Democracy Spraffa

Agenda Document Pack - Audit and Scrutiny Committee - 20/11/2024

Moray Council · 20 November 2024
Back to Audit and Scrutiny Committee — 20 November 2024 and its agenda

Text extracted from the council's PDF. Layout and reading order may differ from the original.

Original council PDF · Download plain text

Page 1

Audit and Scrutiny Committee
Wednesday, 20 November 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 Wednesday, 20 November 2024 at 09:30.
BUSINESS
1. Sederunt
2. Declaration of Group Decisions and Members Interests *
3. Minutes of meeting of 11 September 2024 5 - 12
4. Written Questions **
5. Internal Audit Section Update Report
Report by Audit and Risk Manager
13 - 44
6. Internal Audit Review - Fostering and Kinship Care
Payments
Report by Audit and Risk Manager
45 - 56
7. Internal Audit Review - Governance Arrangements to
Prevent Fraud and Corruption
Report by Audit and Risk Manager
57 - 72
8. Internal Audit Review - Moray Growth Deal
Report by Audit and Risk Manager
73 - 88
9. Internal Audit Charter
Report by Audit and Risk Manager
89 -
100
Page 1

Page 2

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.
Watching the Meeting
You can watch the webcast live by going to: 
http://www.moray.gov.uk/moray_standard/page_43661.html
Webcasts are available to view for 1 year following the meeting.
You can also attend the meeting in person, if you wish to do so,
please come to the High Street entrance door and a member of
staff will be let into the building.
Page 2

Page 3

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 published on the Council’s
committee management system by 4pm the day before the meeting.  The
Member who has put the question may, after the answer has been published,
ask one supplementary question directly related to the subject matter at the
meeting, 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.
Page 3

Page 4

MORAY COUNCIL
Audit and Scrutiny Committee
SEDERUNT
Councillor Scott Lawrence  (Chair)
Councillor Theresa Coull  (Depute Chair)
Councillor Peter Bloomfield  (Member)
Councillor Tracy Colyer  (Member)
Councillor John Divers  (Member)
Councillor Jérémie Fernandes  (Member)
Councillor Donald Gatt  (Member)
Councillor David Gordon  (Member)
Councillor Sandy Keith  (Member)
Councillor Elaine Kirby  (Member)
Councillor Marc Macrae  (Member)
Councillor Neil McLennan  (Member)
Councillor Shona Morrison  (Member)
Councillor John Stuart  (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
Page 4

Page 5

MORAY COUNCIL
Minute of Meeting of the Audit and Scrutiny Committee
Wednesday, 11 September 2024
Council Chambers, Council Office, High Street, Elgin, IV30 1BX
PRESENT
Councillor Peter Bloomfield, Councillor Theresa Coull, Councillor John Divers,
Councillor Amber Dunbar, Councillor Jérémie Fernandes, Councillor Donald Gatt,
Councillor David Gordon, Councillor Sandy Keith, Councillor Scott Lawrence,
Councillor Marc Macrae, Councillor Neil McLennan, Councillor John Stuart, Ms
Margaret Wilson
APOLOGIES
Mr Ivan Augustus, Councillor Shona Morrison
IN ATTENDANCE
Interim Chief Executive; Depute Chief Executive (Education, Communities and
Organisational Development); Head of Governance, Strategy and Performance;
Audit and Risk Manager; Head of Financial Services; Service Manager - Strategic
Commissioning; Interim Chief Social Work Officer and Head of Service; Lizette
Van Zyl, Service Manager; Head of ICT, Human Resources and Organisational
Development; ICT Team Leader/Information Security Officer and Caroline
O'Connor, Committee Services Officer, all Moray Council and Angela Pieri, Grant
Thornton - External Auditors.
1.         Chair
Following the resignation of the previous Chair, Councillor Leadbitter and in terms
of Standing Order 6(a), the Interim Chief Executive called on Members of the
Committee to choose a Member to preside.
Councillor Macrae, seconded by Councillor Divers, moved to nominate Councillor
Lawrence.
There being noone otherwise minded, the meeting unanimously agreed to appoint
Councillor Lawrence as Chair to preside at today's 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 6 "Internal Audit Section Update Report", Councillor Gatt
stated, for transparency, that he is Convener of the Grampian Valuation Joint
Board and would be taking part in the debate.
Item 3.
Page 5

Page 6

With regard to Item 8 "Internal Audit Review - Following the Public Pound",
Councillor Macrae and Councillor Gordon stated, for transparency, that they were
members of the Moray Leisure Centre Board and would be taking part in the
debate.
With regard to Item 8 "Internal Audit Review - Following the Public Pound",
Councillor Divers and Council Fernandes stated, for transparency, that they were
advisors to the Citizens Advice Bureau.
3.         Resolution
The meeting resolved that in terms of Section 50A (4) and (5) of the Local
Government (Scotland) Act 1973, as amended, the public and media
representatives be excluded from the meeting for Item 11 of business on the
grounds that it involves the likely disclosure of exemption information of the class.
Para number of
the minute
Para Number of Schedule 7a
13
Para 8
Information on the amount of any expenditure proposed to be
incurred by the Authority
14
Para 14
Information relating to action taken, or to be taken, in
connection with the prevention, investigation or prosecution of
crime
15
Para 14
Information relating to action taken, or to be taken, in
connection with the prevention, investigation or prosecution of
crime
4.         Minutes of meeting of 25 June 2024
The minutes of the meeting of the Audit and Scrutiny Committee dated 25 June
2024 were submitted for approval.
Councillor McLennan suggested an amendment to the wording of the minute for
Item 10 "Local Government Benchmarking Framework 2022-23 and 2021-22" in
relation to the last paragraph on page 11 as his understanding was that Councillor
Macrae had proposed rather asked about the Framework being considered by
Moray Council and that Councillor McLennan had seconded with no dissent or
counter motion.  The Chair confirmed the wording would be amended to reflect
that Councillor McLennan had seconded the proposal.
Subject to the amendment above, the Committee agreed the minute of the
meeting.
5.         Written Questions **
Under referent to Standing Order 36 a written question from Council McLennan
was submitted in the following terms:
Social Work Case
Page 6

Page 7

On 8th August 2024 I submitted a written question asking about "a decision by a
Scottish Court to uphold a complaint against Moray Council social workers making
false sexual claims about a foster parent and the events therein costing the council
a total of £1.3 million including damages of £346,000 reported in the Press and
Journal 28.06.2024. The press reports suggest the false allegations levelled at the
foster parent(s) were potentially motivated by the fact the foster parents had made
a complaint about the Council.
I noted that understanding this case, having assurances and ensuring lessons are
learned which ensure no repeat of this is vital for public trust and Best Value. This
includes eradicating any culture of attacking those who speak up on serious
matters and wrongdoing. What assurances can be given that such wrongdoing will
not occur again that those involved in this case are properly investigated (and if
appropriate, censured) by their governing body and that children are, and have
been safe under the care of Moray Council?"
In response for the 13th August 2024 Full Council meeting I was told "For clarity,
the total sum of compensatory payments made under Human Rights legislation
was £346,000. Legal costs associated with the case were £514,000. The Chief
Social Work Officer (CSWO) has met with existing employees who were involved
at the time and a member of a partner provider service, from which he has drawn
out points of learning. Work is underway for professional learning and development
from the themes identified. The CSWO is co-operating fully with the Scottish Social
Services Council (SSSC) in its investigations into potential misconduct by those
involved in the case. These investigations have not yet concluded and when their
findings are received, appropriate action will be taken as required."
Can we have reassurance that once the investigations are complete a report into
the findings will be put before this council for careful consideration; and in the
interim can it be confirmed which elected members were made aware of these the
complaint against the Council and has any scrutiny taken place by Elected
Members into the key decisions taken by the Council apropos this case; and is the
Chair and Vice Chair of the Audit and Scrutiny Committee satisfied that all those
involved in decision-making apropos this case have been referred or have self-
referred to appropriate investigatory body(ies). If not will the chair and vice chair
work cross party to ensure that no stone is left unturned in order that the public
have full confidence in Moray Councils ability to look after vulnerable children.
RESPONSE
The Chief Social Work Officer has confirmed that further to the response given to
the meeting of Moray Council on 13 August 2024:
• He notes the dual interests of the Council and the MIJB in relation to this issue.
• Internal learning and development work and external investigations are taking
place, the results of which will be reported to the appropriate committees or
bodies. The Council’s internal and external auditors have been alerted to the
ongoing work and external investigations.
• Due to changes in personnel, it is unknown what conversations took place with
Councillors at that time in relation to the Court’s original findings.  Decisions in
relation to litigation have been taken under delegated powers by the Head of
Governance, Strategy and Performance.
• The question raises the opportunity to highlight to Councillors the outcome of
the recent Child Protection Inspection Report by the Care Inspectorate and the
Page 7

Page 8

opportunity for further training for Councillors in relation to Corporate
Parenting.
Councillor McLennan as a supplementary question asked for assurance that the
Council's auditors and the external auditors will have full access to all paperwork
pertaining to the case and that Elected Members will have full, confidential access
to ensure fulfilment of scrutiny functions and roles. 
In response, the Interim Chief Executive confirmed the internal/external auditors
and Elected Members would have access to all available information however
referred to the Interim Chief Social Work Officer's response which stated that due
to changes in personnel in the time that has lapsed, it may prove challenging to
locate all the information.
6.         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.
Following consideration the Committee unanimously agreed to note the contents of
the report.
7.         Internal Audit Review - Procurement and Creditor Payments
The meeting had before it a report by the Audit and Risk Manager advising the
Committee on an internal audit review completed for the period from 25 June 2024
to 11 September 2024.
In response to a question from Councillor Gordon relating to the testing of the
random sample of payments to suppliers and contractors and the likelihood the
sample would have included consultants, the Audit and Risk Manager advised a
the sampling is done through an audit interrogation software package which
analyses all payments for a specific period and breaks them down into groups. 
The audit team then select random transactions varying in value including credit
payments to test.  The Audit and Risk Manager confirmed he is currently reviewing
the core testing role due to the audit programme being developed several years
ago in consultation with Audit Scotland, noting the testing supports his annual
opinion in terms of a core financial system.
Councillor Macrae, whilst welcoming the work being undertaken detailed in the
audit recommendation in respect of the Authorisation Database risk identified in
the Appendix, noted there are other systems across departments of the Council
which do not interface.   In response the Audit and Risk Manager confirmed there
are systems that require to be developed across the Council however advised
there are competing demands on resources for development of systems balanced
against the operational service demands. 
In response to a follow-up question from Councillor Keith relating to the
Authorisation Database and whether such issues should be picked up by internal
management rather than Internal Audit, the Head of Governance, Strategy and
Performance advised services undertaking continuous improvement checklists
under the Public Sector Improvement Framework, noted as part of the Best Value
Review, will have a programme of services to internally review their systems,
processes, consultation which should pick up such issues.
Page 8

Page 9

Following consideration the meeting unanimously agreed to note the contents of
the report.
8.         Internal Audit Review - Following the Public Pound
The meeting had before it a report by the Audit and Risk Manager advising the
Committee of an internal audit review completed for the period 25 June 2024 to 11
September.
Councillor Divers noted in relation to Audit Finding 5 in the Appendix it stated
discussions had been held with Elected Members on both the Moray Leisure
Centre Board and Citizens Advice Board, however he could not recall being
involved in such discussions.  In response the Audit and Risk Manager advised a
random sample of Elected Members on the Boards were selected as part of the
audit.
In response to a question from Councillor Gatt asking on what basis the Council
was currently operating with the Boards given the expired Service Level
Agreements (SLAs) referred to in Audit Finding 1 in the Appendix, the Depute
Chief Executive (Education, Communities and Organisational Development)
advised there has been a longstanding agreement in place for some time which
requires to be updated and, as reported to Committee, is being progressed.  She
confirmed a progress report will come to Moray Council to update Elected
Members which will explain the delays are as a result of the need to reflect the
wider project being pursued in the agreement by Moray Leisure and, given that
position, the Council will be progressing the SLA in its current form on the basis
that it can be adapted further if required.  In terms of ongoing arrangements and to
provide assurance the Council has good value for money in respect of the support
to Moray Leisure, the Depute Chief Executive advised the Sports and Leisure
Services Manager meets regularly with members of the Board and there have
been regular strategic meetings held between the Council's Interim Chief
Executive, external partners and Moray Leisure Board representatives.
Councillor Keith noted the explanation provided regarding the expired Moray
Leisure SLA and asked for clarification why the Citizens Advice Bureau SLA was
allowed to fall into abeyance.  In response the Head of Governance, Strategy and
Performance advised there is an agreement in place however it does not meet the
requirements of Following the Public Pound in terms of specific deliverables.  He
confirmed it is planned to bring the process for the new SLA to Committee in
October for approval to bind the payment into deliverables related to the Council's
areas of statutory responsibility. 
Following the earlier question from Councillor Divers relating to the discussions
with Elected Members on both Boards, Councillor McLennan suggested it may be
useful in terms of good governance for future engagement to be cross-party and
include the Chair and Depute Chair of this Committee.  In response the Audit and
Risk Manager agreed to take the point on board. 
Following consideration the Committee unanimously agreed to note the contents of
the report.
9.         Internal Audit Review - Commercial Refuse Collection
Page 9

Page 10

The meeting had before it a report by the Audit and Risk Manager advising
Committee on an internal audit review completed for the period from 25 June 2024
to 11 September 2024.
Following consideration the Committee unanimously agreed to note the contents of
the report.
10.         Public Sector Internal Audit Standards - External Quality
Assessment of Internal Audit
The meeting had before it a report by the Audit and Risk Manager providing the
Committee with details of a recent external quality assessment undertaken on the
Council's internal audit services.
The Committee joined the Chair in thanking all staff involved for their hard work
which had resulted in such a positive report. 
In response to a question from Councillor Gatt relating to para 6.3.7 of the
Appendix and whether the Council have the appropriate resources to undertake
the workload, the Interim Chief Executive advised benchmarking work required to
be done over the next few months taking into account the overall financial position
of the Council.
Following discussion the Committee unanimously agreed to note the report and
action plan prepared to address the issues raised in the external quality
assessment of internal audit.
11.         Carefirst Replacement - Progress Update
The meeting had before it a report by the Interim Head of Service and Chief Social
Work Officer informing the Committee of the progress of the replacement Social
Work and social care management information system and the outline business
case.
Councillor Macrae referred to the failure of the server in paragraph 4.7 and
expressed concern at the lengthy downtime for staff and, in terms of business
recovery, asked what assurance could be provided that the Council could continue
to operate if there was a outage across all services.  In response, the Head of
Human Resources, ICT and Organisational Development confirmed back up
arrangements are in place with a prioritised list of services who would be restored
and the list was currently under review in line with business continuity plan
arrangements.
In response to a question from Councillor McLennan regarding whether the 5
hours downtime referred to in paragraph 4.7 was within the parameters of the
business continuity plan, the Head of Human Resources, UCT and Organisational
Development advised she would confirm where the system sits on the prioritised
list and advise Members.
In response to a question from Councillor Macrae relating to whether shared
learning from colleagues in other local authorities could be used to find a solution
to be implemented timeously and at reasonable cost or if outsourcing could be
considered, the Interim Chief Social Work Officer confirmed benchmarking work is
being undertaken to identify councils using single systems.  He advised there is a
cost pressure including significant staff resourcing to transition to a new system as
Page 10

Page 11

migration is a complicated process which cannot be done quickly to ensure
requirements are met.
Councillor McLennan referred to the Audit and Risk Manager's concerns as stated
in paragraph 5(d) of the report and asked what assurance could be provided that
the current systems and any new system will give a balance of multi-agency
working whilst ensuring legislative requirements are met by each agency in terms
of data management and information security.  In response the Interim Chief
Social Work Officer advised the Council and agencies operate within the confines
of information sharing agreements and there are systems in place to ensure
access is proportionate and necessary. 
Following consideration the Committee unanimously agreed to note the report.
The press were asked to leave the meeting.
12.         Order of Business
In terms of Standing Order 29 the meeting agreed to vary the order of business set
down on the agenda and take Item 14 "Update on Improvement Plan for Adult
Social Care Commissioning [Para 8]" followed by Item 12 "Internal Audit Review -
Email Security [Para 4]" and Item 13 "Internal Audit Follow Up Review - Cyber
Security [Para 4]" as the next items of business to allow the Interim Chief Social
Work Officer to attend another meeting.
13.         Update on Improvement Plan for Adult Social Care Commissioning
[Para 8]
The meeting had before it a report by the Interim Head of Service and Chief Social
Work Officer updating the Committee of progress regarding the Improvement Plan
for Adult Social Care Commissioning.
Following consideration the Committee unanimously agreed to:-
i. note the progress of the Improvement Plan attached at Appendix 1;
ii. note the progress within this report as at the end of July 2024 in relation to the
recommendations detailed in the Improvement Plan; and
iii. note the updated report includes details of contract values, timelines and risks.
14.         Internal Audit Review - Email Security [Para 14]
The meeting had before it a report by the Audit and Risk Manager on an internal
audit review completed for the period from 25 June 2024 to 11 September 2024.
Following consideration the Committee unanimously agreed to note the contents of
the report.
15.         Internal Audit Follow Up Review - Cyber Security [Para 14]
The meeting had before it a report by the Audit and Risk Manager providing the
Committee with an updated on a follow up review completed by the Internal Audit
Section.
Page 11

Page 12

Following consideration the Committee unanimously agreed to note the contents of
the report.
Page 12

Page 13

REPORT TO:  AUDIT AND SCRUTINY COMMITTEE ON 20 NOVEMBER 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 5.
Page 13

Page 14

Follow Up Reviews
4.2 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. Internal Audit will also undertake follow up
reviews to evidence the effective implementation of these recommendations.
Please see detailed the following completed follow up reviews:
Debtors
4.3 An audit of the Debtors System was previously undertaken. 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 a check to ensure invoices can be evidenced with enough backing
documentation to be able to support debt recovery should the need arise;
confirm 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. The audit review did not include the arrangements for
recovering debts concerning council tax, non domestic rates and housing rents.
The Follow Up Report to review the implementation of the agreed
recommendations is given in Appendix 2.
Purchasing Cards
4.4 An audit was previously undertaken of the systems and procedures for the
management, use and control of purchasing cards. A purchasing card is similar
to a personal credit card issued by the Council's Bank used by the Moray
Council to enable purchases of supplies and services to be made quickly and
efficiently. Cards are available to officers on approval of their budget manager. It
provides flexibility and a cost effective alternative to the Council's standard
requisition ordering process. Purchasing cards are managed by a payment card
software application administered by the Bank. The audit scope for this review
was to assess the key controls and systems in place in the management and
use of purchasing cards. The Follow Up Report to review the implementation of
the agreed recommendations is given in Appendix 3.
Environmental Services Stores
4.5 A follow up review has been undertaken to evidence the implementation of
recommendations reported in the audit undertaken of the Environmental &
Commercial Services Stores. The stores are located at the Ashgrove Depot in
Elgin and include internal and external storage facilities. This is the primary
storage facility for meeting the needs of Roads, Cleaning, and Fleet Services. In
addition, the stores are responsible for purchasing and issuing approved clothing
for all Council Services. The stores software system has 1225 lines of individual
stock items, which can vary in value from a few pounds to upwards of £1,000. It
was noted during the follow up review that an upgrade to the stores software
system is shortly planned, which should enable greater automation of processes.
The Follow Up Report is given in Appendix 4.
Page 14

Page 15

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.
(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-2045703626-500 
SPMAN-2045703626-501
SPMAN-2045703626-502
SPMAN-2045703626-503
SPMAN-2045703626-504
Page 15

Page 16

Page 16

Page 17

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.
Completed
ICT Hardware Asset Management review of systems and
practices to record / monitor the location
and use of ICT hardware.
Fieldwork in progress
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).
Fieldwork in progress
Item 5.
Page 17

Page 18

Grant Claims Certification of grant claims as required:
strategic timber; network support grant,
regeneration schemes as appropriate
Network Support Grant audit completed,
and claim submitted to Transport
Scotland (October 2023 to March 2024).
Housing Rent Collection & Arrears
Management
A review of the income collection and
accounting arrangements for housing
rents.
Fieldwork in progress
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.
Completed
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. 
Draft report prepared
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.
Completed
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.
Completed
Page 18

Page 19

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 this quarter
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.
Completed
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. 
Completed
Fostering and Kinship payments A review to ensure that the internal
controls in place for administering
Fostering and Kinship Care Allowances
are operating effectively.
Completed
Page 19

Page 20

Follow Up reviews to be undertaken
from previous  Audit Assignments *
Audit Review: Original Scope Status/ Comments
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 this next quarter
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 this next quarter
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)
Page 20

Page 21

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
cans for which the Council received regular
payments from recycling contractors.
Follow Up Review programmed to start
in the next quarter(s)
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)
Page 21

Page 22

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)
Email Security The audit checked the system controls and
supporting policies and procedures used to
administer the Council's email system. The audit
also reviewed the arrangements for risk
identification and actions undertaken to protect
the Council from phishing emails. In addition, in
response to a request from an elected member,
the audit included a review of the password
management controls for members access to the
Council networks and systems.
Follow Up Review programmed to start
in the next quarter(s)
Keith Sports & Community Centre The audit scope reviewed the processes and
procedures in place at the Keith Sports and
Community Centre and evaluate the
effectiveness of internal controls relating to
income and expenditure. This involved the
sample testing of individual transactions to
ensure compliance with Regulations and
Guidelines. In addition, an appraisal of working
practices was also undertaken to assess if the
Service was maximising the income due to the
Council
Follow Up Review programmed to start
in the next quarter(s)
Page 22

Page 23

Environmental Services- Stores This audit reviewed the systems and controls in
managing stock held within Environmental &
Commercial Services Stores. The audit used the
Chartered Institute of Public Finance
Accountants audit programme to review the
systems and controls in managing stock held
within stores. Testing also included a review of
the security arrangements to safeguard against
unauthorised access to the storage areas
Completed
Purchasing Cards The audit scope for this review was to assess the
key controls and processes in place covering the
usage of purchasing cards. The audit included a
review of purchasing card guidelines and testing
the controls operating over the key processes of
purchase card applications, issue of cards,
usage, authorisation and VAT accounting
arrangements. Monitoring undertaken to ensure
compliance with regulations, policies and
procedures has also been undertaken, in
addition to the reconciliation of purchasing card
transactions detailed within the payment card
system to the Council's Financial Management
System
Completed
Foster and Kinship Care Payments The audit scope reviewed policies and
procedures for the management of fostering
and kinship payment of fees and allowances
are administered in accordance with these
policies and procedures and are operating
within budgetary control.
Follow Up Review programmed to start
in the next quarter(s)
Governance arrangements to prevent
Fraud and Corruption
This audit reviewed the Council and the Moray
Integration Joint Board (MIJB) governance
arrangements to prevent fraud and corruption.
The Cipfa Code of Practice on Managing the
Risk of Fraud and Corruption was used as the
template for developing an audit programme
for this review. The audit was also undertaken
as part of a joint working arrangement with the
internal audit service providers of NHS
Grampian, Aberdeen City and Aberdeenshire
Follow Up Review programmed to start
in the next quarter(s)
Page 23

Page 24

Councils.
Moray Growth Deal The scope of the audit included reviewed the
governance and administrative arrangements
surrounding the Moray Growth Deal.  It also
considered how partnership working is
operating, the financial management of the
Deal and how success is being measured.
Follow Up Review programmed to start
in the next quarter(s)
Early Learning and Childcare Premises
Security
The scope of the audit reviewed policies,
procedures, and an appraisal of the security
controls within nursery buildings and play
areas. The audit included a review of
guidelines issued centrally by the Early
Learning and Childcare Service and
instructions or handbooks that individual
nurseries may have developed. The audit
process involved selecting a sample of both
Council and privately run nurseries to visit,
where the actual security controls operating in
practice were observed and tested
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
Page 24

Page 25

APPENDIX 2
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 5.
Page 25

Page 26

2
Moray	Council
Internal	Audit	Section
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.
Page 26

Page 27

3
Moray	Council
Internal	Audit	Section
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
5.04 Consideration should be given for
additional guidance to be included
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.
Medium Yes 31/01/2024 Implemented – Revised Sundry Debt
Management Procedures have been updated
to include guidance on the use of legal action
for unpaid invoices.
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
Implemented – Performance management
information detailing the total value of invoices
raised, aged debt and debts written off by
service has now been developed. This
information is issued to Heads of Services
every quarter to enable more effective debt
management arrangements.
Page 27

Page 28

Page 28

Page 29

APPENDIX 3
Moray	Council
Internal	Audit	Section
DEPARTMENT: Economy, Environment & Finance
SUBJECT: Purchasing Cards
REPORT REF: 24'019
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:
Procedures are in place and frequently reviewed to govern use of the corporate purchasing cards system.
5.01 In accordance with agreed
timescales, Purchasing Card
Procedures should be reviewed
annually and made available on
the Interchange for user
reference. 
Medium Yes 30/04/2024 Implemented. The Purchasing Card
Procedures Manual has been reviewed and
presented on the Interchange for user
reference in June 2024. Going forward, the
procedures will be reviewed on an annual
basis.
Key Control:
A robust purchase card application process is in place accompanied by a controlled process for issue of cards on acceptance of terms of
operation.
Item 5.
Page 29

Page 30

2
Moray	Council
Internal	Audit	Section
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 officers must sign and return a
Payment Card Terms of Use Form
to the Payments Service before
being issued a purchasing card
and access granted to the
Payment Card System.
Medium Yes 30/04/2024 Implemented. Audit testing has confirmed
administrative processes have been
strengthened to ensure purchasing cards are
not despatched to new users until the signed
terms of use acceptance form has been
received by the Payments Service. A tidy up
exercise has also been undertaken to ensure
conditions of use acceptances are on file for all
existing cardholders.   
Key Control:
Usage of purchase cards is controlled by imposed limits, is for purchases not suitable for standard procurement routes, is appropriately
detailed for authorisation and scrutiny purposes and supports the continued appropriateness of card retention.  
5.03 Consideration should be given to Low Yes 31/07/2024 Implemented. An exercise has been
confirmed as undertaken to align cardholder
Page 30

Page 31

3
Moray	Council
Internal	Audit	Section
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
aligning all purchasing
cardholders who hold a standard
single transaction limit to the
current transaction limit of £1,000
to ensure consistency.
transaction limits. There are now 15 officers
holding single transaction limits over the
standard £1,000 threshold, all due to
assessed operational requirements,
compared to the 151 officers with higher than
standard limits in the original audit review.
5.04 The Bank should be informed to
correct the errors found in
Cardholders spending limits noted
during the audit review. 
Low Yes 31/07/2024 Implemented. As referred to in 5.03 above, an
exercise has been undertaken to review all
cardholder spending limits and errors
previously identified have been advised to the
Bank, resulting in amended limits being
applied.
Key Control:
Purchase Card transactions are appropriately authorised by the relevant budget manager.
5.05 Full transaction listings of
purchase card transactions
should be issued for information to
Medium Yes 30/04/2024 Implemented. A catch-up exercise has been
undertaken to issue full transaction listings for
2023/24 and the reports have been evidenced
Page 31

Page 32

4
Moray	Council
Internal	Audit	Section
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
all budget managers every
quarter, in compliance with
purchasing card procedures.
as issued for Quarter 1 of 2024/25. No delay is
expected for issue of reports to budget
managers going forwards due to streamlining
of the recording process with the newly
implemented electronic transaction logging.
5.06 Agreed timescales should be
established where payment card
transactions not authorised by a
budget manager are referred to
the appropriate Head of Service to
resolve and if required, authorise
the outstanding expenditure.
Medium Yes 30/04/2024 Implemented. Significant improvement has
been seen in the prompt authorisation of
transactions since the initial audit. Payments
Section has introduced new processes since
the end of June 2024. Transactions must now
be approved before they can be downloaded
for processing, giving greater impetus for
budget managers to act timeously and for
Page 32

Page 33

5
Moray	Council
Internal	Audit	Section
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
unapproved transactions to be identified and
pursued by Payments. Unapproved
transactions at the time of the follow-up audit
relate to only recent transactions with no
recurring control issue identified.
Key Control:
VAT on purchasing card transactions is accurately documented and accounted for with full recovery of applicable input tax elements.
5.07 A reminder should be issued to all
services to remind officers of VAT
accounting requirements for
payment card transactions. 
High Yes 30/04/2024 Implemented. A reminder of the VAT
accounting requirements has been added to
the annual terms of use confirmation issued to
all cardholders in March 2024. In addition, the
Purchasing Card guidelines have been
augmented in June 2024 to include more
clarity and detail on VAT requirements. The
new electronic receipt logging process
Page 33

Page 34

6
Moray	Council
Internal	Audit	Section
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
implemented in June 2024 has also provided a
further opportunity to communicate VAT
accounting requirements to all cardholders.
Process enhancements implemented can be
seen to have strengthened the VAT
accounting system.
5.08 Consideration should be given for
the Payments Service to
undertake further monitoring of
payment card transactions with
the aim of maximising VAT
recovery where documentary
evidence is required of valid VAT
receipts / invoices from services.
High Yes 31/07/2024 Implemented. Since the audit took place,
mandatory electronic VAT receipt submission
within the Purchasing Card system has been
introduced. This has assisted the monitoring
process with electronic receipt submissions
being validated by the Payments service and
any documentation unsuitable for VAT reclaim
being immediately identified and further
queried as a routine process to ensure
maximisation of VAT recovery is achieved.
Page 34

Page 35

7
Moray	Council
Internal	Audit	Section
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
5.09 The agreed procedure for the
Payments Service of issuing
routine escalation reports on
purchase card transactions with
potential VAT implications to
Heads of Service should be
reinstated to promote VAT
recovery arrangements.
High Yes 30/04/2024 Implemented. A catch-up exercise has been
undertaken to issue VAT information reports to
Heads of Service (HOS) for 2023/24 and for
Quarter 1 of 2024/25. No delay is expected for
issue of reports to HOS going forwards due to
streamlining of the recording process with the
newly implemented electronic transaction
logging. With the requirement for receipt
production on transaction logging, the need to
escalate to HOS is expected to decrease and
will be reviewed in time to assess if still
appropriate and impactful.
Page 35

Page 36

8
Moray	Council
Internal	Audit	Section
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
5.10 Investigation of an electronic
document imaging facility to
record VAT receipts / invoices on
transaction logging should
continue with the aim of
implementing more effective VAT
accounting and documentation
retention arrangements.
Medium Yes 31/07/2024 Implemented. Mandatory electronic receipt
logging has been introduced as part of the
Purchasing Card system in June 2024. This is
already showing benefits in effective VAT
accounting and document retention
arrangements and is deemed to be a welcome
improvement to Purchasing Card
administration.
Key Control:
Processes are in place to ensure purchase card permissions are fully withdrawn from cardholders on termination of employment.
5.11 In accordance with operating
arrangements, the payment card
system should be updated
promptly to reflect current budget
management responsibilities
Medium Yes 30/04/2024 Implemented. A tidy up exercise has been
completed regarding budget managers within
the payment card system. Monthly processing
of leavers is being undertaken.
Page 36

Page 37

9
Moray	Council
Internal	Audit	Section
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
when notified of officers leaving
the employment of the Council. 
5.12 Greater care should be taken on
inputting payroll reference
numbers when setting up
employees on the purchasing
card system.
Low Yes 30/04/2024 Implemented. A reminder on input accuracy
has been issued to relevant officers and follow
-up testing has confirmed accurate set up of
new users on the purchasing card system.
Page 37

Page 38

Page 38

Page 39

APPENDIX 4
Moray	Council
Internal	Audit	Section
DEPARTMENT: Economy, Environment & Finance
SUBJECT: Environmental Services Stores
REPORT REF: 23'023
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 systems and procedures are operating to ensure accurate records are maintained to account for all stocks held within
Environmental Services Stores.
5.01 A review should be undertaken of the
items stored within the external
storage compound and consideration
should be given to whether any items
could be stored within the internal
storage facility for improved security.
High Yes 30/06/2023 Implemented –  A review of the items stored
within the external storage area has been
carried out, and several items, including the
copper coil, are now stored in a secure
location.
Item 5.
Page 39

Page 40

2
Moray	Council
Internal	Audit	Section
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
This includes the copper coil
identified during the audit review.
5.02 All materials and equipment recorded
within Tranman should be updated
with minimum and maximum stock
levels. This should assist in more
effective management of stock levels
at the appropriate levels.
Medium Yes 31/12/2023 Implemented –  Maximum and minimum
stock levels have now been set for all items
within Tranman.  
5.03 Adjustments required to stock figures
recorded within Tranman should
require the authorisation of the Fleet
Business Co-ordinator.
Medium Yes Implemented Implemented -
Procedures have been amended to ensure
that adjustments to Tranman stock levels are
authorised by the Fleet Business Co-ordinator
or the Senior Stores Officer.
5.04 The Stock items currently housed in
the Roads Hanger should be placed
in a secure area where only Stores
Medium Yes Implemented Implemented – A secure area has been
created within the Roads Hanger to store
Page 40

Page 41

3
Moray	Council
Internal	Audit	Section
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
staff can access them so as to ensure
that accurate recording of issues and
returns can be maintained.
stock items, with only Stores officers having
access to this area.
5.05 Current procedures should be
amended to ensure that changes to
framework contract prices of stock
items are regularly updated within
Tranman.
High Yes 30/06/2023 Part Implemented – Increases in the price of
higher value items will be manually updated in
Tranman on delivery of a stock purchase. This
finding concerned a minor variance noted in
the average price stock valuation when an
item is received, recorded within Tranman and
issued before the receipt of the invoice where
there has been an increase in the unit price.
The audit testing of a sample of lower value
stock items where this has occurred only
found a minor material stock valuation
variance within Tranman. An upgrade to the
Tranman system is planned shortly, which
should allow the automation of increases in
framework contract prices. No further follow up
review of this recommendation is planned.
Page 41

Page 42

4
Moray	Council
Internal	Audit	Section
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
5.06 Regular reviews should be
undertaken of stores to highlight any
slow moving or obsolete stock.
Consideration should then be
undertaken as to whether any
identified items are sold or disposed.
Medium Yes 30/09/2023 Implemented – A review of slow-moving stock
has been carried out, and where items have
been identified as obsolete, they have been
written off and disposed. This is now part of an
ongoing process.
Key Control:
Effective systems and procedures operating to ensure accurate records are maintained for all stocks issued and returned by
Environmental Services Stores.
5.08 The details and signature of the
officer raising and authorising
requisitions for items from stores
or similar information within email
requests should be recoded in all
instances. Staff should be
reminded of the need for this to
take place.
Medium Yes Ongoing Implemented –   A reminder email was issued
to all services that use the Stores. The follow
up review was then undertaken and a sample
of requisitions for stock items was randomly
selected. It is pleasing to report that details of
the officer raising and authorising the
requisitions are now recorded. Where
requisitions are raised over the phone or
Page 42

Page 43

5
Moray	Council
Internal	Audit	Section
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
email, Stores staff detail the information and
sign the requisition note.
Page 43

Page 44

Page 44

Page 45

REPORT TO:    AUDIT AND SCRUTINY COMMITTEE ON 20 NOVEMBER 2024
SUBJECT: INTERNAL AUDIT REVIEW – FOSTERING AND KINSHIP CARE
PAYMENTS
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 11 September 2024 to 20 November 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 25 June 2024 to 20 November 2024.:
Fostering and Kinship Care Payments
3.2 An audit has been undertaken of the administrative arrangements for Fostering
and Kinship Care Payments. The audit reviewed that the processing of
fostering and kinship payments of fees and allowances are administered in
accordance with agreed policies and procedures. It is pleasing to report that
within the scope of the audit, the management of fostering and kinship
payments was well managed. However, some administrative control
improvements were noted concerning the recording of information and the
introduction of additional verification checks to confirm eligibility for ongoing
kinship allowance payments. The audit report for this project is given
in Appendix 1.
Item 6.
Page 45

Page 46

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.
Author of Report:            Dafydd Lewis, Audit and Risk Manager
Background Papers:       Internal audit files
Ref:                                 SPMAN-2045703626-505 / SPMAN-2045703626-506
Page 46

Page 47

Appendix 1 
1
Final Internal Audit Report 
Fostering and Kinship Care Payments 
July 2024   
Distribution: Chief Social Work Officer/Head of Service                               
Children and Families Social Work Service Manager 
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
(detailed explanation provided in Appendix1). The audit recommendations for this review have
been classified as follows 
Assurance Level
Risk Ratings for
Recommendations 
Priority 1   0     
Substantial Priority 2   1     
Priority 3   2     
Confidentiality and Disclosure Clause 
This report (“Report”) was prepared by the Internal Audit Section of Moray Council. The matters raised in this Report are
only those which came to our attention during our internal audit work. Whilst every care has been taken to ensure that the
information provided in this Report is as accurate as possible, the Moray Council Internal Audit Section has only been able
to base findings on the information and documentation provided and consequently, no complete guarantee can be given
that this Report is necessarily a comprehensive statement of all the weaknesses that exist, or of all the improvements that
may be required. 
This Report was prepared solely for the use and benefit of the Moray Council, Moray Integration Joint Board or the
Grampian Valuation Joint Board. Moray Council's Internal Audit Section accepts no responsibility and disclaims all liability
to any third party who purports to use or rely for any reason whatsoever on the Report, its contents, conclusions, any
extract, reinterpretation, amendment and/or modification. Accordingly, any reliance placed on the Report, its contents,
conclusions, any extract, reinterpretation, amendment and/or modification by any third party is entirely at their own risk. 
Please refer to the Statement of Responsibility in Appendix 2 of this report for further information about
responsibilities, limitations and confidentiality.   
Item 6.
Page 47

Page 48

Appendix 1 
2
Contents 
Page
Foster and Kinship Care Payments 
1. Introduction & Scope 3
2. Key Issues  3-4 
Detailed Report 
3. Findings/Recommendations 5-7
4. Management Response 5-7 
Appendices 
1. Audit Terms of Reference and Definitions 
2. Statement of Responsibility 
Page 48

Page 49

Appendix 1 
3
1. Introduction and Audit Scope  
The 2024/25 Annual Audit Plan provides for a review of the administration of
Fostering and Kinship Care Payments. 
Fostering occurs when a child cannot be cared for by their birth parents, or by
their extended family or close friends, and need to be cared for by an
approved foster family. Whereas kinship care is where a child is unable to live
with their birth parent and resides instead with a relative or other individual
with whom they have a pre-existing relationship, e.g., a sibling or close family
friend. In August 2023, the Scottish Government and COSLA agreed on the
Scottish Recommended Allowance for foster and kinship carers. In addition,
foster carers are also paid a weekly fee depending on their skill levels and
experience.  A review of the Council’s Financial Management System noted
that fostering and kinship payments made to carers in 2023/24 amounted to
£1.2 million and £443,000 respectively. At the time of the audit, the Council
financially supports 47 children in foster care and 80 children within kinship
arrangements. 
The audit scope reviewed policies and procedures for the management of
fostering and kinship payment of fees and allowances are administered in
accordance with these policies and procedures and are operating within
budgetary control. 
The audit was carried out in accordance with Public Sector Internal Audit
Standards (PSIAS). 
2. Key Issues 
The audit found that the management and processing of fostering and
kinship payments were well managed. However, some systems and
administrative control improvements were noted, including: 
•   The audit noted the Service has detailed case recording procedures to
assist officers in managing foster and kinship arrangements.
However, audit testing of a sample of care arrangements noted that
some documents, although found, had not been saved in the correct
location in accordance with agreed procedures. In addition, it was also
noted a need to update the Kinship Carer Agreement between the
Council and carers to reflect current data protection legislation. 
Page 49

Page 50

Appendix 1 
4
• The scope of this audit included reviewing the controls in place to verify
the ongoing entitlement of allowances and fees paid to carers. It was
noted that a financial irregularity has occurred within another Scottish
Local Authority concerning a significant overpayment of a kinship
payment made to a carer. The irregularity related to the ongoing
payment when the child no longer stayed with the kinship carer. It is
pleasing to note that the Service has controls in place to check carers
eligibility to maintain continued allowance payments; however, further
verification testing should also be considered. 
Page 50

Page 51

Appendix 1 
5
Commercial Waste Collection- 2024/25 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1. Low A requirement of the kinship care placement
process for a child is for a carer to agree and sign
a Kinship Carer Agreement with the Council. This
document details the duties and obligations of
both the Council and the carer regarding the
ongoing care responsibility for the child. The audit
found that on review of the Kinship Carer
Agreement, reference is made to previous data
protection legislation. 
The Kinship Carer Agreement template
should be reviewed and updated with
reference to the current data protection
legislation. 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Social Work Service
Manager
Yes Implemented Kinship Carer Agreement template has been amended to
reflect current data protection legislation. 
Page 51

Page 52

Appendix 1 
6
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
2. Low In addition to a review of the arrangements for
administering fostering and kinship payments, a
check was also made to ensure that
documentation retention of information and key
documents for managing the relationship between
the Council and the carer was saved in
accordance with the Case Recording Procedures.
Audit testing of a sample of care arrangements
noted that some documents, although found, had
not been saved within a location that was per
these agreed procedures.   
All officers administering fostering and
kinship arrangements with carers should be
reminded that the recording and retention
of documents should be in accordance with
the Case Recording Procedures. 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Social Work Service
Manager
Yes 31/10/2024 Reminder will be issued by the Business Support Team to
officers of the requirement to follow Case Recording
Procedures around recording and retention of documents. 
Page 52

Page 53

Appendix 1 
7
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
3.   Medium  As part of the research for this audit, it was noted
that a financial irregularity had occurred within
another Scottish Local Authority concerning a
significant overpayment of a kinship payment
made to a carer. The overpayment occurred due
to ongoing payment when the child no longer
stayed with the kinship carer. The Council
concerned was contacted to gain a further
understanding of the issues that have assisted in
developing the audit programme of testing for this
review. It is pleasing to note that the Service
introduced a requirement a few years ago for
carers to make a self-declaration of eligibility to
maintain continued allowance payments.
However, it is considered that further verification
checks should also be considered.
In accordance with the Children (Scotland)
Act 1995, a carer is entitled to a kinship
allowance payment until the young person
is 18 if they remain in full time education.
Further to discussions with the Service,
consideration should be given to
undertaking regular verification checks to
confirm details of educational status and
address for children within a kinship
residence order arrangement with
Education Services. 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Social Work Service
Manager 
Yes Implemented A new process has been implemented for residence
carers to complete the details of the child’s school on their
annual return.  This information will be checked regularly
with Education Services to ensure there is no change in
circumstances. 
Page 53

Page 54

Appendix 1 
8
Appendix 1 
AUDIT TERMS OF REFERENCE AND DEFINITIONS 
1. Audit Objectives 
1.1 The overall audit objective is to provide an objective independent opinion on
the adequacy and effectiveness of controls / processes.  
1.2 The audit will for each controls / process being considered: 
• Walkthrough the processes to consider the key controls; 
• Conduct sample testing of the identified key controls, and 
•    Report on these accordingly 
1.3 All audit reviews are carried out in accordance with Public Sector Internal
Audit Standards (PSIAS). 
2. Definitions for Auditing Opinions and Findings 
2.1 In order to assist management in using our reports: 
The Internal Auditor will categorise audit assurance opinion according to
their overall assessment of the risk management system, effectiveness of the
controls in place and the level of compliance with these controls and the
action being taken to remedy significant findings or weaknesses. 
Assurance
Level
System and Testing Conclusion
Full The controls tested are being consistently applied
Substantial There is evidence that the level of noncompliance with some of
the controls may put some of the system objectives at risk.
Limited The level of non compliance puts the system objectives at risk.
None Significant non-compliance with basic controls leaves the system
open to error or abuse. 
2.2 Risk ratings for each recommendation is based on the following criteria: 
High Fundamental control weaknesses that require immediate attention
by management to action and mitigate significant exposure to risk
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.
Page 54

Page 55

Appendix 1 
9
Appendix 2 
STATEMENT OF RESPONSIBILITY   
The responsibility for designing and maintaining a sound system of internal control
to prevent and detect fraud and other irregularities rests with management, with
internal audit providing a service to management to support them to achieve this
objective. The Internal Audit Section will assess the adequacy and effectiveness of
the system of internal control arrangements implemented by management and
perform sample testing on those controls in the period under review with a view to
providing an opinion on the extent to which risks in this area are managed. 
The Internal Audit Section will undertake testing with the objective of detecting
significant control weaknesses. However, the audit approach alone should not be
relied upon to identify all strengths and weaknesses in internal controls nor to find
any fraud or irregularity. Even sound systems of internal control can only provide
reasonable and not absolute assurance and may not be proof against collusive
fraud. 
The matters raised in this report are only those that came to our attention during
the course of the audit review and are not necessarily a comprehensive statement
of all the weaknesses that exist or all improvements that might be made.
Recommendations for improvements should be assessed by management for their
full impact before they are implemented. The performance of the audit review
undertaken should not be taken as a substitute for management’s responsibilities
for the application of sound management practices. 
This report is confidential and must not be disclosed to any third party or
reproduced in whole or in part without the written consent of the Moray Council’s
Audit and Risk Manager. 
Page 55

Page 56

Page 56

Page 57

REPORT TO:    AUDIT AND SCRUTINY COMMITTEE ON 20 NOVEMBER 2024
SUBJECT: INTERNAL AUDIT REVIEW – GOVERNANCE ARRANGEMENTS
TO PREVENT FRAUD AND CORRUPTION
BY: AUDIT AND RISK MANAGER
1. REASON FOR REPORT
1.1 The report advises Committee on an internal audit review completed for the
period from 11 September 2024 to 20 November 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 internal audit review completed during the
period 11 September 2024 to 20 November 2024 regarding the Council’s and
the Moray Integration Joint Board (MIJB) governance arrangements to prevent
fraud and corruption:
Governance arrangements to prevent Fraud and Corruption   
3.2 A review was undertaken of the Council and the MIJB’s governance
arrangements to prevent fraud and corruption. The Chartered Institute of Public
Finance and Accountancy Code of Practice on Managing the Risk of Fraud
and Corruption was used as the template for developing an audit programme
of testing to be undertaken. This review was done as part of a joint audit
exercise with the internal audit providers of NHS Grampian and Aberdeenshire
/ Aberdeen City Councils. As the Integration Joint Boards deliver services
through officers and systems of the Council and NHS Grampian, this approach
has allowed for a more overarching and complete review to be undertaken. In
addition, the opportunity for sharing knowledge and expertise has benefited all
the internal audit providers in the delivery of this audit review. 
Item 7.
Page 57

Page 58

3.3 The responsibility for preventing and detecting fraud and corruption rests with
management. However, the Internal Audit Service has a role in supporting
these arrangements by assessing the adequacy of these controls and leading
investigations of irregularities concerning finances, property, services, or
policies of the Council. Regarding allegations of fraud or corruption within NHS
Grampian, it is the responsibility of the NHS Counter Fraud Authority to
investigate. Findings noted where further improvements are needed in
developing agreed procedures between the Internal Audit Service and the NHS
Counter Fraud Authority, as officers of both NHS Grampian and the Council
use systems of both organisations to deliver services. Improvements were also
noted where further development is needed within the Council to enable more
effective reporting of irregularities.  The audit report for this project is given
in Appendix 1.
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.
Page 58

Page 59

Author of Report:            Dafydd Lewis, Audit and Risk Manager
Background Papers:       Internal audit files
Ref:                                 SPMAN-2045703626-507 / SPMAN-2045703626-508
Page 59

Page 60

Page 60

Page 61

Appendix 1 
1
Final Internal Audit Report 
Governance arrangements to
prevent Fraud and Corruption  
October 2024   
Distribution: Interim Chief Officer Health & Social Care Moray (MIJB) 
Head of Governance Strategy & Performance 
Chief Financial Officer 
Head of Human Resources ICT & Organisational Development 
Audit & Risk Manager                             
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
(detailed explanation provided in Appendix1). The audit recommendations for this review have
been classified as follows 
Assurance Level
Risk Ratings for
Recommendations 
Priority 1   0     
Substantial Priority 2   3     
Priority 3   2     
Confidentiality and Disclosure Clause 
This report (“Report”) was prepared by the Internal Audit Section of Moray Council. The matters raised in this Report are
only those which came to our attention during our internal audit work. Whilst every care has been taken to ensure that the
information provided in this Report is as accurate as possible, the Moray Council Internal Audit Section has only been able
to base findings on the information and documentation provided and consequently, no complete guarantee can be given
that this Report is necessarily a comprehensive statement of all the weaknesses that exist, or of all the improvements that
may be required. 
This Report was prepared solely for the use and benefit of the Moray Council, Moray Integration Joint Board or the
Grampian Valuation Joint Board. Moray Council's Internal Audit Section accepts no responsibility and disclaims all liability
to any third party who purports to use or rely for any reason whatsoever on the Report, its contents, conclusions, any
extract, reinterpretation, amendment and/or modification. Accordingly, any reliance placed on the Report, its contents,
conclusions, any extract, reinterpretation, amendment and/or modification by any third party is entirely at their own risk. 
Please refer to the Statement of Responsibility in Appendix 2 of this report for further information about
responsibilities, limitations and confidentiality.  
Item 7.
Page 61

Page 62

Appendix 1 
2
Contents 
Page 
Governance arrangements to prevent Fraud and
Corruption   
1. Introduction & Scope 3
2. Key Issues  3-4 
Detailed Report 
3. Findings/Recommendations 5-10
4. Management Response 5-10 
Appendices 
1. Audit Terms of Reference and Definitions 
2. Statement of Responsibility 
Page 62

Page 63

Appendix 1 
3
1. Introduction and Audit Scope 
The Annual Audit Plan for 2024/25 provides for a review of the Council and the
Moray Integration Joint Board (MIJB) governance arrangements to prevent
fraud and corruption.  The primary responsibility for preventing and detecting
fraud and corruption rests with management who should ensure adequate
systems of internal control, segregation of duties and proper authorisation
procedures. However, the Internal Audit Section does have a role in supporting
these arrangements by assessing the adequacy of these controls, and in
accordance with the Council’s Financial Regulations for the Audit and Risk
Manager to investigate in consultation with the Depute Chief Executive
Education, Communities & Organisational Development irregularities
concerning finances, property, services or policies of the Council. The audit also
reviewed the arrangements for the investigation, preventing and detecting fraud
and corruption within the MIJB. The Council’s Audit and Risk Manager is also
the Chief Internal Auditor of the MIJB. 
The Cipfa Code of Practice on Managing the Risk of Fraud and Corruption was
used as the template for developing an audit programme for this review. The
audit was also undertaken as part of a joint working arrangement with the
internal audit service providers of NHS Grampian, Aberdeen City and
Aberdeenshire Councils. This has allowed the sharing of knowledge and
agreement in the audit testing to ensure consistency and a more overarching
review of the Integration Joint Boards (IJBs) counter fraud and corruption
arrangements within the Grampian area. The IJBs deliver services through
officers and systems of the Council and NHS Grampian. Officers from the
Council and NHS Grampian will have access to the systems of both
organisations. It is hoped these joint working arrangements with the internal
audit service providers within Grampian will continue as it provides the
opportunity for a more cross-organisational review of the IJB’s risk
management, control and governance processes irrespective of NHS Grampian
or Council systems are used in the delivery of services.   
The audit was carried out in accordance with Public Sector Internal Audit
Standards (PSIAS). 
2. Key Issues 
•   The Public Sector Internal Audit Standards require the Chief Internal
Auditor to provide an opinion on the overall adequacy and
effectiveness of the MIJB risk management, control, and governance
processes. MIJB delegated services are delivered by Council and
NHS Grampian employed officers with access to systems of both
organisations. Responsibility for investigating fraud within the Council
Page 63

Page 64

Appendix 1 
4
lies with the Audit and Risk Manager, but for NHS Grampian, it is the
responsibility of the NHS Counter Fraud Authority. It is appreciated
that the occurrence of fraud is rare, but consideration should be given
to developing a protocol between the Audit and Risk Manager in
consultation with the Chief Internal Auditor of Aberdeenshire/
Aberdeen City Councils and the NHS Counter Fraud Authority. This
should assist in providing greater clarity and co-ordination of
responsibility in the notification, investigation and reporting of alleged
frauds within the MIJB, irrespective of whether the Council or NHS
Grampian employs the officer delivering the delegated service.   
•   The CIPFA Code of Practice on Managing the Risk of Fraud and
Corruption requires that an “organisation should make arrangements
for appropriate resources to support the counter fraud strategy”. This
includes the need to detect fraud through data and intelligence
analysis. The staff resources of the Internal Audit Section are limited,
but consideration should be given to including a project within the
Annual Internal Audit Plan to review Council systems and practices
where fraud or irregularities have occurred in other organisations. The
testing undertaken should make use of data evaluation software in the
analysis of information, and a review of fraud cases and other
irregularities reported within the media, Audit Scotland Technical
Bulletins and participation in the Scottish Local Authority Investigator's
Group. 
Page 64

Page 65

Appendix 1 
5
Governance arrangements to prevent Fraud and Corruption - 2024/25 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1. Medium A review of the Council’s policy framework which
supports a counter fraud strategy, noted a range of
policies to inform officers in their conduct and
responsibilities as employees. These policies also
protect officers from false allegations of fraud or
corruption. However, the audit review noted that the
Code of Conduct for Employees and the Policy on
Outside Employment had not been reviewed for a
number of years. It is appreciated that both the Code
of Conduct for Employees and the Policy on Outside
Employment detail best practices and are still relevant;
however, both documents should be reviewed and if
required updated. 
The Code of Conduct for Employees and the
Policy on Outside Employment should be
reviewed and if required updated. In addition,
future dates of review should thereafter be
agreed. 
.
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment 
Organisational Development
Manager
Yes 31/03/2026 The employment policy framework is reviewed annually,
resulting in agreement on the priorities for policy review
according to a range of factors, such as changed legislation.
The Code of Conduct for Employees and the Policy on Outside
Employment remain appropriate and have not been identified
as a priority for updating; however, they will be included in the
annual plan for policies review for 2025/26. 
Page 65

Page 66

Appendix 1 
6
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
2.   Low  It was noted that the Council’s website included details
on reporting allegations of potential fraud to the
Internal Audit Section. However, reference is made
specifically to the reporting of Housing and Social
Security Benefits fraud, as this used to be the most
significant area of allegations received for
investigation. A review of the wording used within the
Council’s internet site should be undertaken, as a
need to report a potential fraud may relate to any
service area of the Council. In addition, research noted
online fraud reporting function within other Local
Authorities as an additional method for an individual to
report an allegation of fraud. 
Current wording used within the Council’s
internet site for reporting an allegation of fraud
should be reviewed and updated. In addition,
consideration should be given to the
development of an online reporting function as
an additional method for an individual to raise a
concern of fraud to the Council.   
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Audit and Risk Manager Yes 31/03/2025 The information on the Council’s website for reporting fraud will
be reviewed and updated. The timescale for implementation of
this recommendation has been recorded as 31 March 2025 due
to the need for updating web pages and the development of an
online fraud reporting function which requires the support of the
ICT Section.   
Page 66

Page 67

Appendix 1 
7
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
3.   Low  As part of the audit planning of projects to be included
within the Annual Audit Plan for 2023/24, a joint
working arrangement was agreed with the internal
audit service providers of NHS Grampian, Aberdeen
City and Aberdeenshire Councils to review the
Integration Joint Boards governance arrangements to
prevent fraud and corruption. This has allowed for a
more overarching review to be undertaken. As part of
the joint audit working arrangement, this has also
enabled the sharing of knowledge and information.
The Financial Regulations of the MIJB were updated
last year to include revised wording for reporting and
investigating a suspected irregularity. However, it was
noted that our neighbouring Councils had developed a
“Counter Fraud Process” detailing best practices to
follow in assessing a referral and investigating fraud.
The occurrence of fraud is rare and the nature of each
investigation can vary in nature, but consideration
should be given to reviewing and if required, adapting
this procedural document within Moray. 
Consideration should be given for the Internal
Audit Section to develop a “Counter Fraud
Process” procedure. 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Audit and Risk Manager Yes 30/11/2024 The “Counter Fraud Process” already developed by a
neighbouring Council will be used to prepare a similar
procedural guidance document for the Moray Council. 
Page 67

Page 68

Appendix 1 
8
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
4.   Medium  The Council’s Audit and Risk Manager is the
appointed Chief Internal Auditor for delivering an
internal audit service to the MIJB. MIJB delegated
services are undertaken by Council and NHS
Grampian officers and systems. Officers of both the
Council and NHS Grampian are required to use the
systems of each organisation to deliver services. The
Audit and Risk Manager is responsible for
investigating suspected irregularities within the
Council, and the NHS Counter Fraud Authority
investigates NHS Grampian's allegations of fraud.
However, an issue may occur if an officer employed by
the Council commits fraud involving an NHS system
and vice-versa as to whether the allegation within the
MIJB should be investigated by the Council’s Audit
and Risk Manager or the NHS Counter Fraud
Authority. The nature of the fraud may have a cross
organisational implication regarding access to
information and the individual officer's terms and
conditions of employment from each organisation. 
Consideration should be given to the Audit and
Risk Manager, in consultation with the Chief
Internal Auditor of Aberdeenshire and
Aberdeen City Councils, to discuss and if
possible, agree on a protocol for the
notification, investigation and reporting of
alleged fraud within the Grampian IJBs with the
NHS Counter Fraud Authority. This may require
a “letter of understanding” detailing agreed
arrangements for the fraud investigation. 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Audit and Risk Manager Yes 30/11/2024 Contact will be made with the Chief Internal Auditor of
Aberdeenshire and Aberdeen City Councils to discuss arranging a
meeting with the NHS Counter Fraud Authority to agree a protocol
for investigating fraud within the Grampian IJBs. 
Page 68

Page 69

Appendix 1 
9
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
5.   Medium  At a Special Meeting of the Moray Council on 28
February 2024, it was decided to reduce the Internal
Audit Section staffing budget by replacing the
Corporate Investigations Officer’s post with a 0.5 full-
time equivalent. The remaining budget was used to
appoint an Assistant Auditor, but this proved
unsuccessful, with no suitable applicants. The CIPFA
Code of Practice on Managing the Risk of Fraud and
Corruption requires that an “organisation should make
arrangements for appropriate resources to support the
counter fraud strategy” of the Council. This includes
the need to detect fraud through data and intelligence
analysis. The limited staff resources of the Internal
Audit Section are appreciated, but consideration
should be given to including a project within the
Annual Internal Audit Plan to review systems and
practices where fraud or irregularities have been
reported within other organisations. 
During this review, it was noted that a financial fraud
was reported in the media of an officer in another
Local Authority embezzling over £1 million in council
tax refunds. Further to consultation with the Council’s
Taxation Manager, additional controls have been
introduced to current operating arrangements. 
The Audit and Risk Manager should consider
including a project within the Annual Internal
Audit Plan to review Councill systems and
practices where fraud has occurred within other
organisations. Identification of the scope and
testing to be undertaken will be determined
from a review of fraud cases reported in the
media, Audit Scotland Technical Bulletins and
participation in the Scottish Local Authority
Investigator's Group. The use of information
data evaluation software should also be used in
the analysis of information and databases. 
Page 69

Page 70

Appendix 1 
10 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Audit and Risk Manager Yes 28/02/2025 A project will be included to support the Council’s and MIJB
counter fraud and corruption arrangements in the Annual
Internal Audit Plan. The scope of the audit and testing
undertaken will be determined from frauds reported within other
organisations. The use of IDEA® Data Analysis software will be
further developed in the analysis of information used for audit
testing. 
Page 70

Page 71

Appendix 1 
11 
Appendix 1 
AUDIT TERMS OF REFERENCE AND DEFINITIONS 
1. Audit Objectives 
1.1 The overall audit objective is to provide an objective independent opinion on
the adequacy and effectiveness of controls / processes.  
1.2 The audit will for each controls / process being considered: 
• Walkthrough the processes to consider the key controls; 
• Conduct sample testing of the identified key controls, and 
•  Report on these accordingly 
1.3 All audit reviews are carried out in accordance with Public Sector Internal
Audit Standards (PSIAS). 
2. Definitions for Auditing Opinions and Findings 
2.1 In order to assist management in using our reports: 
The Internal Auditor will categorise audit assurance opinion according to
their overall assessment of the risk management system, effectiveness of the
controls in place and the level of compliance with these controls and the
action being taken to remedy significant findings or weaknesses. 
Assurance
Level
System and Testing Conclusion
Full The controls tested are being consistently applied
Substantial There is evidence that the level of noncompliance with some of
the controls may put some of the system objectives at risk.
Limited The level of non compliance puts the system objectives at risk.
None Significant non-compliance with basic controls leaves the system
open to error or abuse. 
2.2 Risk ratings for each recommendation is based on the following criteria: 
High Fundamental control weaknesses that require immediate
attention by management to action and mitigate significant
exposure to risk
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.
Page 71

Page 72

Appendix 1 
12 
Appendix 2 
STATEMENT OF RESPONSIBILITY   
The responsibility for designing and maintaining a sound system of internal control
to prevent and detect fraud and other irregularities rests with management, with
internal audit providing a service to management to support them to achieve this
objective. The Internal Audit Section will assess the adequacy and effectiveness of
the system of internal control arrangements implemented by management and
perform sample testing on those controls in the period under review with a view to
providing an opinion on the extent to which risks in this area are managed. 
The Internal Audit Section will undertake testing with the objective of detecting
significant control weaknesses. However, the audit approach alone should not be
relied upon to identify all strengths and weaknesses in internal controls nor to find
any fraud or irregularity. Even sound systems of internal control can only provide
reasonable and not absolute assurance and may not be proof against collusive
fraud. 
The matters raised in this report are only those that came to our attention during
the course of the audit review and are not necessarily a comprehensive statement
of all the weaknesses that exist or all improvements that might be made.
Recommendations for improvements should be assessed by management for their
full impact before they are implemented. The performance of the audit review
undertaken should not be taken as a substitute for management’s responsibilities
for the application of sound management practices. 
This report is confidential and must not be disclosed to any third party or
reproduced in whole or in part without the written consent of the Moray Council’s
Audit and Risk Manager. 
Page 72

Page 73

REPORT TO:    AUDIT AND SCRUTINY COMMITTEE ON 20 NOVEMBER 2024
SUBJECT: INTERNAL AUDIT REVIEW – MORAY GROWTH DEAL
BY: AUDIT AND RISK MANAGER
1. REASON FOR REPORT
1.1 The report advises Committee on an internal audit review completed for the
period from 11 September 2024 to 20 November 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 internal audit review completed during the
period 11 September 2024 to 20 November 2024 regarding the Moray
Growth Deal:
Moray Growth Deal   
3.2 The Moray Growth Deal is a transformational programme of over £100
million, designed to drive economic growth across Moray over a ten year
period. The Moray Growth Deal brings together the Scottish and UK
Governments, Moray Council, partners from across the public and third
sector, and businesses to work collaboratively to deliver the Deal’s vision for
the area. Moray Council is the accountable body for the Growth Deal and
has the responsibility to hold to account partner organisations in the delivery
of the overall programme.
3.3 This audit reviewed the governance and administrative procedures for
managing the Moray Growth Deal. A check was also made for a sample of
grant claims for projects currently in delivery, including the verification of
expenditure claimed by a partner organization to supporting evidence.
Overall, from the audit undertaken and within the scope of this review,
effective arrangements are in place for the governance and administration of
Item 8.
Page 73

Page 74

the Moray Growth Deal. The audit report for this project is given in Appendix
1.
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.
Author of Report:            Dafydd Lewis, Audit and Risk Manager
Background Papers:       Internal audit files
Ref:                                 SPMAN-2045703626-509 / SPMAN-1042990102-275
Page 74

Page 75

Appendix 1 
1
Final Internal Audit Report 
Moray Growth Deal 
October 2024   
Distribution: Acting Head of Economic Growth & Development 
Moray Growth Deal Programme Manager 
Chief Financial Officer 
Senior Communications Officer 
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
(detailed explanation provided in Appendix1). The audit recommendations for this review have
been classified as follows 
Assurance Level
Risk Ratings for
Recommendations 
Priority 1   2     
Substantial Priority 2   3     
Priority 3   2     
Confidentiality and Disclosure Clause 
This report (“Report”) was prepared by the Internal Audit Section of Moray Council. The matters raised in this Report are
only those which came to our attention during our internal audit work. Whilst every care has been taken to ensure that the
information provided in this Report is as accurate as possible, the Moray Council Internal Audit Section has only been able
to base findings on the information and documentation provided and consequently, no complete guarantee can be given
that this Report is necessarily a comprehensive statement of all the weaknesses that exist, or of all the improvements that
may be required. 
This Report was prepared solely for the use and benefit of the Moray Council, Moray Integration Joint Board or the
Grampian Valuation Joint Board. Moray Council's Internal Audit Section accepts no responsibility and disclaims all liability
to any third party who purports to use or rely for any reason whatsoever on the Report, its contents, conclusions, any
extract, reinterpretation, amendment and/or modification. Accordingly, any reliance placed on the Report, its contents,
conclusions, any extract, reinterpretation, amendment and/or modification by any third party is entirely at their own risk. 
Please refer to the Statement of Responsibility in Appendix 2 of this report for further information about
responsibilities, limitations and confidentiality.   
Item 8.
Page 75

Page 76

Appendix 1 
2
Contents 
Page
Moray Growth Deal 
1. Introduction & Scope 3
2. Key Issues  3-4 
Detailed Report 
3. Findings/Recommendations 5-11
4. Management Response 5-12 
Appendices 
1. Audit Terms of Reference and Definitions 
2. Statement of Responsibility 
Page 76

Page 77

Appendix 1 
3
1. Introduction and Audit Scope  
The annual audit plan for 2024/25 provides for a review of the governance and
administrative procedures for the management of the Moray Growth Deal (the
Deal). The Moray Council’s Internal Audit Service will overview the Deal
programme and project activities, but each partner organisation is separately
responsible for allocating internal audit resources for its specific project. 
The Moray Growth Deal is a transformational programme, designed to drive
economic growth across Moray over a ten year period and is supported by
£100 million of investment with £65 million being invested by the UK and
Scottish Governments.  The Deal brings together the UK and Scottish
Governments and Moray Council, together with Partners from across the
public, third sector, and businesses, to work collaboratively in delivering the
Deal's vision for the region.  This year, the Deal entered its fourth year of the
ten year programme with four of the eight approved projects now in the
delivery phase and three of the four having already made grant claim
submissions to draw down funding. At the time of the audit review, the funding
claimed for the Moray Growth Deal amounted to £5.2 million. 
The scope of the audit included a review of the governance and administrative
arrangements surrounding the Moray Growth Deal.  It also considered how
partnership working is operating, the financial management of the Deal and
how success is being measured. 
It is pleasing to report that from the testing undertaken and within the scope
of this review, effective arrangements are in place for the governance and
administration of the Moray Growth Deal. However, the following areas were
identified for management attention:   
The audit was carried out in accordance with Public Sector Internal Audit
Standards (PSIAS). 
2. Key Issues 
• The audit included testing on a sample of grant claims for projects
currently in delivery and the expenditure claimed. The review found that
in relation to one project, not all expenditure claimed had supporting
documentation to evidence the payment. This concerned certain
categories of expenditure relating to salary costs, overheads, travel/
subsistence and software related recharges.
Page 77

Page 78

Appendix 1 
4
• In accordance with the Moray Growth Deal Financial Plan, each Partner
Organisation is separately responsible for allocating internal audit resources
for Moray Growth Deal Activities. It was agreed within a previous audit report
that each Partner Organisation should provide their Annual Audit Plans to the
Moray Council for planned internal audit activity regarding the Moray Growth
Deal. However, this requirement could be further supported with an annual
meeting between the Internal Audit Services of the Council and Partner
Organisation to review previous audits undertaken and to discuss and agree
on the scope of future auditing activities. 
Page 78

Page 79

Appendix 1 
5
Moray Growth Deal- 2024/25 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1. Medium The Communications Protocol was developed by the
Moray Council Communications Team before the
signing of the Deal.  This document sets out an agreed
framework for communication and engagement
protocols for both proactive and reactive activities in
relation to the Moray Growth Deal. The Protocol
details that effective use should be made of My Moray
web and social media sites to ensure members of the
public are kept up to date on Moray Growth Deal news
and developments. The audit appreciates the limited
staff resources, but it was noted that during the audit
period, news releases had not been posted to the My
Moray website and social media postings can be
infrequent. 
Further use should be made to post information
on My Moray website and social media sites to
ensure effective communication of any
developments concerning the Moray Growth
Deal. 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Senior Communications
Officer/ MGD Programme
Manager
Yes 31/12/2024 A lack of dedicated comms and engagement resource was
flagged as a risk before the deal was signed and has continued
to be an issue with ensuring continuous comms activity.
However, information is shared in-line with project comms
plans. Social media posts are shared when there is a relevant
update and appropriate content – best practice is to only share
updates when there is newsworthy content, otherwise
Page 79

Page 80

Appendix 1 
6
engagement rates will be negatively impacted. A publishing
error on the website has now been rectified to ensure all
releases are shared timeously.  
As more projects enter delivery and there is more content
available to share publicly this will be done. Quarterly full deal
public updates will also be introduced. 
Page 80

Page 81

Appendix 1 
7
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
2.   Medium  A Stakeholder Engagement Plan was developed in
2021 to detail the framework for engagement across
all Moray Growth Deal projects with a key objective of
promoting positive benefits for Moray and creating
opportunities for stakeholders to influence the projects
as they develop.  The Plan details the need for regular
review, however it was found there is no evidence of a
formal review of this document. The audit also noted
that the Stakeholder Engagement Plan requires
engagement with targeted audiences to evidence the
success of implementing Moray Growth Deal Projects. 
As more projects enter the delivery phase, it will
become more important to obtain this data to evidence
a success objective in supporting the realisation of
benefits. 
The Stakeholder Engagement Plan should be
reviewed and, if required, updated. 
Engagement should be undertaken with the
targeted audiences for a project to evidence an
established objective of the Moray Growth
Deal.  
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
MGD Programme Manager /
Senior Communications
Officer
Yes 31/03/2025 While engagement has been taking place at the appropriate
stages of project development, the plan needs to be updated
and have partner sign-off.
Analytics, insights and evaluation are included in the comms
tracker and will link to the updated engagement plan. 
Page 81

Page 82

Appendix 1 
8
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
3.   Low  It was noted that a Communications Planner
spreadsheet is used to organise and plan a
communication strategy for all projects.  The audit
noted examples where fields within this spreadsheet
regarding dates and explanatory information had not
been completed. Better use could be made of the
Communications Planner spreadsheet to support the
management of the communication needs of the
Moray Growth Deal more effectively. It was also found
that not all communications related information is
saved on the Moray Growth Deal Sharepoint site.  In
order to ensure consistency, all information concerning
Deal activities should be saved on the Moray Growth
Deal Sharepoint site.  
All fields within the Communications Planner
spreadsheet should be completed to aid the
communication management needs of the
Moray Growth Deal.   
All communications related activities, where
documented, e.g., press releases, should be
saved on the Moray Growth Deal Sharepoint
site. 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Senior Communications
Officer 
Senior Communications
Officer
Yes 
Yes
Implemented 
Implemented 
The tracker has been refined to ensure all fields are relevant
and information has been backdated where necessary to
create a comprehensive record of comms actions undertaken. 
Now that the comms team has full access to the Sharepoint
site, documentation can be kept updated through version
controls. 
Page 82

Page 83

Appendix 1 
9
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
4.   High  The audit reviewed a sample of grant claims for
projects currently being delivered where expenditure
has been claimed from Moray Growth Deal funding. It
was noted that not all spending included in the claims
from a partner organisation could be verified with
supporting evidence.  Invoices/receipts had been
provided for some creditor payments, however, certain
expenditure categories i.e. salary costs, overheads,
travel/ subsistence and software application costs
were not supported by claim forms or system back-up
documentation. 
The audit also checked the type of payments included
within the funding claimed by a partner organisation,
as eligibility for reimbursement can depend on whether
the expenditure is capital or revenue cost. It was noted
that included within the claims are payments for
subsistence, travelling and overheads, which are
generally not considered as capital expenditure.
However, it is appreciated the accounting rules
detailing if expenditure can be capitalised are complex. 
All partner organisations should be informed
that supporting evidence must be provided for
all expenditure claimed from Moray Growth
Deal funding. 
Further to the findings noted within the audit
and discussions with the Chief Financial
Officer, a review of the types of payments
claimed by the partner organisation should be
undertaken to ensure the correct classification
of expenditure. 
Page 83

Page 84

Appendix 1 
10 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Chief Financial Officer 
Chief Financial Officer
Yes 
Yes
Immediate 
31/12/2024
Partners are reminded of the requirement for audit evidence
when claims are submitted and additional scrutiny given to the
project in question 
A review of payment types will be undertaken to ensure
compliance with the European System of Accounts 10 and in
accordance with grant conditions. 
Page 84

Page 85

Appendix 1 
11 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
5.   Medium  Further to an internal audit report issued in 2022, a
recommendation detailed that 'Each Partner
Organisation should provide their Annual Audit Plan to
the Moray Council of planned internal audit activity
regarding Moray Growth Deal activities.  These plans
should then be forwarded to the Audit and Risk
Manager for Review'.  At the time of this review, two
partner organisations internal audit services have
either delivered or are undertaking reviews regarding
the delivery of Moray Growth Deal projects. Copies of
each partner organisations annual audit plans had not
been provided to the Moray Council Internal Audit
Service. However, it is pleasing to note that one of the
partner organisations internal audit services did
forward details of the scope of a review to the
Council’s Audit and Risk Manager, which does provide
some assurance of the audit coverage undertaken of
Moray Growth Deal project delivery. 
Partner organisations' internal audit services
should be reminded to forward copies of their
annual audit plans to the Moray Council
regarding planned internal audit activity of
Moray Growth Deal activities. This will allow the
Moray Council, as the Accountable Body, to be
consulted and contribute to the scope of the
review.
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
MGD Programme Manager /
Senior Auditor
Yes 31/03/2025 At the time of the audit 2 of the 4 Growth Deal projects led by
partners were in delivery, with one having completed an
internal audit at the end of 2023 (the details of which had been
passed to the audit team) and the other project had only
entered delivery in 2024.  
Page 85

Page 86

Appendix 1 
12 
Given different approaches to audit in the partner
organisations, the PMO will work collaboratively with the
Council’s Internal Audit Team to organise an annual meeting
that seeks to: 
- Identify audit activity planned for the year ahead, securing
audit plans ahead of the meeting when Moray Growth Deal
activity is scheduled.  
- Review audit activity undertaken in the previous 12 months
- Share learning and identify cross cutting issues that all
partners should take account of when planning future
activity 
It is expected that the first of these meetings will take place
during Q4 24/25 FY and partners were briefed at the MGD
Board on 26/09/24 of the need to support this.   
Page 86

Page 87

Appendix 1 
13 
Appendix 1 
AUDIT TERMS OF REFERENCE AND DEFINITIONS 
1. Audit Objectives 
1.1 The overall audit objective is to provide an objective independent opinion on
the adequacy and effectiveness of controls / processes.  
1.2 The audit will for each controls / process being considered: 
• Walkthrough the processes to consider the key controls; 
• Conduct sample testing of the identified key controls, and 
•    Report on these accordingly 
1.3 All audit reviews are carried out in accordance with Public Sector Internal
Audit Standards (PSIAS). 
2. Definitions for Auditing Opinions and Findings 
2.1 In order to assist management in using our reports: 
The Internal Auditor will categorise audit assurance opinion according to
their overall assessment of the risk management system, effectiveness of the
controls in place and the level of compliance with these controls and the
action being taken to remedy significant findings or weaknesses. 
Assurance
Level
System and Testing Conclusion
Full The controls tested are being consistently applied
Substantial There is evidence that the level of noncompliance with some of the
controls may put some of the system objectives at risk.
Limited The level of non compliance puts the system objectives at risk.
None Significant non-compliance with basic controls leaves the system
open to error or abuse. 
2.2 Risk ratings for each recommendation is based on the following criteria: 
High Fundamental control weaknesses that require immediate attention
by management to action and mitigate significant exposure to risk
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.
Page 87

Page 88

Appendix 1 
14 
Appendix 2 
STATEMENT OF RESPONSIBILITY   
The responsibility for designing and maintaining a sound system of internal control
to prevent and detect fraud and other irregularities rests with management, with
internal audit providing a service to management to support them to achieve this
objective. The Internal Audit Section will assess the adequacy and effectiveness of
the system of internal control arrangements implemented by management and
perform sample testing on those controls in the period under review with a view to
providing an opinion on the extent to which risks in this area are managed. 
The Internal Audit Section will undertake testing with the objective of detecting
significant control weaknesses. However, the audit approach alone should not be
relied upon to identify all strengths and weaknesses in internal controls nor to find
any fraud or irregularity. Even sound systems of internal control can only provide
reasonable and not absolute assurance and may not be proof against collusive
fraud. 
The matters raised in this report are only those that came to our attention during
the course of the audit review and are not necessarily a comprehensive statement
of all the weaknesses that exist or all improvements that might be made.
Recommendations for improvements should be assessed by management for their
full impact before they are implemented. The performance of the audit review
undertaken should not be taken as a substitute for management’s responsibilities
for the application of sound management practices. 
This report is confidential and must not be disclosed to any third party or
reproduced in whole or in part without the written consent of the Moray Council’s
Audit and Risk Manager. 
Page 88

Page 89

REPORT TO:  AUDIT AND SCRUTINY COMMITTEE ON 20 NOVEMBER 2024
SUBJECT:       INTERNAL AUDIT CHARTER
BY:                    AUDIT AND RISK MANAGER
1. REASON FOR REPORT
1.1 To seek Committee approval for a revised Internal Audit Charter that defines
the purpose, authority, and responsibility of the internal audit activity within the
Council.
1.2 This report is submitted to the Committee in terms of Section III I (2) and (6) of
the Council’s Scheme of Administration relating to the consideration of reports
from the Council’s Internal Auditor and overseeing the independence, objectivity,
performance and conformance to professional standards of Internal Audit.
2. RECOMMENDATION
2.1 The Committee is asked to consider and approve the revised Internal
Audit Charter.
3. BACKGROUND
3.1     The Public Sector Internal Audit Standards (PSIAS) require the purpose,
authority and responsibility of the internal audit activity to be formally defined in
an Internal Audit Charter. The Internal Audit Charter establishes Internal Audit’s
position within the Council; authorises access to records, personnel and physical
properties relevant to the performance of engagements; and defines the scope
of Internal Audit activities.
3.2      The PSIAS was developed by the Chartered Institute of Public Finance and
Accountancy and the Chartered Institute of Internal Auditors and is mandatory
for all providers of internal audit services in the public sector. The standards
include a requirement for an External Quality Assessment (EQA) of internal audit
once every five years and for the findings to be considered at a Council
committee meeting. This was undertaken at the Audit and Scrutiny Committee
meeting on 11 September 2024 (para 10 of minute refers). The overall
conclusion of the external assessment was that Moray Council’s Internal Audit
Service fully conforms with the PSIAS.
Item 9.
Page 89

Page 90

3.3      However, the EQA report included recommendations to update the Audit Charter
to provide greater clarity regarding the Audit and Risk Manager position within
the Council and to detail the separation of duties controls needed between
internal auditing and risk management/ business continuity duties. The revised
Internal Audit Charter has been updated and is provided in Appendix 1.
4. 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
Public sector bodies are required to adopt mandatory standards for
internal audit and these call for the regular review and updating of an
internal audit terms of reference document.
(c) Financial Implications
No implications directly arising from this report.
(d) Risk Implications
Not having a formally agreed charter could mean the role of internal audit
within the council is not clearly defined and understood, and technically is
a non-compliance with the required standards.
(e) Staffing Implications
No implications directly arising from this report.
(f) Property
No implications directly arising from this report.
(g) Equalities/Socio Economic Impact
No implications directly arising from this report.
(h) Climate Change and Biodiversity Impacts
No implications.
(i) Consultations
In accordance with the Public Sector Internal Audit Standards,
consultation of the draft Charter has taken place with the Interim Chief
Executive, Depute Chief Executive (Education, Communities &
Organisational Development), Chief Financial Officer and the Head of
Governance, Strategy & Performance and any comments incorporated
into this report.
5.         CONCLUSION
5.1 The Committee is asked to consider and approve the revised Charter
document for internal audit to ensure ongoing compliance with
recognised auditing standards.
Page 90

Page 91

Author of Report:
Background Papers:
Dafydd Lewis
Internal Audit files
Audit and Risk Manager
Ref: DL/ASC/101124
SPMAN-2045703626-498
SPMAN-2045703626-499
Page 91

Page 92

Page 92

Page 93

APPENDIX 1
Governance, Strategy and
Performance
Internal Audit Charter
Author: Audit and Risk Manager   
Date for review: May 2029
Item 9.
Page 93

Page 94

1. Introduction
1.1 The Local Authority Accounts (Scotland) Regulations 2014 introduced a
requirement for all Scottish Local Authorities to operate a professional and
objective internal auditing service, which must be delivered in accordance
with recognised standards. The standards and practices applied in the UK
for all public sector internal audit providers, in-house, shared or
outsourced, are the Public Sector Internal Audit Standards (PSIAS), which
came into effect in April 2013, and were updated in March 2017. These
standards are largely based on the International Professional Practices
Framework (IPPF). A requirement of the PSIAS is that all local authorities
should have an Internal Audit Charter.
2. Definition and Purpose of Internal Auditing
2.1 The overarching “mission” of an Internal Audit Service is to enhance and
protect organisational value by providing risk-based and objective
assurance, advice and insight. Internal Auditing is defined in the PSIAS as
‘an independent, objective, assurance and consultancy activity designed
to add value and improve an organisation’s operations. Internal Audit adds
value to the organisation (and its stakeholders) by enhancing governance,
risk management and internal control and objectively providing
assurance.
2.2 As part of the meeting Moray Council’s system of corporate governance,
Internal Audit’s purpose is to support the Council in its activities designed
to achieve its declared objectives and to do so:
 In support of the Council’s vision, values and priority.
 As a contribution to the Council’s management of risks, including
assisting management to improve the risk identification and
management process in particular where there is exposure to
significant regulatory, financial, strategic, reputational and operational
risk to the achievement of the Council’s objectives.
 As an aid to ensuring that the Council and its elected members,
employees and contracted third parties are operating within the law
and relevant regulations and that public money is safeguarded and
properly accounted for, and used economically, efficiently and
effectively.
 As a contribution towards establishing and maintaining a culture of
honesty, integrity, openness, accountability and transparency
throughout the Council in all its activities and transaction.
 As a contribution towards ensuring that financial statements and other
published performance information are accurate and reliable.
Page 94

Page 95

2.3 Moray Council also provides an internal audit service to Moray Integration
Joint Board (MIJB) and the Grampian Valuation Joint Board (GVJB). It will
apply the same standards as defined in this Charter to any work
undertaken for the MIJB and the GVJB, with separate Internal Audit plans
and reports presented to their respective ‘senior management’ and ‘board’.
3. POSITION OF INTERNAL AUDIT WITHIN THE ORGANISATION
3.1 The Internal Audit Service is managed by the Audit and Risk Manager. The
Audit and Risk Manager will report functionally to the Audit and Scrutiny
Committee and administratively (i.e., day-to-day operations) to the Head of
Governance, Strategy and Performance (the Council’s Monitoring Officer).
The Audit and Risk Manager will have access to the Chief Executive, to all
Council officers and to the elected members in connection with any
relevant matter
3.2 The Audit and Risk Manager will also have unrestricted access to, and
communicate and interact directly with any Council Committee, including
in private meetings without management present.
3.3 The Audit and Scrutiny Committee is charged with responsibility for
ensuring good stewardship of the Council’s resources, enhancing the
profile, status and authority of Internal Audit and affirming its
independence. Specifically, in relation to audit matters, the committee:
 Contributes to making the Council, its committees and services more
responsive to the audit function and its purpose;
 Enhances good governance arrangements by promoting internal
control and risk management by supporting an anti-fraud culture, and
by the review of revisions to financial procedures;
 Has responsibility for focusing audit resources through agreeing to an
annual programme of work;
 Monitors delivery of the audit service through receipt of quarterly
reports on work carried out by Internal Audit;
 Considers the annual opinion provided by the Audit and Risk Manager
on the adequacy and effectiveness of the control environment.
4. ORGANISATIONAL STATUS AND INDEPENDENCE
4.1 In terms of the PSIAS, the status of Internal Audit should enable it to
function effectively, with recognition of the independence of Internal Audit
that is fundamental to its effectiveness. Moray Council’s financial
regulations detail that the Depute Chief Executive (Education,
Communities and Organisational Development) is responsible for securing
a continuous Internal Audit service to provide an independent and
objective opinion on the control environment comprising risk management,
internal control and governance. This remit is delegated to the Audit and
Risk Manager.
4.2 Internal Audit will systematically review, appraise, make appropriate
recommendations for improvement, and report upon:
Page 95

Page 96

 The efficacy of governance arrangements put in place to achieve the
organisation’s objectives and priorities.
 The effectiveness of all internal controls and other arrangements put in
place to manage risk, in particular where there is exposure to
significant financial, strategic, reputational and operational risk to the
achievement of the organisation’s objectives.
 The completeness, reliability and integrity of information, both financial
and operational performance, including working alongside services in
a ‘critical friend’ role to authenticate any self-assessment evidence of
service performance and improvement.
 The systems formed to ensure compliance with policies, plans,
procedures, laws and regulations whether established by the
organisation or externally.
 The effectiveness of arrangements for safeguarding the organisation’s
assets and interests, including fraud prevention controls and detection
processes.
 The economy, efficiency and effectiveness with which resources are
deployed.
 The extent to which services’ operational practices are being carried
out as planned and objectives and goals are met.
4.3 Internal Audit’s work covers:
 All activities, systems, processes, policies and protocols that currently
exist or under development.
 All records, personnel and properties.
 All services and other activities for which the organisation is
responsible or accountable, whether delivered directly or by third
parties through contracts, partnerships or other arrangements. 
Where the Audit and Risk Manager has or is expected to have roles
and/or responsibilities that fall outside of Internal Auditing, safeguards will
be established to limit impairments to independence or objectivity.
5. RIGHTS OF ACCESS
5.1 The Audit and Risk Manager and any member of the Internal Audit service
are authorised in the performance of an audit engagement and have the
authority to:
 Have access at any reasonable time to all computer systems and
records (both paper and electronic).
Page 96

Page 97

 Require and receive explanations concerning any matter under
examination from personnel relevant to their roles, including elected
members or board members
 Enter at all reasonable times and without notice any properties provided
that the terms of the lease are observed where such properties are
leased to a third party.
 Require personnel to produce cash, stores, or other assets under their
control.
5.2 Internal Audit safeguards all information obtained in the carrying out its
duties, only uses it for defined purposes, and makes no disclosure of any
information held, unless this is authorised or there is a legal/professional
requirement to do so.
6. AUDIT RESOURCES AND WORK PRIORITISATION
6.1 The Moray Council’s Internal Audit Annual Plan, as approved by the Audit
and Scrutiny Committee, is the primary determinant of the relative priority
to be placed on each part of the work of Internal Audit, with Internal Audit
Annual Plans specific to the MIJB and the GVJB being approved and
monitored by their respective ‘senior management’ and ‘board’. The audit
planning process, to determine the priorities of the Internal Audit activity
consistent with the organisation’s goals, includes consideration of the
organisation’s priorities, plans, strategies, objectives, risks and mitigating
controls, and the internal and external assurances provided. The Audit and
Risk Manager determines the actual deployment of available resources
covering the range and breadth of audit activity, which is integral to the
assurance process across the activities of the Council, MIJB and GVJB in
order to provide the statutory annual Internal Audit opinion to each
organisation’s ‘senior management’ and ‘board’. This plan also requires to
be sufficiently flexible to reflect the changing risks and priorities of each
organisation.
6.2 The Audit and Risk Manager ensures that Internal Audit resources are
appropriate, sufficient and effectively deployed to achieve the approved
plan. Appropriate refers to the mix of qualifications, knowledge, skills and
other competencies needed to perform the plan, such as compliance with
the Code of Ethics set out in the PSIAS and with the Nolan principles
established in the Seven Principles of Public Life. This is of particular
importance and relevance for the profession of Internal Audit, founded as it
is on the trust placed in its objective assurance about risk management,
internal control and governance. 
6.3 In the event that there is a need for additional audit work than there are
resources available, the Audit and Risk Manager will identify the shortfall in
the Plan and initially advise the Head of Governance, Strategy and
Performance the Depute Chief Executive (Education, Communities and
Organisational Development) followed by the Audit and Scrutiny
Committee as required. It will be for the Audit and Scrutiny Committee to
decide whether to accept the risks associated with the non-delivery of such
audit work or to recommend to the Council that it requires Management to
identify additional resources.
Page 97

Page 98

6.4 Internal Audit responsibilities are not relieved in areas of the Council’s
work that are subject to review by others, but reliance is placed on the work
of other review agencies, principally the Council’s External Auditor, to
avoid duplication, make the best use of resources and inform the overall
assessment of governance arrangements.
7. MANAGEMENT RESPONSIBILITIES
7.1 Responsibility for internal control rests with Management, who must
ensure that proper internal control arrangements are in place. Internal
Audit’s role is to evaluate the effectiveness of such internal control
arrangements. Management is responsible for accepting and
implementing audit recommendations and bears any risk from not taking
agreed action. Internal Audit is not a substitute for an effective system of
internal control implemented by management.
8. COUNTER FRAUD WORK
8.1 The prevention and detection of fraud is a management function and
management is responsible for implementing and maintaining suitable
systems of control to mitigate the risk of fraudulent activity. In support of
the Council's counter fraud arrangement, the Audit and Risk Manager will
consider including a project within the Annual Audit Plan to review
systems or practices where irregularities or fraud have been reported
within other Local Authorities. Internal audit also supports the Council’s
commitment to fraud prevention and detection by overseeing data
matching exercises carried out under the National Fraud Initiative. The
Council takes the threat of fraud or related malpractice seriously and has
adopted a Policy to Combat Fraud, Theft, Bribery and Corruption. In
addition, a Whistle-blowing Policy has been developed in consultation
with the Human Resources service to facilitate the reporting of any
concerns.
8.2 The Financial Regulations provide that whenever any matter arises which
involves, or is thought to involve, irregularities concerning cash, stores or
other property of the Council or any suspected irregularity in the exercise
of the functions of the Council, any Officer having knowledge thereof,
shall, as soon as possible, notify Internal Audit.
9. OBJECTIVITY AND CONFLICTS OF INTEREST
9.1 The Council’s Code of Conduct for Employees sets out the required
standards for the conduct of all employees and includes provisions for the
declarations of interests, gifts and hospitality.
9.2 The Internal Audit service preserves its independence and objectivity by
ensuring that: staff are free from any conflicts of interest when undertaking
assurance audits by following the requirements of relevant professional
bodies and HR policies; and by providing clarity on duties undertaken
during audit consultancy engagements to ensure these do not impact on
Page 98

Page 99

assurance audits and do not impair its independence and objectivity.
9.3 The Audit and Risk Manager has managerial responsibility for the
corporate functions and resources, which develop, support and advise on
the frameworks in place within the Council on Risk Management, Business
Continuity and on Counter Fraud to support Management. In order to
prevent a perceived impairment of objectivity and to ensure that Internal
Audit independence and impartiality are maintained and demonstrated, no
Internal Audit resources will be used in the performance of these functions.
10. OTHER PARTIES OUTWITH THE COUNCIL
10.1 The Council’s Audit and Risk Manager is also the Chief Internal Auditor
for the Moray Integration Joint Board and the Internal Auditor for the
Grampian Valuation Joint Board. While separate and distinct governance
arrangements apply to these bodies, the principles outlined in this Charter
apply and are adopted in respect of all work completed by Internal Audit.
11. REVIEW
11.1 The PSIAS requires that the chief audit executive periodically reviews the
Internal Audit Charter and presents it to senior management and also to
the Board for approval. In this context, the chief audit executive is the
Audit and Risk Manager, senior management is the Corporate
Management Team, and the Board is the Audit and Scrutiny Committee.
Dafydd Lewis
Audit and Risk Manager
September 2024
Page 99

Page 100

Page 100