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Agenda Document Pack - Audit and Risk Committee - 23/03/2026

Perth and Kinross Council · 23 March 2026
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Ambition | Compassion | Integrity
Our vision is for
a Perth and Kinross where everyone can live life well,
free from poverty and inequality
Council Building
2 High Street
Perth
PH1 5PH
16/03/2026
A hybrid meeting of the Audit and Risk Committee will be held in the Council
Chamber on Monday, 23 March 2026 at 13:00.
If you have any queries please contact Committee Services on (01738) 475000 or
email Committee@pkc.gov.uk.
THOMAS GLEN
Chief Executive
Those attending the meeting are requested to ensure that all notifications are
silent on their device and other devices are in silent mode.
Please note that the meeting will be broadcast online and recorded.  The
recording will be publicly available on the Council’s website following the
meeting.
Members:
Councillor David Illingworth  (Convener)
Councillor Bob Brawn  (Vice-Convener)
Councillor Liz Barrett
Councillor Andy Chan
Councillor Ken Harvey
Councillor Iain MacPherson
Councillor Grant Stewart
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Audit and Risk Committee
Monday, 23 March 2026
AGENDA
MEMBERS ARE REMINDED OF THEIR OBLIGATION TO DECLARE ANY
FINANCIAL OR NON-FINANCIAL INTEREST WHICH THEY MAY HAVE IN ANY
ITEM ON THIS AGENDA IN ACCORDANCE WITH THE COUNCILLORS’ CODE OF
CONDUCT.
1 WELCOME AND APOLOGIES
2 DECLARATIONS OF INTEREST
3 MINUTE OF MEETING OF AUDIT AND RISK COMMITTEE OF 1
DECEMBER 2025 FOR APPROVAL
(copy herewith)
5 - 8
4 PERTH AND KINROSS COUNCIL DRAFT ANNUAL AUDIT PLAN
2025/26
Report by Audit Scotland (copy herewith 26/68)
9 - 30
5 INTERNAL AUDIT UPDATE
Report by Chief Internal Auditor (copy herewith 26/69)
31 - 36
6 INTERNAL AUDIT - 25-09 PETTY CASH
(copy herewith 26/70)
37 - 54
7 INTERNAL AUDIT - 25-05 HOUSING REGULATOR SUBMISSION
(copy herewith 26/71)
55 - 78
8 INTERNAL AUDIT FOLLOW UP
Report by Chief Internal Auditor (copy herewith 26/72)
79 - 82
IT IS RECOMMENDED THAT THE PUBLIC AND PRESS SHOULD BE EXCLUDED
DURING CONSIDERATION OF THE FOLLOWING ITEM(S) IN ORDER TO AVOID
THE DISCLOSURE OF INFORMATION WHICH IS EXEMPT IN TERMS OF
SCHEDULE 7A TO THE LOCAL GOVERNMENT (SCOTLAND) ACT 1973
P1 INTERNAL AUDIT FOLLOW UP - APPENDIX 2 - ACTIONS WITH
A COMPLETION DATE UP TO JANUARY 2026 WHICH HAVE
YET TO BE COMPLETED
• Exempt Reason 15 - The identity of a protected informant.
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DRAFT
Audit and Risk Committee
Minute of hybrid meeting of the Audit and Risk Committee held in the Council
Chambers on Wednesday 1 December 2025 at 1.00pm.
Present: Councillors D Illingworth, B Brawn, A Chan, L Barrett, I MacPherson and G
Stewart.
In Attendance: T Glen, Chief Executive; S Walker, Chief Finance Officer; L Simpson,
Strategic Lead – Legal and Governance; J Clark, K Molley, A Brown and M
Pasternak (all Legal and Governance); S Cooper and S Wilson (Children, Families
and Justice) Z Robertson and S Thomson (Health and Social Care Partnership).
Apology: Councillor K Harvey
Also in Attendance: R Browne and P Bryan (Audit Scotland).
Councillor D Illingworth, Convener, Presiding.
1. Welcome and Apologies/Substitutions
The Convener welcomed everyone to the meeting and gave a special
welcome to Councillor B Brawn as the new Vice-Convener. The Convener also
thanked Councillor C Stewart for his contributions on the committee since 2022.
An apology was noted as above.
2. Declarations of Interest
There were no declarations of interest made in terms of the Councillors’ Code
of Conduct.
3. Minute of Meeting of the Audit and Risk Committee of 17 September
2025 for Approval
The minute of meeting of the Audit and Risk Committee of 17 September
2025 was submitted and approved as a correct record.
4. Outstanding Business Statement
Resolved:
The contents of the Outstanding Business Statement, be noted and it was
agreed to remove the completed actions.
5. Draft 2024/25 Annual Accounts (Audited) Draft 2024/25 Annual Audit
Report
There was submitted a report by Chief Finance Officer (25/330) presenting the
Council’s draft 2024/25 Annual Accounts (Audited) in accordance with the Local
3
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DRAFT
Authority Accounts (Scotland) Regulations 2014 and draft 2024/25 Annual Audit
Report.
R Browne, Audit Scotland, provided a summary of the Audit Scotland’s Draft
2024/25 Annual Audit Report.
The Convener asked the Chief Executive to make a statement about the
inclusion of termination payments. T Glen confirmed he was content with Audit
Scotland’s findings and advised that significant conversations had been held with
colleagues from Audit Scotland over the period. T Glen referred to the recent
instance where a senior post had left the organisation. T Glen confirmed the process
was carried out in line with the governance procedures and the organisation’s
Scheme of Delegation which led to a mutually agreed departure. T Glen added that
verbal updates were provided to the appropriate Elected Members at the time to
advise them of the situation. 
The Vice-Convener queried if the Chief Finance Officer was satisfied that
procedures in place are robust to protect the Council from fraud.  S Walker
confirmed that a lot of work was involved in providing assurance that the correct
measures are in place. Internal controls are scrutinised by Internal Audit and the
organisation’s systems and controls are assessed by Audit Scotland which would be
reported annually to the Audit and Risk Committee. Audit Scotland are in contact
with the Chief Finance Officer and Chief Internal Auditor to see if they have any
concerns. S Walker reassured members that the measures in place are robust as far
as possible to protect the organisation from fraud.
Councillor A Chan queried how exit packages are calculated. L Simpson
confirmed that it would depend on the nature of the exit. If the exit was for
redundancy or voluntary severance, the payment would be set out in terms of
regulations and calculations would be carried out through a formulaic approach. S
Walker added that work would be carried out internally with HR and if appropriate the
Tayside Pension Fund on the process.
Members thanked officers from Audit Scotland for their report 
Members thanked S Walker and his teams for the preparation of the
Accounts. 
Members thanked J Clark for the reassurance from internal audit.
Resolved:
(i) The 2024/25 Audited Annual Accounts, be approved.
(ii) The Leader of the Council, the Chief Executive and the Chief Finance Officer
be authorised to sign the 2024/25 Audited Annual Accounts and the Chief
Finance Officer be authorised to sign the Letter of Representation.
(iii) The contents of Audit Scotland’s Draft 2024/25 Annual Audit Report, be noted.
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DRAFT
6. INTERNAL AUDIT FOLLOW-UP
There was submitted a report by Chief Internal Auditor (25/331) presenting a
summary of Internal Audit’s follow-up work that relate to actions completed up to
September 2025.
Resolved:
The current position in respect of the agreed actions arising from Internal
Audit’s work, be noted.
7. INTERNAL AUDIT UPDATE
There was submitted a report by Chief Internal Auditor (25/332) presenting a
summary of Internal Audit’s work undertaken as part of the Internal Audit Plans for
2024/25 and 2025/26.
Resolved:
The progress with Internal Audit activity, be noted.
8. 24-03 Multi-Agency Screening-Hub (MASH)
There was submitted a report by Chief Internal Auditor (25/333) presenting an
audit undertaken on Multi-Agency Screening Hub (MASH) as part of the Internal
Audit Plan for 2024-25, which was approved by the Audit & Risk Committee on the
24th of June 2024.
Councillor I Macpherson referred to a statement in the report that ‘there were
no limitations identified that would impact the Audit. However, we were not able to
comment on the effectiveness of the arrangements of the partner agencies’ and
queried if this was standard practice across other Local Authorities for similar events.
J Clark confirmed that the process was consistent as internal audit do not look at the
effectiveness from the partner agencies perspective.
The Convener asked the Chief Internal Auditor if she was content that all the
actions she had recommended had been implemented. J Clark advised that she had
not yet asked for evidence for the November dates. S Cooper added that work was
currently being undertaken to update the Memorandum of Understanding and to
improve the administration of sharing information.  S Cooper confirmed that those
actions should be completed by the end of December.
Members thanked J Clark, her team and other relevant officers for their work in
the audit.
Resolved:
The contents of Report 25/333, be noted.
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DRAFT
IT WAS AGREED THAT THE PUBLIC AND PRESS SHOULD BE EXCLUDED
DURING CONSIDERATION OF THE FOLLOWING ITEM IN ORDER TO AVOID
THE DISCLOSURE OF INFORMATION WHICH IS EXEMPT IN TERMS OF
SCHEDULE 7A TO THE LOCAL GOVERNMENT (SCOTLAND) ACT 1973
P1. Internal Audit – Health and Social Care Partnership
There was submitted a report by Chief Internal Auditor (25/335) regarding an
investigation at a Care Home in Perth and Kinross in accordance with the Council’s
Whistleblowing Policy.
Resolved:
The contents of Report 25/335, be noted.
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Perth and Kinross
Council
Annual Audit Plan 2025/26 - Draft 
Prepared for Perth and Kinross Council
March 2026
4
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Perth and Kinross Council Annual Audit Plan | 2 
Contents 
Introduction 3
Audit scope and responsibilities 4
Audit of the annual accounts 6
Wider scope audit 13
Best Value audit 14
Reporting arrangements, timetable and audit fee 16
Other matters 19 
Accessibility
You can find out more and read this report using assistive technology on
our website www.audit.scot/accessibility.
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Introduction | 3 
Introduction 
Purpose of the Annual Audit Plan
1.  The purpose of this Annual Audit Plan is to provide an overview of the
planned scope and timing of the 2025/26 audit of Perth and Kinross
Council’s annual accounts. It outlines the audit work planned to meet the
audit requirements set out in auditing standards and the Code of Audit
Practice, including supplementary guidance. 
Appointed auditor and independence
2.  Rachel Browne, of Audit Scotland, has been appointed by the Accounts
Commission as external auditor of Perth and Kinross Council, hereafter
referred to as ‘the council’, for the period from 2023/24 until 2026/27. The
2025/26 financial year is the third year of Rachel’s four-year audit
appointment. 
3.  Rachel Browne and the audit team are independent of the council in
accordance with relevant ethical requirements, including the Financial
Reporting Council’s Ethical Standard. This standard imposes stringent
rules to ensure the independence and objectivity of auditors. Audit
Scotland has robust arrangements in place to ensure compliance with
ethical standards. The arrangements are overseen by the Executive
Director of Innovation and Quality, who serves as Audit Scotland’s
Ethics Partner.
4.  The Ethical Standard requires auditors to communicate any
relationships that may affect the independence and objectivity of the audit
team. There are no such relationships pertaining to the audit of the council
to communicate.
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Audit scope and responsibilities | 4 
Audit scope and responsibilities 
Scope of the audit 
5.  The audit is performed in accordance with the Code of Audit Practice,
including supplementary guidance, International Standards on Auditing
(UK), and relevant legislation. These set out the requirements for the
scope of the audit which includes: 
• An audit of the financial statements and an opinion on whether they
give a true and fair view and are free from material misstatement. 
• An opinion on statutory other information published with the
financial statements in the annual accounts, namely the
Management Commentary and the Annual Governance Statement.
• An opinion on the audited part of the Remuneration Report. 
• Conclusions on the council's arrangements in relation to the wider
scope areas: Financial Management, Financial Sustainability,
Vision, Leadership, and Governance, and Use of Resources to
Improve Outcomes. 
• Reporting on the council’s arrangements for securing Best Value.
• Providing assurance on the Housing Benefit Subsidy Claim and
Non-Domestic Rates Return.
• A review of the council’s arrangements for preparing and publishing
statutory performance information. 
• Provision of an Annual Audit Report setting out significant matters
identified from the audit of the annual accounts and the wider scope
areas specified in the Code of Audit Practice.
Responsibilities 
6.  The Code of Audit Practice sets out the respective responsibilities of the
council and the auditor. A summary of the key responsibilities is outlined
below. 
Auditor’s responsibilities
7.  The responsibilities of auditors in the public sector are established in
the Local Government (Scotland) Act 1973. These include providing an
independent opinion on the financial statements and other information
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Audit scope and responsibilities | 5 
reported within the annual accounts, and concluding on the council’s
arrangements in place for the wider scope areas. 
Perth and Kinross council’s responsibilities
8.  The council has primary responsibility for ensuring proper financial
stewardship of public funds, compliance with relevant legislation and
establishing effective arrangements for governance, propriety and
regularity that enables it to successfully deliver its objectives. The features
of proper financial stewardship include: 
• Establishing arrangements to ensure the proper conduct of its
affairs. 
• Preparation of annual accounts, comprising financial statements
that give a true and fair view and other information. 
• Establishing arrangements for the prevention and detection of
fraud, error and irregularities, and bribery and corruption. 
• Implementing arrangements to ensure its financial position is
soundly based. 
• Making arrangements to secure Best Value. 
• Establishing an internal audit function.
Communication of fraud or suspected fraud
9.  In line with ISA (UK) 240 (The Auditor’s Responsibilities Relating to
Fraud in an Audit of Financial Statements), in presenting this plan to the
Audit and Risk Committee we seek confirmation from those charged with
governance of any instances of actual, suspected or alleged fraud that
should be brought to our attention. Should members of the committee
have any such knowledge or concerns relating to the risk of fraud within
the council, we invite them to communicate this to the appointed auditor
for consideration. Similar assurances will be sought as part of the audit
completion process.
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Audit of the annual accounts | 6 
Audit of the annual accounts 
Introduction
10.  The audit of the annual accounts is driven by materiality and the risks
of material misstatement in the financial statements, with greater attention
being given to the significant risks of material misstatement. This chapter
outlines materiality, the significant risks of material misstatement that have
been identified, and the impact these have on the planned audit
procedures. 
Materiality
11.  The concept of materiality is applied by auditors in planning and
performing an audit, and in evaluating the effect of any uncorrected
misstatements on the financial statements or other information reported in
the annual accounts. 
12.  The concept of materiality is to determine whether matters identified
during the audit could reasonably be expected to influence the decisions
of users of the financial statements. Auditors set a monetary threshold
when determining materiality, although some issues may be considered
material by their nature. Therefore, materiality is ultimately a matter of the
auditor’s professional judgement.
13.  The materiality levels determined for the audit of the council and its
group are outlined in Exhibit 1.
Exhibit 1
2025/26 Materiality levels for Perth and Kinross Council and its group 
Materiality Council  Group
Materiality – based on an assessment of the needs of
users of the financial statements and the nature of the
council operations, the benchmark used to determine
materiality is gross expenditure based on the audited
2024/25 financial statements. Materiality has been set at
2% of the benchmark.
£15.2 million £15.4 million
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Audit of the annual accounts | 7 
Materiality Council  Group
Performance materiality – this acts as a trigger point. If
the aggregate of misstatements identified during the audit
exceeds performance materiality, this could indicate that
further audit procedures are required. Using professional
judgement, performance materiality has been set at 60% of
planning materiality.
£9.1 million  £9.2 million
Reporting threshold – all misstatements greater than the
reporting threshold will be reported. 
£0.5 million £0.5 million
Source: Audit Scotland
Significant risks of material misstatement to the financial
statements
14.  The risk assessment process draws on the audit team’s cumulative
knowledge of the council, including the nature of its operations and its
significant transaction streams, the system of internal control, governance
arrangements and processes, and developments that could impact on its
financial reporting. 
15.  Based on the risk assessment process, significant risks of material
misstatement to the financial statements have been identified and these
are summarised in Exhibit 2. These are the risks which have the greatest
impact on the planned audit approach, and the planned audit procedures
in response to the risks are outlined in Exhibit 2. 
16.  The risk assessment process is an iterative and dynamic process. The
assessment of risks set out in this Annual Audit Plan and Exhibit 2 may
change as more information and evidence is obtained over the course of
the audit. Where such changes occur, these will be reported to the council
and those charged with governance, where relevant. This may include
risks arising from the shared risk assessment process where scrutiny
bodies meet to share intelligence and agree scrutiny risks at councils. 
17.  The Local Area Network meeting for the council is scheduled to take
place on 16 March 2026. Any risks arising from this meeting which impact
upon our planned audit approach, or shared scrutiny activity which may be
deemed necessary, will be reported to the council and those charged with
governance as appropriate.
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Audit of the annual accounts | 8 
Exhibit 2
Significant risks of material misstatement to the financial statements 
Risk of material misstatement  Planned audit response
Fraud caused by management
override of controls 
Management is in a unique position to
perpetrate fraud because of
management’s ability to override
controls that otherwise appear to be
operating effectively.
The audit team will:
• Evaluate the design and implementation of
controls over journal entry processing.
• Make inquiries of individuals involved in the
financial reporting process about inappropriate
or unusual activity relating to the processing of
journal entries.
• Use data analytics to consider, identify, and test
journal entries, focusing on those that are
assessed as higher risk, such as those affecting
revenue and expenditure recognition around the
year-end. 
• Evaluate significant transactions outside the
normal course of business.
• Assess the adequacy of controls in place for
identifying and disclosing related party
relationships and transactions in the financial
statements. 
• Assess changes to the methods and underlying
assumptions used to prepare accounting
estimates and assess these for evidence of
management bias.
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Audit of the annual accounts | 9 
Risk of material misstatement  Planned audit response
Valuation of property, plant and
equipment
The council held £1.6 billion of property,
plant and equipment (PPE) at 31 March
2025, of which £746 million was other
land and buildings (OLB) assets. 
The council is required to value land
and building assets at existing use value
where an active market exists for these
assets. Where there is no active market,
these assets are valued on a
depreciated replacement cost (DRC)
basis. As a result, there is a significant
degree of subjectivity in these
valuations which are based on specialist
assumptions, and changes in the
assumptions can result in material
changes to valuations.
Also new for 2025/26, CIPFA/LASAAC
has updated the Code of Practice to
reflect HM Treasury’s reforms to public-
sector asset valuations. Under the
revised approach, local authorities will
now move to quinquennial (five-yearly)
full valuations, with annual indexation
applied in the intervening years to
ensure asset values remain materially
accurate. There is an increased risk of
material misstatement due to greater
reliance on management judgement and
estimation, particularly in selecting
appropriate indices and determining
when additional valuations are
necessary in between formal valuations. 
The audit team will: 
• Evaluate the design and implementation of
controls over the valuation process. 
• Review the information provided to the valuers
and assess this for completeness and accuracy.
• Evaluate the competence, capabilities and
objectivity of the valuers.
• Obtain an understanding of management’s
involvement in the valuation process to assess if
appropriate oversight has occurred.
• Review the reconciliation between the accounts,
property asset register and valuers’ reports.
• Test a sample of OLB assets subject to
revaluation in 2025/26, confirm to valuers’
reports, critically assess the appropriateness of
key data and assumptions and challenge these
where required.
• Review the indices applied by management to
assets not subject to valuation in 2025/26 and
assess if these are reasonable and have been
applied correctly.
Source: Audit Scotland
Key audit matters 
18.  The Code of Audit Practice requires public sector auditors to
communicate key audit matters. Key audit matters are those matters, that
in the auditor’s professional judgement, are of most significance to the
audit of the financial statements and require most attention when
performing the audit. 
19.  In determining key audit matters, auditors consider:
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Audit of the annual accounts | 10 
• Areas of higher or significant risk of material misstatement. 
• Areas where significant judgement is required, including accounting
estimates that are subject to a high degree of estimation
uncertainty. 
• Significant events or transactions that occurred during the year.
20.  The matters determined to be key audit matters will be communicated
in the Annual Audit Report. Exhibit 2 outlines the significant risks of
material misstatement to the financial statements that have been
identified. 
21.  In addition to these risks, the following matter has been identified as
an area where significant judgement is required. Focused audit work will
be undertaken as set out below and will be reported on in the Annual Audit
Report. 
• Estimation in the valuation of pension assets and liabilities –
these valuations are based on a range of assumptions including life
expectancy, CPI growth and discounting (based on corporate bond
rates). Small changes in these assumptions can result in a material
change to the valuations. We will assess the scope, independence
and competence of the professional actuaries engaged to provide
these estimates and review the appropriateness of the actuarial
assumptions and results including comparison with other councils.
We will also establish officers’ arrangements for ensuring the
reasonableness of the professional estimates and the accuracy of
the information provided to the council by the actuary.
Group audit 
22.  The council is part of a group and prepares group financial
statements. The group is made up of ten components, including the
council which is the parent of the group. Risk assessment procedures
have been performed on the group audit to identify if there are any risks of
material misstatement to the group financial statements, or any
components where audit procedures are required for the purposes of the
group audit. The outcome of the risk assessment procedures on the group
audit are outlined in Exhibit 3.
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Audit of the annual accounts | 11 
Exhibit 3
Outcome of risk assessment procedures on the group audit 
Group
component 
Accounting
treatment
Risk of material
misstatement 
Audit
procedures
required
Auditor 
Perth and
Kinross Council 
Parent body –
Consolidated on
a line-by-line
basis
Yes – Exhibit 2 Yes – full scope
audit
Audit Scotland
Common Good
Funds
Consolidated on
a line-by-line
basis
No – not material
to the group
financial
statements
Yes – analytical
procedures at
group level
Audit Scotland
Charitable
Trusts
Consolidated on
a line-by-line
basis
No – not material
to the group
financial
statements
Yes – analytical
procedures at
group level
Audit Scotland
Live Active
Leisure Ltd
Consolidated on
a line-by-line
basis
No – not material
to the group
financial
statements
Yes – analytical
procedures at
group level
Azets
Culture Perth
and Kinross
Consolidated on
a line-by-line
basis
No – not material
to the group
financial
statements
Yes – analytical
procedures at
group level
Azets
Perth Theatre
and Concert Hall
(Horsecross Arts
Ltd)
Consolidated on
a line-by-line
basis
No – not material
to the group
financial
statements
Yes – analytical
procedures at
group level
Henderson
Loggie LLP
Tayside
Contracts Joint
Committee
Accounted for
on equity basis
No – not material
to the group
financial
statements
Yes – analytical
procedures at
group level
Audit Scotland
Tayside
Valuation Joint
Board
Accounted for
on equity basis
No – not material
to the group
financial
statements
Yes – analytical
procedures at
group level
Audit Scotland
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Audit of the annual accounts | 12 
Group
component 
Accounting
treatment
Risk of material
misstatement 
Audit
procedures
required
Auditor 
Perth and
Kinross
Integration Joint
Board
Accounted for
on equity basis
No – not material
to the group
financial
statements
Yes – analytical
procedures at
group level
Audit Scotland
Tayside and
Central Scotland
Partnership
(Tactran)
Not consolidated
on grounds of
materiality
N/A N/A Audit Scotland
Source: Audit Scotland
23.  Where audit procedures are required on a component’s financial
statements, and the component auditor is different to Perth and Kinross
Council’s appointed auditor, group audit instructions will be issued to the
component auditor outlining expectations and requirements in performing
these audit procedures.
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Wider scope audit | 13 
Wider scope audit 
Introduction
24.  Reflecting the fact that public money is involved, the Code of Audit
Practice requires that public audit is planned and undertaken from a wider
perspective than in the private sector. The wider scope audit set out by the
Code of Audit Practice broadens the audit of the annual accounts to
include consideration of additional aspects or risks in four wider scope
areas, which are summarised below: 
• Financial Management – this means having sound budgetary
processes. Factors that can impact on the council being able to
secure sound financial management include the strength of the
financial management culture, accountability, and arrangements to
prevent and detect fraud, error and other irregularities, bribery and
corruption. 
• Financial Sustainability – this means looking forward over the
medium and longer term in planning the services to be delivered
and how they will be delivered effectively. This is assessed by
considering the council’s medium to longer-term planning for
service delivery. 
• Vision, Leadership and Governance – this means having a clear
vision and strategy, with set priorities within the vision and strategy.
This is assessed by considering the clarity of plans in place to
deliver the vision and strategy and the effectiveness of the
governance arrangements to support delivery.
• Use of Resources to Improve Outcomes – this means using
resources to meet stated outcomes and improvement objectives
through effective planning and working with partners and
communities. This is assessed by considering the council’s
arrangements for ensuring resources are deployed to improve
strategic outcomes, meet the needs of service users, and deliver
continuous improvement.
25.  Our planning work has not identified any significant risks in the wider
scope areas.
26.  A conclusion on the effectiveness and appropriateness of
arrangements the council has in place for each of the wider scope areas
will be reported in the Annual Audit Report.  
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Best Value audit | 14 
Best Value audit 
Introduction
27.  Under the Code of Audit Practice, the audit of Best Value in councils is
fully integrated within the annual audit. As part of the annual audit, auditors
are required to take a risk-based approach to assessing and reporting on
whether the council has made proper arrangements for securing Best
Value, including follow up of findings previously reported in relation to
Best Value.
Best Value Thematic review 4: Asset Management
28.  The Accounts Commission also reports nationally on thematic aspects
of councils’ approaches to, and performance in, meeting their Best Value
duties. As part of the annual audit, thematic reviews, as directed by the
Accounts Commission, are conducted on the council. The thematic review
for 2025/26 is on the subject of asset management and involves
considering how the council is managing its assets to ensure high quality
services whilst also responding to the challenges around financial
sustainability and climate change. Conclusions and judgements on the
thematic review will be reported in a separate Management Report and
summarised in the Annual Audit Report.
Controller of Audit Report
29.  At least once over the five-year appointment, the Controller of Audit
will report to the Accounts Commission on the council’s performance in
meeting its Best Value duties. The third year of this programme runs from
October 2025 to August 2026. The council is not included in the third year
of the programme. 
Statutory Performance Information / LGBF
30.  Auditors have a statutory duty to satisfy themselves that councils have
made proper arrangements for preparing and publishing statutory
performance information in accordance with the Statutory Performance
Information Direction 2024 (the Direction) issued by the Accounts
Commission. The outcome of this will be reported in the Annual Audit
Report, which will include: 
• A conclusion on the council’s arrangements for preparing and
publishing the statutory performance information. 
• Any instances where the arrangements or reporting are not in
accordance with the Direction. 
• Areas where the arrangements require to be improved. 
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Best Value audit | 15 
31.  In addition, the Accounts Commission requires auditors to include a
summary of Local Government Benchmarking Framework (LGBF)
indicators that the council has reported in the Annual Audit Report.
Fairness and equality
32.  There is an expectation that equalities will be advanced through the
audit process, and auditors should carry out work on the Fairness and
Equality Best Value theme at least once during the five-year audit
appointment. We will assess the fairness and equalities arrangements in
place at the council and report our conclusions in our 2025/26 Annual
Audit Report.
Significant Best Value risks
33.  No significant Best Value risks were identified from the risk
assessment process. Audit work on the wider scope areas will help
support conclusions around Best Value.
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Reporting arrangements, timetable and audit fee | 16 
Reporting arrangements,
timetable and audit fee 
Audit outputs
34.  The outputs from the 2025/26 audit include: 
• This Annual Audit Plan.
• An Independent Auditor’s Report to the council and the Accounts
Commission setting out opinions on the annual accounts.  
• An Annual Audit Report to Perth and Kinross Council and the
Accounts Commission setting out significant matters identified from
the audit of the annual accounts, conclusions from the wider scope
and Best Value audit, recommendations, where required, and any
good practice identified. 
35.  The matters to be reported in the outputs will be discussed with the
council for factual accuracy before they are issued. All outputs from the
audit will be published on Audit Scotland’s website, apart from the
Independent Auditor’s Report, which is included in the audited annual
accounts.  
36.  Target dates for the audit outputs are set by the Accounts
Commission. In setting the target dates for the audit outputs, consideration
is given to the statutory date for approving the annual accounts, which is
30 September 2026 for local government bodies.  
37.  The audit team will be unable to achieve the target date of 30
September 2026 for issuing the Independent Auditor’s Report and Annual
Audit Report. This is due to prioritising the quality of our audit work over
meeting target dates, as required by the Accounts Commission, and
consistent with messaging from the Financial Reporting Council which has
made clear that audit quality takes precedence. The audit team are
working towards completion of the audit by the Audit and Risk Committee
meeting date of 30 November 2026 and are working towards delivering
the audit by target dates over the course of the five-year audit
appointment. 
Audit timetable
38.  Achieving the timetable for production of the annual accounts,
supported by complete and accurate working papers, is critical to delivery
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Reporting arrangements, timetable and audit fee | 17 
of the audit to agreed target dates. Exhibit 4 includes a timetable for the
audit, which has been agreed with management. Agreed target dates will
be kept under review as the audit progresses, and any changes required,
and their potential impact, will be discussed with the council and reported
to those charged with governance, where required. 
Exhibit 4
2025/26 audit timetable 
Audit activity
Council target
date
Audit team
target date
Audit and Risk
Committee date
Issue of Annual Audit Plan N/A 2 March 2026 23 March 2026
Annual Accounts:   
• Consideration of unaudited
annual accounts by those
charged with governance
29 June 2026 N/A  29 June 2026
• Submission of unaudited
annual accounts and all
working papers to audit team
30 June 2026 N/A N/A
• Latest date for audit clearance
meeting
26 October 2026 26 October 2026 N/A
• Issue of draft Letter of
Representation, proposed
Independent Auditor’s Report,
and proposed Annual Audit
Report
N/A 09 November
2026
30 November
2026
• Agreement of audited and
unsigned annual accounts
09 November
2026
09 November
2026
N/A
• Approval by those charged
with governance and signing
of audited annual accounts 
30 November
2026
N/A 30 November
2026
• Signing of Independent
Auditor’s Report and issue of
Annual Audit Report 
N/A 30 November
2026
N/A
Issue of Best Value
Management Report
N/A 31 August 2026 21 September
2026
Certification of Non-Domestic
Rates Return 
N/A 31 October 2026 N/A
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Reporting arrangements, timetable and audit fee | 18 
Audit activity
Council target
date
Audit team
target date
Audit and Risk
Committee date
Certification of Housing Benefit
Subsidy Claim
N/A 30 November
2026
N/A
Source: Audit Scotland
Audit fee
39.  The council’s audit fee is determined in line with Audit Scotland’s fee
setting arrangements. The proposed audit fee for the 2025/26 audit is
£372,000 (2024/25 £358,370).
40.  In setting the audit fee, it is assumed that the council has effective
governance arrangements in place and the complete annual accounts will
be provided for audit in line with the agreed timetable. The audit fee
assumes there will be no significant changes to the planned scope of the
audit. Where the audit cannot proceed as planned, for example, due to
incomplete or inadequate working papers, the audit fee may need to be
increased.
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Other matters | 19 
Other matters 
Internal audit
41.  The council is responsible for establishing an internal audit function as
part of an effective system of internal control. As part of the audit, the audit
team will obtain an understanding of internal audit, including its nature,
responsibilities, and activities. 
42.  While internal audit and external audit have differing roles and
responsibilities, external auditors may seek to rely on the work of internal
audit where it is considered appropriate. A review of internal audit’s
2025/26 audit plan was carried out to identify if there were any areas
where the audit team could rely on its work. The audit team concluded it
will not rely on internal audit’s work. However, the audit team will review
internal audit's reports and assess if there is any impact on the audit.
Audit quality 
43.  Audit Scotland is committed to the consistent delivery of high-quality
audit. Audit quality requires ongoing attention and improvement to keep
pace with external and internal changes. Details of the arrangements in
place for the delivery of high-quality audits is available from the Audit
Scotland website.
44.  The International Standards on Quality Management (ISQM)
applicable to Audit Scotland for 2025/26 audits are:
• ISQM (UK) 1, which deals with an audit organisation’s
responsibilities to design, implement, and operate a system of
quality management (SoQM) for audits. Audit Scotland’s SoQM
consists of a variety of components, such as governance
arrangements and culture to support audit quality, compliance with
ethical requirements, ensuring Audit Scotland is dedicated to high-
quality audit through engagement performance and resourcing
arrangements, and ensuring there are robust quality monitoring
arrangements in place. Audit Scotland carries out an annual
evaluation of its SoQM and has concluded it complies with this
standard. 
• ISQM (UK) 2, which sets out arrangements for conducting
engagement quality reviews, which are performed by senior
management not involved in an audit, to review significant
judgements and conclusions reached by the audit team, and the
appropriateness of proposed audit opinions on high-risk audits. 
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Other matters | 20 
45.  To monitor quality at an individual audit level, Audit Scotland carries
out internal quality reviews on a sample of audits. Additionally, the Institute
of Chartered Accountants of England and Wales (ICAEW) carries out
independent quality reviews on a sample of audits.
46.  Actions to address deficiencies identified by internal and external
quality reviews are included in a rolling Quality Improvement Action Plan,
which is used to support continuous improvement. Progress with
implementing planned actions is monitored on a regular basis by Audit
Scotland’s Quality and Ethics Committee.
47.  Audit Scotland may periodically seek the views of the council on the
quality of audit services provided. The audit team would also welcome
feedback at any time.
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Perth and Kinross Council
Annual Audit Plan 2025/26 - Draft 
Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN
Phone: 0131 625 1500  
www.audit.scot 
AS.5.0
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Page 30

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Page 31

Our vision is a Perth and Kinross where everyone can live life well,
free from poverty and inequality
___________________________________________________________________
Committee or Board: Audit & Risk Committee
Date of Meeting: 23 March 2026
Report Title: Internal Audit Update
Report Number: 26/69
Report Author: Jackie Clark, Chief Internal Auditor
Organisational Lead: Strategic Lead – Legal and Governance
1 Purpose
1.1 The purpose of this Report is to present a summary of Internal Audit’s work
undertaken as part of the Internal Audit Plans for 2024/25 and 2025/26.
1.2 Sections
1. Purpose
2. Recommendations
3. Background/Context
4. Progress Update
5. Outcome from Consultancy Work
6. Conclusion
7. Impact Value Assessment
8. Appendices
2 Recommendation
It is recommended that the Committee:
2.1 notes progress with Internal Audit activity.
3 Background/Context
3.1 The Global Internal Audit Standards in the UK Public Sector (GIAS (UKPS))
and the Code of Practice for the Governance of Internal Audit in UK Local
Government require that the Audit Committee should receive regular
engagement reporting for internal audit activity and on performance relative to
the approved plan.
5
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3.2 Work has continued on assignments from Perth & Kinross Council’s Internal
Audit Plans. In addition, work has continued to be undertaken in connection
with the Internal Audit provision for Perth & Kinross’ Integration Joint Board.
3.3 Internal Audit continues to support Services to investigate matches for the
National Fraud Initiative in line with the timeline as laid down by Audit
Scotland. This exercise is near completion and a report detailing the
outcomes for Perth & Kinross Council will be prepared for consideration at the
next meeting of the Audit & Risk Committee.
4 Progress Update
4.1 Appendix 1 shows the status of audits arising from the Internal Audit Plans.
4.2 Internal Audit continues to undertake a range of unplanned and responsive
work in addition to the planned programme. This includes pieces of
consultancy and advisory support requested directly by services, reflecting the
team’s role not only in providing assurance but also in adding value and
supporting improvement across the organisation. Where any significant
control matters are identified through this unplanned or consultancy activity,
these will be reported to the Audit & Risk Committee.
4.3 Internal Audit has also been commissioned by Housing & Communities to
complete an assurance and advisory assignment in relation to the
arrangements for disposal of 4 chalets at Double Dykes Gypsy Travellers
Site. The objective was to provide reassurance that there have been no
breach of legislation or any actions that have resulted in poor practice, and I
have been pleased to be able to provide that reassurance.
4.4 Internal Audit has discussed A25-12 Asset Management with external audit
colleagues. This will be the focus of Audit Scotland’s thematic work in 2026.
Due to the timing of this and the significant overlap in the scope of both
assignments, and the fact that this is part of a wider programme of work for
External Audit, it is proposed that Internal Audit do not complete their
assignment. This will ensure that there is no duplication of audit effort and will
ensure that the Service is not stretched in responding to two sets of auditors
for a broadly similar purpose
5 Proposals 
5.1 Not applicable.
6 Conclusion
6.1 Not applicable.
7 Impact Value Assessment
7.1 This report has been classified as being an operational report and as such
does not require a full Impact and Value Assessment. 
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8 Appendices
8.1 Appendix 1 – Internal Audit Activity
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Page 34

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Page 35

Appendix 1
INTERNAL AUDIT UPDATE
Internal Audit Activity
Audit
No.
Title Lead Service(s) Status as at
October
2025
Audit
Committee
2024/25
A24-04 Affordable Housing Housing &
Communities
Draft report June 2026
2025/26
C25-01 Strategic Partnering –
Education & Learning
Education &
Learning
Ongoing June 2026
C25-02 Strategic Partnering –
Environment &
Infrastructure
Environment &
Infrastructure
Ongoing June 2026
A25-03 External Funding Multiple Services Ongoing June 2026
A25-04 Health & Safety Strategic Planning,
People &
Performance
Ongoing June 2026
A25-05 Housing Regulator
Submission
Housing &
Communities
Completed March 2026
A25-06 Risk Maturity Strategic Planning,
People &
Performance
June 2026
A25-07 Insurance Finance & Business
Support
Ongoing June 2026
A25-08 Administration of a
social care
establishment
Adult Social Work Completed December
2025
A25-09 Petty Cash All Services Completed March 2026
A25-10 Payroll Strategic Planning,
People &
Performance
Ongoing June 2026
A25-11 Assessment &
Charging
Finance & Business
Support
June 2026
A25-12 Asset Management Finance & Business
Support
Recommended for
deletion from planned
work
5
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Page 37

Internal Audit Report
All Services
PK 25-09 Petty Cash
March 2026
Final Report
(Report No. 26/70)
Legal and Governance
Strategy, People & Resources
Perth & Kinross Council
Council Offices
2 High Street
Perth
PH1 5PH
6
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25-09 Petty Cash
Contents by Section
1. Introduction
2. Executive Summary
3. Audit Background Information
4. Scope and Limitations
5. Assessment of the Control Environment
6. Summary of Findings
7. Conclusions
8. Acknowledgement
9. Action Implementation & Follow Up
10. Management Action Plan
11. Authorisation
12. Distribution
13. Assessment Definitions
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1. Introduction
1.1 The audit of 25-09 Petty Cash was undertaken as part of the Internal Audit
Plan for 2025-2026, which was approved by the Audit & Performance
Committee in June 2025. The period under review for the purposes of the
audit exercise was financial years 2024-2025 and 2025-2026.
1.2 The indicative scope for the audit was to review the appropriate use and
arrangement of Petty Cash within PKC.
1.3 The audit is not directly linked to any particular risk on the Strategic Risk
Register. Internal Audit team would like to acknowledge that the requirement
for the Petty Cash review was highlighted from a separate audit review,
performed prior to this, and as a result some of the related findings are
transferred to this Audit report.
2. Executive Summary
2.1 The audit has found that Limited Assurance can be placed on the Council’s
internal controls in relation to the Petty Cash arrangements currently in place.
2.2 There are 12 actions arising from the findings in Section 6. An action plan is
included at Section 10. Once these actions are completed, Internal Audit
should be able to place substantial assurance on the arrangements in place.
3. Audit Background Information
3.1 The strategy for Internal Audit is to deliver a risk based Internal Audit service
by designing planned activity around the key risks to the Petty Cash
Management and Operational Controls.
3.2 The Local Government (Scotland) Act 1973 requires the Council to have
proper arrangements in place for the administration of its financial affairs.
Cash management is a crucial aspect of financial regulations for local
councils. Cash is easy to lose or misappropriate. As such, Petty Cash and
cash operations are an area of risk, and therefore assurance is necessary that
adequate controls are present and effective.
3.3 Petty Cash advances may be used for making small payments or as a change
float. Purchases made through petty cash are restricted, in line with guidance
provided by the Chief Finance Officer. The administration, compliance and
control over Petty Cash is outlined in the Council’s Financial Regulations and
Petty Cash Procedure.
3.4 Responsibility for the administration of petty cash reimbursements was
transferred to the Customer Services Centre (CSC) in September 2024. Prior
to that, these operations were actioned by the Revenue & Benefits Team;
however, it is important to note that responsibility for the overall process
responsibilities still lay within Finance & Business Support.
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3.5 CSC team float manages all Council’s cash payment requests and serves as
a replenishment float for subsequent smaller Petty Cash Floats within the
establishments and teams in the Council. We would like to add that Criminal
justice does not fall under CSC team and has it’s own G4S service.
The Petty Cash float based in Pullar House is the largest and is independently
reconciled by a financial officer through the PKC financial systems, Integra. It
reimburses its remuneration amount with Secure G4S delivery service. The
rest of the Petty Cash floats, due to their lower value and the lack of access to
use Financial Control Systems, follow the cash collection procedure for
secure storage.
3.6 CSC Team petty cash float is additionally used as a cash request service
desk for the needs covering all services across the council, such as providing
funds for HSCP services under Section 12 and Section 22, under the Health
and Social Care Act, allowing to access client funds; DWP funds where PKC
is the appointee; child protection team funds and many more.
3.7 During 2025/26 financial year we noted a total of 48 Petty Cash active floats
with a total value of approximately £32,000. In the timeframe of the audit, 3 of
those floats are being phased out. During the audit review float holders have
identified that the use of the float is not required and creates additional
administrative tasks, cash not required and cash use being slowly phased out,
especially as a result of the COVID-19 pandemic, cash use has been
reduced.
3.8 We would like to highlight, that as the review of the petty cash Audit
progressed, there has been an incident of theft reported of one of the floats,
with an Imprest limit of £120, within the HSCP, which was therefore added as
part of the testing sample for further investigation.
4. Scope and Limitations
4.1 There were no limitations identified that would impact the Audit.  However, we
will not duplicate testing already undertaken in connection with other audit
work (namely Administration of a Social Care establishment).
4.2 The validation of the operational process was against the published Perth and
Kinross Financial Regulations (2024-27) and Petty Cash procedure (2014). All
relevant staff were interviewed, and a review of documentary evidence was
undertaken.
4.3 Total samples of 6 Petty Cash floats represent 12.5% of the PK Councils
active floats. Internal Audit Team covered services such as HSCP, Children
and Families, Finance and Youth and Employability Teams. The sample
selection was aimed to represent variety of floats with large, medium, and
small values.
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4.4 The details of the control objectives reviewed and Internal Audit’s assessment
of their strength of control in each area is contained within Section 5 of this
report.
5. Assessment of the Control Environment
5.1 The table below contains a summary of the findings against each control
objective and Internal Audit’s assessment of the adequacy and effectiveness
of the controls in place to meet each of the objectives agreed for this audit.
Further details, including any improvement actions, are set out in the
Management Action Plan in Section 10.
Action RatingNo. Control Objective
5 4 3 2 1
Control
Objective
Assessment
1 To ensure that there is a robust Petty
Cash Reimbursement process and
controls are in place to minimise the risk
of Petty Cash mismanagement.
2 1 Reasonable
Assurance
2 To review the adequate reconciliation of
all petty cash across all the services.
3 1 Limited
Assurance
3 To review the general controls, process
and procedures are in place for Petty
cash
2 3 Limited
Assurance
5.2 The auditor has assessed that limited assurance can be placed on controls
overall in relation to 25-09 Petty Cash from the audit. Meaning:
‘Significant gaps, weaknesses or non-compliance were identified.
Improvement is required to the system of governance, risk management and
control to effectively manage risks to the achievement of objectives in the
area audited”.
5.3 A summary of the key findings and actions are provided in section 6, please
note however, the following areas of good practice which have been
highlighted during the audit:
5.3.1 Since transferring the Petty Cash/ Cash Operations to the newly appointed
cash office team (CSC Team), this has improved the daily operations within
the petty cash/ cash office tasks. We have observed new electronic recording
sheets, cross checking with each PC transaction. Documents for each
transaction are shared on EDMS site, accessible within the team. There are
spreadsheets for cash records and daily monitoring for each transaction.
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5.3.2 Improved, however not yet fully implemented, PC financial systems
traceability process has been observed in the work of CSC Team. One of
these improvements is having a log list for the cash operations team, where
each designated officer, uses their own access for processing cash requests
from Pullar House.
5.3.3 CSC Team have taken the initiative and are currently taking the lead to
streamline the process since it has been transferred from the Revenues &
Benefits Team to the service and resulted in appointing meetings with finance
officers.
5.3.4 During the audit we have witnessed effective communication within the CSC
Team and the rest of the Petty Cash/ Cash float users. The CSC Team
responded quickly to all incoming enquiries, providing valuable advice and
support.
5.3.5 As a result of the changes, an updated draft of a new Petty Cash request form
has been created for wider service approval. This would simplify petty
cash/cash requests across the council and reduce the variety of Petty Cash
request formats that come to the CSC Team centre.
6. Summary of Findings
6.1 Below is a summary of key findings and actions, which are reflected in the
Management Action Plan, detailed in section 10.
6.2 Controls are in place to assure robust Petty Cash Reimbursement
process and minimise the risk of Petty Cash mismanagement.
6.2.1 The Financial Regulations stipulates the general controls relevant to the use
and management of a petty cash float. The Petty Cash Procedure supports
these. The audit examined whether the staff involved with cash/ petty cash
followed the outlined procedure; whether the council had sufficient controls in
place to provide the safeguarding of the cash should the float be stolen or no
longer needed, and is there continuous training
6.2.2 The current published Petty Cash Procedures were written in 2014. It was
noted this version did not reflect the recent changes in Pullar House, which is
now actioned by the Customer Services Centre Team and not the Revenues
Section, Housing & Community Care.
6.2.3 During our review, we requested the Petty Cash Operating Procedures
followed by each service to confirm consistency with Council requirements.
There were three areas that had their own related versions of Petty Cash
Procedures on the intranet which detracts from the centralised and consistent
approach across all services.
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6.2.4 In the current Cash/PC Procedure it is referred to as petty cash usage and
reimbursement. The same is applicable for establishments which hold Petty
Cash floats and have established limits. However, no clear reference was
made for processing on Cash requests for the CSC Team in Pullar House
office, instead the procedure referred to Petty cash expenses. Therefore, we
found that cash withdrawals, although validated with budget holder approval,
were not always supported by receipts confirming the expenditure. The audit
team acknowledges the fact, that on some occasions receipts are not
available, based on type of transaction. However, follow up action on receipts
was inconsistent.
[Action Point 1]
6.2.5 Reimbursement for petty cash is initiated by submitting a template form. This
form includes an authorisation section requiring approvals from both the
budget holder and the payment support assistant. However, we have
identified that the reimbursement process lacks standardisation. The
approvals are inconsistently documented. They vary from typed names and
forward emails from budget holders to inserted signatures within the Word
document.
[Action Point 2]
6.2.6 There have been a variety of forms identified that have been used to request
cash/ petty cash reimbursement. Although, there is one approved template
attached to the procedure, we have identified an additional four types of form
used for a variety of requests. To ensure consistency and compliance with
established procedures, it would be recommended to use one approved
cash/petty cash reimbursement template across all Services. All other
versions of cash request forms should be discontinued.
[Action Point 3]
6.2.7 During the audit of petty cash reimbursements, two floats within the HSCP
Service were evaluated by the auditor. Our observations confirm that although
approved by the budget holder, where possible, some of the cash and petty
cash requests had been administered without adequate checks. Additionally,
there is no central point of contact for managing the requests within the
HSCP, which contributes to a lack of accountability and consistency in the
process.
6.3 Controls are in place to assure the adequate reconciliation of all petty
cash done across all the services.
6.3.1 According to the PKC Financial Regulations, regular reconciliation for cash
balances should be performed and recorded. During the audit process, we
could not identify consistent information nor a template form that is used
across all the 48 floats.
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3 out of 6 Imprest Floats (CSC Team, and Children and Families and one
HSCP service) presented recorded evidence of using a template, where the
form was clearly signed and dated, although reconciliation was not done
regularly. The other 3 holders were not aware of specific form (2 x HSCP,
Children and Families- Youth and Employability), although the staff were
aware that reconciliation checks should be performed, guidelines were not
available. It is advisable that all required forms according to the PC procedure,
to be attached as Appendix for consistent and convenient use.
[Action Point 4]
6.3.2 As part of the verification process on the Imprest/ Float account holders, we
requested a list of all floats within PKC for year end of 2024/2025. It was
noted that the paperwork supporting the balance in Pullar House newly
inherited CSC Team float was submitted in July 2025 instead of 31/3/25
accounting year end in April 2025. Additionally, there was a discrepancy (of
£100) between the total amount of the of Imprest from the Accounts list and
the amount submitted on the form.
[Action Point 05]
6.3.3 According to Financial Regulations 10.3, each petty cash float must have an
assigned account holder. However, a consolidated list of all floats and their
respective account holders was not available but provided in separate emails.
The names of two Imprest floats did not match the Imprest received by the
Accounts team (CSC & Youth Employability float). While some floats were
listed individually with responsible officers, others were grouped together
(e.g., Children and Families, HSCP), and a few included multiple names or
lacked a designated account holder entirely.
[Action Point 06]
6.3.4 During the audit, we have reviewed the need of the Petty Cash Floats. We
have identified that 4 Teams no longer use Petty Cash and have enquired to
close the cash. The note for closing the account was highlighted during the
final accounts process at year-end in April 2025, however no steps have been
taken yet to support the action. Using the available Standard Operating
Procedure, Audit team could not identify such instruction.
[Action Point 7]
6.4 Controls are in place to assure processes and procedures are in place
for Petty cash, including budget monitoring.
6.4.1 The CSC Team in Pullar House is responsible for verifying authorisations and
ensuring that approved ledger codes are used for the claims. However, they
do not review the underlying reasons for cash withdrawals.
Additionally, in HSCP floats ledger codes are being entered by a clerical
assistant and approved by the budget holder. The possible budget
overspends, and misallocation of funds was checked at a later stage during
revenue monitoring, and not at the time of payment of expenses.
However, the value of the Petty Cash floats is not material and there is no
requirement to be included at that stage.
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6.4.2 In our review, we acknowledge the fact that the Financial System used in P&
K Council, controls the authorisation limits database and it is a manged
process. The limit is set per management level and not type of expenditure.
6.4.3 Petty Cash/ cash reimbursement was transferred to the new team in
September 2024. As part of every change and process implementation,
individual training is essential. Meanwhile, we could not see evidence of any
training records providing assurance on understanding and following financial
procedures for the CSC team during the transition. Additionally, there is no
evidence on training for new starts on these financial Operations.
[Action Point 8]
6.4.4 As part of the Petty Cash Procedure ‘Services should ensure independent
checks are carried out on petty cash records on an ad hoc basis to ensure
appropriate controls are being adhered to’. There was no clear awareness on
what controls and checks are referred to, nor that those checks are still
adhered to. There was no clear awareness on what controls and checks are
referred to, nor that those checks are still adhered to.
[Action Point 9]
6.4.5 During the testing process, firstly we identified 1 out of 58 vouchers on the PC
Float, where the receipt was dated November’24 then reimbursed in June’ 25,
5 more dated from April ’25 and reimbursed in June. According to the PC
Procedure ‘No retrospective payments, etc, will be made for the previous year
once the Petty Cash books have been closed’. There is no clear time frame for
claiming reimbursement of receipts within the Petty Cash Procedure.
Additionally, the year-end requirements were not followed.
[Action Point 10]
6.4.6 Secondly, one of the 58 reviewed items was approved based on an invalid
receipt, which consisted only of a screenshot showing an online basket total.
The purchase included items that are not permitted under petty cash
procedures and should have been processed via a credit card transaction
instead. Similar identification was seen in HSCP float transactions, where
majority of cash payments could have been progressed through usual PECOS
purchasing.
[Action Point 11]
6.4.7 The auditor examined 30 receipts in one of the Children and Families petty
cash floats. Of these, 21 were paid using personal cards and 9 were paid in
cash. As per the given Children and Families PC procedure ‘Use of personal
cash, debit, or credit cards in anticipation of retrospective authorisation is not
permitted’. This indicates a procedural gap that should be addressed in the
PKC Petty Cash Procedure to ensure compliance and clarity.
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6.4.8 During the audit, an incident involving theft of a petty cash float. The fact that
cash has gone missing (float with Imprest limit of £120), highlights a
weakness in the current cash handling and security arrangements. As part of
the audit testing, we found that 2 of the petty cash float holders were not
following the outlined guidelines for secure key storage.
Immediate improvements are required to strengthen safeguarding measures,
enhance accountability, and ensure compliance with financial procedures to
prevent recurrence. Security of cash is at risk.
[Action Point 12]
6.4.9 Secure cash storage arrangements are outlined in the existing Petty Cash
Procedure. However, this procedure was originally written in 2014, when PKC
operated under more traditional working arrangements, including closed office
spaces. Since 2024/2025, and particularly following the COVID-19 pandemic,
PKC has adopted flexible working practices, including hot-desking and open-
plan office layouts. As a result, teams responsible for managing petty cash
floats are now situated in open workspaces, which introduces increased risks
related to cash storage and accountability. There is an increased need of
Process review, and the Audit team wants to emphasize the need of reduction
of the Petty Cash floats where possible.
7. Conclusion
7.1 The Internal Audit review is able to place Limited Assurance on the overall
control environment for the Internal Petty Cash/ Cash operations. The agreed
actions, once implemented, should enable Internal Audit to place Substantial
assurance on these.
8. Acknowledgements
8.1 Internal Audit would like to thank all officers who were involved in this audit:
Liz Colledge, Service Centre Manager, Customer Service Centre
Alison O’Brien, Manager CDS - Accountancy
Shona Welsh, Finance & Governance Team Leader
Alison Stewart, Finance Administrator, Finance & Governance
Jamie Ridgway, Senior Incomes Officer
Craig Robertson, Central Services Manager, CDS – Accountancy
Claire Palmer, Finance and Governance Service Manager
Lorraine Kelly, Business & Management Officer, Finance & Business Support
Almondbank House
Kathryn Devine, Youth Employability Co-ordinator
Lorna Davage, Team Leader, HSCP - Mental Health
Elaine Mudie, Finance Officer, Children and Families - Finance & Governance
Bunjan Phimjaras, Payment Support Assistant
Hazel Rylance, Supply Payment Support Assistant
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9. Action Implementation & Follow up
9.1 Responsibility for the maintenance of adequate and effective controls rests
with management. Where the audit has identified areas for management
action, these are identified in the Management Action Plan. Where a decision
is taken by management not to act in response to finding from this review, it is
the responsibility of management to assess and accept the risk arising from
non-implementation.
9.2 Achievement of the agreed actions is monitored through Internal Audit’s
‘follow up’ arrangements
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10. Management Action Plan 
Acti
on
Poin
t
Para.
No Finding Risk
Rating Agreed Action & Evidence Action Owner
Target
Completion
Date
1. 6.2.2
6.2.3
6.2.4
The current published PKC Petty
Cash and Cash request Procedure
were written in 2014:
It was noted this version did not
reflect the recent changes in Pullar
House Encashment office, which is
now actioned by the Customer
Services Centre Team and not the
Revenues Section, Housing &
Community Care.
There were three areas that had
their own related versions of the
Petty Cash Procedures on the
intranet which that detracts from
the centralised and consistent
approach across all services.
Follow up action on receipts was
inconsistent.
3 Agreed action:
 New procedures to
be prepared
 once completed
these additional
versions will be
removed.
Agreed evidence:
1. New procedures
2. If there is
supplementary
guidance it will be
identified as such.
J. Jennings
Senior Accountant
March 2026
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2. 6.2.5 We have identified that the
reimbursement process lacks
standardisation. The approvals are
inconsistently documented. They
vary from typed names and
forward emails from budget
holders to inserted signatures
within the Word document.
3 Agreed action:
New procedures to be
prepared
Agreed evidence:
New procedures
L. Colledge,
Service Centre
Manager
J. Jennings
Senior Accountant
 March
2026
3. 6.2.6 To ensure consistency and
compliance with established
procedures, it would be
recommended to use one
approved cash/petty cash
reimbursement template across all
Services. All other versions of cash
request forms should be
discontinued.
1 Agreed action:
New procedures to be
prepared.  There will be
separate forms for petty
cash float reimbursement
and a petty cash payment.
Agreed evidence:
All forms will be on integra
and reports can be pulled
to ensure that these match
any outlays. 
J. Jennings
Senior Accountant
March 2026
4. 6.3.1 According to the PKC Financial
Regulations, regular reconciliation
for cash balances should be
performed and recorded. During
the audit process, we could not
identify consistent information nor
a template form that is used across
all the 48 floats.
3 Agreed action:
New procedures to be
prepared
Agreed evidence:
New procedures
J. Jennings
Senior Accountant
March 2026
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5. 6.3.2 As part of the verification process
on the Imprest/ Float account
holders, we requested a list of all
floats within PKC for year end of
2024/2025. It was noted that the
paperwork supporting the balance
in Pullar House newly inherited
CSC Team float was submitted in
July 2025 instead of
31/3/25accounting year end in
April 2025. Additionally, there was
a discrepancy (of £100) between
the total amount of the of Imprest
from the Accounts list and the
amount submitted on the form.
2 Agreed action:
An annual list will be
agreed as part of the
schedules returned during
the Final Accounts
process.
The year end guidance
states that return must be
submitted in April each
year.
Agreed evidence:
Annual List
Schedules returned in line
with year end guidelines
C Robertson,
Central Accounting
J Ridgway
Senior Incomes
Officer
June 2026
6. 6.3.3 The names of two Imprest floats
did not match the Imprest received
by the Accounts team (CSC &
Youth Employability float). While
some floats were listed individually
with responsible officers, others
were grouped together (e.g.,
Children and Families and
Children’s Services, HSCP), and a
few included multiple names or
lacked a designated account
holder entirely.
3 Agreed action:
Finance Business Partners
will ensure there is a
designated person
recorded on the forms for
each float at Final
Accounts.   This will be
added to the updated
procedures.
Agreed evidence:
C. Robertson,
C. France,
C. Palmer
Finance Business
Partners
M. Grant
J. Jennings
Senior Accountant
June 2026
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Updated guidance and
Imprest final accounts
returns forms.
7. 6.3.4 During the audit, we have reviewed
the need of the Petty Cash Floats.
We have identified that 4 Teams no
longer use Petty Cash and have
enquired to close the cash. The
note for closing the account was
highlighted during the final
accounts process at year-end in
April 2025, however no steps have
been taken yet to support the
action. Using the available
Standard Operation Procedure,
Audit team could not identify such
instruction.
3 Agreed action:
New procedures to be
prepared with such
addition.
Agreed evidence:
New procedures
J. Jennings
Senior Accountant
March 2026
8. 6.4.3 Petty Cash/ cash reimbursement
was transferred to the new team in
September 2024. As part of every
change and process
implementation, individual training
is essential. Meanwhile, we could
not see evidence of any training
records providing assurance on
understanding and following
financial procedures for the CSC
team during the transition.
Additionally, there is no evidence
3 Agreed action:
Once new form launched
and policy and procedure
agreed, training will be
carried out.  
Agreed evidence:
Confirmation from staff
member that they have
read, understood and
L. Colledge
Service Centre
Manager
April 2026
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on training for new starts on PKC
financial Operations.
agreed that sufficient
training has been
undertaken, and a log kept
of this.
9. 6.4.4 As part of the PK Petty Cash
Procedure ‘Services should ensure
independent checks are carried out
on petty cash records on an ad hoc
basis to ensure appropriate
controls are being adhered to’.
There was no clear awareness on
what controls and checks are
referred to, nor that those checks
are still adhered to.
3 Agreed action:
New procedures to be
prepared
Eform process will fill this
need
No requirement to check
on ad hoc basis this will be
removed from the
guidelines
Agreed evidence:
New procedures
J. Jennings
Senior Accountant
March 2026
10. 6.4.5 According to the PC Procedure ‘No
retrospective payments, etc, will be
made for the previous year once
the Petty Cash books have been
closed’. There is no clear time
frame for claiming reimbursement
of receipts within the Petty Cash
Procedure. Additionally, the year-
end requirements were not
respected.
3 Agreed action:
New procedures to be
prepared
Agreed evidence:
New procedures
J. Jennings
Senior Accountant
March 2026
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11. 6.4.6 The purchase included items that
are not permitted under petty cash
procedures and should have been
processed via a credit card
transaction instead. Similar
identification was seen in HSCP
float transactions, where majority
of cash payments could have been
progressed through usual PECOS
purchasing.
4 Agreed action:
New procedures will make
this clear that it is the
Budget Holders
responsibility to purchase
through the appropriate
route.
Eform will allow Finance to
identify issues and raise
this with Budget Holders.
Agreed evidence:
New procedures
J. Jennings
Senior Accountant
March 2026
12. 6.4.8 The fact that cash has gone
missing (float with Imprest limit of
£120), highlights a weakness in the
current cash handling and security
arrangements. As part of the audit
testing, we found that 2 of the petty
cash float holders were not
following the outlined guidelines for
secure key storage.
4 Agreed action:
Updated guidance will be
completed and will be
circulated to Budget
Holders
Agreed evidence:
Email to budget holders
J. Jennings
Senior Accountant
(Updated Guidance)
C. France
C. Palmer
C. Robertson
M. Grant
Finance Business
Partners
March 2026
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Page 54

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Page 55

Internal Audit Report
Housing & Communities
25-05 Housing Regulator Submission
March 2026
Final Report
(Report No. 26/71)
Legal and Governance
Perth & Kinross Council
Council Offices
2 High Street
Perth
PH1 5PH
7
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25-05 Housing Regulator Submission
Contents by Section
1. Introduction
2. Audit Background Information
3. Scope and Limitations
4. Assessment of the Control Environment
5. Summary of Findings
6. Conclusions
7. Acknowledgement
8. Action Implementation & Follow Up
9. Management Action Plan
10. Authorisation
11. Distribution
12. Assessment Definitions
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1. Introduction
1.1 The audit of the Housing Regulator Submission was undertaken as part of the
Internal Audit Plan for 2025/26, which was approved by the Audit and Risk
Committee on 25 June 2025. The period under review for the purposes of the
audit exercise was the financial year 2024-25. 
1.2 The indicative scope for the audit was to review arrangements for the
compilation of the annual submissions to the Housing Regulator.
1.3 The audit is not directly linked to any particular risk on the Strategic Risk
Register, however, forms the basis for external assurance provider, which
may be relied on by Internal Audit as part of planning, in accordance with the
Global Internal Audit Standards in the UK Public Sector.
2. Executive Summary 
2.1 The audit has found that Substantial Assurance can be placed on the
Council’s internal controls in relation to the review for the compilation of the
annual submissions to the Housing Regulator by the Council, with no
improvement actions arising from the Internal Audit (Objectives 1 and 2
below). Areas of good practice have been highlighted within Section 5 of this
report.
2.2 Whilst reviewing the arrangements for the compilation of the annual
submission, Internal Audit reviewed in detail the content of the Submission
(Objective 3 below). We found that the Service were aware of these and were
taking actions to address the issues, where possible. These findings are
captured in Section 6 and an action plan in Section 10 includes the actions
which are on-going to address the issues raised. As a result of this part of the
audit, there are ten actions arising. These actions are designed to enhance
performance as reported in the Submission.
3. Audit Background Information
3.1 The Scottish Housing Regulator (SHR) was established on 01 April 2011 in
accordance with the Housing (Scotland) Act 2010. Its objective is to protect
and promote the interests of tenants and other service users of Local
Authorities and Registered Social Landlords (RSLs).
3.2 The Regulatory Framework states that each landlord is responsible for
delivering good outcomes and services for its tenants and service users.
Landlords need to be self-aware, analytical, open and honest about their
performance, and identify and drive improvement.
3.3 Section 2.4 of the Regulatory Framework requires landlords to prepare and
publish an Annual Assurance Statement. This statement serves to confirm to
both tenants and the Scottish Housing Regulator that the landlord is meeting
the relevant regulatory requirements applicable to Local Authorities and
Registered Social Landlords (RSLs).
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3.4 In accordance with section 2.9 of the Framework, the main risks that they
consider are:
 poor outcomes for tenants, people who are homeless and other service
users
 poor quality or safety of tenants’ homes
3.5 Further, the Regulatory Framework advises that landlords should consider
how best to utilise Internal Audit as a source of independent assurance when
preparing their Annual Assurance Statements. This includes providing
assurance on compliance with regulatory requirements, such as the
Standards of Governance and Financial Management applicable to
Registered Social Landlords (RSLs).
3.6 According to section 4.2 the statement should be completed and agreed by
the governing body or local authority committee. It is mentioned that the
governing body or committee should confirm that they have appropriate
assurance that they comply with:
 all relevant regulatory requirements set out in Chapter 3 of the
Regulatory Framework
 all relevant standards and outcomes in the Scottish Social Housing
Charter
 all relevant legislative duties
 the Standards of Governance and Financial Management (RSLs only)
 any specific assurance requirements asked landlords to cover in their
Statement.
4. Scope and Limitations
4.1 The Audit has reviewed the relevant standards and outcomes in the Scottish
Social Housing Charter and identified the arrangements for the compilation of
the annual submissions to the Housing Regulator (HR).
4.2 To arrive at an opinion on the achievement of the control objective, the review
included,
 Document reviews concerning Housing Regulator submission
 Interviews with key staff who are responsible for the various indicators
 Reviewing of any third-party documents and arrangements with relevant
performance indicators
 Ensuring lessons learned from previous non-compliance are incorporated
into future planning.
4.3 There were no limitations identified that would impact the Audit.
4.4 The details of the control objectives reviewed and the Internal Audit’s
assessment of their strength of control in each area are contained within
Section 5 of this report.
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5. Assessment of the Control Environment
5.1 The table below contains a summary of the findings against each control
objective and Internal Audit’s assessment of the adequacy and effectiveness
of the controls in place to meet each of the objectives agreed for this audit.
Further details, including any improvement actions, are set out in the
Management Action Plan.
Action RatingNo. Control Objective
5 4 3 2 1
Control
Objective
Assessment
1 To ensure appropriate evidence
has been gathered to support
the level of assurance.
Substantial
Assurance
2 To assess whether the
conclusion arrived at is
appropriate based on the
evidence available and satisfies
the governance requirement.
Substantial
Assurance
3 To ensure all relevant standards
and outcomes in the Scottish
Social Housing Charter and
legislative duties have been
achieved.
7 2 1 Reasonable
Assurance
5.2 The auditor has assessed that Substantial Assurance can be placed on
controls overall in relation to the arrangements for the compilation of the
annual submissions to the Housing Regulator. Meaning:
“A sound system of governance, risk management and control exists, with
internal controls operating effectively and being consistently applied to
support the achievement of objectives in the area audited”.
5.3 A summary of the key findings and actions is provided in section 6. Please
note, however, the following areas of good practice which have been
highlighted during the audit:
5.3.1 The submission of Annual Assurance Statements commenced in 2018/19,
and over the past six years, there has been a consistent demonstration of
commitment and the delegation to ensure timely submission. Cross functional
teams worked together for the compilation of the Annual Assurance
Statement for the 2024/25 and to meet the 31 October 2025 deadline.
5.3.2 There are certain delegated authorities have been appointed to oversee all
aspects related to the housing regulator submission and delivery of the
different services to the tenants. Service performance is reported regularly to
the Housing Management Team, Communities Senior Management Team
and Executive Leadership Team.
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5.3.3 According to the Scottish Housing Regulator website 8,226 homes are owned
by Perth and Kinross council as of 31 March 2025. The total rent due to this
landlord reported for the year 2024/25 was £32,978,973.
It further mentioned that the PKC increased its weekly rent on average
by 6.0% from the previous year but it is still below the Scottish average weekly
rents.
5.3.4 Our observations confirm that appropriate measures have been implemented
to ensure all the houses achieve the Gas Servicing Compliance requirements
2024/25 year. We commend the Housing Compliance Team for their
dedication and performance in achieving this target and encourage the
continued application of the Gas Servicing Quality Assurance Framework.
5.3.5 Our review indicates that PKC remains committed to delivering home
adaptations, with 404 completed during 2024/25. Notably, the number of
households waiting for adaptations was reduced from 45 to 32. While the
average completion time has slightly decreased, it remains better than the
Scottish average. The efficient use of resources has also led to a significant
reduction in total expenditure. The dedication of the Property - Housing
Capital Projects and New Builds team, in collaboration with the Occupational
Therapist, is commendable in achieving these outcomes.
5.3.6 It has been noticed that PKC charges the lowest factoring fee of £20
compared with the Scottish Average and other Registered Social Landlords.
Currently, there are 116 owners across multi-storey and other blocks who are
subject to this fee. Satisfaction with factoring services has increased over the
year, reflecting strong performance in delivering good value for money
(outcome 13), communication (outcome 2) and participation (outcome 3) in
line with the Scottish Social Housing Charter.
5.3.7 According to Social Housing Allocation Guidelines, in allocating housing,
social housing landlords need to balance a range of factors such as, the
individual's housing need, the suitability of the house for that applicant and the
needs of the community. In April 2025, PKC revised the Common Allocation
Policy (CAP) to better identify the priority tenants in response to housing
pressure. We appreciate the steps taken to implement Perth and Kinross
Common Housing Register (CHR), a computer-based, single waiting list
shared by PKC, Caledonia Housing Association, Hillcrest Homes and
Kingdom Housing Association. This system uses Group Plus Points System to
ensure fair and consistent allocations, in alignment with relevant housing
legislation and the Scottish Social Housing Charter.
5.3.8 The preparation of Assurance Statements requires the collection and input of
various data into the Scottish Housing Regulator’s system. This process has
been effectively coordinated by a designated officer who possesses
comprehensive knowledge across all relevant areas. The officer has provided
consistent support to the Team Leader, ensuring that all necessary evidence
has been appropriately gathered. The resulting Assurance Statement
addresses all key indicators in accordance with the requirements of the
Regulatory Framework.
5.3.9 In our observation, the Assurance Statement was prepared well in advance,
with all supporting documentation clearly itemised in a separate annexe. The
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assurance provided is consistent with the evidence presented, which has
been reviewed and found satisfactory by the Internal Audit.
5.3.10We observed that appropriate governance arrangements were in place for the
submission to the Scottish Housing Regulator. This was evidenced by
participation in the Housing and Social Wellbeing Committee meeting held on
01 October 2025. During this meeting, the Assurance Statement along with
the relevant appendices was formally approved for submission to the
Regulator. This approval aligns with the Framework’s requirements and was
granted by the Committee on the same day.
5.3.11As internal audit we agree with the conclusion derived in the Assurance
Statement which states that “during 2024/25 Perth and Kinross Housing
Service complied with all except one regulatory requirement as set out in
Chapter 3 of the Scottish Housing Regulator's Framework.” Also, we are
satisfied with the explanation provided in relation to the recognised non-
compliance.
5.3.12During 2024/25, Perth and Kinross Council reported non-compliance in
relation to the management of Gypsy/Traveller sites. The details of this non-
compliance have been outlined in our findings. However, the Assurance
Statement clearly highlights the steps taken to address the issue, including
the provision of quarterly updates to the Scottish Housing Regulator. We
acknowledge and commend the ongoing efforts made throughout the year to
achieve and maintain full compliance in the management of Gypsy/Traveller
sites.
6. Summary of Findings
6.1 Below is a summary of key findings and actions, which are reflected in the
Management Action Plan, detailed in section 10. 
6.2 The assurance process was conducted effectively, and sufficient evidence
was gathered to support the expressed opinion.
6.3 As part of the audit, whilst testing was undertaken for the third control
objective, as detailed in Section 5 above, Internal Audit has identified areas
where additional controls could be beneficial particularly in relation to certain
national key performance indicators.
6.4 Our observation confirm that the Customer Satisfaction Survey was
conducted by an independent, third-party organisation, Knowledge
Partnership, using a representative sample to assess overall tenant
satisfaction. Key areas evaluated included keep tenants informed,
opportunities to participate, housing quality, repairs, neighbourhood
management and rent value. During 2024/25 most of these indicators showed
a decline compared to the previous year and indicating a downward trend in
tenant satisfaction.
[Action point 01]
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6.5 Regarding the complaint handling, all the complaints are received via email or
telephone and are recorded in Firmstep (Case Viewer), before being
downloaded to Excel for verification. Housing-related complaints are manually
identified, sorted, and documented as a part of this process. Although
discussions have taken place regarding the implementation of a complaint’s
dashboard, it should be noted that the dashboard was not fully operational
during the 2024/25 reporting period and therefore was not utilised for the
Housing Regulator submission.
[Action point 02]
6.6 The review of documents and discussions with the Corporate Complaints
Team Leader revealed an increase in Stage 2 complaints rising from 60 to 80
from 2023/24 to 2024/25. Stage 2 Complaints means if the complainant is
dissatisfied with the Stage 1 outcome or if the issue remains unresolved, the
complaint is escalated to Stage 2. Additionally, more serious complaints may
be classified directly as Stage 2. These are typically resolved within 20
working days. It was noted that 9 of the 80 complaints received during the
year were carried forward to 25/26 financial year and resolved fully. Actions
have already been implemented in this area; therefore, no further actions are
currently required.
6.7 The audit has identified that a substantial amount of information in relation to
the social housing is publicly available in the PKC website. This includes the
access to applications, common allocation policy and clarifications addressing
misconceptions regarding the allocation process. However, it was noticed that
certain information on the website is outdated. For instance, the update
provided for the Common Housing Register Waiting List is dated 13
September 2021 which may lead to confusion or misinformed expectations
among applicants.
[Action point 03]
6.8 According to the Scottish Housing Quality Standards (SHQS), social landlords
must ensure that their tenants’ homes:
 energy efficient, safe and secure,
 not seriously damaged
 have kitchen and bathrooms that are in good condition.
Landlords are expected to maintain these standards unless otherwise they
prevent by social or technical reason from completing improvements required
by SHQS. It is mentioned that in general, SHQS should be achieved rather
than avoided.
6.9 From our observation, we found that there are 1662 houses which do not
pass this minimum SHQS in 2024/25; from these, 123 houses are in
abeyance (refers to the situation where planned work cannot be completed
due to social reasons such as tenant behaviour), and 417 houses are under
exemption (due to technical or economic reasons).
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1082 houses have fully failed to meet the standards. Specifically, 999 houses
failed on one criterion, while 83 houses failed on two or more criterion. The
most common failures notified were roof structure and common floor/parts
failures. For the year 2024/25 SHQS pass rate is 80.28%, reflecting an
improvement from the previous year pass rate of 76.32%. It is noted that the
Council will not achieve 100% conformance in this area, due to reasons such
as tenant preference, the type of housing stock etc, and that the Council’s
performance is above the local authority average; the Service continues to
progress towards achieving the maximum compliance rate possible.
[Action point 04]
6.10 The Energy Efficiency Standard for Social Housing (EESSH) was introduced
to improve the energy efficiency of social housing in Scotland, with the aim of
reducing energy consumption, fuel poverty and greenhouse gas emissions.
As part of our review, it was identified that a significant number of properties
failed to meet EESSH requirements. Specifically, 1055 properties did not
comply with the standard in 2024/25; 451 of these properties are under
exemption (due to technical or economic reasons) or an abeyance (tenant
issues, for example, opting out of the improvements required or not allowing
access).
[Action point 05]
6.11 The status of the Energy Performance Certificate (EPC) of PKC Housing
Stock as of 31 March 2025 has been observed as follows.
Following the introduction of the Energy Team, the number of properties without
an EPC has significantly decreased from 919 to 198. As of 31 March 2025,
there were 210 properties with Energy Performance Certificates (EPC) rated in
Bands E and F, comprising 170 properties in Band E and 40 in Band F.
6.12 As per the updated figures as of 30 June 2025, we noted that there are 185
properties without Energy Performance Certificate (EPC) and 874 out of date
which require attention from the Housing Capital Projects & New Builds team
in Property Services. It is appreciated that these figures can be impacted by
lack of access provided to carry out the EPC surveys.
[Action point 06]
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6.13 Currently, there are multiple software solutions used by the Council to support
various aspects of housing management operations. The primary asset
database utilised by the Housing Capital Projects & New Builds Team is the
“Houses” Database, which is operated by BACRA. This system underpins
reporting requirements for both ARC (Annual Return on the Charter) and
SHQS (Scottish Housing Quality Standards). The Housing Service employs
the NEC Housing Management System to effectively manage and maintain a
range of functions including Housing Advice, Homelessness, Allocations,
Tenancies, Rents, Arrears, Customer Services, Planned Maintenance, and
Housing Online. Additionally, the Housing Repairs Service utilises the Total
Mobile (Total Connect) system for job management, scheduling, and mobile
delivery.
6.14 Whilst it is appreciated that the current reports and quality assurance
processes for the compilation of the submission to the Scottish Housing
Regulator ensure that the information is accurate, there is scope for
considering some improvement.  The audit identified the Council does not
maintain a centralised asset database accessible across all departments. For
instance, the “Houses” database is not integrated with other systems such as
NEC and Total Mobile.
[Action point 07]
6.15 Regarding the indicator Anti-social behaviour cases resolved, it was noted
that there is a 13.77% (From 91.37% to 79.60%) reduction from previous year
of resolving them within the agreed time.
[Action point 08]
6.16 We have observed positive progress in rent collection, accompanied by a
significant reduction in gross rent arrears. However, it has been identified that
there is currently no utilisation of advanced technologies to proactively detect
potential rent arrears at the tenant level. Several other councils have
successfully implemented predictive analytics to identify early indicators of
financial distress among tenants and this may be a route for PKC to consider. 
[Action point 09]
6.17 During the audit, we observed that concerns were raised in relation to the
safety, standards, communication and human rights concerns at
Gypsy/Travellers site by the Scottish Housing Regulator published on 21
March 2025. In the Double Dykes site, PKC failed to meet the minimum
standard for Essential Fabric Standards (Standard 1), Safety and Security
(Standard 4), Maintenance and Repairs (Standard 5), Fair Treatment
(Standard 6) and Consultation (Standard 7). In the Bobbin Mill site, PKC failed
to meet the Essential Fabric Standards (Standard 1), Energy Efficiency
(Standard 2), Safety and Security (Standard 4) and Consultation (Standard 7).
6.18 The Housing Regulator mentioned both Gypsy/Travellers sites are failing to
meet several Social Housing Charter Outcomes such as Equalities (outcome
1), Communication (outcome 2), Participation (outcome 3), Repairs,
maintenance and improvement (outcome 5), Gypsy/Travellers (outcome 16).
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There is an ongoing replacement of the chalets and general upgrades in both
sites. However, on the completion day of this audit, the Comprehensive
Satisfaction Survey has not been carried out.
[Action point 10]
6.19 The latest Stock Condition Survey was carried out in June 2021 and covered
30% of the housing stock at that time. As per Regulator guidance, the next
scheduled Survey is to be held before June 2026 and this was also due to
cover 30% of different houses for SHQS compliance, as per the Annual return
submitted. Since the Annual Return was submitted in May 2025, the Service
has reconsidered its position going forward, to improve the accurate
understanding of the condition of the housing stock. A new contract is being
progressed that will ensure that 100% of the properties are reviewed within
the lifetime of the contract, therefore within the five year period required for
the next Stock Condition Survey.
7. Conclusion
7.1 The Internal Audit review is able to place Substantial Assurance on the overall
control environment for arrangements for the compilation of the annual
submissions to the Housing Regulator. The agreed actions, once
implemented, should enable Internal Audit to place substantial assurance on
these.
8. Acknowledgements
8.1 Internal Audit would like to thank all officers who were involved in this audit,
Elaine Ritchie (Strategic Lead – Housing & Communities),
Calvin Cameron (Housing Development Worker, Communities - Performance
& Business Support),
Andrea McCallum (Service Manager - Housing - Communities),
Mark Weir (Team Leader - Income Maximisation, Communities - Performance
& Business Support),
June McColl (Service Manager (Housing) Communities - Repairs &
Improvements),
Nicola Lennon (Service Manager - Capital Projects & New Build),
Nicola Sworowski (Place Strategies Manager & Chief Planning Officer
Communities - Planning & Housing Strategy),
Martin Smith (Service Manager - Perth City and Specialist Services
Communities - Perth City & Specialist),
Connor Wilson (Business Support Service Manager – Finance & Business
Support),
Joy Mayglothling (Corporate Complaints Team Leader)
9. Action Implementation & Follow up
9.1 Responsibility for the maintenance of adequate and effective controls rests
with management. Where the audit has identified areas for management
action, these are identified in the Management Action Plan.
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Where a decision is taken by management not to act in response to findings
from this review, it is the responsibility of management to assess and accept
the risk arising from non-implementation.
9.2 Achievement of the agreed actions is monitored through Internal Audit’s
‘follow up’ arrangements.
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10. Management Action Plan
Action
Point
Para.
No Finding Risk
Rating Agreed Action & Evidence Action Owner
Target
Completion
Date
1 6.4 Our observations confirm that the
Customer Satisfaction Survey was
conducted by an independent,
third-party organisation, Knowledge
Partnership, using a representative
sample to assess overall tenant
satisfaction. Key areas evaluated
included keeping tenants informed,
opportunities to participate, housing
quality, repairs, neighbourhood
management and rent value.
During 2024/25 most of these
indicators showed a decline
compared to the previous year and
indicating a downward trend in
tenant satisfaction.
3 Agreed action:
The findings of the Satisfaction
Survey for 2025/26 are being
reviewed for any areas where
action can be taken to address
areas of concerns being raised.
Agreed evidence:
Outomes from the review of
tenant satisfaction within Perth
and Kinross.
A. McCallum
(Service
Manager -
Housing -
Communities)
May 2026
2 6.5 Regarding the complaint handling,
all the complaints are received via
email or telephone and are
recorded in Firmstep (Case
Viewer), before being downloaded
to Excel for verification. Housing-
related complaints are manually
identified, sorted, and documented
as a part of this process. Although
discussions have taken place
2 Agreed action:
A pilot dashboard has been
developed with managers
presenting live data, tracking and
themes with a view to resolving
complaints quickly and efficiently.
Roll out took place from January
2025, becoming fully operational
from April 2025.
C. Wilson
(Business
Support Service
Manager –
Finance &
Business
Support)
Completed
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regarding the implementation of a
complaints dashboard, it should be
noted that the dashboard was not
fully operational during the 2024/25
reporting period and therefore was
not utilised for the Housing
Regulator submission.
Agreed evidence:
Live dashboard
3 6.7 The audit has identified that a
substantial amount of information in
relation to the social housing is
publicly available in the PKC
website. This includes the access to
applications, common allocation
policy and clarifications addressing
misconceptions regarding the
allocation process. However, it was
noticed that certain information on
the website is outdated. For
instance, the update provided for
the Common Housing Register
Waiting List is dated 13 September
2021 which may lead to confusion
or misinformed expectations among
applicants.
1 Agreed action:
 We recognise the importance
of providing data that is
meaningful and relevant to
both applicants and tenants,
and significant progress has
been made in this area.
Agreed evidence:
 The updated waiting list
M. Smith
(Service
Manager -
Housing)
Completed
4 6.9 From our observation, we found
that there are 1662 houses which
do not pass this minimum SHQS in
2024/25; out of that 123 houses are
in abeyance (refers to the situation
where planned work cannot be
3 Agreed action:
 New Contract put in place for
Stock Condition Survey.
 New Asset Management
Database for all areas of
Housing to feed data into to
N. Lennon
(Service
Manager -
Capital Projects
& New Build)
October
2027
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completed due to social reasons
such as tenant behaviour), and 417
houses are under exemption (due
to technical or economic reasons).
1082 houses have fully failed to
meet the standards. Specifically,
999 houses failed on one criterion,
while 83 houses failed on two or
more criterion. The most common
failures notified were roof structure
and common floor/ parts failures.
For the year 2024/25 SHQS pass
rate is 80.28%, reflecting an
improvement from the previous
year 76.32%. It is noted that the
Council will not achieve 100%
conformance in this area, due to
reasons such as tenant preference,
the type of housing stock etc, and
that the Council’s performance is
above the local authority average;
the Service continues to progress
towards achieving the maximum
compliance rate possible.
ensure asset management
information is up to date.
 Review of SHQS failures and
targeted inspections carried
out to investigate elements
shown as failures
Agreed evidence:
 Appointment of contractor for
Stock Condition Survey and
commencement of contract
within 2026
 Appointment of new Asset
Management Database
provider and move from
current databases to new
Database undertaken
 Regular reports provided by
database to track reduction in
SHQS failures
 Data relating to each failure is
fully evidenced and shown
with a plan of how this will be
addressed
J McColl,
(Service
Manager
(Housing)
Communities -
Repairs &
Improvements
Nicola
Sworowski,
(Place
Strategies
Manager &
Chief Planning
Officer)
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5 6.10 The Energy Efficiency Standard for
Social Housing (EESSH) was
introduced to improve the energy
efficiency of social housing in
Scotland, with the aim of reducing
energy consumption, fuel poverty
and greenhouse gas emissions. As
part of our review, it was identified
that a significant number of
properties failed to meet EESSH
requirements. Specifically, 1055
properties did not comply with the
standard in 2024/25; 451 of these
properties are under exemption
(due to technical or economic
reasons) or an abeyance (tenant
issues, for example, opting out of
the improvements required or not
allowing access).
3 Agreed action:
 Targeted plan to address
EESSH failures, taking into
account budgetary pressures
Agreed evidence:
 EESSH failures list
categorised into elements to
be addressed to improve
EESSH compliance and work
towards completion of delivery
of the required elements
N. Lennon
(Service
Manager -
Capital Projects
& New Build)
Overall
target:
March 2030
Interim
targets:
March 2026
– 114
properties
March 2027
– 306
properties
March 2028
– 182
properties
March 2029
– 1 property
March 2030
- 1 property
6 6.12 As per the updated figures as of 30
June 2025, we noted that there are
185 properties without Energy
Performance Certificate (EPC) and
874 out of date which require
attention from the Housing Capital
Projects & New Builds team in
Property Services. It is appreciated
3 Agreed action:
 Properties currently without an
EPC or with an out-of-date
EPC are being prioritised for
surveys through the current
contract that is in place; this
contract has a planned
N. Lennon
(Service
Manager -
Capital Projects
& New Build)
March 2027
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that these figures can be impacted
by lack of access provided to carry
out the EPC surveys.
delivery requirement to
guarantee it meets the
required deliverables.
Agreed evidence:
 Progress monitoring reports
provided fortnightly by the
contractor at the progress
meeting
 Bi-monthly Highlight Reports
provided to Housing
Management Team. 
7 6.14 Whilst it is appreciated that the
current reports and quality
assurance processes for the
compilation of the submission to the
Scottish Housing Regulator ensure
that the information is accurate,
there is scope for considering some
improvement in that the audit
identified the Council does not
maintain a centralised asset
database accessible across all
departments.
3 Agreed action:
 A comprehensive contract
strategy has been completed
to tender for a new system.
This strategy acknowledges
the limitations and sets out a
clear pathway for procuring a
new housing asset
management solution that
meets both current and future
operational and regulatory
needs. This process has taken
significant time given the
complexities involved. 
 Market testing has been
conducted to ensure the
proposed system will deliver
improved functionality,
integration, and data reliability.
N. Lennon
(Service
Manager -
Capital Projects
& New Build)
J. McColl
(Service
Manager
(Housing)
Communities -
Repairs &
Improvements
March 2026
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 However, the costs have
been passed to our Finance
colleagues for review and
comment, as the quotation
received far exceeds the
anticipated costs, therefore it
is unclear at this stage
whether we will have a budget
to meet the full requirements
Agreed evidence:
 Contract award document /
outcome from decision on
whether to proceed
8 6.15 Regarding the indicator Anti-social
behaviour cases resolved, it was
noted that the 13.77% (From
91.37% to 79.60%) reduction from
previous year of resolving them
within the agreed time.
3 Agreed action:
 Review and update the ASB
procedures.
 Deliver targeted staff training –
with a particular focus on
trauma informed approach.
 Encourage the use of a wide
range of interventions and
legal tools.
 Promote early intervention
through positive engagement,
education, mentoring, and
diversion activities
Agreed evidence:
 ASB indicator for 25/26
A.McCallum
(Service
Manager -
Housing -
Communities)
May 2026
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9 6.16 We have observed positive
progress in rent collection,
accompanied by a significant
reduction in gross rent arrears.
However, it has been identified that
there is currently no utilisation of
advanced technologies to
proactively detect potential rent
arrears at the tenant level. Several
other councils have successfully
implemented predictive analytics to
identify early indicators of financial
distress among tenants and this
may be a route for PKC to consider.
2 Agreed action:
 We are currently testing NEC
Analytics, which is a form of
AI, to help with the
identification of trends and
forecasting to target our work
and free up staff to focus on
those more complex and
challenging cases.
Agreed evidence:
 Reports run by NEC Analytics
A. McCallum
(Service
Manager -
Housing -
Communities)
Build
completion
December
2025
Phased go-
live Q1
2026
10 6.18 Housing Regulator mentioned both
Gypsy/Travellers sites are in
failures in meeting several Social
Housing Charter Outcomes such as
Equalities (outcome 1),
Communication (outcome 2),
Participation (outcome 3), Repairs,
maintenance and improvement
(outcome 5), Gypsy/ Travellers
(outcome 16). There is an ongoing
replacement of the chalets and
general upgrades in both sites.
However, on the completion day of
this audit, the Comprehensive
Satisfaction Survey has not been
carried out.
3 Agreed action:
 Tenant satisfaction surveys
are embedded within our
programme and scheduled in
accordance with both statutory
requirements and resident
feedback.
 Review the findings of the
Satisfaction Survey for
2025/26.  Consider the
potential to extend the current
contract or alternative means
of collecting the satisfaction
levels. The regulator only
requires updates every 3
years for these indicators.
A. McCallum
(Service
Manager -
Housing -
Communities)
April 2026
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Agreed evidence:
 Comprehensive Satisfaction
Survey
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11. Authorisation
11.1 The auditor for this assignment was D. Arachchilage.  The supervising auditor
was J Clark.
This report is authorised for issue:
12. Distribution
12.1 The final report will be issued to:
T Glen, Chief Executive
C Mailer, Depute Chief Executive
E Ritchie, Strategic Lead – Housing & Communities
S Marone, Strategic Lead – Economy, Development & Planning
S Walker, Strategic Lead – Finance & Business Support
J Beveridge, Strategic Lead – Property Services
A McCallum (Service Manager - Housing - Communities),
J McColl (Service Manager (Housing)Communities - Repairs & Improvements,
N Lennon (Service Manager - Capital Projects & New Build),
M Smith (Service Manager - Perth City and Specialist Services Communities -
Perth City & Specialist)
C Wilson (Business Support Service Manager – Finance & Business Support)
N Sworowski (Place Strategies Manager & Chief Planning Officer Communities
- Planning & Housing Strategy)
Committee Services
External Audit
13. Assessment Definitions
13.1 The following table contains the definitions of the control objective
assessment.
Control Objective Assessment
Level of assurance Definition
Substantial
Assurance
A sound system of governance, risk management and
control exists, with internal controls operating effectively
and being consistently applied to support the achievement
of objectives in the area audited.
Reasonable
Assurance
There is a generally sound system of governance, risk
management and control in place. Some issues, non-
compliance or scope for improvement were identified
which may put at risk the achievement of objectives in the
area audited.
Limited Assurance Significant gaps, weaknesses or non-compliance were
identified. Improvement is required to the system of
governance, risk management and control to effectively
manage risks to the achievement of objectives in the area
audited.
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No Assurance Immediate action is required to address fundamental gaps,
weaknesses or non-compliance identified. The system of
governance, risk management and control is inadequate to
effectively manage risks to the achievement of objectives
in the area audited.
13.2 The following table contains the definitions applied by Internal Audit in rating
audit findings/actions.
Risk Rating for Individual Findings
Rating Rating
description
Definition
5 Critical Significant observations / major concerns which require
immediate action. Management will need to add these to
the appropriate Service risk register
Issue represents a control weakness which could cause,
or is causing, severe disruption of the process or severe
adverse effect on the ability to achieve process
objectives
4 High Significant observations regarding the absence / failure
of key controls requiring urgent action. Management
should consider adding these to the appropriate Service
/ divisional risk register
Issue represents a control weakness which could have,
or is having, major adverse effect on the ability to
achieve process objectives
3 Medium Observations regarding the effectiveness of key controls
requiring reasonably urgent action. Management should
consider these when updating any divisional / team risk
registers
Issue represents a control weakness which could have,
or is having, significant adverse effect on the ability to
achieve process objectives
2 Low Minor observations regarding the adequacy of controls
which require action to improve the efficiency,
effectiveness, or economy of operations or which
otherwise require to be brought to the attention of Senior
Management
Issue represents a minor control weakness with minimal
but reportable impact on the ability to achieve process
objectives
1 Trivial / Minor Very minor observations which will be raised during the
audit and may not be included within the final report
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Issue represents a very minor control weakness with
negligible impact on the ability to achieve process
objectives. The issue will be raised during the audit and
may not be included within the final report.
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Our vision is a Perth and Kinross where everyone can live life well,
free from poverty and inequality
___________________________________________________________________
Committee or Board: Audit & Risk Committee
Date of Meeting: 23 March 2026
Report Title: Internal Audit Follow Up
Report Number: 26/72
Report Author: Jackie Clark, Chief Internal Auditor
Organisational Lead: Strategic Lead – Legal and Governance
1. Purpose
1.1 The purpose of this Report is to present current summary of Internal Audit’s
‘follow up’ work relating to actions due for completion up to September 2025.
1.2 Sections
1. Purpose
2. Recommendations
3. Background/Context
4. Follow Up Outcomes
5. Conclusion
6. Impact Value Assessment
7. Appendices
2. Recommendation
It is recommended that the Committee:
2.1 notes the current position in respect of the agreed actions arising from Internal
Audit’s work.
3. Background/Context
3.1 The Global Internal Audit Standards in the UK Public Sector (GIAS (UKPS))
and the Code of Practice for the Governance of Internal Audit in UK Local
Government require that the Audit Committee should oversee the tracking
and implementation of actions agreed following audits.
3.2 Internal Audit request evidence from Services which confirms that actions
have been implemented and, therefore, controls have been improved.
8
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4. Progress Update
4.1 There were 13 actions due to be completed up to January 2026. Five actions
have been verified by Internal Audit as having been satisfactorily completed.
The remaining actions have revised completion dates, as detailed in Appendix
1 and 2. Appendix 2 contains details of actions which were previously
considered in private session of the Audit & Risk Committee.
5 Conclusion
5.1 Not applicable.
6. Impact and Value Assessment
6.1 This report has been classified as being an operational report and as such
does not require a full Impact and Value Assessment. 
7. Appendices
7.1 Appendix 1 – Actions with a completion date of up to September 2025 which
have yet to be completed
7.2 Appendix 2 - Actions with a completion date up to January 2026 which have
yet to be completed
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Appendix 1
Actions with a completion date up to January 2026 which have yet to be completed
Finding Action Action owner
& Service
Date(s) Current status Internal
Audit
Opinion
A24-01 - Business Continuity
Management (BCM) Planning
Action Point: Action Point 1.3
Importance: High
Audit Committee Date: June
2025
Our observation highlighted
the need for Business
Continuity Plans (BCPs) to be
regularly updated, particularly
regarding contact details and
emergency actions. Despite
the introduction of a new
template, upto-date BCPs
were not found across all
services. The audit concluded
without verifying signed BCPs
for all services
Ensure all Business
Continuity Plans are signed
by the Strategic Leads
Strategic
Leads,
supported by S
Terras,
Emergency
Planning &
Business
Continuity
Officer
June 2025
Dec 2025
Mar 2026
Three Strategic Leads
have still to finalise
and sign their Plan. 
The Emergency
Planning & Business
Continuity Officer has
been busy dealing with
the aftermath of the
Scott Street fire. She
is gradually reducing
the time she needs to
be at Scott Street as it
should be finished
soon and all families
home. She thinks that
this should leave
enough time for her to
arrange sessions with
the three Strategic
Leads to complete and
sign their Plans. 
Accepted
A24-01 - Business Continuity
Management (BCM) Planning
Action Point : 2
Importance: High
Arrange training and
exercising of all plans once
approved and as per the
BCP tracker.
S Terras,
Emergency
Planning &
Business
Jun 2025 
Nov 2025
Mar 2026
As above. Accepted
8
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Our observations revealed that
the previous versions of the
BCPs had not routinely been
subject to adequate testing
and communication (training
and exercise) since prior to the
Covid-19 pandemic.
Furthermore, the latest
Business Continuity
Management (BCM)
procedure has not been
finalised, preventing us from
providing any comments on its
effectiveness at this stage. 
Continuity
Officer
24-03 - Multi-Agency
Screening Hub (MASH)
Action Point : 1.1
Importance: Medium
Audit Committee Date:
December 2025
There are some discrepancies
between the Memorandum of
Understanding (MOU) and the
actual practice.
MOU will be updated (as
the list of children, as well
as their personal data on
the MASH spreadsheet, is
available for participants).
S Wilson,
Improvement
Officer
Dec 2025
Apr 2026
This action has yet to
be completed, due to
availability of
resources. This is now
due to be completed
by April 2026.
Satisfactory
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