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Agenda Document Pack - Audit and Scrutiny Committee - 25/06/2024

Moray Council · 25 June 2024
Back to Audit and Scrutiny Committee — 25 June 2024 and its agenda

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Audit and Scrutiny Committee 
Tuesday, 25 June 2024 
NOTICE IS HEREBY GIVEN that a Meeting of the Audit and Scrutiny Committee
is to be held at Council Chambers, Council Office, High Street, Elgin, IV30 1BX
on Tuesday, 25 June 2024 at 14:00. 
BUSINESS 
1. Sederunt 
2. Declaration of Group Decisions and Members Interests * 
3. Minute of meeting of 8 May 2024 5 - 10
4. Written Questions ** 
5. Internal Audit Annual Report - 2023-24
Report by Audit and Risk Manager
11 - 24
6. Internal Audit Section Update Report
Report by Audit and Risk Manager
25 - 50
7. Internal Audit Section - Completed Projects Report
Report by Audit and Risk Manager
51 - 66
8. Annual Governance Statement
Report by Interim Chief Executive
67 - 82
9. Local Government Benchmarking Framework 2022-23
and 2021-22 Results
Report by Depute Chief Executive (Education, Communities and
Organisational Development)
83 -
112
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Summary of Audit and Scrutiny Committee functions:
Audit Functions - Consider reports from the Council's internal auditor
& Audit Scotland concerning Council Functions.
Scrutiny Functions - Scrutinising the policies of the Council and their
effectiveness in meeting the action plans of the Council as set out in
the Corporate Development Plan and evaluating the actions of
Committees in implementing the action plans set out in the Corporate
Development Plan.
Performance Monitoring - To receive reports on the performance of
and trends within all of the Council’s services in terms of service
standards and performance information.
Standards - To ensure that the highest standards of probity and public
accountability are demonstrated.     
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GUIDANCE NOTES 
* Declaration of Group Decisions and Members Interests - The Chair of the
meeting shall seek declarations from any individual or political group at the
beginning of a meeting whether any prior decision has been reached on how
the individual or members of the group will vote on any item(s) of business on
the Agenda, and if so on which item(s).  A prior decision shall be one that the
individual or the group deems to be mandatory on the individual or the group
members such that the individual or the group members will be subject to
sanctions should they not vote in accordance with the prior decision.  Any such
prior decisions will be recorded in the Minute of the meeting. 
** Written Questions - Any Member can put one written question about any
relevant and competent business within the specified remits not already on the
agenda, to the Chair provided it is received by the Proper Officer or Committee
Services by 12 noon two working days prior to the day of the meeting.  A copy
of any written answer provided by the Chair will be tabled at the start of the
relevant section of the meeting.  The Member who has put the question may,
after the answer has been given, ask one supplementary question directly
related to the subject matter, but no discussion will be allowed. 
No supplementary question can be put or answered more than 10 minutes after
the Council has started on the relevant item of business, except with the
consent of the Chair. If a Member does not have the opportunity to put a
supplementary question because no time remains, then he or she can submit it
in writing to the Proper Officer who will arrange for a written answer to be
provided within 7 working days. 
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MORAY COUNCIL 
Audit and Scrutiny Committee 
SEDERUNT 
Councillor Graham Leadbitter  (Chair)
Councillor Shona Morrison  (Depute Chair)  
Councillor Peter Bloomfield  (Member)
Councillor Theresa Coull  (Member)
Councillor John Cowe  (Member)
Councillor John Divers  (Member)
Councillor Amber Dunbar  (Member)
Councillor Jérémie Fernandes  (Member)
Councillor Donald Gatt  (Member)
Councillor David Gordon  (Member)
Councillor Sandy Keith  (Member)
Councillor Scott Lawrence  (Member)
Councillor Marc Macrae  (Member)
Councillor Neil McLennan  (Member)  
Mr Ivan Augustus  (Non-Voting Member)
Ms Margaret Wilson  (Non-Voting Member)
Clerk Name: Caroline O'Connor
Clerk Telephone: 07779 999296
Clerk Email: committee.services@moray.gov.uk 
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MORAY COUNCIL 
Minute of Meeting of the Audit and Scrutiny Committee 
Wednesday, 08 May 2024 
Council Chambers, Council Office, High Street, Elgin, IV30 1BX 
PRESENT 
Councillor Peter Bloomfield, Councillor Theresa Coull, Councillor John Cowe,
Councillor John Divers, Councillor Amber Dunbar, Councillor Jérémie Fernandes,
Councillor Donald Gatt, Councillor David Gordon, Councillor Sandy Keith, Councillor
Graham Leadbitter, Councillor Marc Macrae, Councillor Neil McLennan, Councillor
Shona Morrison, Councillor John Stuart, Ms Margaret Wilson 
APOLOGIES 
Mr Ivan Augustus 
IN ATTENDANCE 
The Chief Executive; Depute Chief Executive (Education, Communities and
Organisational Development); Depute Chief Executive (Economy, Environment
and Finance); Head of Governance, Strategy and Performance; Head of Financial
Services; Audit and Risk Manager; Records and Heritage Manager; Caroline
O'Connor, Committee Services Officer as Clerk to the meeting, all Moray Council
and Angela Pieri, Grant Thornton - External Auditors. 
1.         Chair 
Councillor Leadbitter, as Chair of the Audit and Scrutiny Committee, chaired the
meeting.  
2.         Declaration of Group Decisions and Members Interests * 
In terms of Standing Orders 21 and 23 and the Councillors' Code of Conduct, there
were no declarations from Group Leaders or Spokespersons in regard to any prior
decisions taken on how Members will vote on any item on the agenda or any
declarations of Member's interests in respect of any item on the agenda.  
With regard to Item 7 "Annual Audit Plan for Year Ending 31 March 2024",
Councillor Gatt stated, for transparency, that he is Convener of the Grampian
Valuation Joint Board and would be taking part in the debate.  
3.         Minute of meeting of 14 February 2024 
The minute of the Audit and Scrutiny Committee of 14 February 2024 was
submitted and approved.  
4.         Written Questions ** 
The Committee noted that no written questions had been submitted.  
Item 3.
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5.         Internal Audit Section Update Report 
The meeting had before it a report by the Audit and Risk Manager providing
Committee with an update on the work of the Internal Audit Section. 
In response to a question from Councillor Stuart relating to the serious concerns
around resources referred to by the Audit and Risk Manager and whether
processes require to be streamlined or if the Committee required to keep the
situation under close review, the Audit and Risk Manager advised that resources
have reduced however demands have increased including measures including a
requirement to support counter fraud and corruption arrangements.  The main
issue is coverage, meaning the service is struggling to meet the auditing
requirements of the Council and partner organisations in accordance with the
Public Sector Internal Standards.  The Audit and Risk Manager advised that with
the current resources of the Internal Audit Section, it is at a point where
consideration is required to provide limited assurances on the adequacy and
effectiveness of the Council’s internal control systems. 
In response to a question from Councillor Gatt also relating to the serious concerns
around resources and whether there are enough staff to undertake the work and if
Internal Audit staffing resources should be revisited when considering the next
budget, the Chief Executive advised there is an increasing expectation of self-
evaluation within local authorities combined with the reduction in corporate
services as a result of frontline services which are protected in terms of budget
setting.  He further advised a national report regarding workforce issues within the
public sector and local authorities has been published and considered by the
Convention of Scottish Local Authorities (COSLA).  The Chief Executive suggested
the immediate solution lies with the cross-party working group recently
commissioned by Corporate Committee to review workforce issues. 
In response to a follow-up question from Councillor Stuart regarding whether the
impacts were known when the decisions were made to cut resources as part of the
budget, the Chief Executive explained the fundamental change is the changing
nature of audit and scrutiny noting it is now clear that self-evaluation requires more
effort and resources than previously considered and therefore consideration by the
cross-party working group would be the most appropriate way forward to provide
assurance to Committee there are sufficient resources to undertake the level of
audit inspection members would wish as a local authority. 
Councillor McLennan echoed the concerns raised by Councillor Stuart noting there
requires to be effective regulation.  He welcomed the scrutiny by the Audit and
Risk Manager raising his concerns which now require to be addressed. 
Given the concerns raised by members of Committee together with the advice
provided by the Chief Executive, the Chair moved to add an additional
recommendation that the concerns about staff resources will be taken forward
through discussion at the Strategic Leadership Forum and cross-party working
group. 
In response to a query from the Chair regarding the Data Protection audit review
and whether it requires more discussion at Corporate Committee given the links to
cyber security, the Audit and Risk Manager stated that implementing some of the
recommendations with current resources of the service would require a multi-year
timescale.  He further proposed a full audit of the areas for improvement would be
undertake and included in a future audit plan.  The Head of Governance, Strategy
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and Performance further advised it would be reported as part of the Annual
Information Governance report to Corporate Committee to keep focus on this area. 
In response to a question from Councillor Gordon regarding whether there was any
benchmarking in relation to the Roads maintenance performance indicators
comparing in-house contractor pricing, the Audit and Risk Manager advised some
work has done with a local comparator however it needs to be more
comprehensive across the range of services. 
Thereafter the Committee unanimously agreed:- 
i. to note the contents of the report; and 
ii. to invite the Council's Strategic Leadership Forum and the cross-party
Workforce Working Group to consider the Council's Internal Auditor's serious
concerns about whether the existing resources of the Internal Audit Section
are sufficient to meet the Council and partner organisation's audit requirements
and to support effective counter fraud and corruptions.  
6.         Internal Audit Section - Completed Projects Report 
The meeting had before it a report by the Audit and Risk Manager advising
Committee on the work of the Internal Audit Section for the period from 14
February 2024 to 8 May 2024. 
In response to a question from Councillor Gatt relating to the Pool Cars review and
the rechargeable rate not having being reviewed for a number years and why this
is not reviewed annually in line with other council charges, the Audit and Risk
Manager confirmed that this will be an annual review.  The Head of Financial
Services confirmed an efficiency exercise had been undertaken some years ago to
minimise internal recharging to ensure only took place in areas where there was
some financial benefit to focus attention on financial controls, with pool cars being
one of the areas where there is recharging within general services to ensure the
person using the car is the one who bears the costs and stated a review of the
rechargeable rate would be helpful. 
In response to a question from Ms Wilson relating to the Payroll Regularity Review
and in particular whether the new policy/procedures should quantify the balances
of Time Off in Lieu (TOIL) at year end where a restriction in staffing may mean it is
not possible to recover the TOIL, the Chief Executive agreed it would be helpful to
be quantify as there may be a connection to earlier discussions regarding lack of
capacity which does create a hidden cost. 
In response to a question from the Chair relating to whether the findings from the
Early Learning and Childcare Premises Security review would be shared with
partners given a large number are private providers, the Depute Chief Executive
(Education, Communities and Organisational Development) confirmed the Early
Years Service Manager has passed the information onto the providers who will be
following through the risk assessment process which will be supported through the
central management team. 
In response to a question from Councillor Gordon regarding how much VAT had
not been claimed in relation to the Purchasing Card review, the Head of Financial
Services advised the inability to claim VAT was mainly due to those making
purchases with cards not submitting receipts.  The absolute highest estimate
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would be £25K not backed by receipt, however not all purchases have reclaimable
VAT and when the Payments Section sends out quarterly reminders, this typically
results in receipts being sent for more than half of those purchases.  
Following consideration the Committee unanimously agreed to note the contents of
the report.   
7.         Annual Audit Plan for Year Ending 31 March 2024 
The meeting had before it a report by the Depute Chief Executive (Economy,
Environment and Finance) informing the Committee of the Auditor's Annual Audit
plan for 2023/24. 
In response to a request for more information from Ms Wilson regarding the Audit
Fees on page 86 where it is mention of increased fees due to high-risk control
environment relating to journals, the External Auditor advised the fee is levied due
to the way journals are authorised at the Council which results in more testing
being required for high than low risk areas.  Ms Wilson stated limited staff have
access to process journals meaning access is restricted and security measures
are in place so was unclear why it is noted as a high risk area.  In response the
External Auditor advised it had been assessed due to authorisation controls before
journals are input which had put the council into the high risk category.   
In response to a further question from Ms Wilson regarding whether that meant
every single journal would require to be authorised by the Chief Financial Officer at
year end to reduce the auditor's fee, the External Auditor advised that would be an
internal matter for council officers.  The Head of Financial Services noted there
appeared to be differing interpretation of the word 'journals' where the Council's
interpretation was that they were entries in the general ledger but the external
auditor's use was that it includes all transactions.  In response to a request from
the Chair that it would be useful for a glossary explanation on how the term is used
by both in terms of governance, the Head of Financial Services agreed to prepare
such an explanation. 
Following consideration the Committee unanimously agreed to note the contents of
the External Auditor's Annual Plan for 2023/24.  
8.         National Fraud Initiative 2022-23 
The meeting had before it a report by the Audit and Risk Manager advising the
Committee of outcomes from the Council's participation in the National Fraud
Initiative for 2022/23. 
In response to a question from Ms Wilson on whether there was any avenue to ask
whether the mandatory element could be reduced in line with the outcomes, the
Audit and Risk Manager advised valid matches were producing little benefit given
the reasons for the matches and suggested the best way was to test on a set
sample based on the limited resources to provide evidence to Audit Scotland. 
In response to a question from the Chair regarding whether it would be beneficial
to have dialogue with the Cabinet Office or Audit Scotland about more flexibility
around the Council's risk assessment process, the Audit and Risk Manager
advised the level of testing undertaken needs to be risk-based and proportionate
considering the resource levels and benefits being realised. 
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In response to a question from Councillor McLennan regarding whether if staffing
levels were at pre 2023/24 budget level this would still be a concern, the Audit and
Risk Manager advised a proportionate approach was required to make best use of
resources across all services of the Council. 
Councillor McLennan stated the report is for noting but queried whether an
additional recommendation was required given a significant change was being
proposed.  In response the Chair moved to add an additional recommendation
instructing the Internal Auditor to explore options around making the National
Fraud Initiative work more proportionate.  This was seconded by Councillor
McLennan. 
There being no one otherwise minded the Committee unanimously agreed:- 
i. to note the contents of the report; and 
ii. to instruct the Audit and Risk Manager to explore options around making the
National Fraud work more proportionate.     
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REPORT TO: AUDIT AND SCRUTINY COMMITTEE ON 25 JUNE 2024 
SUBJECT: INTERNAL AUDIT ANNUAL REPORT – 2023/24 
BY: AUDIT AND RISK MANAGER 
1. REASON FOR REPORT 
1.1 To provide Committee with a copy of the Internal Audit Annual Report for the
year ended 31 March 2024, together with the Audit and Risk Manager’s
opinion on the adequacy and effectiveness of the Council’s system of internal
control.  
1.2 This report is submitted to Committee in terms of Section III (2) and (10) of
the Council’s Scheme of Administration relating to the consideration of
reports from the Council’s Internal Auditor and the provision of the annual
assurance statement provided by Internal Audit on the Council’s control
environment. 
2. RECOMMENDATION 
2.1 That Committee considers the contents of the annual report given as
Appendix 1 to this report and seeks clarification on any matters relating
thereto. 
3. BACKGROUND 
3.1 The purpose of this report is to present to the Audit and Scrutiny Committee
the Internal Audit Annual Report for the year to 31 March 2024, which includes
the Audit and Risk Manager's independent assurance opinion on the adequacy
of the Council's overall control environment. 
3.2  The Public Sector Internal Audit Standards (PSIAS) requires the Chief Audit
Executive (CAE), the Council’s Audit and Risk Manager, to provide an annual
internal audit opinion and report on the adequacy and effectiveness of the
Council’s governance, risk management and internal controls to support the
preparation of the Annual Governance Statement. 
3.3  To meet the requirements of the PSIAS, the Internal Audit Annual Report
2023/24, at Appendix 1, includes the annual Internal Audit opinion and
provides details of the internal audit activity and performance during the year. 
Item 5.
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4. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan
(LOIP))
Internal audit work supports good governance and the delivery of
efficient services. 
(b) Policy and Legal
No implications. 
(c) Financial Implications
No implications directly arising from this report. 
(d) Risk Implications
The independent review of selected systems and procedures mitigates
the risks associated with inadequate or ineffective control procedures. 
(e) Staffing Implications
No implications. 
(f) Property
No implications. 
(g) Equalities/ Socio Economic Impacts
No implications. 
(h) Climate Change and Biodiversity Impacts
No implications. 
(i) Consultations
There have been no direct consultations during the preparation of this
report. 
5. CONCLUSION 
5.1 The Internal Audit annual report provides a summary overview of the
nature and extent of audit work carried out during the year to inform the
audit opinion on the internal control environment operating within the
Council. 
Author of Report:             Dafydd Lewis, Audit and Risk Manager
Background Papers:        Internal audit files 
Ref:                      SPMAN-1042990102-233
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APPENDIX 1 
INTERNAL AUDIT ANNUAL REPORT        
1 APRIL 2023 to 31 MARCH 2024 
Item 5.
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2 
CONTENTS 
Page
SECTION 1 –  INTRODUCTION                                                                                                            3
SECTION 2 –  BASIS OF OPINION                                                                                                     3-4
SECTION 3 –  SUMMARY AND LIMITATIONS OF WORK THAT SUPPORTS OPINION                 4-12
SECTION 4 –  OPINION                                                                                                                     12-13 
Contact Details 
Audit and Risk Manager: Dafydd Lewis 
E-mail: dafydd.lewis@moray.gov.uk
www.moray.gov.uk 
SECTION 1 – INTRODUCTION
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3 
1.1 This report is issued in compliance with the Public Sector Internal Audit Standards (PSIAS), which requires the Audit and Risk
Manager to deliver ‘an annual internal audit opinion and report that can be used by the organisation to inform its governance
statement’, and which ‘must conclude on the overall adequacy and effectiveness of the organisation’s framework of governance,
risk management and control.’ This report constitutes the required statement.  
1.2 It is management’s responsibility to maintain risk management systems, internal control and governance. Internal audit is an element
of the internal control framework established by management to examine, evaluate and report on accounting and other controls over
operations. Internal audit assists management in effectively discharging its responsibilities and functions by examining and
evaluating controls. Internal audit cannot be held responsible for internal control failures.  
1.3 Internal audit’s role includes assessing the adequacy of the risk management, internal controls and governance arrangements put
in place by management and performing testing on a sample of transactions to ensure those controls were operating for the period
under review.  
1.3 Public Sector Internal Audit Standards (PSIAS) require officers of the Internal Audit Section to communicate on a timely basis all
facts and matters that may have a bearing on their independence. I can confirm that all staff members involved in the 2023/24
internal audit reviews were independent of operational processes and their objectivity was not compromised in any way. 
SECTION 2- BASIS OF OPINION 
2.1 This opinion is based on my knowledge of the Council’s governance, risk and control processes and from the audit work completed
during the period 1 April 2023 to 31 March 2024.  There are limitations to the level of assurance that can be provided, dependent on
the scope and coverage of the audit work completed. My evaluation is based on the following: 
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4 
.
SECTION 3- SUMMARY AND LIMITATIONS OF WORK THAT SUPPORTS THE OPINION 
3.1 Internal audit operates independently within the Council. It helps the Council accomplish its objectives by bringing a systematic,
disciplined approach to evaluate and improve the effectiveness of risk management, control and governance processes. There have
been no limitations imposed by management on the scope of audit work performed. The internal audit opinion has been informed
by the audit work completed during the year. 
3.2 The annual audit plan presented to the Audit and Scrutiny Committee describes in some detail the framework around which audit
work is developed. In addition, the selection of audit topics was selected with regard to corporate planning documents, budget data,
and information drawn from the corporate risk register, and take into account input from senior management regarding possible
areas for audit. The percentage of internal audit plans completed for 2023/2024, together with a comparison to the previous year, is
summarised below, with a more detailed analysis also provided of the status of each audit project. 
Overall
Opinion
Assurance
statements signed
by Heads of Services
Risks identified in
the Council's Risk
Register
Reports issued by
the External Auditor
and other  external
review agencies
Audit work
undertaken by
Internal Audit during
the year to 31st
March 2024
Follow Up Reviews
to evidence
implementation of
audit
recommendations
Governance, risk
management and
performance
monitoring
arrangements
Review of corporate
governance
arrangements
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5 
Percentage of Internal Audit Plan Completed (%) - 2022/ 23 and 2023/ 24 
Status of each project included within the Internal Audit Plan 2023/ 24 
0
10
20
30
40
50
60
70
80
90
100
2022/ 23 2023/ 24
Completed Carried Forward
Audit Projects      Status
Housing Benefits - Rent
Rebates and Rent Allowances 
External Audit now undertaking review as part of core audit
fee
Payroll   Completed
Procurement and Creditor
Payments 
Completed
Debtors  Completed
Transformation Programme Completed
Housing and Property-
Reactive Maintenance Works 
Audit Review to be carried forward to a future Audit Plan
Environmental & Commercial
Services – Grant Claims 
Awaiting  re-submission of supporting evidence for
certification
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3.3 The internal audit work has been conducted in accordance with an established methodology that promotes quality and conformance
with the Public Sector Internal Audit Standards and the approved Internal Audit Annual Audit Plan. 
Progress on the 2023/2024 Internal Audit Plan 
3.4 Progress against planned audit work for the year to 31 March 2023 can be summarised as follows:- 
Pool Cars  Completed
E-Mail Security  Completed
Moray Growth Deal Completed
Education – Secondary
School 
Completed
Purchasing Cards  Completed
ICT Disaster Recovery   Audit Review to be carried forward to a future Audit Plan
Food Standards Scotland
Guidelines 
Completed
Keith Sports and Community
Centre 
Completed
Burial Services Completed
Refugee Integration Scheme Completed
Early Learning and Childcare
Premises Security
Completed
Children Services-
Commissioning Service 
Completed
Disabled Parking System Completed
Occupational Therapy
Services – Stores 
Completed
Grampian Valuation Joint
Board
Completed
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• Each year, an element of the plan covers work on core financial systems, which are of key significance to the good financial
governance of the Council. These systems receive the most significant focus in terms of management control and are also
reviewed on a cyclical basis by the External Auditor to obtain assurances needed for the audit of the annual accounts. Internal
audit testing has noted examples of non-compliance with the Council’s Financial Regulations, but generally, effective controls
are operating in the management of financial systems. 
• Summaries of the issues arising in relation to each system or activity covered by internal audit work in 2023/2024 have been
reported separately to the Audit and Scrutiny Committee. Appropriate responses to the recommendations are also included.
When actioned, the recommendations made in the internal audit reports should provide management with additional comfort
that the system of control operates as intended. It is therefore imperative that the agreed actions are implemented by
management. 
• The changes in working practices within services of officers working from home have required changes in established working
practices, e.g., making greater use of audio, video, and screen-sharing software applications. These changes have brought
challenges to resolving audit queries and responding to audit report recommendations timeously. Despite these constraints, I
am pleased to report that the majority of the audit plan for 2023/24 has been completed. However, it has been required to carry
forward the Housing and Property- Reactive Maintenance Works and Information, Communication and Technology (ICT)
Section Disaster Recovery reviews to a future audit plan. This is disappointing. The Internal Audit Section has been operating
with a vacancy in the post of Corporate Investigations Officer, who was responsible for investigating fraud, supporting the audit
team's work on the National Fraud Initiative, and performing other routine audit work. The duties of the post have been covered
by other officers within the Section. 
• The Internal Audit Section has introduced revised arrangements where follow-up reviews to evidence the implementation of
recommendations are reported to the Audit and Scrutiny Committee. It is appreciated the demands on services, however the
follow-up audits undertaken found recommendations that had yet to be implemented within the agreed timescales. The need to
revisit audit reviews to evidence the implementation of recommendations has resulted in an additional workload commitment for
the Internal Audit Section. Implementation of recommendations is a key determinant in assessing the adequacy and
effectiveness of the Council’s internal control system. If recommendations are not implemented in a timely manner, then
weaknesses in control and governance frameworks will remain in place. 
• The audit role for the Moray Integration Joint Board (MIJB) involves providing assurances that governance and financial
arrangements have been developed and are operating in accordance with policies and that selected systems and processes
are suitably controlled. The audits undertaken have noted significant findings, especially in the administration and management
of adult social care. These audits and the follow-up reviews to evidence implementation of the recommendations have been a
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particularly time-consuming commitment on the Internal Audit Section. It is anticipated this requirement will continue in 2024/25.
In my role as the Chief Internal Auditor of the MIJB, I have highlighted concerns regarding the adequacy and effectiveness of
their governance and control environment. It is appreciated that the MIJB is a separate statutory body; however, as the Audit
and Risk Manager of the Council, I note the Council has a significant ongoing funding contribution in the delivery of services. I
am of the opinion that the Council needs to develop further monitoring arrangements for MIJB delivered services by receiving
regular assurance reports to confirm effective operating arrangements of internal control systems and governance
arrangements. This should include receiving regular updates on progress in implementing improvements highlighted by
regulatory bodies, including External and Internal Audit Services.     
3.5 The total number of recommendations made is set out in the following table: 
Report Risk Ratings for
Recommendations
System/ Testing
Assessment     
2023/24 Audit Plan High Medium Low 
Payroll   1 2 0 Full
Procurement and Creditor Payments  0 0 0 Full
Debtors  1 4 0  Substantial
Transformation Programme 1 2 0 Full
Pool Cars  2 2 3  Substantial
E-Mail Security  5 2 0  Substantial
Moray Growth Deal 2 3 0 Substantial
Education – Secondary School  0 3 0 Substantial
Purchasing Cards  3 6 3 Substantial
Food Standards Scotland Guidelines  0 3 6 Substantial
Keith Sports and Community Centre  1 5 2 Substantial
Burial Services 0 2 2 Substantial
Refugee Integration Scheme 2 2 4 Substantial
Early Learning and Childcare Premises Security 2 6 0 Substantial
Children Services - Commissioning Service  0 3 0  Substantial 
Disabled Parking System 2 2 1 Limited
Occupational Therapy Services – Stores  2 13 2  Limited 
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3.6    The following performance measures were in place for 2023/2024: 
Measure Description Target Actual
2022/23
Actual
2023/34
Final Report Percentage of Auditee(s) responding within
20 days of receiving the draft report.
100% 69% 65%
Final Report Percentage of final audit reports issued
within 10 days of agreeing the draft report
100% 100% 100%
Audit Plan Delivery Percentage of audits completed v planned. 85% 94% 89%
Audit Budget Percentage of audits completed within
budgeted days.
80% 75% 76%
Audit Recommendations Percentage of audit recommendations
agreed.
90% 100% 100%
Customer Feedback Percentage of respondents who rated that
the audit added value and provided
meaningful results.
100% 100% 100%
Follow Up Reviews Percentage of Follow Up Reviews
completed v planned
100% 90% 92% 
Analysis of the performance of the Internal Audit Section for 2023/24 details the majority of planned projects within the audit plan
for last year were completed. A comparison to the previous year’s percentage of audits completed against the audit plan has seen
a reduction in performance. However, as detailed previously in this report, the Internal Audit Section has had staffing issues with
the duties of the vacant Corporate Investigations Officer being undertaken by other officers within the Section.   All reports were
issued as “final” within 10 days of agreeing on the draft report, and officers agreed to all recommendations. Unfortunately,
difficulties were again experienced in obtaining replies to audit recommendations within 20 days of officers receiving the draft
report. In addition, delays were also found in obtaining the information requested or explanations to audit queries. Heads of
Services have been informed of the need to respond promptly to audit questions and recommendations. The demands on officers
to meet service requirements are appreciated, but delays in responding within agreed timescales will impact the Audit and Risk
Manager’s ability to deliver the audit plan to members of the Audit and Risk Committee. 
3.7 Governance – regarding the preparation of the Council’s Annual Governance Statement, it is considered that sufficient
information has been obtained to conclude that the Council generally complies with the latest good governance practice issued
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by CIPFA /SOLACE and that the Corporate Management Team (comprising the Chief Executive, two Depute Chief Executives
and the Chief Officer - Health and Social Care Moray) and Senior Managers have a strong awareness of the challenges facing
the Council in the incoming period. Written assurances from senior managers also considered governance practice within
individual service areas.  
3.8 Key governance and internal control arrangements have been maintained, albeit capacity issues called for resources to be
prioritised for essential services and to take forward the Council's strategic priorities. Progress has been noted in several key
priority areas. However, a review of findings detailed within the audit reports issued during the year has found that some Council
Policies and Regulations are in need of review and if required, updating. Maintaining up to date policies and regulations is an
important control element in the governance arrangements of the Council.     
3.9 The Audit and Risk Manager facilitated a workshop with Members of the Audit and Scrutiny Committee to carry out self-
assessments of Compliance with the Good Practice Principles Checklist and Evaluation of Effectiveness Toolkit from the CIPFA
Publication – Audit Committees - Practical Guidance for Local Authorities and Police 2022 Edition. This CIPFA Publication sets
out its guidance on the function and operation of audit committees in local authorities and police bodies and represents CIPFA’s
view of best practices for audit committees in local authorities throughout the UK. The outcome of the self-assessment and
evaluation noted significant compliance with good practice principles and a high degree of effectiveness and was reported to the
Audit and Scrutiny Committee on 14 February 2024 (para 9 of the minute refers). 
3.10 Counter Fraud - While the prevention of fraud and error rests with management through the design and operation of suitable
systems of control, the audit plan continues to provide time for Internal Audit to coordinate the Council’s participation in the
National Fraud Initiative (NFI), a data matching exercise involving a range of public sector bodies. This activity is viewed as
complementary to other audit activities, and participation assists Internal Audit in assessing the potential for the occurrence of
fraud and related fraud risk. The findings of the NFI 2022/23 data matching exercise were reported to the Audit and Scrutiny
Committee on 8 May 2024 (para 8 of the minute refers). No fraud was found, but the exercise generally noted information that is
out of date or simply timing differences, e.g., if an individual changes jobs or address around the time the data for matching is
submitted, the old and new information can appear as a match but on checking can be quickly discounted.
.
3.11 An element of the audit plan is devoted to core financial systems including both payroll expenditure and creditor payments, i.e.,
payment for works, goods and services to suppliers or contractors. Testing was undertaken using a data analysis software
application to extract a random sample of transactions for review. The audit programme of testing undertaken was developed
from the Chartered Institute of Public Finance and Accountancy Systems Based Auditing Control Matrices and consultation with
the External Auditor. Findings found examples of non-compliance with Council Policies, Regulations and Procedures, but
generally appropriate controls are operating effectively, and the integrity of systems had been maintained. Further use is planned
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11 
of the data analysis software application to ensure more focused audit testing can be undertaken to provide additional assurance
in the prevention of fraud and error. 
3.12 The Policy to Combat Fraud, Theft, Bribery and Corruption was reviewed and updated during the year. This involved consultations
with the Human Resources Service and other consultative groups. The revised Policy was reported and agreed by the Corporate
Committee on 30 January 2024 (para 13 of the minute refers). 
3.13  Risk Management – procedures have been developed with a risk management policy in place and risk registers have been
maintained at corporate and service levels. The Risk Management and Business Continuity Officer has assisted in facilitating
further implementation and development of risk management arrangements. This has included updating policies covering
risk management and business continuity. It was noted that the full Corporate Risk Register was reported to the Corporate
Committee for review and consideration at its meeting on 23 April 2024. At this Committee, it was agreed there should be quarterly
reporting to the Committee on risks that had a high-risk score to enable regular review of the risks and mitigating actions. 
3.14 Financial, staffing, information, communication and technology risks remain acute challenges to the Council. These are prominent
risks for the Council covering how it discharges its functions in terms of good governance, how it manages its financial affairs, the
arrangements for managing and supporting its workforce, and the use of technology, which is key to delivering most, if not all
services. It is appreciated these high-risk categories come not only from circumstances internal to the Council but also from
challenges from the broader economic and social environment faced by all local authorities. 
Statement on Conformance with the Public Sector Internal Audit Standards 
3.15 The Local Authority Accounts (Scotland) Regulations 2014 require that ‘a local authority must operate a professional and objective
internal auditing service in accordance with recognised standards and practices in relation to internal auditing’. The recognised
standards adopted by all Scottish councils are the Public Sector Internal Audit Standards (PSIAS) developed by the Chartered
Institute of Public Finance and Accountancy and the Chartered Institute of Internal Auditors. 
3.16 Internal performance monitoring against PSIAS has been ongoing over the last few years. All Scottish local authorities are required
to have an External Quality Assessment (EQA) every 5 years. As part of the Council’s membership of the Scottish Local Authorities
Chief Internal Auditors’ Group, it was agreed that this EQA requirement would be met by each local authority internal audit service
undertaking a review of another council and will thereafter receive a review in return. An EQA of the Internal Audit Section has
recently been completed by Perth and Kinross Council. It is pleasing to report that the initial feedback provided has indicated full
compliance with PSIAS. A separate report of the assessment will be provided to the Audit and Scrutiny Committee. 
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12 
3.17 The Public Sector Internal Audit Standards require the Audit and Risk Manager to consider whether or not the audit staffing
resources are sufficient to meet the audit needs of the organisation, and where it is believed that the level of resources may
adversely impact the provision of the annual internal audit opinion and draw this to the attention of the Committee. 
3.18 Demands on the Internal Audit Section have increased over a number of years, and it is expected this will continue. Further to a
Special Meeting of the Moray Council on 28 February 2024, it was agreed to reduce the Internal Audit Section staffing budget by
replacing the Corporate Investigations Officer’s post with a 0.5 full-time equivalent. This is in addition to deleting an Assistant
Auditor post in 2022/23. However, further to the additional funding secured and the remaining budget from the reduction of the
Corporate Investigations Officer post, it has provided a sufficient budget to seek the appointment of a full time Assistant Auditor.
I hope that appointing an Assistant Auditor can mitigate the risks associated with reducing staff resources while still maintaining
the delivery of an effective internal audit service. As the Audit and Risk Manager, I am concerned about whether available
resources will be sufficient to meet the future auditing needs of the Council, Moray Integration Joint Board and the Grampian
Valuation Joint Board. 
3.19 In considering the sufficiency of the audit coverage, the Committee is reminded that the responsibility for developing and
maintaining a sound control environment rests with management and not with internal audit. 
SECTION 4- OPINION 
4.1  Any system of control can only ever provide reasonable and not absolute assurances that control weaknesses or irregularities do
not exist or that there is no risk of error, fraud, or breaches of laws or regulations. Furthermore, it is the responsibility of
management to establish an appropriate sound system of internal control and monitor its effectiveness. It is the responsibility of
the Audit and Risk Manager to provide an annual assessment of the robustness of the internal control system. 
4.2   It is my opinion, based on the audit work completed and other sources of assurance, that reasonable assurance can be placed
on the adequacy and effectiveness of the Council’s internal control system for the year ending 31 March 2024. 
Dafydd Lewis
Audit and Risk Manager
13 May 2024
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REPORT TO:  AUDIT AND SCRUTINY COMMITTEE ON 25 JUNE 2024
SUBJECT:       INTERNAL AUDIT SECTION UPDATE REPORT
BY:                    AUDIT AND RISK MANAGER 
1. REASON FOR REPORT 
1.1 The report provides Committee with an update on the work of the Internal
Audit Section. 
1.2 This report is submitted to Committee in terms of Section III (I) (2) and (8) of the
Council’s Scheme of Administration relating to consideration of reports from the
Council’s Internal Auditor and monitoring delivery of the audit service through
receipt of quarterly reports on work carried out by Internal Audit. 
2. RECOMMENDATION 
2.1 Committee is asked to consider the contents of this report, seek
clarification on any points noted and otherwise note the report. 
3. BACKGROUND 
3.1  Public Sector Internal Audit Standards requires the Audit and Risk Manager to
prepare and present reports to committee on internal audit’s activity,
performance relative to its Audit Plan, and any other relevant matters. 
3.2  This report provides an update on audit activity and projects progressed since
the last meeting.   
4. UPDATE OF PROGRESS AGAINST THE 2024/25 AUDIT PLAN 
Audit Plan Update
4.1 The Internal Audit Plan is a means of determining the priorities of the internal
audit activity and how these fit with the wider goals of the Council. Enclosed as
Appendix 1 is an update on the progress undertaken by the Internal Audit
Section regarding the completion of audit review projects against the Annual
Audit Plan. 
Item 6.
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CIPFA Publication – Audit Committees - Practical Guidance for Local
Authorities and Police 2022 Edition
4.2 The CIPFA Publication – Audit Committees - Practical Guidance for Local
Authorities and Police 2022 Edition provides guidance on the function and
operation of audit committees and represents their view of best practices for
audit committees in local authorities throughout the UK. A report was provided to
Audit and Scrutiny Committee on 14 February 2024 (para 9 of minute refers),
detailing the outcome from a self-assessment of compliance with the good
practice guidelines from the CIPFA Guidance. An action identified was for the
Audit and Risk Manager to meet in private with the Audit and Scrutiny
Committee Members at least annually, where Members are required to seek
assurance that the Audit Risk Manager is free to determine the scope of internal
audit work without interference and to discuss any governance issues within the
Council that may be of concern. In addition, the meeting can also provide the
“opportunity to test out a question on the auditor, perhaps when the audit
committee member is not sure if it is an appropriate question to ask”. 
4.3 Further to a meeting held with Members on 4 June 2024, I am pleased to confirm
there has not been any interference in the work undertaken or the reporting of
the Internal Audit Section. However, a discussion was held regarding the
Council’s governance arrangements that included the role of the Internal Audit
Section. The scrutiny function of the Audit and Scrutiny Committee was also
discussed, and whether this could be further expanded in the reporting to this
Committee. This issue has already been highlighted for development by senior
management. The meeting also provided an opportunity to update members on
service developments within the Internal Audit Section regarding a revised
internal audit reporting format. 
Follow Up Reviews 
4.4 Internal audit reports are regularly presented to Members detailing not only
findings but also the responses by management to the recommendations with
agreed dates of implementation. The Internal Audit Section will also undertake
follow up reviews to evidence the effective implementation of these
recommendations. Please see detailed the following completed follow up
reviews: 
4.5   Domestic Refuse Collection
A follow up review was undertaken of the audit undertaken into the
arrangements for collecting refuse materials from domestic properties. Moray
Council collects refuse at approximately 46,000 domestic properties at the cost
of £3.1 million annually. Systems were reviewed to ensure the most effective and
efficient use are made of resources in collecting domestic waste. The audit also
checked the procedures for disposing of recyclable waste. It is pleasing to report
that the majority of recommendations have been implemented. However, some
recommendations remain outstanding as the Scottish Government has delayed
the introduction of the national Deposit Return Scheme until October 2027. The
Follow Up Report to review the implementation of the agreed recommendations
is given in Appendix 2.  
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Disabled Parking Permit Scheme
4.6 A follow up review to evidence implementation of the recommendations contained
within an audit report regarding the administrative arrangements of the Disabled
Parking Permit Scheme has been completed. Disabled parking permits, also
known as blue badges, help people with disabilities or health conditions park
closer to their destination. Local authorities are responsible for the day-to-day
administration and enforcement of the scheme. However, Transport Scotland has
set the framework for the scheme. The audit reviewed the systems and
procedures for administering the Disabled Parking Permit Scheme. This has also
included the processes for investigating blue badge misuse. It is pleasing to report
that all the recommendations detailed within the audit report have been
implemented. The Follow Up Report to review the implementation of the agreed
recommendations is given in Appendix 3. 
Debtors
4.7 A follow-up review has been undertaken to evidence the implementation of the
recommendations for an audit review of the Debtors System. Invoices are raised
for various types of services, e.g., financial contribution for care, trade waste,
special uplifts, hire of facilities and rechargeable repairs. The audit scope involved
testing to ensure invoices can be evidenced with enough backing documentation
to be able to support debt recovery should the need arise; confirming payments
had been auto-matched to debtor accounts; receipts without a valid reference
have been posted to and cleared from a suspense account on a regular basis;
effective monitoring of unpaid invoices are monitored and chased in accordance
with debt recovery procedures; collection performance is monitored and reported.
It is pleasing to report that most recommendations have been implemented, but
further development is still required regarding the performance management of
debt recovery arrangements. The Follow Up Report to review the implementation
of the agreed recommendations is given in Appendix 4. 
5       SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
Internal audit work supports good governance and the delivery of
efficient services. 
(b) Policy and Legal
No implications directly arising from this report. 
(c) Financial Implications
No implications directly arising from this report. 
(d) Risk Implications
The independent review of selected systems and procedures mitigates
the risk associated with inadequate or ineffective control procedures. 
(e) Staffing Implications
No implications directly arising from this report. 
(f) Property
No implications directly arising from this report.
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(g) Equalities/Socio Economic Impact
No implications directly arising from this report. 
(h) Climate Change and Biodiversity Impacts 
No implications. 
(i) Consultations
There have been no direct consultations during the preparation of this
report. 
6. CONCLUSION 
6.1 This report provides committee with an update on internal audit work
progressed in the latest review period. 
Author of Report:
Background Papers: 
Dafydd Lewis
Internal Audit files
Audit and Risk Manager
Ref:  SPMAN-
1042990102-228   
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APPENDIX 1 
MORAY COUNCIL 
INTERNAL AUDIT SERVICE 
ANNUAL AUDIT PLAN 2024/25 
CORE FINANCIAL SYSTEMS  
Area Type of coverage Status/ Comments
Payroll   Continuous auditing to confirm the
adequacy of the systems and
procedures for the payment of salaries.
Audit programmed to start in the next
quarter(s)
Procurement and Creditor Payments  Continuous auditing of samples of non-
pay expenditure to test compliance with
procurement and payment processing
regulations.
Audit testing completed
ICT Hardware Asset  Management review of systems and
practices to record / monitor the location
and use of ICT hardware. 
Audit programmed to start in the next
quarter(s)
Stocks and stores - year end valuations    Attendance at stocktaking and
reconciliation of stocks held to ledger
balances.
Year end stock valuations agreed
OTHER SYSTEMS  
Area Type of coverage 
Housing and Property Reactive
Maintenance Works 
Audit of works undertaken within
Building Services for the completion of
reactive maintenance works (Council
Housing). 
Audit programmed to start in the next
quarter(s)
Grant Claims Certification of grant claims as required:
strategic timber; network support grant,
regeneration schemes as appropriate
Review of Network Support Grant in
progress.
Item 6.
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Housing Rent Collection & Arrears
Management
A review of the income collection and
accounting arrangements for housing
rents. 
Audit programmed to start in the next
quarter(s)
Moray Growth Deal  An audit review of the governance and
administrative procedures within the
Council for the management of the
Moray Growth Deal. The scope will
include the concerning partnership
working, financial management and
measuring success. 
Audit programmed to start in the next
quarter(s)
Education – Secondary School Establishment visits as part of cyclical
review.
Audit programmed to start in the next
quarter(s)
Treasury Management  To provide assurance that processes
and controls are continuing to operate
effectively for the Council's treasury
management system.  
Audit programmed to start in the next
quarter(s)
Commercial Refuse Collection  To consider whether adequate control is
in place covering trade waste income
and expenditure, that appropriate
agreements and other paperwork is in
place, and that accounting arrangements
are robust.
Audit testing completed and draft report
prepared
Governance arrangements to prevent
Fraud and Corruption 
Overview of the Councils governance
arrangements to prevent fraud and
corruption. The audit will use the Cipfa
Code of practice on managing the risk of
fraud and corruption as the basis in
developing the audit programme for the
review.
Fieldwork in progress
Education- Secondary School Premises
Security
Review the controls in place to mitigate
the risk of unauthorised access to
Secondary School Premises.
Audit programmed to start in the next
quarter(s)
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Absence Management An audit to consider the effectiveness of
sickness absence monitoring and
reporting. 
Audit programmed to start in the next
quarter(s)
Following the Public Pound To ensure that there is proper
accountability for public funds used in
delivering services, irrespective of the
means of service delivery.
Fieldwork in progress
Moray Integration Joint Board   
Residential Care An audit to review the adequacy of
procedures and administrative
arrangements regarding the third party
suppliers appointed to provide care
home services The audit will also include
testing to verify the accuracy of the
financial assessments and the charging
for residential care of both respite and
permanent care residents.  
Audit programmed to start in the next
quarter(s)
Out of area placement A review of the systems and procedures
regarding adult services users that are
out of area but responsibility remains to
meet their eligible care and support
needs under the Care Act.  
Audit programmed to start in the next
quarter(s)
Fostering and Kinship payments A review to ensure that the internal
controls in place for administering
Fostering and Kinship Care Allowances
are operating effectively. 
Fieldwork in progress 
Follow Up reviews to be undertaken
from previous  Audit Assignments *
Audit Review: Original Scope Status/ Comments
Business Continuity  The audit reviewed the Council's Business
Continuity arrangements to confirm up to date
policies, procedures and plans are regularly  
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tested and reviewed, and that an appropriate
level of awareness of Business Continuity is held
throughout the organisation.
Follow Up Review programmed to start
in this quarter 
Self Directed Support (SDS) – Option 1 This audit remit was to review Option 1 Direct
Payments under the SDS scheme, where a
payment is made by the local authority directly to
a supported person for the provision of support.
The scope of the audit was to ensure compliance
with operating guidelines in the financial
management of SDS packages, expenditure
incurred is in accordance with the agreed budget
and support plans, and surplus funds are
recovered from service users where appropriate.
Follow Up Review programmed to start
in the next quarter(s) 
Self Directed Support (SDS) – Option 2/3  The scope of the audit was to review systems
and procedures in the delivery and management
of adult social care provided under Options 2 and
3 of the SDS scheme. This included examination
of the processes to support individuals in
determining their preferred care delivery option,
contractual relationships with care providers,
financial management and monitoring of
individual care packages. 
Follow Up Review programmed to start
in the next quarter(s) 
Building Services - Planned
Maintenance Projects
An overview was undertaken of how the annual
planned maintenance programme is determined
and the contract management arrangements of
these projects by Building Services. The audit
also involved a random selection of projects to
verify costs can be evidenced to supporting
documentation. Additional testing was also
undertaken of the systems regarding the
management and control of overtime paid to
officers.
Follow Up Review programmed to start
in this quarter 
Emergency Planning The objective of this audit was to provide
assurance over the adequacy and effectiveness
of current controls over emergency planning. The
audit scope included a check to ensure adequate
training, planning and testing has been
developed in the event of an emergency.
Follow Up Review programmed to start
in the next quarter(s) 
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Disabled Parking Permit Scheme- Blue
Badge
The scope of this audit was to review systems
and procedures in the administration of the
Disabled Parking Permit Scheme. This included
the processes for assessment, management and
investigation of misuse of blue badges. The audit
also reviewed the procedures for the issue,
control and income collection arrangements.   
Completed 
Refugee Integration Scheme The scope of this audit involved a review systems
and procedures to account for the relatively new
and increasing source of funding for national
humanitarian protection schemes. This audit has
specifically covered the financial and
administrative processes involved in the
operation of the Ukrainian Refugee Scheme.
Follow Up Review programmed to start
in the next quarter(s) 
Building Services - Stores  This audit scope reviewed the systems and
controls in managing stock held within Building
Services Stores. Testing involved a review of the
stores software application called Servitor used
for the recording and valuation of materials and
equipment. Testing also included a check of the
security arrangements to safeguard against
unauthorised access to the storage areas.
Follow Up Review programmed to start
in the next quarter(s) 
Debtors The audit scope was to review the key
operational controls within the Council's Debtors
System. The audit checked the systems for
raising invoices, collecting income, recording
income and debt recovery arrangements. The
audit review did not include the arrangements for
recovering debts concerning council tax, non
domestic rates, and housing rents.
Completed 
Domestic Refuse Collection  The scope of this audit was to review systems
and procedures to ensure the most effective and
efficient use is made of resources for the
collection of domestic waste. The audit also
checked the arrangements for disposing of
recyclable waste. This included disposal of
plastic, glass and biodegradable waste, in
addition to paper / card, aluminium and steel
Completed 
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cans for which the Council received regular
payments from recycling contractors.
Pool Cars Scheme The scope of this audit was to review systems
and procedures in the management and use of
pool cars. Policies and procedures were checked
to ensure they provide appropriate operating
guidance to officers in the booking and use of
pool cars. The audit included a review of
arrangements for internal recharging to services
and also exploration if further use of pool cars
could provide additional value for money
opportunities to the Council.
Follow Up Review programmed to start
in the next quarter(s) 
Cyber Security The audit reviewed systems, practices and an
assessment of the controls in place to protect the
Council from a cyber-attack. The audit also
reviewed Information, Communication and
Technology (ICT) security policies and
procedures to ensure they are regularly reviewed
and promote best practices. The audit
programme has been developed from the
Scottish Government Cyber Resilience
Framework and other good practice guidelines.
Follow Up Review programmed to start
in the next quarter(s) 
Moray Integrated Community Stores The audit reviewed the management of the
Moray Integrated Community Stores. This
included reviewing the procedures for ordering
and issuing occupational therapy equipment to
service users. In addition, a check was made to
compare stock records to the actual equipment
held within the Stores.  
Follow Up Review programmed to start
in the next quarter(s) 
Forres Academy The audit reviewed the operation of the Devolved
School Management Scheme regarding the allocation
of funding and the management of these funds at the
school level. The review involved a study of the
management of the significant staffing costs involved
in delivering the curriculum, a review of procurement
practices, an examination of the School's
administration of income and also confirming
accountability for School Fund monies.
Follow Up Review programmed to start
in the next quarter(s) 
* Additional follow up reviews may be reported depending on the implementation dates detailed by Services for recommendation
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APPENDIX 2
Moray Council
Internal Audit Section
DEPARTMENT: Economy, Environmental & Finance
SUBJECT:  Domestic Refuse Collection 
REPORT REF: 23'016 
Follow Up Audit Review 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Key Control: Service operations are planned to achieve best value principles. 
5.01 Consideration should be given to
exploring software applications
that could assist the process and
provide value for money
opportunities in the determination
of operational routes and the
resources required. 
Low Yes 31/05/2023 Implemented- Demonstrations of route
optimisation software were sourced from
multiple providers. Whilst the benefits of the
products were clearly seen and would be
welcomed as an improvement to the current
manual route planning system, costings
proved to be prohibitive with funding not
available for the considerable costs of
installation and ongoing provision.
Item 6.
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Moray Council
Internal Audit Section 
2
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Management decision has been taken that due
to financial climate, the use of route
optimisation software is not feasible. 
Key Control: Staffing requirements are carefully assessed based on operational needs and payments made to staff are appropriately
controlled. 
5.02 Documented business continuity
plans should be agreed to ensure
continuous delivery of services in
the event of any disruption in
meeting operational requirements. 
Medium Yes 31/01/2023 Implemented- Work has been undertaken by
the Service and the Business Continuity & Risk
Management Officer and a Business Impact
Assessment is now seen to be in place which
will be updated as required, on changes to
operations and associated risks.   
5.03 Officers should be reminded to
ensure timesheets are carefully
checked prior to authorisation,
and supporting documentation is
completed accurately before
Medium Yes 12/01/2023 Implemented- Enhanced checking
procedures are now embedded on submission
of timesheets to the Administration Section
and on preparing summary detail for the
Payroll Service to process. Audit testing of a
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Moray Council
Internal Audit Section 
3
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
being passed to the payroll
service for payment. 
sample of employee payments and supporting
documentation has found no errors and the
process in place is considered to be working
effectively.  
Key Control: Vehicle costs borne by the service are accurately calculated and allocated based on service requirements and resource
planning.
5.04 Consideration should be given to
the apportionment of vehicle and
transport costs to the green waste
collection cost centre to enable
further budgetary control of all
elements of the domestic refuse
collection service. 
Low Yes 31/01/2023 Implemented- Vehicle and transport costs
pertaining to the green waste collection service
are now separately identified in the financial
ledger, with accompanying budget provision. 
Key Control: Disposal of recyclable materials collected from kerbside is controlled by formalised contractual arrangements with
approved external contractors and all payments made in line with contractual terms. 
5.05 Management should review
current arrangements for plastic
recycling to determine whether
Medium Yes 31/01/2024 Outstanding- With the national Deposit
Return Scheme (DRS) anticipated to capture
up to 90% of materials currently processed, a
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Moray Council
Internal Audit Section 
4
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
improvements can be made to
decrease haulage costs and
achieve higher quality
submissions that could generate
additional income for the Council. 
review of plastic recycling arrangements was
intended to be undertaken after the early
impact of DRS was evaluated. However, the
Scottish Government has now delayed the
introduction of DRS from August 2023 until
October 2027. A review of operations is not
beneficial until the substantial change in the
recycling landscape is effected which is
outwith the control of the Service. Due to the
revised date of possible implementation,
another audit review of this subject will be
included in a future Audit Plan to evidence
implementation.   
5.06 A contract should be agreed
between the Council and a third
sector organisation for providing a
rediverting and recycling of waste
service. The agreement should
include the rates payable and
Low Yes 30/04/2023 Part Implemented- Discussions have been
held with the third sector organisation and
efforts made by the Service to initiate a formal
service level agreement. Support from Legal
Services to progress the service level
agreement is awaited but involves work
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Moray Council
Internal Audit Section 
5
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
service specification.    prioritisation issues with Legal Services
experiencing acute staffing shortages. As no
revised date of completion could be provided,
another audit review of this subject will be
included in a future Audit Plan to evidence
implementation. 
5.07 Supporting documentation should
be provided of VAT applicable
income received by the Service to
the Payments Section to ensure
proper accounting arrangements
can be followed in compliance
with HMRC regulations.   
High Yes 12/01/2023 Implemented- It has been evidenced that self-
billing invoices are being sent by the Service to
Payments on a monthly basis to ensure VAT is
appropriately and fully accounted for at the
point of receipt of paper income. 
5.08 Documented agreement should
be undertaken to formalise
arrangements for recycling
aluminium and steel cans.   
Medium Yes 30/04/2023
(Revised
Implementation
Date
10/02/2025)
Outstanding- Aluminium and steel cans are
being administered under the terms of the Dry
Mixed Recyclates contract. The
implementation of DRS was awaited to
determine implications for can recycling but
this has now been delayed nationally until
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Moray Council
Internal Audit Section 
6
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
October 2027. Advice has been obtained from
the Procurement Service and aluminium and
steel cans will be included as a separate lot in
the new Dry Mixed Recyclates contract which
will be awarded in February 2025.   
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APPENDIX 3
Moray Council
Internal Audit Section 
BODY: Health & Social Care Moray
SUBJECT:  Disabled Parking Permit Scheme 
REPORT REF: 24'010 
Follow Up Audit Review 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Key Control: Effective management controls operate to ensure the delivery of the Disabled Parking Permits System is in
accordance with Transport Scotland guidelines.
5.01 The Blue Badge Scheme Policy
should be reviewed and updated.
This should include reference to
responsibility for investigating
misuse and arrangements if
required to cancel a service users’
blue badge. 
Medium Yes 31/03/2024 Implemented- The Blue Badge Scheme
Policy has been updated to include procedures
for investigating allegations of misuse of blue
badges. 
Item 6.
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Page 44

Moray Council
Internal Audit Section 
2
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
5.02 All service users identified that
have received a blue badge in
2020 a 2021 but not billed should
be invoiced as a matter of priority.   
High Yes 31/01/2024 Implemented- The Service has reviewed and
invoiced all service users who received a blue
badge in 2020/21 but had not been billed. It
was noted that this required 1424 invoices to
be issued, with a total value of £28,480. 
5.03 In accordance with Financial
Regulations, service users should
be invoiced within one month of
receiving a blue badge.  An action
plan should also be agreed to
resolve any backlog of blue
badges issued to applicants who
have yet to be invoiced. 
The audit review noted that the fee
for a blue badge is payable on
application in some Local
Authorities. Consideration should
Medium 
Low
Yes 
Yes
31/08/2023 
31/12/2023
Implemented- Audit testing of recent
applications has found that service users
receiving a blue badge are invoiced in
accordance with Financial Regulations. In
addition, it was also confirmed that the backlog
of blue badges issued to applicants but not
invoiced has been resolved. 
Implemented – It was noted that a working
group was established to investigate the
possibility of changing the current invoicing
procedures to request payment for a blue
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Moray Council
Internal Audit Section 
3
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
be given to investigating the
option for an individual to pay the
charge for a blue badge on
completion of the application form. 
badge within the application process. Further
to this review, the Head of Service has decided
to require individuals to pay the charge for a
blue badge upon completion of the application
form. The Service has advised these new
arrangements will be implemented by 30
September 2024.
5.04 All sensitive personal data held
within the Community Care
Finance Office should be stored
securely with access restricted to
only authorised officers. 
High Yes 31/08/2023 Implemented- All sensitive personal data are
now being stored securely and access is
restricted to authorised officers only. 
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APPENDIX 4
Moray Council
Internal Audit Section 
DEPARTMENT: Economy, Environment & Finance
SUBJECT:  Debtors 
REPORT REF: 24'011 
Follow Up Audit Review 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Key Control: The audit reviewed the key operational controls in the management of the Debtors System.
5.01 Further to a review undertaken by
the Payments Section, additional
controls have been implemented
to ensure more effective
monitoring of software licensing
requirements. This will include
establishing a register of software
High Yes 31/12/2023 Implemented – Revised processes have been
introduced to ensure software licenses are
renewed in accordance with contract
conditions.   
Item 6.
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Moray Council
Internal Audit Section 
2
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
certificates requiring future
renewal.
5.02 To ensure the Council is
maximising income recovering
arrangements, services should be
reminded to resolve any disputed
invoices as quickly as possible. 
Medium Yes 31/01/2024 Implemented – The Payments Section sends
quarterly debt management reports of unpaid
invoices to services. Services have been
reminded of the need to resolve disputed
invoices promptly. Payments Section also
undertakes regular age debt analysis to
highlight unpaid invoices over different time
periods. 
5.03 In accordance with Financial
Regulations, services should be
reminded of the requirement that
invoices are issued promptly,
either in advance or within a
maximum of 30 days of the service
or goods being provided.
Medium Yes 31/01/2024 Implemented – Quarterly debt management
reports are sent to services, which include a
reminder of the Financial Regulations
requirement of issuing invoices within 30 days
of providing a service or goods. 
5.04 Consideration should be given for
additional guidance to be included
Medium Yes 31/01/2024 Implemented – Revised Sundry Debt
Management Procedures have been updated
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Moray Council
Internal Audit Section 
3
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
within the Sundry Debt Management
Procedures to ensure a uniform
approach is taken where the use of
legal action should be considered by
services for the recovery of unpaid
invoices. 
to include guidance on the use of legal action
for unpaid invoices. Procedures remain within
the consultation period with an expectation of
final agreement by the end of June 2024. 
5.05 Consideration should be given to
further developing performance
management information to allow
benchmarking with other local
authorities and for the internal
management of debt recovery action
undertaken by individual services. 
Medium Yes 31/03/2024
Revised
Implementation
Date 31/08/2024
Outstanding – Operational demands and
staffing vacancies have delayed the
implementation of this recommendation. Work
has started on the analysis of information,
which will then be used to develop
performance indicators for benchmarking with
other local authorities. Revised
implementation date 31/08/2024. 
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Page 51

REPORT TO:    AUDIT AND SCRUTINY COMMITTEE ON 25 JUNE 2024 
SUBJECT: INTERNAL AUDIT SECTION – COMPLETED PROJECTS
REPORT 
BY: AUDIT AND RISK MANAGER 
1. REASON FOR REPORT 
1.1 The report advises Committee on the work of the Internal Audit Section for the
period from 8 May 2024 to 25 June 2024. 
1.2 This report is submitted to Committee in terms of Section III (I) (2) and (8) of
the Council’s Scheme of Administration relating to consideration of reports
from the Council’s Internal Auditor and monitoring delivery of the audit service
through receipt of quarterly reports on work carried out by Internal Audit. 
2. RECOMMENDATION 
2.1 That Committee consider the contents of this report, seeks
clarification  on any points noted and otherwise notes the report. 
3. BACKGROUND 
3.1 This report provides details of the following internal audit work concluded
during the period 8 May 2024 to 25 June 2024: 
Forres Academy 
3.2 A review of the administrative arrangements within Forres Academy has been
completed. The scope of this audit was to undertake a review of the Devolved
School Management Scheme in terms of the allocation of funding and the
management of these funds at the School. In addition to undertaking an
overview of how the School develops, monitors and controls its £5.1 million
budget, the audit reviewed the management of the staffing costs involved in
delivering the curriculum. The audit checked that non payroll expenditure
complied with Financial Regulations and Procurement Guidelines. A review
was also undertaken to ensure appropriate accounting arrangements are
followed when managing school fund monies. The review found that within the
audit scope, Forres Academy was well managed. The executive summary and
recommendations for this project are given in Appendix 1. 
Item 7.
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Keith Sports and Community Centre 
3.3 An audit of Keith Sports and Community Centre has been undertaken. The
audit reviewed and evaluated the effectiveness of internal controls relating to
income and expenditure. Included within the audit was a review of the income
collection and monitoring arrangements of the FitLife? membership scheme.
The scope of the audit also included a check that the processing of debit and
credit card transactions adhere to the Payment Card Industry Data Security
Standard. The Centre provides various services, including a swimming pool,
gym, indoor and outdoor sports facilities. In addition, the Centre undertakes the
administrative overview and management responsibility for the other Council
operated sporting facilities.  Findings from the audit found improvements are
needed in the administrative arrangements, especially regarding the FitLife?
membership scheme. The executive summary and recommendations for this
project are given in Appendix 2. 
4. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan
(LOIP))
Internal audit work supports good governance and the delivery of
efficient services. 
(b) Policy and Legal
No implications. 
(c) Financial Implications
No implications directly arising from this report. 
(d) Risk Implications
The independent review of selected systems and procedures mitigates
the risks associated with inadequate or ineffective control procedures. 
(e) Staffing Implications
No implications. 
(f) Property
No implications. 
(g) Equalities/ Socio Economic Impacts
No implications. 
(h) Climate Change and Biodiversity Impacts
No implications. 
(i) Consultations
There have been no direct consultations during the preparation of this
report. 
5. CONCLUSION 
5.1 This report provides Committee with a summary of findings arising
from an audit project completed during the review period. 
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Author of Report:            Dafydd Lewis, Audit and Risk Manager
Background Papers:       Internal audit files 
Ref:                                 SPMAN-1042990102-235
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Page 55

APPENDIX 1 
AUDIT REPORT 24'025
FORRES ACADEMY 
Executive Summary 
The annual Internal Audit plan for 2023/24 provides for a review of a secondary school
within Education Services. This audit details the findings from the review undertaken
of Forres Academy as part of a rolling programme of visits planned for all secondary
schools.   
The scope of this audit was to review the Devolved School Management Scheme in
terms of funding allocation and management at the school level. Consideration was
given to how budgets are affected by National, Council, and School priorities. 
In addition to undertaking an overview of how the School develops, monitors and
controls its £5.1 million budget, the audit involved a study of the management of the
staffing costs involved in delivering the curriculum. The audit checked that non payroll
expenditure complied with Financial Regulations and Procurement Guidelines. A
review was also undertaken to ensure appropriate accounting arrangements are
followed when managing School Fund monies in accordance with the School Fund
Regulations. This report sets out the work undertaken in relation to the 2023/24
financial year. 
The audit was carried out in accordance with the Public Sector Internal Audit
Standards (PSIAS). 
The review found that within the scope of the audit that Forres Academy was well
managed and had a good appreciation of policies, procedures, and financial
management processes. However, consideration should be given to the following: - 
• It was noted that an independent accountant prepares the School Fund
annual accounts. It is appreciated that preparation of the annual
accounts requires the accountant to have an understanding of School
Fund transactions. However, the accountant details that the preparation
of the annual accounts does not include any auditing certification. In
accordance with the School Fund Regulations, annual accounts must be
independently audited. Further clarification of the role of the appointed
accountant to the School Fund should be undertaken, or an Auditor must
be appointed to certify the annual accounts.   
• The School was found to have a good awareness of the need to ensure
effective arrangements to protect and restrict access to confidential
information to only authorised officers. It was noted that information is
held on mobile storage devices and stored securely within a secure
location. However, there are recognised security risks with mobile
devices. Consideration should be given to using the Council network for
storing information where user access can be restricted.  
Item 7.
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The Internal Audit Section provides Management with an opinion on the internal
control environment and also categories risk ratings for recommendations as high,
medium or low. The audit recommendations for this review have been classified as
follows: 
Risk Ratings for Recommendations
High Medium Low
Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Less critically important controls
absent, not being operated as
designed or could be improved. 
Lower level controls absent, not
being operated as designed or
could be improved. 
0 3 0 
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Recommendations 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Key Control: School Funds are administered in compliance with the School Fund Regulations. 
5.01 Current auditing
arrangements of the School
Fund should be clarified, and
in accordance with the School
Fund Regulations, an auditor
appointed. 
Medium Yes Meeting to be
held with the
School Fund
Accountant to
make
arrangements
for the
accounts to be
audited going
forward.
Head Teacher 31/08/2024
5.02 A full reconciliation between
the cashbook and bank
statements should be
undertaken every month, and
evidence retained. 
Medium Yes School Fund
reconciliation
procedures
have now been
amended to
ensure full
reconciliation
takes place.
School
Support     
Co-Ordinator 
Implemented
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Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Key Control: Effective information management controls are operating in the use of ICT systems at the School. 
5.03 Investigation should be
undertaken into using the
Council network for saving
confidential information,
rather than within mobile
storage devices. 
Medium Yes A review of
information
currently held
on mobile
storage
devices is
being
conducted with
a view to
storing any
confidential or
information
using the
Council
network.
School
Support     
Co-Ordinator 
31/08/2024 
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APPENDIX 2 
AUDIT REPORT 24'024
KEITH SPORTS AND COMMUNITY CENTRE   
Executive Summary
The annual Internal Audit Plan for 2023/24 provided for an audit of the arrangements
for the accounting of income and expenditure at Keith Sports and Community Centre.
In addition, the review also included a check of whether the procedures followed in
processing debit and credit card transactions comply with the Payment Card Industry
Data Security Standard. 
The Keith Sports and Community Centre provides a range of services that include a
swimming pool, gym, indoor and outdoor sports facilities.  In addition, the Centre
undertakes the administrative overview and management responsibility for the other
Council operated sporting facilities. The audit also reviewed the income collection and
monitoring arrangements of the ‘FitLife?’ membership scheme.
In 2023/24, Keith Sports and Community Centre's operating costs were approximately
£472,000. The income collected at the Centre was approximately £412,000. Council
income received from the FitLife? membership scheme was £1.45 million. The audit
involved a review of systems to evaluate the effectiveness of internal controls. This
involved the sample testing of individual transactions to ensure compliance with
Financial Regulations and Procurement Guidelines. In addition, an appraisal of
working practices was also undertaken to assess if the Service was maximising the
income due to the Council.
The audit was carried out in accordance with Public Sector Internal Audit Standards
(PSIAS). 
The main findings of the audit were as follows: - 
• FitLife? membership is administered through a software application system
called Gladstone. However, the Council’s Financial Management System
(FMS) manages direct debits for membership payments. A reconciliation
between both systems noted that more service users were recorded within
Gladstone than in FMS. The format of data fields held between Gladstone and
FMS is different, but from the audit testing undertaken, service users were
identified where access to sporting facilities remained, but without a payment
plan. 
• It was noted that the FitLife? scheme allows for a family membership category
with a set number of adults and under 18 service users. However, once a family
membership has been established, there is no alert within the Gladstone
System or a manual review currently being undertaken to highlight when an
individual becomes 18 with a requirement for a separate membership category. 
Item 7.
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• The Centre has some sporting clothing and equipment for sale. However, a
review of the purchases of these items for resale noted examples where they
had not been bought from an approved supplier in accordance with the
Council’s Procurement Guidelines. The audit review also noted where further
improvements are required in the stock management arrangements.   
The Internal Audit Section provides Management with an opinion on the internal
control environment and also categories risk ratings for recommendations as high,
medium or low. The audit recommendations for this review have been classified as
follows: 
Risk Ratings for Recommendations
High Medium Low
Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Less critically important controls
absent, not being operated as
designed or could be improved. 
Lower level controls absent, not
being operated as designed or
could be improved. 
1 5 2 
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Recommendations 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Key Control: Effective controls operate in the financial management of the Keith Sports and Community Centre and the FitLife? membership
scheme.  
5.01 In accordance with Financial
Regulations and Petty Cash
Guidance, reimbursement of
parking fees must be made
through an officer’s expenses
claim and not from the petty
cash account. 
Low Yes Parking fees
will no longer
be reimbursed
through Petty
Cash, but will
be claimed by
officers through
a Mileage &
Other
Expenses
Claim Form.
Principal Sport
& Leisure
Officer  
Implemented 
5.02 Details of the numbered
receipt provided by a security
company for cash collections
should be recorded within the
income records at the Centre.   
Medium Yes Cash
Collection
procedures are
to be amended
to ensure that
security
company
receipt
numbers are
recorded on
corresponding
Principal Sport
& Leisure
Officer  
30/06/2024
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Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
income
records.
5.03 Officers must use their
individual login credentials
when using the Gladstone
system. 
Medium Yes All staff are to
be reminded of
the
requirement to
use their
individual
allocated log in
credentials
when using the
Gladstone
System.
Principal Sport
& Leisure
Officer  
30/06/2024 
5.04 A reconciliation between the
Gladstone system and FMS
should be undertaken to
identify service users with no
agreed payment plans. New
payment plans should then be
agreed for the service users
identified, or membership
should be cancelled. 
High Yes A reconciliation
exercise
between the
Gladstone
System and
FMS is
currently
underway to
identify all
active FitLife?
members with
no payment
plan.
Principal Sport
& Leisure
Officer  
31/07/2024 
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Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Membership
status will then
be agreed with
service users,
and if required,
any
outstanding
membership
fees will be
recovered. 
5.05 Failure in direct debit
payments should result in the
immediate suspension of a
service users FitLife?
membership. 
Medium Yes A service
user’s Fitlife?
membership
will be
suspended on
notification of a
stopped or
failed direct
debit from the
Payments
Service. A
review is also
planned of
whether further
use could be
Principal Sport
& Leisure
Officer / Sport
& Culture
Service
Manager 
30/09/2024
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Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
made of the
Gladstone
System to allow
for the
management of
direct debit
membership
payments. 
5.06 Regular reviews should be
undertaken of FitLife? Service
users to ensure they remain
within the correct category of
membership. 
Medium Yes A system was
in place to
identify and
amend family
membership
when a person
turns 18, but
unfortunately, it
lapsed due to
staff capacity
issues. These
monthly
procedures will
be reinstated.
Principal Sport
& Leisure
Officer / Sport
& Culture
Service
Manager 
30/06/2024
5.07 A review should be
undertaken to assess the
need to maintain a Repairs
Low Yes Repairs and
Works Log
recording
Principal Sport
& Leisure
Officer 
30/06/2024 
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Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
and Works Log. If required,
processing of minor work
orders should be in
accordance with agreed
Centre procedures. 
procedures at
the Centre are
to be
maintained in
accordance
with agreed
procedures
used at other
leisure
facilities. 
5.08 Sporting equipment and
clothing bought for re-sale
should be purchased in
accordance with Procurement
Guidelines. In addition,
appropriate stock control
records should be maintained
of sporting clothing and
equipment held for resale. 
Medium Yes A review of the
procurement of
sporting
equipment will
be carried out
to ensure that
future
arrangements
comply with
Procurement
Guidelines.
Stock control
procedure to be
introduced
Principal Sport
& Leisure
Officer 
31/08/2024
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Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
across all
facilities.
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REPORT TO:    AUDIT AND SCRUTINY COMMITTEE ON 25 JUNE 2024 
SUBJECT: ANNUAL GOVERNANCE STATEMENT 
BY: INTERIM CHIEF EXECUTIVE 
1. REASON FOR REPORT 
1.1     This report provides Committee with a copy of the Council’s Annual
Governance Statement for 2023/24 for review and approval. 
1.2     This report is submitted to Committee in terms of Section III (I) (5) of the
Council’s Scheme of Administration relating to supporting the council’s
governance arrangements through review of the Annual Governance
Statement. 
2. RECOMMENDATION 
2.1     Committee is asked to scrutinise the draft Annual Governance Statement
provided as Appendix 1. 
3. BACKGROUND 
3.1      The function of good governance in the public sector ensures that entities act
in the public interest at all times. Governance comprises the arrangements put
in place to ensure intended outcomes are defined and achieved. 
3.2 The Chartered Institute of Public Finance and Accountancy (CIPFA) and the
Society of Local Authority Chief Executives (SOLACE), building on work
undertaken by the International Federation of Accountants, have published a
guidance framework on ‘Delivering Good Governance in Local Government’. 
3.3  The Local Authority Accounts (Scotland) Regulations 2014 requires the
Council to publish an Annual Governance Statement with its annual accounts.
The Statement is based on the guidance and summarises practice across the
seven principles identified within the framework, considers the roles of those
who oversee the development and operation of such practice, and provides an
overall assessment of the effectiveness of governance arrangements. The
statement includes an annual opinion provided by the Audit and Risk Manager
in line with Public Sector Internal Audit Standards.  
Item 8.
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3.4  Good governance practice involves both elected members and officers and
this is reflected in the requirement for the statement to be certified by both the
Leader of the Council and the Interim Chief Executive as Acting Head of Paid
Service. 
3.5  The statement is subject to review by external audit, where the external auditor
is required to report on anything believed to be inconsistent with any other
findings disclosed from the audit work completed. There has been nothing to
report in this regard in previous annual audits. 
4. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan
(LOIP))
Governance refers to how organisations are managed and controlled.
Effective governance is key to the delivery of the strategic priorities
promoted in Community and Council strategic plans. 
(b) Policy and Legal
The Annual Governance Statement forms part of the annual accounts
the Council is required to prepare under statute. 
(c)  Financial Implications 
No implications directly arising from this report. 
(d)  Risk Implications
Good governance includes the effective management of risk, as
evidenced in this ‘risk implications’ paragraph in all reports that come
before the council and its committees, and in the council’s corporate risk
register that is kept under review by Senior Management and reported at
agreed intervals to the Corporate Committee. 
(e) Staffing Implications
No implications directly arising from this report. 
(f) Property
No implications. 
(g) Equalities/ Socio Economic Impacts
No implications. 
(h) Climate Change and Biodiversity Impacts
No implications. 
(i)  Consultations
The Interim Chief Executive, and Corporate and Senior Management
Teams have been consulted and have contributed to the content of the
Annual Governance Statement. In addition, the Leader of the Council, as
a signatory to the Statement, has also been consulted.  
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5. CONCLUSION 
5.1 This report provides Committee with a copy of the draft 2023/24 Annual
Governance Statement, which has been produced following completion
of the annual review of the Council’s governance arrangements and
system of internal control. 
Author of Report:  Atholl Scott, Business Continuity and Risk Management Officer
Background Papers: Various including Committee Reports and Senior Manager   
Assurance Statements
Ref: AS/asc250624/ags  
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APPENDIX 1
1
Annual Governance Statement 2023/24 
Scope of Responsibility 
The council is responsible for ensuring its business is conducted in accordance with
the law and proper standards, and that public money is safeguarded, properly
accounted for, and used economically, efficiently and effectively. The council has a
statutory duty to make arrangements to secure Best Value under the Local
Government in Scotland Act 2003. 
In discharging these responsibilities, elected members and the corporate and senior
management teams are responsible for putting in place proper arrangements for the
governance of the council’s affairs and for facilitating the effective exercise of its
functions. In delivering these functions, there is a requirement to maintain effective
partnership working with others, principally with NHS Grampian and Moray
Integration Joint Board, Grampian Valuation Joint Board, and the Moray Leisure
Centre, as well as with other bodies involved in Community Planning and in the
delivery of the Moray Growth Deal. 
This annual governance statement, which covers the period from 1 April 2023
through to the date of signing of these annual accounts, explains how the council
has used the CIPFA/SOLACE 2016 Framework ‘Delivering Good Governance in
Local Government’ as a basis for considering the effectiveness of its own
governance arrangements.
Framework for Good Governance 
The overall aim of the ‘Delivering Good Governance in Local Government’
Framework is to ensure that: resources are directed in accordance with agreed
policy and according to priorities; there is sound and inclusive decision making; and
there is clear accountability for the use of those resources in order to achieve
desired outcomes for service users and communities. 
The CIPFA/SOLACE Framework defines the seven core principles of good
governance, namely: 
1. Behaving with integrity, demonstrating strong commitment to ethical values, and
respecting the rule of law; 
2. Ensuring openness and comprehensive stakeholder engagement; 
3. Defining outcomes in terms of sustainable, economic, social and environmental
benefits;
4. Determining the interventions necessary to optimise the achievement of the
intended outcomes; 
5. Developing the entity’s capacity, including the capability of its leadership and the
individuals within it;
Item 8.
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6. Managing risks and performance through robust internal control and strong public
financial management; and 
7. Implementing good practices in transparency, reporting, and audit to deliver
effective accountability.
The key elements of the council’s governance arrangements are described in terms
of the seven principles defined in the Framework, summarised as follows: 
1. Behaving with integrity, demonstrating strong commitment to ethical values,
and respecting the rule of law; 
The roles and responsibilities of elected members and senior officers and the
processes to govern the conduct of the council’s business are defined in procedural
Standing Orders, a Scheme of Administration, a Scheme of Delegation, and
Financial Regulations. These are updated in response to strategic need. The
Schemes of Administration and Delegation were revised during the year primarily to
reflect amendments to the Integration Scheme for the Health and Social Care
Partnership. Standing Orders were also updated to support improvements in
collaborative leadership. Codes of Conduct for both elected members and officers
are in place, and these define the ethical values and standards of behaviour
expected. The Codes draw on the ‘Standards in Public Life’ covering issues
including leadership, fairness and integrity. 
The Council’s Head of Governance, Strategy and Performance is the designated
Monitoring Officer responsible for ensuring that agreed procedures are followed and
that all applicable statutes and regulations are complied with. External support during
the period has also assisted in the development of collaborative leadership as an aid
to good governance in decision making. 
2. Ensuring openness and comprehensive stakeholder engagement;
In developing improvement and modernisation opportunities, meetings of the council
and its committees are delivered using a hybrid format that enables attendance in
person or via web link. Meetings are live streamed and available for public viewing,
with matters discussed and determined in confidence relating only to those deemed
confidential in terms of Part 1 of Schedule 7A of the Local Government (Scotland)
Act 1973.  The rationale for all decisions proposed and taken is fully set out in
committee reports. 
Stakeholder engagement is central to the council’s work at a strategic level, notably
in the development of the Corporate Plan which was refreshed during the year. Both
staff and the public were surveyed, and the results reported to a meeting of the
council to aid and inform consideration of the priorities to be taken forward. Service
consultations are also conducted as appropriate, recent examples including a tenant
satisfaction survey in housing, and on options for future school provision in several
communities across Moray.  The council’s petitions process was also widened to
include and improve engagement with groups under 18 years of age.
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The council seeks and obtains feedback on delivery of its services having adopted a
comprehensive complaints procedure based on a model scheme developed by the
Office of the Scottish Public Services Ombudsman. All complaints are responded to
as appropriate, and inform improvements to service delivery. A comprehensive
report on complaints handling is prepared and presented annually to a council
committee. 
3. Defining outcomes in terms of sustainable economic, social, and
environmental benefits;
The creation and implementation of a vision for the local area, including expected
outcomes for the community, is encompassed in the Local Outcomes Improvement
Plan (LOIP). The overarching aim and purpose of this 10-year Plan is ‘to raise
aspirations by creating an enabling environment where our residents can achieve
expanded choices, improved livelihoods and wellbeing”. 
In particular, the LOIP recognises the importance of and benefits from reducing
inequalities and poverty, with outcomes focused on the need for a growing, diverse
and sustainable economy, building a better future for our children and young people
in Moray, empowering and connecting communities, and a broadened objective of
improving the wellbeing of our population. 
The LOIP is a partnership plan, and its strategic delivery is overseen by a
Community Planning Board, which meets quarterly. The Board comprises
representatives from a broad range of organisations as reflected in agenda items
considered during the year. These included reports on School Age Childcare,
Climate Change, Moray Growth Deal, Behaviour in Moray schools; Promotion of
Physical Activity, and Health and Transport partnership working. Development
sessions have been held to further strengthen good governance arrangements,
recognising the benefits that working in partnership can bring. 
A proposal under active consideration is the development of a single multi-agency
strategic plan for Moray. Currently the LOIP sits alongside a refreshed Corporate
Plan Moray 2024-2029, that sets out the vision and priorities of the council for the
next five years. The council plan updates council priorities focussing on three key
themes; tackling poverty and inequality, building a stronger greener vibrant
economy, and seeking to build thriving, resilient, empowered communities. The plan
sets targets for outcomes consistent with maintaining a sustainable council that
provides valued services to its communities. 
4. Determining the interventions necessary to optimise the achievement of the
intended outcomes; 
The strategic partnership and corporate plans are translated into service plans
prepared within each council service area. These facilitate delivery of agreed
outcomes and assist in securing continuous improvement. Service plans are
reported to a meeting of the council or appropriate service committee for
consideration and approval, in reports that provide information on planned activity.
More generally, all committee reports contain a ‘Summary of Implications’ section
that links report content to strategic plans, legal and policy issues; financial
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implications, risk, staffing and property matters; equalities; social impact; and climate
change and biodiversity considerations. A particular focus is given to financial
implications given the current economic climate.
The council is fully aware of the financial challenges it faces and through its
established committee structures, elected members have been provided with an
extensive volume of information on both the availability of resources and options for
future service delivery. This has been reflected in reports to the council on budget
setting, including projections for the medium to longer term, and regular budget
monitoring reports. The council successfully delivered a balanced budget for
2024/25, noting that its financial position in future years is not sustainable based on
current known factors.
This sustainability issue is one of a number of issues highlighted by the Accounts
Commission during the period in its latest report on Best Value, with concerns raised
about the council’s capacity to effect change of the scale required within a relatively
short time frame.
The achievement of agreed outcomes is monitored through an established
Performance Management Framework that calls for frequent reporting on key
performance measures developed for each service. In addition, the council
participates in the Local Government Benchmarking Framework which compares a
range of established performance measures with those of other Scottish local
authorities. Elected members are provided with reports to review, scrutinise and note
actions undertaken by services to meet performance objectives and an annual Public
Performance Report is prepared and published. 
5. Developing the entity’s capacity, including the capability of its leadership
and the individuals within it;
The Corporate Management Team (CMT) consists of a Chief Executive, two Depute
Chief Executives and the Chief Officer, Health & Social Care Moray. CMT is
supported by a Senior Management Team (SMT) comprising nine Heads of Service.
CMT/SMT meet frequently to discuss and provide leadership on the strategic
direction of the council. 
The Chief Executive is responsible and accountable to the council for all aspects of
management including promoting sound governance, providing quality
information/support to inform decision making and scrutiny, supporting other
statutory officers, and building relationships with all elected members. This role is
currently filled on an interim basis following retirement of the permanent jobholder.
Four other senior management posts have also seen changes during the period due
to staff retiring or leaving the organisation. 
Leadership capacity of senior officers is supported through the promotion of a
Leadership Forum, which brings together senior managers from all services to
provide a wider perspective to the consideration of issues facing the council. Forum
meetings ensure consistent messaging is available from senior management to
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managers. Human Resources has continued to review and refine the leadership
development strategy and provide training opportunities online. 
The council has an agreed elected members’ development strategy that includes an
on-going training programme of learning, development and briefings. Members
appointed to certain committees also receive specific training related to the
responsibilities of these committees. A Strategic Leadership Forum has been
established involving both elected members and senior officers to facilitate cross
party discussions on the future direction of council services.
In addition, elected members represent the council on a range of outside bodies,
including on boards of other Community Planning partners, across partnership
bodies such as the Moray Economic Partnership, various national bodies such as
COSLA and its themed Boards, and a broad range of charitable and third sector
organisations. This representation provides valuable learning and networking
opportunities for those members. 
6. Managing risks and performance through robust internal control and strong
public financial management; 
The council has a risk management policy designed to support the identification,
evaluation and mitigation of risks that may impact on its ability to meet its objectives.
The policy was updated during the year. A Corporate Risk Register is also
maintained providing summary information on what the CMT/SMT considers are the
principal risks facing the council. The register describes how these are managed and
controlled. Risk implications feature in committee reports to inform the decision-
making process.
The council’s system of internal control is based on a framework of financial
regulations, regular management information, administrative procedures,
management supervision and a scheme of delegation that defines accountabilities of
senior officers. Establishing and maintaining an effective system of internal control is
a management function. An Audit and Scrutiny Committee, through its consideration
of reports by internal and external auditors, monitors the effectiveness of the system
of internal control.
Strong financial management is secured through the work of the Chief Financial
Officer appointed in terms of s.5 of the Local Government (Scotland) Act 1973. This
officer advises the Council on all financial matters and ensures the timely production
and reporting of budget estimates, budget monitoring reports and annual accounts.
Draft and audited Annual Accounts are published on the council website. 
7. Implementing good practices in transparency, reporting, and audit to deliver
effective accountability;
Council business is conducted through an established cycle of webcast committee
meetings. Webcasts remain available for viewing for 12 months following a meeting.
Meeting dates are published in advance, and agenda papers are made available at
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least one week before meetings take place. Minutes of meetings are prepared, and
important decisions are publicised on the council website and through social media.
The council’s website provides a platform from which to disseminate a wide range of
information including news items on policy decisions, guidance on council services,
and on service disruptions/interruptions arising from weather events or similar. The
website increasingly facilitates efficient access to digital services across a range of
service areas and allows for consultations to be undertaken and for interested
parties to provide feedback electronically. 
The council responds to the findings and recommendations of Internal Audit,
External Audit, and other Scrutiny and Inspection bodies by developing improvement
Action Plans. The Audit and Scrutiny Committee is integral to overseeing
independent and objective assurance processes that make recommendations for
improvements to the system of internal control. Training for elected members on the
specifics of effective scrutiny was provided during the period.
The council responds to requests for information under Freedom of Information
legislation having processed over 1,500 such requests during the period covered by
this statement. 
Review of the Adequacy and Effectiveness of the Council’s Governance
Framework 
In order to assess the effectiveness of the governance framework, including the
system of internal control, it is necessary to consider the role of the functions and
individuals who contribute to it, as follows: 
•  Elected Members 
Governance arrangements at a political level emanate from the council, its
committees and from other roles that elected members fulfil. These include
participation in the Community Planning Board and associated groups for multi-
agency issues. Elected members also have substantive roles on the Moray
Integration Joint Board for Health and Social Care, the Grampian Valuation Joint
Board, and the Moray Leisure Arm’s Length External Organisation (ALEO), each of
which has its own governance arrangements. In addition, elected members have
membership and represent Moray Council interests in partnerships that contribute to
meeting council aims and objectives, notably in the development and delivery of the
Moray Growth Deal.  
Audit and Scrutiny Committee
The council has an Audit and Scrutiny Committee where elected members consider
reports on audit matters. These provide assurances on the adequacy and
effectiveness of the system of internal controls including those relative to the delivery
of plans, compliance with laws and regulations, accuracy of information and
safeguarding of assets. The Committee functions in line with best practice guidance
published by the Chartered Institute of Public Finance and Accountancy. Two
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external members sit on the committee to provide an independent perspective on
issues under consideration.
This committee is a key component of good governance, distinguished from other
committees by the role elected members are required to fulfil, not in setting policy or
considering service matters, but by providing independent oversight and challenge in
support of the council’s duty to secure continuous improvement. These functions are
delivered independently from the supervisory oversight roles of the Corporate and
Senior Management Teams. 
• The Corporate Management Team 
The Corporate Management Team (CMT) has overarching operational responsibility
for good governance arrangements. The team comprises the Chief Executive, two
Depute Chief Executives with portfolio responsibilities for Education, Communities
and Organisational Development; and Economy, Environment and Finance
respectively, and the Chief Officer (Health and Social Care Moray). 
• The Corporate Management Team / Senior Management Team 
This is an extended management team comprising the CMT and Heads of Services.
The role and remit of this group is to support the formulation and implementation of
policies, strategies and plans to achieve local and national outcomes, to share and
promote good practice from an inter-service perspective, to act with the wider
objectives of the council in mind to ensure the resources are effectively deployed,
and to assist CMT in keeping the governance of the council and its services under
review. 
Individual Heads of Service, collectively the Senior Management Team (SMT), have
considered the effectiveness of governance arrangements within their respective
services by reference to the principal risks identified in the council’s Corporate Risk
Register and provided assurance statements for use in the preparation of this
corporate statement. This affirms the broad ownership of good governance and
recognition of its importance within the senior leadership of the council.
Overall, the assurance statements provided confirm that governance arrangements
within services are working as intended, and in support commentary has been given
on elevated risks and on mitigating actions taken in response. The main issues
raised in these returns are:
• Staffing shortages and vacancies impacting on capacity to deliver change at
pace and on the interdependencies required to progress complex areas of
work.
• Continuing risk of data breaches with monitoring statistics showing the
number of breaches remaining broadly similar compared with last year. This
despite mitigating actions having been taken to provide refresher training and
remind staff of the importance of holding personal data safely and securely. 
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• Elements of partnership working require on-going attention, including
oversight and control of the council’s funding contribution to the Health and
Social Care Partnership (as detailed further below), and a need to progress
work to secure an updated service level agreement with Moray Leisure
Centre. 
• Housing Service obligations to monitor homelessness data and progress
electrical safety improvements in council houses in support of national
initiatives directed by the Scottish Housing Regulator.
• A need for continued focus on Health and Safety requirements thereby
protecting the workforce and minimising the number of reportable incidents. 
• The Head of Governance, Strategy and Performance (Monitoring Officer) /  
Chief Financial Officer 
The Head of Governance, Strategy and Performance and the Chief Financial Officer
perform their respective statutory duties as outlined elsewhere in this statement. In
discharging the responsibilities of the role, the Chief Financial Officer complies with
the governance requirements of the CIPFA Statement on the role of the Chief
Financial Officer, and the Head of Governance, Strategy and Performance provides
an annual report on the duties of Monitoring Officer to a meeting of the council. 
• The Chief Social Work Officer 
The Head of Service, Health and Social Care Moray fulfils the statutory role of Chief
Social Work Officer (CSWO) as part of the duties of the post. The latest available
CSWO annual report for the year to 31 March 2024 notes continuing challenges,
with increased service needs set against financial and recruitment pressures. 
This is the first year Children & Young People and Criminal Justice Social Work
services have been fully integrated into the Health and Social Care Partnership. The
report describes this as a period of many changes and adjustment, and that work will
continue to better align governance structures across Health and Social Care. 
Improvements under way include replacement of the case management system,
development of data used for performance reporting, and progressing the review of
adult commissioning arrangements in response to a recently completed audit of
current practice by an external firm. 
The report also noted an impending change in the holder of the CSWO post and in a
number of other senior manager roles and stresses the importance of ensuring
services remain as stable as possible during a period of further transition. Key to this
will be the realisation of savings plans, while delivering appropriate and proportionate
services that uphold the rights and best interests of individuals in need of support.
Interim appointments have since been made to the posts of CSWO and Chief Officer
- Health and Social Care. 
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• Internal Audit
The Audit and Risk Manager is accountable on a day-to-day basis to the Head of
Governance, Strategy and Performance and to the Audit and Scrutiny Committee.
Internal Audit applies mandatory Public Sector Internal Audit Standards (PSIAS) in
delivering the Internal Audit Service. 
PSIAS requires an external quality assessment of Internal Audit to be undertaken at
least every five years. This assessment was conducted during the year and
disclosed that the service fully complies with these Standards.
The Council has a system of internal control designed to manage risk to a
reasonable level. Internal controls cannot eliminate the risk of failure to achieve
policies, aims and objectives and can therefore only provide reasonable and not
absolute assurance of effectiveness. 
The internal audit plan for the year includes a range of audit projects covering main
financial systems, other systems operating within services and several ad-
hoc/unplanned projects. The outcomes from these projects, together with any
recommendations to enhance the control environment, are reported to the Audit and
Scrutiny Committee. This Committee is chaired by an elected member who is not
part of the council Administration. Almost all planned reviews detailed within the
Annual Internal Audit Plan for 2023/24 were completed as scheduled. 
PSIAS requires an internal audit opinion to be provided annually. As planned audit
work was substantially completed by the year-end and based on this and other
knowledge of the organisation and its control systems, it is the opinion of the Audit
and Risk Manager that reasonable assurance can be placed upon the adequacy and
effectiveness of the internal control environment which operated in the council during
the year. 
• Health & Social Care Partnership 
The council, as a key partner of Health and Social Care Moray has an interest in the
governance arrangements of the Moray Integration Joint Board (MIJB). This given its
financial exposure as a principal funder and continuing statutory responsibilities for
Social Work services and the role of the Chief Social Work Officer.
Audit arrangements for the MIJB are provided jointly by the council’s Internal Audit
Service and NHS Grampian’s Internal Auditors. The council’s Audit and Risk
Manager (as Chief Internal Auditor for the MIJB) provides assurance over social care
services, and oversight of the MIJB governance arrangements. There is no formal
reporting of internal audit work relative to NHS services delivered under direction by
the IJB, these audits are reported solely to the NHS Grampian’s Audit Committee.
This position remains under review, the appointed NHS internal auditors being
contractually accountable only to the NHS and not to any other third party.
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From audit work completed in this role, the Chief Internal Auditor has provided an
opinion of only limited assurance that the Moray Integration Joint Board has
adequate systems of governance and internal control for the year ended 31st March
2024. 
A particular governance consideration for the council on a recurring basis is the
financial sustainability of the MIJB, with any overspend against budget requiring to
be met by NHS Grampian and the council as principal funders, pro-rata in line with
an agreed funding agreement. For the 2023/24 financial year, an overspend was
forecast and work undertaken to identify savings. While progress has been made,
service pressures in Health and Social Care are likely to persist and require close
monitoring going forward.  
• External Agencies 
In addition to the various internal review processes and the external audit of the
Annual Accounts, aspects of the council’s governance arrangements are considered
in various inspection reports produced by the external auditor and other inspectorate
agencies.
The latest Accounts Commission Best Value Report on the council, while highlighting
areas of good practice, made a number of recommendations to further strengthen
systems and processes in key strategic areas. The council in response has reviewed
its governance arrangements around priorities and strategic direction, and prepared
a comprehensive Best Value Action Plan and Transformation Strategy to aid
progress. The Best Value Report findings were formally accepted at a special
meeting of the council on 12 June 2024. A need for additional resources to support
implementation of these plans has been identified.
Overall assessment of the effectiveness of governance arrangements
Having regard to the information provided in the preceding paragraphs, it is
considered that established systems and processes are broadly fit for purpose and
not inconsistent with the seven principles identified in the ‘CIPFA/SOLACE’
Framework ‘Delivering Good Governance in Local Government.’ 
Significant governance issues 
Governance issues requiring attention for the prior financial year 2022/23 were
described in the management commentary published with the Annual Accounts for
that year as risks and mitigation measures. They were not restated in the Annual
Governance Statement. The council has a good awareness of its risks through
regular consideration of its Corporate Risk Register, and of how it seeks to mitigate
these risks having regard to the extensive regulatory framework in which it operates.
Looking forward, the focus on strengthening governance arrangements further has
been aligned to a recent Accounts Commission Best Value report, and to a report
prepared by an external adviser who provided consultancy support during the period.
These reports informed a Best Value self-assessment exercise completed by council
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managers and the development of a three-year action plan designed to effect
improvements. The following are priority areas:
▪ Continue work to establish a clear shared vision for Moray that supports
delivery of sustainable public services.
▪ Maintain current activity to ensure leadership is effective and there is good
collaboration between elected members and senior officers.
▪ Increase the pace of transformation and identify savings with the intention of
securing longer term financial sustainability.
▪ Revisit governance arrangements covering partnerships; principally for Health
and Social Care Moray in respect of performance and early identification of
any significant financial and service risks.
Creating capacity to deliver these priorities alongside the ‘routine’ business of the
council will be key to maintaining good governance arrangements. The challenge of
doing so remains considerable with difficulty in recruiting staff an issue reported
across many services and a number of senior manager positions presently vacant or
filled on an interim basis. Despite the risk this presents in terms of service continuity,
it also provides an opportunity to review roles and responsibilities within current
structures and determine any revisions necessary to support the effective delivery of
change going forward.
Concluding Remarks 
This Annual Governance Statement summarises the extensive governance
arrangements the council has in place to support delivery of its strategic plans and to
secure Best Value in its use of resources. While the statement demonstrates that
these arrangements are comprehensive and broadly fit for purpose, there are
multiple influences, both external and internal, that will impact on how council
services are designed and delivered going forward. It is clear that a period of
significant change and challenge lies ahead and this, inevitably, will require further
refinement of existing governance arrangements. In our respective roles as Council
Leader and Interim Chief Executive, we are committed to making this happen to
ensure the council and its resources continue to be effectively managed and
controlled. 
Kathleen Robertson                                                                 John W Mundell OBE     
Leader of the Council                                                         Interim Chief Executive
26th June 2024
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REPORT TO: AUDIT AND SCRUTINY COMMITTEE ON 25 JUNE 2024   
SUBJECT: LOCAL GOVERNMENT BENCHMARKING FRAMEWORK 2022-23
AND 2021-22 RESULTS 
BY:  DEPUTE CHIEF EXECUTIVE (EDUCATION, COMMUNITIES &
ORGANISATIONAL DEVELOPMENT) 
1. REASON FOR REPORT 
1.1 The reason for this report is to present to the Committee a corporate overview
of benchmarking performance data for the period 2022-23 and 2021-22. 
1.2 This report is submitted to Committee in terms of Section III A (4) of the
Council’s Scheme of Administration relating to monitoring performance in
accordance with the Council’s performance management framework. 
2. RECOMMENDATION 
2.1 It is recommended that the Committee consider and note the Council’s
performance in terms of a corporate overview of benchmarking results. 
3. BACKGROUND 
3.1 Local Government Benchmarking Framework (LGBF) data, most results are
published annually by late summer that informs the National Benchmarking
Overview Report.  Results are gathered from national sources following
annual data submissions that are subject to extensive validation processes, a
contributory factor to the time-lag in publication and reporting.  A limited
number of results are supplied directly by local authorities.  The full suite of
benchmarking data can be viewed using the LGBF Dashboard.   
3.2 Results and commentary on benchmarking performance are included in
Quarter 4 performance reports submitted to service committees in line with
the Council’s performance management framework.   
3.3 In response to previous member comments, for indicators in the lowest
quartile, where a more up to date position has been reported to service
Committee, this has been reflected in the narrative. 
Item 9.
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3.4 With work relating to budget savings and the corporate plan taking priority  in 
the latter part of 2023, reporting of the 2021/22 corporate overview of 
benchmarking data was delayed to such an extent most results for 2022/23 
have been published, therefore 2021/22 data is provided for information and 
to show performance trends, however the narrative and focus presented in 
the corporate overview relates to 2022/23, addressing the requirements of the 
Council’s Performance Management Framework.   
3.5 Nine indicators are not due for publication in 2022/23 due to national reporting
timescales, or they are no longer being collected locally. The remaining seven
indicator results yet to be published cover child poverty, housing energy
efficiency and carbon emissions. Results will be reported when they are
published. 
3.6 The summary (Appendix 1) for 2022/23 includes – 
i) notes to results by exception (indicators ranked in lowest quartile);
ii) bullet points highlighting results that have improved / worsened by 5%
(based on previous year);
iii) tables detailing all indicator results presented by service themes for
both years. 
3.7 The summary (Appendix 2) for 2021/22 includes – 
i)  notes to results by exception (indicators ranked in lowest quartile);
ii) bullet points highlighting results that have improved / worsened by 5%
(based on previous year). 
3.8  Caution is advised on making direct comparison between years due to 
significant impact of Covid-19 on more recent results, however an 
assessment based on available 2022/23 results can be inferred to an extent. 
The tables show that, for indicators currently published (92), there has been
an overall drop in performance with indicator result values worsening to a
greater margin (53%) than those that have improved (46%). 
3.9 Assuming no significant change in rankings for the seven indicators yet to be
updated, a shift towards the lower quartiles can be inferred in both national
and family groupings. 
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3.10 Indicators featuring in the lowest quartile (ranked 25th to 32nd) have  been 
scrutinised in relation to improvements by the relevant Service 
Committees as part of 2023/24 Quarter 4 Performance Reports, links where 
available are provided as background papers. Appendix 1 provides a
commentary on these indicators and the actions that are planned to address
them. However, it is recognised that a number of the indicators have been
consistently reported for some time.  Therefore, the current position will be
reviewed further by the Corporate Management Team to scrutinise and
ensure actions to secure improvement in priority areas and the outcome of
this will be reported to a future committee to ensure that the council is
focussed on continuing to improve performance to meet its priorities.
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4 SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
The Council and its partners have agreed priorities in the LOIP, with a
range of outcome targets included for each of the priorities.  It will be
important that service committees keep those targets in mind when
reviewing the performance data in the national benchmarking results, for
two reasons: 
1. To recognise that to achieve success the targets might mean weaker
performance in non-priority areas, and 
2. To consider whether the priorities and targets should be reviewed or
amended in light of the information contained with the national
benchmarking results. 
(b) Policy and Legal
The Council has a statutory obligation to publish a range of information
that will demonstrate that it is improving local services and local
outcomes, demonstrating best value and assisting in comparing
performance both over time and between authorities where appropriate. 
(c) Financial implications
There are no direct financial implications arising from this report. 
(d) Risk Implications
There are no direct risk implications arising from this report although
effective performance management assists in the management of risk. 
(e) Staffing Implications
There are no direct staffing implications arising from this report. 
(f) Property
None. 
(g) Equalities/Socio Economic Impact 
An Equality Impact Assessment is not needed because the report is to 
inform the committee on performance issues. 
(h) Climate Change and Biodiversity Impacts
None. 
(i) Consultations 
Heads of Service and Service Managers have been consulted on 
reports submitted to relevant service committees.
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5. CONCLUSION 
5.1 In 2022-23, based on publication of results to date, 43% of Local
Government Benchmarking Framework indicator results feature in the
top 16 of 32 Scottish councils compared to 52% in 2021-22. 
5.2 When compared to national and comparator performance, there may be
slight movement in rankings towards the lower quartiles in 2022-23
following a shift from first to second quartiles in 2021/22 results. 
5.3 The Corporate Management Team plan to undertake further review of
performance information and proposed improvement actions to ensure
that priority is given to improving in areas to ensure the Council
priorities are met and the outcome of this will be reported to a future
committee. 
Author of Report: Louise Marshall, Strategy and Performance Manager
Background Papers: National Benchmarking Overview Report 2021-22 
National Benchmarking Overview Report 2022-23 
LGBF Dashboards 
Performance Report (Financial Services) Period to March
2023 and March 2024 
Performance Report (Human Resources, Information
Communications Technology and Organisational
Development) Period to March 2023 and March 2024 
Performance Report (Governance, Strategy and
Performance) Period to March 2023 and March 2024 
Performance Report (Economic Growth and Development
Services) - Period to March 2023 and March 2024 
Performance Report (Environmental and Commercial
Services) - Period to March 2023 and March 2024 
Performance Report (Housing and Property Services) –
Period to March 2023 and March 2024 
Performance Report (Education) - Period to March 2023
and March 2024 
Performance Report (Education Resources and
Communities) - Period to March 2023 and March 2024 
Performance Report (Children and Families and Criminal
Justice Social Work) - Period to March 2023 
Ref: SPMAN-2045703626-423 / SPMAN-2045703626-405
SPMAN-2045703626-391 
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APPENDIX 1 
Local Government Benchmarking Framework
(LGBF) 
Benchmarking Overview
2022-23 
Item 9.
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Preface
All 32 Scottish councils signed up to the Local Government Benchmarking Framework, that
provides a common approach to benchmarking, which is grounded in reporting standard
information on services councils provide to local communities across Scotland.
The core purpose of local government’s efforts through this work is to support all councils to
improve their services by working and learning together.  By engaging in benchmarking,
services will learn how to continue to improve their use of performance information; improve
their understanding of variations which affect achievements and enabling the opportunity to
share effective service practices across councils.  This information is made publically
available, so that the public in turn can hold services to account for what is achieved on
their behalf.  The public are encouraged to use the information to ask questions of services
in order to engage with services in the improvement process. 
When reading the information, it is important to remember though that councils across
Scotland do not have common service structures.  Each council has the structure and
service arrangements that it believes are the most appropriate and cost effective to support
its local community.  Equally, all councils report their performance locally within developed
and agreed public reporting frameworks.  Therefore, to ensure comparability across
councils, it has been necessary to develop standard service definitions, and standard
classifications for spending and performance. 
Councils developed a process to drill into the information collated through the Local
Government Benchmarking Framework to understand, in more detail, why variations occur. 
The process was organised around ‘family groups’ of councils so that councils similar in
terms of the type of population that they service (e.g. relative deprivation and affluence) and
the type of area in which they serve them (e.g. urban, semi-rural, and rural) can compare. 
This allows improvements to the benchmarking framework to be identified and good
practice to be shared between councils. 
The indicators in the Framework cover how much councils spend on particular services;
service performance and how satisfied people are with the major services provided.  All the
information that this report draws upon uses standard definitions and is therefore
comparable to a high degree of accuracy. 
The indicators in the Local Government Benchmarking Framework are designed to focus
questions on why variations in cost and performance are occurring between similar
councils.  They do not supply the answers, those emerge as councils engage with each
other to drill down and explore why these variations are happening.  The LGBF Workshop
Programme has been added to the platform for learning and improvement. 
Our ambition in undertaking benchmarking is to continue to increase the quality of life and
develop the well-being of everyone in Moray.    
All of the information generated by the Framework has been placed in a dedicated website
LGBF Dashboard showing movement on indicators across themes, times and all councils. 
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Summary
The Local Government Benchmarking Framework (LGBF) data provides evidence of trends in how resources are allocated, performance
of services and levels of customer satisfaction.  This year’s results introduce data from 2022/23 and provides an evidence-based picture
of the impact of the pandemic as well as the extraordinary effort and achievement during this exceptional period.   
Exceptions based on 32 local authorities; areas of service delivery ranked in the lowest quartile are presented below as Notes to
Benchmarking Results.  Care should be taken when making comparison over time and with others due to the complexities around altered
delivery and operating landscapes during the reporting period. 
The National Benchmarking Overview Report 2022/23 is available here. 
Notes to Benchmarking Results (indicators
ranked in the lowest quartile)  
No Challenges Actions to improve Outcome
Children’s Services  
3 The proportion of children being looked after in
the community has seen a significant decrease
to 75.3%, the lowest level recorded. A
shortage of specialist foster carers has led to
children and young people with complex needs
being accommodated in residential settings. 
• Increased focus and resources on the recruitment of
foster carers, drawing on the assistance of local,
regional and national partners.
• Identify and address the training and development
needs of foster, kinship and residential care workers
employed.
• Better understand what peer support foster and kinship
carers want.
• Embed the learning from PACE in policies and
procedures relating to the placement of children and
young people in care.
• With care experienced children and young people
develop a local maintaining relationships policy with a
specific focus on siblings.
(Source: Children’s Service Plan 2023-26 (short term actions))
The number and range of placements available meets
the needs of children and young people in need of care. 
Siblings are supported to maintain positive relationships
with one another.
1 The proportion of secondary leavers achieving
5 or more awards at Level 6 have fallen for the
second consecutive year to 28%, in line with
similar trends witnessed nationally and within
our family group. 2020/21 and 2021/22, where
there was no formal examination diet, are not
comparable with the current period.
Performance in 2022/23 is broadly in line with
pre-COVID levels, again similar trends were
• Getting it right for every child so that we continue to
improve attainment for all.
• Further develop the curriculum in the BGE and Senior
Phase taking account of the national review and
international research including project based learning. 
Improved attainment at both Broad General Education
(BGE) and Senior Phase. 
Improved curriculum offer in line with national advice. 
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Notes to Benchmarking Results (indicators
ranked in the lowest quartile)  
No Challenges Actions to improve Outcome 
2
4,5,6,7,8
witnessed nationally and within our comparator
group. Scottish Qualifications Authority (SQA)
leaver attainment across secondary schools in
Moray was reported to the Education,
Children’s and Leisure Service Committee on
14 Mary 2024 (item 12 of the Agenda refers) in
the continued focus on improving outcomes
and raising attainment through the actions
noted in the report. 
Similarly, the proportion of leavers from the
most deprived 20% achieving 5 or more
awards at Level 6 has also decreased to 12%.
Differences in cohort numbers have a
significant impact on proportions. What
appears to be a significant reduction relates to
one less child achieving at this level. 
Tariff scores allows examination of how
different ability cohorts are attaining in relation
to the appropriate family and national cohorts
by allocating a specific number of points to
each qualification (including non-examination,
unit-based courses).  More demanding
qualifications gain more points than less
demanding ones and in graded courses, a
grade ‘A’ is equivalent to more points than a
grade ‘C’ for example, within the same course. 
The number of qualifications and units
available for a young person to complete
varies significantly due to the number of
different curriculum structures there are across
Scotland.  In Moray, scores decreased overall
and in across SIMD Quintiles 1-5. 
• Through renewed focus on the Scottish Attainment
Challenge Logic Model with specific regard to
outcomes at school/community and regional levels 
• Recent work on curriculum choice and innovations,
working with Education Scotland in collaboration with
Moray Secondary Schools and an ADES-Education
Scotland Collaborative Improvement event focused on
Senior Phase Curriculum will progress further work on
curriculum design for strengthened consortia working
and senior phase offers to improve scoring. 
(Source: Education Service Plan 2024-25) 
Meet stretch aims. 
Increased attendance, reduced exclusions. 
Increase in subjects, courses and accreditation 
9,10 The percentage of P1, P4 and P7 pupils
combined achieving expected CFE Levels in
Literacy and Numeracy made further
improvement to 67.9% and 75.5% respectively,
exceeding Stretch Aims targets and gaining
ground on national averages.  Support and
challenge discussions between the central
Quality Improvement Team and Head
Ongoing work to build and maintain improvement is
detailed in the Initial Analysis of Achievement of
Curriculum for Excellence Levels 2023 submitted to
Education, Children’s and Leisure Service Committee
on 20 February 2024 (para 3.38 of the report refers). 
• Early intervention addressing whole family well-being
to ensure that children can reach their full potential
Improved attainment at both Broad General and Senior
Phase identified through ACEL measures.
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Notes to Benchmarking Results (indicators
ranked in the lowest quartile)  
No Challenges Actions to improve Outcome
Teachers.  Roll-out of Seemis Progress and
Achievement for Tracking and Monitoring was
completed in June 2023 and a data analysis
tool (AnalyseM) was developed and training
completed in December 2023.    (Source: Education Service Plan 2024-25)
11,12 The percentage point gap in between the least
and most deprived pupils in the P1, P4 and P7
combined in literacy (75.5%) and numeracy
(32.1%) increased to proportionately a greater
degree than national increases.  
In collaboration with the Education Scotland Attainment
Advisor, schools continue to be supported with their
Pupil Equity Funding planning, allocations, and
spending in enacting interventions to close identified
poverty gaps based on intelligence and data.
Improved attainment at both Broad General and Senior
Phase identified through ACEL
13 Funded early years provision which is graded
good/better improved slightly to 87.5%.  The
increase duty brings significant challenges
around workforce expansion, building and
expanding provision, whilst simultaneously
maintaining and improving the quality is
challenging, faced with significant shortages in
the availability of qualified staff and seeing the
average experience level of the workforce
lowered.
Early years provision not reaching grade 4 good/better
receive support from the respective Continuous
Improvement Officer and the Early Years Teaching and
Learning Teacher to address the required actions
resulting from recommendations or requirements.  
Improve quality of leadership, learning, teaching and
assessment 
Improve self-evaluation profiles leading to change
Corporate Services  
14 There has been an improvement in the
Council’s gender pay gap to 5.3%. 
Improvement is partly down to pay deals which
disproportionately affect female dominated
jobs.  Across Scotland, results range from -6.2
to 11.4, reinforcing the likely variations in
methods of calculation.
• Have in place fair and competitive pay and conditions
that are recognised and free from bias. 
(Source: HR & OD Service Plan 2024-25)
Improved assessment of gender pay gap and equality
issues.
15 Teacher absence levels increased in 2022/23
to 7.9 days per teacher and are now higher
than pre-pandemic levels and the highest
recorded since benchmarking began. 
Pressures exacerbated by the pandemic,
treatment delays and increasing mental health
issues are compounded by a skills shortages
and recruitment challenges, all contributory
factors to increased absence.  
Policy and practise review as well as supporting and
developing wellbeing initiatives continue in response to
these significant challenges. 
• Pro-actively support the health and well-being of
employees through increased awareness of mental
health.
• Review proactive measure to reduce sickness
including Day One notification for focus on short term
absence.
• Review and streamline implementation of absence
management procedures to ensure effective
management of absence while reducing the resourcing
impact on managers.
Employees are supported to attend work and managers
are supported to proactively manage sickness absence. 
Managers are enabled to support employees to attend
work and manage any absence efficiently and
timeously.
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Notes to Benchmarking Results (indicators
ranked in the lowest quartile)  
No Challenges Actions to improve Outcome
(Source: HR & OD Service Plan 2024-25)
16 Discretionary Housing Payments are
administered by Councils to households who
require financial assistance towards their
housing costs and are an important tool to
prevent homelessness and help struggling
households to sustain tenancies.  The national
budget available to DHP has increased
significantly since 2019/20.  In Moray, 79.8% of
the overall proportion of the budget was spent,
likely due to the timing of the provision of
additional allocation and pandemic related
delays in processing.  
• Establish whether there is a viable case for further
centralisation of means testing. 
(Source: GS&P Service Plan 2024-25)
Maximise use of funding to benefit those that require
financial assistance to meet housing cost. 
Determine whether a staffing efficiency and
maximisation of council resources is achievable
Assets  
17 There has been a slight improvement to 56.3%
in the percentage of internal floor area of
operational buildings in satisfactory condition. 
The Moray Learning Estate is a significant
contributory factor to the operational building
condition indicator and with half of the 54
schools having condition surveys within the
last 5 years, there is a risk that the results
could worsen as condition surveys are
completed.  
All condition surveys anticipated to complete by
September 2024.  
Moray Learning Estate Strategy 2022-2032 sets out the
steps needed to develop a long-terms strategy for the
learning estate. 
• Tackle the affordability and standard of our schools
and the buildings they operate from, deal with
changing demographics and demands.
(Source: ERC Service Plan 2023-24)
Transforming Education: To have high performing
schools that are fit for the future and financially
sustainable. 
Children and young people in Moray are learning in the
best learning environments. 
Learning environments service the wider community
and where appropriate are integrated with the delivery
of other public services.
Culture & Leisure  
18 The cost per library visit has increased
significantly to £6.55 due to a reduction in the
number of visits recorded. The service
reviewed the virtual visit definition for this
indicator and are now counting launches or
interactions with a page / post rather than the
number having seen a page / post.  In
2022/23, the number of physical visits
increased by 62% to 234,213.  Following the
review, virtual visits in 2022/23 were 127,347
in comparison with 485,283 in 2021/22. 
Across Scotland, results range, perhaps
suggesting there are similar variations in
calculation methods.  At the time of submitting
attendance results, Libindx results were not
available, these would improve the cost per
• Transform our Libraries, Learning Centres & Heritage
service provision to ensure a sustainable council for
the future 
Alternative delivery options: Create a sustainable future
for our services
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Notes to Benchmarking Results (indicators
ranked in the lowest quartile)  
No Challenges Actions to improve Outcome
visit slightly from £6.55 per library visit to
£5.88, ranking remains unchanged.  (Source: ERC Service Plan 2023-24)
Housing Services  
19 In 2022/23 982 of 6,342 (15.5%) properties
within scope met the Scottish Housing Quality
Standards (SQHS).  
The Scottish Housing Regulator invited landlords to
reassess compliance with electrical inspections, in
Moray most properties fell slightly short of the required
standard, frustrated by factors such as the availability of
qualified contractors; an improvement action plan is in
place to ensure compliance by November 2024.  In
addition, compliance with Energy Efficiency Standard
for Social Housing (EESSH) is a contributory factor in
achieving SQHS, significant programmes of work have
not progressed as planned.  The Scottish Government
plan to review for EESSH2 to strengthen and realign
the standard with the target for net zero heat in Housing
to 2040.
Phased improvement of energy efficiency within
corporate buildings and housing stock
Economic Development  
20 There were 107 Business Gateway Start-Ups
in the year to March 2023, below the local
target of 130, noting that there was just one
Business Adviser in the latter half of the year. 
There remains uncertainty which has
increased the risk of starting a business, labour
shortages and disrupted supply chains have
increase barriers for business start-ups.  It is
unlikely that performance will improve in the
short term.  
Moray Economic Strategy, Moray Growth Deal and
other programmes are intended to stimulate this area,
but any improvement will only become evident in the
longer term.
Achievement of Moray Growth Deal Outcomes relating
to job creation and skills uplift.
21 87.2% of properties in Moray receive superfast
broadband.  Moray retains a higher proportion
of properties without access to sufficient
broadband speeds than across Scotland as a
whole.  
The Scottish Government’s R100 programme is
targeted to addressing this issue.  However, despite the
R100 North Lot contract being awarded to BT in
December 2020, there have been no properties served
locally through the rollout of the main contract, with
many not scheduled to be served until 2028.  Even
then, several properties will remain without access to
superfast broadband as the cost of delivery is deemed
too significant but will be eligible to access support via
the Scottish Broadband Voucher Scheme.  In Moray, a
new project has been funded via the UK Shared
Prosperity Fund aimed at increasing awareness and
uptake of this scheme.
Full connection to superfast broadband
Financial Sustainability  
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Notes to Benchmarking Results (indicators
ranked in the lowest quartile)  
No Challenges Actions to improve Outcome
22 The measure of Uncommitted General fund
Balance as a percentage of council annual
budgeted net revenue provides an indication
on the level of uncommitted reserves, a low
level may be a sign that the council could
struggle if any unknown financial surprise were
to occur.  Moray achieved a result of 2.1%.
The Council’s reserves policy was approved by Council
on 15 September 2021 (para 29 of the Minute refers) is
to hold £5 million as free reserves, around 2% of
budgeted revenue expenditure on General Services,
therefore the reported level remains within that
threshold.
Ensure a financially sustainable future
23 Financing Costs to Net Revenue Stream is an
indicator of affordability, it highlights the
revenue implications of existing and proposed
capital expenditure by identifying the
proportion of the revenue budget required to
meet financing costs, net of investment
income.  Moray reported a ratio of 8.7.
Prudential Indicators were reported to Council on 1
March (para 6 of the Minute refers) and reflected the
ongoing general requirement to increase borrowing to
fund capital expenditure in the capital plan, particularly
in the Learning Estate and the Moray Growth Deal. 
This is factored into the Council’s financial planning and
is used as a tool for assessing affordability of the capital
plan,
Ensure a financially sustainable future
24 The need for budgets and forecasts to reflect
actual spending becomes increasingly
important with decreasing or lower levels of
usable reserves to draw on and is measured in
the Actual outturn as a percentage of budgeted
expenditure.  Moray achieved an Actual
outturn of 93.4%.
Patterns of budgeting spend are impacted across all
local authorities, albeit in different ways, although an
increase in the level of reserves held was a common
feature.  Budget manager training, key to an accurate
forecast was reviewed and updated.
Ensure a financially sustainable future 
Caution on making direct comparison over time in the charts below due to the significant impact of Covid-19 on more recent results.  With
around 7% of indicators yet to be published (9 indicators not due for publication in 2022/23), it can be inferred that performance has
dropped with a greater percentage of indicators in the bottom two quartiles than the top two in the context of national and family
groupings.  A drop in indicator results appears to have had an impact on rankings both nationally and within the family group.  Based on
the data published, results have slightly worsened to a greater margin than those that have improved.
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Relative performance: Percentage of indicator rankings by quartiles – 
1Excludes 9 indicators not due for publication in 2022/23
Moray appears in the following Benchmarking Family Groups – 
26% 30% 28% 28%
18% 21%
19% 17% 19% 24%
34% 22%
29% 28% 24%
27% 24%
25%
26% 25% 29% 20% 24%
24%
7%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2017/18 2018/19 2019/20 2020/21 2021/22 2022/23
LGBF relative performance -national
1st quartile 2nd quartile 3rd quartile 4th quartile N/A
People Services (A) Other Services (B)
Includes education, social work and housing.
The benchmarking clubs are based on the
average social context of the local authority
population (using data from SIMD 2012).
Includes environmental services and
culture/leisure services. The benchmarking
clubs are based on the dispersion of the local
authority population (using data for the Grant-
Aided Expenditure indicator for population
dispersion).
Angus
Argyll & Bute
East Lothian
Highland
Midlothian
Moray 
Scottish Borders
Stirling
East Ayrshire
East Lothian
Fife 
Moray
North Ayrshire
Perth & Kinross
Stirling
South Ayrshire 
Results improved
41 indicators
Results worsened
49 indicators
No change 2
indicator 
2021/22 vs 2022/23
Not yet published1 
7 indicators N/A
25% 30% 30% 34%
22% 21%
21% 19%
10%
18%
32%
20%
19% 17%
22%
18% 18%
27%
35% 34% 39% 30% 28%
24%
7%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2017/18 2018/19 2019/20 2020/21 2021/22 2022/23
LGBF relative performance -family
1st quartile 2nd quartile 3rd quartile 4th quartile N/A
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Table Legend
Relative Change Short Term Trend Rank 2021/22
2020/21 to 2021/22 Result to Previous
Year
Local Authorities
(32)
Family Group
(8)
Result improving by 5%
or more  improved 1st quartile 1st quartile
Result worsened by 5%
or more  worsened 2nd quartile 2nd quartile  
no change
3rd quartile  3rd quartile  
4th quartile  4th quartile
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N/A1  Data no longer collected nationally / locally.
N/A2 Result below 5; not published to protect confidentiality.
N/A3 Data not yet published.
11
Results improved / worsened (past 12 months)
Results that improved by 5% or >
• The gross cost of both residential and community placements reduced
significantly, residential costs by 32% and community placements by 8%.
• No children were re-registered on the Child Protection Register within 18 months.
• 10% reduction in the cost of collecting Council Tax per dwelling, with the overall
cost reducing and a slight increase in the number of dwellings.
• £590k of Scottish Welfare Fund was spent, 124% of budget.
• Homecare costs per hour for people aged 65 or over decreased due to a 10%
increase in care hours against a slight increase in total homecare expenditure.
• Increased attendance has resulted in a reduced cost per attendance at sports
facilities.
• Net expenditure for waste disposal decreased resulting in a reduced cost of
disposal per premise.
• A 14% reduction in gross expenditure in Environmental Health, has resulted in a
decrease in cost per 1,000 population across indicators.
• Proportion of recycled household waste increase by 6%, highest rate nationally
• Average working days to complete non-emergency repairs fell by 41% and the
number completed dropped by 18%, resulting in an overall reduction in the
average time taken.
• Gross expenditure on Economic Development & Tourism increased from £4.5m
to £7.8m, increasing investment per 1,000 population to £80,510, albeit
performance remains below the national average and in the bottom quartile.
• Proportion of people earning less than the living wage improved to 13.8%. 
Results that worsened by 5% or >
• The percentage of children from the most deprived 20% gaining 5+ awards at
level 6 fell by 7%.
• The proportion of Looked After Children in community-based placements, rather
than residential accommodation decreased by 5.3%, with an increase of 10
children placed in residential placements since 2021/22.
• Tariff scores have dropped across all six measures, and by over 5% in four.  All
but one feature is the lowest quartile.
• The percentage point gap between the least and most deprived pupils in literacy
and numeracy (P1, P4 and P7 combined) has widened further, with results
ranked in the lowest quartile.
• School exclusion rates have increased by 6 per 1,000 showing a 42.4% increase
from the previous period recorded 2020/21. A similar trend is witnessed nationally
and within our family group with increases of 39.5% and 55.1% respectively.
• Sickness absence increased for both teaching and non-teaching staff back to pre-
covid levels.
• The proportion of Community Care Grant decisions made within 15 days reduced
by 5.7% to 89.3%. It should be noted that recently released figures for 2023/24
show the proportion has increased to 98.5%.
• Residential cost per week per resident for people aged 65 or over have increased
by around one third, principally due to increase in gross expenditure.
• 74% of care services inspected were graded good or better by the Care
Inspectorate, a slight decrease from previous years’ results. 
• Number of days that over 75-year-olds spend in hospital when ready to be
discharged, expressed per 10,000 population increased significantly.
• Cost per library visit doubled due to around a 50% reduction in visits against a
slight increase in net expenditure.  A review of the indicator definition has refined
the count of virtual visits.  
• Net cost of Waste collection per premise increased slightly, this indicator remains
within the top quartile.
• Costs of roads per kilometre increased slightly due to rise in gross expenditure,
the indicator result remains in the top quartile.
• Cost of Trading Standards, Money Advice & Citizens Advice per 1,000 population
increased slightly due to rise in gross expenditure.
• A 20% drop in the number of Planning Applications decided against a slight
decrease in gross expenditure has resulted in an overall increase in cost per
application.
• The number of business start-ups decreased by 10% to 11.1 per 10,000
population
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N/A1  Data no longer collected nationally / locally.
N/A2 Result below 5; not published to protect confidentiality.
N/A3 Data not yet published.
12
Overview of Local Government Benchmarking Framework Indicator Results 
Note Indicator Description
Moray National
Average
Relative Change
2021/22 to
2022/23
Rank
2022/23
2018/19 2019/20 2020/21 2021/22 2022/23 2022/23 %
change 
Short
Term
Trend
Nat
(32)
FG
(8)
Children’
s Services (A) 
CHN 1: Cost per primary school pupil (£) 5,437 5,677 5,776 6,272 6,562 6,841 4.6  8 2 
CHN 2: Cost per secondary school pupil (£) 7,965 8,062 7,864 8,161 8,364 8,495 2.5  15 3 
CHN 3: Cost per pre-school education place (£) 3,687 5,749 8,091 10,108 10,324 11,002 2.1  11 4 
CHN% of secondary pupils achieving 5 or more
awards at Level 5 62 62 66 63 63 62 -1  23 6
1 % of secondary pupils achieving 5 or more awards at
Level 6 30 34 34 30 28 38 -2  31 8 
% of pupils living in the 20% most deprived areas
Gaining 5+ awards at Level 5 N/A2 N/A2 62 52 N/A2 50    
2 % of pupils living in the 20% most deprived areas
Gaining 5+ awards at Level 6 N/A2 N/A2 19 19 12 22 -7  26 7 
Gross Cost of “Children Looked After” in Residential
Based Services per child per week (£) 4,814 5,394 5083 4,403 2,989 4,804 -32  9 4 
Gross Cost of “Children Looked After” in a
Community Setting per child per week (£) 457 472 435 474 435 422 -8  18 6
3 % of children being looked after in the community 79.1 81.4 82.2 80.6 75.3 89.2 -5.3  31 8 
% of adults satisfied with local schools (rolling 4
years) 74.6 77.0 79.3         79.3  76.7 73.7 -2.7  15 4 
% of pupils entering positive destinations 92.8 93.1 94.1 96.2     95.1 95.9     -1.1  22 5
4 Overall average total tariff  814 799 876 882 830 915 -5.9  27 7 
Overall average total tariff SIMD Quintile 1 826 939 887 735 561 658 -23.7  21 4
5 Overall average total tariff SIMD Quintile 2 573 687 635 637 580 781 -8.9  31 8
6 Overall average total tariff SIMD Quintile 3 830 729 868 868 814 905 -6.2  28 7
7 Overall average total tariff SIMD Quintile 4 838 836 954 944 917 1051 -2.9  30 7
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N/A1  Data no longer collected nationally / locally.
N/A2 Result below 5; not published to protect confidentiality.
N/A3 Data not yet published.
13 
Note Indicator Description
Moray National
Average
Relative Change
2021/22 to
2022/23
Rank
2022/23
2018/19 2019/20 2020/21 2021/22 2022/23 2022/23 %
change 
Short
Term
Trend
Nat
(32)
FG
(8)
8 Overall average total tariff SIMD Quintile 5 934 903 959 1,005 974 1,264 -3.1  29 8
9 % P1, P4 & P7 pupils combined achieving expected
CFE Level in Literacy 64.8 N/A1 63.9 65.1 67.9 72.7 2.8  28 5
10 % P1, P4 & P7 pupils combined achieving expected
CFE Level in Numeracy 69.9 N/A1 67.8 71.8 75.5 79.6 3.7  27 6
11
Literacy Attainment Gap (P1,4,7 combined) –
percentage point gap between the least and most
deprived pupils
14.9 N/A1 19.8 26.3 32.1 20.3 21.7  29 8
12
Numeracy Attainment Gap (P1,4,7 combined) –
percentage point gap between the least and most
deprived pupils
13.8 N/A1 17.5 24.7 26.6 17.0 7.8  28 7 
% of children meeting developmental milestones 93.2 95.6 96.0 84.9 87.3 82.1     2.4  5 2
13 % of funded early years provision which is graded
good/better  75.4 78.3 85.2 86.9 87.5 90.1 0.6  25 7 
School attendance (%) 93.9 N/A1 93.8 N/A1 91.0 90.2 -2.8  8 2 
School attendance rates (LAC, %) 87.4 N/A1 89.4 N/A1 N/A1 N/A1     
School exclusion rates per 1,000 pupils 22.7 N/A1 14.2 N/A1 20.2 16.6 6  21 5 
School exclusion rates per 1,000 looked after children 180.4 N/A1 125.0 N/A1 N/A1 N/A1     
% participation for 16-19 year-olds 91.3 93.5 91.8 91.6 95.4 94.3 3.9  11 5 
% of child protection re-registrations within 18 months 3.2 7.5 2.3 9.8 0      5.6      -9.8  1 1 
% LAC with more than 1 placement in the last year
(Aug-July) 31.0 25.0 14.9 14.5 11.8     17.2     -2.8  6 3 
% of children living in poverty (after housing costs) 21.9 23.4 21.3 24.1 N/A3        N/A3           
Corpor
ate
Servic Support Services as a % of Total Gross Expenditure 4.3 4.2 4.1 3.9 3.8 4.0 -0.1  18 5 
% of the highest paid 5% employees who are women 54.1 54.7 61.1 62.7 59.5 58.9 -3.3  15 5
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N/A1  Data no longer collected nationally / locally.
N/A2 Result below 5; not published to protect confidentiality.
N/A3 Data not yet published.
14 
Note Indicator Description
Moray National
Average
Relative Change
2021/22 to
2022/23
Rank
2022/23
2018/19 2019/20 2020/21 2021/22 2022/23 2022/23 %
change 
Short
Term
Trend
Nat
(32)
FG
(8)
14 The gender pay gap (%) 7.6 6.4 6.2 7.0 5.3 2.5 -1.6  28 7 
Cost of collecting Council Tax per dwelling 10.26 9.50 8.67 8.36 7.54 6.84 -9.8  18 7
15 Sickness Absence days per Teacher 6.5 6.8 4.5 6.0 7.9 6.8 31.6  27 4 
Sickness Absence days per Employee (non-teacher) 12.5 12.7 8.7 11.1 12.8 13.2 15.8  12 3 
% of income due from Council Tax received by the
end of the year 96.9 97.0 95.8 96.7 96.7 96.2 -0.0  15 4 
% of invoices sampled that were paid within 30 days 89.7 87.3 84.0 85.5 89.4 90.6 3.9  23 6 
% of Crisis Grant Decisions within 1 day
Note: 2023/24 result 97.0%  92.8 94.3 98.5 98.3 97.8 91.8 -0.5  15 5 
% of CCG Grant Decisions within 15 days
Note: 2023/24 result 98.5%  95.3 85.3 91.0 95.0 89.3 87.3 -5.7  19 5 
Proportion of SWF Budget Spent 82.7 84.3 64.3 99.0 123.9 130.0 24.9  19 5
16 Proportion of DHP Funding Spent 90.8 91.3 90.6 75.6 79.8 94.4 4.2  27 8
Assets
(B) 
% of operational buildings that are suitable for their
current use 98.2 98.2 98.2 97.6 95.7 86.1 -0.1  1 1
17 % of internal floor area of operational buildings in
satisfactory condition 54.2 53.9 66.9 54.9 56.3 90.12 1.3  32 8
Adult Social W
ork (A)  Home Care costs per hour for people aged 65 or over
(£) 39.95 38.45 30.31 25.80 23.94 31.85 -7.2  7 3 
Self-Directed Support spend on people aged 18 or
over as a % of total Social Work spend on adults 4.1 4.1 5.0 3.6 4.6 8.7 1.0  22 6 
% of people aged 65 or over with long term care
needs receiving personal care at home 65.3 62.2 62.0 61.0 59.8 61.5 -1.2  21 5 
% of adults supported at home who agree that their
services and support had an impact in improving or
maintaining their quality of life (rolling 4 years) 
79.20  73.25       
% of adults supported at home who agree that they
are supported to live as independently as possible  82.72  79.34      
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N/A1  Data no longer collected nationally / locally.
N/A2 Result below 5; not published to protect confidentiality.
N/A3 Data not yet published.
15 
Note Indicator Description
Moray National
Average
Relative Change
2021/22 to
2022/23
Rank
2022/23
2018/19 2019/20 2020/21 2021/22 2022/23 2022/23 %
change 
Short
Term
Trend
Nat
(32)
FG
(8) 
% of adults supported at home who agree that they
had a say in how their help, care or support was
provided 
79.68  70.22       
% of carers who feel supported in their caring role  30.70  31.59       
Residential costs per week per resident for people
aged 65 or over (£) 453 433 543 473 638 684 34.9  13 3 
Rate of readmission to hospital within 28 days per
1,000 discharges (%) 77.1 77.7 100.9 85.9 82.2 101.7 -4.3  7 1 
Proportion of care services graded ‘good’ (4) or better
in Care Inspectorate inspections (%) 81.8 75.2 79.8 80.0 74.0 75.0 -6.0  23 6 
Number of days people spend in hospital when they
are ready to be discharged, per 1,000 population
(75+)
Note: 2023/24 result 386 
1063 768 493 755 1061 919 40.0  23 6
Culture &
Leisure (B) 
Gross cost per attendance at Sports facilities (£) 2.26 0.97 20.40 2.83 2.44 4.89 -13.0  5 2
18 Cost per Library visit (£) 1.48 1.70 3.21 2.93 6.55 2.81 123.5  29 6 
Cost of Museums per visit (£) 2.81 2.41 N/A1 N/A1 N/A1     
Cost of Parks & Open Spaces (£) per 1,000
population 15,234 11,680 12,955 15,918 15,548 23,311 -2.3  6 2 
% of adults satisfied with Libraries (rolling 4 years) 74.9 77.6 82.9 82.3 79.3 71.0 -3.0  7 6 
% of adults satisfied with Parks and Open Spaces
(rolling 4 years) 85.1 82.4 85.1 85.7 86.3 87.3 0.6  20 6 
% of adults satisfied with Museums and Galleries
(rolling 4 years) 58.1 60.1 64.1 62.3 58.3 71.3 -4.0  24 7 
% of adults satisfied with Leisure Facilities (rolling 4
years) 66.4 66.7 72.4 74.7 71.3 71.0 -3.4  17 6
Enviro
nment
al  Net cost per Waste collection per premises (£) 58.73 42.20 37.93 36.10 38.92 79.20 7.8  6 1 
Net cost per Waste disposal per premises (£) 120.82 107.39 111.23 108.79 98.86 99.76 -9.1  14 5
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N/A1  Data no longer collected nationally / locally.
N/A2 Result below 5; not published to protect confidentiality.
N/A3 Data not yet published.
16 
Note Indicator Description
Moray National
Average
Relative Change
2021/22 to
2022/23
Rank
2022/23
2018/19 2019/20 2020/21 2021/22 2022/23 2022/23 %
change 
Short
Term
Trend
Nat
(32)
FG
(8) 
Net Cost of Street Cleaning (£) per 1,000 population 9,650 7,931 7,908 8,501 8,785 16,068 3.3  5 1 
Street Cleanliness Score N/A1 N/A1 N/A1 N/A1 N/A1     
Cost of Maintenance per Kilometre of Roads (£) 6,835 7,524 4,690 5,508 6,443 12,844 17.0  3 1 
% of A Class roads that should be considered for
maintenance treatment (rolling 2 years) 28.6 29.2 26.6 23.2 24.1 27.4 1.0  14 2 
% of B Class roads that should be considered for
maintenance treatment (rolling 2 years) 25.6 25.8 22.3 18.3 18.4 31.5 0.1  3 1 
% of C Class roads that should be considered for
maintenance treatment (rolling 2 years) 28.1 25.2 21.3 19.3 20.6 32.7 1.3  5 1 
% of unclassified roads that should be considered for
maintenance treatment (rolling 2 years) 31.1 35.5 35.0 32.0 30.3 36.4 -1.7  9 2 
Cost of trading standards and environmental health
(£) per 1,000 population 22,074 21,521 20,430 25,138 22,944 22,302 -8.7  19 7 
Cost trading standards, money advice & citizens
advice (£) per 1,000 population 5,528 5,579 5,104 5,169 5,790 7,060 12.0  12 3 
Cost of environmental health (£) per 1,000 population 16,550 15,943 15,325 19,964 17,156 15,239 -14.1  22 7 
% of total household waste arising that is recycled 57.0 59.0 54.9 52.2 58.0 43.3 5.8  1 1 
% of adults satisfied with refuse collection  (rolling 4
years) 82.8 73.5 69.8 71.7 76.0 78.0 4.3  23 6 
% of adults satisfied with street cleaning (rolling 4
years) 65.3 58.6 58.3 58.7 62.7 58.3 4.0  13 5
Housing
Services (A)  Gross rent arrears (all tenants) as at year end as a %
of rent due for the reporting year 2.4 2.6 3.2 3.8 4.5 9.6 0.7  2 1 
% of rent due in the year that was lost due to voids 0.8 0.9 1.2 1.2 1.0 1.7 -0.2  7 3
19 % of council dwellings meeting Scottish Housing
Quality Standard 92.5 90.7 93.8 6.3 15.5 70.9 9.1  26 6 
Average number of days to complete non-emergency
repairs 7.5 9.5 6.1 8.0 5.7 9.7 -28.3  2 1
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N/A1  Data no longer collected nationally / locally.
N/A2 Result below 5; not published to protect confidentiality.
N/A3 Data not yet published.
17 
Note Indicator Description
Moray National
Average
Relative Change
2021/22 to
2022/23
Rank
2022/23
2018/19 2019/20 2020/21 2021/22 2022/23 2022/23 %
change 
Short
Term
Trend
Nat
(32)
FG
(8) 
% of council dwellings that are energy efficient 57.4 54.6 57.4 60.4 N/A3 N/A3    
Economic Development (B) 
% Unemployed People Assisted into work from
Council operated / funded Employability Programmes 3.4 0.6 5.3 5.9 10.1 12.9 4.3  24 8 
Cost per Planning Application 5, 285 4,512 4,887 5,426 6,348 5, 538 18.0  22 5 
Average time (Weeks) per Planning Application 6.7 6.4 6.7 6.2 6.3 12.0 0.3  2 2 
% of procurement spent on local small / medium
enterprises 23.9 21.9 23.6 25.2 24.8 29.6 -0.4  19 3
20
No of business gateway start-ups per 10,000
population
Note: 2023/24 result 3.1 
12.6 16.2 9.4 12.4 11.1 14.3 -10.1  29 8 
Investment in Economic Development & Tourism per
1,000 population (£) 25,757 35, 414 37,225 46,407 80,510 109,349 73.5  24 6 
Proportion of people earning less than the living wage
(%) 27.40 24.00 21.50 19.40 13.8 9.4 -5.6  15 2
21 Proportion of properties receiving superfast
broadband (%) 83.2 84.7 85.7 85.6 87.2 95.5 1.6  26 8 
Town Vacancy Rates (%) 6.9 6.9 10.9 10.6 11.0 12.0 0.4  14 3 
Immediately available employment land as a % of
total land allocated for employment purposes in the
local development plan 
49.0 24.2 34.8 14.9 14.9 22.8 -0.1  20 3 
Gross Value Added (GVA) per capita (£) 23,807 23,742 22,380 23,172 24,282 27,039 4.8  11 3 
Claimant count as a % of working age population (%)
Note: 2023/24 result 2.1  2.0 2.5 4.9 3.7 2.4 3.2 -1.3  10 3 
Claimant count as a % of 16-24 population (%)
Note: 2023/24 result 2.1  3.1 3.5 6.7 4.5 2.8 3.5 -1.7  11 3
Finan
cial
Sustai Total useable reserves as a % of council annual
budgeted net revenue 10.5 15.0 25.1 26.3 24.8 24.5 -1.5  16 3
22 Uncommitted General fund Balance as a % of council
annual budgeted net revenue 6.2 7.5 7.2 2.2 2.1 3.2 -0.2  25 8
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N/A1  Data no longer collected nationally / locally.
N/A2 Result below 5; not published to protect confidentiality.
N/A3 Data not yet published.
18 
Note Indicator Description
Moray National
Average
Relative Change
2021/22 to
2022/23
Rank
2022/23
2018/19 2019/20 2020/21 2021/22 2022/23 2022/23 %
change 
Short
Term
Trend
Nat
(32)
FG
(8)
23 Ratio of Financing Costs to Net Revenue Stream 10.0 9.5 8.0 8.3 8.7 5.4 0.5  29 7 
Ratio of Financing Costs to Net Revenue Stream –
Housing Revenue Account 20.3 21.5 21.6 20.7 22.0 21.4 1.2  14 5
24 Actual outturn as a % of budgeted expenditure 100.1 96.0 89.6 91.1 93.4 98.6 2.3  31 7
Climate
Change (B) 
CO2 emissions area wide per capita 5.11 5.01 4.11 5.11 N/A3 N/A3     
CO2 emissions area wide: emissions within scope of
LA per capita 7.77 7.34 6.39 7.39 N/A3 N/A3     
CO2 emissions from Transport per capita 37.2 36.55 29.03 35.31 N/A3 N/A3     
CO2 emissions from Electricity per capita 51.34 41.08 30.06 32.85 N/A3 N/A3     
CO2 emissions from Natural Gas per capita  49.00 45.21 45.09 48.99 N/A3 N/A3     
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1 
APPENDIX 2 
Local Government Benchmarking Framework
(LGBF) 
Benchmarking Overview - Summary
2021-22 
Item 9.
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2 
Summary
The Local Government Benchmarking Framework (LGBF) data provides evidence of trends
in how resources are allocated, performance of services and levels of customer satisfaction. 
This year’s results introduces data from 2021/22 and provides an evidence-based picture of
the impact of the pandemic as well as the extraordinary effort and achievement during and
following this exceptional period.   
Exceptions based on 32 local authorities; areas of service delivery ranked in the lowest
quartile are presented below as Notes to Benchmarking Results.  Care should be taken
when making comparison over time and with others due to the complexities around altered
delivery and operating landscapes during the reporting period. 
The National Benchmarking Overview Report 2021/22 is available here. 
Notes to Benchmarking Results (indicators ranked in the lowest quartile)
No Comment
Children’s Services
1-10 The percentage of P1, P4 & P7 combined achieving expected CFE Levels for Literacy and
Numeracy improved, encouraging given the disruption during Covid and the resulting lockdowns that
had a significant impact on learning for children.  The percentage point gap in between the least and
most deprived pupils in the P1, P4 and P7 combined in numeracy increased against a generally a
decreasing national trend. 
The percentage of secondary pupils gaining 5 or more awards at Level 5 improved and at Level 6
worsened slightly.  Five of six average total tariff score measures remain in the lowest quartile.   
Analysis of achievement of Curriculum for Excellence Levels 2022 was presented to the Education,
Children’s and Leisure Services Committee on 25 January 2023 (item 8 of the Agenda refers). 
Further analysis at individual school level and support and challenge discussions followed.  Quality
Improvement visits in primary during Terms 1 and 2 focused on Learning, Teaching and Assessment
centred on common areas for development including increased moderation within schools and
associated school groups, building practitioner confidence in teacher professional judgements
against national benchmarks and cross school and sector moderation activities focused on literacy
and numeracy leading to redeveloped action plans.  In secondary education, virtual and extended in-
person improvement model visits supported by revised processes were undertaken during term 2
and support and challenge visits in term 3 in line with the Secondary Attainment and Performance
Framework.   
Curriculum structures of authorities’ impact on tariff points available to students through the number
of qualifications they can take, where more demanding qualifications gain more points than less
demanding ones and in graded courses, a grade ‘A’ is equivalent to more points than a grade ‘C’
within the same course.  Therefore in addition, locally complementary tariff scores is measured to
apply parity of achievement of young people in their top five qualifications studied.
Corporate Services
11 The Gender Pay Gap at 6.95% is almost double the national average of 3.54%.  The gap in pay is
the percentage difference between male employees’ average hourly rate of and female employees
average hourly rate of pay, where a positive figure indicates male employees are, on average, paid
more per hour than female employees.  Across Scotland, results range from -6.2 to 11.4, reinforcing
the likely variations in methods of calculation.
12 Of the 202k invoices sampled, 85% were paid within 30 days.  With all payments made immediately
on receipt of authorised invoices from services, a measure taken during the pandemic to support the
local economy, the pace of authorisation by budget managers impacts on this result.  Heads of
Service are periodically informed of the performance of their service in processing in order to
improve.
13 Discretionary Housing Payments (DHPs) may be awarded when the Council considers that a
housing benefit or Universal Credit claimant requires further financial assistance towards housing
costs.  In 2021-22, of the estimated £790k funding available, 76% was spent.  Scottish Government
has increased funding by around 40% since pre-covid levels.  Increased workload and priority being
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3 
given to processing Self Isolation Support Grant impacted on the time available for DHPs, albeit in
the reporting period there was less need for DHPs for new tenants or tenants looking to move to new
tenancies. Scottish Government have since investigated and will reduce funding provided for future.
Assets
14 The Moray Learning Estate is a significant contributory factor to the operational building condition
indicator result.  A programme of Local condition surveys has progressed, to provide a more
accurate picture of schools’ condition with historical surveys between 5-8 years old.  Improvements
are ongoing through the upgrade programme.
Adult Social Work
15 Nationally there is significant variation in both the scale of growth and the pattern of uptake of direct
payments (DP) or Personalised Managed Budgets (PMB).  In Moray, of the £63m gross social work
spend on over 18s, £2.3m was through Self-Directed Support.  Self-Directed Support (SDS)
Scotland published a report in September 2021, My Support My Choice; People’s Experiences of
Self-directed Support and Social Care in Moray which considered the views of 54 people in Moray
who received SDS reporting positive views across several aspects.  The research identified
recommendations in response to concerns, which will inform and influence Health and Social Care
Moray’s ongoing efforts in responding to areas of challenge.  Moray was one of three local authority
areas chosen to work intensively with the SDS Project Team at Social Work Scotland to test out and
develop the approved Framework Standards that will support future practice across Scotland. 
Locally, work has also progressed in creating an Option 2 Flexible Framework to support greater
choice for individuals.
16 The percentage of adults supported at home who agree that their services and support had an
impact in improving or maintaining their quality of life is one of the national core indicators reflecting
the aggregate impact of local person-centred work to improve personal outcomes.  Moray’s result
(73.3%), below the national average (78.1%) was reported for the first time to the Integration Joint
Board Audit, Performance and Risk Committee in June 2022.
Environmental Services
17 Adults satisfied with refuse collection improved to 71.7%.  The data source is the Scottish Household
Survey and results are presented as a rolling average.  Typically, responses total around 10,000,
however responses were significantly affected during the pandemic when fieldwork was suspended
and the survey was carried out using remote interviewing, therefore results are not comparable to
previous years.
Housing Services
18 The requirement for housing stock to meet Energy Efficiency Standard for Social Housing (EESSH)
compliance was introduced in January 2021 and amended fire safety regulation from February 2022,
both contributory factors to achieving target.  Completion of fire safety upgrades and focus on
heating installations will improve performance results in the percentage of council housing stock
meeting the Scottish Housing Quality Standard (SHQS).
19 Conclusion of a major contract for Warm Homes Round 4 grand funding was delayed throughout the
pandemic periods resulting in heating installation work being suspended for several months. 
Surveys continue and completion of heating systems programme is dependent on Air Source Heat
Pumps and boilers availability, also affected by industry shortages therefore it is unlikely to see any
significant improvement in the percentage of council dwelling that are energy efficient in the short
term.
Economic Development
20 In the period to March 2022, 88 people were assisted into work from council employability
programmes.  A suite of employability services is being delivered through the Local Employability
Partnership Plan using Scottish Government and UK Shared Prosperity Funding.  Annual progress
around Employability and Skills was reported within the Information Report: Economic Recovery
Plan to Economic Development and Infrastructure Services Committee on 22 March 2022 (para 11
refers)
21 In January 2021 Moray Speyside were awarded £350k over the next 3 years in support of its Moray
Investment in Economic Development & Tourism Recovery Plan.  In addition, a successful
application was submitted to the Rural Tourism Infrastructure Fund (RTIF) for the Coast to Country
project, an integral part of Moray wide strategic staycation programme, in September 2021, that was
match funded by the Council and Highlands and Islands Enterprise.  It is anticipated that these
opportunities will contribute to improved performance going forward.
Financial Sustainability
22 The Ratio of Financing Costs to Net Revenue Stream – General Fund is an indicator of affordability
and highlights the revenue implications of existing and proposed capital expenditure by identifying
the proportion of the revenue budget required to meet financing costs, net of investment income. 
This is factored into the Council’s financial planning and will be used as a tool for assessing
affordability in reviews of the capital plan.
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4 
23 Actual Outturn is calculated as the total actual revenue expenditure as a percentage of the total
budgeted revenue expenditure.  Patterns of budgeted spend are impacted across all local
authorities, albeit in different ways, with for an example an increase in the level of reserves held a
common feature.  Budget manager training is key to an accurate forecasting.
Climate Change
24 Emissions within scope of Local Authority per capita increased and remain above the national
average.  The annual report on Energy Strategy/Actions was submitted to the Economic
Development and Infrastructure Committee on 15 November 2022.  Publication of the Scottish
Government’s The Heat in Buildings Strategy set the requirement for all local authorities to produce
a Local Heat and Energy Efficiency Strategy (LHEES) by December 2023.  In March 2021 the
Council adopted the Climate Change Strategy which set the goal of the Council being carbon neutral
by 2030 and approved the Route Map to Net Zero creating a framework for actions aimed at
reducing carbon emissions. 
Caution on making direct comparison over time in the charts below due to the significant
impact of Covid-19 on more recent results.  Results show improving and worsening
positions in equal share, but a general shift of results is evident from 1st to 2nd quartile. 
Relative performance: Percentage of indicator rankings by quartiles – 
2020/21        
vs   
2 2021/22 
Results improved
48 indicators 
Results worsened
49 indicators 
No change
2 indicators
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Results improved / worsened (past 12 months)
Results that improved by 5% or >
• 10% reduction in the gross cost of looked after children in residential-based
services resulted in a fall in the cost per child per week and improvement in
ranked position to the lowest recorded in over a decade
• £703k of Scottish Welfare Fund payments were made, 99% of budget, improving
on previous years percentage spend
• Homecare costs per hour for people aged 65 or over decreased due to a reduction
in total homecare costs and increase in care hours
• 13% reduction in net expenditure on care homes for older people against a small
increase in number of long-stay residents gives a low cost per resident
• Significant reduction in rate of readmissions to hospital within 28 days per 1,000
discharges 
• Increased attendance and income resulted in reduced cost per attendance at
sports facilities
• Proportionately larger increase in number of library visits than net expenditure led
to lower cost per library visit  
• Increased number of premises for refuse collection against reduction in net
expenditure gave a reduced cost of collection per premise, lowest nationally
• Percentage of unemployed people assisted into work from Council operated /
funded Employability Programmes improved albeit as a result of a proportionately
larger decrease in the model-based unemployment count than those assisted into
work
• Slight improvement in average time in processing weeks per planning application
• The rise in the number of Business Gateway Start Ups led to an improved ratio per
10,000 population
• Significant increase in gross expenditure in Economic Development and Tourism
resulted in improved investment per 1,000 population, albeit position remains less
than half national average and in the lowest quartile
• GVA per capita increased slightly albeit the ranking remained unchanged
• Claimant count as a percentage of working age population reduced due to a
significant fall in the claimant count overall and within the 16-24 population 
Results that worsened by 5% or >
• 6% increase in gross expenditure and slight decrease in pupil numbers contributed
to an overall increase in cost per primary school pupil
• 22% increase in pre-school gross expenditure resulting in another significant rise
in cost per pre-school education place
• Reduction in the percentage of pupils living in the 20% most deprived areas
• Attainment gap in literacy and numeracy between least and most deprived has
widened, is above national average and dropped in ranking to the lower quartiles
• Percentage of children meeting developmental milestones decreased and ranked
position dropped to second quartile
• Significant increase in percentage of child protection re-registrations within 18
months
• Sickness absence days per teacher and non-teacher increased because of a 44%
and 34% rise in days lost against a 9% and 5% rise in FTE staff numbers
respectively to levels similar to pre-Covid.  2020/21 results were unusually low,
mirrored nationally
• The proportion of Discretionary Housing Payment funding spent reduced with the
result now ranking second lowest nationally
• Drop in overall internal floor area of operational buildings considered satisfactory in
condition maintaining ranking of lowest nationally 
• Percentages of adults supported at home agreeing that they had a say in how
services were provided or that they improved or maintained their quality of life both
fell slightly
• Significant increase in the number of bed days people (75 and over) spend in
hospital when ready to be discharged, rate per 1,000 population returning to pre-
Covid levels, positioned mirrored nationally
• Increase in the cost of parks and open spaces per 1,000 population due to 23%
increase in net expenditure against a slight increase in estimated population
• 7% increase in cost of street cleaning per 1,000 population due to slight increases
in net expenditure
• 17% increase in the cost of road maintenance per kilometre resulting in an
increased cost of maintenance per kilometre
• Cost of trading standards and environmental health per 1,000 population increased
as a result of 24% rise in gross expenditure largely attributed to environmental
health
• Properties within scope of housing quality standard increased whilst those meeting
standard considerably reduced resulting in drop in performance, a similar position
reflected in national results
• Non-emergency house repairs rose considerably in a return to pre-Covid levels
whilst working days to complete more than doubled last year, both contributing to
an increase in average days to complete repairs
• Slight increase in planning applications against proportionately higher gross
expenditure led to an increase in cost per planning application and a drop in
ranked position nationally 
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gaining 5+ awards at Levels 5 and 6
• Gross costs of looked after children in a community setting increased slightly
against a drop in the number of children looked after resulting in a greater cost per
child per week
• Drop in overall average tariff SIMD quintile 1 (most deprived), result above national
average
• Percentage of immediately available employment land dropped by half, albeit
remaining in the 3rd quartile
• Percentage of uncommitted General Fund Balance against budgeted net revenue
fell by five percentage points to below national average and from the top to third
quartile
• CO2 emissions area wide and within scope of Local Authority per capita increased 
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