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Agenda Document Pack - Risk and Audit Scrutiny Committee - 09/12/2025

South Lanarkshire Council · 9 December 2025
Back to Risk and Audit Scrutiny Committee — 9 December 2025 and its agenda

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Council Offices, Almada Street        
Hamilton, ML3 0AA 
Monday, 01 December 2025 
Dear Councillor 
Risk and Audit Scrutiny Committee 
The Members listed below are requested to attend a meeting of the Committee to be held as
follows:- 
Date:  Tuesday, 09 December 2025
Time:  10:00
Venue: Hybrid - Committee Room 1, Council Offices, Almada Street, Hamilton,
ML3 0AA 
The business to be considered at the meeting is listed overleaf. 
Yours sincerely 
Paul Manning
Chief Executive 
Members 
Elaine McDougall (Chair), Mary Donnelly (Depute Chair), Mathew Buchanan, Colin Dewar,
Alistair Fulton, Ross Gowland, Celine Handibode, Susan Kerr, Richard Lockhart 
Substitutes
Monique Equi, Gavin Keatt, Julia Marrs, Helen Toner
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BUSINESS 
1 Declaration of Interests 
2 Minutes of  Previous Meeting
Minutes of the meeting of the Risk and Audit Scrutiny Committee held on
30 September 2025 submitted for approval as a correct record.  (Copy
attached) 
3 - 14 
Item(s) for Decision 
3 Internal Audit Activity Report
Report dated 14 November 2025 by the Executive Director (Finance and
Corporate Resources).  (Copy attached) 
15 - 36 
Item(s) for Noting 
4 Accounts Commission 2025 – Scrutiny, Governance and
Transparency of Decision Making of Exit Packages of Senior Officers
Report dated 3 November 2025 by the Executive Director (Finance and
Corporate Resources).  (Copy attached) 
37 - 42 
5 Fraud Statistics Six Monthly Update 2025/2026
Report dated 14 November 2025 by the Executive Director (Finance and
Corporate Resources).  (Copy attached) 
43 - 50 
6 Performance and Review Scrutiny Forum Annual Update
Report dated 25 November 2025 by the Chief Executive.  (Copy attached) 
51 - 54 
7 Forward Programme for Future Meetings
Report dated 19 November 2025 by the Executive Director (Finance and
Corporate Resources).  (Copy attached) 
55 - 58 
Urgent Business 
8 Urgent Business
Any other items of business which the Chair decides are urgent. 
Clerk Name: Ishara Opatha
Clerk Telephone: 07385370069
Clerk Email: ishara.opatha@southlanarkshire.gov.uk 
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RISK AND AUDIT SCRUTINY COMMITTEE 
Minutes of meeting held via Confero and in Committee Room 1, Council Offices, Almada Street,
Hamilton on 30 September 2025 
Chair: 
Councillor Elaine McDougall 
Councillors Present:
Councillor Mathew Buchanan, Councillor Colin Dewar, Councillor Mary Donnelly (Depute),
Councillor Ross Gowland, Councillor Susan Kerr, Councillor Richard Lockhart, Councillor Helen
Toner (substitute for Councillor Alistair Fulton) 
Councillors' Apologies:
Councillor Alistair Fulton, Councillor Celine Handibode 
Councillor Also Present:
Councillor Gerry Convery (for items 3 and 4) 
Attending:
Chief Executive’s Service
P Manning, Chief Executive (for items 3 and 4)
Finance and Corporate Resources
J Taylor, Executive Director; Y Douglas, Internal Audit Manager; S Dunsmore, Insurance and Risk
Management Adviser; E-A McGonigle, Administration Adviser; A Norris, Administration Assistant; L
O’Hagan, Head of Finance (Strategy); I Opatha, Administration Officer; I Strachan, Head of
Administration and Legal Services 
Also Attending:
Audit Scotland
A Barclay, J Boyd, and M Ferris, External Auditors 
Order of Business
The Committee decided: that the items of business be dealt with in the order
minuted below. 
1 Declaration of Interests 
No interests were declared. 
2 Minutes of Previous Meeting 
The minutes of the meeting of the Risk and Audit Scrutiny Committee held on 25 June 2025
were submitted for approval as a correct record. 
The Committee decided: that the minutes be approved as a correct record.
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3a External Auditors’ Annual Report 2024/2025 
The following documents were submitted by Audit Scotland, the Council’s external auditors:- 
 letter and appendices relating to the 2024/2025 Annual Audit report on South Lanarkshire
Council 
 2024/2025 South Lanarkshire Council proposed Annual Audit report to members of the
Council and the Controller of Audit 
The Audit Director, Audit Scotland, spoke on the Annual Audit report and highlighted the
following:- 
 the audit of the 2024/2025 Annual Accounts
 financial management
 financial sustainability
 best value 
 vision, leadership and governance
 use of resources to improve outcomes:-
 key messages 
 significant findings and key audit matters:-
 implementation of IFRS 16 (Leases) disclosures
 prior year restatement relating to South Lanarkshire Leisure and Culture (SLLC)
Limited pension asset 
 significant risks of material misstatement in the annual accounts identified during planning
of the audit:-
 risk of material misstatement due to fraud caused by management override of
controls
 valuation of property, plant and equipment
 estimation of the pension liability
 2024/2025 action plan on recommendations for improvement
 summary of corrected misstatements 
The external auditors’ opinion on the Council’s Annual Accounts 2024/2025 and the charities
administered by the Council was unmodified, that is, the financial statements and related reports
were free from material misstatement. 
Due to the interaction of section 106 of the Local Government in Scotland Act 1973 with the
charity’s legislation, a separate independent auditor’s report was required for the statement of
accounts of each registered charity where members of the Council were sole trustees, and this
was irrespective of the size of the charity. 
Officers responded to members’ questions in relation to:- 
 the year-end timetable and the importance of ensuring working papers for the External
Audit were provided to the Finance Strategy team in line with deadlines
 the high-level review of Oracle Fusion implementation, which had identified that clear
supporting documentation had not been available due to the Council’s retention policy
 the post-implementation and benefits realisation review of the new Oracle platform, and
assurance that the Committee would be updated as appropriate 
 training and development of members to ensure the Committee was effective in its role 
The Audit Director, Audit Scotland, undertook to arrange a session with members to conduct an
annual review and self-assessment.  The Audit Director also commended the Finance (Strategy)
team for delivering the statutory audit on time, particularly with the challenges faced with the
implementation of Oracle Fusion.
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The Depute Leader thanked the External Auditors for the report and extended thanks to the
Executive Director (Finance and Corporate Resources), the Head of Finance (Strategy) and the
wider team for the comprehensive work that had been undertaken to prepare the annual
accounts.  The Chair, on behalf of the Committee, echoed those remarks. 
The Committee decided: that the report be noted. 
3b Transformation: How Councils are Redesigning and Delivering More Efficient
Services to Achieve Planned Outcomes - Best Value Thematic Work in South
Lanarkshire Council 2024/2025 
A report dated September 2025 by Audit Scotland, the Council’s external auditors, was
submitted entitled ‘Transformation: How Councils are Redesigning and Delivering More Efficient
Services to Achieve Planned Outcomes - Best Value Thematic Work in South Lanarkshire
Council 2024/2025’. 
The report set out how the Council was responding to transformation challenges through
redesigning and delivering more efficient services to achieve planned outcomes.  The Accounts
Commission’s Strategy (2021 to 2026) had set out its priorities to focus on inequalities, funding,
communities and recovery.  The Code of Audit Practice had set out the Best Value work
required to report on those priorities. 
The Audit Director, Audit Scotland, highlighted the following sections of the report:- 
 key messages
 transformation planning
 programme management
 partnership working and community engagement
 impact of transformation 
The report detailed the following audit recommendations:- 
 the Council should ensure its plans for transformation were sufficiently ambitious to ensure
that it could continue to deliver sustainable services, prioritising transformational activities
that would deliver the most impact and contribute towards reducing its budget gap 
 the Council should assess whether its arrangements for resourcing transformation
activities were sufficient to drive the scale and pace of change required in future
 the Council should ensure it demonstrated how engagement with communities, including
vulnerable groups, had informed planned changes to services
 the Council should prioritise establishing a framework that identified and monitored the
estimated and realised impact to date of its transformation work, including on service
delivery and on outcomes for service users. It should report to the Corporate Management
Team (CMT) and elected members on both the financial and non-financial impact of the
full range of its transformational activities 
An improvement action plan, attached as Appendix 1 to the report, set out those audit
recommendations and the Council’s planned response, which included responsible officers and
dates for implementation.   
The Executive Director (Finance and Corporate Resources) responded to a member’s question
in relation to actions being reported back to the Committee. 
The Committee decided: that the report be noted.
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3c External Auditors’ Annual Report 2024/2025: South Lanarkshire Council
Charitable Trusts 
Summary letters, proposed independent auditor’s reports and letters of representation (ISA 580)
were submitted by Audit Scotland, the Council’s external auditors for South Lanarkshire Council
Charitable Trusts. 
The Audit Manager, Audit Scotland advised that there were no unadjusted misstatements to be
corrected for the Charitable Trusts administered by the Council. 
The Committee decided: that the report be noted. 
4 Audited Annual Accounts 2024/2025 
A report dated 19 September 2025 by the Executive Director (Finance and Corporate
Resources) was submitted on the:- 
 Council’s Certified Annual Accounts and Charitable Trusts’ Accounts for 2024/2025, which
had received a clean audit certificate from the Council’s external auditors, Audit Scotland
 requirement to approve the Annual Accounts 2024/2025 for signature in terms of both the
Council’s accounts and related charitable trusts 
The accounts covered the Council as well as 2 Charitable Trusts managed by the Council,
namely South Lanarkshire Council Educational Trust and South Lanarkshire Council Charitable
Trust.  A clean audit certificate had been received for each, with no qualifications on the
Council’s accounts.  An agreed action plan had been included in the external auditor’s report,
and officers would work to ensure those were implemented in 2024/2025. 
The Annual Accounts would be advertised as being available for public inspection on the
Council’s website and on request from Finance Services. 
The Chair, on behalf of the Committee, thanked the Head of Finance (Strategy) and team for
their extensive work involved in preparing the Annual Accounts. 
The Committee decided: 
(1) that it be noted that the South Lanarkshire Council Annual Accounts 2024/2025 and the
Charitable Trusts’ Accounts had each received a clean audit certificate from the Council’s
external auditors, Audit Scotland; 
(2) that the audited South Lanarkshire Council Accounts 2024/2025 and the Charitable Trusts’
Accounts be approved for signature; 
(3) that it be noted that the external auditor’s report would be referred to a future meeting of
South Lanarkshire Council for information; and 
(4) that it be noted that, as detailed in section 3.6 of the report, the Audited Accounts
2024/2025 would be available on the Council’s website. 
[Reference: Minutes of 25 June 2024 (Paragraph 5)] 
5 Internal Audit Activity as at 31 August 2025 
A report dated 5 September 2025 by the Executive Director (Finance and Corporate Resources)
was submitted on work completed by Internal Audit during the period 1 June to 31 August 2025.
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Findings from internal audit assignments were reported to this Committee throughout the year,
and the last progress report was considered by the Committee on 25 June 2025.  Information
was provided for the Internal Audit work completed during the period from 1 June to 31 August
2025. 
As at 31 August 2025, good progress had been made with 74% of the 2025/2026 Audit Plan in
progress and 14% of assignments completed to the final report stage.  Targets for the remainder
of the year were outlined to ensure delivery of the Plan by May 2026.  Key performance
indicators for the period, including 5 indicators assessed as amber with planned corrective
actions, were detailed in Appendix 1 to the report. A summary of the audit output for each
assignment was detailed in Appendix 2. 
Updates were also provided on:- 
 audit plan progress, as detailed in section 4 of the report. All assignments from 1 April
2025 would be conducted in conformance with the Global Internal Audit Standards (GIAS).
Three assignments from 2024/2025 and 7 assignments from 2025/2026 were completed
or closed in the period to 31 August 2025, and those were detailed in paragraph 4.2 of the
report
 all of those assignments, except Self-Directed Support, which would be progressed to a
final report. It was proposed that the planned assignment reviewing Self-Directed Support
arrangements would be deferred to 2026/2027 to align with the implementation of the new
Social Work Resources’ IT system (Liquid Logic), as detailed in paragraph 4.3 of the
report.  The allocated days for this assignment would be used for a substitute audit to
review direct payment arrangements within Social Work Resources, providing a fuller
assessment of risks and controls
 a summary of the audit output for each assignment, which was detailed in Appendix 2 to
the report. Further information in relation to the one, more significant assignment, the
Economic Crime and Corporate Transparency Act 2023, was set out at Appendix 3 to the
report, and the key points were detailed in paragraph 4.4 of the report.  The introduction of
a new offence of ‘failure to prevent fraud’ was in place from 1 September 2025, which
would hold large organisations, including the Council, to account if they profited from fraud
 8 assignments which were finalised in the same period for external clients, with output
reported to their respective audit committees and Boards
 the Council’s response to the Accounts Commission Consultation on priorities and work
programme, as detailed in Appendix 4 to the report
 key findings and recommendations, as detailed in section 5 of the report
 emerging risks and issues, as detailed in section 6 of the report
 a compliance and standards update, as detailed in section 7 of the report
 governance and Committee engagement, as detailed in section 8 of the report 
The Committee decided: 
(1) that progress with delivery of the 2025/2026 Internal Audit Plan be noted; 
(2)  that performance in the period to 31 August 2025, as detailed in Appendix 1, be noted; 
(3) that the proposed amendment to the Audit Plan, as set out in paragraph 4.3, be approved; 
(4) that audit output from assignments completed in the period, as detailed in appendices 2
and 3, be noted; and 
(5) that the responses to the Accounts Commission Consultation, as detailed in Appendix 4,
be noted. 
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The Internal Audit Manager responded to a member’s question in relation to the percentage of
assignments for which final reports had been issued. 
The Chair thanked the Internal Audit team for the comprehensive report. 
[Reference: Minutes of 25 June 2025 (Paragraph 3)] 
6 Annual Update on the Use of Surveillance Powers - The Regulation of
Investigatory Powers (Scotland) Act 2000 (RIPSA) 
A report dated 6 August 2025 by the Executive Director (Finance and Corporate Resources)
was submitted, providing an updated version of the Council’s Regulation of Investigatory Powers
(Scotland) Act 2000 (RIPSA) Policy and providing an overview and update on the use of
directed surveillance powers by the Council. 
The use of surveillance to provide information was a potentially valuable resource for the
protection of the public and the maintenance of law and order.  To ensure that local authorities
and law enforcement agencies were able to discharge their responsibilities, use was made of
unaided surveillance and surveillance devices. 
RIPSA provided a legal framework for the use, deployment, duration and effectiveness of covert
surveillance and the use of covert human intelligence sources.  The Council must comply with
RIPSA and adhere to the authorisation procedures specified in the Council’s RIPSA Policy and
related procedures.  The Investigatory Powers Commissioner's Office (IPCO) provided
independent oversight of the use of the powers contained within RIPSA.  This oversight included
inspections by IPCO inspectors on a regular basis, approximately every 3 years, with the
Council’s next inspection expected in 2026.  
The Council’s RIPSA Policy and its procedures applied where ‘Directed Surveillance’ was being
planned or carried out.  Directed Surveillance could only be conducted to achieve one or more
of the permitted RIPSA purposes, namely:- 
 preventing or detecting crime or the prevention of disorder
 in the interests of public safety
 protecting public health 
Directed surveillance was covert and was undertaken for the purpose of a specific investigation
to obtain private information.   
The Council’s RIPSA Policy comprised a Protocol for Covert Directed Surveillance and a
Protocol for Using Covert Human Intelligence Source.  Those were last reviewed in May 2023
and November 2016, respectively and had been the subject of a fresh review.  A few minor
updates had been made to reflect changes in Council structure and aligned the 2 Protocols, as
detailed in appendices 1 and 2 of the report.  Those changes had been made by officers under
delegated authority in terms of the Scheme of Delegation due to the minor nature of the
changes. 
Going forward, those Protocols would be the subject of an annual review, the outcome of which
would be reported to the Committee in line with the IPCO’s recommended practice. 
The Committee decided: 
(1) that the contents of this report be noted;
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(2) that the updated Council’s Regulation of Investigatory Powers (Scotland) Act 2000
(RIPSA) Policy, being the Protocol for Direct Covert Surveillance and the Protocol for using
Covert Human Intelligence Source, included in appendices 1 and 2 to the report, be noted;
and 
(3) that it be noted that the Council’s use of surveillance powers under RIPSA would be
reported annually to the Committee going forward. 
7 Financial Resilience and Sustainability 
A report dated 10 September 2025 by the Executive Director (Finance and Corporate
Resources) was submitted, providing an update on:- 
 the Council’s financial outlook, financial resilience and sustainability
 how risks posed by the financial challenges would be responded to 
A report had been presented to the Executive Committee on 25 June 2025, which detailed the
2026/2027 to 2027/2028 Revenue Budget Strategy.  The report highlighted that the Council
faced a Budget Gap of £24.273 million over the next 2 years, with potential further risks if pay
awards exceeded assumptions, potentially increasing the gap to over £42 million.  The report
also noted that Transformational Reviews and options to increase Council Tax could help
address the gap. 
The report acknowledged the importance of financial resilience in light of those challenges.
Financial resilience was defined as more than reliance on usable reserves, and included
understanding exposure to loss of income, expenditure commitments, and flexibility to access
funds in a time of crisis. 
The Revenue Budget Strategy report to the Executive Committee on 25 June 2025 had detailed
that a further report would be presented to the Risk and Audit Scrutiny Committee, which would
provide more information on the Council’s resilience.  Detailed information was provided on:- 
 the financial position and plan for 2026/2027 to 2027/2028, as detailed in section 4 of the
report
 financial resilience and a summary of the Financial Resilience Framework, as detailed in
section 5 and Appendix 1 to the report 
The Committee decided: 
(1) that the Financial Position and Plan for 2026/2027 to 2027/2028, as detailed in section 4 of
the report, be noted; and 
(2) that the Financial Resilience Framework, as detailed in section 5 and Appendix 1 of the
report, be noted. 
[Reference: Minutes of the Executive Committee of 25 June 2025 (Paragraph 8) and Minutes of
24 September 2024 (Paragraph 6)] 
8 Audit Scotland – Local Government Budgets 2025/2026 
A report dated 7 August 2025 by the Executive Director (Finance and Corporate Resources)
was submitted on the information contained within Audit Scotland's ‘Local Government Budgets
Briefing 2025/2026’.
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In May 2025, Audit Scotland published a report entitled ‘Local Government Budgets 2025/2026’
on behalf of the Accounts Commission.  The Audit Scotland report was part of a series of
outputs produced by the Accounts Commission that provided an independent overview of the
local government sector. 
Detailed information was provided on:- 
 the introduction and key messages from the Audit Scotland report, as detailed in section 4
of the report
 funding, budgeting and communities, as detailed in section 5 of the report
 the Council’s position in relation to the key messages in the Audit Scotland report, as
detailed in section 6 of the report   
The Committee decided: 
(1) that the key messages and data from the Audit Scotland ‘Local Government Budgets
2025/2026’ report, as detailed in sections 4 and 5 of the report, be noted; and 
(2) that the commentary on the Council’s position, as detailed in section 6 of the report, be
noted. 
9 Fraud Statistics Annual Report 2024/2025 
A report dated 28 August 2025 by the Executive Director (Finance and Corporate Resources)
was submitted, providing:- 
 a summary of the fraud statistics and workload for the year to 31 March 2025 and a
comparison to the same period in 2024 
 an update on other anti-fraud activity 
 a comparison of current fraud arrangements to best practice 
The number, types, outcomes and costs of fraud investigations, together with performance
measures for the year to 31 March 2025, were detailed in the report.  A comparison to the
statistics for the same period in the previous year was also provided. Those statistics highlighted
that:- 
 30 fraud investigations, with a total value of £9,000, had been reported in the period,
representing a decrease in both number and value from the previous year
 177 cases were closed in the period, of which:-
 14 were founded
 1 had insufficient information
 44 were unfounded
 118 had no housing benefit in the claim
 of the 14 founded allegations, 13 were external and one was benefits-related   
Information on the wider fraud workload was provided in paragraphs 4.7 to 4.11 of the report.
Outcomes for concluded investigations had been reported to this Committee as part of Internal
Audit’s Annual Assurance report or captured in the National Fraud Initiative (NFI) exercise in
2022. 
Details on the following were provided in sections 5 to 8 of the report, respectively:- 
 the NFI 2024 exercise 
 the ‘Three Lines of Defence’ – Fraud Risk Analysis
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 a comparison of fraud risk arrangements to best practice
 the Serious and Organised Crime (SOC) Group 
The Committee decided: that the contents of the report be noted. 
[Reference: Minutes of 24 September 2025 (Paragraph 8) and Minutes of 25 June 2025
(Paragraph 3)] 
10 Year-End Insured Risk Report 2024/2025 
A report dated 5 September 2025 by the Executive Director (Finance and Corporate Resources)
was submitted on the Council’s insurance claims for the year to 31 March 2025 for the following
main classes of insurance:- 
 combined liability (covering both public liability and employer’s liability) 
 motor insurance
 property insurance and other miscellaneous risks 
Appendix 1 to the report provided annual comparisons of the numbers and values of claims by
Resources for the years 2020/2021 to 2024/2025. Claims costs had fluctuated over the last 5
years. On average, over that period, the self-insured cost of claims per annum was £2.882
million, however, the costs for 2024/2025 were above average at £4.137 million.  The figures for
2024/2025 had been impacted by Storm Eowyn, with the self-insured estimated cost of that
event included within the total.  Inflation, increased costs of materials, vehicle parts and repair
charges had also impacted claim values. 
Appendix 2 to the report compared claim numbers and costs for 2024/2025, at 31 March 2025,
with the equivalent position for 2023/2024.  This showed a reduction of 40 claims (4.5%) on the
numbers reported in 2023/2024, with a total of 846 claims intimated.  The cost of claims
increased from £3.548 million in 2023/2024 to £4.137 million in 2024/2025.  This represented an
increase of £0.589 million (16.6%), which was a result of the estimated cost of property and
motor claims increasing, with the position being offset slightly by reduced estimated costs for
liability claims. 
Appendix 3 to the report provided a further breakdown of public liability claims and costs
specifically for Roads and other services within Community and Enterprise Resources. 
Information was also provided in sections 6 to 9 of the report on:- 
 liability claim
 motor claims
 property claims
 insurance hotspots and the progress made over the last year to mitigate risks 
The Committee decided: that the Insured Risks Report for the year ended 31 March
2025 be noted. 
[Reference: Minutes of 24 September 2024 (Paragraph 9)]
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11 Year End Risk Management Report (2024/2025) and Review of Council’s Top
Risks (2025/2026) 
A report dated 5 September 2025 by the Executive Director (Finance and Corporate Resources)
was submitted providing an update on:- 
 progress with risk management activity undertaken during 2024/2025
 the Council’s top risk register following the review and consultation process 
Annual reviews of the Council’s top risks were undertaken, with the findings of the last review
reported to the Committee on 24 September 2024.  This year’s full review commenced in April
2025, and the consultation had sought views from Heads of Service, elected members and trade
unions on new areas of risk. 
Risk Sponsors were required on an annual basis to assess their Resources’ compliance with the
Risk Management Strategy and provide supporting evidence.  The information for 2024/2025
was summarised in the end-of-year compliance statement, which was detailed in Appendix 1 to
the report. Resources continued to demonstrate full compliance with the Strategy, having scored
45 out of 45. 
The progress made in delivering actions to control the Council’s top risks was detailed in section
5 of the report.   As at 31 March 2025, the percentage of actions completed on the 2024/2025
risk control plan was 73.4% against an overall target of 90%.  Actions that were on hold or
experienced slippage, in relation to Community Planning and IT forecasting, had been carried
forward to the 2025/2026 risk control plan. 
The annual review, in line with previous years, did not result in wholesale changes to the top risk
register.  The risks from the previous year’s review, as detailed in the report to the Committee on
24 September 2024, were still deemed to be valid. 
The results of the review of the Council’s top risks 2025/2026 were detailed in section 6 of the
report. The main changes from the previous year were:- 
 2 risks had been removed from the top risk register:-
 the Council was materially affected by the implications arising from the National Care
Service (NCS) Bill
 the Council inherited commercially unviable shopping centres due to the financial
failure of existing owner/management companies, resulting in significant financial and
operational liabilities transferring to the Council
 the following 2 risks had been consolidated, with the new wording, as detailed in Table 2 of
the report, intended to cover all types of civil emergencies:-
 failure to fulfil emergency response commitments befitting the Council’s status as a
Category One (emergency) responder
 the Council did not have the appropriate emergency/business continuity plans,
contingency arrangements, or partnerships in place to respond to/or recover from a
pandemic/endemic event
 some changes to residual risk scores, as detailed in Table 3 of the report
 some key risk wordings had been updated to reflect the current status of risks and/or to
provide more straightforward and understandable risk descriptions 
As part of the review of the Risk Management Strategy, risk categories had been realigned, and
some scores had been revised. This had resulted in the previously high categorised risks now
being categorised as medium-level risks and no longer featured as part of the Council’s top
risks, as detailed in paragraph 6.3 of the report.
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The Council’s top risk register was monitored on an ongoing basis and updates were reported
annually to this Committee. Risk scores and rankings would be amended if new information
came to light that allowed the position to be reassessed. The top Risk Register for 2025/2026
was attached as Appendix 2 to the report. 
Details were provided in section 7 of the report on a benchmarking exercise that had been
conducted to review risks faced by a sample of other Scottish local authorities.  This review
established that the current South Lanarkshire Council top risk register was, in the main,
reflective of the risks faced by those other authorities. 
Horizon scanning was used to identify several areas that could pose potential threats and risks
or emerging issues and opportunities that could affect the Council.   Areas identified, as detailed
in section 8 of the report, included Transformational Change, the Terrorism (Protection of
Premises) Act, the Care Reform (Scotland) Bill and Scotland Excel Supply Chain Intelligence
Report.  Those areas would continue to be monitored to ensure the Council was adequately
prepared to respond, where required. 
Details were also provided in sections 9 and 10 of the report on the following areas:- 
 the ‘Three Lines Model’ work was being undertaken by Internal Audit. This had now
concluded and Resource Risk Sponsors have been provided with individual analysis and
guidance to support in developing further controls and in closing gaps for the Council's top
risks
 the scope and appetite for risk, which included the top risks heat map and the top risks
profile 
The Insurance and Risk Management Adviser responded to a member’s question in relation to
Employer National Insurance Contributions (ENICs). 
The Committee decided: 
(1) that Resource compliance with the requirements of the Risk Management Strategy be
noted; 
(2) that the progress being made in delivering actions to mitigate top Council risks be noted;
and 
(3) that the updated Council’s top risks, as detailed in Appendix 2 of the report, be noted. 
[Reference: Minutes of 24 September 2024 (Paragraph 10)] 
12 Forward Programme for Future Meetings 
A report dated 20 August 2025 by the Executive Director (Finance and Corporate Resources)
was submitted on the outline forward programme for the meetings of the Risk and Audit Scrutiny
Committee to 29 September 2026. 
As part of future arrangements, members were invited to suggest topics for inclusion in the
Committee’s forward programme. 
The Committee decided: that the outline forward programme for the meetings of the
Risk and Audit Scrutiny Committee to 29 September 2026
be noted. 
[Reference: Minutes 25 June 2025 (Paragraph 8)]
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13 Urgent Business 
There were no items of urgent business. 
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Report
Agenda Item 
Report to: Risk and Audit Scrutiny Committee
Date of Meeting: 9 December 2025 
Report by: Executive Director (Finance and Corporate Resources) 
Subject: Internal Audit Activity Report 
1. Purpose of Report
1.1. The purpose of the report is to:- 
 update the Committee on the progress, performance and output from the Internal
Audit service in the period 1 September to 14 November 2025 
2. Recommendation(s)
2.1. The Committee is asked to approve the following recommendation(s):- 
(1) that progress with delivering the 2025/2026 Internal Audit Plan be  noted;
(2) that performance in the period to 31 October 2025, detailed in Appendix 1, be
noted; 
(3) that output from internal audit assignments completed in the period 1
September to 14 November 2025, as summarised in Appendix 2, be noted;
(4) that the proposed amendments to the Audit Plan, as set out at paragraph 4.7,
be approved;
(5) that the outline Audit Strategy and draft Data Strategy set out in appendices 3
and 4, be noted; and
(6) that the assessed level of compliance with the Global Internal Audit
Standards, as set out in Appendix 5, be noted. 
3. Executive Summary 
3.1. The Internal Audit Plan for 2025/2026 was approved by the Risk and Audit Scrutiny
Committee (RASC) in February 2025.  A copy of this plan can be found here.  Good
progress has been made with 86% of the Plan started by mid-November 2025.  A
draft report has been issued for 29%1 of assignments in the Plan.  This represents
reasonable progress at this point in the year.  The following targets have been set to
progress the Plan to ‘draft report’ stage for the remainder of the year:- 
RASC meeting Assignments to Draft Report Stage
March 2026 68% (target of 59% reported to RASC, 30
September 2025)
May 2026 100%2 (target of 100% reported to RASC,
30 September 2025)   
1 Target of 29% reported to RASC, 30 September 2025
2 This pattern of delivery reflects that the nature of some audit assignments is such that they are delivered
across the financial year and cannot be closed until the end of this period.
3
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3.2. There are no significant concerns at this point in the year around the overall
deliverability of the Plan, but there remains a significant risk around unforeseen
service demands and, potentially, wider, inherent risks around responding timeously
to team up-skilling requirements, particularly around the development of digital skills. 
These risks are mitigated by the inclusion of contingency time within the annual plan,
a focus on coaching and training and setting realistic expectations around the extent
to which data analytics can begin to be incorporated more widely within audit
assignments. 
3.3. The risk of significant, subsequent amendments to the Plan, arising from a change in
the Council’s priorities or risks, is managed by a regular re-assessment of capacity
and the content of the Audit Plan to allow incremental adjustments and reporting to
the RASC as the year progresses.   
3.4. Having provided the mandate for an internal audit service to be delivered within
South Lanarkshire Council (which includes the authority, role and responsibilities
under which Internal Audit operates), the Committee should satisfy itself that the
function is fulfilling its mandate.  One element of this is to review how the Service has
performed in the period under review. 
3.5. Performance indicators for the period to 31 October 2025 are set out in Appendix 1
alongside targets and an overall assessment as to whether it is anticipated that these
will be met by 31 March 2026.  All indicators have been included for completeness,
but some are not reported until the end of the financial year.  The table notes how
these are being progressed, in the interim, to provide assurance that all aspects of
performance are being managed. 
3.6. There are currently 4 indicators assessed as amber.  A list of these indicators and
planned corrective action is as follows:- 
Indicator Corrective Action
Number of processes where we 
use continuous control monitoring.
To be developed as part of the Fusion 
programme of testing through to 31 
March 2026.  It is anticipated that the 
target will be met.
Number of training days per 
Employee.
Formal programme in place through to 
31 March 2026, that will meet the target 
in full.
Plan completed to draft report 
stage by 30 April.
Targets to complete set are out at 3.1.  
Arrangements in place to conclude the 
Plan by 30 April 2026.
Internal Audit recommendations
followed up.
Programme of work scheduled for 
Quarter 4.  Output will be reported in 
the Annual Assurance Report 
presented to RASC in June 2026. 
3.7. Members are asked to note progress with delivering the approved Plan in the
reporting period,  and that overall performance against delivery targets is positive in
the period to 31 October 2025.   
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4. Audit Plan Output
4.1. The last progress report to the Committee was in September 2025 and reported on
work completed in the period 1 June to 31 August 2025. This report covers all work
completed in the period 1 September to 14 November 2025.   
4.2. All assignments from 1 April 2025 will be conducted in conformance with the Global
Internal Audit Standards (GIAS). Four assignments from 2025/2026 were completed
in the period to 14 November 2025.  These are as follows:- 
Audit Assignment Scope of Assignment 
Data Analytics  To explore tools to analyse data that is
gathered during an audit assignment and how
this may be presented to Council Services in
the form of management information.  
Pupil Equity Fund Risk Indicators  Extract a range of data from the financial ledger
relating to Pupil Equity Fund expenditure and
present this in a format that allows further
analysis by Education Resources using a range
of defined risk indicators.
Risk Register Review  Analysis of controls using the Institute of
Internal Auditors ‘three lines of defence’3 model.  
Audit Strategy  Development of an audit strategy that complies
with the requirements of GIAS. 
4.3. A summary of the audit output for each of these assignments is detailed in Appendix
2.  A copy of the outline Audit Strategy and draft Data Strategy is included in
appendices 3 and 4.   
4.4. The Audit Strategy seeks to provide a structured, forward-looking plan that assists
with evidencing compliance with GIAS.  It does this by setting out how the function
adds value and optimises resources, by demonstrating a focus on continuous
improvement and establishing an over-arching alignment of the Council’s
governance expectations with its organisational goals. 
4.5. The Data Strategy recognises that this is a new and emerging area setting out a
series of objectives for Internal Audit to progress the embedding of automation and
analysis of data throughout the audit process.  This draft Strategy requires to be
refined and, through time, aligned to the wider Council approach to the use of data
as this develops and matures. 
4.6. In addition to completing work across these 4 audit areas, 2 assignments were
concluded for external clients along with mid-year reports that will be presented to
the relevant external Committee or Board in November and December 2025.   
4.7. GIAS requires reconsideration of the Plan as the year progresses to ensure that it
continues to be risk-based and aligns with the organisation’s objectives.  This review,
undertaken most recently in October 2025, suggests that work in 3 separate areas
should be deferred.  The reasons for this and the proposed courses of action are set
out in the table below:- 
3 This model defines 3 separate groups as having separate roles and responsibilities for managing and
overseeing risk and can be used to inform assurance mapping exercises.  
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Assignment Audit
Days
Reason for Deferral  Proposed Action 
Financial
Sustainability 
15 Included within the scope of the
External Audit’s 2024/2025 work
and reported to RASC in
September 2025.  Further audit
work in this area would provide
no added value.  
Days transferred to
contingency.
Housing
System
20 Deferred to 2026/2027 to align
with the implementation of
HOME, the new Housing
system.  
Days transferred to
investigative
assignments.
Social Work
System 
20 Deferred to 2026/2027 to align
with the implementation of
Liquid Logic, the new Social
Work system.  
Days transferred to
contingency. 
4.8. Members are asked to note the assignments completed and closed in the period and
approve the proposal to defer three assignments and the respective, proposed
courses of action. Members are also to note the outline Audit Strategy and draft Data
Strategy as set out in appendices 3 and 4 and that a final Audit Strategy will be
presented to the Committee in March 2026. 
5. Key Findings and Recommendations
5.1. Across all the assignments concluded in the period, Council Resources have
demonstrated a good level of engagement and, where required, an action plan has
been developed and agreed to address areas for improvement.  These actions have
now been logged together with a ‘responsible owner’ and a due date.  Verbal
updates are obtained when the action falls due.  This is classed as informal follow up
and included within routine performance indicators reported to RASC.  Separately,
actions will be formally followed up to confirm that there is evidence of action being
taken, and the findings of these reviews reported to RASC throughout the year. 
5.2. Fifty internal audit actions fell due in the period to 31 October 2025.  Most of the
actions were in response to special investigation assignments. 90% have been
verbally advised as implemented on time.   
6. Emerging Risks and Issues
6.1. The annual process to review the Council’s top risks has concluded.  These revised
risks have been mapped to the approved 2025/2026 Internal Audit Plan, with 3 from
5 of the top risks (categorised as very high) within the scope of planned assignments
in 2025/2026.  A further 3  from eleven of the top risks (categorised as high) are
within the scope of planned assignments in 2025/2026. 
6.2. New and emerging risks will continue to develop as the year progresses and there
will be periodic reassessments of the Plan to ensure that it continues to be risk-
based and aligned to the organisation’s objectives.  Any proposed amendments to
the Plan will be presented to RASC for approval.
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7. Compliance and Standards Update
7.1. A report that set out the requirements and responsibilities of the new GIAS, which
was effective from 1 April 2025, was presented to this Committee on 18 February
2025.  A copy of this report can be found here. 
7.2. As an audit committee, the RASC have a key role to play in ensuring that the internal
audit function adheres to the Standards and fulfils its mandate effectively and
efficiently. The role of audit committees is set out in some detail in Domain 3
“Governance of the Internal Audit function”.  The RASC demonstrates support for the
Service by engaging constructively with Internal Audit’s findings, conclusions and
advice. 
7.3. The Code of Practice for the Governance of Internal Audit in UK Local Government
assists with the interpretation of the new GIAS.  Specifically, in relation to these
activity updates, the Committee should be satisfied that the content is such to allow
them to effectively scrutinise and challenge. 
7.4. A process to map current practice to all elements of the new GIAS is ongoing, and a
summary assessment as at November 2025 is attached in Appendix 5.  Progress in
levels of compliance can be seen in the revised and extended suite of performance
indicators.  This, together with the development of a detailed Audit Strategy,
addresses the 2 main gaps in compliance with GIAS. The outline Audit Strategy and
Data Strategy will be developed further, and a final Audit Strategy presented
alongside the proposed Audit Plan for 2026/2027 to this Committee in March 2026. 
8. Governance and Committee Engagement
8.1. The Council’s Internal Audit Manager attends all meetings of the RASC.  The
authority of the internal audit function is established through its direct reporting
relationship to the Council’s audit committee, which allows for unrestricted access. 
8.2. Arrangements are in place to allow members of the RASC to meet privately with the
Internal Audit Manager, as required by GIAS, in December 2025.  This will provide
an opportunity to offer feedback around the revised format of the activity report and
to share suggestions for areas for inclusion in the 2026/2027 Internal Audit Plan. 
8.3. Further one-to-one or group support will continue to be available to Members should
this be required to allow Members to ensure appropriate scrutiny can be undertaken
by them in their role.   
9. Employee Implications 
9.1. There have been no changes to the team in the period to 31 October 2025 and there
are no vacancies within the Service.  Training arrangements includes regular team
briefs, internal training sessions, attendance at professional body conferences and
external seminars and briefings.  Further online resources are being secured to
support the team throughout the year. 
10. Financial Implications
10.1. The Internal Audit plan for the year aligns to the budget that has been set, and
sufficient resources are in place to deliver the approved programme of audit
assignments. 
11. Climate Change, Sustainability and Environmental Implications
11.1. There are no implications for climate change, sustainability or the environment in
terms of the information contained in this report. 
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12. Other Implications
12.1. There are no other implications in terms of the information contained in this report. 
13. Integrated Impact Assessment and Consultation Requirements
13.1. There is no requirement to impact assess the contents of this report.              
13.2.   Heads of Service are consulted on each and every audit assignment. 
Jackie Taylor
Executive Director (Finance and Corporate Resources)   
14 November 2025 
Link(s) to Council Values/Priorities/Outcomes
 Accountable, effective, efficient and transparent 
Previous References
 Risk and Audit Scrutiny Committee-18 February 2025 (Internal Audit Plan Report     
2025/2026)
 Risk and Audit Scrutiny Committee-18 February 2025 (Global Internal Audit Standards
Report)
 Risk and Audit Scrutiny Committee-6 May 2025 (Internal Audit Activity Report)
Risk and Audit Scrutiny Committee- 25 June 2025 (Internal Audit Annual Assurance
Report 2024/2025)
 Risk and Audit Scrutiny Committee- 25 June 2025 (Internal Audit Activity Report)
 Risk and Audit Scrutiny Committee- 30 September 2025 (Internal Audit Activity
Report) 
List of Background Papers
 Figtree extracts of Action Plans 
Contact for Further Information
If you would like to inspect the background papers or want further information, please
contact:- 
Yvonne Douglas, Internal Audit Manager
Ext:  2618
(Tel:  01698 452618)
E-mail:  yvonne.douglas@southlanarkshire.gov.uk 
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Key Audit Performance Indicators – October 2025             Appendix 1 
Measures reported during financial year
No Area Monthly Measure Target  Actual  Status
1 Operation Number of open vacancies 0 0 
2
Operation Employees holding a qualification from a recognised CCAB
body or Institute of Internal Auditors  75%  75% 
3 Operation Number of audits completed that comply with the
requirements of Global Internal Audit Standards 100% 100% 
4 Operation Number of processes where we use continuous control
monitoring 3 1 
5 Operation Number of training days per employee 5 2 
6 Operation Plan completed to draft report stage by 30 April   100% 29% 
7 Performance  Internal Audit recommendations delivered on time 80% 90% 
8 Performance Utilisation of contingency time by 30 April 100% 38% 
9 Performance Meetings with Heads of Service during each audit 2 2 
10 Performance Planned assignments deferred to a future year to
accommodate unplanned work 0 0 
11 Performance Draft reports issued by target date  80% 100% 
12 Performance Audit assignments completed within budget days 80% 100% 
13 Performance Internal Audit recommendations followed up 80% 0% 
14 Performance Top risks covered in the audit plan on an annual basis  33% 38% 
15 Performance Number of Council Services covered by Audit Plan on an 33% 62% 
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No Area Monthly Measure Target  Actual  Status
annual basis 
16 Strategic Number of audits where objectivity or independence is
impaired 0 0 
17 Strategic Audits that align to the Council's values 100% 100% 
18 Strategic Internal Audit Manager attendance at meetings of the RASC 100% 100% 
19 Strategic Number of formal complaints about the Service 0 0 
20
Strategic  Audit Plan presented to Risk and Audit Scrutiny Committee March 2025 February
2025 
21 Strategic Annual Internal Audit Report presented to Risk and Audit
Scrutiny Committee June 2025 June 2025 
22 Strategic Audit Strategy presented to Risk and Audit Scrutiny
Committee
Ahead of
2026/2027
IA Plan
December
2025 
23 Strategic Meeting with members of the Risk and Audit Scrutiny
Committee (in private and without senior management) 1 December
2025 
Measures to be reported at the end of the financial year
No Area Monthly Measure Target  Actual  Status
24 Operation Number of key performance indicators achieved  100% March 2026 
25 Performance Planned annual audit days delivered by 30 April 100% March 2026 
26 Strategic Issue of Service questionnaires to support audit planning
process and assess levels of satisfaction with the Service March 2026 March 2026 
27 Strategic Meetings with 5  Executive Directors and Chief Executive
each financial year 1 Scheduled
Q3 
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Definition of Measures 
AREA DEFINITION 
Operation measures that assess day to day operational targets for the Service
Performance measures the effectiveness of the Service in its delivery of core objectives
Strategic measures as to how activity aligns to wider organisational objectives 
STATUS DEFINITION 
anticipate that target will not be met by 31 March 2026 
anticipate that target will be met by 31 March 2026 but some slippage that requires corrective action 
anticipate that target will be met by 31 March 2026 
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Assignments Completed 1 September to 14 November 2025         Appendix 2 
Number Assignment name Draft Issue Final Issue Audit Conclusion 
I340126 Data Analytics  23/10/2025 23/10/2025 Investigate and trial use of different IT tools with a focus on
the development of the Power BI which has been used to
present data for one audit assignment.  Power BI was found
to be helpful to visualise and analyse data but it was noted
that some other IT tools e.g. Microsoft co-pilot AI (artificial
intelligence) may provide wider benefits across the
programme of work given not all audit assignments are based
on data.  Internal Audit are part of the co-pilot accelerator
programme trialling an advanced version of the tool and have
used this to generate summaries for audit planning meetings. 
The team will continue to participate in this pilot exercise and
develop AI skills across the team. 
I350135 Pupil Equity Fund (PEF)
Risk Indicators 
31/10/2025 31/10/2025 Use of Power BI to provide a visual analysis of PEF spend. 
To be used as an initial overview with further detailed analysis
of areas of interest.  Data passed to Education Resources for
review.  
I650238 Risk Register Review  14/10/2025 14/10/2025 An analysis of the Council’s Top Risk Register controls using
the Institute of Internal Auditors 3 lines of defence model. 
Each group of controls will be mapped as part of the
2026/2027 audit planning process to identify sources of
assurance that the control is working effectively.  The
‘assurance map’ will be presented to RASC in March 2026
alongside the 2026/2027 Internal Audit Plan.
I810052 Audit Strategy  14/11/2025 14/11/2025 An outline Audit Strategy is attached in Appendix 3, and a
draft Data Strategy at Appendix 4.  See 4.4 and 4.5. 
No assignment generated an action plan 
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Internal Audit Strategy for South Lanarkshire Council   Appendix 3 
Purpose of Internal Audit 
Internal Audit is an independent assurance function that seeks to provide the Council’s
audit committee and senior management with independent and objective assurance and
consultative guidance that meets professional standards. 
Internal Audit seeks to enhance governance, risk management and control processes
within the Council to support achievement of the organisation’s objectives and its ability to
serve the public interest. 
The internal audit function aims to operate in compliance with the Global Internal Audit
Standards issued by the International Internal Audit Standards Board and endorsed by the
Institute of Internal Auditors effective from 1 April 2025. 
1. Vision
The internal audit function will be recognised as a strategic advisor, proactively
assessing risks and providing well-supported recommendations that help South
Lanarkshire Council achieve its objectives in governance, sustainability, efficiency,
and public trust. The function will promote transparency, accountability, continuous
improvement, and ethical conduct across the council. 
2. Stakeholder Expectations
Internal Audit will seek to meet stakeholder expectations which are defined as
follows:-
 Senior Management: seeks assurance that Council resources are managed
transparently and efficiently.
 Risk and Audit Scrutiny Committee: expects robust risk-based assurance, strategic
advice, and effective reporting.
 External Auditors and Regulators: require evidence of compliance with standards
and effective governance.
 Public and Partners: expect value for money, ethical conduct, and continuous
improvement. 
3. Key Challenges 
Key challenges for the team are around:-
 Delivery of core purpose alongside responding to unplanned requests for support
and assistance 
 Building expertise in emerging areas (e.g., digital transformation, new systems)
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 Enhancing the fraud prevention role in response to new legislation and emerging
threats
 Enhancing perception of the function’s role as a trusted strategic advisor, not just
a compliance unit.
 Optimise resources available through best use of technology. 
4. Strategic Objectives, Initiatives, and Key Performance Measures
Objective 1: Delivery of Core Purpose
Initiative: set interim targets for % of the Plan to draft report stage throughout the year  
 Measured by KPI 6 (Plan complete to draft report stage by 30 April)
 Measured by KPI 10 (planned assignments deferred to a future year to
accommodate unplanned work)
 Interim targets set and reported to the Risk and Audit Scrutiny Committee in routine
update reports 
Objective 2: Build Expertise in Key Risk Areas
Initiative: Develop formal training programmes for auditors in digital transformation and
new council systems (e.g., Fusion, housing, social work). 
 Measured by KPI 2 (employees holding a qualification from a recognised CCAB body
or Institute of Internal Auditors) with resulting CPD requirements 
 Measured by KPI 5 (number of training days per employee) 
Objective 3: Enhancing Fraud Prevention Role
Initiative: Develop formal training programmes for auditors in fraud prevention 
 Measured by KPI 5 (number of training days per employee) 
 Measured by delivery of fraud awareness programme (tracked and reported
separately) 
Objective 4: Enhancing Perception 
Initiative: Deliver a service that is perceived as enhancing governance, risk management
and control processes
 Measured by KPI 3 (number of audits completed that comply with the requirements
of the Global Internal Audit Standards)
 Measured by KPI 7 (Internal Audit recommendations delivered on time)
 Measured by KPI 8 (utilisation of contingency time)
 Measured by KPI 9 (meetings with Heads of Service during each year)
 Measured by KPI 19 (number of formal complaints about the Service)
 Measured by KPI 26 (issue of questionnaire to support audit planning and to assess
levels of satisfaction with the Service)
 Measured by KP 27 (meetings with Executive Directors and Chief Executive) 
Objective 5: Optimise Resource Utilisation
 Initiative: Leverage data analytics to automate routine audit tasks and improve
efficiency
 Measured by KPI 4 (number of processes where continuous control monitoring is
used) 
 Measured by KPI 5 (number of training days per employee) 
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5. Communicate the Strategy
To implement the Strategy, we will present the vision and objectives to senior
management and the Risk and Audit Scrutiny Committee. We will use internal
communications to build credibility and shift perceptions of the Service from
compliance to that of a strategic advisor. 
6. Review and Revise
Strategic objectives and initiatives will be reviewed during the annual planning
process, adjusted as required and re-communicated.  We will continue to provide
regular update reports to senior management and the Risk and Audit Scrutiny
Committee.
7. Addressing Weaknesses 
To address perceived weaknesses, we will take the following action:
 Expertise Gaps: introduce targeted training in emerging areas (e.g., digital, fraud,
cybersecurity).
 Resource Constraints: further develop the support network with other Councils to
share tools and training.
 Perception Issues: meet with Resources on a six-monthly basis to discuss our
Strategy, Plan and performance.
Alignment with Council Priorities and Standards
This strategy is fully aligned with the Global Internal Audit Standards, the council’s own
Mandate and Charter, and the priorities set out in the annual Audit Plan. It supports the
council’s objectives of accountability, efficiency, and continuous improvement, and ensures
the internal audit function remains independent, well-resourced, and strategically focused. 
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Data Strategy          Appendix 4 
Mission: To further embed the use of automation and analysis of data throughout the
audit process.   
Our objective is to make Internal Audit more efficient and enhance our performance: 
 by changing the “way” we audit (moving away from time intensive / small sample
review / site visits / need to copy individual back-up documentation to desk based
100% testing – quickly and easily providing more accurate assurances and requiring
less time to perform the audit work / write up findings and working papers etc).
 by changing how we “prepare” our audit plans (by using artificial intelligence (AI)
to provide succinct audit planning documents that provide intelligent identification of
risk areas meaning we spend less time on the administration associated with
preparing audit plans)
 by changing how we “report” (keeping written reports short and succinct, with the
key output being presented in visual format, when relevant).  
 by improving the quality of our data and in turn improve the quality of our
output (at all stages - plans, audit findings, reports) 
 by supporting clients better (in terms of more targeted audit recommendations,
availability of new management information, more dynamic data, better 100%
assurances) 
To do this, we will extract / analyse / provide data to clients on: 
 an individual / one-off basis – as required as part of individual reviews / audits
 a continuous basis (making best use of Oracle Fusion and IDEA) 
This data will be relevant and meaningful as well as complete and accurate.  We will
analyse this data competently and ensure personal, sensitive and confidential data is
sufficiently protected and safeguarded.
We will use the data to provide: 
 improved business intelligence - greater insight / identify any strategic emerging
issues 
 directions for audit testing - to target our testing better / expand our audit sample 
The key benefits to our audit clients will be: 
 added value by taking the client’s raw data and turn it into meaningful management
information that supports the client’s own local analysis
 improved value from testing to obtain assurances / identify risks
 provision of data and output in new “dynamic” ways (such as dashboards
instead of traditional appendices) 
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GIAS Compliance Assessment Checklist            Appendix 5 
Purpose: This checklist is designed to assess compliance with the Global Internal Audit Standards (GIAS). It covers the five domains 
and fifteen principles, providing a structured approach to evaluate adherence, identify gaps, and plan corrective actions. 
Domain/Principle Requirement Evidence Status 
Domain 1: Purpose,
Authority, and Responsibility 
Principle 1 – Purpose of
Internal Audit
Is the internal audit function
clearly defined in the charter?
Does it align with
organisational objectives?
Internal Audit Mandate and Charter sets out the purpose
of the internal audit function.  This was presented to
RASC in February 2025. 
This document also confirms that Internal Audit seeks to
enhance governance, risk management and control
processes within the Council to support achievement of
the organisation’s objectives and its ability to serve the
public interest.
C
Domain 1: Purpose,
Authority, and Responsibility 
Principle 2 – Independence
and Objectivity
Is the internal audit function
independent from
management? Are
safeguards in place to
maintain objectivity?
The Internal Audit Mandate and Charter sets out the
purpose of the internal audit function and states that
Internal Audit is an independent assurance function. 
The internal audit function operates within a position of
organisational independence with a direct accountability to
the Council’s Risk and Audit Scrutiny Committee. 
Internal Audit is located within Finance and Corporate
Resources, under the direction of the Proper Officer, the
Executive Director Finance and Corporate Resources.   
The Chief Internal Auditor is positioned at a level in South
Lanarkshire Council that enables an internal audit service
and responsibilities to be performed without interference
from management and establishes the idependence of the
internal audit function. 
The Chief Internal Auditor reports directly to the Risk and
C
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Audit Scrutiny Committee. This Committee serves as the
audit committee for South Lanarkshire Council and
independently provides assurance on the soundness of
the Council’s control environment and the adequacy of
governnace and risk management frameworks. 
The Chief Internal Auditor has direct access and reports
administratively to the Executive Director Finance and
Corporate Resources, the Proper Officer, as defined in
Section 95, Local Government Act 1973, meeting with this
officer on a regular one to one basis. 
This relationship is the escalation route for issues arising
within Internal Audit and for those matters where it is
appropriate for the Chair of the Risk and Audit Scrutiny
Committee to be briefed.    
The Chief Internal Auditor also has direct access to the
Council’s Monitoring Officer and will use this route to
report as appropriate. 
The Chief Internal Auditor confirms to Risk and Audit
Scrutiny Committee on an annual basis that the internal
audit function is organisationally independent.  Any factors
that impact on independence will be disclosed to the Risk
and Audit Scrutiny Committee along with any issues
encountered relating to a limitation of scope, performance
or communication of internal audit findings and
conclusions.   
Within South Lanarkshire Council, the Employee Code of
Conduct provides guidance on the type and nature of
interests that should be declared (including paid
employment outside the Council and personal interests in
contracts). Auditors declare any interests in accordance
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with the Code of Conduct and with regard to the audit
principle of independence, notifying the Chief Internal
Auditor of any conflicts of interest which may arise.  This
formal declaration is required to be renewed on an annual
basis but is revisited should any conflicts arise. 
This disclosure extends to any impairments of
independence either actual or perceived with an
expectation that internal auditors act with profesional
objectivity in all aspects of the audit engagement, that this
results in balanced assessments that considers all facts
and circumstances and avoids bias and undue influence. 
The Chief Internal Auditor is required to report to the audit
committee and senior management any potential
impairments to independence.
Domain 1: Purpose,
Authority, and Responsibility 
Principle 3 – Professional
Responsibility
Are auditors adhering to
ethical standards and
professional conduct?
Employees are required to accept the terms of the
Council’s Code of Conduct as a condition of employment. 
The Internal Audit team (qualified and part qualified) are
members of various professional accountancy bodies with
a requirement to adhere to ethical standards and
professional conduct. 
A structured programme of training is in place. 
Within South Lanarkshire Council, the Employee Code of
Conduct provides guidance on the type and nature of
interests that should be declared (including paid
employment outside the Council and personal interests in
contracts). Auditors must declare their interests in
accordance with the Code of Conduct and with regard to
the audit principle of independence, notify the Chief
Internal Auditor of any conflicts of interest which may
arise.  This formal declaration is required to be renewed
C
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on an annual basis but is revisited should any conflicts
arise. 
This disclosure extends to any impairments of
independence either actual or perceived with an
expectation that internal auditors act with profesional
objectivity in all aspects of the audit engagement, that this
results in balanced assessments that considers all facts
and circumstances and avoids bias and undue influence.
Domain 2: Governance 
Principle 4 – Governance
Structure
Is there clear oversight by the
board or audit committee?
The Executive Director Finance and Corporate Resources
and the Chief Internal Auditor seek to maintain sound
working relationships with appropriate elected members
and ensure that good channels of communication are
maintained.   
The audit committee discuss with the Chief Internal
Auditor, the function’s mandate in terms of its role,
responsibility, scope and services and review and approve
the Internal Audit Mandate and Charter on an annual
basis. 
Members of the Risk and Audit Scrutiny Committee and
the Chief Internal Auditor are able to meet privately.  
Internal Audit report all findings from concluded
assignments via progress reports to the Risk and Audit
Scrutiny Committee.  Lines of communication between the
Chairs of all Committees and the Chief Internal Auditor is
open at all times. 
All elected members are free to raise concerns directly
with the Chief Internal Auditor and input to the Internal
Audit Charter and audit plan.  Areas suggested for
inclusion in the audit plan are assessed in terms of risk
prior to any audit work being undertaken. 
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Enquiries from elected members follow the Council’s
protocols and guidance. 
The Risk and Audit Scrutiny Committee approve a risk-
based internal audit plan on an annual basis having
satisfied itself around the adequacy of budgets,
qualifications and competencies of the internal audit
function and of the Chief Internal Auditor to deliver the
plan. 
The Committee satisfy itself that a quality assurance and
improvement programme has been established and
review the results of the quality assurance and
improvement programme on an annual basis. 
The Risk and Audit Scrutiny Committee seek assurances
that there has been no limitation in scope or resources
and receive regular updates in relation to performance to
allow this to be assessed relative to the function’s
objectives and individual roles and responsibilities.
Domain 2: Governance 
Principle 5 – Board
Oversight
Does the board approve the
audit plan and monitor
performance?
The audit committee discusses with the Chief Internal
Auditor the function’s mandate in terms of its role,
responsibility, scope and services and reviews and
approves the Internal Audit Mandate and Charter on an
annual basis. 
The Risk and Audit Scrutiny Committee approves a risk-
based internal audit plan on an annual basis having
satisfied itself around the adequacy of budgets,
qualifications and comptencies of the internal audit
function and of the Chief Internal Auditor to deliver the
plan. 
Any factors that impact on independence are disclosed to
the audit committee along with any issues encountered
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relating to a limitation of scope, performance or
communication of internal audit findings and conclusions. 
The Risk and Audit Scrutiny Committee seek assurances
that there has been no limitiation in scope or resources
and receive regular updates in relation to performance to
allow this to be assessed relative to the function’s
objectives and individual roles and responsibilities. 
A suite of performance measures are reported at each
meeting of the audit committee and to senior management
as part of the annual reporting process. 
Domain 2: Governance 
Principle 6 – Organisational
Alignment
Is internal audit integrated
into governance processes?
Internal Audit within South Lanarkshire Council forms part
of the Council’s wider governance framework.  Output
from the function is the delivery of a planned programme
of internal audit assignments.  Each assignment is
formally reported to the Council’s Risk and Audit Scrutiny
Committee and, from 1 April 2025, an ‘assignment
conclusion’ (previously an ‘audit opinion’) expressed
based on the level of assurance that testing has provided. 
These assurances, in turn, inform an overall assessment
of the adequacy and effectiveness of the Council’s
framework of governance, risk management and control
arrangements that is reported annually to the Corporate
Management Team and the Risk and Audit Scrutiny
Committee and captured within the Council’s Governance
Statement that forms part of the Annual Accounts.
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Domain 3: Managing the
Internal Audit Function 
Principle 7 – Internal Audit
Strategy
Is there a documented
strategy aligned with
organisational goals?
A process to map current practice to all elements of the
new GIAS is ongoing and the final key documents, a
formal outline Audit Strategy is attached at Appendix 3
and a draft Data Strategy at Appendix 4.  These will be
developed further and presented alongside the proposed
Audit Plan for 2026/2027 in early 2026.   
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Action: Final Audit Strategy to be presented alongside
the 2026/2027 Internal Audit Plan (March 2026).
Domain 3: Managing the
Internal Audit Function 
Principle 8 – Resource
Management
Are resources adequate and
appropriately skilled?
No resourcing constraints that would prevent delivery of 
the Audit Plan. 
Training includes regular team briefs, internal training 
sessions, attendance at professional body 
conferences and external seminars and briefings.
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Domain 3: Managing the
Internal Audit Function 
Principle 9 – Quality
Assurance and Improvement
Is there a QAIP (Quality
Assurance and Improvement
Programme)?
Quality Assurance and Improvement Programme has
been developed and is reported as part of the Internal
Audit assurance report.
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Domain 4: Performing
Internal Audit Services 
Principle 10 – Engagement
Planning  
Are objectives, scope, and
criteria clearly defined?
Standard audit remit template that sets out a review of
governance, risk management and control processes; the
audit objective and scope; testing and sample details;
arrangements for the reporting of findings; Audit Staff who
will deliver the audit; liaison arrangements; audit
timescales and budget.
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Domain 4: Performing
Internal Audit Services 
Principle 11 – Engagement
Execution
Are audits conducted in
accordance with standards?
Compliant processes have been developed.  Audit
assignments are planned; risk-based approach and
methodology developed; sufficient fieldwork and evidence
gathered; clear reporting protocol in place; follow up and
monitoring arrangements established and continuous
improvement promoted. 
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Domain 4: Performing
Internal Audit Services 
Principle 12 – Evidence and
Documentation
Is sufficient, appropriate
evidence maintained?
Electronic audit files are retained for all assignments. C
Domain 5: Communicating
Results and Monitoring
Progress 
Principle 13 – Reporting
Are reports clear, accurate,
and timely?
Reports are subject to review before issue.  Target
timescales track timeous issue.  Standard format for all
audit reports.
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Domain 5: Communicating
Results and Monitoring
Progress 
Principle 14 – Follow-up and
Monitoring
Are corrective actions tracked
and verified?
All actions are logged in a database.  Actions are logged 
together with a ‘responsible owner’ and a due date.  
Verbal updates are obtained when the action falls due.
This is classed as informal follow up and included within 
routine performance indicators reported to 
RASC.  Separately, actions are formally followed up to 
confirm that there is evidence of action being taken and 
the findings of these reviews reported to RASC throughout 
the year.
C
Domain 5: Communicating
Results and Monitoring
Progress 
Principle 15 – Continuous
Improvement
Is there a process for
ongoing improvement? There is ongoing evaluation of performance (performance
indicators); a Quality Assurance and Improvement
Programme has been developed; emerging risks are
evaluated throughout the year; best practices in audit
processes are identified and implemented; promotion of
continuous professional development for audit staff and 
stakeholder engagement to review expectations and
alignment with organisational objectives and governance
requirements.
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Report
Agenda Item 
Report to: Risk and Audit Scrutiny Committee
Date of Meeting: 9 December 2025
Report by: Executive Director (Finance and Corporate Resources)  
Subject:    Accounts Commission 2025 – Scrutiny, Governance and
Transparency of Decision Making of Exit Packages of
Senior Officers 
1. Purpose of Report
1.1. The purpose of the report is to:- 
 provide an update to the Risk and Audit Scrutiny Committee on a letter recently
issued by the Accounts Commission to all councils in relation to the scrutiny,
governance and transparency of decision making of exit packages of senior
officers, and provide a summary of the Council’s position on the 5
recommendations the Accounts Commission makes in relation to exit packages
related to senior officers 
2. Recommendation(s)
2.1. The Committee is asked to approve the following recommendation(s):- 
(1) that the contents of the report be noted; and
(2) that the next steps detailed in section 6, be noted.
[1recs]
3. Background
3.1. Since the late 1990s, a number of reports have been published by the Accounts
Commission for Scotland and Audit Scotland on the management of early retirements,
with a view to ensuring that public sector organisations have sufficiently robust
frameworks in place for decision making and scrutiny. These are included in the
Background Papers section for reference. 
3.2. The Accounts Commission has recently written to all councils in relation to the scrutiny,
governance and transparency of decision-making of exit packages of senior officers. 
This followed the publication of a report on Senior Officer Exit Packages at Glasgow
City Council ( link to report here  - Glasgow City Council S102 report) 
4. Accounts Commission 2025
4.1. On 8 September 2025, the Accounts Commission wrote to the Leaders and Chief
Executives of all Councils in Scotland.  The purpose of this letter was to advise that
on the 14 August 2025, the Accounts Commission considered a report from the
Controller of Audit (under powers in s102 (1) of the Local Government (Scotland) Act
1973) in relation to the scrutiny, governance and transparency of decision making of
exit packages of senior officers in Glasgow City Council (GCC). 
4
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4.2. The Commission advises that it considered carefully the most appropriate way to use
the powers available to it, including holding a hearing, making recommendations to
Scottish Ministers or censuring in light of the concerning issues presented in the report.
On this occasion, alongside publishing findings, the Commission states that it is vital
that all councils take action to recognise the important learnings from this report. The
Commission expects that the letter issued to councils and the issues they note that
the report highlights, would be discussed by Councils’ Risk and Audit and Scrutiny
Committee and that steps would be taken to review its Scheme of Delegation and
decision-making processes. 
4.3. The Commission also recognised that as councils continue to face financial
challenges, service redesign and restructuring are key tools available to councils to
respond to these challenges. However, transparency and good governance around
decision-making were essential. 
4.4. The Commission is clear that decisions of elected members and officers should uphold
the 9 Key Principles of Public Life in Scotland – selflessness, integrity, objectivity,
accountability, openness, honesty, leadership, public services, respect. Key Principles
of Public Life | The Standards Commission for Scotland 
4.5. The Commission stated that where decisions around restructuring and exit packages
are being taken, councils must ensure there is clear evidence of effective governance,
independent scrutiny, and value for money, as well as robust and transparent record
keeping. The lessons learned from GCC have been considered in light of the  5 key
recommendations set out in a previous Audit Scotland report (2003).  These have
been adapted by the Commission for today’s context:-  
1. Frameworks for decision-making: policies in relation to the exit packages of
senior officers should be approved by councillors and reviewed regularly. 
2. Informing councillors: councillors should receive a report at least annually that
details the number of early retirals, and redundancy decisions made in the year,
along with the associated costs and savings attached to these decisions. 
3. Decision-making: councils should rigorously appraise individual business cases
to ensure the expected savings associated with a retiral or redundancy outweigh
the costs, ensuring value for money. 
4. To improve accountability and assist in monitoring, the costs of early retirement
should be charged to the appropriate service budget. 
5. Elected members should be involved in approving early retirement and
redundancy decisions for senior staff, providing the independent scrutiny that is
essential to issues and decisions where there are potential conflicts of interest. 
4.6. The Council’s position on the adapted recommendations is detailed in section 5. 
4.7. All councils were urged to take action now to ensure that officers and members are
familiar with the Key Principles of Public Life and that they could evidence that their
organisation's culture respects and fully supports them.  
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5. Council Position
5.1. As a result of previous Audit Scotland reports on Early Release, the following
recommendations were approved at the Executive Committee on 12 September
2012:- 
 that Reports regarding early retirement/voluntary severance of all Chief
Officers/Statutory Officers would be presented to the Executive Committee for
approval
 these reports would include information on the rationale for early release and any
consequential implications, including financial implications, which will allow the
Executive Committee to decide on the appropriateness of the proposals  
 to accommodate this, a change is required to be made to the Council’s Scheme
of Delegation 
5.2. The Council is compliant with the position recommended by the Commission (included
at 4.5):- 
1. Framework for decision-making : 
All personnel policies are approved at the Committee and reviewed on a regular basis;
this includes policies in relation to exit packages relating to all employees including
senior officers. 
Any early retirement/voluntary severance of any Chief Officer/Statutory Officer would
require to be presented to the Executive Committee for approval. 
2. Informing Councillors:
The Council reports on a 6 monthly basis to Finance and Corporate Committee on all
early retirement, voluntary severance and SWITCH2. 
There have been no early retirement or redundancy payments made to any officers in
the last 6 years 
3. Decision Making:
Any service review that results in structures changing and posts being removed,
resulting in early release, would be presented to the appropriate Resource or
Executive Committee. In addition, the 6-monthly report to Finance and Corporate
Committee would include details of one-off and recurring employer costs, however,
there have not been any recent costs to report.   
4. Accountability/Monitoring:
Any business case and decision relating to early departures of Chief Officers/Statutory
Officers (Described as senior officers by the Accounts Commission) would be required
to be approved by Councillors at Committee, and any costs associated with this would
be reported and charged to the appropriate service budget. 
There have been no arrangements agreed for early retirement or voluntary severance
since 2019. 
5. Elected Member Oversight:
This scrutiny exists through reports and approvals at the Committee, as summarised
above.  
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5.3. In summary, reports regarding any structure changes which result in early
retirement/voluntary severance of all Chief Officers/Statutory Officers would be
presented to the Executive Committee for approval.   These reports would include
information on the rationale for early release and any consequential implications,
including financial implications, which will allow the Executive Committee to decide on
the appropriateness of the proposals.   
6. Next Steps
6.1. To demonstrate that the council continues to meet the recommendations outlined in
paragraph 4.5, the following next steps are proposed:- 
 the Council will continue to review any requirement to change existing policies,
and any change would be reported to the Committee for approval 
 a personnel circular will be issued to all employees, reminding them of the
Principles of Public Life 
 that the Principles of Public Life are included in Elected Member and Employee
Induction programmes and are circulated on an annual basis with the Employee
Code of Conduct.  These will be updated by January 2026 
 as per the Scheme of Delegation, all requests for early retirement / voluntary
severance for Chief Officers and Statutory Officers must be presented to
Executive Committee for decision/approval   
 any request for early release/early severance must demonstrate clear evidence
of effective governance, independent scrutiny, and provide evidence of value for
money, as well as robust and transparent record keeping 
7. Employee Implications
7.1. As covered earlier in the report, this paper clarifies that for Chief Officers and Statutory
Officers, any early release must be approved by elected members.   
8 Financial Implications
8.1. There are no direct financial implications from this report. 
9 Climate Change, Sustainability and Environmental Implications
9.1. There are no climate change, sustainability or environmental associated with this
report. 
10. Other Implications
10.1. There are no other implications associated with this report. 
11. Integrated Impact Assessment and Consultation Requirements
11.1. This report does not introduce a new policy, function or strategy or recommend a
change to an existing policy, function or strategy and, therefore, no impact assessment
or consultation is required.  
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11.2 There is no requirement to consult with the Trade Unions. 
Jackie Taylor
Executive Director (Finance and Corporate Resources) 
3 November 2025 
Link(s) to Council Values/Priorities/Outcomes
 Accountable, effective, efficient, and transparent
 Fair, open, and sustainable
 Ambitious, self-aware, and improving 
Previous References
 None 
List of Background Papers
 1997- Accounts Commission for Scotland; Bye Now, Pay Later? report
 2003 - Accounts Commission for Scotland; Bye Now, Pay Later? A follow up review of the
management of early retirement report.
 May 2013 - Audit Scotland; Managing departures from the Scottish public sector report 
 November 2013 - Audit Scotland; Scotland’s public sector workforce report
 September 2012 Early Retirement and Voluntary Severance Authorisation Process,
Executive Committee 
List of Appendices
 None 
Contact for Further Information
If you wish to inspect the background papers or want further information, please contact:-
Michelle Milne, Head of Personnel Services
Ext:  4330 (Tel:  01698 454330)
Email: michelle.milne@southlanarkshire.gov.uk 
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Report
Agenda Item 
Report to: Risk and Audit Scrutiny Committee  
Date of Meeting: 9 December 2025
Report by: Executive Director (Finance and Corporate Resources) 
Subject: Fraud Statistics Six Monthly Update 2025/2026 
1. Purpose of Report
1.1. The purpose of the report is to:- 
 provide a summary of the fraud statistics for the six months to 30 September
2025 and a comparison to the same period in 2024
 provide an update on the progress of other fraud awareness activity and anti-
fraud work 
2. Recommendation(s)
2.1. The Committee is asked to approve the following recommendation(s):- 
(1) that the contents of this report be noted. 
3. Background
3.1. Collating and reporting fraud statistics and setting targets for improvement are
considered best practice by the Chartered Institute of Public Finance and
Accountancy (CIPFA) and the Association of Local Authority Risk Managers
(ALARM).   
3.2. This report provides information on the number, types and outcomes of fraud
investigations within South Lanarkshire Council (SLC) for the 6 months to  30
September 2025, together with a comparison to the statistics for the same period in
2024, where available.  It includes all frauds reported to Internal Audit, benefit frauds
during this period passed to the Department for Work and Pensions (DWP) for
investigation and insurance losses resulting from a failure in internal controls or
which have been investigated by Internal Audit.  It also contains information on other
work being undertaken by Internal Audit in relation to fraud prevention. 
3.3. Although responsibility for housing benefit fraud investigations has transferred to the
DWP Fraud and Error Service (FES), SLC retains responsibility for the recovery of
fraud overpayments from its own Housing Benefit claimants.  Housing Benefit fraud
data will therefore continue to be included within the fraud statistics reported, as
information is provided by FES.    
5
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3.4. Benefits and Revenue deliver an annual programme of rolling reviews on Housing
Benefit claimants based on risk-profiling to establish the most likely areas of benefit
fraud or overpayment.  Information is also obtained from HMRC through the
Verification of Earnings and Pensions arrangement, from DWP through the Housing
Benefit Matching Service and from data gathered through the National Fraud
Initiative (NFI).  Where fraud is suspected, the case will be passed to FES for
investigation and, if proven, returned to SLC to pursue recovery.  Irrespective of
whether a fraud is proven or not, the Council takes steps to recover any
overpayment. 
4. Results
4.1. All concerns reported to Internal Audit are risk assessed, with high-risk areas
investigated by Internal Audit, medium risks investigated by Resources and low risks
registered for monitoring of trends.  Internal Audit may also undertake joint
investigations with Resources and the Fact-Finding team within Personnel Services
depending on the nature of the fraud and the level of operational knowledge
required. 
4.2. Areas within the Council that have an inherently higher risk of fraud are considered
for inclusion in the annual Audit Plan.  There have been no new patterns or trends
identified in the first 6 months of 2025/2026. 
4.3. An analysis of the fraud caseload for the six months to 30 September 2025 and the
comparative period in 2024 is detailed in Table 1. 
Table 1 - Fraud Caseload
Status
Six Months to
30/09/25
Six Months to
30/09/24 
Nos. £000 Nos. £000
Cases open as of 1 April  24 5 171 44
Concerns reported during financial year   11 49 271 8
SLC caseload for the year    35 54 198 52
Cases closed in period (see Table 2) 15 1 13 14
Work in progress at 30 September    20 53 185 38 
4.4. DWP referrals made to the Council have been excluded from Table 1 to ensure data
reflects only the SLC-managed element of the caseload.  A further 19 SLC
investigations are currently being progressed by the DWP with a potential cumulative
housing benefit overpayment/fraud value of around £7k.  On conclusion of
investigations, if required, SLC will seek repayment in line with standard recovery
procedures. 
4.5. Concerns reported in the first 6 months were relatively low, with cases coming
primarily from suspected benefit fraud.   
1 includes one case where work to ascertain value is still in progress 
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4.6. An analysis of closed cases in the year is detailed in Table 2:- 
Table 2 - Analysis of Closed Cases 
Source of fraud
Six Months to 
30/09/25
Six Months to 
30/09/24 
Nos. £000 Nos. £000
Founded allegation (see Table 3) 3 0 10 7
Insufficient information 7 1 1 0
Unfounded allegations 5 0 2 7
Total 15 1 13 14 
4.7. An analysis of founded allegations is detailed in Table 3:- 
Table 3 – Analysis of Founded Allegations
Source of fraud
Six Months to 
30/09/25
Six Months to 
30/09/24 
Nos. £000 Nos. £000
External  3 0 10 7
Internal  0 0 0 0
Benefits 0 0 0 0
Total 3 0 10 7 
5. Wider Fraud Workload
5.1. Time spent on and outcomes from investigative work are monitored throughout the
year.  Services work with the Security Coordinator or with Internal Audit to review
and address gaps in controls identified during the investigation of cases.  Where
appropriate, improvement plans are agreed with the relevant Heads of Service and
the actions followed up by Internal Audit to ensure implementation. Outcomes for
concluded investigations are reported to the Risk and Audit Scrutiny Committee as
part of routine activity reports and included in Internal Audit’s annual assurance
report.   
5.2. Aside from time to respond to potential frauds, there is a wider programme of anti-
fraud activity that runs across the year to proactively manage the risk of fraud. 
Interim updates in relation to these other areas are set out in paragraphs 5.3 to 5.15
below. 
Fraud Awareness Programme
5.3. A fraud awareness programme has been developed which aims to focus the
attention of all employees on the increased risks of fraud, their responsibilities and
the need for daily vigilance and action.  To date, the following actions have been
completed in 2025/2026:- 
 the Conflict of Interest policy has been re-issued 
 a fraud presentation has been delivered to the Risk Sponsors Group
 fraud risk registers have been updated
 a Personnel Circular has been issued providing an update on the NFI exercise 
5.4. A series of communications to SLC employees are the final actions in this
programme for 2025/2026.  These communications are a range of short anti-fraud
updates and messages to be conveyed across the remainder of the financial year.
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5.5. All of this activity forms part of a wider response to the new corporate criminal
offence of ‘failure to prevent fraud’.  A plan has been developed to mitigate legal and
reputational risks attached to non-compliance with the legislation and good progress
is being made with implementing actions.  
5.6. A full update on progress will be provided in the 2025/2026 annual fraud report. 
Fraud Alerts 
5.7. Internal Audit monitors fraud alerts through internal and external sources and
disseminates information as appropriate.  In 2025/2026 these have continued to
relate to ad-hoc issues and have been shared with Council Resources as
appropriate with action taken where required. 
Lessons Learned Exercises 
5.8. External auditors are required to report significant frauds, or suspected frauds, to
Audit Scotland, where they were caused or facilitated by weaknesses in public
bodies’ internal controls.  Frauds and irregularities are considered significant where
the value of the loss is over £5,000 or where it is of significance owing to the nature
of the activity. 
5.9. Audit Scotland routinely report these frauds within technical bulletins which also
includes detail around improvements to controls to prevent similar frauds occurring.
Bulletins are reviewed and cases shared with relevant Services to assess whether
controls require amendment. 
5.10. The most recent bulletin shared a fraud in relation to a third party impersonating a
foreign supplier to commit a bank mandate fraud which resulted in the public body
paying £34,000 to a fraudulent bank account.  Standard processes are in place to
validate any change in bank account details within SLC.  Details of the case have
been shared with Finance (Transactions) Services to act as a reminder and raise
awareness. 
5.11. The second case was in relation to an employee who received £12,000 of salary to
which they were not entitled as they were paid a full-time salary for a part-time post. 
Details of this case have been shared with Personnel Services to review and
respond, if required. 
Comparison of Fraud Risk Arrangements to Best Practice
5.12. On an annual basis, the Council subscribes to the National Anti-Fraud Network
(NAFN), a UK-based organisation that provides data and intelligence services to
support public sector bodies in tackling fraud, safeguarding, and regulatory
compliance. 
5.13. In the summer of 2025, SLC participated in a UK-wide survey which aimed to
“provide a clear view into a rapidly evolving and increasingly complex and
challenging (fraud) environment (and to offer) a foundation for informed, evidence-
based action”.   
5.14. The output from this survey highlights a significant increase in fraud case volumes
over the past 5 years, estimating £265 million in detected fraud nationally for
2024/2025 (based on survey extrapolation).  Average fraud case values were noted
as falling, suggesting a rise in lower-value but higher-volume frauds. 
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5.15. Tenancy, procurement and council tax fraud were noted as remaining the highest-
value categories. 
5.16. A report on the survey has been published, and a summary will be included in the
2025/2026 annual fraud report presented to this Committee, along with any required
actions.   
6. National Fraud Initiative
6.1. Aside from internal reviews, the Council also participate in the NFI, a UK-wide data
matching exercise led by the Cabinet Office and Audit Scotland to detect and
prevent fraud across public sector organisations.   
6.2. The Council, on a biennial basis, uploads a series of pre-defined datasets.  These
datasets are then matched against the same datasets uploaded by all participating
bodies, with a ‘match’ indicating a case that requires review and which may,
potentially, be fraudulent. 
6.3. Participating bodies receive a high level of matches and, from this, select a series of
target matches that are determined on the basis of high risk, fraud risk and outcomes
from previous years.  Within SLC, these are then issued to relevant Services for
investigation. 
6.4. At 30 September 2025, a total of 34,547 matches have been received.  Progress
with investigations is shown in Table 4, which is being regularly monitored by Internal
Audit.  All target investigations are anticipated to be completed by the deadline of 31
March 2026. 
Table 4 – NFI Investigation Progress 
Category Total
matches
Target
matches
Progress on
matches
investigated
Housing Benefits 130 91 74
Payroll 115 111 89
Creditors 1,242 316 116 #
Housing Tenants 1,225 474 379
Housing Waiting List 670 231 201
Council Tax Reduction 2,592 493 355
Blue Badges 1,365 1,365 333
Procurement 39 39 10 #
Small Business Bonus Scheme (SBBS) 166 166 0 #
Single Person Discount 27,003 638 * 102 #
Total 34,547 3,924 1,659 
# Investigation work has commenced but not finalised/NFI website to be updated 
* Target will be increased following a review by Datatank, a contractor employed by the Council to undertake
rolling reviews 
7. Employee Implications
7.1. SLC has a zero-tolerance approach to fraud. Manager and employee roles and
responsibilities are set out in SLC’s Counter Fraud, Bribery and Corruption Policy.
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8. Financial Implications
8.1. The investigation of fraud, participation in the NFI exercise and the collection and
reporting of fraud statistics is carried out within existing resources.  The 2025/2026
Internal Audit Plan includes 165 days to manage the NFI exercise, disseminate fraud
alerts, update fraud risk registers and undertake anti-fraud assignments and fraud
investigations.   
9.  Climate Change, Sustainability and Environmental Implications 
9.1.  There are no implications for climate change, sustainability or the environment in
terms of the information contained in this report. 
10. Other Implications
10.1. Fraud risk is recognised as one of the top risks facing SLC.  This risk is significant as
it can adversely affect the delivery of Council objectives and erode valuable
resources.  It is therefore important that the risk of fraud is soundly managed.  Fraud
Risk Registers are in place within all Resources and are reviewed and updated
annually in line with standard Risk Management procedures.  Periodic self-
assessment exercises against good practice guidance in fraud management inform
these updates. 
10.2. The Council’s Serious and Organised Crime (SOC) working group progress delivery
of various anti-fraud actions, revising whether any new or emerging threats are
identified through the pan Lanarkshire Multi Agency SOC Group.  This Group met in
May 2025 for a workshop, and plans to articulate the next steps that are being
developed.   A high-level summary will be included within fraud statistics reports. 
10.3. The collection and reporting of fraud statistics assist in the management of fraud by
identifying patterns and trends of fraud and areas of high risk where preventative
controls should be concentrated. However, in order to do this effectively, fraud
statistics must be complete.  Internal Audit will continue to highlight areas where
practice could be improved to ensure that all instances of potential and actual fraud
are reported to Internal Audit.   
11. Integrated Impact Assessment and Consultation Requirements
11.1. There is no requirement to undertake an impact assessment. 
11.2. Consultation was not necessary for this report. 
Jackie Taylor
Executive Director (Finance and Corporate Resources) 
14 November 2025 
Link(s) to Council Values/Priorities/Outcomes
 Accountable, effective, efficient and transparent 
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Previous References  
 Risk and Audit Scrutiny Committee-18 February 2025 (Fraud Statistics Six Monthly
Update)
 Risk and Audit Scrutiny Committee-25 June 2025 (National Fraud Initiative Exercise
-2022) 
 Risk and Audit Scrutiny Committee-30 September 2025 (Fraud Statistics 2024/2025
Annual Report) 
List of Background Papers
 None 
Contact for Further Information
If you would like to inspect the background papers or want further information, please
contact:- 
Yvonne Douglas, Internal Audit Manager
Ext:  2618  (Tel:  01698 452618)
E-mail:  yvonne.douglas@southlanarkshire.gov.uk 
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Report
Agenda Item 
Report to: Risk and Audit Scrutiny Committee
Date of Meeting: 9 December 2025
Report by: Chief Executive  
Subject: Performance and Review Scrutiny Forum Annual
Update 
1. Purpose of Report
1.1. The purpose of the report is to:-
[purpose]
 provide, for information, a summary of the reports considered by the Performance
and Review Scrutiny Forum during the period January to December 2025
[1purpose]
2. Recommendation(s)
2.1. The Committee is asked to approve the following recommendation(s):-
[recs]
(1) that the content of this report be noted.
[1recs]
3. Background
3.1. The Terms of Reference and Powers and Responsibilities for the Performance and
Review Scrutiny Forum includes consideration of the Council’s response to Best
Value, improvement and performance management. 
3.2. The details within this report provide the Risk and Audit Scrutiny Committee with a
summary of business reported to the Performance and Review Scrutiny Forum. 
4. Agenda Items
4.1. The table below notes the reports submitted to the Performance and Review Scrutiny
Forum during 2025 under the main areas of responsibility. 
Date Report
4 February   Audit Scotland: Delivering for the Future – why Leadership
Matters
 Audit of Best Value – reports on City of Edinburgh,
Clackmannanshire and Scottish Borders councils
 Transformational Reviews – update
 Transformational Reviews – forward reporting programme
1 April  Local Government Benchmarking Framework 2023/2024
results and action plan
 Statutory Performance Information Direction 2024
 Audit of Best Value – reports on Western Isles, Fife, and
Renfrewshire councils
 Transformational Reviews – update
 Third Sector Partnership review
17 June  Audit of Best Value – reports on Highland Council and Argyll
and Bute Council
6
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 Transformational Reviews - update
 Property Services – Efficiencies and Income Generation
 Fleet Management
 Digital Transformation – update
 Customer Engagement Transformational Review - update
19 August  Council Plan Connect Quarter 4 progress report 2024/2025
 Annual Performance Spotlights 2024/2025
 Audit of Best Value – reports on East Lothian and Renfrewshire
councils
 Transformational Reviews – update
 Digital Transformation – update
 Customer Engagement Transformational Review - update     
4.2. A schedule of reporting will continue covering the key themes noted at paragraph 3.1
above.  The Risk and Audit Scrutiny Committee will be provided with an annual report
for information, advising it of the business presented to the Performance and Review
Scrutiny Forum. 
5. Employee Implications
5.1. There are no employee implications relating to this report. 
6. Financial Implications
6.1. There are no financial implications relating to this report. 
7. Climate Change, Sustainability and Environmental Implications
7.1 There are no Climate Change, Sustainability and Environmental implications relating
to this report. 
8 Other Implications
8.1. There are no risk or sustainability issues associated with the content of this report. 
9. Integrated Impact Assessment and Consultation Requirements
9.1. This report does not introduce a new policy, function or strategy or recommend a
change to an existing policy, function or strategy and therefore no impact assessment
is required. 
9.2. There is also no requirement to undertake any consultation in terms of the information
contained in this report. 
Paul Manning
Chief Executive 
25 November 2025 
Link(s) to Council Values/Priorities/Outcomes
 Accountable, effective, efficient and transparent
 Ambitious, self-aware and improving
 We will work to recover, progress and improve 
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Previous References
 None 
List of Background Papers
 Performance and Review Scrutiny Forum meetings – 4 February 2025, 1 April 2025, 17
June 2025 and 19 August 2025. 
Contact for Further Information
If you would like to inspect the background papers or want further information, please
contact:-
Tom Little, Head of Communications and Strategy
Ext: 4904 (Tel:  01698 454904)   
Email: tom.little@southlanarkshire.gov.uk
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Report
Agenda Item 
Report to: Risk and Audit Scrutiny Committee
Date of Meeting: 9 December 2025 
Report by: Executive Director (Finance and Corporate Resources)  
Subject: Forward Programme for Future Meetings 
1. Purpose of Report
1.1. The purpose of the report is to:-
[purpose]
 advise members of the forward programme for the meetings of the Risk and Audit
Scrutiny Committee to 3 November 2026, and invite members to suggest topics
for inclusion in the Committee’s forward programme
[1purpose]
2. Recommendation(s)
2.1. The Committee is asked to approve the following recommendation(s):-
[recs]
(1) that the report and the outline forward programme for the meetings of the Risk
and Audit Scrutiny Committee to 3 November 2026, attached as an Appendix
to the report, be noted.
[1recs]
3. Background
3.1. As part of a range of improvement measures introduced as a result of Audit
Scotland’s report on the Audit of Best Value and Community Planning (2009), an
Action Plan was prepared.  One of the actions was to include, as a standard agenda
item, a list of items proposed for consideration at subsequent meetings of this
Committee to provide an opportunity for members to inform future agendas.  The
outline forward programme to 3 November 2026 is attached, for members’
information, as an Appendix to the report.  
4. Employee Implications
4.1. There are no employee implications. 
5. Financial Implications
5.1. There are no financial implications. 
6. Climate Change, Sustainability and Environmental Implications
6.1. There are no Climate Change, Sustainability or Environmental implications in terms
of the information contained within this report. 
7. Other Implications 
7.1. There are no risk implications in terms of the information contained within this report.
7
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8. Integrated Impact Assessment and Consultation Requirements
8.1. The report does not introduce a new policy, function or strategy or recommend a
change to an existing policy, function or strategy and, therefore, no impact
assessment is required. 
8.2. There was no requirement to undertake any consultation in terms of the information
contained in this report. 
Jackie Taylor
Executive Director (Finance and Corporate Resources) 
19 November 2025 
Link(s) to Council Values/Priorities/Outcomes
 Accountable, Effective, Efficient and Transparent 
Previous References
 Executive Committee 8 July 2009 
List of Background Papers
 Audit Scotland Audit of Best Value and Community Planning 
Contact for Further Information
If you would like to inspect the background papers or want further information, please
contact:-
Ishara Opatha, Administration Officer
Tel:  07307385370069
E-mail:-  ishara.opatha@southlanarkshire.gov.uk 
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APPENDIX – RASC OUTLINE FORWARD PROGRAMME 
Meeting Date  Item Responsibility   
10 March 2026 Internal Audit Activity Report Audit and Compliance
Manager 
2026/2027 Internal Audit Plan Audit and Compliance
Manager 
RASC Good Governance Update
and Significant Governance Areas
Quarter 2 Progress Report 
Head of Administration and
Legal Services 
Annual Audit Plan External Audit 
26 May 2026 Internal Audit Activity Report Audit and Compliance
Manager 
2025 NFI Exercise Audit and Compliance
Manager 
Audit Scotland – Financial Bulletin
2024/2025 
Head of Finance (Strategy) 
Financial Resources Scrutiny
Forum Activity
Head of Finance (Strategy)   
23 June 2026
(Special) 
Internal Audit Assurance Report
2025/2026 
Audit and Compliance
Manager 
Annual Governance Statement for
2025/2026 and Significant
Governance Areas for Quarter 4
Progress Report 
Head of Administration and
Legal Services 
Unaudited Annual Accounts
2025/2026
Head of Finance (Strategy) 
25 August 2026 Internal Audit Activity Report Audit and Compliance
Manager 
Year End Insured Risks Report
2025/2026 
Head of Finance
(Transactions) 
Year End Risk Management Report
2025/2026 and Review of Council’s
Top Risks 2026/2027 
Head of Finance
(Transactions) 
Fraud Statistics Annual Report
2025/2026 
Audit and Compliance
Manager 
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Financial Resilience and
Sustainability Report
Head of Finance (Strategy)     
29 September 2026
(Special)
External Auditor’s Annual Report to
South Lanarkshire Council
2025/2026 
External Audit 
Audited Annual Accounts
2025/2026 
Head of Finance (Strategy) 
3 November 2026    Internal Audit Activity Report 
Audit Scotland Report: Local
Government in Scotland Overview
2025 
Audit and Compliance
Manager 
Head of Communications
and Strategy 
Annual Update on the Use of
Surveillance Powers - The
Regulation of Investigatory Powers
(Scotland) Act 2000 
Head of Administration and
Legal Services 
N.B:- Audit Scotland national studies and reviews will appear as a recurring item, but the
frequency and subject matter will vary according to their programme. 
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