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22-02 - Climate Change

Perth and Kinross Council · 25 March 2024
Back to Audit and Risk Committee — 25 March 2024 and its agenda

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(Report No. 24/98) 
Internal Audit Report
All Services
22-02 Climate Change
February 2024 
Final Report 
Legal and Governance
Corporate and Democratic Services
Perth & Kinross Council
Council Offices
2 High Street 
Perth
PH1 5PH

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20-02 Climate Change
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 climate change was undertaken as part of the Internal Audit Plan
for 2022/23, which was approved by the Audit Committee on 28 June 2022. 
1.2 The indicative scope for the audit was to provide support, advice and
challenge to the strategic arrangements in place to fulfil the Council’s climate
change duties. 
1.3 This audit is linked to Strategic Risk 2:
The actions and decisions of the Council fail to affect the behavioural and
cultural change required to mitigate the causes of and reduce the impact of
climate change in Perth and Kinross. 
2.  Executive Summary 
2.1  The audit has found that reasonable assurance can be placed on controls
overall in relation to the limited sphere of influence the Council has regarding
climate change. 
2.2  Areas of good practice have been highlighted in Section 5 of this report, and
there are 5 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 Council’s key risks were reported to the Audit & Risk Committee in June
2024. The Strategic Risk Register. classifies Climate Change as a Priority 1
risk (Risk SR02). A Priority 1 risk is where ‘Risk remains extreme even after
all identified controls and treatments have been applied. There are significant
risks, which may have a serious impact on the Council and the achievement
of its objectives if not managed. Immediate management action needs to be
taken to reduce the level of risk.’ Given this priority, the Chief Internal Auditor
has decided to include a review of this this in the Internal Audit work for
2022/23. The Register details key controls that are in place and key actions
thought necessary by officers to mitigate the risk. 
3.2  In December 2019, the Council approved an Interim Climate Emergency
Report and Action Plan (Report No 19/362 refers). This highlighted the
Intergovernmental Panel on Climate Change’s (IPCC) concerns in relation to
keeping the global average temperature rise below 1.5°C, which had been
also reflected at COP26. 
3.3  In December 2021, a report was submitted to the Council that provided an
update on the climate action progress made since the Council approved the
Interim Climate Emergency Report and Action Plan. It also provided a
summary of public engagement undertaken and the latest emissions update.
Based on this evidence, the Climate Strategy and Action Plan was developed
and approved by the Council, (Report No. 21/245 refers).

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3.4  The Council has a legal responsibility for emissions reductions and climate
resilience both within the Council’s operations and the Perth and Kinross
geographic area. As such, the Climate Change Strategy and Action Plan
covers the identified necessary actions for the Council to undertake for both
areas. 
3.5  The Council has signed up to a number of initiatives, becoming signatories to
the Covenant of Mayors, the Edinburgh Declaration and the Glasgow Food
and Climate Declaration (Report No. 21/209 refers). 
3.6  The Action Plan is broken down into eight thematic areas. The first five from
the interim plan, aligned with significant emissions sectors: transport;
buildings and energy; business and industry; waste; and land use, and a
further three included in the updated plan: climate resilience – as a result of
the Council’s legal duty in this area; education and engagement – to address
behavioural change; governance – to recognise the importance of clear
governance and performance monitoring in delivering improvement. There is
a roadmap for each theme within the Strategy and a detailed Action Plan. 
4. Scope and Limitations 
4.1  The review consisted of identifying and testing controls in place to ensure
delivery of the Climate Change Strategy and Action Plan. 
4.2  The review identified the design and substance of the key controls listed in the
Council’s Strategic Risk Register and tested their effectiveness. It also
considered the progress of the key actions listed on the Register. 
4.3  To arrive at an opinion on the achievement of the control objective, the review
included interviews with officers and a review of systems and documents in
use. 
4.4  Internal Audit recognises that many of the big drivers for climate change are
outwith the control of the Council and that, for those areas within the influence
of the Council, funding required from Scottish and/or UK Government may not
be forthcoming. It is noted that progress against our targets from 2011 to 2021
has been very slow and if it continues on this path, the probability of the
Council meeting the Scottish and UK Government targets are slim / unlikely.
However, the overall achievement of climate objectives, at this point in time, is
not the subject of this audit review but will be considered for inclusion in future
Internal Audit plans. 
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.

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No. Control Objective Action Rating  Control Objective
Assessment
5 4 3 2 1
1.  To ensure the adequacy of
governance arrangements to
deliver on the Council’s Climate
Change Strategy. 
1 3 1  Reasonable
Assurance 
5.2  The auditor has assessed that reasonable assurance can be placed on
controls overall in relation to the limited sphere of influence the Council has
regarding climate change. Meaning: 
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. 
5.3  A summary of the key findings and actions are provided in section 5. In
addition, the following areas of good practice have been highlighted during the
audit: 
5.4  The governance structure is good, in terms of: thematic working groups;
Climate Change Board; Climate Change and Sustainability Committee; and
Council. These working groups, Board and Committee meet regularly. 
5.5  There are standing items on the Climate Change Board agenda to review the
action log and for updates to be provided by the Climate Change and
Sustainability Team Leader and from each of the Theme Leads. 
5.6  There is a template in use for the Climate Change and Sustainability Team
Leader to direct their reporting of data to the Climate Change Board. The
template heading requests the preparer’s name and the date of preparation. It
has six sections and an appendix: 
• Key actions since last Board Meeting; 
• Status Tracker;
• Recruitment and budget update; 
• Key risks to development and delivery; 
• Looking ahead;
• Funding; and 
• Summary of Top Actions Classified as Red (Appendix). 
5.7  There is a template in use for each thematic working group Lead to direct the
reporting of data to the Climate Change Board. The template heading
requests the working group name and the date of preparation. It has five
sections: 
• Key progress since last Board Meeting; 
• Priorities for the next two months;
• Successes/challenges/areas for assistance to raise at Board meeting;

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• Comments on any Top or High Priority Actions with Red Status and what
is being done to get these back on track; and 
• Funding opportunities – summary of any opportunities on the horizon (if
not able to pursue them, why not e.g. capacity). 
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 9.   
6.2  Governance Structure:  We noted that there are at least seven stakeholders
who are involved in assisting PKC achieve its Climate Change Strategy and
Targets see below list of the parties. 
1. Climate Change Board 
2. Climate Change Sustainability Committee
3. Perth and Kinross Climate Change Commission
4. Executive Director (Communities) as Executive Sponsor
5. Climate Change Working Group Theme Leads
6. Climate Change Team
7. The Council 
There are clear terms of reference and responsibilities are in place for most of
these. There is clarity of the role of the Climate Change Working Groups but
there is scope to improve clarity of the role of the theme leads regarding their
expectations. 
Working groups and other parties involved submit data against their actions
plans. These are collated by the Climate Change Team and provided to the
Climate Change Board for scrutiny and challenge. 
Internal Audit has been informed that the Perth and Kinross Climate Change
Commission (PKCCC) is undertaking a review of how it functions and its
effectiveness. However there was an undertaking that the PKCCC will provide
an annual report on its work and in doing so will provide its assessment of the
Council’s progress”. No annual report has been prepared since its
establishment in May 2022.
Action Point 1 
The Climate Change Board consists of officers from across the Council, with
sufficient seniority to effect change. With the new leadership structure being
implemented, the Service has informed Internal Audit that there will be a
review of membership of the Board, along with its role within the overall
Council governance structures, to ensure that this is the case going forward.
Action Point 2 
6.3  Action Plans 
There are eight themes: Transport; Building and Energy; Waste and
Resources; Business and Industry; Land Use; Climate Resilience;

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Governance: and Education and Engagement.  Each theme has a lead and
working group. 
There are 182 strategic actions in the Climate Change Master Action Plan,
with 89 KPIs. Each working group is responsible for updating their action plan
and this is compiled into the master document. Internal Audit reviewed this
master document and found that it does not detail targets for all key
performance indicators nor was progress recorded for many of the indicators
reviewed. Of the 182 actions, 97 actions (53%) do not have specific start or
end date, with 90 (49.4%) also not having milestones. 
Two different files are used to capture information, one for Action Plan and
one for KPIs and targets. It is a little challenging to reconcile the two files.
There is scope to streamline these documents to limit duplication, gaps and
overlaps.
Action Point 3 
6.4 Resourcing of priority actions. 
The Council has identified 25 actions as top priority and funding was provided
for these 25 top priorities.  However, A review of the Master Action Plan that 9
of these top priority actions had available resources, 7 had partial resources
(i.e. for feasibility / design), and 9 were without allocated resources.
Action Point 4 
6.5  Buy in from community and private sectors. 
Taking the necessary comprehensive and urgent action on climate change
requires the Council to work in partnership with our communities, businesses
and organisations at an unprecedented scale. 
The PKCCC was formed in May 2022. Its aim is to bring together people and
organisations from the public, private and civic sectors who work
collaboratively to help drive, guide, support and monitor climate action. The
PKCCC is to provide independent active leadership and support for cross-
sector collaboration and action on climate change. However, it is unclear from
the website whether private sector organisations are represented, as
individuals only are named, and the PKCCC is yet to measure and report
since its establishment, as detailed in paragraph 5.2 above. 
Internal Audit has been advised that the PKCCC is reviewing its approach and
membership. It may be helpful to have explicit links to the external
organisations that individuals represent, where this is the case, to
demonstrate the representation of such organisations and to for the Council to
consider whether the PKCCC is a control measure for the strategic risk
register. 
Action Point 1

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7.  Conclusion 
7.1  The Internal Audit review is able to place reasonable assurance on the overall
control environment for the Council’s arrangements for Climate Change at this
time. 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,
particularly the officers within the Climate Change team and Property
Services. 
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
Action
Point
Para.
No Finding Risk
Rating
Agreed Action &
Evidence
Action
Owner
Target
Completion
Date
1  5.2 1. Perth and Kinross Climate Change Commission
(PKCCC) is required to provide an annual report on its
work and provide its assessment of the Council’s
progress.  No annual report has been produced since
its establishment in May 2022 
2 It may be helpful to have explicit links to the external
organisations that individuals represent, where this is
the case, to demonstrate the representation of such
organisations and to for the Council to consider
whether the PKCCC is a control measure for the
strategic risk register.
3
3
Agreed action:
Climate Change
Strategic Lead to work
with PKCCC to review
Commission’s role,
membership and
performance and to
ensure that any annual
reporting requirements
are adhered to. 
Agreed evidence:
Outcome of the review
and annual report 
Agreed action:
The Strategic Lead,
Environment will work
with, and consider, the
outcome of the
PKCCC’s own review
in relation to the
matters raised in this
finding. 
Agreed evidence:
F Crofts,
Strategic
Lead,
Environment 
F Crofts,
Strategic
Lead,
Environment 
December
2024 
December
2024

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Outcome of review
and updated Risk
Register 
2  5.2 The Climate Change Board consists of officers from
across the Council, with sufficient seniority to effect
change. With the new leadership structure being
implemented, the Service has informed Internal Audit
that there will be a review of membership of the Board,
along with its role within the overall Council governance
structures, to ensure that this is the case going forward
2 The Strategic Lead will
review the
membership of the
Board to ensure that it
remains relevant and
fit for purpose
following the
leadership review. 
Agreed evidence:
Outcome of review 
F Crofts,
Strategic
Lead,
Environment 
December
2024 
3  5.3 Action Plans. 
The Action Plan does not detail targets for all key
performance indicators nor was progress recorded for
many of the indicators reviewed. Of the 182 actions, 97
actions (53%) do not have specific start or end date,
with 90 (49.4%) also not having milestones. 
Two different files are used to capture information, one
for Action Plan and one for KPIs and targets. It is a little
challenging to reconcile the two files and there is scope
to streamline these documents to limit duplication, gaps
and overlaps.
3 Agreed action: 
The Climate Change &
Smart Investment
Manager will support
the Climate Change
Board to review and
approve actions in
Climate Change Action
Plan with milestones,
KPI and targets.
As part of this, the
documents will be
reviewed to ensure
that they fully and
completely record both
actions and KPIs 
S Marone,
Climate
Change &
Smart
Investment
Manager 
December
2024

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Agreed evidence:
Revised
documentation
considered by the
Climate Change Board 
4  5.4 Lack of resources both financial and capacity.
The Council has identified 25 actions as top priority and
funding was provided for these 25 top priorities. 
However, we noted from our review of the Master
Action Plan that 9, of these top priority actions had
available resources, 7 had partial resources (i.e. for
feasibility / design), and 9 were without allocated
resources.
4 Agreed action: 
The Climate Change &
Smart Investment
Manager will support
the Climate Change
Board to review the
actions to ensure that
resourcing is
appropriately reflected
to deliver these top
priority actions 
Agreed evidence:
Outcome of review
from the Climate
Change Board.
S Marone,
Climate
Change &
Smart
Investment
Manager 
September
2024

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11.  Authorisation 
11.1  The auditor for this assignment was M Stewart.  The supervising auditor was
I Iman. 
This report is authorised for issue: 
12.  Distribution 
12.1  This report has been distributed to:
T Glen, Chief Executive
B Renton, Executive Director (Communities)
A Williams, Director, Economy, Place & Learning
C Mailer, Director, Strategy, People & Resources
F Crofts, Strategic Lead, Environment
D Littlejohn, Strategic Lead, Economy, Development & Planning
S Crawford, Strategic Lead, Property Services
S Merone, Climate Change & Smart Investment Manager 
L Simpson, Strategic Lead, Legal & Governance
Committee Services
External Audit

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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.
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

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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
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.