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Agenda Document Pack - Audit and Scrutiny Committee - 07/05/2025

Moray Council · 7 May 2025
Back to Audit and Scrutiny Committee — 7 May 2025 and its agenda

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Audit and Scrutiny Committee 
Wednesday, 07 May 2025 
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, 07 May 2025 at 09:30. 
BUSINESS 
1. Sederunt 
2. Declaration of Group Decisions and Members Interests * 
3. Minute of meeting of 12 February 2025 5 - 12
4. Written Questions ** 
5. Internal Audit Section Update Report
Report by Audit and Risk Manager
13 - 60
6. Internal Audit Review - Special Investigation - Building
Services - Windows Replacement Programme
Report by Audit and Risk Manager
61 - 80
7. The National Fraud Initiative in Scotland
Report by Audit and Risk Manager
81 - 90
8. Annual Audit Plan for the Year Ending 31 March 2025
Report by Depute Chief Executive (Economy, Environment and Finance)
91 -
188
9. Local Government Benchmarking Framework 2023-24
Results
Report by Depute Chief Executive (Education, Communities and
Organisational Development)
189 -
212 
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Summary of Audit and Scrutiny Committee functions:
Audit Functions - Consider reports from the Council's internal auditor &
Audit Scotland concerning Council Functions.
Scrutiny Functions - Scrutinising the policies of the Council and their
effectiveness in meeting the action plans of the Council as set out in the
Corporate Development Plan and evaluating the actions of Committees
in implementing the action plans set out in the Corporate Development
Plan.
Performance Monitoring - To receive reports on the performance of and
trends within all of the Council’s services in terms of service standards
and performance information.
Standards - To ensure that the highest standards of probity and public
accountability are demonstrated.     
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 attend
in person, please come to the High Street entrance door and a
member of staff will let you into the Chamber. 
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GUIDANCE NOTES 
* Declaration of Group Decisions and Members Interests - The Chair of the
meeting shall seek declarations from any individual or political group at the
beginning of a meeting whether any prior decision has been reached on how the
individual or members of the group will vote on any item(s) of business on the
Agenda, and if so on which item(s).  A prior decision shall be one that the
individual or the group deems to be mandatory on the individual or the group
members such that the individual or the group members will be subject to
sanctions should they not vote in accordance with the prior decision.  Any such
prior decisions will be recorded in the Minute of the meeting. 
** Written Questions - Any Member can put one written question about any relevant
and competent business within the specified remits not already on the agenda, to
the Chair provided it is received by the Proper Officer or Committee Services by 12
noon two working days prior to the day of the meeting.  A copy of any written
answer provided by the Chair will be 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. 
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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 Marc Macrae  (Member)
Councillor Paul McBain  (Member)
Councillor Neil McLennan  (Member)
Councillor John Stuart  (Member)
Councillor Sonya Warren  (Member)  
Mr Ivan Augustus  (Non-Voting Member)
Ms Margaret Wilson  (Non-Voting Member)
Clerk Name: Caroline O'Connor
Clerk Telephone: 07779 999296
Clerk Email: committee.services@moray.gov.uk 
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MORAY COUNCIL 
Minute of Meeting of the Audit and Scrutiny Committee 
Wednesday, 12 February 2025 
Council Chambers, Council Office, High Street, Elgin, IV30 1BX 
PRESENT 
Mr Ivan Augustus, Councillor Peter Bloomfield, Councillor Tracy Colyer, Councillor
Theresa Coull, Councillor John Divers, Councillor Jérémie Fernandes, Councillor
Donald Gatt, Councillor David Gordon, Councillor Sandy Keith, Councillor Elaine
Kirby, Councillor Scott Lawrence, Councillor Marc Macrae, Councillor Shona
Morrison, Councillor John Stuart, Ms Margaret Wilson 
APOLOGIES 
Councillor Neil McLennan 
IN ATTENDANCE 
Interim Chief Executive; Depute Chief Executive (Education, Communities and
Organisational Development); Depute Chief Executive (Economy, Environment
and Finance); Audit and Risk Manager; Head of Governance, Strategy and
Performance; Head of Financial Services; Head of Housing and Property Services;
Housing Services Manager and Caroline O'Connor, Committee Services Officer,
all Moray Council and Angela Pieri, Grant Thornton - External Auditors. 
1.         Chair 
Councillor Lawrence, as Chair of Audit and Scrutiny Committee, chaired the
meeting.  
2.         Declaration of Group Decisions and Members Interests * 
In terms of Standing Orders 21 and 23 and the Councillors' Code of Conduct, there
were no declarations from Group Leaders or Spokespersons in regard to any prior
decisions taken on how Members will vote on any item on the agenda or any
declarations of Member's interests in respect of any item on the agenda.  
With regard to Item 10 "Internal Audit Plan Year Ending 31 March 2026",
Councillor Gatt stated, for transparency, that he is Convener of the Grampian
Valuation Joint Board and would be taking part in the debate.  
Mr Augustus stated, for transparency, that he was carer representative on the
Moray Integration Joint Board and would be taking part in the debate. 
3.         Resolution 
The Chair sought agreement from the Council 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
ground that it involves the likely disclosure of exempt information of the class.
Item 3.
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Councillor Keith sought to move Item 11 on the agenda into the open session of
the agenda given the unusual level of public interest in how the Council arrived at
its decision to enforce the collection of non-domestic rates liability and on the
balance of harms, it was in the public interest to deal with the matter in
public.  This was seconded by Councillor Stuart.  
The Chair sought clarification from the Monitoring Officer on Item 11 on the
agenda.  
In response, the Monitoring Officer confirmed that in terms of legislation it is for
members to decide on where to discuss items on the agenda based on advice
from Officers.  He further added that the advice on Item 11 is that, as the report
refers to the tolerances for rates enforcement which could prejudice the Council's
ability to enforce for other properties, the report should be heard in the confidential
section.  This would allow for more candid discussion and following the meeting
today, while the Chair would hold authority to grant publicity rights on the
information contained in the report, there would still be sensitivity around some of
the details to be publicly shared.    
The Chair confirmed he was in favour of the report being head in the confidential
section to allow more robust discussion following the advice of the Monitoring
Officer and was in agreement with providing a public statement following the
meeting sharing as much information within the constraints highlighted.  
As an amendment Councillor Macrae moved the Resolution as there remained
questions from the report which answers would not be forthcoming in a public
session and would require to be the subject of further external investigation.  
In response, the Monitoring Officer confirmed the report was being held
confidentiality due to it containing information relating to the financial of business
affairs of any particular person(s) and whilst the issues raised by Councillor
Macrae would be a knock-on effect, the primary reason for holding the report in the
confidential session must be related to one of the paragraphs in the exemption
information schedule in the Resolution.   
Following the advice from the Monitoring Officer, Councillor Macrae reworded his
amendment to move the Resolution to discuss the report in the confidential section
as should the report be discussed in public, it may prejudice any future potential
external investigation.  This was seconded by Councillor Gatt. 
On a division there voted:- 
For the Motion (5) Councillors Keith, Stuart, Divers, Fernandes, Morrison 
For the Amendment (8) Councillors Macrae, Gatt, Bloomfield, Colyer, Coull,
Gordon, Kirby, Lawrence 
Abstentions (0) 
Accordingly the Amendment became the finding of the meeting and the Committee
agreed to consider Item 11 in the confidential section of the agenda.  
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
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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
11
Para 6
Information relating to the financial or business affairs
of any particular person(s) 
4.         Written Questions ** 
The Committee noted that no written questions had been submitted.  
5.         Minutes of meeting of 20 November 2024 
The minutes of the Audit and Scrutiny Committee on 20 November 2024 had been
submitted.  
The Chair advised Councillor McLennan had submitted a number of amendments
relating to Paragraph 6 of the Minute "Internal Audit Section Update Report" which
he was happy to accept if the Committee were minded to do so, namely:- 
1. Para 6, seventh paragraph, third line - after "sought a seconder", add new
sentence "The Chair said Councillor McLennan could seek a seconder or
speak to him after the meeting." 
2. Para 6, seventh paragraph, sixth line - after "added to the Audit Plan", add
"The Audit and Risk Manager asked Councillor McLennan what was to be
added. Councillor McLennan said the circumstances of circa £860k being
paid out to be investigated to ensure it met Best Value and compliance
through appropriate processes". 
3. Para 6, seventh paragraph, tenth line - replace "thanked the Interim Chief
Social Work Officer for the reassurance provided regarding the progress
being made and confirmed he was happy to discuss scrutiny of the case with
the Chair and Interim Chief Social Work Officer following the meeting."
with "thanked the Interim Chief Social Work Officer for the correspondence
provided regarding the progress being made and confirmed he was happy. to
discuss scrutiny of the case offline." 
4. Para 6, between seventh and eighth paragraphs - add two new paragraphs
- "Cllr Gordon tabled a Point of Order, citing SO 29, but this was not pursued
by the Chair."  followed by "Ms Wilson then asked if any similar cases were
in the pipeline.  The Interim Chief Social Work Officer confirmed not that he
was aware of.  However there was one case that was bubbling away but no
sign of that going through a court process any time soon."  
Subject to the above amendments, the Committee unanimously agreed the minute
of the meeting.   
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.  
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In response to a question from Councillor Coull asking if there was any update on
the recruitment challenges detailed in paragraph 4.2, the Audit and Risk Manager
advised following the unsuccessful recruitment of an Assistant Auditor and in order
to meet the requirements of the Public Sector and Internal Audit Standards, having
reviewed within the budget, an Auditor position on a part time basis had been
advertised which he hoped would address some of the resource concerns.  
As a follow-up question, Councillor Gatt asked if the Audit and Risk Manager could
provide Committee with assurance that there were enough staff resources and
budget to carry out the audit role to the standard required.  In response, the Audit
and Risk Manager explained he had raised concerns regarding resources
previously as part of the Public Sector Internal Audit Standards requirements and it
was also an issue raised by as part of the external quality assessment from
another Chief Internal Auditor.  He advised the resources also cover the auditing
requirements of the Moray Growth Deal, the Moray Integration Joint Board and the
Levelling Up Fund and he was concerned that the level of resources is soon
reaching a critical point in whether it can meet the demands on the service. 
The Interim Chief Executive advised he had been in dialogue with the Audit and
Risk Manager on the issues and had responded formally to advise the matter
would be addressed as part of phase 2 corporate management structure and had
also discussed with the new permanent Chief Executive who was mindful of the
issues raised.    
Following consideration the Committee unanimously agreed to note the report. 
7.         Internal Audit Review - Out of Area Placements 
The meeting had before it a report by the Audit and Risk Manager advising the
Committee on an internal review completed for the period from 20 November 2025
to 12 February 2025.  
On the invitation of the Chair, Councillor Mustard, in relation to Recommendation 4
in Appendix 1 regarding determination of the ordinary residence, sought
clarification on the circumstances which it would be necessary to escalate
determination of an individual and ensure any actions are taken in conjunction and
agreement with the individual and their families.  
The Audit and Risk Manager advised a number of criteria requires to be taken into
consideration however within the report the reference is to review care delivery
and care packages to the meet the needs of the individual with responsibility for
the cost to either remain with the Council or move to the new council where the
individual resides.  
In response to a question from Mr Augustus asking why financial monitoring had
not taken place, the Audit and Risk Manager confirmed monitoring was taking
placing, however the audit recommended further development on the monitoring
requirement in taking out of area costs from larger budgets to consider them within
a more defined budget.   
With reference to Recommendation 3 in Appendix 1, Councillor Stuart, noting that
some of the issues contained in the report had been highlighted in previous adult
social care commissioning reports, asked for confirmation that the timescale for
implementation date accepted by the service for all placements to receive interim
Service Level Agreements or contracts was 30 June 2026 as noted.  In response,
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the Audit and Risk Manager advised the follow up review of adult social care and
commissioning of contracts with external care providers was included in Internal
Audit Plan for next year and confirmation will be sought regarding the
implementation date of recommendations.  
As a follow-up, Councillor Stuart expressed concern at the implementation date
given the financial factor given the substantial amounts of money involved and, in
respect of best value in terms of outcomes and experiences for individuals, would
have hoped this could have been implemented earlier.  In response, the Audit and
Risk Manager advised, with no one from the service in attendance to confirm, he
expected implementation recommendations to be undertaken sooner rather than
later.  The Interim Chief Executive further confirmed he would discuss with the
Chief Officer the possibility of an earlier implementation date.    
Councillor Colyer, appreciating the financial position of the Moray Integration Joint
Board (MIJB), asked for individuals coming into Moray with expensive care
packages whether there is a limit that can be set for a care package or if it is set in
statute that the full package requires to be funded.  In response, the Audit and Risk
Manager advised the question would require a response from the service however
it was his understanding that it would depend on the care requirement of the
individual.  
Councillor Gatt expressed concern regarding how the situation had occurred as
monitoring out of area expenditure should be automatic given the level of
expenditure involved and what actions could be taken to resolve it. 
The Chair made reference to the Care First system being overdue for replacement
and asked whether the replacement would assist implementation of some of the
recommendations.  In response, the Audit and Risk Manager confirmed the
delayed replacement of Care First was concerning as it was the primary recording
database within the service and from an audit perspective, in terms of the
sensitivity of the information held within it, there was a need to progress with an
updated system.  He confirmed as the Auditor, he was required to provide an
annual opinion on the control and governance arrangements of the MIJB and
would be considering between this meeting and June the audit work that has been
done, recommendations that have been implemented, not implemented,
developments still to be done and whether there was a need to limit his annual
opinion and raise concerns with this Committee.  
Councillor Coull stated it was positive the recommendations were accepted by the
Chief Officer and asked whether there was any follow-up given that the timescale
for implementation of 31 January 2025 in Recommendation 2 on Appendix 1 had
now passed.  In response the Audit and Risk Manager confirmed a follow-up
review of the entire audit would commence after the last recommendation date had
passed to evidence whether recommendations were being implemented which
would be reported back to this Committee.      
Following on from concerns raised by members of the Committee, Councillor Keith
stated the Committee had limited assurance given the wording used in the report
and high risk identified and suggested it would have been beneficial if an officer
from the service had attended the meeting to answer questions from the
Committee.  In relation to Recommendation 6 of Appendix 1, Councillor Keith
noted the timescale for implementation for reviewing Care and Support Plans was
31 December 2025, and he would have liked to ask someone from the service
what is involved in reviewing a Support Plan and understand why it would take so
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long to implement this recommendation.  In response the Interim Chief Executive
agreed he would have expected an officer from the MIJB to be in attendance at the
meeting and, while expressing concern about a number of historical issues and
capacity, he would discuss the concerns and issues raised including a review of
the timescales proposed in the audit report with the Chief Officer.  He confirmed he
would provide Committee members with a note to provide assurance that the
issues raised would be moved forward appropriately. 
Councillor Stuart welcome the assurance provided by the Interim Chief Executive
and asked the Monitoring Officer whether it was within the remit of Committee to
propose an amendment to have the timescale formally reviewed and reported back
at an earlier date if the Committee felt the recommendations in the audit report
were not strong enough.  In response, the Monitoring Officer that the
recommendations in the audit report would be followed up as part of the follow-up
review undertaken by the auditor within the timescales agreed with the service
however if Committee become frustrated at a lack of progress in relation to
actions, it may be appropriate at that stage for this Committee to discuss with the
appropriate bodies, namely MIJB.  The Audit and Risk Manager confirmed until
such time as the follow-up review is reported back, in other similar cases the
service have provided progress update reports to this Committee to provide some
assurance of progress in the implementation of the recommendations.  The Interim
Chief Executive, whilst having given commitment to seek a review, confirmed he
could see no reason why the Committee could not challenge a date and ask for a
particular deadline to be reviewed, however it would be entirely inappropriate for
Committee to set a date as there required to be dialogue with officers through
support and challenge to review any implementation dates. 
In response to a question from Councillor Kirby asking if it was possible for the
follow-up review to take place before the last timescale for implementation date,
the Audit and Risk Manager advised it would not be possible due to resources and
audits to undertaken within the Action Plan. 
Councillor Colyer asked how the Interim Chief Executive proposed to share the
information with the Committee following discussions with the Chief Officer.  In
response the Interim Chief Executive confirmed he would either speak with or write
to the MIJB Chief Officer with a view to getting a written response back to
members as soon as practicable.  
Following lengthy consideration, and with the assurance from the Interim Chief
Executive to provide a written response to Committee following discussions with
the Chief Officer, the Committee unanimously agreed to note the report.  
8.         Internal Audit Review - Treasury Management 
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 20 November
2024 to 12 February 2025.  
Following consideration the Committee unanimously agreed to note the report.  
9.         Internal Audit Review - Housing Rents Collection and Arrears
Management 
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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 20 November
2024 to 12 February 2025.  
In relation to Recommendation 1 of Appendix 1 and noting that the Rent Arrears
Policy had not been reviewed since its introduction in 2013, Councillor Gatt noted
there was a recurring theme in terms of policies not being reviewed for a
considerable time and suggested introduction of a corporate policy register to
avoid repetition of policies not being reviewed for considerable periods of time.  In
response the Head of Housing and Property Services acknowledged the slippage
due to resource however confirmed a resource was assigned to review the policy
as part of this years’ service plan and other housing related policies would be
reviewed on a similar basis.  
Following consideration the Committee unanimously agreed to note the report.  
10.         Internal Audit Plan Year Ending 31 March 2026 
The meeting had before it a report by the Audit and Risk Manager providing the
Committee with details of the planned internal audit covering for the year ending
31 March 2026.  
With reference to paragraph 8.2 of Appendix 1 relating to Council Fraud Work,
Councillor Macrae asked if the internal auditor has ever been notified of any such
matters such as collecting non-domestic rates. In response the Audit and Risk
Manager confirmed previously if there is a suspicion of an irregularity or fraud, he
should be informed and would then review any such notifications in terms of any
further investigations to be taken and any potential referral to Police Scotland.  
On the invitation of the Chair, Ms Pieri provided an update on the progress of the
external audit plan confirming the draft plan would be issued in the next few weeks
and would be reported to the next meeting of this Committee in May.  
Following consideration the Committee unanimously agreed to note the proposed
internal audit coverage for the 2025/26 financial year.  
11.         Internal Audit Review - St Giles Shopping Centre - Non-Domestic
Rates [Para 6] 
The meeting had before it a report advising Committee on an internal audit review
completed for the period from 20 November 2024 to 12 February 2025.  
Councillor Gatt welcomed the internal audit recommendations contained in the
audit report and, in order to highlight the importance of the audit recommendations
being progressed, moved to change the wording of the recommendation in the
report replacing the word "note" with "endorse".  This was seconded by Councillor
Lawrence.  
Following consideration and there being no one otherwise minded, the Committee
unanimously agreed to endorse the report. 
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Report to: Audit and Scrutiny
Committee
Meeting Date: 7 May 2025     
Report by: Audit and Risk Manager Report No: GSP007/25/DL  
Author: Dafydd Lewis Contact Email: dafydd.lewis@moray.gov.uk 
Subject: Internal Audit Section Update Report 
1. PURPOSE 
☒ For Decision      ☐  For Information 
1.1 The purpose of this report is to consider 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. SUMMARY  
2.1 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.  
2.2 This report provides an update on audit activity and projects progressed since the last
meeting. 
3. RECOMMENDATIONS  
3.1 It is recommended that Committee:   
i) Considers and notes the contents of this report, seek clarification on any
points.   
Dafydd Lewis
Audit and Risk Manager 
4. BACKGROUND AND CONTEXT  
Item 5.
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Internal Audit Plan Update
4.1 The Audit Plan is a means of determining the priorities of the internal audit activity and how
these align with the broader goals of the Council.  Enclosed in Appendix 1 is an update on
the progress made by the Internal Audit Section in completing audit review projects in
accordance with the Annual Audit Plan. As detailed to this Committee on 12 February 2025
(refer to paragraph 6 of the minutes), there has been a requirement to carry forward the
reviews of absence management and payroll payment testing to the 2025/26 Internal Audit
Plan.   
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: 
Domestic Refuse
4.3 This follow-up review examined the implementation of recommendations made in a
previous review of systems and procedures related to the collection of domestic waste. The
audit also assessed the procedures for disposing of recyclable waste. Moray Council
collects refuse from approximately 46,000 domestic properties at an annual cost of £3.5
million. A previous follow-up review was reported to this Committee on 25 June 2024
(paragraph 7 of the minutes refers). It was noted that one recommendation remained
outstanding due to the Scottish Government’s delay in introducing the national Deposit
Return Scheme, now scheduled for October 2027. It was agreed that another audit review
on this subject would be included in a future audit plan to assess implementation. However,
one recommendation concerning the formalisation of arrangements for recycling
aluminium and steel cans included a revised implementation date of 10 February 2025. I
am pleased to report that a dry mixed recyclates contract, including can recycling, has been
awarded. 
Foster and Kinship Care Payments
4.4 A follow-up review was undertaken to assess the implementation of recommendations from
a previous audit of the administrative arrangements for fostering and kinship care
payments. The reporting template for this review follows a new format, developed in
consultation with the Audit Management Software Supplier. This format aims to enhance
understanding and transparency in reporting the findings and tracking the implementation
of recommendations by services. There will be a transition period between the previous and
current reporting formats.  
4.5 The audit reviewed the processing of fostering and kinship payments, ensuring that 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 identified, particularly regarding the recording of information and the introduction of
additional verification checks to confirm eligibility for ongoing kinship allowance payments.
The follow-up review found that the implementation of recommendations had progressed,
but further checks were required to verify the educational status of individuals residing
outside Moray. The Follow-Up Report reviewing the implementation of the agreed
recommendations is provided in Appendix 2.
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Self Directed Support (SDS)
4.6 An audit was previously conducted on the financial monitoring arrangements within the
SDS Team for direct payments made to individuals receiving adult social care services. The
audit assessed the effectiveness of procedures for monitoring funds issued to service
users. This involved randomly selecting a sample of care packages and verifying
compliance with operating procedures, ensuring that service user expenditures aligned with
agreed budgets and support plans, and confirming that surplus funds were recovered where
appropriate.  
4.7 The Follow-Up Report, reviewing the implementation of the audit's agreed
recommendations, is provided in Appendix 3. Significant progress has been made by the
Service in implementing these recommendations. While workload and staffing concerns
are acknowledged, several recommendations remain only partially implemented. This is the
third follow-up review conducted by the Internal Audit Section for this audit. The Service has
indicated that all recommendations should be fully implemented during 2025/26. It is
proposed that no further follow-up review be conducted; however, an audit of Self-Directed
Support for direct payments will be included in a future Internal Audit Plan.   
Keith Sports and Community Centre 
4.8 This follow-up review assessed the implementation of recommendations from an audit of
Keith Sports and Community Centre. The audit evaluated the effectiveness of internal
controls related to income and expenditure. It also included a review of the income
collection and monitoring arrangements for the FitLife? membership scheme. Additionally,
the audit examined whether the processing of debit and credit card transactions complies
with the Payment Card Industry Data Security Standard. The follow-up review noted the
implementation of recommendations contained within the audit report, with the Service
undertaking significant action in the recovery of outstanding FitLife?  membership fees due
to the Council. The Follow-Up Report reviewing the implementation of the agreed
recommendations is provided in Appendix 4.   
Building Services - Planned Maintenance Projects
4.9 This follow-up review examined the implementation of recommendations made in a
previous audit of Planned Maintenance Projects undertaken by Building Services. The audit
undertook an overview of how the annual planned maintenance programme is determined
and the contract management arrangements for individual projects within Building
Services. Additional testing was also conducted on the systems for managing and
controlling overtime payments to officers. The follow-up review was delayed to align with a
responsive repairs audit to minimise further operational disruptions within Building
Services. It was found that good progress has been made in implementing the
recommendations. However, further development is still required to ensure greater
transparency in the rates used, as well as in the accounting arrangements for determining
budgets and recovering the costs of planned maintenance work. The Follow-Up Report,
which evaluates the implementation of the agreed recommendations, is provided in
Appendix 5. 
5. PROPOSALS  
5.1 It is recommended that Committee agree to note the progress made by Internal Audit in the
period from 12 February 2025 to 7 May 2025.
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6. SUMMARY OF IMPLICATIONS  
6.1 The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan)  ×
Policy and Legal  ×
Financial  ×
Risk × 
Staffing  ×
Best Value and Transformation × 
Property  ×
Information Communications Technology/Digital             ×
Equalities. Social Inclusion and Economic Impact   ×
Climate Change, Biodiversity and Sustainability  × 
6.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute to
improved outcomes for communities as outlined in the following Council Plan strategic
priorities:
☐ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☐ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support and
contribute to improved outcomes for communities as outlined in the following local
Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population 
6.3 Policy and Legal 
No implications directly arising from this report.  
6.4 Financial 
No implications directly arising from this report. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments
Page 16

Page 17

Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments       
6.5 Risk 
The independent review of selected systems and procedures mitigates the risk associated
with inadequate or ineffective control procedures.  
6.6 Staffing 
No implications directly arising from this report.  
6.7 Best Value and Transformation 
Internal audit work supports good governance and the delivery of efficient services.  
6.8 Property 
No implications directly arising from this report.  
6.9 Information Communications/Technology/Digital 
No implications directly arising from this report.  
6.10 Equalities, Social Inclusion and Economic Impact 
No implications directly arising from this report.  
6.11 Climate Change and Biodiversity Impacts 
No implications directly arising from this report. 
7. CONSULTATION  
7.1 There have been no direct consultations during the preparation of this report.   
8. BACKGROUND PAPERS  
8.1 None   
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APPENDIX 1
MORAY COUNCIL 
INTERNAL AUDIT SERVICE 
ANNUAL AUDIT PLAN 2024/25 
CORE FINANCIAL SYSTEMS  
Area Type of coverage Status/ Comments
Payroll   Continuous auditing to confirm the
adequacy of the systems and procedures
for the payment of salaries.
Audit Review to be carried forward to a
future Audit Plan
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. 
Audit Review and Draft Report
Completed
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). 
Completed
Grant Claims Certification of grant claims as required:
strategic timber; network support grant,
regeneration schemes as appropriate
The review of the Network Support Grant
to Transport Scotland for the period up to
13 October 2024 is ongoing. 
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APPENDIX 1
Housing Rent Collection & Arrears
Management
A review of the income collection and
accounting arrangements for housing
rents. 
Completed
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 Review and Draft Report
Completed
Treasury Management  To provide assurance that processes and
controls are continuing to operate
effectively for the Council's treasury
management system.  
Completed
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
Education- Secondary School Premises
Security
Review the controls in place to mitigate
the risk of unauthorised access to
Secondary School Premises. 
Audit Review and Draft Report
Completed
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APPENDIX 1
Absence Management An audit to consider the effectiveness of
sickness absence monitoring and
reporting. 
Audit Review to be carried forward to a
future Audit Plan
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 Review Ongoing
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 
Follow Up reviews to be undertaken
from previous  Audit Assignments *
Audit Review: Original Scope Status/ Comments
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APPENDIX 1
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.
Completed
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 currently in progress 
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.
Completed 
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 currently in progress 
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APPENDIX 1
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.
Completed 
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 currently in progress 
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.
Completed 
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
Follow Up Review currently in progress 
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APPENDIX 1
records to the actual equipment held within the
Stores.   
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.
Completed 
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 currently in progress 
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 
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 
Completed 
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APPENDIX 1
administered in accordance with these policies
and procedures and are operating within
budgetary control. 
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 currently in progress 
* Additional follow up reviews may be reported depending on the implementation dates detailed by Services for recommendation 
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APPENDIX 2
1
Final Internal Audit Report (Follow-up Review)
Fostering and Kinship Care Payments 
March 2025
Distribution: Chief Social Work Officer  
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
Substantial
Priority 1 0
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.
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Appendix 2 
2
Contents 
Page
Fostering and Kinship Care Payments 
1. Introduction & Scope 3
2. Key Issues  3-4 
Detailed Report 
3. Findings/Recommendations 5-9
4. Management Response 5-9 
Appendices 
1. Audit Terms of Reference and Definitions 
2. Statement of Responsibility 
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Appendix 2 
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. 
• 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
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Appendix 2 
4
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. 
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5 
Findings/Recommendations - Fostering and Kinship Care Payments 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
Children and Families
Social Work Service
Manager
Yes Implemented Kinship Carer Agreement template has been
amended to reflect current data protection
legislation.
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Implemented N/A Follow up review has confirmed that that Kinship Carer Agreement template has been
updated to reflect current data protection legislation.   
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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
Children and Families
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. 
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7 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Implemented N/A Business Support Team has issued a reminder to officers of the requirement to follow
Case Recording Procedures regarding the recording and retention of documents. 
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8 
Ref Risk Ratings for
Recommendations
Audit Findin 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
Children and Families
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
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9 
Education Services to ensure there is no
change in circumstances.
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Implemented N/A The follow up review has found that processes have been amended to require
residence carers to complete the details of the child’s school on their annual return.
Testing confirmed that for locally resident carers, information is checked regularly with
Education Services to ensure no change in circumstances. For out of area residence
carers processes are now in place for residence details to be verified directly with the
child’s school. 
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10 
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 non compliance 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.
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11 
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 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. 
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APPENDIX 3
Moray Council
Internal Audit Section 
1
BODY: Health & Social Care Moray 
SUBJECT: Self-Directed Support Financial Review
REPORT REF: 22'013 
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: Clear and current policy documents and operational guidelines have been developed for the financial administration of SDS packages.
5.01 The SDS Direct Payment guidance
and financial monitoring
procedures should be reviewed
and updated on a regular basis.   
Low Yes 30/04/2022 Implemented. Implementation completed as
detailed in the follow-up report presented to the
Council’s Audit & Scrutiny Committee on
10/05/2023 (para 7 of minute refers) and MIJB’s
Audit, Performance & Risk Committee on
29/06/2023 (para 5 of minute refers). 
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APPENDIX 3
Moray Council
Internal Audit Section 
2
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation  
Key Control: Financial reviews are being carried out to monitor the usage of SDS funding in accordance with operational guidelines.
5.02 Annual financial reviews should be
undertaken in line with the direct
payment financial monitoring
procedures. 
High Yes 31/01/2022
(Revised
Implementation
Date
31/08/2023; 
Further Revised
Implementation
Date
30/09/2024) 
Part Implemented. Significant progress has
been evidenced as made in undertaking annual
financial reviews with the appointment of a
temporary Finance Assistant post in September
2023. As an indication of the improvement in
scale, 331 reviews were carried out in the 2024
calendar year compared to 107 undertaken in
2023. The additional resource has allowed all
unmanaged accounts to be subjected to an
annual review and although a backlog of
managed account annual reviews is still in
existence, this is being worked through using a
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APPENDIX 3
Moray Council
Internal Audit Section 
3
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
logical system of risk-based prioritisation and
all overdue reviews have been allocated to
officers within the SDS Team for future
undertaking. Accurate records are being kept of
completed activities and due reviews and
management are employing effective
monitoring to direct limited resources to best
use. It is considered that the service is applying
focus to the financial review requirements and
are on a clear path to address the
recommendation fully by 31/03/2026 within
current staff resources.   
5.03 Consideration should be given to
the routine production of reports
Medium Yes 31/12/2021 Implemented. Implementation completed as
detailed in the follow-up report presented to the
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APPENDIX 3
Moray Council
Internal Audit Section 
4
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
from the Care First System which
can be used to detail financial
reviews falling due and allow
management to prioritise
workloads accordingly. The
requirement of manual
spreadsheets should be minimised
wherever possible to ensure
information reference points come
direct from the Care First system.   
Council’s Audit & Scrutiny Committee on
10/05/2023 (para 7 of minute refers) and MIJB’s
Audit, Performance & Risk Committee on
29/06/2023 (para 5 of minute refers). 
5.04 A risk based approach should be
initiated by management to
prioritise outstanding financial
reviews and work through the
backlog in an order which makes
High Yes 31/12/2021
(Revised
Implementation
Date
31/08/2023)
Implemented. Implementation completed as
detailed in the follow-up report presented to
MIJB’s Audit, Performance & Risk Committee on
26/10/2023 (para 7 of minute refers) and the
Council’s Audit & Scrutiny Committee on
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APPENDIX 3
Moray Council
Internal Audit Section 
5
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
best use of limited resources.  22/11/2023 (para 5 of minute refers). 
5.05 A reminder should be issued to
people receiving services, and
approved payroll providers where
applicable, to inform the Authority
when funds in excess of the
contingency amount are held. This
may assist in the prioritisation of
early financial reviews and
highlight issues for further
investigation. 
High Yes 30/04/2022 Implemented. Implementation completed as
detailed in the follow-up report presented to the
Council’s Audit & Scrutiny Committee on
10/05/2023 (para 7 of minute refers) and MIJB’s
Audit, Performance & Risk Committee on
29/06/2023 (para 5 of minute refers). 
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APPENDIX 3
Moray Council
Internal Audit Section 
6
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
5.06 A review should be undertaken of
all people receiving a service in
regard to the current balances held
within their SDS bank account.
Action should then be taken to
recover excess funds. 
High Yes 30/04/2022
(Revised
Implementation
Date
31/08/2023;
Further Revised
Implementation
Date
30/09/2024)
Implemented. Annual reviews for unmanaged
accounts has allowed appropriate surpluses to
be recovered on an ongoing basis. In relation to
managed accounts where some annual reviews
remain overdue as detailed at recommendation
5.02, bank balances are being obtained monthly
and surpluses reclaimed where appropriate
even though a comprehensive review has not
yet been undertaken. Surpluses reclaimed in
the 24/25 financial year to date, 10 months from
April to December, amount to the significant
sum of £932,337, illustrating the progress made
by the SDS Team. 
Page 41

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APPENDIX 3
Moray Council
Internal Audit Section 
7
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
5.07 In compliance with established
procedures, one-off direct
payments should be subject to a
financial monitoring review 3
months (or in limited
circumstances at another interval)
after the funding has been
distributed to confirm its
appropriate usage. 
Medium Yes 30/04/2022
(Revised
Implementation
Date
31/08/2023;
Further Revised
Implementation
Date
31/03/2024)
Part Implemented. Significant progress has
been evidenced as made in undertaking reviews
falling due, as detailed at recommendation
5.02.  Although a small number of one-off
payment  reviews remain overdue, the backlog
is being worked through using a logical system
of risk-based prioritisation and all overdue
reviews have been allocated to officers within
the SDS Team for future undertaking. It is
considered that the service is applying focus to
the financial review requirements and are on a
clear path to address the recommendation fully
by 31/03/2026 within current staff resources.      
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APPENDIX 3
Moray Council
Internal Audit Section 
8
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
5.08 The Service should comply with the
monitoring requirements detailed
within an agreement between the
Council and the Service User for
the purchase and adaptation of a
mini van. 
Medium Yes 31/12/2021
(Revised
Implementation
Date
31/03/2023;
Further Revised
Implementation
Date
31/12/2023)
Implemented. Inspection visits have been
undertaken and current MOT, road tax and
insurance has been confirmed as held. The
regulatory requirements will continue to be
monitored by ongoing reviews for the period of
the legal agreement.   
5.09 Closing financial reviews of SDS
care packages should be
undertaken in accordance with
agreed procedures. Evidence
should be retained of any
expenditure outwith the agreed
support plan and of the full
Medium Yes 31/12/2021
(Revised
Implementation
Date
31/08/2023;
Further Revised
Implementation
Part Implemented. Significant progress has
been evidenced as made in undertaking reviews
falling due, as detailed at recommendation 5.02
and in common with recommendation 5.07. 
Although a number of closing reviews remain
overdue, the backlog is being worked through
and all overdue reviews have been allocated to
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APPENDIX 3
Moray Council
Internal Audit Section 
9
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
discussions held and decisions
made by Social Workers regarding
retrospective authorisation. 
Date
30/09/2024)
officers within the SDS Team for future
undertaking. It is considered that the service is
applying focus to the financial review
requirements and are on a clear path to address
the recommendation fully by 31/03/2026 within
current staff resources.         
Key Control:
SDS Funding is only used to support the service user's support plan outcomes and compliance is monitored to ensure public funds are spend
appropriately. 
5.10 Care and Support Plans should be
reviewed annually to ensure the
agreed care is being provided and
High Yes 01/05/2022
(Revised
Implementation
Outstanding. The issue of annual reviews of
care and support plans not being able to be
resourced has also been raised in the audit of
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APPENDIX 3
Moray Council
Internal Audit Section 
10 
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
continues to meet the needs of the
person receiving the service. 
Date
31/08/2023;
Further Revised
Implementation
Date
30/09/2024) 
SDS Option 2/3 and the recent Out of Area
Placements audit. The Heads of Service have
stated a review schedule is to be established
and reviews considered as part of efficiencies
strategies. An implementation date of
31/12/2025 has now been set and progress will
be reported in the Out of Area Placements
follow-up review in due course. 
5.11 All Social Workers should be
reminded of the requirement to
inform the SDS Team of any
amendment to a Support Plan that
will have a financial change to a the
care package of a person receiving
a service.  
High Yes 01/12/2022 Implemented. Implementation completed as
detailed in the follow-up report presented to the
Council’s Audit & Scrutiny Committee on
10/05/2023 (para 7 of minute refers) and MIJB’s
Audit, Performance & Risk Committee on
29/06/2023 (para 5 of minute refers). 
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APPENDIX 3
Moray Council
Internal Audit Section 
11 
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: SDS service has effective arrangements in place to monitor support packages and report on performance.
5.12 Consideration should be given to
the development of appropriate
performance monitoring measures
to be reported to service
management on a regular basis.
Given the current backlog of
reviews and consequences of
direct payment accounts not being
scrutinised on a timely schedule, it
may be beneficial for performance
information to be made available
Low Yes 30/09/2022
(Revised
Implementation
Date
31/03/2023)
Implemented. Implementation completed as
detailed in the follow-up report presented to
MIJB’s Audit, Performance & Risk Committee on
26/10/2023 (para 7 of minute refers) and the
Council’s Audit & Scrutiny Committee on
22/11/2023 (para 5 of minute refers). 
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APPENDIX 3
Moray Council
Internal Audit Section 
12 
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
for management to identify any
resourcing issues arising and
assess risks involved. 
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Page 48

APPENDIX 4
Moray Council
Internal Audit Section 
1
DEPARTMENT: Education, Communities & Organisational Development
SUBJECT:  Keith Sports and Community Centre 
REPORT REF: 24'024 
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
5.01 In accordance with Financial
Regulations and Petty Cash Guidance,
reimbursement of parking fees must
be made through an officer’s expenses
claim and not from the petty cash
account.
Low Yes Implemented Implemented – The Keith Sports and
Community Centre (Centre) no longer has a
petty cash fund;  officers will be reimbursed for
parking fees by submitting a Mileage & Other
Expenses Claim Form to the Payroll Service. 
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APPENDIX 4
Moray Council
Internal Audit Section 
2
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation 
5.02 Details of the numbered receipt
provided by a security company for
cash collections should be recorded
within the income records at the
Centre 
Medium Yes 30/06/2024 Implemented - Details of the numbered receipt
provided by the security company for cash
collections are now attached to the income
records held at the Centre.
5.03 Officers must use their individual login
credentials when using the Gladstone
system.
Medium Yes 30/06/2024 Implemented – It was noted that officers at the
Centre have been reminded to use their 
individual log-in credentials when logging in and
using the Gladstone system. 
5.04 A reconciliation between the
Gladstone system and FMS should be
undertaken to identify service users
with no agreed payment plans. New
payment plans should then be agreed
Medium Yes 31/07/2024 Implemented -  A reconciliation exercise has
been undertaken between the Gladstone
system and the Council’s Financial
Management System (FMS). It was found that 50
accounts had active membership but with no
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Page 50

APPENDIX 4
Moray Council
Internal Audit Section 
3
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
for the service users identified, or
membership should be cancelled. 
established direct debit payment arrangement.
The total outstanding amount due to the
Council has been calculated as £32,652. The
Service is undertaking action to recover this
outstanding income due to the Council.
5.05 Failure in direct debit payments
should result in the immediate
suspension of a service users FitLife?
membership. 
Medium Yes 30/09/2024 Implemented - The payment of direct debits for
FitLife? Membership is now managed through
the Gladstone system. Any payment failures are
automatically flagged and continued use of
membership by a service user is only permitted
on payment of the outstanding balance. 
5.06 Regular reviews should be undertaken
of FitLife? Service users to ensure they
remain within the correct category of
membership. 
Medium Yes 30/06/2024 Implemented –  The follow-up review has noted
that an exercise has been undertaken to identify
historical instances of family memberships
where a child has turned 18, and a membership
status change is required.  Monthly procedures
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Page 51

APPENDIX 4
Moray Council
Internal Audit Section 
4
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
are now in place to identify any family
membership users where a child will soon be 18
years of age, with contact then made with the
account holder detailing a need to amend their
membership category. 
5.07 A review should be undertaken to
assess the need to maintain a Repairs
and Works Log. If required, processing
of minor work orders should be in
accordance with agreed Centre
procedures 
Low Yes 30/06/2024 Implemented - A review of repair work logs
maintained at the centre was carried out and all
works were found to be recorded in accordance
with local procedures.
5.08 Sporting equipment and clothing
bought for re-sale should be
purchased in accordance with
Medium Yes 31/08/2024
(Revised
Implementation
Part Implemented -  The follow up review noted
that stock control records detailing the quantity
of items held for resale are now being
maintained. However, it was found that the
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APPENDIX 4
Moray Council
Internal Audit Section 
5
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Procurement Guidelines. In
addition, appropriate stock control
records should be maintained of
sporting clothing and equipment
held for resale.
Date
30/06/2025)
Service is still in the process of agreeing to a
revised contractual agreement for the supply of
sporting equipment and clothing for resale. A
revised implementation date of 30/06/2025 has
been agreed with the Service. 
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Page 53

APPENDIX 5
Moray Council
Internal Audit Section 
1
DEPARTMENT: Economy, Environment & Finance
SUBJECT:  Building Services – Planned Maintenance 
REPORT REF: 23'017 
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:  Planned maintenance works are managed in accordance with contract, procurement and financial regulations. 
5.01 A review should be undertaken of the
revised working time arrangements for
craft and manual officers agreed at a
meeting of the Communities
Medium Yes 30/09/2023
(Revised
Implementation
Part Implemented –  Further to consultation
with officers and unions in 2023, it was agreed
to continue with current working time shift
patterns. However, no approval was obtained
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Page 54

APPENDIX 5
Moray Council
Internal Audit Section 
2
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Committee on 22 October 2013 (para.
21 of the minute refers). If the benefits
of these changes to core hours and
shift patterns remain, an agreement
should be sought to continue with
current arrangements. 
Date
30/09/2025)
from committee to continue with these revised
arrangements.  The Building Services Manager
has indicated that he intends to undertake
another consultation exercise with officers and
the unions regarding working time
arrangements. The results of this exercise will
be reported to committee. A revised
implementation date of 30/09/2025 has been
agreed with the Service. 
5.02 Consideration should also be given in
developing performance targets for
the time taken to complete works from
comparisons or benchmarking with
the private sector. 
Medium Yes 31/03/2024
(Revised
Implementation
Date
30/06/2025)
Outstanding –  Discussion with the Building
Services Manager noted that contracts for the
Housing Investment Programme 2024/25
relating to housing energy efficiency
improvements regarding heating, kitchens,
bathrooms, and insulation works have been
awarded by area to external contractors, but
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Page 55

APPENDIX 5
Moray Council
Internal Audit Section 
3
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation 
also to Building Services.  It is intended to use
the charges for the work done by the external
contractors to benchmark against costs within
Building Services.  Benchmarking in relation to
other works will also be conducted separately.
A revised implementation date of 30/06/2025
has been agreed with the Service. 
5.03 A review should be undertaken of the
rates used and accounting
arrangements for determining budgets
and recovery of costs of planned
maintenance works. 
Medium Yes 31/03/2024
(Revised
Implementation
Date
31/03/2026)
Outstanding –  As noted in the review of the
reactive repairs audit, an exercise was
undertaken to determine individual costs and
overhead recovery rates several years ago.   The
Building Services Manager stated that the
annual percentage increase in rates is uplifted
every year after consultation with Property and
Housing Services, with consideration also given
to the Building Cost Information Service (BCIS)
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Page 56

APPENDIX 5
Moray Council
Internal Audit Section 
4
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
indices. It is appreciated that a review of
costings and overhead recovery rates for all
works will be a significant exercise that may also
require the assistance of other services. The
Building Services Manager has detailed a
revised implementation date of 31/03/2026.
5.04 Procedures should be developed to
allow the recording and monitoring of
the metal collected for recycling. 
Low Yes 31/05/2023 Implemented - Procedures are now in place
detailing arrangements for recording and
monitoring scrap metal collected for recycling. 
5.05 Officers should be reminded of the
Council’s Retention Schedule to
ensure all have a clear understanding
of the time periods regarding the
retention of records.
Medium Yes 30/06/2023 Implemented –Officers involved in the storage
of records have been reminded of the need to
comply with retention schedules and notices
detailing retention time periods have been
affixed to filing cabinets holding historic
records. 
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Page 57

APPENDIX 5
Moray Council
Internal Audit Section 
5
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
5.06 Officer timesheets should be
amended to allow any overtime
undertaken to be recorded against a
specific job number. 
In accordance with agreed operating
arrangements, officers’ timesheets
must be authorised by a supervisor
and a co-ordinator. 
Medium 
Medium
Yes 
Yes
31/03/2023 
31/03/2023
Implemented –  Timesheets have now been
amended to allow overtime against specific job
numbers to be recorded. 
Implemented - Sample testing was carried out
and it was found that time sheets were being
correctly authorised by supervisors.
5.07 The use of C-track system should be
investigated as an aid to allow the
monitoring of officers timesheets of
the working time charged to jobs.
Medium Yes 31/03/2023 Implemented – Periodic and exception based
reviews are now being undertaken by
management to review information held on C-
track to officers timesheets. It was further noted
that Safe Driver training had been provided to
82% of drivers within Building Service; this has
included highlighting the requirement to utilise
the C-track system in accordance with detailed
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Page 58

APPENDIX 5
Moray Council
Internal Audit Section 
6
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
procedures. Training will be provided to
remaining drivers within Building Services by
31  March 2025. 
5.08 All Clerk of Works Instructions should
be recorded detailing the requirement
for any additional work needed within
planned works. 
Medium Yes 30/06/2023 Implemented - Sample testing confirmed that
additional works carried out for planned works
were supported by Clerk of Works Instructions.
5.09 Contracts should be agreed with
companies used regularly for the
supply of goods and materials where
annual expenditure exceeds the Quick
Quote threshold of £5000. 
Medium Yes 31/03/2024 Implemented. Testing undertaken has
confirmed that the Service now uses national
frameworks or local contacts to purchase
goods and services where cumulative
expenditure to a supplier is in excess of £5,000.
The Service is also reviewing on an ongoing
basis all payments made to off-contract
suppliers to determine whether there is a need
for a more formal contractual relationship. 
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Page 59

APPENDIX 5
Moray Council
Internal Audit Section 
7
Page 59

Page 60

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Page 61

Report to: Audit and Scrutiny
Committee
Meeting Date: 7 May 2025     
Report by: Audit and Risk Manager Report No: GSP006/25/DL  
Author: Dafydd Lewis Contact Email: dafydd.lewis@moray.gov.uk 
Subject:  Internal Audit Review – Special Investigation - Building Services -
Windows Replacement Programme   
1. PURPOSE 
☒ For Decision      ☐  For Information 
1.1 The report advises Committee on an internal audit review completed for the               period from
12 February 2025 to 7 May 2025. 
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. SUMMARY  
2.1 This report provides details of the internal audit review completed of a Special
Investigation - Building Services - Windows Replacement Programme during the period
from 12 February 2025 to 7 May 2025. 
3. RECOMMENDATIONS  
3.1 It is recommended that Committee:   
i) Considers the contents of this report, seeks clarification on any points noted,
and endorses the recommendations contained within the report.   
Dafydd Lewis
Audit and Risk Manager 
4. BACKGROUND AND CONTEXT  
Item 6.
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4.1 A review of a contract for a window replacement programme for properties at Carnie
Place, Buckie has been undertaken.  The Head of Housing and Property Services
requested the audit after concern had been raised by an Elected Member that windows
had been purchased for a housing estate that could not be installed.  
4.2 Building Services awarded a contract in 2021 for manufacturing replacement windows for
101 properties, which included 1 house and 16 flats at Carnie Place, Buckie, to a value of
£40,412. A total of 96 replacement windows were manufactured for the properties at
Carnie Place and delivered to Building Services in 2022. However, it was found that on the
installation of the replacement windows, they could not be fitted as the dimensions of the
windows manufactured were greater than the rough openings at the properties. The audit
report on Appendix 1 details the findings and recommendations from a review undertaken
of the contract. 
5. PROPOSALS  
5.1 This report provides Committee with a summary of findings arising from an audit project
completed during the review period. 
6. SUMMARY OF IMPLICATIONS  
6.1 The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan)  ×
Policy and Legal  ×
Financial  ×
Risk × 
Staffing  ×
Best Value and Transformation × 
Property  ×
Information Communications Technology/Digital             ×
Equalities. Social Inclusion and Economic Impact   ×
Climate Change, Biodiversity and Sustainability  × 
6.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☐ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☐ Build Thriving, resilient, empowered Communities.   
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b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population   
6.3 Policy and Legal  
No implications directly arising from this report.  
6.4 Financial  
No implications directly arising from this report. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments       
6.5 Risk 
The independent review of selected systems and procedures mitigates  the risks
associated with inadequate or ineffective control procedures.  
6.6 Staffing 
No implications directly arising from this report.  
6.7 Best Value and Transformation 
Internal audit work supports good governance and the delivery of efficient services.  
6.8 Property 
No implications directly arising from this report.  
6.9 Information Communications/Technology/Digital 
No implications directly arising from this report.  
6.10 Equalities, Social Inclusion and Economic Impact 
No implications directly arising from this report.  
6.11 Climate Change and Biodiversity Impacts 
No implications directly arising from this report. 
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7. CONSULTATION  
7.1 There have been no direct consultations during the preparation of this  report. 
8. BACKGROUND PAPERS  
8.1 None   
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APPENDIX 1
1
Final Internal Audit Report
Special Investigation- Building Services-
Windows Replacement Programme   
March 2025
Distribution: Head of Housing and Property Services
Building Services 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 1
Limited Priority 2 2
Priority 3 0
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.  
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Appendix 1 
2
Contents 
Page 
Special Investigation- Building Services- Windows
Replacement Programme 
1. Introduction & Scope 3
2. Key Issues  3-4 
Detailed Report 
3. Findings/Recommendations 5-13
4. Management Response 10-14 
Appendices 
1. Audit Terms of Reference and Definitions 
2. Statement of Responsibility 
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Appendix 1 
3
1. Introduction and Audit Scope 
The Head of Housing and Property Services, after consulting with the
Corporate/ Senior Management Team, requested a review of a contract for a
window replacement programme for properties at Carnie Place, Buckie. This
was due to concern raised by an Elected Member in October 2024 that “large
quantities of ill-fitting windows” had been purchased for a housing estate that
could not be installed. 
A contract for the manufacture of windows of 765 windows for 101 properties
in Dufftown, Rothes, Cullen, Raffan and Buckie was awarded by Building
Services in 2021. The contract was for a total tender value of £297,174.00 and
included the manufacture of 96 windows for 1 house and 16 flats at Carnie
Place, Buckie, for £ 40,412. The contract was for the manufacture of windows,
while the installation was awarded to another contractor.  As part of the
contract tender documents, Property Services undertook external sizing
measurements for the windows, but a condition of the contract required the
window manufacturer to carry out onsite dimensional surveys to ensure the
new windows fitted the external wall openings. Property Services provided
sizing measurements for the windows to allow cost comparisons between
manufacturers as part of the tender evaluation. The contract conditions also
allowed for an intrusive survey to be done if required at the properties to
determine the actual sizing for manufacturing the windows.  
The audit scope was to check the contract for manufacturing replacement
windows for properties at Carnie Place. This involved discussions with
officers, review of documentation, emails, and minutes of meetings in the
administration of this contract. The audit also undertook a physical inspection
with the support of an officer in Property Services to confirm the stock of
windows stored by Building Services. 
The audit was carried out in accordance with Public Sector Internal Audit
Standards (PSIAS). 
2. Key Issues 
•   The audit noted that most of the 765 replacement windows
manufactured for the 101 properties in Dufftown, Rothes, Cullen,
Raffan and Buckie have been successfully installed. However, the 96
windows manufactured as part of the contract for Carnie Place,
Buckie cannot be fitted to the properties. This is because the size
dimensions of the windows manufactured are greater than the rough
openings to allow installation without structural changes to the
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Appendix 1 
4
properties at a significant cost. Enquiries with officers from Property
and Building Services found that the rough openings for the windows
at the properties are greater when measured externally than the
internal sizing. This feature of the properties at Carnie Place was not
known in preparation of the tender contract documents by either
Property or Building Services. However, a requirement of the contract
was for the supplier (manufacturer) to undertake a dimensional
survey by qualified officers of the windows at the properties. A site
visit was undertaken in January 2022 at Carnie Place by the
Manufacturer awarded the contract; also in attendance was the Clerk
of Works Design from Property Services. An external survey was
undertaken, but the Clerk of Works Design only noted the house was
entered to check the internal dimensions of the window openings.
After the site visit, the Manufacturer emailed the Contract Manager
(Building Services) to highlight that the window openings for the
properties were “tighter than outside reveals”. The Contracts
Manager noted the proposed action that internal plaster boards could
be “chipped away” to allow installation of the windows.  The windows
were then manufactured within a 5mm tolerance, except for 11
windows to the original specification of the tender contract
documentation and delivered to Building Services premises in April
2022.  Concern was initially raised by a contractor attempting to
install the replacement windows of a sizing issue in April 2022.
Further investigation by Building Services found that the replacement
window frames manufactured had a greater dimensional sizing of
between 20 mm to 100mm to fit the rough openings for the windows
at the properties.  Due to this variance, and as the internal wall was
solid block and plaster, it could not be “chipped away”. Installation of
the replacement windows would need structural changes to the
properties, which would not be a cost-effective option and would
result in significant disruption to the tenants. 
•    The issue concerning purchasing “ill-fitting” windows was raised with
the Head of Property and Housing by an Elected Member in October
2024. However, concern regarding the sizing of the windows
manufactured for Carnie Place was known in April 2022. The
replacement windows have been stored at a Building Services
premises but have not been recorded within the Building Services
Stores System as they were ordered for a specific contract. Improved
accounting arrangements should be introduced for all contract items
and materials to ensure any unused or surplus materials are
reviewed by senior management. A decision should be undertaken
about the future use of the replacement windows purchased for
Carnie Place, Buckie, in accordance with Financial Regulations. 
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Appendix 1 
5
Special Investigation- Building Services- Windows Replacement Programme- 2024/25 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1. High A review was undertaken regarding the purchase of
replacement windows for 17 properties at Carnie
Place, Buckie. The following points were noted: 
1.1 The purchase of windows for Carnie Place,
Buckie was part of a more extensive windows
replacement programme in 2019 for 101
properties in Dufftown, Rothes, Cullen,
Rathan and Buckie. The contract documents
between the Housing Service and Building
Services included measurements of the
windows' external dimensions (width x
height). Enquiries noted this was from an
external survey by Property Services for
tender costing purposes and undertaken
before the lifting of Covid restrictions. The
contract documentation detailed in Clause 3,
General that Building Services should: 
“Prior to ordering of the respective timber
windows, the Contractor is to determine, by
site dimensional survey of each window, that
the new window will occupy the full external
opening and that the openings are suitable or
fully modified to suit the window installation
proposed”
The audit considers that a more detailed survey
of the properties at Carnie Place, Buckie would
have highlighted a need to amend the initial
external dimensions measurements for the
windows provided by Property Services.  A
review of procedures should be undertaken
regarding the checks required to confirm
compliance with conditions and accuracy of
specifications, including measurements for
future contracts.     
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Appendix 1 
6
1.2 In addition, the contract also allowed for “an
intrusive survey to establish, e.g., the cover at
jambs and soffits, or if existing openings
require to be modified in any way.” It was
found this was not undertaken, and the tender
contract documents provided to the
manufacturers to price were the external
dimension measurements for the windows
undertaken by Property Services. 
1.3 Building Services separated the tendering
process for the supply and installation of the
windows replacement programme. The
tenderers for manufacturing the windows
were informed of “approximate dimensions”
within the contract documentation. Building
Services awarded the contract for the supply
of windows for 101 properties in July 2021 for
£297,174.00. This included the 17 properties
(1 house & 16 flats) at Carnie Place, Buckie
for 96 windows valued at £40,412.  The
contract awarded detailed the following
specification requirements: 
“Prior to manufacture of the respective timber
windows, the Supplier is to determine, by site
dimensional survey of each window, that the
new window will fit into the external wall
opening rebate and that the openings are
suitable or fully modified to suit the window
installation proposed. 
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Appendix 1 
7
If the minimum 12mm at the head & 12.5mm
at the jamb cover is not achievable at the
external window opening rebate then
agreement on how to proceed should be
made prior to the manufacture of the
windows.” 
1.4 In addition to the previous contract
specifications, there was a condition for the
Manufacturer to undertake a site survey, a
requirement also included “staff involved in
the site survey should be suitably qualified
and experienced (i.e. time-served or former
tradesmen technically proficient in
measurement for replacement windows)
taking care to establish the height and width
of openings and the rebate depth at head and
jambs…”. 
1.5 A site visit was undertaken at Carnie Place,
Buckie in January 2022 by the Manufacturer.
In addition, the Clerk of Works Design
(Property Services) was also present.   An
email on 17 May 22 from the Manufacturer to
the Contracts Manager within Building
Services detailed   that “inside reveals at
Cairnie Place are tighter than outside
reveals”. The window manufacturer also
stated that as “agreed on site” with the Clerk
of Works Design “that inside plaster board
would be chipped away”. The response from
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Appendix 1 
8
the Contracts Manager was “noted”. 
1.6 The Contracts Manager within Building
Services is no longer employed by the
Council. However, a discussion has been held
with the Clerk of Works Design. The officer
stated that he had verbally raised his
concerns regarding the sizing of the windows
for Carnie Place, Buckie with the Contracts
Manager and suggested that a window
installer should undertake a survey before
ordering the windows. The site visit with the 
Manufacturer in January 2022 involved an
external check of the properties, but the Clerk
of Works Design only noted the Manufacturer
entering the  house within Carnie Place to
undertake an internal survey.   
1.7 The windows were then manufactured within
a 5mm tolerance, except for 11 windows,
according to the original specification from
Property Services within the tender contract
documentation and delivered to Building
Services premises in April 2022. The
Contractor installing the windows at Carnie
Place informed Building Services of an issue
with sizing in April 2022. Further investigation
by Building Services found that the
manufactured window frames for the flats had
a greater dimensional sizing of between 20
mm to 75 mm to the rough openings. 
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Appendix 1 
9
However, 3 windows for the flats and 8
windows for the house at Carnie Place were
manufactured to a different size to the original
specification detailed within the tender
contract documentation. A recent survey
undertaken by Building Services of the house
noted  variances between the manufactured
window frames to the rough openings of
between 20mm to 100mm. 
1.8 It was also found that the internal rough
openings for the windows at the properties
were less than the external dimensions.  The
audit has been advised this is unusual, and as
the internal wall was solid block and plaster, it
could not be “chipped away”. Installation of
the replacement windows would need
structural changes to the properties, which
would not be a cost effective option. 
1.9 The 96 replacement windows for Carnie
Place, Buckie have until recently been stored
at a Building Services premises in Keith since
2022. The minutes of the Housing
Maintenance Partnership Contract Meetings
involving officers from Property and Building
Services noted the issue concerning the
replacement windows programme for Carnie
Place, Buckie was discussed from August
2023.   
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Appendix 1 
10 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment 
Head of Housing and
Property Services/ Building
Services Manager 
Yes 30/09/2025 A review of Property and Building Services operating
arrangements will be undertaken to identify any improvements
needed to current practices in preparing tender specifications
and checks to ensure compliance with contract conditions. 
Updated procedures have now been introduced that require
additional sample checking to be undertaken by Building
Services officers prior to approval being given for a supplier to
manufacture windows. 
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Appendix 1 
11 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
2. Medium  It was noted that the replacement windows for Carnie
Place, Buckie had been stored until recently at a
Building Services premises in Keith since 2022. As the
windows had been ordered for a contract, they were
not recorded as stock within the Stores System.
Materials/items purchased for a contract can
sometimes be stored within a Building Services
premises, but this should only be for a short period to
allow the practical completion of the works. Audit
testing as part of this review undertook a physical
check to confirm the replacement windows purchased
for Carnie Place, Buckie were the same as those
stored at the Building Services premises. This was
confirmed. However, it was found that in addition to
the purchased windows, 51 windows intended for
another 6 properties were also present. Enquiries
found these windows related to properties with
planned installation dates before 2023. Discussions
with Building Services officers noted that these
windows were not installed because tenants refused
access to the properties. However, further
investigation and discussions are now being
undertaken to allow the fitting of these windows at the
properties.   
A full inventory check of the contract materials
held within Building Services premises should
be undertaken, including the dates ordered and
intended contracts. This information should
then be provided to the Head of Housing and
Property Services for review and to authorise in
accordance with Financial Regulation if
alternative use, sale or disposal is required.   
Consideration should also be given to
investigating whether the Stores Management
System could be further used to account for
materials/items purchased for contract
purposes. Alternatively, a 6 monthly stock take
should be undertaken of the materials/items
held for contracts with the dates purchased and
the intended works programme. This should
then be reviewed by the Building Services
Manager.
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Appendix 1 
12 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Building Services Manager  Yes 
Yes
30/04/2025 
31/10/2025 
A full inventory check of contract materials held within all Building
Services premises will be undertaken and provided to the Head
of Housing and Property Services. 
The Building Services Stores Management System will be used
to purchase and record all future contract materials. Regular 6
monthly stock takes will be undertaken for contract materials.
This will be periodically reviewed by the Building Services
Manager. Storage arrangements for contact materials are also
being reviewed, with the intention of making greater use of direct
orders from suppliers. 
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Appendix 1 
13 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
3.    Medium As detailed in the previous finding, the audit undertook
a physical check to confirm the stock of 96
replacement windows held for Carnie Place, Buckie
until recently at the Building Services premises in Keith
since 2022. The following points were also noted: 
• The audit confirmed the 96 replacement windows
held in storage by Building Services. However,
from the survey undertaken by the Manufacturer
in January 2022 for the house within the
replacement windows programme at Carnie
Place, 8 windows had been manufactured to
different dimension measurements from the
information provided by Property Services as
part of the tender contract documentation. The
Manufacturer had not detailed these size
changes to Building Services. 
• A variance was found between the actual sizing
of the windows manufactured and the dimension
measurements detailed within the tender
contract documentation of 3 windows for the flats
at Carnie Place. 
Improved checking arrangements should be
undertaken by officers to verify materials or items
purchased are in accordance with the agreed
specification.
Officers should be reminded to check deliveries
on receipt against the purchase order to verify
accuracy and allow for any issues to be raised
with the supplier/manufacturer in accordance
with the terms and conditions of the contract. 
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Appendix 1 
14 
Management Response
Responsible Officer Accepted
(Yes/ No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management Comment
Building Services Manager  Yes Implemented Improved procedures are now in place to ensure the accurate
checking of deliveries on receipt against the purchase order
and to verify the accuracy and condition of goods received. Any
issues will be raised with the supplier/manufacturer and
payment of invoices will be held until they are resolved. 
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Appendix 1 
15 
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.
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Appendix 1 
16 
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. 
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Report to: Audit and Scrutiny
Committee
Meeting Date: 7 May 2025     
Report by: Audit and Risk Manager Report No: GSP005/25/DL  
Author: Dafydd Lewis Contact Email: dafydd.lewis@moray.gov.uk 
Subject: The National Fraud Initiative in Scotland 
1. PURPOSE 
☒ For Decision      ☐  For Information 
1.1 To provide Committee with information on the Council’s approach to participation in the
National Fraud Initiative (NFI). 
1.2 This report is submitted to Committee in terms of Section III (I) (5) of the Council’s Scheme
of Administration relating to considering reports from the Council’s Internal Auditor. 
2. SUMMARY  
2.1 The National Fraud Initiative (NFI) is a data-matching project conducted by the Cabinet
Office on behalf of Audit Scotland every two years. It involves a data-matching exercise
using information from various Council systems, as well as data provided by other
councils and organisations. Public bodies, including local authorities, are mandatory
participants in this process. The 2024/25 NFI exercise has begun, and the agreed
approach is for services to review and document the reasons for data matches, while the
Internal Audit Section investigates potential fraud, monitors progress, and reports on the
outcome.  
2.2 This report details the NFI self-appraisal checklist that has been completed as part of the
planning process for the 2024/25 data matching exercise. 
3. RECOMMENDATIONS  
3.1 It is recommended that Committee:   
i) Considers and endorses the Audit Scotland self-appraisal checklists that
participating bodies are invited to complete and present to their local audit
committees.   
Item 7.
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Dafydd Lewis
Audit and Risk Manager 
4. BACKGROUND AND CONTEXT  
4.1 In August 2024, Audit Scotland published a report titled “The National Fraud Initiative
Scotland 2024” (link). This report detailed the success of the NFI exercise within the public
sector in mitigating fraud and error. It states that in 2022/23, 110 public sector bodies in
Scotland participated in the NFI exercise, identifying £21.5 million in savings due to fraud,
overpayment, and error. However, previous data-matching exercises in Moray have not
uncovered fraud; instead, they have revealed timing differences or outdated information.
For example, if an individual changes jobs or addresses around the time the data is
submitted for matching, both old and new information may appear as a match but can be
quickly discounted upon review  
4.2 The National Fraud Initiative in Scotland 2024 report includes a recommendation for the
Council to complete an "NFI self-appraisal checklist as part of planning for the 2024/25
exercise." These self-appraisal checklists have now been reviewed and completed by the
Audit and Risk Manager and are provided as Appendix 1. It is pleasing to report that,
based on the overview undertaken, the Council is essentially meeting Audit Scotland’s
requirements, with no immediate actions required.  
4.3 Participation in the National Fraud Initiative supports the Council’s anti-fraud and
corruption arrangements. At the conclusion of the data-matching exercise, the findings
will be reported to this Committee by the Audit and Risk Manager. 
5. PROPOSALS  
5.1 The Committee is asked to note Audit Scotland's requirement for participants in the
National Fraud Initiative to complete a self-assessment checklist provided with this report. 
6. SUMMARY OF IMPLICATIONS  
6.1 The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan)  ×
Policy and Legal  ×
Financial  ×
Risk × 
Staffing  ×
Best Value and Transformation × 
Property  ×
Information Communications Technology/Digital             ×
Equalities. Social Inclusion and Economic Impact   ×
Climate Change, Biodiversity and Sustainability  × 
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6.2 Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☐ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☐ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population 
6.3 Policy and Legal  
No implications directly arising from this report.  
6.4 Financial 
No implications directly arise from this report; however, there are benefits where
correction of errors results in additional funding for the Council, and additionally,
assurances are obtained on the robustness of our systems. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments       
6.5 Risk 
The risk of not participating is that fraud or error occurs and is allowed to continue
unchecked  
6.6 Staffing 
No implications directly arise from this report; however, staff time is required in the
administration and investigation of matches from participation in the NFI exercise.  
6.7 Best Value and Transformation 
Internal audit work supports good governance and the delivery of efficient services.
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6.8 Property 
No implications directly arising from this report.  
6.9 Information Communications/Technology/Digital 
No implications directly arising from this report.  
6.10 Equalities, Social Inclusion and Economic Impact 
No implications directly arising from this report.  
6.11 Climate Change and Biodiversity Impacts 
No implications directly arising from this report. 
7. CONSULTATION  
7.1 The Chief Financial Officer as the NFI Senior Responsible Officer has been consulted with
the content of this report. 
8. BACKGROUND PAPERS  
8.1 None   
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APPENDIX 1 
Audit Scotland
National Fraud Initiative- Self-appraisal checklists 
Part A:
For those charged with
governance
Yes/No/Partly Is action
required?
Who by and
when?
Leadership, commitment and communication
1. Are we aware of emerging fraud
risks and taken appropriate
preventative and detective action? 
Yes
Irregularities reported
by the Accounts
Commission, Audit
Scotland, and the
Scottish Local
Authority
Investigators' Group
are reviewed by the
Internal Audit Section.
Points of concern will
be raised with senior
management. A
counter-fraud review
is included in the
2025/26 Audit Plan.
The scope of the audit
and testing
undertaken will be
informed by fraud
reported within other
organisations. 
No N/A
2. Are we committed to NFI? Has the
council/board, audit committee and
senior management expressed
support for the exercise and has this
been communicated to relevant
staff? 
Yes
The Chief Financial
Officer is the
delegated NFI Senior
Responsible Officer,
while the Audit and
Risk Manager is the
Key Contact Officer.
Individual officers
within services are
responsible for
progressing and
investigating matches
within their remit (e.g.,
Payroll, Creditors).
Internal Audit will
investigate any fraud
and monitor progress.
The Audit and Risk
Manager will report
the outcome of the
No N/A
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APPENDIX 1 
data-matching
exercise to a future
Audit and Scrutiny
Committee.
3. Is the NFI an integral part of our 
corporate policies and strategies
for preventing and detecting
fraud and error. And do we
make reference to NFI in our
governance codes and
statements? 
Yes
NFI is referred to and
forms part of the
Council’s Policy to
Combat Fraud, Theft,
Bribery, and
Corruption. This
Policy was reported to
the Corporate
Committee on 30
January 2024.
Reference is also
made to the Council’s
participation in the NFI
data-matching
exercise within the
counter fraud section
of the Internal Audit
Annual Report.
No N/A
4. Does our Key Contact have
sufficient authority and time to
ensure that NFI is delivered
effectively?
Yes
The Chief Financial
Officer is the
delegated NFI Senior
Responsible Officer,
while the Audit and
Risk Manager serves
as the Key Contact
Officer. Internal Audit
officers maintain
regular contact with
service
representatives to
monitor progress.
No N/A
5. Has the approach to follow up of
different NFI match types been
clearly set out and reported as
part of the bodies NFI planning
process?
Yes
As reported to the
Audit and Scrutiny
Committee on 12
February 2025, the
agreed approach
requires services to
review a sample of
each data set and
document the reasons
for the matches. The
Internal Audit Section
will then investigate
any potential fraud,
monitor progress, and
report to the Audit and
Scrutiny Committee
on the outcomes and
any other
administrative
requirements related
to the Council’s
participation in the NF
No N/A
6. Are NFI progress and outcomes
reported regularly to senior
management and elected/board
members (e.g., the audit
Yes
As in previous NFI
exercises, the
outcome of the review
of matches will be
Yes The outcome of
investigating NFI
matches will be
reported to a future
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APPENDIX 1 
committee or equivalent)? reported to the Audit
and Scrutiny
Committee. 
Committee.
7. Where we have not submitted data
or         used the matches returned to us
(e.g. council tax single person
discounts), are       we satisfied that
alternative fraud detection
arrangements are in place and that
we know how successful they  are?
Yes
All data submission
requests have been
fulfilled. However, the
Council has decided
to use Datatank to
validate single-person
discount claims.
(Datatank is a private
company specialising
in data analytics
solutions and
managed services to
support Local
Authority revenue and
benefits fraud
detection. The
Taxation Service will
monitor the results
from Datatank's use).
No N/A
8. Does internal audit, or equivalent,
monitor our approach to NFI and
our main outcomes, ensuring that
any weaknesses are addressed in
relevant  cases?
Yes
The Audit and Risk
Manager is the key
contact officer
overseeing the
matching process.
No N/A
9. Do we review how frauds and
errors         arose and use this
information to improve our internal
controls?
Yes
When an investigation
identifies control
weaknesses,
recommendations are
made to management
to reduce the risk of
the error recurring in
the future
No N/A
10.Do we need and have access to
fraud investigation officers to
enable frauds to be followed up
fully?
No
The Council no longer
employs a dedicated
Fraud Investigation
Officer. Any fraud
investigations will be
conducted by the
Internal Audit Section.
No N/A
11. Do we publish, as a deterrent,
internally and externally the
achievements of our fraud
investigators (eg, successful
prosecutions)?
No
Previous investigation
of data matches has
related to errors or
issues that require
corrective actions as
opposed to fraud that
would merit formal
prosecution.
No N/A 
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APPENDIX 1 
Part B:
For NFI Key Contacts and
users
Yes/No/Partly Is action
required?
Who by and
when?
Planning and preparation
1. Are we aware of emerging fraud
risks  and taken appropriate
preventative and detective action? 
Yes
Fraud and
irregularities reported
by the Accounts
Commission, Audit
Scotland, and the
Scottish Local
Authority
Investigators' Group
are reviewed by the
Internal Audit Section.
These reports are
then used to identify
projects for review
within the annual
counter-fraud review
or as separate
projects in the Annual
Audit Plan. 
No N/A
2. Are we investing sufficient resources
in  the NFI exercise? 
Yes
Services undertake
the investigation of
matches. Internal
Audit will oversee the
process and report on
the outcomes. 
No N/A
3. Do we plan properly for NFI 
exercises, both before submitting
data and prior to matches becoming
available? This includes considering
the quality of data and being clear
about the approach to follow up of
different match types.
Yes
The Internal Audit
Section coordinates
the NFI data
matching exercise.
Guidance on
information and
deadlines for
uploading data is
provided to Services
and the ICT Section.
The quality of data is
continuously
assessed
throughout the
processing of each
dataset.
No N/A
4. Where NFI outcomes have been low 
in the past, do we recognise that this
may not be the case the next time,
that NFI can deter fraud and that
there is value in the assurances that
we can take from low outcomes?
Yes
The review of findings
from an investigation
into matches for the
2022/23 NFI data-
matching exercise
found no instances of
fraud. Moving forward,
the sampling process
for future data-
matching exercises
No N/A
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APPENDIX 1 
will be continued and
refined to ensure the
most effective use of
staff resources, based
on the findings from
past investigations.
Participation in the
NFI exercise supports
the Council’s counter-
fraud arrangements
5. Do we confirm promptly (using the 
online facility on the secure website)
that we have met the fair processing    
notice requirements?
Yes  No N/A
6. Do we plan to provide all NFI data
on       time using the secure data file
upload facility properly?
Yes
NFI data uploaded in
accordance with
timetable. 
No N/A
Effective follow-up of matches
7. Do all departments involved in NFI 
start the follow-up of matches
promptly after they become
available?
Yes
The need to
investigate matches
promptly must be
balanced with the
operational demands
of the service. 
No N/A
8. Do we give priority to following up 
high-risk matches, those that
become quickly out-of-date and
those that could cause reputational
damage if a fraud is not stopped
quickly?
Yes
A proportionate
approach has been
agreed upon for
investigating data
matches on a sample
basis in 'high-risk'
categories to
determine whether
further testing is
required. 
No N/A
9. Are we investigating the 
circumstances of matches
adequately before reaching a ‘no
issue’ outcome, in particular?
Yes
Services investigate
matches to determine
whether any further
action is required. 
No  N/A
10. Are we drawing appropriately (in 
health bodies) on the help and
expertise available from NHS
Scotland Counter Fraud Service?
N/A  
11. Are we taking appropriate action in 
cases where fraud is alleged
(whether disciplinary action,
penalties/cautions or reporting to the
Procurator Fiscal)? Are    we
recovering funds effectively?
Yes
When errors are
identified that require
the Council to recover
funds, the necessary
steps are taken. Any
fraud identified will be
investigated by the
Internal Audit Section.
No  Future actions will
depend on results from
the investigations
undertaken of data
matches.
12. Do we deploy resources in 
proportion to risks, and scale down
work on match reports where early
work has not found any fraud or
error?
Yes
The process of
checking has been
refined over
successive NFI
exercises to reflect the
No  A proportionate
approach to checking
will continue to ensure
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APPENDIX 1 
risks apparent from
sampled matches,
with testing being
sufficient to draw
conclusions.
reviewing the highest-
risk or most productive
matches for follow-up. 
13. Where the number of high-risk 
matches is very low, are we
adequately  considering the medium
and low-risk matches before we
cease our follow-up work?
Yes
The all-matches report
is for informational
purposes only,
focusing on specific
matches involving
individual datasets to
be reviewed by
services. The
emphasis is on each
service taking a
proportionate
approach to checking
returned matches
No  N/A
14. Overall, are we deploying 
appropriate resources on managing
the NFI exercise?
Yes
In the current financial
climate and with the
increased demands
on services, the
available staff
resources to complete
and manage the NFI
data matching
exercises are proving
challenging 
No N/A
Recording and reporting
15. Are we recording outcomes properly 
in the secure website and keeping it
up to date?
Yes
Findings from
investigating the data
matches are recorded
directly on the secure
NFI website
No N/A
16. Do staff use the online training 
modules and guidance on the
secure website, and do they
consult the Cabinet Office NFI
team if they are unsure about how
to record outcomes (to be
encouraged)?
Yes
Contact is made with
the Cabinet Office NFI
team and Audit
Scotland for further
clarification as
needed. 
No N/A
17. If, out of preference, we record 
some or all outcomes outside the
secure website, have we made
arrangements to inform Audit
Scotland and the Cabinet Office NFI
team about these outcomes?
N/A
To minimise data
breaches, all results
are recorded within
the secure NFI
website.
No N/A 
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Report to: Audit and Scrutiny
Committee
Meeting Date: 7 May 2025      
Report by: Depute Chief Executive
(Economy, Environment
and Finance)
Report No: FIN002/25/LP/LC      
Author: Lorraine Paisey Contact Email: lorraine.paisey@moray.gov.uk 
Subject: Annual Audit Plan for the Year Ending 31 March 2025 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to inform the Committee of the External  Auditor’s Annual
Audit Plan for 2024/25.  
1.2  This report is submitted to Committee in terms of Section III (I) (9) of the Council’s Scheme
of Administration relating to considering reports produced by the Council’s External
Auditor. 
2.  SUMMARY  
2.1  The Annual Audit Plan sets out the risks which the External Auditor has identified during
the audit planning process and sets out the approach which the External Auditor will take,
including Wider Scope and Best Value issues.  It highlights that the Council may be
reclassified as requiring greater audit scrutiny if gross expenditure in the year exceeds
£500 million. An Audit Risk Assessment underpins the report. 
3.  RECOMMENDATIONS  
3.1  It is recommended that Committee:   
i)  Scrutinises the Audit Risk Assessment; and 
ii)  Considers and note the contents of the External Auditor’s Annual Plan for
2024/25.   
Lorraine Paisey
Chief Financial Officer 
Item 8.
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4.  BACKGROUND AND CONTEXT  
4.1  In September 2022, the Accounts Commission confirmed the appointment of Grant
Thornton as the external auditor for the Council for financial years 2022/23 to 2026/27
inclusive.  
4.2  In delivering the public audit for Moray, Grant Thornton will provide independent
assurance that public money has been spent appropriately and provides value.  Audit work
is carried out in accordance with International Standards on Auditing, the Code of Audit
Practice and any other relevant guidance.  
4.3  The audit includes consideration of Best Value as part of the Wider Scope audit.  
4.4 Grant Thornton’s Annual Audit Plan (AAP) for 2024/25 is attached as Appendix 1 to this
report.  The Plan sets out the scope of the audit work and the auditor’s approach to the
audit. The AAP is risk based and details the initial risks identified at the planning stage by
Grant Thornton on pages 11 to 16.  These will direct the focus of audit testing and the AAP
sets out the planned work to be undertaken for the audit of the financial statements for the
year ending 2024/25.   
4.5 In order to assist with the assessment of risk, an Informing the Audit Risk Assessment was
completed by senior managers and this is attached as Appendix 2.  This Committee is
asked by the Auditor to scrutinise the Audit Risk Assessment.  
4.6 Page 50 of the AAP shows the baseline audit fee for 2024/25 as £305,550, which is an
increase of 1.9% on the previous year.  In the main this fee is set by Audit Scotland.  In
addition a fee of £7,190 is notified in respect of the audit of those Council trusts which are
charities.  Additional fees are identified as liable to be incurred but not yet quantifiable.  If
the Council’s gross expenditure exceeds £500 million the baseline audit fee will increase
to reflect that additional work required.  
4.7 The annual accounts timetable, including key deadlines are shown on page 46 of the AAP
and includes the statutory requirement for the Council to submit the Unaudited Annual
Accounts along with supporting working papers to Grant Thornton by 30 June 2024,
following consideration by those charged with governance at the meeting of Moray Council
on 25 June 2025. The Council will be asked to consider the Annual Audit Report and
approve the Audited Annual Accounts at its meeting on 24 September 2025. 
5.  PROPOSALS  
5.1  The Audit Plan will direct the work of the External Auditor.  Any additional work required will
be reported on as part of the Annual Audit Report.  
6.  SUMMARY OF IMPLICATIONS  
6.1  The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan)  √
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Policy and Legal √ 
Financial √ 
Risk √ 
Staffing √ 
Best Value and Transformation  
Property  √
Information Communications Technology/Digital  
Equalities. Social Inclusion and Economic Impact   √
Climate Change and Biodiversity Impact  √ 
6.2  Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☐ Tackle Poverty and Inequality.
☐ Build Stronger Greener Vibrant Economy.
☐ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
local Outcomes Improvement Plan priorities:
☐ Developing a diverse, inclusive, and sustainable economy
☐ Building a better future for our children and young people in   Moray.
☐ Empowering and connecting communities.
☐ Improving wellbeing of our population 
6.3  Policy and Legal 
The external audit is conducted in terms of statutory powers afforded to the appointed
External Auditor and in accordance with Grant Thornton’s Code of Practice.  
6.4  Financial 
The baseline audit fee for 2024/25 is £305,550. 
One off Costs:
Service
Area
Budget Budget
Years
Proposed
Spend this
Year
Virement
From
Other
Comments       
Annually Recurring Costs:
Service
Area
Budget With
Effect
From
Annual
Net
Impact
Virement
From (if
applicable)
Other
Comments
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Financial
Services –
External
Audit
£305,820 1 April
2025 
N/A 
6.5  Risk 
There are no risk implications arising from this report.  
6.6  Staffing 
Preparation of the Council’s financial statements will be co-ordinated by the Chief
Financial Officer and will require input from all sections of Financial Services along with
other departments across the Council.  
6.7  Best Value and Transformation 
The audit covers aspects of Best Value.  
6.8  Property 
None arising directly from this report.  
6.9  Information Communications/Technology/Digital 
None arising directly from this report  
6.10  Equalities, Social Inclusion and Economic Impact 
None arising directly from this report.  
6.11  Climate Change and Biodiversity Impacts 
None arising directly from this report. 
7.  CONSULTATION  
7.1  This report has been prepared in consultation with CMT, the Chief Financial Officer and
the Audit and Risk Manager and any comments made have been incorporated into the
report  
8.  BACKGROUND PAPERS  
8.1     
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Moray Council External
Audit Plan
Financial year ending 31 March 2025
Prepared for those Charged with Governance, the
Controller of Audit and the Accounts Commission
07 May 2025
APPENDIX 1
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Contents
Section Page
1. Key developments impacting our audit approach 03
2. Introduction and Headlines 05
3. Identified risks 10
4. Our approach to materiality 21
5. Group audit 25
6. IT audit strategy 27
7. Wider scope and best value arrangements 29
8. Audit Scotland deliverables 41
9. Logistics 45
10. Fees and related matters 49
11. Independence considerations 53
12. Communication of audit matters with those charged with governance 55
13. Delivering audit quality 57
14. Appendices 61
Moray Council External Audit Plan 2024/25 2
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Key developments impacting our audit
approach
01
Moray Council External Audit Plan 2024/25 3
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4Moray Council External Audit Plan 2024/25 4
Key developments impacting our audit approach
Our commitments
• As a firm, we are absolutely committed to audit quality and financial reporting in the local government sector.
• To ensure close work with audited bodies and an efficient audit process, our preference as a firm is either for our
staff to work on site with you and your staff or to develop a hybrid approach of on-site and remote working.
• We would like to offer a formal meeting with the Chief Executive each quarter as part of our commitment to keep
you fully informed on the progress of the audit.
• At appropriate points within the audit, we would also like to meet informally with the Chair of your Audit and
Scrutiny Committee, to brief them on the status and progress of the audit work to date.
• We will consider your arrangements for managing and reporting your financial resources as part of our audit in
completing our wider scope work in relation to financial management and financial sustainability.
• Our wider scope work will also consider your arrangements relating to vision, leadership and governance and use of
resources to improve outcomes.
• We hold annual financial reporting workshops for our audit bodies to access the latest technical guidance and
interpretation, discuss issues with experts and create networking links with other client to support consistent and
accurate financial reporting across the sector.
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Introduction and Headlines02
Moray Council External Audit Plan 2024/25 5
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Introduction and headlines (1)
Purpose
This document provides an overview of the planned
scope and timing of the external audit of Moray
Council and its group for those charged with
governance. The Group includes:
• Subsidiaries: Connected Charitable Trust Funds,
Other Trusts Funds and Common Good Fund
• Associates: Moray Council, Grampian Valuation
Joint Board and Moray Leisure Limited
We are appointed by the Accounts Commission as
the external auditors of Moray Council for the five-
year period 2022/23 to 2026/27.
Respective responsibilities
• The Code of Audit Practice (the Code) summarises
where the responsibilities of auditors begin and
end and what is expected from the audited body. 
Our respective responsibilities, and that of Moray
Council are summarised in the Appendix of this
Audit Plan. We draw your attention to this and the
Code.
Scope of our Audit
The scope of our audit is set in accordance with the
Code and International Standards on Auditing (ISAs)
(UK).  We are responsible for forming and expressing
an opinion on Moray Council’s financial statements,
which have been prepared by management with the
oversight of those charged with governance (Full
Council). Our audit of the financial statements does
not relieve management or the Full Council of your
responsibilities. 
It is your responsibility to ensure that proper
arrangements are in place for the conduct of your
business, and that public money is safeguarded and
properly accounted for.  As part of our wider scope
and Best Value work, we will consider how you are
fulfilling these responsibilities.
Our audit approach is based on a thorough
understanding of Moray Council and is risk based.
Moray Council External Audit Plan 2024/25 6
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Introduction and headlines (2)
Group Audit
Moray Council is required to prepare group financial statements that
consolidate the financial information of:
• Moray Council
• Moray Integration Joint Board
• Grampian Valuation Joint Board
• Moray Leisure Limited
• Moray Council Common Good Funds & Moray Council Trust Funds
Moray Council External Audit Plan 2024/25 7
Significant risks
Those risks requiring special audit consideration and procedures to address the
likelihood of a material financial statement error have been identified as:
• Management override of controls (ISA (UK) 240);
• Risk of fraud in expenditure recognition – non payroll expenditure (cut-off)
(PN10);
• Valuation of land, buildings and Council dwellings;
• Valuation of defined benefit pension scheme liability.
We will communicate significant findings on this area as well as any other
significant matters arising from the audit to you in our Audit Findings (ISA 260)
Report.
The audit plan sets out our risk-based audit approach for Moray Council.  This plan outlines our planning risk assessment and is reported to
those charged with governance (full Council) and will be shared with Audit Scotland.
Materiality
We have calculated our planning materiality to be £8.080 million (Group) (PY:
£7.542 million) and £7.650 million (Council) (PY: £7.143million), which equates
to 2% (Group) (PY: 2%) and 1.9% (PY: 1.9%) (Council) of your prior year gross
expenditure as per the audited 2023/24 financial statements.
Performance materiality has been determined as £5.660 million (Group) (PY:
£5.258 million) and £5.350 million (Council) (PY: £5.000 million) and is based
on 70% (PY: 70%) of planning materiality.
We are obliged to report uncorrected omissions or misstatements other than
those which are ‘clearly trivial’ to those charged with governance.
A lower materiality threshold will of £25,000 will be used on the Senior Officers
Remuneration table within the Remuneration Report.
We will revisit our materiality throughout our audit including updating to reflect
the draft unaudited financial statements for 2024/25.
Other Matters
We summarise other audit matters for the Audit and Scrutiny Committee’s
awareness.  This includes:
• Consideration of going concern in accordance with Practice Note 10. 
• Certification of grant claims and returns. The two approved claims/returns for
2024/25 relate to housing benefit (HB) subsidy and non-domestic rates
(NDR).
• Completing Assurance Statements on Whole of Government Accounts.
• In accordance with the Code and planning guidance we also required to
complete and submit a number of information returns and other deliverables
to Audit Scotland during the year.
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Introduction and headlines (3)
Audit Fees
Audit fees were shared by Audit Scotland with Moray Council in January 2025.
The baseline audit fee set is £305,550.
Audit fees are paid to Audit Scotland who in turn pay Grant Thornton UK LLP.
The baseline audit fee has been agreed with the audited body.  We reserve the
right to review our fee during the audit should significant delays be encountered
and/or new technical matters arise.
There will be changes to the above audit fee due to anticipated increased work
required on the audit and the introduction of new requirements as follows:
• IFRS 16 applies for the first time in 2024/25
• ISA (UK) 600 – Group Financial Statements has been amended
• Additional testing of journals due to lack of authorisation control
• Follow up of significant number of audit recommendations raised in the
2023/24 audit
• Potential recategorisation of Moray Council as a category 2 audit as
expenditure is greater than £500 million
Until the work is fully performed on these new areas the full impact is not yet
determined and will be discussed with management and reported in our Annual
Audit Report. More detail on the above can be found at page 50 of this plan.
We reserve the right to review our fee during the audit should significant delays
be encountered and/or new technical matters arise.
Moray Council External Audit Plan 2024/25 8
Adding Value Through the Audit
Our overall approach to adding value through the audit is clear and upfront
communication, founded on our public sector credentials. We use our LEAP audit
methodology and data analytics to ensure delivery of a quality audit. 
We aim to add value to Moray Council through our external audit work by being
constructive and forward looking, by attending meetings of both the Full Council
where appropriate and the Audit and Scrutiny Committee and by
recommending and encouraging good practice. In so doing, we will help Moray
Council promote improved standards of governance, better management and
decision making and more effective use of resources.
We will ensure an element of unpredictability in our testing to highlight areas of
risk and improvements that can be made through both the financial statement
and wider scope and best value audit.
We have also invited members of your financial reporting team to our annual
Local Government Chief Accountants workshop, which is led by our internal
financial reporting technical team.
We also look to bring forward audit testing where possible by performing an
interim audit which was delivered in March 2025. Early testing covered NNDR
reliefs and payroll for the first nine months of the financial year. This will help
provide a smooth and efficient audit process to support delivery for the year end
audit.
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Introduction and headlines (4)
Group audit approach
A revised edition of ISA (UK) 600 applies for the first time to 2024/25 annual
audits. This introduces significant changes to the audit of groups including the
following:
• A proactive risk-based approach to the audit of groups. This means more
focus on identifying and assessing the risks of material misstatement,
planning the approach to the audit and performing engagement procedures
that respond to the assessed risks.
• Greater focus on the resources needed to perform the engagement, and the
direction and supervision of the engagement team and the review of its work.
• The definition of ‘engagement team’ includes component auditors.
• The definition of ‘significant components’ has been removed.
• The requirements for robust two-way communication between the group and
component auditor have been strengthened.
Moray Council External Audit Plan 2024/25 9
Wider Scope
In accordance with the Code, our planning considers the wider scope and Best
Value areas of audit. 
We have identified the following wider scope risks and will conclude on these
during the audit:
Financial management – There is a potential significant risk that budgetary
control and financial management information for members is not consistent for
effective decision making. More information relating to the response to this risk
can be found on page 32 of this report.
Financial sustainability – There is a risk that transformation and savings plans to
address financial pressures for medium to longer term are not sufficient to
address future funding gaps and increasing deficits. More information relating
to the response to this risk can be found on page 34 of this report.
Vision, Leadership and Governance -  There is a potential significant risk that the
Council do not meet their key priorities due to delayed progression of objectives
and the pace of change being limited or slow. More information relating to the
response to this risk can be found on page 36 of this report.
Use of Resources to Improve Outcomes – no significant risks identified.
Findings and conclusions drawn from procedures undertaken on the four wider
scope areas will be reported within the Annual Audit Report.
As part of our integrated wider-scope work we also use a risk-based approach to
assess and report on whether Moray Council has made proper arrangements for
securing Best Value and is complying with its community planning duties. For
2024/25 we are required to carry out work and report on the Best Value
thematic ‘Transformation – How councils are redesigning and delivering more
efficient services to achieve planned outcomes.’
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Identified risks03
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Significant risks identified (1)
Significant risks are defined by ISAs (UK) as risks that, in the judgement of the auditor, require special audit consideration. In identifying risks, audit teams consider
the nature of the risk, the potential magnitude of misstatement, and its likelihood. Significant risks are those risks that have a higher risk of material misstatement.
“In determining significant risks, the auditor may first identify those assessed risks of
material misstatement that have been assessed higher on the spectrum of inherent risk to
form the basis for considering which risks may be close to the upper end. Being close to the
upper end of the spectrum of inherent risk will differ from entity to entity and will not
necessarily be the same for an entity period on period. It may depend on the nature and
circumstances of the entity for which the risk is being assessed. The determination of which
of the assessed risks of material misstatement are close to the upper end of the spectrum of
inherent risk, and are therefore significant risks, is a matter of professional judgment, unless
the risk is of a type specified to be treated as a significant risk in accordance with the
requirements of another ISA (UK).” (ISA (UK) 315).
In making the review of unusual significant transactions “the auditor shall treat identified
significant related party transactions outside the entity’s normal course of business as
giving rise to significant risks.” (ISA (UK) 550).
Significant risk Description
Management override
of controls
Under ISA (UK) 240 there is a non-rebuttable presumed
risk that the risk of management override of controls is
present in all entities.
Our risk focuses on the areas of the financial statements
where there is potential for management to use their
judgement to influence the financial statements
alongside the potential to override the entity’s internal
controls, related to individual transactions.
We have therefore identified management override of
controls, in particular journals, management estimates
and of transactions outside the course of business as a
significant risk of material misstatement.
We will:
• Document our understanding of and evaluate the design effectiveness of
management’s key controls over journals.
• Analyse your full journal listing for the year and use this to determine our
criteria for selecting high risk journals.
• Test the high risk journals we have identified.
• Gain an understanding of the critical judgements applied by management in
the preparation of the financial statements and consider their reasonableness.
• Gain an understanding of the key accounting estimates made by
management and carry out substantive testing on in scope estimates.
• Evaluate the rationale for any changes in accounting policies, estimates or
significant unusual transactions.
Management should expect engagement teams to challenge
management in areas that are complex, significant or highly
judgmental which may be the case for accounting estimates, going
concern, related parties and similar areas. Management should also
expect to provide to engagement teams with sufficient evidence to
support their judgments and the approach they have adopted for key
accounting policies referenced to accounting standards or
changesthereto.
Where estimates are used in the preparation of the financial
statements management should expect teams to challenge
management’s assumptions and request evidence to support
those assumptions.
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Significant risks identified (2)
Significant Risk Description
Fraud in Expenditure
Recognition
Due to the presumption that there are risks of fraud in expenditure
recognition, we are required to evaluate which types of expenditure,
expenditure transactions or assertions give rise to such risks. Practice
Note 10: Audit of Financial Statements of Public Sector Bodies in the
United Kingdom (PN10) states:
"As most public bodies are net spending bodies, then the risk of material
misstatement due to fraud related to expenditure may be greater than
the risk of material misstatements due to fraud related to revenue
recognition".
Moray Council’s expenditure includes both payroll and non-payroll costs. 
We consider payroll costs to be well forecast and are able to agree these
costs to underlying payroll systems.  As such we believe there is less
opportunity for a material misstatement as a result of fraud to occur in
this area.
We therefore focus our risk on the completeness of non-payroll
expenditure streams.  Our testing will include a specific focus on year end
cut-off arrangements, including consideration of the existence of
accruals and provisions, in relation to non payroll/non finance
expenditure for the single entity.
We therefore consider this to be a significant risk to our audit however do
not consider this to be a key audit matter.
We will:
• Evaluate the design and implementation effectiveness of the
accounts payable system.
• Evaluate the design and implementation effectiveness of your
system for recording accruals.
• Verify that the operating expenses included within the
financial statements are complete via review of the
reconciliations between the Accounts Payable system and the
General Ledger.
• Search for unrecorded liabilities by performing a substantive
sample test of invoices input on to the accounts payable
system post period end.
• Search for unrecorded liabilities by reviewing cash payments
post period end.
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Significant risks identified (3)
Significant Risk Description
Fraud in Revenue
Recognition
Under ISA (UK) 240 there is a rebuttable presumed risk that
revenue may be misstated due to the improper recognition
of revenue. This presumption can be rebutted if the auditor
concludes that there is no risk of material misstatement due
to fraud relating to revenue recognition.
(rebutted)
Having considered the risk factors set out in ISA240 and the nature of the
revenue streams at Moray Council and the Group, we have determined that
the risk of fraud arising from revenue recognition for all revenue streams can
be rebutted, because:
• there is little incentive to manipulate revenue recognition.
• there is a low opportunity to manipulate other income since it is non
complex and there are sufficient controls in place to prevent and detect
fraud from other income streams, we therefore believe that the risk of
material fraud is low.
Therefore, we do not consider this to be a significant risk for Moray Council
and the Group.
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Significant risks identified (4)
Significant Risk Description
Valuation of land,
buildings and
council dwellings
In accordance with the CIPFA/LASAAC Code of Practice, except for initial recognition,
Moray Council is required to hold property and property, plant and equipment (PPE)
on a valuation basis.  The valuation basis used will depend on the nature and use of the
assets.  Specialised land, buildings, equipment, installations and fittings are held at
depreciated replacement costs, as a proxy for fair value. Non-specialised land and
buildings, such as offices, are held at fair value except for Headquarters Campus
buildings which are too large to be marketed as office accommodation and are
measured at depreciated replacement cost as an estimate of current value. Council
dwellings are determined using the basis of existing use value for social housing. 
Moray Council employ an internal valuer to undertake a rolling programme of
valuations across their asset base valuing land, buildings and council dwellings at least
once every five years. In the intervening periods, Moray Council carries out an
indexation exercise. As at 31 March 2024, Moray Council held PPE of £1.239 billion
including land and buildings of £0.498 billion and council dwellings of £0.446 billion.
Given the significant value of the land, non-specialised buildings and council dwellings
held by Moray Council, and the level of complexity and judgement involved in their
estimation process, there is an inherent risk of material misstatement in the year end
valuation of  some of these assets.  However, the risk is less prevalent in other assets as
these are generally held at depreciated historical cost, as a proxy of fair value and
therefore less likely to be materially misstated. We will therefore focus our audit
attention on assets that have large and unusual changes in valuations compared to
last year and/or unusual approaches to their valuations, as a significant risk requiring
special audit consideration. The risk will be pinpointed as part of our final accounts
work, once we have understood the population of assets revalued.
We therefore consider this to be a significant risk to our audit and a key audit matter.
We will:
• Evaluate management’s processes and controls for the
calculation of the valuation estimates, the instructions
issued to their management experts and the scope of their
work.
• Evaluate the competence, capabilities and objectivity of
the valuation expert.
• Write to the valuer to confirm the basis on which the
valuations were carried out.
• Challenge the information and assumptions used by the
valuer to assess completeness and consistency with our
understanding.
• Evaluate the valuer’s report to identify assets that have
large and unusual changes and/or approaches to the
valuation – these assets will be substantially tested to
ensure the valuations are reasonable.
• Test a sample of other asset revaluations made during the
year to ensure they have been input accurately into the
body’s asset register and associated entries in the
financial statements.
• Evaluate the assumptions made by management for any
assets not revalued during the year and how management
has satisfied themselves that these are not materially
different to current value.
• For any assets not formally revalued, evaluate the
judgement made by management or others in the
determination of the current value of these assets.
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Significant risks identified (5)
Significant Risk Description
Defined benefit
pension scheme
The Council participates in the North East Scotland Pension Fund (NESPF), a local
government pension scheme.  There is an established Pension Fund protocol in place
with Pension Fund auditors to provide external auditors with relevant assurance.
The local government pension scheme is a defined benefit pension scheme and in
accordance with IAS 19: Employee Benefits, Moray Council is required to recognise its
share of the scheme assets and liabilities in its Statement of Financial Position.
In 2023/24, the Council applied the asset ceiling test as prescribed by IFRIC 14 which
limited the measurement of a defined benefit asset to the ‘present value of economic
benefits available in the form of refunds from the plan or reductions in future
contributions to the plan.’ The pension asset can be recognised as the lower of the net
pension asset or the present value of any economic benefits available. The Council’s
actuaries undertook this assessment and the asset value in the accounts was reduced
as the present value of the benefits available were lower than the pension asset. The
net liability arising from the unfunded defined benefit obligation remained as there is
no right to offset this.
The Council’s actuary will provide an annual IAS 19 actuarial valuation of Moray
Council’s net liabilities in the pension scheme.  There are a number of assumptions
contained within the valuation, including: discount rate; future return on scheme
assets; mortality rates; and future salary projections.  Given the material value of the
scheme’s gross assets and gross liabilities and the level of  estimation in the valuation,
there is an inherent risk that the defined benefit pension scheme net liability could be
materially misstated within the financial statements.  This risk is focussed on the
appropriateness and reasonableness of the underlying assumptions adopted by the
actuary and the suitability of these for the Council.
We therefore consider this to be a significant risk to our audit and a key audit matter.
We will:
• Evaluate management's processes and controls for the
calculation of the gross asset and gross liability and
estimates, the instructions issued to the actuarial expert
and the scope of their work.
• Evaluate the assumptions made by the actuary in the
calculation of the estimate, using work performed by an
auditor’s expert commissioned on behalf of Audit Scotland
and additional follow up procedures (where required).
• Evaluate the data used by management’s experts in the
calculation of the estimates.
• Perform substantive analytical procedures over the gross
assets, gross liabilities and in year pension fund
movements, investigating any deviations from audit
expectations.
• Assess the accuracy and completeness of the IAS 19
estimates and related disclosures made within the
Council’s financial statements.
• Review management’s assessment of the application of
IFRIC 14 (if applicable).
• Evaluate the response received from the NESPF auditor in
line with the Audit Scotland Protocol for Auditor
Assurances for Local Government Pension Schemes.
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Other risks identified (1)
Other Risk Description
IFRS 16 – Right
of Use Assets
In line with the Code of Audit Practice for Local Authority Accounting in the UK, 
Moray Council is required to adopt IFRS 16 Leases. 2024/25 will be the first year
the Council will account for leases in line with IFRS 16.
Under IFRS 16, a lessee is required to recognise right-of-use assets and associated
lease liabilities in its Statement of Financial Position. This will result in significant
changes to the accounting for leased assets and the associated disclosures in the
financial statements in the year ended 31 March 2025.
Further detail on the implications of this Accounting Standard is set out at
Appendix 4.
Our initial discussions with officers have indicated that:
• the Council has established systems and processes to
capture the data required to account for right-of-use
lease assets in accordance with IFRS 16;
• the Council revised its accounting polices for the year
ended 31 March 2025 to reflect the requirements of this
accounting standard.
We will assess the existence, accuracy and completeness
of the right-of-use assets and associated lease liabilities,
and the related disclosures, during our audit. As this is a
new area of focus for 2024/25, any work will be subject to
an additional audit fee.
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Other matters (1)
Other work
In addition to our expected responsibilities under the Code of Practice, we have
a number of other audit responsibilities, as follows:
• We audit parts of your Remuneration Report, as required under the Code, and
check whether these sections have been properly prepared (opinion). These
procedures are performed to a lower materiality.
• We read the sections of your Statement of Accounts which are not subject to
audit and check that they are consistent with the financial statements on
which we give an opinion (opinion).
• We carry out work to satisfy ourselves that disclosures made in your Annual
Governance Statement are in line with requirements set out in Delivering Good
Governance in Local Government: Framework (2016) (opinion).
• We consider our other duties under the Code and planning guidance
(2024/25), as and when required, including:
• Supporting Audit Scotland’s reporting to the Accounts Commission.
• Contributing to Audit Scotland Performance Reports and providing regular
updates to Audit Scotland to share awareness of current issues.
• Contributing to the National Fraud Initiative (NFI) report.
• Notifying the Controller of the Audit when circumstances indicate a
statutory report may be required.
• Completing mandated information requests and returns and notifying Audit
Scotland of any cases of money laundering or fraud.
• Review of Technical guidance prior to issue by Audit Scotland.
Moray Council External Audit Plan 2024/25 17
Internal control environment
During our initial audit planning we will develop our understanding of your
control environment (design and implementation) as it relates to the
preparation of your financial statements. In particular we will:
• Consider key business processes and related controls.
• Assess the design of key controls over all significant risks we have
identified. This will include key controls over:
• Journal entries and other key entity level controls.
• The completeness and accuracy of information provided to the
actuary to perform the valuation of the net pension fund liability.
• The review of actuarial outputs including key assumptions made by
the actuary and significant movements impacting the net pension
liability.
• The review of valuation outputs including key assumptions made by
the valuer and significant movements in revalued assets.
• The completeness of accruals and liabilities recorded within the
general ledger.
• The processes in place to identify all leases to be accounted for under
IFRS 16.
Our focus is on design and implementation of controls only.  We do not
intend to assess or place any reliance on the operating effectiveness of your
controls during our audit.
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Other matters (2)
Going concern assessment
As auditors, we are required to obtain sufficient appropriate audit evidence
regarding, and conclude on:
• whether a material uncertainty related to going concern exists; and
• the appropriateness of management’s use of the going concern basis of
accounting in the preparation of the financial statements.
The Public Audit Forum has been designated by the Financial Reporting
Council as a “SORP-making body” for the purposes of maintaining and
updating Practice Note 10: Audit of financial statements and regularity of
public sector bodies in the United Kingdom (PN 10).  It is intended that
auditors of public sector bodies read PN 10 in conjunction with (ISAs) (UK).
PN 10 was updated in 2020 to take account of revisions to ISAs (UK),
including ISA (UK) 570 (Revised September 2019) on going concern. PN 10
allows auditors to apply a ‘continued provision of service approach’ when
auditing going concern in the public sector, where appropriate.  Audit
Scotland’s also issued further guidance in a Going Concern publication in
December 2020).
Within our wider scope work we will conclude on Moray Council’s
arrangements to ensure financial sustainability.
Internal Audit
We read and understand the work of Internal Audit during the year, and how
this work feeds into management’s governance processes and inclusion
within the Annual Governance Statement.  We do not rely directly upon the
work of Internal Audit, and our approach is fully substantive.
Moray Council External Audit Plan 2024/25 18
Financial reporting developments
During our audit we will actively discuss emerging financial reporting
developments with you.
We invited members of your finance team to our LG technical audit workshops
earlier this year. The workshop will include focus on the new accounting and
audit requirements for IFRS 16 on leases, and good practice information for those
bodies preparing group accounts.
Progress against prior year audit recommendation
As part of our final account's procedures, we will follow up on the implementation
of prior year audit recommendations and report on progress against the
recommendations in full within our Annual Audit Report.
Whole of government accounts (WGA)
The Code of Audit Practice requires appointed external auditors to review and
report on WGA returns prepared by audited bodies. External auditors of local
authorities are required to provide an assurance statement on the 2024/25 WGA
returns for bodies over a prescribed threshold determined by NAO.
While we do not expect to be informed of the threshold before July 2025, we
anticipate that we will be required to provide a partial assurance statement for
Moray Council for 2024/25.
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Other matters (3)
National Fraud Initiative
The National Fraud Initiative (NFI) in Scotland is a biennial counter-fraud
exercise led by Audit Scotland, and overseen by the Public Sector Fraud
Authority for the UK as a whole.
The Council received their NFI matches in early 2025 and we will review
progress towards reviewing matches, in particular those matches assessed
as very high risk, and provide an update in our Annual Audit report.
Interim Testing
As part of our interim procedures, we will complete testing on a number of
areas when efficient to do so, which will cover the first nine months of the
financial year. This will include:
• Payroll - starters, leavers and changes in circumstances
• Payroll substantive analytical procedure
• NDR reliefs testing
Other material balances and transactions
Under International Standards on Auditing, "irrespective of the assessed risks
of material misstatement, the auditor shall design and perform substantive
procedures for each material class of transactions, account balance and
disclosure".  All other material balances and transaction streams will
therefore be considered as part of our audit. However, the procedures will not
be as extensive as the procedures adopted for the significant risks we have
identified and highlighted in this Audit Plan.
Moray Council External Audit Plan 2024/25 19
Section 106 Charities
Our audit appointment as the Council’s auditor includes the audit of any
trust funds falling within Section 106 of the Local Government (Scotland) Act
1973 that are registered charities.  For Moray Council we have therefore been
appointed as auditors of the connected charitable trust funds.  The audit fee
for this work is outside of the main fee and is £7,190.
Our audit procedures for the connected charities trust funds include:
• Total transactional audit testing over all income and expenditure
transactions incurred during 2024/25.
• Agreeing investment balances held by the trust fund to external
confirmation from investment fund managers.
Grant Claims
Local government auditors are required to review and report on approved
grant claims prepared by local authorities. We will work with officers to
ensure the timely completion and audit inspection of your Housing Benefit
return and Non-Domestic Rates claim. 
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Other matters (4)
Local Area Network
Moray Council has a Local Area Network (LAN) comprising of representatives
from relevant scrutiny bodies. The LAN is responsible for sharing information
and intelligence between scrutiny bodies and for considering the timing of
scrutiny activity to ensure that the scrutiny footprint is manageable for those
engaging with the process.
As the appointed auditor, we are responsible for bringing LAN members
together at the start of planning and for informing the council about the LAN
process. As part of our audit planning, we will engage with members of the
Local Area Network (LAN) in other agencies to collect information on
performance and scrutiny risks to inform risk assessment discussions.
We will share with the Council a timetable of scrutiny activity for the year
and advise the Chief Executive that any specific concerns should be raised
with the relevant scrutiny body
Moray Council External Audit Plan 2024/25 20
Risk Categorization
ISQM (UK) 1 (Revised March 2023) requires audit firms to establish policies
and procedures for the acceptance and continuance of client relationships.
These acceptance and continuance procedures are the initial way that we
manage risk and determine whether we should engage with an entity or
whether to continue with an existing engagement.
Risk management of our audit engagements is achieved through
categorisation; by dividing up our audit engagements into categories and
putting in place relevant risk management processes and procedures to
mitigate those risks. Categorisation also assists with ensuring that we
identify the correct ethical requirements which apply to each entity and
assists with monitoring and checking compliance with the Ethical Standard.
In the first two years of our audit appointment, Moray Council was classified
as a Category 4C audit as gross expenditure did not exceed £500 million. In
2024/25, the Council may have gross expenditure which exceeds £500m and
if this were to occur, our audit methodology requires us to recategorize the
audit as a Category 2 audit.
This would result in the audit team undertaking addition audit procedures,
including engaging with external auditor’s experts and require our internal
quality team to undertake an assessment over the accounts, known as a hot
review. It also means our audit work is performed to a lower materiality
(below 2.5%).
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Our approach to materiality04
21Moray Council External Audit Plan 2024/25
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Our approach to materiality (1)
The concept of materiality is fundamental to the preparation of the financial statements and the audit process and applies not only to the monetary misstatements
but also to disclosure requirements and adherence to acceptable accounting practice and applicable law.
Matter Description Planned audit procedures
Determination
We have determined planning materiality (financial statement
materiality determined at the planning stage of the audit) based
on professional judgement in the context of our knowledge of the
business, including consideration of factors such as shareholder
expectations, industry developments, financial stability and
reporting requirements for the financial statements. We have
determined financial statement materiality based on a
proportion of the gross expenditure of the Council for the
financial year.
Materiality at the planning stage of our audit is £8.080 million for
the Group (Prior Year £7.542 million) and £7.650 million for the
Council (Prior Year £7.143 million), which equates to
approximately 2% for the Group (Prior Year 2%) and 1.9% for the
Council (Prior Year 9%) of your 2023/24 gross expenditure less
IJB contributions of the Group and the Council.
• We determine planning materiality in order to:
– establish what level of misstatement could reasonably be expected to influence the
economic decisions of users taken on the basis of the financial statements;
– assist in establishing the scope of our audit engagement and audit tests;
– determine sample sizes;
– assist in evaluating the effect of known and likely misstatements in the financial
statements.
Other factors
An item does not necessarily have to be large to be considered to
have a material effect on the financial statements
• An item may be considered to be material by nature when it relates to:
– instances where greater precision is required (e.g. the Senior Management and
Councillor Remuneration and Pension Benefits Tables).
Reassessment of materiality
Our assessment of materiality is kept under review throughout
the audit process
• We reconsider planning materiality if, during the course of our audit engagement, we
become aware of facts and circumstances that would have caused us to make a
different determination of planning materiality.
01
02
Moray Council External Audit Plan 2024/25 22
03
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Our approach to materiality (2)
Matter Description Planned audit procedures
Matters we will report to the Audit and Scrutiny Committee
Whilst our audit procedures are designed to identify
misstatements which are material to our opinion on the financial
statements as a whole, we nevertheless report to the Audit and
Scrutiny Committee any unadjusted misstatements of lesser
amounts to the extent that these are identified by our audit work.
Under ISA 260 (UK) ‘Communication with those charged with
governance’, we are obliged to report uncorrected omissions or
misstatements other than those which are ‘clearly trivial’ to those
charged with governance. ISA 260 (UK) defines ‘clearly trivial’ as
matters that are clearly inconsequential, whether taken
individually or in aggregate and whether judged by any
quantitative or qualitative criteria.
• We report to the Audit and Scrutiny Committee any unadjusted misstatements of
lesser amounts to the extent that these are identified by our audit work.
• In the context of the Council, we propose that an individual difference could normally
be considered to be clearly trivial if it is less than £0.404 million for the Group (Prior
Year £0.377 million) and £0.382 million for the Council (Prior Year £0.357 million). If
management have corrected material misstatements identified during the course of
the audit, we will consider whether those corrections should be communicated to the
Audit and Scrutiny Committee to assist it in fulfilling its governance responsibilities.
Misstatements, including omissions, are considered to be material if they, individually or in the aggregate, could reasonably be expected to influence the
economic decisions of users taken on the basis of the financial statements; Judgments about materiality are made in light of surrounding circumstances,
and are affected by the size or nature of a misstatement, or a combination of both; and Judgments about matters that are material to users of the
financial statements are based on a consideration of the common financial information needs of users as a group. The possible effect of misstatements
on specific individual users, whose needs may vary widely, is not considered. (ISA (UK) 320)
Moray Council External Audit Plan 2024/25 23
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Our approach to materiality (3)
Amount (£) Qualitative factors considered
Materiality for the Group’s financial statements
Materiality for the Council’s financial statements
£8.080 million
£7.650 million
Our materiality has been set at 2% (Group) and 1.90% (Council) of prior year gross
expenditure as per the 2023/24 financial statements. In setting this threshold, the
following factors have been considered:
• There were no significant findings in the 2023/24 audit report.
• No significant deficiencies have been identified in the Council’s control environment.
• The level of public interest in Moray Council by the public and the Scottish
Government.
Materiality for specific transactions, balances or
disclosures – Remuneration Report
£25,000 Due to the sensitivity of the disclosures to the users of the financial statements, a lower
materiality threshold has been applied to the Senior Officers remuneration table within
the Remuneration Report. All other remuneration disclosures will be audited at headline
materiality.
24Moray Council External Audit Plan 2024/25 24
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Group Audit05
Moray Council External Audit Plan 2024/25 25
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Group audit scope and risk assessment
In accordance with ISA (UK) 600 Revised, as group auditor we are required to obtain sufficient appropriate audit evidence regarding the financial information of the
components and the consolidation process to express an opinion on whether the group financial statements are prepared, in all material respects, in accordance with
the applicable financial reporting framework.
Component Risk of material
misstatement to
the group
Planned audit approach and level
of response required under ISA (UK)
600 Revised
Response performed by Risks identified Auditor
Moray Council Yes Full scope audit performed by
Grant Thornton UK LLP.
Group auditor Valuation of land and buildings,
valuation of pension benefits risk of
fraud in expenditure recognition
Grant Thornton UK
Moray Integration
Joint Board
No Analytical procedures at group
level
Group Auditor N/A Grant Thornton UK
Grampian
Valuation Joint
Board
No Analytical procedures at group
level
Group Auditor N/A Grant Thornton UK
Moray Leisure
Limited
No Analytical procedures at group
level
Group Auditor N/A Saffery LLP
Moray Common
Good Funds
No Specific audit procedures on PPE
and Cash held at 31 March
Group Auditor Valuation of land and buildings Grant Thornton UK
Moray Trust
Funds
No Specific audit procedures on PPE
and Cash held at 31 March
Group Auditor Valuation of land and buildings Grant Thornton UK
There were have been no key changes in the group during 2024/25.
We have not been made aware of any actual or attempted frauds in the year during our planning procedures performed to date. Should any factors arise in relation
to fraud risk or actual or attempted fraud we ask that you inform us of this at the earliest possible opportunity.
During the course of our audit engagement, we will continue to assess the appropriateness of our planned approach in relation to the group audit scope.
Moray Council External Audit Plan 2024/25 26
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IT audit strategy06
Moray Council External Audit Plan 2024/25 27
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IT audit strategy
In accordance with ISA (UK) 315, we are required to obtain an understanding of the IT environment related to all key business processes, identify all risks from the use
of IT related to those business process controls judged relevant to our audit and assess the relevant IT general controls (ITGCs) in place to mitigate them.
Our audit will include completing an assessment of the design and implementation of ITGCs related to security management; technology acquisition, development
and maintenance; and technology infrastructure.
IT application Audit area Planned level IT audit assessment
Advance Business Solutions e5
System Financial Reporting • ITGC assessment (design and implementation effectiveness only)
iTrent Payroll • ITGC assessment (design and implementation effectiveness only)
CIPFA Asset Management PPE • ITGC assessment (design and implementation effectiveness only)
The following IT applications are in scope for IT controls assessment based on the planned financial statement audit approach, we will perform the indicated
level of assessment:
Moray Council External Audit Plan 2024/25 28
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Wider scope and best value
arrangements
07
Moray Council External Audit Plan 2024/25 29
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Wider scope and best value arrangements (1)
Our responsibilities under the Code extend beyond the audit of the financial statements.  The Code sets out four wider scope areas that constitute the wider scope of
public audit in Scotland.
We consider each of these areas through our audit planning process and have set out below the identified areas of risk for our wider scope work.
From our initial planning work, we have identified one significant risk in relation to Financial Sustainability. We have also identified two potential significant risks in
relation to Financial Management and Vision, Leadership and Governance. We will continue to review your arrangements before we issue our Annual Audit Report.
30Moray Council External Audit Plan 2024/25
Financial management
Has the body got sound
budgetary process, financial
capacity and the control
environment and internal
controls are operating
effectively.
Financial Sustainability
How the body looks forward to
the medium and longer term to
consider whether the body is
planning effectively to deliver
its services or the way in which
they should be delivered.
Vision, Leadership and
Governance
How effective are the body’s
scrutiny and governance
arrangements, leadership and
decision making, and
transparent reporting of
financial and performance
information.
Use of Resources to Improve
Outcomes
How the body makes best use
of their resources to meet
stated outcomes and
improvement objectives,
through effective planning and
working with strategic partners
and communities. This includes
demonstrating economy,
efficiency and effectiveness
through the use of financial
and other resources and
reporting performance against
outcomes.
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Wider scope and best value arrangements (2)
31
No significant weaknesses in arrangements identified or improvement recommendation made (in the Annual Audit Report – October 2024).
No significant weaknesses in arrangements identified, but improvement recommendations made (in the Annual Audit Report – October 2024)
Significant weaknesses in arrangements identified and key recommendations made (in the Annual Audit Report – October 2024)
Moray Council External Audit Plan 2024/25
This section of our report documents our conclusions from audit work on the wider scope areas set out in the Code.  We take a risk-based audit approach to wider
scope work. We will continue to review your arrangements before we issue our Annual Audit Report.
Financial
Management
The Council has arrangements in place for financial
management but there is room for improvement in the
arrangements in place for reporting the financial position,
savings and budget to Members.
Potential significant
risk has been
identified.
We reviewed the financial management processes in place at Moray Council,
including budget setting and preparation of monitoring reports taken to the
Board during the year. We will follow up all prior year audit recommendations,
including those raised in the Controller of Audit Report, as part of our year-end
procedures.
Financial
Sustainability
The Council’s arrangements in place for projecting the financial
position of the Council in the medium to longer term require
enhancement to ensure Members are being given information
that will allow them to make informed and effective decisions.
Significant risk
identified in relation
to financial
sustainability.
We reviewed future financial projections which show the level savings the
Council need to deliver in future years in order to achieve financial
sustainability. We reviewed the processes in place to agree efficiency savings
as part of the 2025/26 budget and how delivery of existing savings are
monitored. We will follow up all prior year audit recommendations, including
those raised in the Controller of Audit Report, as part of our year-end
procedures.
Use of
Resources to
Improve
Outcomes
The Council has appropriate arrangements to report outcomes
against Council priorities. Some key performance indicators
have improved, but there are less indicators in the top two
quartiles of performance than the previous year.
No significant risk has
been identified
We reviewed the 2024/25 service performance reports taken to Committee
meetings to gain an understanding of the Council’s in year performance. We
will follow up all prior year audit recommendations raised as part of our year-
end procedures. We will follow up all prior year audit recommendations,
including those raised in the Controller of Audit Report, as part of our year-end
procedures.
Vison,
Leadership
and
Governance
The Council has made improvements in its governance
arrangements and arrangements to deliver the vision, strategy
and priorities set by the Council, however, there remains work to
be done which is being monitored by the Best Value Action Plan.
Potential significant
risk has been
identified.
We reviewed the governance arrangements in place at the Council. We also
liaised with Internal Audit to confirm the result of their reviews to date and the
impact of any issues identified to date. We will follow up all prior year audit
recommendations, including those raised in the Controller of Audit Report, as
part of our year-end procedures.
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32Moray Council External Audit Plan 2024/25
Financial Management
Strong budgetary control is essential in any local authority. Where savings plans are required, they
should be detailed and progress on their attainment regularly reported to Officers and Members.
Financial forecasts must be accurate and regularly updated in order that effective decisions can be
made.
When the 2024/25 budget was approved, the Council projected a budget deficit of £19.196 million. The
Council’s plan to achieve financial balance was through the agreement of a savings plan totalling
£8.971 million, with the remaining £10.225 million being funded from working reserves. Further efficiency
savings were identified following the agreement of the budget, with the final planned savings for the
year totalling £12.473 million.
Details on the progress of the savings plan and the projected use of reserves has been reported to
Members throughout the financial year. The most recent update was provided as part of the Quarter 3
revenue monitoring report which was presented to Council in February 2025. This confirmed that the
forecast use of working reserves is currently £6.477 million as at 31 December 2024. The Council are
making good progress in the delivery of its savings plans and anticipate they will deliver more than 90%
of expected savings in 2024/25. Delivering more than 90% of the updated savings target is higher than
the Council had initially forecast to deliver.
At the end of the financial year, the Council should report the final outturn position including a year-end
reconciliation of budget and savings, setting out where services have under or overspent and have under
or overachieved savings targets.
The Council has a history of planning and using free reserves to balance the budget.  In order to address
this, the Council approved a Short to Medium Term Financial Strategy (2024-25 – 2026/27) in June
2024.  The Strategy aimed to remove the reliance on reserves to balance the budget for 2025/26 and
future years. Following approval of the 2025/26 Revenue Budget in February 2025, it was confirmed the
Council has achieved this target as there is no forecast use of reserves in 2025/26.
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33Moray Council External Audit Plan 2024/25
Financial Management (continued)
We recognise that the Council has made some progress with their financial management arrangements, including the fact they are no longer relying on
reserves to balance the 2025/26 budget. However, several financial management recommendations were made in the 2023/24 Annual Audit Report in October
2024 and the Council have had limited time to respond to these in the months since.  We will assess the implementation of these recommendations as part of
our year end audit procedures.
Therefore a potential significant risk has been identified in relation to the Council’s financial management arrangements.
Potential significant risk identified:
There is potentially a risk that budgetary control and financial management information for members is not consistent for effective decision making.
Response to significant risk:
We will:
• Review financial forecasting and reporting arrangements for timeliness and accuracy.
• Review and consider the accuracy of financial reporting (revenue and capital) as well as the narrative accompanying financial reports to Members.
• Review and monitor progress against the savings plans identified for 2024/25 and beyond consider the level of detail that is provided to Members.
• Follow up the recommendations raised in the 2023/24 Annual Audit Report, including those raised in the Controller of Audit Report.
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34Moray Council External Audit Plan 2024/25
Financial Sustainability
Like all Scottish local authorities, Moray Council continue to face unprecedented financial pressures. In
its 2025/26 Revenue Budget, approved by Full Council in February 2025, the Council confirmed that
efficiency savings totalling £10.905 million would be required over the next three years (2025/26 –
2027/28) in order to achieve financial balance.  The Council have approved £7.889 million of savings
for 2025/26 and £1.021 million for financial years 2026/27 and 2027/28.  A further £1.995 million of
savings need to be identified.  Delivery of these savings will be critical in ensuring the Council can
achieve financial balance in the medium term. We note that the three-year deficit position in the
2025/26 budget is a significant improvement on the previous outlook agreed as part of the 2024/25
budget.
The Council also prepare a Medium to Longer Term Financial Strategy (2025/26 – 2034/35) (MTLFS)
document which was approved by the Council in December 2024. Whilst the MTLFS was prepared in
advance of the agreement of the 2025/26 Revenue Budget, meaning the projections have since been
updated, it shows the level of challenge the Council is likely to face in the coming years.
The MTLFS is based on optimistic, average and pessimistic assumptions and the budget gap could
range from a  budget surplus of £28.6 million to a budget deficit of £107.5 million.
The mid range projections show a total budget gap of £41.365 million over the 10-year period to
2034/35 and the Council will need to identify new approaches to manage this gap over the longer
term.
Significant risk identified:
There is a risk that transformation and savings plans to address financial pressures for medium to
longer term are not sufficient to address future funding gaps and increasing deficits.
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35Moray Council External Audit Plan 2024/25
Financial Sustainability (continued)
Response to significant risk:
We will:
• Review how the council identifies significant financial pressures that are relevant to its short and medium-term plans and builds them into its plans.
• Review how the council plans to bridge its funding gap and identify achievable savings and future transformation.
• Review how the council plans its finances to support the sustainable delivery of services in accordance with strategic and statutory priorities.
• Review how the council identifies and manages risk to financial resilience, such as unplanned changes in demand and assumptions underlying its plans.
• Review how the council sets longer term financial plans and capital investment to deliver on priorities and how they determine their affordability.
• Follow up the recommendations raised in the 2023/24 Annual Audit Report, including those raised in the Controller of Audit Report.
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36Moray Council External Audit Plan 2024/25
Vision, leadership and governance
The Council hold a committee-based structure which has delegated functions to several committees
who subsequently become responsible for the administration of services. We will continue to review the
arrangements in place prior to issuing our Annual Report. Our work will also include reviewing the
consistency of the Annual Governance Statement with the key findings from audit, scrutiny, and
inspection.
During the 2023/24 audit, we identified several recommendations in relation to the Council’s vision,
leadership and governance arrangements including issues in relation to pace of change, cross party
working and the effectiveness of the Audit & Scrutiny Committee. A number of these issues were also
raised as part of the Controller of Audit Report and the Council continue to take steps to address the
issues raised.  Progress is monitored as part of the Best Value Action Plan which is reported to the
Corporate Committee which confirms the progress the Council are making in addressing the issues
raised in the Controller of Audit Report. 
Due to the number of vision, leadership and governance recommendations made in the 2023/24
Annual Audit Report and the limited time to respond to these in the months since, a potential significant
risk has been identified in relation to the Council’s vision, leadership and governance arrangements.
Potential significant risk identified:
There is potentially a risk that the Council do not meet their key priorities due to delayed progression
of objectives and the pace of change being limited or slow.
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37Moray Council External Audit Plan 2024/25
Vision, leadership and governance (continued)
Response to significant risk:
We will:
• Review cross party working arrangements and governance arrangements in place to inform effective decision making.
• Review arrangements in place to track and monitor performance and outcomes of council priorities as well as reviewing arrangements in place over the
information provided by members to inform effective decision making.
• Review the Council’s progress in implementing the actions identified in the Best Value Action Plan.
• Follow up the recommendations raised in the 2023/24 Annual Audit Report, including those raised in the Controller of Audit Report.
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38Moray Council External Audit Plan 2024/25
Use of resources to improve outcomes
We have not identified a risk in relation to the Council’s use of resources to improve outcomes at the
planning stage. The Council has a Performance Management Framework (PMF) with the aim to seek
continuous improvement. There are several mechanisms in place to report performance including the
Annual Performance Report, Service Performance Reporting and the Local Government Benchmarking
Framework (LGBF).
Our work will include reviewing the arrangements the Council has in place to meet its performance
objectives, for working with strategic partners and communities and reporting performance against
outcomes, financial and other resources. We will also complete work on Theme 3 in the Best Value
statutory guidance which relates to the effective use of resources (see further detail on page 40). We
will also follow up the recommendations raised in the 2023/24 Annual Audit Report, including those
raised in the Controller of Audit Report.
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39Moray Council External Audit Plan 2024/25
Best Value
Local government bodies have a duty under the Local Government in Scotland Act 2003 to make arrangements which secure Best Value. Best Value is
continuous improvement in the performance of the body’s functions, having regard to:
• efficiency
• effectiveness
• economy
• the need to meet equal opportunity requirements.
Local government bodies are required to follow statutory guidance in respect of their Best Value duties.
Best Value Thematic
The Code requires that auditors assess and report on audited bodies’ performance in meeting their Best Value and community planning duties, as part of
their annual audit. The Accounts Commission’s approach to Best Value involves reporting on individual local government bodies and thematically across
the local government sector through performance reports. The thematic work for 2024/25 is on the subject of ‘Transformation: how councils are
redesigning and delivering more efficient services to achieve planned outcomes’. This work will include an assessment of and conclusion on:
• to what extent does the council have clear plans for transformation that link to its priorities and support long-term financial sustainability
• to what extent do the council’s programme management arrangements facilitate effective oversight of its transformation plans
• to what extent are communities and partners involved in the development and delivery of the council’s plans for transformation
• to what extent has the council considered the impact of its transformation activity, including on vulnerable or protected groups.
This work will be completed and reported to those charged with governance in advance of the financial statements audit work.
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40Moray Council External Audit Plan 2024/25
Performance Reporting
Theme three in the Best Value statutory guidance is the effective use of resources, an element of which is performance reporting. We are required to undertake
work on performance reporting annually. Below we set out the Audit Scotland requirements for 2024/25.
Controller of Audit Report
At least once every five years, the Controller of Audit reports to the Accounts Commission on each council’s performance in meeting its Best Value duties. Moray
Council was selected as one of the 2023/24 reports and the report for Moray Council was published in April 2024.
We will follow up the Council’s progress in implementing the recommendations from the Controller of Audit and the Accounts Commission as part of our
2024/25 audit fieldwork and report on this to members in our Annual Audit Report.
Area of work What we will consider
Service performance reporting • The council’s assessment of progress against its service priority measures in 2024/25 and beyond
• The council’s reporting of relative performance, using the Local Government Benchmarking Framework
Continuous improvement • The council's pace of improvement in delivering priority services
• The council's depth of implementing improvement across council services
Statutory performance reporting Whether the council has made proper arrangements for preparing and publishing statutory performance
information:
• Performance in improving local public services (including those provided with its partners and communities) and
progress against agreed desired outcomes (SP1)
• Its own assessment and audit, scrutiny and inspection body assessments of how it is performing against its duty of
Best Value and how it as responded to these assessments (SP2).
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Audit Scotland Deliverables08
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Audit Scotland Deliverables (1)
42Moray Council External Audit Plan 2024/25
As set out in the Code of Audit Practice, as appointed auditors we have a number of wider reporting responsibilities beyond the audit of the financial statements. 
Below we summarise the key areas of work for our 2024/25 audit, including expected reporting under Audit Scotland’s Code of Audit Practice and audit planning
guidance:
Requirement How we will report our findings
Annual Accounts
Perform an audit of the annual accounts and express an audit opinion.
• Independent Auditor’s Report on the financial statements
• Annual Audit Report detailing findings from our audit work on the financial
statements.
Wider scope audit areas
Conclude and report on our assessment of the wider scope audit  areas.
• Annual Audit Report
Best Value– Follow Up
Follow up of the Moray Council’s progress in implementing the
recommendations raised in previous Best Value Assurance Reports, Annual
Audit Reports and the Controller of Audit report issued in March 2024
• Annual Audit Report
Best Value thematic work for 2024/25
We are required to  report locally on any Best Value thematic work prescribed
by the Accounts Commission. For 2024/25 the prescribed thematic is
‘Transformation’.
• Annual Audit Report
• Reporting in a separate management report is also required.
Statutory Performance Information
Consider and report on Statutory Performance Information arrangements.
• Annual Audit Report
National Fraud Initiative (NFI)
Contribute to NFI report.
• Annual Audit Report
• Reporting participation to Audit Scotland including completion of NFI
questionnaire
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43Moray Council External Audit Plan 2024/25
Requirement How we will report our findings
Statutory Objections
Consider statutory objections to the annual accounts
• Response to any objections received.
Whole of Government Accounts (WGA)
Provide assurance over Moray Council’s WGA return.
• Partial Assurance Statement on WGA return
Housing Benefits Subsidy Claim
Independent certification on housing benefit subsidy claim to the Department
for Works and Pensions (DWP).
• Auditor certificate on Housing Benefit Subsidy Claim (Deadline to be
confirmed when Technical Guidance Note is released in April 2025)
Non-domestic rates (NDR)
Certification of NDR claim.
• Auditor certificate on Non-Domestic Rate Return (Deadline to be confirmed
when Technical Guidance Note is released in May 2025)
Current Issues Returns
Prepare and submit Current Issues Returns.
• Current Issues Returns
Statutory Objections
Consider statutory objections to the annual accounts
• Response to any objections received.
Correspondence queries
Carry out preliminary enquiries into any correspondence relevant to Moray
Council that is referred to Audit Scotland.
• Providing responses to any correspondence received based on our audit
knowledge and understanding and the results of any review as agreed with
Audit Scotland
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44Moray Council External Audit Plan 2024/25
Requirement How we will report our findings
Emerging issues
Communication of emerging issues to Audit Scotland and highlight any issues
for potential statutory reports.
• Communicating throughout our audit emerging issues identified
throughout the year
Performance, impact and overview reports
Contribute to housing benefit performance audits, the Shared Risk
Assessment, sector annual reports, shared intelligence on health and social
care, and sector meetings.
• Providing information returns to Audit Scotland
Money laundering and fraud
Provide information on cases of money laundering or fraud.
• Completion of fraud returns for all frauds over £5,000 or involving
misappropriation or theft of assets or cash which are facilitated by
weaknesses in internal control
• Reporting cases to the National Crime Agency of any instances of money
laundering or fraud
Technical Guidance
Contribute to Technical Guidance Notes
• Providing responses to Audit Scotland consultations on draft Technical
Guidance Notes for Auditors
Local Area Network
Engage with members of the Local Area Network (LAN) in other agencies to
collect information on performance and scrutiny risks to inform risk
assessment discussions
• We will share with the Council a timetable of scrutiny activity for the year
and advise the Chief Executive that if they have any specific concerns on
the timetable, it should be raised with the relevant scrutiny body
• We will share the timetable of scrutiny activity with the Scrutiny
Coordination Group
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Logistics09
Moray Council External Audit Plan 2024/25 45
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The Audit Timeline - Logistics (1)
Planning
January – March
2025
Key
Dates
Final 
July - September
2025
Completion
September 2025
Key elements
• Planning meeting with management to set audit scope
• Planning requirements checklist
to management
• Agree timetable and deliverables with management
• Issue the Audit Plan to management and Audit and Scrutiny
Committee
• Review of key judgements and estimates
• Undertake payroll testing (first nine months of starters, leavers,
changes in circumstances and payroll substantive analytic)
Key elements
• Audit teams to complete
fieldwork and detailed testing
• Weekly update meetings
with management
Key elements
• Draft Audit Findings issued to management
• Audit Findings meeting with management
• Draft Audit Findings issued to Full Council
• Audit Findings presentation
to Full Council
• Annual Audit Report
• Finalise and sign financial statements & audit
report
Audit & Scrutiny
Committee
07 May 2025
Full Council
24 September
2025
Audit
phases:
Year end
31 March 2025
We are required to submit audit plans to Audit Scotland by 31 March 2025, and it is anticipated that we will submit audited accounts and the Annual Audit Report
by 30 September 2025. We have set out below our planned timescales for the Moray Council audit.
Wider Scope &
Best Value
July 2025
Draft Audit Plan
submitted to
Audit Scotland
31 March 2025
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The Audit Timeline - Logistics (2)
Audited body responsibilities
Where audited bodies do not deliver to the timetable agreed, we need to ensure that this does not impact on audit quality or absorb a disproportionate amount of
time, thereby disadvantaging our other audit engagements. Where additional resources are needed to complete the audit due to an audited body not meeting their
obligations, we are not able to guarantee the delivery of the audit to the agreed timescales. In addition, delayed audits due to client issues may incur additional audit
fees.
Our requirements
To aid the audit process, you need to ensure that you:
• produce draft accounts, comprising financial statements and related reports, of good quality, by the deadline you have agreed with us;
• prepare good quality working papers which support the figures included in the financial statements, in line with the working paper requirements schedule that we
have shared with you, and make these available to us at the start of the year end audit visit;
• provide all agreed data reports to us at the start of the audit, which are fully cleansed and reconciled to the figures in the financial statements;
• ensure that all appropriate staff are available to us for queries over the planned period of the audit , or as otherwise agreed;
• respond promptly and appropriately to all audit queries, within agreed timescales;
• respond promptly to the request for information on the best value thematic and wider scope work to agreed timelines and ensure appropriate supporting evidence
is provided;
• Provide all required information for the housing benefit and non-domestic rates grant claims, within agreed timescales.
Moray Council External Audit Plan 2024/25 47
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48Moray Council External Audit Plan 2024/25 48
Our team and communications
Service delivery Audit reporting Audit progress Technical support
Formal
communications
• Annual audit closure
meeting
• The Audit Plan
• The Annual Audit Report
• Progress and Sector Update
Reports
• Audit planning meetings
• Audit clearance meetings
• Communication of issues log
• Technical updates
Informal
communications
• Open channel for
discussion
• Communication of audit
issues as they arise
• Notification of up-coming
issues (where appropriate)
Angela L Pieri
Engagement Lead
T: 0161 214 6337
E: Angela.L.Pieri@uk.gt.com
Andrew Wallace
Audit Manager
T: 0141 223 0671
E: Andrew.D.Wallace@uk.gt.com
Lucy X Bell
Audit Senior / In-charge
• Key contact for senior
management and Audit and
Scrutiny Committee
• Overall quality assurance
• Audit team management
• Resource management
• Wider scope and best value reporting
• Day-to-day point of contact
• Audit planning/interim
• Audit fieldwork
Pool of technical specialists (e.g. IT audit and valuations staff)
Yashika Goel
Audit In-Charge
T: 0141 223 0000
E: Yashika.Goel@uk.gt.com
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Fees and related matters10
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Audit Fees
Across all sectors and firms, the Financial Reporting Council (FRC) has set out its
expectation of improved financial reporting from organisations and the need for
auditors to demonstrate increased scepticism and challenge and to undertake
additional and more robust testing.
As a firm, we are absolutely committed to meeting the expectations of the FRC
on audit quality and public sector financial reporting.  This includes, for Audit
Scotland contracts, meeting the expectations of the Audit Scotland Quality
Team and the Scottish quality framework. 
Audit fees were shared by Audit Scotland with the Chief Executive and Chief
Financial Officer in January 2025. Audit fees are paid to Audit Scotland who in
turn pay us. We reserve the right to review our fee during the audit should
significant delays be encountered and/or new technical matters arise.
Relevant Professional Standards
Audit Scotland set the baseline audit fee.  We can increase the fee, from the
baseline, for the inclusion of additional risks, new technical matters or where
specific client matters are identified, such as prior year misstatements and
disclosure amendments re-occurring during the audit.
We are required to consider all relevant professional standards, including
paragraphs 4.1 and 4.2 of the FRC’s Ethical Standard (revised 2024) which state
that the Engagement Lead must set a fee sufficient to enable the resourcing of
the audit with partners and staff with appropriate time and skill to deliver an
audit to the required professional and Ethical standards.
The baseline fee of £305,550 has been set by Audit Scotland. In accordance with
Audit Scotland guidance, we are able to discuss a variation to the audit fee
where additional work is required. Further detail on the audit fee is available at
page 52.
Moray Council External Audit Plan 2024/25 50
Our audit appointment includes the audit of any trust funds falling within
section 106 of the Local Government (Scotland) Act 1973 that are registered as
charities with the Office of the Scottish Charities Regulator (OSCR). Auditors,
appointed under the Accounts Commission are eligible under the charities
regulations to audit a charity’s statement of accounts. As part of our audit work
in the current year we will provide an opinion over the Council’s registered
charity. The audit fee for this work is not covered in the fee set by Audit
Scotland.  At this stage we anticipate that the fee will be £7,190 based upon a
similar level of work and number of charities as in previous years. If additional
work is required which would result in an additional audit fee, this will be advised
and subject to agreement with Moray Council.
There will be changes to the baseline audit fee due to anticipated increased work
required on the audit and the introduction of new requirements as follows:
• IFRS 16 applies for the first time in 2024/25
• ISA (UK) 600 – Group Financial Statements has been amended
• Additional testing of journals due to lack of authorisation control
• Follow up of significant number of audit recommendations raised in the
2023/24 audit
• Potential recategorisation of Moray Council as a category 2 audit as
expenditure is greater than £500 million.
These are considered in further detail at page 51.
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Audit Fees
The baseline audit fee does not consider any new areas of audit work which
auditors are required to undertake in year. The following additional audit work
will be carried out as part of our 2024/25 audit:
• This is the first year the Council will account for leases in accordance with
IFRS 16. Additional audit work will be required to gain an understanding of
how the Council has accounted for its leases under the new accounting
standard and the relevant disclosures within the financial statements.
• There has been a change to ISA (UK) 600 – Audit of Group Financial
Statements which requires auditors to enhance their understand of the group
component. This will require additional audit work in 2024/25, although the
full extent of our procedures are not yet known.
• Additional work will be carried out due to the higher risk environment at the
Council due to a lack of authorisation controls when journals are posted.
• A high number of audit recommendation were raised in the 2023/24 Audit
Report in relation to our financial statements audit, the wider scope audit, the
Controller of Audit Report and the best value thematic. We are required to
follow each recommendation up in 2024/25 and report on the progress the
Council has made in addressing each recommendation.
• In 2024/25, the Council may have gross expenditure which exceeds £500m. If
this occurs, our audit methodology requires us to recategorize the audit as
Category 2, in line with Financial Reporting Council (FRC) requirements. This
would result in the audit team undertaking addition audit procedures,
including engaging with external auditor’s experts and require our financial
reporting team to undertake a financial review of the financial statements,
known as a hot review.
Moray Council External Audit Plan 2024/25 51
• Grant Thornton methodology allows from 2024/25 onwards that audits under
£500 million expenditure can have materiality up to 2.5%.  The maximum for
audits over £500 million is 2%.  Therefore moving category means there will be
additional testing required, appreciating that the up to 2.5% materiality level
cannot be considered.
Until the work is fully performed on these new areas the full impact is not yet
determined and will be discussed with management and reported in our Annual
Audit Report.
We reserve the right to review our fee during the audit should significant delays
be encountered and/or new technical matters arise.
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Audit Fees (2)
Audit fees for 2024/25
We seek the additional fee to external auditor remuneration due to:
• Additional work required in 2024/25 in relation to new IFRS 16 accounting
requirements, new ISA 600 auditing standard and additional journals work due
to heightened risk
• Follow-up of prior year audit recommendations
• The potential recategorization of the audit (TBC)
At this stage, the extent of the additional work required from all of the above is
not yet determined, and it will be discussed with management and confirmed in
our Annual Audit Report. We therefore note at this stage the external auditor
remuneration is £250,980 (the normal plus the charity) within the total audit fee
of £312,740.
Fee Assumption
In setting the fee for 2024/25 we have assumed that you will:
• prepare a good quality set of accounts, supported by comprehensive and
well-presented working papers which are ready at the start of the audit
• provide appropriate analysis, support and evidence for all critical and
significant judgements and estimates made in preparing the financial
statements
• provide early notice of proposed complex or unusual transactions which could
have a material impact on the financial statements
• provide ongoing access to officers and management experts throughout the
audit and timely responses to audit queries.
• provide all requested information on the best value thematic and wider scope
work to agreed timelines
• provide the housing benefit and non-domestic rates grant claims and
supporting working papers within agreed timescales.
Additional Fees (Non-Audit Services)
Moray Council External Audit Plan 2024/25 52
Service
Fees
(£)
External Auditor Remuneration £243,790
Pooled Costs £6,120
Contribution to Performance Audit and Best Value £58,670
Sectoral cap adjustment -£3,030
2024/25 initial fee (informed by Audit Scotland) £305,550
Trust Fund Charity (not covered in the initial fee) £7,190
Baseline fee for 2024/25 £312,740
Service
Fees
(£)
At planning stage we confirm there are no planned
non-audit services
Nil
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Independence considerations11
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Independence considerations
Ethical Standards and ISA (UK) 260 require us to give you timely disclosure of all significant matters that may bear upon the integrity, objectivity and independence
of the firm or covered persons (including its partners, senior managers, managers). In this context, there are no matters that we are required to report.
As part of our assessment of our independence at planning we note the following matters:
We confirm that there are no significant facts or matters that impact on our independence at planning as auditors that we are required or wish to draw to your
attention and consider that an objective reasonable and informed third party would take the same view. The firm and each covered person have complied with the
Financial Reporting Council’s Ethical Standard and confirm that we are independent and are able to express an objective opinion on the financial statements.
No non-audit services provided by Grant Thornton UK LLP have been identified. Any changes and full details of all fees charged for audit related and non-audit
related services by Grant Thornton UK LLP and by Grant Thornton International Limited network member Firms will be included in our Annual Audit Report at the
conclusion of the audit.
Matter Conclusions
Relationships with Grant Thornton We are not aware of any relationships between Grant Thornton and the Council that
may reasonably be thought to bear on our integrity, independence and objectivity.
Relationships and Investments held by individuals We have not identified any potential issues in respect of personal relationships with the
Council or investments in the Council held by individuals.
Employment of Grant Thornton staff We are not aware of any former Grant Thornton partners or staff being employed, or holding discussions
in respect of employment, by the Council as a director or in a senior management role covering
financial, accounting or control related areas.
Business relationships We have not identified any business relationships between Grant Thornton and the Council.
Contingent fees in relation to non-audit services No contingent fee arrangements are in place for non-audit services provided.
Gifts and hospitality We have not identified any gifts or hospitality provided to, or received from, a member of the Council’s
board, senior management or staff (that would exceed the threshold set in the Ethical Standard).
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Communication of audit matters with
those charged with governance
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Communication of audit matters with those charged
with governance
Our communication plan Audit
Plan
Annual Audit
Report
Respective responsibilities of auditor and management/those charged with governance 
Overview of the planned scope and timing of the audit, form, timing and expected general
content of communications including significant risks and Key Audit Matters 
Planned use of internal audit 
Confirmation of independence and objectivity  
A statement that we have complied with relevant ethical requirements regarding
independence. Relationships and other matters which might be thought to bear on
independence. Details of non-audit work performed by Grant Thornton UK LLP and network
firms, together with fees charged. Details of safeguards applied to threats to independence
 
Significant matters in relation to going concern  
Views about the qualitative aspects of the Group’s accounting and financial reporting
practices including accounting policies, accounting estimates and financial statement
disclosures

Significant findings from the audit 
Significant matters and issue arising during the audit and written representations that have
been sought 
Significant difficulties encountered during the audit 
Significant deficiencies in internal control identified during the audit 
Significant matters arising in connection with related parties 
Identification or suspicion of fraud involving management and/or which results in material
misstatement of the financial statements 
Non-compliance with laws and regulations 
Unadjusted misstatements and material disclosure omissions 
ISA (UK) 260, as well as other ISAs (UK),
prescribe matters which we are required to
communicate with those charged with
governance, and which we set out in the
table here.
This document, the Audit Plan, outlines our
audit strategy and plan to deliver the
audit, while the Annual Audit Report will be
issued prior to approval of the financial
statements and will present key issues,
findings and other matters arising from the
audit, together with an explanation as to
how these have been resolved.
We will communicate any adverse or
unexpected findings affecting the audit on
a timely basis, either informally or via an
audit progress memorandum.
Respective responsibilities
As auditor we are responsible for performing
the audit in accordance with ISAs (UK),
which is directed towards forming and
expressing an opinion on the financial
statements that have been prepared by
management with the oversight of those
charged with governance.
The audit of the financial statements does
not relieve management or those charged
with governance of their responsibilities.
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Delivering audit quality13
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Delivering audit quality (1)
How our strategy differentiates our
service
Our investment in a specialist team,
and leading tools and methodologies
to deliver their work, has set us apart
from our competitors in the quality of
what we do.
The FRC highlighted the following as
areas of particularly good practice in
its recent inspections of our work:
• use of specialists, including at
planning phases, to enhance our
fraud risk assessment
• effective deployment of data
analytical tools, particularly in the
audit of revenue
• clear oversight at group level when
working with component auditors,
including detailed review of working
papers to flush out the critical issues
early.
Our quality strategy
We deliver the highest standards of audit quality by focusing our
investment on:
Creating the right environment
Our audit practice is built around the markets it faces. Your audit team
are focused on the Public Sector audit market and work with clients like
you day in, day out. Their specialism brings experience, efficiency and
quality.
Building our talent, technology and infrastructure
We’ve invested in digital tools and methodologies that bring insight and
efficiency, and invested in senior talent that works directly with clients
to deploy bespoke digital audit solutions.
Working with premium clients
We work with great public and private businesses that, like you, value
audit, value the challenge a robust audit provides, and demonstrate
the strongest levels of corporate governance. We’re aligned with our
clients on what right looks like.
Our objective is to be the best audit firm in the UK for the quality of our
work and our client service, because we believe the two are intrinsically
linked.
Moray Council External Audit Plan 2024/25 58
The right people at the right time
We are clear that a focus on quality,
effectiveness and efficiency is the
foundation of great client service.
By doing the right audit work, at the
right time, with the right people, we
maximise the value of your time and
ours, while maintaining our second-
to-none quality record.
Bringing you the right people means
that we bring our specialists to the
table early, resolving the key
judgements before they impact the
timeline of your financial reporting.
The engagement leader always
retains the final call on the critical
decisions; we use our experts when
forming our opinions, but we don’t
hide behind them.
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Delivering audit quality (2)
Wendy Russell
Partner, UK Head of Audit
Quality underpins everything at Grant Thornton, as our FRC inspection results in the
chart below attest to. We’re growing our practice sustainably, and that means
focusing where we know we can excel without compromising our strong track record or
our ability to deliver great audits. It’s why we will only commit to auditing businesses
where we’re certain we have the time and resource, but, most importantly, capabilities
and specialist expertise to deliver. You’re in safe hands with the team; they bring the
right blend of experience, energy and enthusiasm to work with you and are fully
supported by myself and the rest of our firm.
Good or limited
improvements required
Significant
improvements required
Improvements
required
FRC’s Audit Quality Inspection and Supervision Inspection
(% of files awarded in each grading, in the most recent report for each firm)
0% 20% 40% 60% 80% 100%
Moray Council External Audit Plan 2024/25 59
Digital differentiation
We’re a digital-first audit practice, and our investment in
data analytics solutions has given our clients better
assurance by focusing our work on transactions that carry
the most risk. With digital specialists working directly with
your teams, we make the most of the data that powers
your business when forming our audit strategy.
Oversight and control
Wherever your audit work is happening, we make sure that
its quality meets your exacting requirements, and we
emphasise communication to identify and resolve potential
challenges early, wherever and however they arise. By
getting matters on the table before they become “issues”,
we give our clients the time to deal with them effectively.
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Audit Quality Framework
The Audit Quality Framework (AQF) published by Audit Scotland sets out it’s
approach to achieving high quality  public audit by all auditors and providers. The
AQF is the framework used to provide the Auditor General and the Accounts
Commission with robust, objective, and independent quality assurance, over the
work conducted on their behalf by Audit Scotland and external firms. This work
includes delivering the respective performance audit and Best Value work
programmes and the annual audits of public bodies across Scotland’s public sector.
Audit quality is at the core of public audit in Scotland and is the foundation for
building consistency and confidence across all audit work. High-quality public audit
provides the public, decision-makers, and politicians, with the assurance and
information they need, and it helps Scotland’s Parliament hold public bodies to
account. This is more important than ever when public services face rising demand
and tightening budgets.
Annual Audit Quality Report
Audit Scotland’s Audit Quality and Appointment (AQA) team prepares an annual
Audit Quality Report to provide assurance on audit quality, including compliance
with the Financial Reporting Council’s Ethical Standard, to the Auditor General for
Scotland and the Accounts Commission.
This annual report summarises the AQA’s assessment of audit quality conducted on
audit work, delivered by Audit Scotland and the six appointed firms (including Grant
Thornton UK LLP) on behalf of the Auditor General for Scotland and the Accounts
Commission on the 2022/23 audits. The report provides evidence that auditors have
designed and implemented audit quality arrangements to assure the quality of their
audit work and highlights areas for further improvement.
This report is available at Quality of public audit in Scotland: Annual report 2023/24
and is published on annual basis.
Independent External Reviews
Independent external assurance offers the highest level of assurance to
stakeholders. ICAEW replaced ICAS for 2021/22 independent reviews
following a successful tendering exercise undertaken by Audit Scotland in
2022.
ICAEW review audit files to assess the quality of audit work and
compliance with the International Standards on Auditing (UK), Financial
Reporting Council’s Practice Note 10 and Audit Scotland’s Code of Audit
Practice.
External reviews cover the firms and Audit Directors in Audit Scotland over
a three-year cycle, with the external review results shown within the chart
below for the last five financial years.
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Appendices14
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Appendix 1 - Respective responsibilities
Moray Council
Your responsibilities include: 
• Maintaining adequate accounting records and
working papers
• Preparing accounts for audit, comprising financial
statements, which give a true and fair view, and
related reports
• Establishing and maintaining a sound system of
internal control
• Establishing sound arrangements for proper conduct
of affairs, including the regularity of transactions
• Maintaining standards of conduct for the prevention
and detection of fraud and other  irregularities
• Maintaining strong corporate governance
arrangements and a financial position that is soundly
based
• Establishing and maintaining an effective internal
audit function.
External Audit
Our responsibilities include:
• Compliance with the FRC Ethical Standard
• Compliance with the Code and UK Auditing Standards
(ISA’s UK) in the conduct and reporting of our financial
statements audit
• Compliance with the Code and guidance issued by
Audit Scotland in the conduct and reporting of our
wider scope work
• Providing assurance on specified returns and other
outputs (where required), as specified in guidance
issued by Audit Scotland
• Liaison with and notifying Audit Scotland when
circumstances indicate a statutory report may be
required
• Contributing to relevant performance studies (as set
out in Audit Scotland’s Planning Guidance for
2024/25).
The Code sets out auditor responsibilities and responsibilities of the audited body.  Key responsibilities are summarised
below.  Please refer to the Code for further detail.
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Appendix 2 - The Grant Thornton Digital Audit – Inflo
A suite of tools utilised throughout the audit process
01 Collaborate Ingest Detect
Information requests are uploaded by
the engagement team and directed to
the right member of your team, giving a
clear place for files and comments to be
uploaded and viewed by all parties.
What you’ll see
• Individual requests for all information
required during the audit
• Details regarding who is responsible,
what the deadline is, and a
description of what is required
• Graphs and charts to give a clear
overview of the status of requests
on the engagement
The general ledger and trial balance
are uploaded into Inflo. This enables
samples, analytical procedures, and
advance data analytics techniques to
be performed on the information
directly from your accounting records.
Journals interrogation software which
puts every transaction in the general
ledger through a series of automated
tests.From this, transactions are
selected which display several potential
unusual or higher risk characteristics.
What you’ll see
• Journals samples selected based on
the specific characteristics of your
business
• A focused approach to journals
testing, seeking to only test and
analyse transactions where there is
the potential for risk or misstatement
02 03
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Appendix 3 - New or revised IFRS
Amendments to IAS 21 – Lack of exchangeability
IAS 21 has been amended by the IASB to specify how an entity should assess
whether a currency is exchangeable and how it should determine a spot
exchange rate when exchangeability is lacking. The amendments are effective
in the UK from 1 January 2025.
IFRS 18 Presentation and Disclosure in the Financial Statements
IFRS 18 will replace IAS 1 Presentation of Financial Statements. All entities
reporting under IFRS Accounting Standards will be impacted.
The new standard will impact the structure and presentation of the statement
of profit or loss as well as introduce specific disclosure requirements. Some of
the key changes are:
• Introducing new defined categories for the presentation of income and
expenses in the income statement
• Introducing specified totals and subtotals, for example the mandatory
inclusion of ‘Operating profit or loss’ subtotal.
• Disclosure of management defined performance measures
• Enhanced principles on aggregation and disaggregation which apply to the
primary financial statements and notes.
IFRS 18 will be effective in the UK  from 1 January 2027.Amendments to IFRS 9 and IFRS 7 – Classification and measurement of 
financial instruments
These amendments clarify the requirements for the timing of recognition and
derecognition of some financial assets and liabilities, adds guidance on the
SPPI criteria, and includes updated disclosures for certain instruments. The
amendments are effective in the UK from 1 January 2026.
IFRS 19 Subsidiaries without Public Accountability: Disclosures
IFRS 19 provides reduced disclosure requirements for eligible subsidiaries. A
subsidiary is eligible if it does not have public accountability and has an
ultimate or intermediate parent that produces consolidated financial
statements available for public use that comply with IFRS Accounting
Standards. IFRS 19 is a voluntary standard for eligible subsidiaries and is
effective in the UK from 1 January 2027.
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The following IFRS Standards and amendments have been recently issued but have not yet been adopted by the Code of Audit Practice. Many of the items below will
have limited or nil applicability for the Council but are included for completeness purposes. 
IFRS 17 Insurance contracts
IFRS 17 replaces IFRS 4. IFRS 17 provides consistent principles for all aspects of
accounting for insurance contracts. It removes existing inconsistencies and
enables investors, analysts and others to meaningfully compare companies,
contracts and industries. It has been effective in the UK since 1 January 2023.
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‘Grant Thornton’ refers to the brand under which the Grant Thornton member firms provide assurance, tax and advisory services to their clients and/or refers to one or
more member firms, as the context requires. Grant Thornton International Ltd (GTIL) and the member firms are not a worldwide partnership. GTIL and each member firm
is a separate legal entity. Services are delivered by the member firms. GTIL does not provide services to clients. GTIL and its member firms are not agents of, and do not
obligate, one another and are not liable for one another’s acts or omissions.
Moray Council External Audit Plan 2024/25 65
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Informing the audit risk assessment
for Moray Council 2024/25
Angela Pieri
Director
T 0161 214 6337
E Angela.L.Pieri@uk.gt.com
Andrew Wallace
Manager
T 0141 223 0671
E andrew.d.wallace@uk.gt.com
APPENDIX 2
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The contents of this report relate only to the matters which have come to our attention, which
we believe need to be reported to you as part of our audit process.  It is not a comprehensive
record of all the relevant matters, which may be subject to change, and in particular we cannot
be held responsible to you for reporting all of the risks which may affect your business or any
weaknesses in your internal controls.  This report has been prepared solely for your benefit and
should not be quoted in whole or in part without our prior written consent. We do not accept any
responsibility for any loss occasioned to any third party acting, or refraining from acting on the
basis of the content of this report, as this report was not prepared for, nor intended for, any
other purpose.
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Table of Contents
Section Page
Purpose 4
General Enquiries of Management 6
Fraud 9
Fraud Risk Assessment 10
Laws and Regulations 15
Impact of Laws and Regulations 16
Related Parties 18
Going Concern 20
Accounting Estimates                                                                                            22
Accounting Estimates - General Enquiries of Management 23
Appendix A – Accounting Estimates   26
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Purpose
The purpose of this report is to contribute towards the effective two-way communication between Moray Council's external auditors and Moray
Council’s Audit Committee, as 'those charged with governance'. The report covers some important areas of the auditor risk assessment where we
are required to make inquiries of the Audit Committee under auditing standards.  
Background
Under International Standards on Auditing (UK), (ISA(UK)) auditors have specific responsibilities to communicate with the Audit Committee. ISA(UK)
emphasise the importance of two-way communication between the auditor and the Audit Committee and also specify matters that should be
communicated.
This two-way communication assists both the auditor and the Audit Committee in understanding matters relating to the audit and developing a
constructive working relationship. It also enables the auditor to obtain information relevant to the audit from the Audit Committee and supports the
Audit Committee in fulfilling its responsibilities in relation to the financial reporting process.
Communication
As part of our risk assessment procedures we are required to obtain an understanding of management processes and the Council’s oversight of the
following areas:
• General Enquiries of Management
• Fraud,
• Laws and Regulations,
• Related Parties,
• Going Concern, and
• Accounting Estimates.
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Purpose
This report includes a series of questions on each of these areas and the response we have received from Moray Council’s management. The Audit
Committee should consider whether these responses are consistent with its understanding and whether there are any further comments it wishes to
make.
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General Enquiries of Management
Question Management response
1. What do you regard as the key events or issues that
will have a significant impact on the financial statements
for 2024/25? 
Impact of inflation on staffing costs.
2. Have you considered the appropriateness of the
accounting policies adopted by Moray Council?
Have there been any events or transactions that may
cause you to change or adopt new accounting policies?
If so, what are they?
Accounting Policies are reviewed each year as the Accounts are prepared and charges incorporated when
deemed necessary.
No changes to Accounting Policies are anticipated for the 24/25 Accounts.
3. Is there any use of financial instruments, including
derivatives? If so, please explain No derivatives.
Financial Liabilities – measured at amortised cost and include: Long Term Loans from PWLB and
commercial lenders, Short Term Loans from other Local Authorities, Lease Payables, PPP Contracts, Trade
Payables.
Financial Assets – measured at amortised cost and include: Cash in Hand, Bank Current and Deposit
Accounts, Trade Receivables for Goods and Services Provided.
4. Are you aware of any significant transaction outside
the normal course of business? If so, what are they? Not aware of any.
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General Enquiries of Management
Question Management response
5. Are you aware of any changes in circumstances that
would lead to impairment of non-current assets? If so,
what are they?
Not aware of any.
6. Are you aware of any guarantee contracts? If so,
please provide further details N/A
7. Are you aware of the existence of loss contingencies
and/or un-asserted claims that may affect the financial
statements? If so, please provide further details
N/A
8. Other than in house solicitors, can you provide details
of those solicitors utilised by Moray Council during the
year. Please indicate where they are working on open
litigation or contingencies from prior years?
Further information to be provided under from Legal Team.
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General Enquiries of Management
Question Management response
9. Have any of the Moray Council’s service providers
reported any items of fraud, non-compliance with laws
and regulations or uncorrected misstatements which
would affect the financial statements? If so, please
provide further details
Not aware of any.
10. Can you provide details of other advisors consulted
during the year and the issue on which they were
consulted?
Mercer for Actuarial Services in relation to IAS 19 Employee Benefits.
Arlingclose – Treasury Management Advisers.
11. Have you considered and identified assets for which
expected credit loss provisions may be required under
IFRS 9, such as debtors (including loans) and
investments? If so, please provide further details
Bad Debt Provision for Trade Debtors, Council Tax and Housing Rents will be processed as normal.
No further allowance anticipated in 2023/24
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Fraud
Matters in relation to fraud
ISA (UK) 240 covers auditors responsibilities relating to fraud in an audit of financial statements.
The primary responsibility to prevent and detect fraud rests with both the Audit Committee and management. Management, with the
oversight of the Audit Committee, needs to ensure a strong emphasis on fraud prevention and deterrence and encourage a culture of
honest and ethical behaviour. As part of its oversight, the Audit Committee should consider the potential for override of controls and
inappropriate influence over the financial reporting process.
As Moray Council’s external auditor, we are responsible for obtaining reasonable assurance that the financial statements are free from
material misstatement due to fraud or error. We are required to maintain professional scepticism throughout the audit, considering the
potential for management override of controls.
As part of our audit risk assessment procedures we are required to consider risks of fraud. This includes considering the arrangements
management has put in place with regard to fraud risks including:
• assessment that the financial statements could be materially misstated due to fraud,
• process for identifying and responding to risks of fraud, including any identified specific risks,
• communication with the Audit Committee regarding its processes for identifying and responding to risks of fraud, and
• communication to employees regarding business practices and ethical behaviour.
We need to understand how the Audit Committee oversees the above processes. We are also required to make inquiries of both
management and the Audit Committee as to their knowledge of any actual, suspected or alleged fraud. These areas have been set out in
the fraud risk assessment questions below together with responses from Moray Council’s management.
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Fraud risk assessment
Question Management response
1. Has Moray Council assessed the risk of material
misstatement in the financial statements due to fraud?
How has the process of identifying and responding to
the risk of fraud been undertaken and what are the
results of this process?
How do the Council’s risk management processes link to
financial reporting?
The Council has established risk management, governance and operating procedures to mitigate the
risk of material misstatement in the financial statements. 
The Corporate Risk Register detailing the Council’s principal risks is reviewed by CMT/SMT on a 6
monthly basis with an annual report provided to elected members. Services are also required to maintain
risk registers detailing identifiable risks and mitigating controls. In addition, the Audit and Risk Manager
prepares a risk-based audit plan which considers the Council’s strategic objectives, associated risks and
the views of senior management.
2. What have you determined to be the classes of
accounts, transactions and disclosures most at risk to
fraud?
A risk register is maintained by Accountancy recording risks, controls, etc. In addition, Internal Audit will
also review and test transactions to ensure compliance with Council Regulations and  Procedures. The
use of IDEA, a computer assisted software system is used to analyse and select a sample for testing
3. Are you aware of any instances of actual, suspected
or alleged fraud, errors or other irregularities either
within Moray Council’s as a whole, or within specific
departments since 1 April 2023? If so, please provide
details
No irregularity noted below the £5000 reporting threshold
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Fraud risk assessment
Question Management response
4. As a management team, how do you communicate
risk issues (including fraud) to those charged with
governance?                                                                                        
The Council’s Financial Regulations require all irregularities to be reported to the Audit and Risk Manager.
Principal risks facing the Council are reviewed on a 6 monthly basis by CMT/SMT and the Corporate Risk
Register is then updated accordingly.
5. Have you identified any specific fraud risks? If so,
please provide details
Do you have any concerns there are areas that are at
risk of fraud?
Are there particular locations within Moray Council
where fraud is more likely to  occur?
Not aware of any.
6. What processes do Moray Council have in place to
identify and respond to risks of fraud? Financial Regulations detail that all staff irregularities should be reported to the Audit and Risk Manager.
This is supported by the Policy to Combat Fraud, Theft, Bribery and Corruption and the Whistleblowing
Policy. In addition, the Council participates in the National Fraud Initiative data matching exercise, and also
publicises a point of contact to report fraud or irregularities involving the misuse of council resources.
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Fraud risk assessment
Question Management response
7. How do you assess the overall control environment for Moray
Council, including:
• the existence of internal controls, including segregation of
duties; and
• the process for reviewing the effectiveness the system of
internal control? 
If internal controls are not in place or not effective where are the
risk areas and what mitigating actions have been taken?
What other controls are in place to help prevent, deter or detect
fraud?
Are there any areas where there is a potential for override of
controls or inappropriate influence over the financial reporting
process (for example because of undue pressure to achieve
financial targets)? If so, please provide details
The responsibility for developing and maintaining sound control environment rests with
management. However, the Audit and Risk Manager prepares a risk-based audit plan
which considers the Council’s strategic objectives and associated risks. While the
prevention of fraud and error rests with management through the design and operation of
suitable systems of control, reviews undertaken by Internal Audit will make
recommendations to improve the control environment. Internal Audit also coordinates the
Council’s participation in the National Fraud Initiative, a data matching exercise involving
a range of public sector bodies. This activity is viewed as complementary to other audit
activities, and participation assists Internal Audit in assessing the potential for the
occurrence of fraud and related fraud risk. Testing will primarily be undertaken by the
Services, with Internal Audit undertaking an overview of the process.
In accordance with an Audit and Scrutiny Committee Report, the Internal Audit Section
reviewed the key fraud risks identified within an Audit Scotland Report – Fraud &
Irregularity. Findings detailing risks, mitigating controls and responsible officer(s) were
reported to the Information Assurance Group.
8. Are there any areas where there is potential for misreporting? If
so, please provide details
None known.
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Fraud risk assessment
Question Management response
9. How does Moray Council communicate and
encourage ethical behaviours and business
processes of it’s staff and contractors?
How do you encourage staff to report their concerns
about fraud?
What concerns are staff expected to report about
fraud? Have any significant issues been reported? If
so, please provide details
The Council has a Policy to Combat Fraud, Theft, Bribery and Corruption. This policy is built around a
counter fraud culture supported by practices to deter and detect fraudulent and corrupt activities. It takes
account of the Council’s statutory obligations, including, and in particular, the provisions of the Bribery
Act 2010.
The Council has a statutory responsibility to make arrangements for the administration of its financial
affairs under the direction of a proper officer - the Chief Financial Officer. The Council has incorporated
within its standing orders and procurement procedures, arrangements in respect of contracts for the
supply of services, goods or materials and the execution of works. These ensure that established and
consistent contracting procedures are available for use by the Council, and all procuring officers are
either fully trained or are given support by Procurement Officers as part of the Supported Tender
Process.
The Audit and Scrutiny Committee has a remit which includes ensuring that the highest standards of
probity and public accountability are demonstrated. This involves oversight of internal control processes
as a contribution to good governance and generally supporting an anti-fraud, theft, corruption, and
bribery culture. This Committee considers reports produced by Internal and External Audit on the
Council’s systems; reports which include recommendations to strengthen internal controls and in turn
reduce the risk of fraud and related behaviours going undetected.
.As detailed previously, Managers have an ongoing responsibility for implementing effective systems of
control which secure the legitimacy of expenditure, the safeguarding of assets and income, the reliability
of management information, the accuracy of record keeping and compliance with statutory guidance.
They also have a responsibility to communicate this policy to their staff and ensure established systems
are followed.
Financial Regulations detail that all irregularities should be reported to the Audit and Risk Manager. In
addition, a Confidential ‘whistle blowing’ policy and procedure is in place, enabling employees to raise
any concerns about any aspect of the Council’s work without fear of victimisation, subsequent
discrimination or disadvantage, and in the knowledge that such concerns will be properly investigated
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Fraud risk assessment
Question Management response
12. What arrangements are in place to report fraud
issues and risks to the Audit Committee?
How does the Audit Committee exercise oversight
over management's processes for identifying and
responding to risks of fraud and breaches of internal
control?
What has been the outcome of these arrangements
so far this year?
The Public Sector Internal Audit Standards (PSIAS) applicable to Local Government in Scotland requires
the Audit and Risk Manager to report functionally to the Audit and Scrutiny Committee on various issues
relative to the work of the Internal Audit Service, including special investigations.
The Audit and Scrutiny Committee has a remit which includes ensuring that the highest standards of
probity and public accountability are demonstrated. This involves oversight of internal control processes
as a contribution to good governance and generally supporting an anti-fraud, theft, corruption, and
bribery culture. This Committee considers reports produced by Internal and External Audit on the
Council’s systems; reports which include recommendations to strengthen internal controls and in turn
reduce the risk of fraud and related behaviours going undetected. Functions and makeup of the Audit
and Scrutiny Committee have also been recently reviewed and updated to reflect the requirements of the
Chartered Institute of Public Finance and Accountancy (CIPFA) Position Statement: Audit Committees in
Local Authorities and Police 2022.
13. Are you aware of any whistle blowing potential
or complaints by potential whistle blowers? If so,
what has been your response?
None noted.
14. Have any reports been made under the Bribery
Act? If so, please provide details
None noted.
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Law and regulations
Matters in relation to laws and regulations
ISA (UK) 250 requires us to consider the impact of laws and regulations in an audit of the financial statements.
Management, with the oversight of the Audit Committee, is responsible for ensuring that Moray Council's operations are conducted in accordance
with laws and regulations, including those that determine amounts in the financial statements.
As auditor, we are responsible for obtaining reasonable assurance that the financial statements are free from material misstatement due to fraud or
error, taking into account the appropriate legal and regulatory framework. As part of our risk assessment procedures we are required to make
inquiries of management and the Audit Committee as to whether the body is in compliance with laws and regulations. Where we become aware of
non-compliance or suspected non-compliance we need to gain an understanding of the non-compliance and the possible effect on the financial
statements.
Risk assessment questions have been set out below together with responses from management.
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Impact of laws and regulations
Question Management response
1. How does management gain assurance that all relevant laws
and regulations have been complied with?
What arrangements does Moray Council have in place to
prevent and detect non-compliance with laws and regulations?
Are you aware of any changes to the Moray Council’s
regulatory environment that may have a significant impact on
the Moray Council’s financial statements?
Generally speaking each service area (for example planning, procurement, social work) are
familiar with the statutory regime in which they operate and will keep up to speed with
developments through their professional associations such as CIPFA or SOLAR.
Changes to legislation, consultations and guidance are notified to the Council by the
Scottish Government and are distributed to the relevant departmental area.
The legal section has teams which specialise in different areas of Council activity and will be
involved (at the request of client departments) in the implementation of more complex
changes (such as formation of the IJB) and in any areas where legislation is unclear.
Legal compliance will often be subject to external regulation (for example data protection).
The Councils Scheme of Delegation (detailing the powers given to officers to implement
services under specified legislation) is reviewed annually in line with revised legislative
powers, in consultation with client departments
2. How is the Audit Committee provided with assurance that all
relevant laws and regulations have been complied with?
The Councils Scheme of Delegation (detailing the powers given to officers to implement
services under specified legislation) is reviewed annually in line with revised legislative
powers, in consultation with client departments
3. Have there been any instances of non-compliance or
suspected non-compliance with laws and regulation since 1
April 2024 with an on-going impact on the 2024/25 financial
statements? If so, please provide details
There are some minor data protection breaches that are currently being monitored. These
are unlikely to have an impact on the financial statements.
4. Are there any actual or potential litigation or claims that
would affect the financial statements? If so, please provide
On going asbestos claims
Employee tribunal cases
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Impact of laws and regulations
Question Management response
5. What arrangements does Moray Council have in
place to identify, evaluate and account for litigation
or claims?
The legal section has teams which specialise in different areas of Council activity and will be involved (at
the request of client departments) in the implementation of more complex changes (such as formation of
the IJB) and in any areas where legislation is unclear.
Where necessary external advise will be sought
6. Have there been any reports from other regulatory       
bodies, such as HM Revenues and Customs, which
indicate non-compliance? If so, please provide
details
The on going records management plan from 2022/23
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Related Parties
Matters in relation to Related Parties
Moray Council are required to disclose transactions with bodies/individuals that would be classed as related parties.  These may include:
■ bodies that directly, or indirectly through one or more intermediaries, control, or are controlled by Moray Council;
■ associates;
■ joint ventures;
■ a body that has an interest in the authority that gives it significant influence over the Moray Council;
■ key management personnel, and close members of the family of key management personnel, and
■ post-employment benefit plans (pension fund) for the benefit of employees of the Moray Council, or of any body that is a related party
of the Council.
A disclosure is required if a transaction (or series of transactions) is material on either side, i.e. if a transaction is immaterial from the [type of
body]’s perspective but material from a related party viewpoint then the Council must disclose it.
ISA (UK) 550 requires us to review your procedures for identifying related party transactions and obtain an understanding of the controls that you
have established to identify such transactions. We will also carry out testing to ensure the related party transaction disclosures you make in the
financial statements are complete and accurate.
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Related Parties
Question Management response
1. Have there been any changes in the related
parties including those disclosed in Moray Council’s
2024/25 financial statements?
If so please summarise:
• the nature of the relationship between these
related parties and Moray Council
• Whether Moray Council has entered into or
plans to enter into any transactions with these
related parties
• the type and purpose of these transactions 
No changes
2. What controls does Moray Council have in place
to identify, account for and disclose related party
transactions and relationships?
Senior Officers and Elected Members make annual returns and any significant factors that arise as part
of this process would be factored into the Related Parties Note in the Annual Accounts
3. What controls are in place to authorise and
approve significant transactions and arrangements
with related parties?
Normal procedures following the Authorisation policy would apply – transactions over £25,000 are
checked by the Chief Financial Officer
4. What controls are in place to authorise and
approve significant transactions outside of the
normal course of business?
For significant transactions that are new and outside the normal course of business Committee approval
is required
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Going Concern
Matters in relation to Going Concern
The audit approach for going concern is based on the requirements of ISA (UK) 570, as interpreted by Practice Note 10: Audit of financial
statements and regularity of public sector bodies in the United Kingdom (Revised 2020). It also takes into account the National Audit Office's
Supplementary Guidance Note (SGN) 01: Going Concern – Auditors’ responsibilities for local public bodies.
Practice Note 10 confirms that in many (but not all) public sector bodies, the use of the going concern basis of accounting is not a matter of
significant focus of the auditor’s time and resources because the applicable financial reporting frameworks envisage that the going concern basis
for accounting will apply where the body’s services will continue to be delivered by the public sector. In such cases, a material uncertainty related
to going concern is unlikely to exist.
For this reason, a straightforward and standardised approach to compliance with ISA (UK) 570 will often be appropriate for public sector bodies.
This will be a proportionate approach to going concern based on the body’s circumstances and the applicable financial reporting framework. In
line with Practice Note 10, the auditor’s assessment of going concern should take account of the statutory nature of the body and the fact that the
financial reporting framework for local government bodies presume going concern in the event of anticipated continuation of provision of the
services provided by the body. Therefore, the public sector auditor applies a ‘continued provision of service approach’, unless there is clear
evidence to the contrary. This would also apply even where those services are planned to transfer to another body, as in such circumstances, the
underlying services will continue.
For many public sector bodies, the financial sustainability of the body and the services it provides are more likely to be of significant public
interest than the application of the going concern basis of accounting. Financial sustainability is a key component of value for money work and it
is through such work that it will be considered.
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Going Concern
Question Management response
1. What processes and controls does management have
in place to identify events and / or conditions which may
indicate that the statutory services being provided by
Moray Council will no longer continue?
Regular reporting on the Council’s finances would highlight any conditions which may meant he
Council is no longer to deliver statutory duties. Regular performance reports to Service Committees
would highlight this as well
2. Are management aware of any factors which may
mean for Moray Council that either statutory services will
no longer be provided or that funding for statutory
services will be discontinued? If so, what are they?
Not aware of any
3. With regard to the statutory services currently
provided by Moray Council does Moray Council expect
to continue to deliver them for the foreseeable future, or
will they be delivered by related public authorities if there
are any plans for Moray Council to cease to exist?
Moray Council expects to continue to deliver statutory services
4. Are management satisfied that the financial reporting
framework permits Moray Council to prepare its financial
statements on a going concern basis? Are management
satisfied that preparing financial statements on a going
concern basis will provide a faithful representation of the
items in the financial statements?
The annual accounts will be prepared on a going concern basis and this will provide a faithful
representation of the items included in the financial statements
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Accounting estimates
Matters in relation to accounting estimates
ISA (UK) 540 (Revised December 2018)  requires auditors to understand and assess a body’s internal controls over accounting estimates,
including:
• The nature and extent of oversight and governance over management’s financial reporting process relevant to accounting estimates;
• How management identifies the need for and applies specialised skills or knowledge related to accounting estimates;
• How the body’s risk management process identifies and addresses risks relating to accounting estimates;
• The body’s information system as it relates to accounting estimates;
• The body’s control activities in relation to accounting estimates; and
• How management reviews the outcomes of previous accounting estimates.
As part of this process auditors also need to obtain an understanding of the role of those charged with governance, which is particularly important
where the estimates have high estimation uncertainty, or require significant judgement.
Specifically do Audit Committee members:
• Understand the characteristics of the methods and models used to make the accounting estimates and the risks related to them;
• Oversee management’s process for making accounting estimates, including the use of models, and the monitoring activities undertaken by
management; and
• Evaluate how management made the accounting estimates?
We would ask the Audit Committee to satisfy itself that the arrangements for accounting estimates are adequate.
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Accounting Estimates - General Enquiries of Management
Question Management response
1. What are the classes of transactions, events and
conditions, that are significant to the financial
statements that give rise to the need for, or changes in,
accounting estimate and related disclosures?
Valuation of Property, Plant & Equipment
Valuation of Pension Liability
2. How does the Council’s risk management process
identify and address risks relating to accounting
estimates?
By engaging with experts in each of the areas identified the risk of material misstatement is reduced
3. How does management identify the methods,
assumptions or source data, and the need for changes
in them, in relation to key accounting estimates?
The results of prior year audits are looked at and whether there was any material concerns raised or
amendments made – in those instances accounting estimates would be reviewed
4. How do management review the outcomes of
previous accounting estimates? The results of prior year audits are looked at and whether there was any material concerns raised or
amendments made – in those instances accounting estimates would be reviewed
5. Were any changes made to the estimation processes
in 2024/25 and, if so, what was the reason for these? No
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Accounting Estimates - General Enquiries of Management
Question Management response
6. How does management identify the need for and
apply specialised skills or knowledge related to
accounting estimates?
Each area is looked at in isolation and the skills/knowledge/capacity of relevant Services considered
7. How does the Council determine what control
activities are needed for significant accounting
estimates, including the controls at any service
providers or management experts?
Ensuring that relevant information is provided on time and accurately to ensure that the information received
can be relied upon.
8. How does management monitor the operation of
control activities related to accounting estimates,
including the key controls at any service providers or
management experts?
Regular updates provided by preparers of the Accounts on any issues that arise.
9. What is the nature and extent of oversight and
governance over management’s financial reporting
process relevant to accounting estimates, including:
- Management’s process for making significant
accounting estimates
- The methods and models used
- The resultant accounting estimates included in the
financial statements.
The unaudited accounts are reported to Committee and then again upon completion of the audit. External
Audit reporting also helps to inform on estimates
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Accounting Estimates - General Enquiries of Management
Question Management response
10. Are management aware of any transactions,
events, conditions (or changes in these) that may
give rise to recognition or disclosure of significant
accounting estimates that require significant
judgement (other than those in Appendix A)? If so,
what are they?
Not aware of any additional areas where new estimates would be required to be disclosed.
11. Why are management satisfied that their
arrangements for the accounting estimates, as
detailed in Appendix A, are reasonable?
No major changes required to annual accounts in previous years.
12. How is the Audit Committee provided with
assurance that the arrangements for accounting
estimates are adequate ?
Annual accounts are reported to Full Council
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Appendix A Accounting Estimates
Estimates Method / model used to
make the estimate
Controls used to
identify estimates
Whether
management
have used an
expert
Underlying assumptions:
- Assessment of degree of uncertainty
- Consideration of alternative
estimates
Has there
been a
change in
accounting
method in
year?
Land and
buildings
valuations
Infrastructure/Community
Assets/AUC – DHC
Schools – DRC
Surplus Assets – Fair Value
Council Dwellings - EUV
Information used is
industry standard
information from entities
such us BCIS.
Internal valuers No
Investment
property
valuations
Fair Value Per the Code –
Investment Property
reviewed annually
Internal valuers Follow the Code No
Depreciation Straight line method over the
useful life of the asset
Estates provide useful
life estimates
Internal valuers No
Heritage Assets Insurance valuations/Historic
cost
Yes No
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Appendix A Accounting Estimates
Estimate Method / model used to
make the estimate
Controls used to
identify estimates
Whether
management
have used an
expert
Underlying assumptions:
- Assessment of degree of uncertainty
- Consideration of alternative
estimates
Has there
been a
change in
accounting
method in
year?
Provisions Only one provision – amounts
based on actual amounts
Liaise with HR No Based on information from HR , which is
confirmed annually that it is still at the
right level
No
Accruals Based on actual entries in the
general ledger or from
information from departments
No, but in some
cases estimates
are made by
quantity
surveyors
Most cases are based on general ledger
and no estimates.
Were estimates are provided it will be
based on professional judgement and we
would query if it was materially different
from estimates provided
No
Credit Loss
and
Impairment
Bad Debt Provision – debtors,
council tax, housing rents
Debtors/Housing Rents:
>12 months – provided
in full
6-12 months – 50%
<6 months – 0%
Council Tax:
<12 months – 0%
>12 months – 100%
No Looked at and reviewed each year to see
if the percentages are still appropriate
No
Valuation of
Defined
Based on information from
actuaries
Information provided to
actuaries based on year
Yes Disclosure in accounts regarding the
changes that could happen and the
No
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Appendix A Accounting Estimates
Estimate Method / model used to
make the estimate
Controls used to
identify estimates
Whether
management
have used an
expert
Underlying assumptions:
- Assessment of degree of uncertainty
- Consideration of alternative
estimates
Has there
been a
change in
accounting
method in
year?
Accrued
Income
Based on actual entries in the
general ledger, or from
information from departments
No In most cases based on actual general
ledger entries, so no estimates.
Where estimates are provided it is based
on professional judgement ad we would
query if it was materially different from
estimates provided
No
PFI Liabilities Financial models are used
each year
Financial models are
well established and
were set up in
conjunction with experts
and have been audited
in detail since then
Models used
were set up in
conjunction with
experts – annual
use is by council
staff
No changes considered – process well
established
Yes – Minor
amendment to
incorporate
IFRS 16 Leases
Fair Value of
Assets and
Liabilities
(Financial
Instruments)
In most cases the fair value is
calculated using models
provided by the Councils
treasury management advisers
Use of external expert
information
Yes No
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Report to: Audit and Scrutiny
Committee 
Meeting Date: 7 May 2025  
Report by: Depute Chief
Executive (Education,
Communities and
Organisational
Development)
Report No: GSP004/25/LM      
Author: Louise Marshall Contact Email: performance@moray.gov.uk 
Subject: Local Government Benchmarking Framework 2023-24 Results 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to present a corporate overview of benchmarking
performance data for the period 2023-24. 
1.2  This report is submitted to Committee in terms of Section III A (4) of the Council’s
Scheme of Administration relating to monitoring performance in accordance with the
Council’s performance management framework. 
2.  SUMMARY  
2.1  The Local Government Benchmarking Framework (LGBF) provides evidence of trends
in how resources are allocated, performance of services and levels of customer
satisfaction.   
2.2  At the time of reporting, results have been published for ninety-three indicators.  Two
indicators are no longer collected locally.  The remaining twenty-three results yet to be
published cover attainment, children looked after, developmental milestones,
attendance and exclusion, child protection, council dwellings energy efficiency, gross
value added and carbon emissions. 
2.3  An assessment of relative performance in recent years can be inferred to an extent in
an improving trend up to 2020/21, followed by a drop off in 2021/22, thereafter the
pace of recovery has slowed.  The charts below show that in 2023/24, for indicators
currently published (83), overall, there has been a slight drop in performance with
Item 9.
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indicator result values worsening to a greater margin (53%) than those that have
improved (41%). 
2.4  Assuming no significant change in rankings for the twenty-three indicators yet to be
updated, overall, the position in terms of relative performance will remain similar to
that of 2022/23. 
2022/23 vs 2023/24 
No change        
5 indicators 
Not yet 
Results improved  Results worsened N/A published1           
34 indicators        44 indicators  23 indicators 
3.  RECOMMENDATIONS  
3.1  It is recommended that Committee:   
i)  scrutinise and note the Council’s performance in terms of a corporate
overview of benchmarking results.   
Louise Marshall
30% 28% 28% 18% 23% 18%
17% 19% 24% 34% 22% 19%
28% 24% 27% 24% 28%
20%
25% 29% 20% 24% 27%
22%
22%
0%
20%
40%
60%
80%
100%
2018/19 2019/20 2020/21 2021/22 2022/23 2023/24
LGBF relative performance -national
1st quartile 2nd quartile 3rd quartile 4th quartile N/A
30% 30% 34% 22% 23% 20%
19% 10%
18% 32% 21% 15%
17%
22%
18% 18% 29%
21%
34% 39% 30% 28% 27%
23%
22%
0%
20%
40%
60%
80%
100%
2018/19 2019/20 2020/21 2021/22 2022/23 2023/24
LGBF relative performance -family
1st quartile 2nd quartile 3rd quartile 4th quartile N/A
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Strategy & Performance Manager 
4.  BACKGROUND AND CONTEXT  
4.1  Local Government Benchmarking Framework (LGBF) data is refreshed throughout the
year with the final data published in June that informs the National Benchmarking
Overview Report.  Results are gathered from national sources following annual data
submissions and subject to extensive validation processes, a contributory factor to the
time-lag in publication and reporting.  A small number of results are supplied directly by
local authorities.  The full suite of benchmarking data can be viewed using the
Improvement Service LGBF Dashboard. 
4.2  Family Groups of councils were developed around the type of population that they
service (e.g. relative deprivation and affluence) and the type of area in which they serve
them (e.g. urban, semi-rural, and rural) to allow improvements to be identified and good
practice shared. 
People Services Other Services
Includes education, social work and
housing. The benchmarking clubs are
based on the average social context of
the local authority population (using
data from SIMD).
Includes environmental services and
culture/leisure services. The
benchmarking clubs are based on the
dispersion of the local authority
population (using data for the Grant-
Aided Expenditure indicator for
population dispersion).
Angus
Argyll & Bute
East Lothian
Highland
Midlothian
Moray 
Scottish Borders
Stirling
East Ayrshire
East Lothian
Fife 
Moray
North Ayrshire
Perth & Kinross
Stirling
South Ayrshire 
4.3  Results and commentary on benchmarking performance are included in Quarter 4
performance reports submitted to service committees in line with the Council’s
performance management framework.  
4.4  Caution is advised on making direct comparison between years due to significant impact
of Covid-19 on results. 
5.  PROPOSALS  
5.1  The national context presents a similar picture to that of Moray in the efforts and
achievements delivered against an increasingly challenging backdrop and how sustained
financial and workforce pressures have disrupted performance and efficiency
improvements gained in previous years. 
5.2  Despite challenges, good or improving performance is recognised in crisis grant decision
timescales, older people receiving personal care at home, adult care inspectorate
gradings, hospital re-admission rates, road condition, waste recycling rates, housing rent
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collection and repairs response times.  Generally, indicator results across service areas
are low in cost compared to other local authorities; however, this should be considered
alongside performance and customer results. 
5.3  Of the 106 results published, 23 results are placed in the lowest quartile (ranked 25th to
32nd), these will be scrutinised in relation to improvement by the relevant Service
Committee as part of 2024-25 Quarter 4 Performance Reports submitted to the June
cycle of meetings.  Commentary on these indicators and the service plan actions
undertaken throughout 2024/25 is included at Appendix 1. 
5.4  Sixteen of the 23 indicators have featured in the lowest quartile over several years being:
overall average tariff scores, average total tariff scores Scottish Index of Multiple
Deprivation (SIMD) quintiles 2,3,4 and 5, P1, P4 and P7 pupils combined achieving
expected levels in literacy and numeracy, funded early year provision grading. gender pay
gap, teacher absence, operational building condition, cost of library visit, dwellings
meeting Scottish Housing Quality Standards (SHQS), superfast broadband provision,
ratio of financing costs and actual outturn.   
5.5  Lowest quartile performance was reviewed by the senior management team to ensure
planned word will secure improvement, particularly in the following Corporate Plan
priority areas – 
• Improving attainment for all, a focus within the tackling poverty and inequality priority
is being progressed through the development and implementation of the following
strategy areas that will directly contribute to improved performance results; National
Improvement Framework self-evaluation and Raising Achievement of our Learners,
Our Moray Standard: Learning and Teaching Strategy and Supporting all Learners
Strategy, Moray and Northern Alliance Progressions of Literacy and Numeracy,
Achievement of Curriculum for Excellence Levels Assessment and Moderation
Guidelines, Quality Assurance and Moderation support, Tracking and Monitoring
Guidelines and Moray Quality Improvement Framework.  Devolved school budgets
and wider funding of Scottish Attainment Challenge, Pupil Equity and Strategic Equity
Funding ensure schools continue to work to close identified attainment gaps.
• Tackling the affordability of the school estate whilst meeting climate requirements
contributes to Building Thriving, Resilient, Empowered Communities is addressed
with the development of the Learning Estate Strategy, due to be reported to
committee in September 2025 following completion of a staged programme of
engagements.  The Climate Change Strategy 2020-2030 and Routemap to Net Zero is
subject to review through 2025 by the Climate Change Working Group who will reflect
on progress and update targets with a greater understanding of the decarbonisation
pathway the Council is on, the changes in national policies presenting a final report in
December 2025. 
• Corporate Plan Strategic Framework and improving indicator results rests on the
delivery of the Medium to Long Term Financial Strategy and the Workforce and
Organisational Development Strategy. 
5.6  If rankings of the unpublished indicators remain like previous years, up to six may also
feature in the lowest quartile covering: attainment at level 6, children looked after in a
community setting, looked after children exclusion, council dwellings energy efficiency,
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CO2 emissions within local authority scope and from transport.  Results will be reported
in 2025/26 quarter 2 performance reports to Service Committees.  
5.7  Results that have improved / worsened by 5% from previous year are highlighted at
Appendix 2 and a table of results split by theme is presented at Appendix 3. 
6.  SUMMARY OF IMPLICATIONS  
6.1  The table below shows whether risks and implications apply if the recommendations are
agreed: 
SUBJECT YES NO
Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X 
Policy and Legal  
Financial  
Risk  
Staffing  
Best Value and Transformation  
Property  
Information Communications Technology/Digital  
Equalities. Social Inclusion and Economic Impact   
Climate Change and Biodiversity Impact   
6.2  Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Improved Collaborative Leadership, as part of continuous improvement through Best
Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. 
a) Links to Council Corporate Plan – The proposals in this report support and contribute
to improved outcomes for communities as outlined in the following Council Plan
strategic priorities:
☒ Tackle Poverty and Inequality.
☒ Build Stronger Greener Vibrant Economy.
☒ Build Thriving, resilient, empowered Communities.   
b) Links to Local Outcomes Improvement Plan – The proposals in this report support
and contribute to improved outcomes for communities as outlined in the following
local Outcomes Improvement Plan priorities:
☒ Developing a diverse, inclusive, and sustainable economy
☒ Building a better future for our children and young people in   Moray.
☒ Empowering and connecting communities.
☒ Improving wellbeing of our population 
6.3  Policy and Legal 
The Council has a statutory requirement to publish a range of information that will
demonstrate that it is a securing best value and assist in comparing performance both
over time and between authorities where appropriate.  
6.4  Financial 
None arising from this report.
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6.5  Risk 
None arising from this report although effective performance management assists in
the management of risk.  
6.6  Staffing 
None arising from this report.  
6.7  Best Value and Transformation 
How councils plan for, manage and report on performance is a key area of focus in
external audit work, particularly on best value.  
6.8  Property 
None arising from this report.  
6.9  Information Communications/Technology/Digital 
None arising from this report.  
6.10  Equalities, Social Inclusion and Economic Impact 
None arising from this report.  
6.11  Climate Change and Biodiversity Impacts 
None arising from this report. 
7.  CONSULTATION  
7.1  This report has been prepared in consultation with Head of Governance, Strategy and
Performance and senior managers, any comments made have been incorporated into
the report. 
8.  BACKGROUND PAPERS  
8.1  LGBF Dashboards
National Benchmarking Overview Report 2023/24
Elected Member Guidance: Understanding and Using the LGBF
LGBF Indicators – Pentana backing tables   
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APPENDIX 1 
The Local Government Benchmarking Framework (LGBF) data provides evidence of trends in how resources are allocated, performance
of services and levels of customer satisfaction.  This year’s results introduce data from 2023/24.   
Exceptions based on 32 local authorities; areas of service delivery ranked in the lowest quartile are presented below as Notes to
Benchmarking Results (appendix 3 refers).  Care should be taken when making comparison over time and with others due to the
complexities around altered delivery and operating landscapes during the reporting period. 
The National Benchmarking Overview Report 2023/24 is due to be published early April. 
No Challenges Actions to improve Outcome
Children’s Services  
1 Percentage of leavers entering positive
destinations fell to 93.8% in 2023/24, dropping
into the lowest quartile.  Both national and
family group averages decreased albeit to a
lesser extent.
• Getting it right for every child so that we continue to
improve attainment for all 
Q3 update (65% complete) - Ongoing reporting to
committee with interventions outlined and progress to
date (ECLS in November – Secondary Senior Phase
Attainment and in February – ACEL).  Continue focus on
raising attainment for all in line with resources available. 
• Further develop curriculum offer in senior phase
including consortia arrangements 
Q3 update (65% complete) - Secondary Head Teacher
Consortia sub-group formed and progressed at pace
with almost all secondary schools offering SCQF level 7
(Advanced Higher) consortia offer to other schools
(range of subjects) and some SCQF level 6 (Higher) as
trial.  Reinstatement of common column across Moray,
building into course options with consortia options
process finalised for the session.  Further exploration of
working with Aberdeen City Council through their ABZ
Campus anytime course offer for interrupted
learners/those learners requiring additional subjects.
Improved attainment at both Broad General and Senior
Phase identifies through ACEL and LGBF measures 
Increase in subjects, courses and accreditation 
2,3,4,5,6,7 Tariff scores allow examination of how
different ability cohorts are attaining in
relation to the appropriate family and national
cohorts by allocating a specific number of
points to each qualification (including non-
examination, unit-based courses).  More
demanding qualifications gain more points
than less demanding ones and in graded
courses, a grade ‘A’ is equivalent to more
points than a grade ‘C’ for example, within the
same course.  The number of qualifications
and units available for a young person to
complete varies significantly due to the
number of different curriculum structures
there are across Scotland.  In Moray, scores
decreased overall and in all but one of SIMD
Quintiles 1-5.  Indicator rankings remain in the
lowest quartile.
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(Source: Education Service Plan 2024-25)
8,9 The percentage of P1, P4 and P7 pupils
combined achieving expected CFE Levels in
Literacy and Numeracy made further
improvement to 70.6% and 76.5%
respectively, exceeding Stretch Aims targets
and gaining ground on national averages. 
Support and challenge discussions between
the central Quality Improvement Team and
Head Teachers.  Roll-out of Seemis Progress
and Achievement for Tracking and Monitoring
was completed in June 2023 and a data
analysis tool (AnalyseM) was developed and
training completed in December 2023. 
Indicator rankings remain in the lowest
quartile.
• Early intervention addressing whole family well-being
to ensure that children can reach their full potential 
Through assessment and moderation activities,
QAMSO (Quality Assurance and Moderation Support
Officer) supports at school and ASG level as well as
central quality improvement monitoring, we continue
to support and challenge BGE ACEL level achievement
and strengthening of practitioner confidence in their
Teacher Professional Judgements. This includes
through ASG moderation activities, Inset activities and
a well planned range of interventions delivered at
school level in order to strengthen learner attainment
and achievement. 
Ongoing work to build and maintain improvement is
detailed in the Initial Analysis of Achievement of
Curriculum for Excellence Levels 2024 submitted to
Education, Children’s and Leisure Service Committee
on 18 February 2025 (item 10 of the agenda refers). 
(Source: Education Service Plan 2024-25)
Improved attainment at both Broad General and Senior
Phase identifies through ACEL and LGBF measures 
10 Funded early years provision which is graded
good/better fell slightly to 84.1%.  The increase
duty brings significant challenges around
workforce expansion, building and expanding
provision, whilst simultaneously maintaining
and improving the quality is challenging, faced
with significant shortages in the availability of
qualified staff and seeing the average
experience level of the workforce lowered.
Indicator ranking remains in the lowest
quartile. 
Early years provision not reaching grade 4 good/better
receive support from the respective Continuous
Improvement Officer and the Early Years Teaching and
Learning Teacher to address the required actions
resulting from recommendations or requirements.  
Improve quality of leadership, learning, teaching and
assessment 
Improve self-evaluation profiles leading to change
Corporate Services  
11 The gender pay gap closed slightly from 5.3%
to 4.6%.  The gap is the percentage difference
between men’s and women’s hourly pay.  The
positive figure indicates that male employees
• Have in place fair and competitive pay and
conditions that are recognised and free of bias 
Assessment of gender pay gap and equality issues
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are on average paid more per hour than female
employees.  Despite these small
improvements, the result remains in the
bottom quartile.
Note: an error was made when submission of
results was reversed, therefore the national
data does not reflect the true position which
has been corrected for local reporting.
Albeit progress has been affected by staff absence,
with progress on planned activity at 30% complete (Q3
update), slight improvement is accounted for due to
continuing to offer flexible working opportunities to the
workforce which encourages and supports females. 
Additionally with the regrading of Social Care
Assistants, the council has seen a positive impact on
the gender pay gap and this is supported by an
increased number of females represented in Grade 10
and above posts.  Work is rescheduled to begin in
January 2025. 
(Source: HR & OD Service Plan 2024-25)
12 Teacher absence levels increased in 2023/24
to 9.6 days per teacher and are now higher
than pre-pandemic levels and the highest
recorded since benchmarking began. 
Pressures exacerbated by the pandemic,
treatment delays and increasing mental health
issues are compounded by skills shortages
and recruitment challenges, all contributory
factors to increased absence.  Indicator
ranking remains in the lowest quartile.
Policy and practise review as well as supporting and
developing wellbeing initiatives continue in response to
these significant challenges. 
• Pro-actively support the health and well-being of
employees through increased awareness of mental
health.
• Review proactive measure to reduce sickness
including Day One notification for focus on short term
absence.
• Ensure revised operational implementation of
absence management procedures are applied by
managers.
• Provide support for reducing incidents of violence and
aggression in schools as set out in the agreed ASN
action plan, working collaboratively with Trade Unions
to identify specific actions to help address short term
absence. 
Q3 update (75% complete) - Work is ongoing to devise a
more targeted approach that will address absence.
Improvements around implementing the policy at an
operational level has been discussed at both the
leadership forum and with the HR Advisers. A pilot has
also been developed within Education which if rolled
out could have some meaningful impact to the
monitoring of absence within schools. A training and
Absence is managed effectively, and levels of absence
are reduced efficiently and timeously. 
Measures are deployed that support school-based
staff to feel safe at work and feel equipped to manage
challenging behaviour appropriately.
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refresher module is in development and monthly
absence review meetings are in place, supported by a
revised approach to case flow management allowing for
improved monitoring and prioritisation. 
(Source: HR & OD Service Plan 2024-25)
13 Percentage of invoices sampled that were paid
within 30 days remained unchanged at 89.4%. 
Of the 55k invoices sampled, 49k invoices
were paid within 30 days, resulting in the
indicator dropping back into lowest quartile.
• Increase efficiency and availability of digital process
for Payments; roll out e-Accounts Payable form 
Q3 update (100% complete) – E-Accounts Payable form
now fully LIVE across all departments, any service
submitting paper or email invoices are being advised to
use the new system. 
(Source: Finance Service Plan 2024-25)
Roll out e-Accounts Payable form Introduction of
workflow to streamline process for Payments and
service departments. 
More efficient and timely processing of invoices.
Assets  
14 There has been no change to 56.3% in the
percentage of internal floor area of operational
buildings in satisfactory condition.  The Moray
Learning Estate is a significant contributory
factor to the operational building condition
indicator and with half of the 53 schools
having condition surveys and 31 categorised
within the last 5 years as less than B condition
(6 schools still to complete survey updates). 
Indicator ranking remains in the lowest
quartile.
• Tackle the affordability and standard of our learning
estate to ensure sustainability while meeting climate
requirements 
External consultant appointed to commence
development of detailed asset management plans for
up to 10 schools over a 6-month period with further
planned for 2025/26.
Moray Learning Estate Strategy 2022-2032 sets out the
steps needed to develop a long-terms strategy for the
learning estate. 
(Source: ERC Service Plan 2024-25)
Moray has high performing schools that are fit for the
future and financially and environmentally sustainable.
Adult Social Work
15 The percentage of carers who feel supported
in their caring role fell from 32% in 2021/22 to
28% in 2023/24.  Indicator ranking has
dropped into the lowest quartile.
Taken as an extract from the Health & Care Experience
Survey by Scottish Government.  Moray Carers
Strategy 2023-2026 contains three strategic priorities;
Recognition for carers, Valuing carers, Supporting
carers.  Quarriers are contracted to continue
delivering information, support, advice and to offer
both Adult Carer Support Plans and Young Carer
Statements.  As of March 2024, 1130 unpaid adult and
Carers in Moray feel recognised, listened to and
respected as equal and expert partners in care, and to
be supported in their vital role so they live well
alongside caring.
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170 young carers registered with the service, of which
16 and 15 were receiving intense support respectively.
Culture & Leisure  
16 The cost per library visit has decreased to
£5.44 due to a proportionately greater
increase in the number of library visits to net
expenditure.  The service reviewed the virtual
visit definition for this indicator in 2022/23 and
are now counting launches or interactions
with a page / post rather than the number
having seen a page / post.  Across Scotland,
results range, perhaps suggesting there are
similar variations in calculation methods.  At
the time of submitting attendance results,
Indicator ranking remains in the lowest
quartile.
• Transform our Sport & Leisure, Libraries, Learning
Centres & Heritage, Music Instruction & Performance
service provision to ensure a sustainable council for
the future 
Q3 update (93% complete) – The Change Management
Plan has now been partially implemented.  Several
proposals for Change Management Plan have been
paused until the outcome of the Libraries, Learning
Centres and Heritage service redesign and savings
proposals have been determined. 
(Source: ERC Service Plan 2024-25)
Create a sustainable future for our services by: 
Engaging new users to access our service to be active
and ensure prevention/early intervention improves
their long-term health and wellbeing prospects. 
Engaging new users to access digital and physical
resources and support to improve their lifelong learning
experiences. 
Creative arts participation and pathways are further
developed enhancing lifelong learning experiences.
17 The percentage of adults satisfied with
Museums and Galleries (rolling 4 years) fell
slightly to 57%.  Indicator ranking dropped into
the lowest quartile for the first time since
2018.
Due to budgetary constraints, operation of the Moray
Museum Service ceased on 1st April 2020 and the
Falconer Museum with Store is closed until an
alternative service model is established.  The
collection continues to be monitored and the buildings
maintained.
N/A
Environmental Services
18 The percentage of adults satisfied with refuse
collection (rolling 4 years) remained at 76%. 
Indicator has dropped back into the lowest
quartile.
Taken from the Scottish Household Survey from
Scottish Government where around 10,500 households
were interviewed with lower-than-expected response
rates inferring the sample size may be small.  Following
an increase in complaints related to household
collections, the service is reviewing to identify themes
and causation.
N/A
Housing Services  
19 In 2023/24, 1,444 of 6,380 (22.6%) properties
within scope met the Scottish Housing Quality
Standards (SQHS). Meeting energy efficiency
elements is a significant part of SHQS. 
Indicator remains in the lowest quartile.  
• Continue to reduce the carbon impact arising from
Housing and Property Services 
Q3 update (75% complete) – Housing Improvement
Plan reported to Housing and Community Safety
Committee on 7 May 2024 detailed plan to improve
energy performance of our housing stock. Work
Phased improvement of energy efficiency within
corporate buildings and housing stock.
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progressing by internal contractor (DLO) and external
contractors to undertake improvements. Final figure
will be reported as part of the Annual Return on the
Charter (ARC) to the Scottish Housing Regulator in
April 2025. Significant investment has been undertaken
extending to more than £6m on a variety of
improvement measures including insulation and
upgrading heating systems. Due to time lag in updating
certification and method of reporting no interim figures
are currently available that accurately present
progress. 
(Source: Housing and Property Service Plan 2024-25)
Economic Development  
20 The percentage of unemployed people
assisted into work from Council operated /
funded employability Programmes more than
halved to 4.3% with 65 people supported into
work.
Delays in confirmation of grant funds resulted in
reduced numbers progressing into MERI Scheme,
coupled with a reduction in applications from
employers due to the inability within the Scheme to
carry forward committed funds.  Delays also meant the
procurement of the new SWAP vocational skills was
later than initially planned with the programme being
active for only 6 of the intended 12 months.  Increasing
client mental health issues has also been a
contributory factor with those affected being further
away from entering employment.   Job outcomes is just
one of many other positive outcomes that were
reported in 2023/24, for example, 90 started the SWAP
programme, 102 engaged with personal development
training and 50 progressed in college / university. 
In the previous 2 reporting years, due to Covid recovery
measures, there was significant additional investment
in employability, so higher-than-average numbers being
assisted into employment were reported.   
With these challenges resolved for the 2024/25
reporting, figures to date show Job outcomes have
increased, with the SWAP programme having a positive
impact on results, the overall position continues to be
closely monitored.
Increase the number of individuals who are
participating in learning, training and employment
opportunities
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(Source: Economic Growth and Development Service Plan
2024-25)
21 The proportion of properties receiving
superfast broadband increased slightly to
87.8%.
Taken from Connected Nations Annual Report by
OFCOM.  According to a Scottish Government
response, the rollout of the R100 broadband scheme
will not be completed until 2028 in Moray.  The
programme is behind on initial time targets, The
programme comprises of three strands of activity, the
R100 contracts, R100 Scottish Broadband Voucher
Scheme and continued expansion of commercial
coverage, including emerging technologies such as
Low Earth Orbit satellite connectivity.
Conclude R100 contract delivery in Moray during 2028
Financial Sustainability  
22 Financing Costs to Net Revenue Stream is an
indicator of affordability, it highlights the
revenue implications of existing and proposed
capital expenditure by identifying the
proportion of the revenue budget required to
meet financing costs, net of investment
income.  Moray reported a ratio of 8.7. 
Indicator remains in the lowest quartile.
Prudential Indicators are reported to Council and
reflective the ongoing general requirement to increase
borrowing to fund capital expenditure in the capital
plan, particularly in the Learning Estate and the Moray
Growth Deal.  This is factored into the Council’s
financial planning and is used as a tool for assessing
affordability of the capital plan,
Ensure a financially sustainable future
23 The need for budgets and forecasts to reflect
actual spending becomes increasingly
important with decreasing or lower levels of
usable reserves to draw on and is measured in
the Actual outturn as a percentage of
budgeted expenditure.  Moray achieved an
Actual outturn of 97.1%.  Indicator remains in
the lowest quartile.
Patterns of budgeting spend are impacted across all
local authorities, albeit in different ways, although an
increase in the level of reserves held was a common
feature.  Budget manager training, key to an accurate
forecast was reviewed and updated.
Ensure a financially sustainable future 
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APPENDIX 2 
Results improved / worsened (past 12 months for results published)                 
Results that improved by 5% or >
• The cost per Pre-School Education place reduced by 10% to £9,834, a 4% reduction
in gross expenditure and a 6% increase in number of places contributory factors.
• Tariff score in SIMD Quintile 2 improved by 7% to 620, albeit result remains in
lowest quartile.
• 14% reduction in the cost of collecting Council Tax per dwelling, due to an overall
cost reduction and a slight increase in the number of dwellings.
• An initial decision was made within 15 days for almost all Community Care Grants. 
• Proportion of Discretionary Housing Payments spent increased to 90%.
• Reduced gross expenditure and a minor change in the number of long-stay
residents supported has led to a reduction in the residential care home cost per
week per resident.
• Proportion of adult care services graded good or better improved to 81%.
• The number of bed days people (75+) spend in hospital when ready to be
discharged fell by 44%, against a slight increase in population (+75) leading to an
improved delayed discharge rate.  
• Increased attendance and reduced net expenditure resulted in a reduced cost per
attendance at sports facilities.
• Proportionately greater increase in number of library visits than net expenditure
reduced the cost per library visit.
• Reduced cost of street cleaning due to decrease in net expenditure against a slight
increase in estimated population.
• Decreases in gross expenditure in Trading Standards and Environmental Health, has
resulted in a decrease in cost per 1,000 population across both indicators.
• Slight improvement in proportion of council dwellings meeting SHQS, the indicator
remains in the lowest quartile. 
Results that worsened by 5% or >
• Tariff scores dropped in five of six measures, and by over 5% in SIMD Quintile 1.  All
feature is the lowest quartile.
• Sickness absence days for both Teacher and Employee (non-teacher) have
increased, due to an increase in days lost and reduction (teachers) or minimal
change to staff numbers.
• £490k of Scottish Welfare Fund budget was spend, 112% of budget.
• Homecare costs per hour for people aged 65 or over increased with a 27% increase
in homecare expenditure against a slight increase in care hours.
• Satisfaction relating to adult social care dropped in all four measures, and by over
5% in two measures.
• Proportionately greater increase to parks and open spaces net expenditure than that
of mid-year population estimate resulting in a greater cost per 1,000 population.
• Cost of roads per kilometre increased slightly due to rise in gross expenditure, the
indicator result remains in the top quartile.
• Drop in proportion of adults satisfied with street cleaning based on 3 year rolled
averages.
• The percentage of unemployed people assisted into work from council
employability programmes reduced by over 50% dropping into the lowest quartile.
• Average time per business and industry planning application (weeks) increased
slightly but result remains within the top quartile. 
• Gross expenditure on Economic Development & Tourism decreased from £8.2m to
£7.4m, reducing investment per 1,000 population to £78k, performance remains
below the national average and in the bottom quartile.
• Total usable reserves as a percentage of annual budgeted revenue dropped to 19%. 
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APPENDIX 3 
Table Legend
Relative Change Short Term Trend Rank 2021/22
2020/21 to 2021/22 Result to Previous Year Local Authorities (32) Family Group (8)
Result improving by 5% or more  improved 1st quartile 1st quartile
Result worsened by 5% or more  worsened 2nd quartile 2nd quartile  
no change
3rd quartile  3rd quartile
N/A1  Data no longer collected nationally / locally
N/A2 Result below 5; not published to protect confidentiality
N/A3 Data not yet published
4th quartile 4th quartile 
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Overview of Local Government Benchmarking Framework Indicator Results 
Note Indicator Description
Moray National
Average
Relative
Change
2022/23 to
2023/24
Rank
2023/24
2019/20 2020/21 2021/22 2022/23 2023/24 2023/24 %
change 
Short
Term
Trend
Nat
(32)
FG
(8)
Children’s Services (A) 
CHN 1: Cost per primary school pupil (£) 6,050 6,156 6,500 6,926 6,922 7,213 -0.1  9 2 
CHN 2: Cost per secondary school pupil (£) 8,592 8,381 8,458 8,828 8,920 8,957 1.0  15 4 
CHN 3: Cost per pre-school education place (£) 6,127 8,623 10,476 10,897 9,834 11,659 -9.8  5 3 
CHN% of secondary pupils achieving 5 or more
awards at Level 5 62 66 63 62 N/A3               
% of secondary pupils achieving 5 or more
awards at Level 6 34 34 30 28 N/A3               
% of pupils living in the 20% most deprived areas
Gaining 5+ awards at Level 5 N/A2 19 19 12 N/A3               
% of pupils living in the 20% most deprived areas
Gaining 5+ awards at Level 6 N/A2 19 19 12 N/A3               
Gross Cost of “Children Looked After” in
Residential Based Services per child per week (£) 5,748 5,417 4,564 3,155 N/A3               
Gross Cost of “Children Looked After” in a
Community Setting per child per week (£) 503 463 492 460 N/A3               
% of children being looked after in the community 81.4 82.2 80.6 75.3 N/A3               
% of adults satisfied with local schools (rolling 4
years) 77.0 79.3         79.3  76.7 73.0 70.7 -3.7  14 5
1 % of pupils entering positive destinations 93.1 94.1 96.2          95.1 93.8          95.7 -1.3  30 7
2 Overall average total tariff  799 877 886 841 831 918 -1.2  26 7
3 Overall average total tariff SIMD Quintile 1 939 887 735 571 378 658 -33.8  29 8
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Note Indicator Description
Moray National
Average
Relative
Change
2022/23 to
2023/24
Rank
2023/24
2019/20 2020/21 2021/22 2022/23 2023/24 2023/24 %
change 
Short
Term
Trend
Nat
(32)
FG
(8)
4 Overall average total tariff SIMD Quintile 2 687 635 637 581 620 762 6.7  30 7
5 Overall average total tariff SIMD Quintile 3 729 868 868 820 780 889 -4.9  31 7
6 Overall average total tariff SIMD Quintile 4 836 954 944 921 917 1,049 -0.4  29 7
7 Overall average total tariff SIMD Quintile 5 903 959 1,005 977 970 1,260 -0.7  29 7
8 % P1, P4 & P7 pupils combined achieving
expected CFE Level in Literacy N/A1 63.9 65.1 67.9 70.6 74.0 2.7  28 6
9 % P1, P4 & P7 pupils combined achieving
expected CFE Level in Numeracy N/A1 67.8 71.8 75.5 76.5 80.3 1.0  28 6 
Literacy Attainment Gap (P1,4,7 combined) –
percentage point gap between the least and most
deprived pupils
N/A1 19.8 26.3 32.1 N/A3               
Numeracy Attainment Gap (P1,4,7 combined) –
percentage point gap between the least and most
deprived pupils
N/A1 17.5 24.7 26.6 N/A3               
% of children meeting developmental milestones 95.6 96.0 84.9 87.3 N/A3              
10 % of funded early years provision which is graded
good/better  78.3 85.2 86.9 87.5 84.1 89.8 -3.4  28 7 
School attendance (%) N/A1 93.8 N/A1 91.2 90.8 90.3 -0.4  12 3 
School attendance rates (LAC, %) N/A1 89.4 N/A1 83.4 N/A3               
School exclusion rates per 1,000 pupils N/A1 14.2 N/A1 20.2 N/A3               
School exclusion rates per 1,000 looked after
children N/A1 125.0 N/A1 156.0 N/A3              
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Note Indicator Description
Moray National
Average
Relative
Change
2022/23 to
2023/24
Rank
2023/24
2019/20 2020/21 2021/22 2022/23 2023/24 2023/24 %
change 
Short
Term
Trend
Nat
(32)
FG
(8) 
% participation for 16-19 year-olds 93.5 91.8 91.6 94.5 93.1 92.7 -1.4  17 7 
% of child protection re-registrations within 18
months 7.5 2.3 9.8 0          N/A3               
% LAC with more than 1 placement in the last
year (Aug-July) 25.0 14.9 14.5 11.8          N/A3               
% of children living in poverty (after housing
costs) 23.4 21.3 24.1 23.9          N/A3              
Corporate Services (B) 
Support Services as a % of Total Gross
Expenditure 4.2 4.1 3.9 3.8 3.7 4.1 -0.1  14 5 
% of the highest paid 5% employees who are
women 54.7 61.1 62.7 59.5 61.2 59.8 1.7  10 4
11 The gender pay gap (%) 6.4 6.2 7.0 5.3 4.6 1.7 0.8  29 7 
Cost of collecting Council Tax per dwelling 10.12 9.24 8.67 7.96 6.86 5.89 -13.8  17 4
12 Sickness Absence days per Teacher 6.8 4.5 6.0 7.9 9.6 7.6 21.4  29 7 
Sickness Absence days per Employee (non-
teacher) 12.7 8.7 11.1 12.8 14.0 13.9 8.9  17 5 
% of income due from Council Tax received by the
end of the year 97.0 95.8 96.7 96.7 96.2 95.5 -0.5  16 5
13 % of invoices sampled that were paid within 30
days 87.3 84.0 85.5 89.4 89.4 93.1 0.0  26 6 
% of Crisis Grant Decisions within 1 day
Note: 2024/25 result 99.5%  94.3 98.5 98.3 97.8 98.3 94.0 0.5  13 4 
% of CCG Grant Decisions within 15 days
Note: 2024/25 result 100.0%  85.3 91.0 95.0 89.3 98.0 83.3 8.7  15 5
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Note Indicator Description
Moray National
Average
Relative
Change
2022/23 to
2023/24
Rank
2023/24
2019/20 2020/21 2021/22 2022/23 2023/24 2023/24 %
change 
Short
Term
Trend
Nat
(32)
FG
(8) 
Proportion of SWF Budget Spent 84.3 64.3 99.0 123.9 111.5 128.9 -12.4  22 5 
Proportion of DHP Funding Spent 91.3 90.6 75.6 79.8 90.0 101.0 10.2  23 4
Assets
(B) 
% of operational buildings that are suitable for
their current use 98.2 98.2 97.6 97.5 97.4 85.5 -0.1  1 1
14 % of internal floor area of operational buildings in
satisfactory condition 53.9 66.9 54.9 56.3 56.3 89.8 -0.0  32 8
Adult Social W
ork (A) 
Home Care costs per hour for people aged 65 or
over (£) 40.98 32.30 26.74 25.27 31.5 33.61 24.7  12 4 
Self-Directed Support spend on people aged 18
or over as a % of total Social Work spend on
adults
4.1 5.0 3.6 4.6 4.8 9.0 0.2  20 6 
% of people aged 65 or over with long term care
needs receiving personal care at home 62.2 62.0 61.0 59.8 62.7 62.6 2.9  17 3 
% of adults supported at home who agree that
their services and support had an impact in
improving or maintaining their quality of life
(rolling 4 years)
79.2  73.3  69.3 69.8 -3.9  19 7 
% of adults supported at home who agree that
they are supported to live as independently as
possible
82.7  79.3  71.9 72.4 -7.5  21 6 
% of adults supported at home who agree that
they had a say in how their help, care or support
was provided
79.7  70.2  59.5 59.6 -10.7  20 7
15 % of carers who feel supported in their caring role 30.7  31.6  28.2 31.2 -3.4  26 7
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Note Indicator Description
Moray National
Average
Relative
Change
2022/23 to
2023/24
Rank
2023/24
2019/20 2020/21 2021/22 2022/23 2023/24 2023/24 %
change 
Short
Term
Trend
Nat
(32)
FG
(8) 
Residential costs per week per resident for
people aged 65 or over (£) 461 578 490 673 556 723 -17.5  4 1 
Rate of readmission to hospital within 28 days per
1,000 discharges (%) 77.7 100.9 85.9 80.5 76.5 103.9 -4.9  4 1 
Proportion of care services graded ‘good’ (4) or
better in Care Inspectorate inspections (%) 75.2 79.8 80.0 74.0 81.1 77.0 7.1  15 4 
Number of days people spend in hospital when
they are ready to be discharged, per 1,000
population (75+)
768 493 778 1058 952 846 -10.0  21 6
Culture & Leisure (B) 
Gross cost per attendance at Sports facilities (£) -0.31 21.74 2.94 2.58 1.80 4.35 -30.1  5 2
16 Cost per Library visit (£) 1.81 3.42 3.04 6.91 5.44 2.38 -21.3  28 6 
Cost of Museums per visit (£) 2.41 N/A1 N/A1 N/A1 N/A1     
Cost of Parks & Open Spaces (£) per 1,000
population 12,669 14,080 16,874 16,779 18,010 23,362 7.3  8 2 
% of adults satisfied with Libraries (rolling 4 years) 77.6 82.9 82.3 79.3 78.0 67.0 -1.3  5 3 
% of adults satisfied with Parks and Open Spaces
(rolling 4 years) 82.4 85.1 85.7 86.3 85.3 85.0 -1.0  16 5
17 % of adults satisfied with Museums and Galleries
(rolling 4 years) 60.1 64.1 62.3 58.3 57.0 69.3 -1.3  26 8 
% of adults satisfied with Leisure Facilities (rolling
4 years) 66.7 72.4 74.7 71.3 69.7 67.0 -1.6  13 5
Enviro
nment
al
Servic
es (B)  Net cost per Waste collection per premises (£) 44.98 40.42 37.41 41.08 39.97 78.72 -2.7  2 1 
Net cost per Waste disposal per premises (£) 114.45 118.54 112.75 104.35 101.81 104.38 -2.4  13 3
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Note Indicator Description
Moray National
Average
Relative
Change
2022/23 to
2023/24
Rank
2023/24
2019/20 2020/21 2021/22 2022/23 2023/24 2023/24 %
change 
Short
Term
Trend
Nat
(32)
FG
(8) 
Net Cost of Street Cleaning (£) per 1,000
population 8,602 8,594 9,011 9,481 8,376 15,961 -11.6  4 1 
Street Cleanliness Score N/A1 N/A1 N/A1 N/A1 N/A1     
Cost of Maintenance per Kilometre of Roads (£) 8,019 4,998 5,708 6,801 7,337 13,788 7.9  6 1 
% of A Class roads that should be considered for
maintenance treatment (rolling 2 years) 29.2 26.6 23.2 24.1 26.8 28.9 2.7  13 3 
% of B Class roads that should be considered for
maintenance treatment (rolling 2 years) 25.8 22.3 18.3 18.4 21.0 32.5 2.6  5 1 
% of C Class roads that should be considered for
maintenance treatment (rolling 2 years) 25.2 21.3 19.3 20.6 22.7 33.4 2.1  5 1 
% of unclassified roads that should be
considered for maintenance treatment (rolling 2
years)
35.5 35.0 32.0 30.3 29.3 36.2 -1.0  3 1 
Cost of trading standards and environmental
health (£) per 1,000 population 23,342 22,203 26,647 24,759 23,513 22,804 -5.0  18 6 
Cost trading standards, money advice & citizens
advice (£) per 1,000 population 6,050 5,548 5,484 6,246 5,715 7,266 -8.5  10 3 
Cost of environmental health (£) per 1,000
population 17,292 16,656 21,163 18,514 17,799 15,538 -3.9  21 6 
% of total household waste arising that is
recycled 59.0 54.9 52.2 57.8 55.2 43.5 -2.6  4 2
18 % of adults satisfied with refuse collection (rolling
4 years) 73.5 69.8 71.7 76.0 75.7 78.3 -0.3  25 7 
% of adults satisfied with street cleaning (rolling 4
years) 58.6 58.3 58.7 62.7 57.7 58.0 -5.0  23 8
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Page 210

Note Indicator Description
Moray National
Average
Relative
Change
2022/23 to
2023/24
Rank
2023/24
2019/20 2020/21 2021/22 2022/23 2023/24 2023/24 %
change 
Short
Term
Trend
Nat
(32)
FG
(8)
Housing Services (A)  Gross rent arrears (all tenants) as at year end as a
% of rent due for the reporting year 2.6 3.2 3.8 4.5 4.7 9.5 0.2  2 1 
% of rent due in the year that was lost due to
voids 0.9 1.2 1.2 1.0 0.7 1.8 -0.3  5 1
19 % of council dwellings meeting Scottish Housing
Quality Standard 90.7 93.8 6.3 15.5 22.6 77.8 7.1  26 6 
Average number of days to complete non-
emergency repairs 9.5 6.1 8.0 5.7 5.7 10.0 -1.3  2 1 
% of council dwellings that are energy efficient 54.6 57.4 60.4 N/A3 N/A3     
Economic Development (B)
20
% Unemployed People Assisted into work from
Council operated / funded Employability
Programmes
0.6 5.3 5.9 10.1 4.3 12.1 -5.8  31 7 
Cost per Planning Application 4,809 5,208 5,624 6,700 6,667 6,679 -0.5  18 2 
Average time (Weeks) per Planning Application 6.4 6.7 6.2 6.3 7.2 10.7 15.5  3 2 
% of procurement spent on local small / medium
enterprises 21.9 23.6 25.2 24.8 23.6 30.7 -1.2  21 5 
No of business gateway start-ups per 10,000
population 16.5 9.6 12.7 11.3 11.0 13.6 -2.7  23 7 
Investment in Economic Development & Tourism
per 1,000 population (£) 38,411 40,456 49,193 86,881 77,786 118,765 -10.5  24 7 
Proportion of people earning less than the living
wage (%) 24.0 21.5 19.4 13.8 14.4 10.2 0.6  14 2
21 Proportion of properties receiving superfast
broadband (%) 84.7 85.7 85.6 87.2 87.8 95.9 0.6  27 8
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Page 211

Note Indicator Description
Moray National
Average
Relative
Change
2022/23 to
2023/24
Rank
2023/24
2019/20 2020/21 2021/22 2022/23 2023/24 2023/24 %
change 
Short
Term
Trend
Nat
(32)
FG
(8) 
Town Vacancy Rates (%) 6.9 10.9 10.6 10.6 14.1 12.3 3.5  22 6 
Immediately available employment land as a % of
total land allocated for employment purposes in
the local development plan 
24.2 34.8 14.9 14.9 14.9 24.5 0.0  20 4 
Gross Value Added (GVA) per capita (£) 23,742 22,380 23,172 24,282 N/A3     
Claimant count as a % of working age population
(%)
Note: 2024/25 result 2.2 
2.5 4.9 3.7 2.4 2.2 3.1 -2.3  7 1 
Claimant count as a % of 16-24 population (%)
Note: 2024/25 result 2.6  3.7 7.1 4.7 3.0 2.7 3.3 -2.5  10 2
Financial
Sustainability (B) 
Total useable reserves as a % of council annual
budgeted net revenue 15.0 25.1 26.3 24.8 19.0 23.9 -5.8  24 4 
Uncommitted General fund Balance as a % of
council annual budgeted net revenue 7.5 7.2 2.2 2.1 2.3 2.3 0.2  14 5
22 Ratio of Financing Costs to Net Revenue Stream 9.5 8.0 8.3 8.7 8.7 5.8 0.0  27 7 
Ratio of Financing Costs to Net Revenue Stream –
Housing Revenue Account 21.5 21.6 20.7 22.0 23.6 20.0 1.6  15 6
23 Actual outturn as a % of budgeted expenditure 96.0 89.6 91.1 93.4 97.1 99.6 3.7  29 7
Climate
Change (B) 
CO2 emissions area wide per capita 4.88 4.0 4.83 4.64 N/A3     
CO2 emissions area wide: emissions within
scope of LA per capita 7.26 6.34 7.17 6.94 N/A3     
CO2 emissions from Transport per capita 37.2 29.6 36.12 44.79 N/A3     
CO2 emissions from Electricity per capita 41.81 30.65 33.6 30.91 N/A3     
CO2 emissions from Natural Gas per capita 46.01 45.98 50.1 45.83 N/A3     
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Page 212

Note Indicator Description
Moray National
Average
Relative
Change
2022/23 to
2023/24
Rank
2023/24
2019/20 2020/21 2021/22 2022/23 2023/24 2023/24 %
change 
Short
Term
Trend
Nat
(32)
FG
(8) 
Page 212