransomware and unauthorised modification. • Core productivity services (Microsoft 365, Teams, SharePoint, Exchange Online) are cloud-hosted and resilient. • Regular testing and assurance of backup restoration processes remain critical to ensure recoverability during extended or complex incidents. • Disaster recovery planning exists but is based on historic assumptions. Further assurance is required that plans remain fit for an organisation of North Lanarkshire Council’s scale and complexity, particularly over extended outage periods. Incident Response and External Support • Cyber Incident Response Plan in place and progressing through formal approval. • Pre-arranged agreement with NCC Group provides specialist support for response and recovery during major incidents. • Formal approval, exercising, and continuous refinement of the incident response plan should remain a priority. Training and Awareness • Mandatory cyber and information security training delivered via LearningNL, with uptake monitored at senior level. • Corporate messaging from the Chief Executive reinforces compliance and cultural expectations. • Ongoing reinforcement and role-specific training may be required to address emerging risks and lessons learned from sector incidents. Audit Recommendation Delivery • Actions and timescales are identified in response to audit recommendations. • Competing priorities may place pressure on delivery; continued focus on realistic timescales, escalation, and member visibility is essential to avoid slippage. Preparedness and Testing • Ad hoc cyber incident exercises undertaken, including a senior- level table-top exercise in February 2025. • Sector learning highlights the need for a structured, recurring programme of cyber incident testing, including severe and prolonged disruption scenarios. Item 11 Page 122 of 124
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• Further assurance is required that plans remain fit for an organisation of North Lanarkshire Council’s size and complexity, particularly for extended outage periods. • Undertaking of red team exercising to support identification of gaps in technical and incident identification and response controls. Capacity and Capability • Dedicated cyber governance and technical capability in place. • Recruitment and retention of cyber-specialist staff remains challenging across the sector; current capacity constrains the pace of assurance, testing, and continuous improvement. Education Estate Coverage • Assurance activity focused on the corporate IT estate. • Further examination of vulnerability management and resilience arrangements within the Education estate is required. Financial Governance and Assurance • Resilient backup technologies, cloud-based systems, and established business continuity arrangements provide mitigation against cyber disruption. • Continued focus on prevention, testing, and recovery assurance is critical to protecting audit trails, statutory reporting, and overall financial governance. • As highlighted above, work ongoing to develop cloud-based solutions for the main financial ledger and Revenues and Benefits system) Item 11 Page 123 of 124
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