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Agenda Document Pack - Audit and Scrutiny Committee - 18/06/2026

Moray Council · 18 June 2026
Back to Audit and Scrutiny Committee — 18 June 2026 and its agenda

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Audit and Scrutiny Committee 
Thursday, 18 June 2026 
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
Thursday, 18 June 2026 at 09:30. 
BUSINESS 
1. Sederunt 
2. Declaration of Group Decisions and Members Interests * 
3. Minute of meeting of 25 March 2026 7 - 14
4. Written Questions ** 
5. Internal Audit Section Update Report
Report by Service Manager Internal Audit and Risk
15 -
102
6. Internal Audit Review - Milnes High School
Report by Service Manager Internal Audit and Risk
103 -
118
7. Internal Audit Review - Capital Plan Project Review
Report by Service Manager Internal Audit and Risk
119 -
130
8. Internal Audit Review - Common Good Fund
Report by Service Manager Internal Audit and Risk
131 -
148
9. Internal Audit Review - Payroll
Report by Service Manager Internal Audit and Risk
149 -
162
10. Internal Audit Follow Up Review - Adult Social Care
Commissioning
Report by Service Manager Internal Audit and Risk
163 -
186
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11. Internal Audit Annual Report - 2025-26
Report by Service Manager Internal Audit and Risk
187 -
206
12. National Fraud Initiative 2024-25
Report by Service Manager Internal Audit and Risk
207 -
214
13. Best Value Thematic Review 2025-26 - Asset Management
Report by Executive Director Finance, Strategy and Transformation
215 -
248
14. Local Government Benchmarking Framework 2024-25
Results
Report by Executive Director Finance, Strategy and Transformation
249 -
280
15. Guidance on Agenda Items
Report by Executive Director Finance, Strategy and Transformation
281 -
290
16. Grant Thornton - Audit progress report and sector updates
Report by Executive Director Finance, Strategy and Transformation
291 -
314
17. Annual Governance Statement
Report by Chief Executive
315 -
334 
Summary of Audit and Scrutiny Committee functions:
The Committee is responsible for upholding high standards of probity and
public accountability, overseeing the Council’s audit and governance
arrangements, and carrying out scrutiny of service performance and
improvement. Its remit includes reviewing reports from Internal Audit,
Audit Scotland, and the External Auditor; supporting governance, risk
management, internal controls, anti-fraud measures, and financial
procedures; agreeing and monitoring the annual audit plan; and
considering annual assurance and governance statements. It also
scrutinises policy, service delivery, and performance issues where
progress is insufficient, considers improvement themes and
benchmarking information across Council services, reviews findings from
external regulators and corporate improvement frameworks, and from
June 2027 will consider the Council’s draft Annual Accounts before final
approval by the Council.   
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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
5pm three working days prior to the day of the meeting, please see Standing Order
36 for deadlines.  A copy of any written answer provided by the Chair will be
published on the Council’s committee management system by 12pm the day
before the meeting.  The Member who has put the question may, after the answer
has been published, may 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, 25 March 2026 
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 Scott
Lawrence, Councillor Marc Macrae, Councillor Paul McBain, Councillor Neil McLennan,
Councillor John Stuart, Councillor Sonya Warren, Ms Margaret Wilson 
IN ATTENDANCE 
Chief Executive; Executive Director Economy, Enterprise and Operations; Executive
Director Finance, Strategy and Transformation; Service Manager Internal Audit and
Risk; Chief Governance Officer (Monitoring Officer); Head of Education (Chief
Education Officer); Service Manager Building Services; Service Manager Strategic
Planning and Development; Programme Manager Levelling Up Fund; Chief Financial
Officer (Depute S95 Officer) and Caroline O'Connor, Committee Services Officer, all
Moray Council; and Angela Pieri, Grant Thornton - External Auditors 
1.         Chair 
The meeting was chaired by Councillor Scott Lawrence.  
2.         Pre-Election Period 
The Chair reminded the Committee the meeting was taking place during the pre-
election period and that there are restrictions on the Council over publishing material
which could show support for a particular party.  As Council meetings are webcast,
they fall within these restrictions.  
The Chair stated the advice from the Monitoring Officer was that, whilst the
Committee can continue to deal with "business as usual" items, should debate
become overtly political then the Chair may require to intervene.   
3.         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 5 "Internal Audit Section Update Report", Item 10 "Internal Audit
Review - Procurement and Creditor Payments" and Item 11 "Annual Audit Plan for the
Year Ending 31 March 2026", Councillor Gatt stated, for transparency, that he is
Item 3.
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Convener of the Grampian Valuation Joint Board and would be taking part in the
debate.  
With regard to Item 5 "Internal Audit Section Update Report", Item 10 "Internal Audit
Review - Procurement and Creditor Payments" and Item 11 "Annual Audit Plan for the
Year Ending 31 March 2026", Councillors Warren and Macrae stated, for
transparency, that they were members of the Grampian Valuation Joint Board and
would be taking part in the debate.  
4.         Minute of meeting of 19 November 2025 
The minute of the meeting of the Audit and Scrutiny Committee dated 19 November
2025 was submitted for approval.  
The Chair referenced an amendment from Councillor Gatt relating to paragraph 7
"Internal Audit Review - Procurement and Creditor Payments" requesting that the
wording in the third paragraph be amended from "alternative measures" to
"disciplinary measures" to accurately reflect what he had said at the meeting.  The
Chair confirmed he was in agreement with the suggested change.    
Subject to the amendment above, the Committee unanimously agreed the minute of
the meeting.  
5.         Written Questions ** 
The Committee noted that no written questions has been submitted.  
6.         Internal Audit Section Update Report 
The meeting had before it a report by the Service Manager Internal Audit and Risk
providing an update on the work of the Internal Audit Section.  
With reference to audit recommendation 6 of Appendix 6, Councillor Gatt sought
assurance that the practice of pre-signing cheques would not occur in the future.  In
response, the Head of Education (Chief Education Officer) confirmed advice had
been circulated to schools based on the learning from the review that cheques
should not be pre-signed and that all audit recommendations from the Keith
Grammar School were had been implemented. 
The Service Manager Internal Audit and Risk advised that, further to the special
investigation referred to in the report concerning the windows replacement
programme within Building Services, the surplus windows have now been disposed of
in accordance with the Council’s Financial Regulations.  
Following consideration the Committee unanimously agreed to note the contents of
the report.  
7.         Internal Audit Review - Levelling Up Fund 
The meeting had before it a report by the Service Manager Internal Audit and Risk
advising Committee on an internal audit review completed for the period from 19
November 2025 to 25 March 2026. 
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Councillor Macrae expressed concern that while the funding from the UK
Government was received in November 2023, there had been no financial monitoring
of the expenditure until identified by audit and implemented in November 2025 and,
noting the changes in world politics since the funding was received, queried what
risks had been identified that could result in slippage of delivery timescales of
projects and actions being taken to mitigate any potential risks.  In response, the
Service Manager Strategic Planning and Development confirmed the audit related to
the governance of the administrative arrangements confirming changes made to the
programmes and projects within the programme had been reported to Council.  He
further advised detailed risk register was discussed every few weeks to identify any
emerging issue and mitigation measures and, along with regular reporting to Moray
Council, any issues relating to adherence to timescales etc would be reported to
Corporate Leadership Team, the Transform Board and Moray Council.    
In terms of transparency, Councillor Gordon asked if the website could be updated
with names, photographs and declarations of interest of Project Board member on
the Council's website and whether the monthly financial statements should be
reported to the relevant service committee.  The Service Manager Strategic Planning
and Development confirmed they would share details of those on the Board.  In
response to the query regarding reporting of financial statements to service
committees, the Executive Director Economy, Enterprise and Operations advised
service committees provide scrutiny at a higher strategic level rather than operational
level and the project was being tracked through the transformation strategy updates
provided to Corporate Committee.  She further confirmed consideration was being
given to opportunities to improve communications relating to major programmes.  
Councillor McLennan joined the meeting during discussion of this item.  
Following consideration the Committee unanimously agreed to endorse the
recommendations contained within the report. 
8.         Internal Audit Review – Democracy and Governance 
The meeting had before it a report by the Service Manager Internal Audit and Risk
advising Committee on an internal audit review completed for the period from 19
November 2025 to 25 March 2026. 
Councillor Bloomfield queried whether targeted training would resolve the issue of
missing information from reports, in particular Integrated Impact Assessments (IIAs)
referenced in the third bullet point under Key Issues.  In response, the Executive
Director Finance, Strategy and Transformation confirmed the new Head of People,
Change and Community Strategy was progressing briefings and training for officers
and members with oversight of reports from the Corporate Leadership Team to
ensure the appropriate information is included.  To provide further assurance the
Chief Governance Officer advised the committee reporting writing guidance for
officers had been amended to clearly reflect the requirement for IIAs.  
Councillor Gatt expressed concerned at the non-compliance with Financial
Regulations referenced in the second bullet point under Key Issues and highlighted by
the Service Manager Internal Audit and Risk in other audits, and stressed the
importance of compliance with the Regulations being enforced by officers.  In
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response, the Executive Director Finance, Strategy and Transformation provided
assurance all new staff would be trained in the importance of adherence to financial
regulations, particularly those with budget responsibility.  To provide further
assurance the Service Manager Internal Audit and Risk confirmed Internal Audit
would continue monitoring by sampling payments transactions within next years
Internal Audit Plan, escalating any issues identified to the Executive Director Finance,
Strategy and Transformation, and reporting any findings to this Committee.  
In response to a question from Councillor Warren asking whether the Council's
scrutiny function was not as robust as it should be, noting the limited scrutiny
functions highlighted in the report, the Service Manager Internal Audit and Risk
agreed it required to be enhance and that work was being undertaken to identify new
areas of scrutiny to be reported to this Committee.  The Chief Governance Officer
referred to the updated remit of Audit and Scrutiny Commission approved at the most
recent Moray Council meeting and advised a report would come to a future meeting
of this Committee to demonstrate how cross-cutting themes will be identified and
agreed.  
The Chair confirmed the process of identifying relevant scrutiny topics was underway
however encouraged members to raise with him any relevant topics they would wish
to be considered. 
During discussion Councillor Keith referred to a consultation document issued to
Elected Members seeking their views to inform the report and queried why the
headings were not reflected in the report.  In response, the Service Manager Internal
Audit and Risk confirmed the report had been compiled following analysis of the
responses, was based on common themes raised by Elected Members and specific
issues raised by Councillor Keith could be addressed by the review of the current
committee reporting arrangements detailed in Audit Recommendation 6.    
Following consideration the Committee unanimously agreed to endorse the
recommendations contained within the report. 
9.         Internal Audit Review – Procurement and Creditor Payments 
The meeting had before it a report by the Service Manager Internal Audit and Risk
advising Committee on an internal audit review completed for the period from 19
November 2025 to 25 March 2026. The Service Manager Internal Audit and Risk
explained that the scope of the review related to payments managed under the
direction of the Moray Integration Joint Board.  
During discussion concern was raised by various members of the Committee relating
to further non compliance with Financial Regulations and seeking assurance
measures were in place to ensure such breaches would not occur in future and that
the issues identified in the audit findings were isolated incidents. In response, the
Service Manager Internal Audit and Risk confirmed that another review of creditor
transactions has been included within next year’s Internal Audit Plan. This review will
include further sample testing of transactions to confirm that control measures are
operating effectively within the payment process. Audit testing will also undertake
checks to identify any potential duplicate payments.  The Executive Director
Financial, Strategy and Transformation noted the issues in the audit were exceptions
in terms of the volume of transactions processed by the Council however reiterated it
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was recognised training and culture awareness required to be improved, particularly
within the Moray Integration Joint Board, and ensuring staff were comfortable raising
any capacity issues with managers.  
Following consideration the Committee unanimously agreed to endorse the
recommendations contained within the report. 
10.         Internal Audit Review – Counter Fraud Review 
The meeting had before it a report by the Service Manager Internal Audit and Risk
advising Committee on an internal audit review completed for the period from 19
November 2025 to 25 March 2026. 
With reference to the training requirement identified in the Key Issues of Appendix 1
and referred to during consideration of earlier reports on this agenda, Councillor
McBain asked how confident management were that staff who require training were
undertaking it and how that was being monitored.  In response, the Executive Director
Finance, Strategy and Transformation advised confidence was high in terms of new
staff through the Council induction process with refresher training also being
progressed for existing staff by the Head of People, Change and Community Strategy,
as previously stated.  
In response to a question from Councillor Macrae relating to the annual fraud risk
assessment of Elgin Neighbourhood Board referenced in Audit Recommendation 2
asking that minutes of the Board should be publicly available given the significant
sum of funding awarded and the Council being the accountable body, Councillor
Keith, as a member of the Board, confirmed meetings and minutes were public and
the project officer was in frequent communication with the relevant officers within
the Council.  The Service Manager Internal Audit and Risk stated that the requirement
to undertake a fraud risk assessment was a condition of the funding and that the
Internal Audit Section had assisted the service in completing this exercise. The
Service Manager Internal Audit and Risk also confirmed that an annual counter‑fraud
review is included within next year’s Internal Audit Plan and will continue to be
included in future Plans to support the Council’s governance arrangements.  
Following consideration the Committee unanimously agreed to endorse the
recommendations contained within the report. 
11.         Internal Audit Plan 2026-27 
The meeting had before it a report by the Service Manager Internal Audit and Risk
providing the Committee with details of the planned internal audit coverage for the
year ending 31 March 2027.  The Service Manager for Internal Audit and Risk
confirmed that the Internal Audit Plan had been prepared in compliance with the
Global Internal Audit Standards. This includes a requirement to annually consider
reviews relating to cybersecurity, third‑party arrangements and strategic
procurement. It is expected that this list of projects will increase over time. The
Internal Audit Plan also includes a copy of the Internal Audit Charter, which sets out
the roles and responsibilities for delivering the Internal Audit Service. 
In response to a question from Councillor Gordon relating to the Moray Integration
Joint Board asking for a synopsis of what is being reported to the Board's Risk
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Committee, the Service Manager Internal Audit and Risk confirmed all audit reports
that are reported to the Board's Audit, Performance and Risk (APR) Committee are
also reported to this Committee, with the exception of the NHS internal audit report
which are reported confidentially to APR.  The reporting of NHS internal audit reports
required a separate authorisation agreement from NHS Grampian and their Internal
Audit Provider.   The Chair, as Chair of APR Committee, confirmed the crossover in
terms of scrutiny.  
Councillor Warren sought information on how changes to the plan are managed if
emerging risks arise during the year and how Committee would be informed of the
amendments to the plan due to there be limited capacity within Internal Audit.  In
response, the Service Manager Internal Audit and Risk confirmed he was required to
report any changes to this Committee given its responsibility under the Global
Internal Audit Standards.  Any proposed changes to projects detailed within the
Internal Audit Plan, whether from Members or Management, should be raised directly
with the Service Manager Internal Audit and Risk. This will allow the Service Manager
Internal Audit and Risk to assess, in accordance with the Global Internal Audit
Standards, how the Internal Audit Service can best meet this additional requirement.
This may include expanding the scope of a current review, replacing a project within
the Internal Audit Plan or considering the matter for inclusion in a future Audit Plan.
In addition, some flexibility may be required in reporting follow-up reviews, as audit
projects may require multiple visits and revised implementation dates for
recommendations. 
In response to a question from Councillor McLennan asking what the process is for
Elected Members to raise issues they consider should be included in the audit plan,
the Service Manager Internal Audit and Risk advised an email is sent to all Elected
Members and senior management during the audit planning process in
September/October asking if there are any topics they wish to be considered for the
audit plan. In addition, a workshop is to be arranged with Members later this year to
review compliance with the Chartered Institute of Public Finance and Accountancy
guidance on Audit Committees, during which any issues can be raised directly with
the Service Manager for Internal Audit and Risk.  
Following consideration the Committee unanimously agreed the proposed internal
audit coverage for the 2026/27 financial year as detailed in the Internal Audit Plan for
2026/27 (Appendix 1).  
12.         Annual Audit Plan for the Year Ending 31 March 2026 
The meeting had before it a report by the Chief Financial Officer informing Committee
of the External Auditor's Annual Audit Plan for the 2025/26 financial period.  
In response to a question from Councillor Gordon asking whether VAT turnover could
be included as an Appendix in the accounts, the Chief Financial Officer agreed to
discuss with Councillor Gordon the benefits of that being added as an Appendix to
the accounts.  The Service Manager Internal Audit and Risk confirmed VAT was a topic
in the Internal Audit Plan for 2026/27.  
Councillor McBain referring to the Significant Risk relating to valuation of land,
buildings and Council dwellings referenced in the Introduction and Headlines (1)
section of Appendix 1, asked how it was considered a significant risk if revaluations
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are undertaken every 5 years.  In response, the External Auditor advised the value is
significantly material from an audit perspective and the requirements on the Chief
Financial Officer are to ensure that the accounts are materially correct in terms of
programme evaluation or indexation, confirming it would show as a significant risk
every year because of the estimated figure.  
In response to a question from Councillor McLennan querying whether the second
last bullet point under Other Work in the Other matters (1) section should be "alleged
fraud", the External Auditor confirmed reporting is after the fact in terms of scrutiny
and lessons learned for other bodies of types of fraud that can occur.  The Service
Manager Internal Audit and Risk encouraged any Elected Members or members of the
public who had concerns about alleged fraud to raise those with him directly.  
With reference to paragraph 4.5 of the covering report relating to the two sets of draft
financial statements, Ms Wilson asked whether the entire process in terms of
consultation, advertising etc would require to be undertaken when issuing the
second set of draft accounts.  In response, the Chief Financial Officer advised the
draft accounts to be reported to Moray Council on 30 June would include a disclosure
note that the information does not include revalued housing asset but would seek
agreement to publish the second set of accounts including revaluations by mid
September which to allow sufficient time for consultation before the final authorised
accounts are published by the deadline of 30 September.  
Following consideration the Committee unanimously agreed to note the contents of
the External Auditor's Annual Plan for 2025/26.  
13.         Accounts Commission Report - Comhairle nan Eilean Siar - Cyber-attack
affecting operations and services 
The meeting had before it a report by the Service Manager Internal Audit and Risk
summarising the key issues identified in the Accounts Commission's review of the
2023/24 Comhairle nan Eilean Siar cyber-attack and highlighting lessons for all public
sector bodies to consider and apply to strengthen their cyber resilience, governance
and business continuity.  
Following consideration the Committee unanimously agreed to:-  
i) note the contents of the report and the Account Commission's report regarding
the Comhairle nan Eilean Siar cyber-attached affecting operations and
services; and 
ii) note that a review of the Council's systems and processes relative to
cybersecurity forms part of the planned internal audit coverage for 2026/27.   
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Report to: Audit and Scrutiny
Committee
Meeting Date: 18 June 2026 
Report by: Service Manager Internal Audit and Risk
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 Global Internal Audit Standards requires the Service Manager Internal Audit and Risk 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 considers and notes the contents of this report,
seeking clarification on any points.
Dafydd Lewis
Service Manager Internal Audit and Risk
Item 5.
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4.  BACKGROUND AND CONTEXT 
Moray Integration Joint Board – Internal Audit Service
4.1 As Service Manager Internal Audit and Risk for the Council, I have agreed to the
appointment of Chief Internal Auditor for the Moray Integration Joint Board (MIJB) to deliver
their internal audit service.  This is a two‑year appointment, ending on 31 March 2028. The
role provides independent assurance on the adequacy and effectiveness of the internal
control framework governing the systems and practices used by the MIJB to deliver
delegated services, irrespective of whether those systems are owned by the Council or
NHS Grampian. In previous years, I have entered into an agreement with NHS Grampian
and its External Internal Audit Provider to enable reliance on and reporting of audit reviews
undertaken within NHS Grampian to the MIJB Audit, Performance and Risk Committee. It
is intended that this arrangement will continue. In accordance with the requirements of
the Chief Audit Executive role, as defined by the Global Internal Audit Standards, I do not
consider that this appointment will impair, either in "fact or appearance", my role as
Service Manager Internal Audit and Risk for the Council. 
Chartered Institute of Public Finance and Accountancy (CIPFA) Publication – Audit
Committees: Practical Guidance for Local Authorities and Police 
4.2 The CIPFA publication Audit Committees: Practical Guidance for Local Authorities and
Police sets out a framework for the roles, functions, and operations of audit committees
within local authorities and police bodies. It represents CIPFA’s view of best practice for
the effective operation of audit committees across the United Kingdom public sector. 
4.3 Audit Committees are a key component of an authority’s governance framework and
provide an independent and high-level resource to support governance and strong public
financial management. The guidance states the purpose of an audit committee is “to
provide an independent and high-level focus on the adequacy of governance, risk and
control arrangements. The committee’s role in ensuring that there is sufficient assurance
over governance risk and control gives greater confidence to all those charged with
governance that those arrangements are effective.” 
4.4 CIPFA promotes that a high standard of performance against recommended practice,
together with a knowledgeable and experienced membership, is essential to the effective
operation of audit committees. In support of this, CIPFA has developed a high-level review
checklist comprising a Self-Assessment of Compliance with the Good Practice Principles
and an Evaluation of Effectiveness. This incorporates the key principles set out in the
CIPFA publication Audit Committees: Practical Guidance for Local Authorities and Police. 
4.5 A workshop with members of the Audit and Scrutiny Committee was undertaken last year
to complete a Self-Assessment and Evaluation Checklist. The findings and
recommendations arising from this exercise were reported to the Audit and Scrutiny
Committee on 24 June 2025 (paragraph 11 of the minute refers). In accordance with CIPFA
guidance, I plan to facilitate a further workshop with members to review and complete the
Self-Assessment and Evaluation Checklist. A copy of the full CIPFA publication, Audit
Committees: Practical Guidance for Local Authorities and Police, will be shared with
members in advance of the meeting.   
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Follow Up Reviews
4.6 Internal Audit reports are regularly presented to members, detailing not only audit findings
but also management’s responses to the recommendations, including agreed
implementation dates. In addition, Internal Audit undertakes follow-up reviews to provide
assurance on the implementation of agreed actions. Details of the completed follow-up
reviews are set out below:   
4.7 
Self Directed Support (SDS) – Option 2/3 
A follow‑up review has been undertaken to assess the implementation of
recommendations arising from the previous audit of Self‑Directed Support (SDS). The
Social Care (Self‑Directed Support) (Scotland) Act 2013, which came into effect in April
2014, introduced the term “Self‑Directed Support” to describe how individuals can
exercise choice and control over the support or services that enable them to live
independently and achieve their agreed outcomes. The original audit examined the
systems and procedures for administering SDS Option 2 – Managed Budget, under which
individuals, following assessment, choose their preferred support, while Health and Social
Care Moray (HSCM) arranges its provision and payment. It also reviewed Option 3 –
Managed Support, where HSCM selects, commissions and pays for the appropriate
support on behalf of the individual. The audit covered processes relating to supporting
individuals in determining their preferred care delivery options, the contractual
arrangements with care providers, financial management and the ongoing monitoring of
individual care packages. 
4.8 The follow-up report, provided in Appendix 1, confirms that the majority of
recommendations have now been implemented. Revised implementation dates have
been agreed for the outstanding recommendations and the Service has advised that all
actions are expected to be fully implemented during 2026/27. As this audit has been
ongoing for a number of years, it is proposed that no further follow-up review is undertaken
at this time. However, an audit of Self-Directed Support Options 2 and 3 will be considered
for inclusion in a future Internal Audit Plan. 
4.9 
Moray Integrated Community Store
An audit was previously undertaken of the Occupational Therapy Store, now known as the
Moray Integrated Community Equipment Store. Occupational therapy stock consists of
aids and equipment issued to support individuals with daily living activities such as
cooking, dressing, and bathing. Items vary significantly in value, ranging from a few
pounds to over £1,000 for certain types of hoists and specialised seating.
A key feature of this service is the management of equipment returns once items are no
longer required. Where feasible, returned equipment is decontaminated and made
available for reuse. The original audit identified significant areas requiring improvement in
operational arrangements. A follow‑up report evidencing the implementation of the agreed
recommendations is provided in Appendix 2. 
4.10 
Following the Public Pound
A follow-up review was undertaken to assess the implementation of recommendations
from the audit of Following the Public Pound. The scope of the audit covered the Council’s
governance and funding arrangements with Moray Leisure Limited, which manages the
leisure centre in Elgin, and Moray Citizens Advice Bureau, which provides advice and
support on a range of matters, including benefits entitlements, housing, consumer issues,
debt and money management. The follow-up review confirmed that an updated Service
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4.11 
4.12 
4.13 
Level Agreement has been agreed between the Council and Moray Citizens Advice Bureau.
In addition, revised draft Service Level Agreement and Lease Agreement documentation
between the Council and Moray Leisure Limited has also been agreed; however, at the
time of the follow-up review, these agreements had not yet been formally signed. The
follow-up report is provided in Appendix 3.  
Procurement and Creditor Payments 
Part of the Annual Internal Audit Plan includes a review of the Council’s main financial
systems. This included an audit of non‑payroll expenditure, specifically payments to
suppliers and contractors for works, goods and services. The objective of the audit was to
provide assurance over key functions of the Financial Management System, focusing on
the accuracy of payment processing and expenditure recording. The review identified
areas requiring improvement in operating and administrative arrangements. A follow‑up
review was undertaken to assess the implementation of the agreed recommendations. It
was found that the development of an updated Authorisation Database remains
outstanding. The Chief Financial Officer and the Service Manager Finance Operations
have advised that implementation has been delayed due to the requirement to procure a
replacement Financial Management System, as the current contract expires in March
2027. While further development of the Authorisation Database will be considered,
priority has been given to the procurement and implementation of the new system. The
Follow‑Up Report, which evaluates the implementation status of the agreed
recommendations, is provided in Appendix 4. 
Housing Rent Collection & Arrears Management
A follow‑up review was undertaken to assess the implementation of the recommendations
from an audit of housing rent income collection and accounting arrangements. The
objective of the audit was to confirm that effective controls and procedures were in place
for the administration of rent accounts and the accurate accounting of all income
received. In addition, the audit examined the debt recovery arrangements for rent arrears
relating to both current and former tenants. It is pleasing to note that the follow‑up review
confirmed that all recommendations have been fully implemented. The Follow‑Up Report
is provided in Appendix 5. 
Pool Cars Scheme
This follow-up review assessed the implementation of recommendations made in an audit
of the Pool Car Scheme. A pool car is a vehicle owned by the Council and made available
to employees on a shared basis. At the time of the original audit, the Council’s pool car
fleet consisted of 118 vehicles, including 84 classified as general-use vehicles and 34
designated as service-dedicated vehicles. Approximately 10% of the fleet comprised
electric vehicles. The scope of the audit was to review the systems and procedures
governing the management and use of pool cars. This included an assessment of whether
policies and procedures provide sufficient guidance to officers for booking and using
these vehicles. The follow-up review found that the majority of recommendations have
been completed; however, some actions remain outstanding, and revised implementation
dates have been agreed. The Follow-Up Report is provided in Appendix 6. 
Treasury Management
4.14 This follow-up audit reviewed the implementation of recommendations arising from the
audit of procedures and controls relating to the operational management of the Treasury
Management function. The overall objective of the audit was to confirm that the Council
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has appropriate procedures and controls in place to ensure compliance with the
requirements for borrowing and treasury management, as set out in the Chartered
Institute of Public Finance and Accountancy (CIPFA) Code of Practice on Treasury
Management in the Public Services (2021), which defines the policies and objectives for
treasury management activities, and the CIPFA Prudential Code for Capital Finance in
Local Authorities (2021). The follow-up audit found that, while progress has been made,
revised implementation dates have been agreed for the outstanding recommendations. It
is acknowledged that a number of significant staffing changes within Financial Services
have occurred recently, which may have impacted the implementation of the agreed
actions. The Follow-Up Report is provided in Appendix 7.  
5.  PROPOSALS  
5.1  It is recommended that Committee agree to note the progress made by Internal Audit in
the period from 25 March 2026 to 18 June 2026. 
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 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.
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☐ 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. 
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. 
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 Section
1
BODY: Health & Social Care Moray
SUBJECT: Self Directed Support (Options 2 & 3)
REPORT REF: 23'025
Follow Up Audit Review
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Key Control: Effective controls operate in the management and recording arrangements for the delivery of SDS Options 2 and 3 care
packages  
5.1 In accordance with SDS
Regulations, evidence should be
maintained to document the
discussions held by social workers
regarding the various care
delivery options discussed with
High Yes 30/09/2023 Implemented. The audit follow-up review
reported to MIJB’s Audit, Performance &
Risk Committee on 19/06/2025 (para 7 of
minute refers) and to the Council’s Audit &
Scrutiny Committee on 24/06/2025 (para 7
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Appendix 1
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
the individual using care services.  of minute refers), noted that new
documentation and guidance had been
developed on required standards to be met
and the first quality assurance review had
been undertaken. The Service has
introduced a quality assurance review
process, in which findings are reported to
the Practice Governance Board on a
quarterly basis. This internal monitoring
process is facilitating improvement and
informing ongoing training and
development activities, to ensure the
required quality of care option discussions
are recorded.
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Appendix 1
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
5.2 Documented procedures should
be developed to support social
workers and individuals using care
services in the selecting of SDS
care delivery options. 
High Yes 31/03/2024
(Revised
Implementation
Date
30/09/2025)
Implemented. Social Work Assessment
Guidance to support officers have been
developed by the Service and formally
agreed and put into practice from October
2024. This has been supported by further
work on information to individuals, through
revised guides and improved internet
content, aligning available information to
SDS standards and the development of a
Resource Allocation process. The
recommendation is now assessed as fully
implemented.    
5.3 An annual reference document
detailing a breakdown of the rates
paid to care providers should be
High Yes 30/06/2023
(Revised
Implementation
Implemented. The annual reference
document used for budgetary planning and
costing of support packages has been
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Appendix 1
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
provided to all relevant officers to
assist in budgetary planning and
the accurate preparation of an
individual's support package.   
Date
01/04/2025)
updated to include breakdown rates for
block funded services. Going forward, the
extended use of framework agreements
will allow the provision of the requisite
detail on provider rates for costing
purposes. 
5.4 All officers should be reminded to
update the CareFirst System to
ensure the database is up-to-date
and accurate for each individual
using care services. 
High Yes 30/09/2023 Implemented.   The Guidance referenced
in 5.1 & 5.2 defines CareFirst
requirements, with training, quality
assurance, and ongoing monitoring
overseen through service reviews and
monthly Practice Governance Board
meetings. This was reported in the follow-
up report presented to MIJB’s Audit,
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Appendix 1
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
Performance & Risk Committee on
19/06/2025 (paragraph 7 of the minutes
refers) and to the Council’s Audit &
Scrutiny Committee on 24/06/2025
(paragraph 7 of the minutes refers). 
5.5 A tripartite agreement between
the individual using the care
service, Council and care provider
should be agreed for all SDS
Option 2 care packages. 
Medium Yes 30/09/2024
(Revised
Implementation
Date
31/07/2025)
Implemented.  Whilst the first audit follow-
up exercise evidenced significant progress
in implementing tripartite agreements for
Option 2 packages, extension to historical
packages was to be undertaken to ensure
all Option 2 individuals receiving a social
care service had a tripartite agreement in
place. The audit review has found that this
exercise to identify all Option 2
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Appendix 1
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
arrangements and agree tripartite
agreements has been completed.   
5.6 A contractual agreement detailing
service delivery and costs should
be agreed with the 3 providers of
day care services noted within the
findings. 
High Yes 31/03/2024
(Revised
Implementation
Date
31/08/2025)
Outstanding.  The Service has advised
that a significant review of future delivery
needs is required for these day services,
and this is intended to be completed in
2026/27. It is not intended that a third audit
follow up is conducted and instead another
review will be included in a future Audit
Plan to evidence implementation. 
5.7 Annual support plan reviews of
individuals in receipt of SDS
Option 2 and 3 care packages
should be undertaken in
accordance with agreed
High Yes 30/09/2024
(Revised
Implementation
Date
31/12/2025)
Outstanding. The follow-up review found
that significant progress has been made in
reviewing and if required, updating the
Support Plans of individuals receiving SDS
Option 2 and 3 care packages in
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Page 27

Appendix 1
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
procedures.  accordance with agreed procedures.
However, audit testing identified
continuing variances across Teams in the
timeliness of Support Plan reviews.
Regular reviews are essential to ensure
Support Plans remain current, effective
and compliant with statutory requirements.
Following consultation with the Service, it
is intended that progress will be made
during 2026/27 to review and where
required, update outstanding Support
Plans. Progress will be closely monitored
by Senior Management
5.8 Consideration should be given for
management to undertake regular
reviews of the accuracy and
recording of the checks completed
Medium Yes 30/09/2023 Implemented. A Standard Operating
Procedure has been introduced for invoice
checks, with monthly management
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Appendix 1
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
to ensure the accuracy of
payments made to care providers. 
reviews of samples to ensure compliance.
These reviews are evidenced through an
invoice monitoring spreadsheet
maintained by Community Care Finance.
This was reported in the follow-up report
presented to MIJB’s Audit, Performance &
Risk Committee on 19/06/2025 (para 7 of
minute refers) and to the Council’s Audit &
Scrutiny Committee on 24/06/2025 (para 7
of minute refers).   
5.9 The Council's charging policy
should be reviewed in regard to
day care and a decision made as
to whether a charge should be
levied for the service in the future. 
High Yes 30/09/2023
(Revised
Implementation
Date
30/09/2025)
Outstanding.   The review of the Social
Care Charging Policy was planned but was
delayed due to staffing availability and the
need to align with emerging COSLA non-
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Appendix 1
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 
residential care charging guidance. A
change of approach has now been
determined for the review of day care
services charging, with its removal from
the remit of the broad charging review to
be undertaken for Social Care. A review of
day service charging will instead be
included in the overall Day Services review
being undertaken as part of the 2026/27
Savings Plan. It is not intended that a third
audit follow up is conducted and instead,
another review will be included in a future
Audit Plan to evidence implementation. 
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Appendix 1
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
5.10 A review of arrangements
regarding the authorisation of
individual care packages should
be undertaken. Thereafter,
authorisation requirements should
be documented and
communicated to all appropriate
officers.   
Medium Yes 31/08/2023
(Revised
Implementation
Date
30/06/2025)
Part-Implemented. The follow-up audit
noted that operating arrangements have
been developed for the authorisation of
individual care packages at differing
monetary thresholds. In addition, a High
Cost Package Panel has been established
to review and authorise complex care
packages. However, the authorisation
requirements have not yet been formally
documented, resulting in a risk of
inconsistent application and a lack of
clarity regarding the agreed operating
arrangements. This matter has been
discussed and agreed by the Operational
Management Team (OMT), with formal
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Appendix 1
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
procedures expected to be issued to
officers by 31 July 2026. 
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APPENDIX 2
Moray Council
Internal Audit Section
1
DEPARTMENT: Health & Social Care Moray
SUBJECT: Moray Integrated Community Equipment Stores
REPORT REF: 24'013
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: Effective systems and procedures operating to ensure accurate records are maintained to account for all Occupational Therapy
equipment held within Stores and issued to Service Users
5.1 A full stock check should be
undertaken to ensure records
correspond to the actual number of
items held within Stores.
High Yes 31/03/2024 Implemented – The review confirmed that
Stores officers completed a full stock check
after implementing new stock management
arrangements. The stock take was verified by
an officer from the Internal Audit Section with
only minor variances noted between system
recorded figures and the actual stock held.
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Appendix 2
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 
Items of equipment should be kept
wherever possible in Asset Number
order within the Stores Building.
Asset Numbers should be clearly
recorded where possible on shelving. 
Medium  Yes  31/03/2024
Variances were investigated and explanations
obtained. 
Implemented - Asset numbers are now clearly
recorded on shelving used for storing
equipment.  Shelf locations across the store
have also been added to the Stores Software
Application (ELMS).  
5.2 The software application used for
purchasing equipment should be
regularly updated with the stock
issued to ensure an accurate unit
price is maintained. 
Further exploration should be
undertaken of ELMS with the purpose
of enabling the direct purchase of
equipment.
Medium 
Medium
Yes 
Yes
31/03/2024
(Revised
Implementation
Date
30/06/2025) 
31/10/2024
(Revised
Implementation
Implemented –      The follow-up review found
that the separate stores management
software application is no longer used to
provide stock valuation for occupational
therapy equipment. This function is now
performed through ELMS. 
Implemented –   The follow-up review found
that while the purchasing of occupational
therapy equipment is still undertaken through
a separate stores management software
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Appendix 2
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 
Date
30/11/2025)
application, the ELMS software package has
been updated to include a stock valuation
function. 
5.3 A review should be undertaken of the
current policy of revaluing re-used
items of equipment at 50% of the
original unit price. 
Medium Yes  31/01/2024
(Revised
Implementation
Date
30/06/2025)
Implemented – It has been agreed by senior
management within the service to revalue re-
used equipment at 50% of the original
purchase price has been reviewed and it has
been decided to continue with the policy of
50% revaluation. 
5.4 Users of the Service should be
advised that any equipment received
should be included within their
personal property content insurance.
Medium No 31/01/2024
(Revised
Implementation
Date
30/06/2025) 
Not Implemented –  The Service has decided
that individuals will not be required to include
occupational therapy equipment under their
personal property contents insurance.
However, individuals will be advised to inform
their insurer if the equipment has a structural
impact on their property. 
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Appendix 2
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 
5.5 Maximum and minimum stock levels
should be implemented in ELMS to
assist officers in ensuring the
effective management of stock levels.
Medium Yes 31/03/2024 Implemented - The review has confirmed that
maximum and minimum stock level functions
are now used within ELMS. The Service also
intends to review these stock level parameters
regularly. 
5.6 A record should be maintained of the
stock checks undertaken, and any
adjustments to stock figures for
equipment recorded within ELMS
should require the authorisation of
the supervisor.
Medium Yes 31/01/2024 Implemented – Records of weekly stock
checks are now maintained. It was also
confirmed that adjustments to stock levels
within ELMS can now only be authorised by
Supervisory Officers.
5.7 In regard to the stock of returned
specialised chairs noted during the
audit review, a decision should be
undertaken regarding their future
use. 
Medium Yes 31/03/2024 Implemented - The Service has decided to
retain the chairs. A meeting between officers
from the Equipment Stores of Aberdeen City,
Aberdeenshire and Moray agreed to explore
options regarding the use of these chairs and
other equipment within the Grampian area. In
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Appendix 2
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
addition, the Service has advised that the
chairs could be adapted to meet the specific
needs of individuals, potentially providing an
alternative to procuring new items. 
5.8 Further development should be
undertaken of ELMS to enable
greater use of the software
application in the management of
stock items. 
Medium Yes 31/03/2024 Implemented – It was found that the Service
is making greater use of the reporting functions
within ELMS. In addition, data from ELMS is
exported to another software application to
allow for greater analysis of information. 
5.9 Officers should be instructed to utilise
the facility within ELMS to mark stock
as out for delivery. 
Low Yes 30/06/2024 Implemented - Procedures are now in place
requiring drivers delivering equipment from
Stores to mark equipment as out for delivery
within ELMS. 
5.10 A review of off contract expenditure
should be carried out and where
necessary contracts developed.
Low Yes 31/03/2024
(Revised
Implementation
Date 30/06/2025
Implemented –  Formal contracts are now in
place for the procurement of the majority of
equipment, including the provision of
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Appendix 2
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
Revised
Implementation
Date
31/10/2025)
specialised chairs, as noted in the audit report
findings. 
5.12 Current operating practices should be
recorded within a Service Operating
Manual.
Medium Yes 31/03/2024 Implemented - Operating Procedures are now
in place to provide officers with a point of
reference guidance in the administration of the
Moray Integrated Community Equipment
Store.
5.13 A review of service procedures
should be undertaken to ensure the
store is informed of a change in
circumstance in a service user’s
condition where an item of equipment
may no longer be required.
Arrangements should then be
undertaken for collection at the
earliest opportunity.
Medium  Yes  29/02/2024  Implemented -  The Moray Integrated
Community Equipment Service is informed of
equipment issued to an individual but is no
longer required. Testing has confirmed that
when informed, arrangements are made for
the collection of this equipment. 
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Appendix 2
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
If no agreement can be made for
an item of equipment to be
returned to the store,
consideration should be given to
invoicing the service user.
Medium Yes 31/01/2024
(Revised
Implementation
Date 30/06/2025
Revised
Implementation
Date
30/11/2025)
Implemented – The Service has formalised
procedures for issuing invoices to users when
an agreement cannot be reached regarding
the return of previously allocated equipment. 
5.14 Improvements identified to the
Service during the audit review
regarding the physical security of the
Occupational Therapy Stores
building should be implemented as a
matter of urgency.  
High Yes 31/03/2024 Implemented - A new alarm system has been
fitted at the Moray Integrated Community
Equipment Store and is now in operation. 
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APPENDIX 3
1
Final Internal Audit Report (Follow-up Review)
Following the Public Pound 
March 2026
Distribution: Chief Governance Officer 
Service Manager Leisure & Culture   
Service Manager Benefits & Money Advice
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 4
Priority 2 3
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 3 
2
Contents 
Page
Following the Public Pound   
1. Introduction & Scope 3
2. Key Issues  4 
Detailed Report 
3. Findings/Recommendations 5-16
4. Management Response 6-17
5. Follow Up Reviews 7-17 
Appendices 
1. Audit Terms of Reference and Definitions 
2. Statement of Responsibility 
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Appendix 3 
3
1. Introduction and Audit Scope 
The Internal Audit Plan for 2024/25 provided for a “Following the Public Pound”
review to ensure proper accountability for public funds used in delivering services,
irrespective of the means of service delivery. Councils fund Arm’s Length External
Organisations (ALEOs) to provide important services to the public. These funding
arrangements are often more complex than purchase contracts for goods or
services but can bring both financial and operational benefits to councils. 
Audit Scotland describes an ALEO as an organisation that is ‘formally separate
to the council but is subject to its control or influence.’ Ownership, provision of
funding, and significant shareholdings in a company indicate significant control or
influence and therefore constitute an arm’s length relationship with an external
organisation. A council is responsible for ensuring that Audit Scotland’s ‘Following
the Public Pound’ principles are consistently applied by any ALEOs that it
provides funding to and must ensure that ALEOs can demonstrate value for
money. 
A ‘Code of Guidance on Funding External Public Bodies and Following the Public
Pound’ was published by the Convention of Scottish Local Authorities (COSLA)
and the Accounts Commission in 1996, detailing principles and requirements that
should be considered when determining funding for ALEOs. This Code along with
more recent publications from Audit Scotland including "Arm's length external
organisations (ALEOs): are you getting it right?" (2011) and "Following the Public
Pound" (2004 and 2005) was also considered in the development of the audit
programme for this review. 
The audit scope did not include checking the procedures for small charitable
donations or external bodies where the Council has entered into a contractual
relationship. The audit has instead reviewed the arrangements in place with
regard to Moray Leisure Limited for the operational management of a leisure
centre in Elgin, and the Moray Citizens Advice Bureau for providing support and
advice on a number of different topics, including benefits entitlement, housing,
consumer issues, debt and money management. Whilst Moray Citizens Advice
Bureau is not specifically categorised as an ALEO, the Council has a significant
funding contribution and has been included in this review. 
The audit was carried out in accordance with Global Internal Audit Standards
(GIAS).     
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Appendix 3 
4
2. Key Issues 
• Moray Leisure Centre operated by Moray Leisure Limited, was established
as an ALEO in 1993, and in addition to Council operated sports and
community centres contribute to meeting the leisure and sporting needs of
Moray. The audit noted that reviews have been undertaken over the last
10 years regarding the future delivery direction for leisure services. A
Moray Sport and Leisure Asset Review report by the Depute Chief
Executive (Education, Communities and Organisational Development) to
the Moray Council Committee on 26 June 2024 (item 12) agreed to procure
a company called Alliance Leisure to conduct a comprehensive leisure
assets review for Moray. The purpose of this review is to establish an
evidence base to guide future strategic planning, investment decisions and
management practices concerning leisure assets, including Moray Leisure
Centre. The audit notes and concurs with the recommendations for a report
to “be presented back to Council within 6 months detailing the findings of
the asset review”.     
• In accordance with recommended good practice and the Council’s
Financial Regulations, a formal written agreement should exist between
the Council and any externally funded organisation. It was noted that a
Service Level Agreement (SLA) previously existed between Moray Council
and Moray Citizens Advice Bureau (CAB); however, this agreement
expired in 2019.  An SLA between Moray Council and Moray Leisure Ltd
was established in 1993 in conjunction with the 25-year lease to operate
the leisure centre. The SLA did not specify an end date. Following
consultation with the Chief Governance Officer, it has been assumed that
the SLA has continued on an implied basis and that the terms of the 1993
agreement remain in effect between the Council and the Moray Leisure
Centre. An SLA provides a clearly defined contractual framework that
should reflect current expectations for service delivery, funding
arrangements and performance monitoring. Such documentation
strengthens accountability for the use of public funds and provides
assurance that funded organisations contribute effectively to the
achievement of the Council’s strategic objectives. 
• A requirement of the Moray Leisure Limited’ Articles of Association is to
appoint 3 elected members as directors on the Board.  Moray Citizens
Advice Bureau requests that 2 elected members attend Board meetings in
an advisory capacity. As part of this audit review, discussions were held
with the elected members on both Boards to ensure there was a clear
understanding of the roles and possible limitations of their duties.
Feedback from elected members noted a need for further guidance to
clarify expectations and possible parameters in responsibilities as elected
members representing the Council within the Boards of these
Organisations. 
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5 
Findings/Recommendations - Following the Public Pound 2024/25 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1 High As detailed within the Financial Regulations, the
Council has adopted the principles of the COSLA /
Accounts Commission's ‘Code of Guidance on
Funding External Bodies and Following the Public
Pound’. The Code sets out a framework for the
Council’s relationships with external bodies through
which they seek to carry out some of their functions
other than on a straight-forward contractual basis. In
accordance with the “Code” and as detailed within
the Financial Regulations, there is a requirement for
a written agreement between the Council and the
external bodies. A written agreement, in the form of
a Service Level Agreement (SLA), had been
established between Moray Council and Moray
Citizens Advice Bureau, but this expired in 2018.
The Council has an SLA with Moray Leisure Ltd,
established in 1993 alongside a 25‑year lease to
operate the leisure centre. Although the SLA did not
include an end date, and the lease has since
expired, advice from the Chief Governance Officer
indicates that the SLA is considered to have
continued implicitly. It was noted that work has been
ongoing for several years between the Council and
the Moray Leisure Centre to update this SLA to
reflect better current expectations for service
Service Level Agreements should be agreed
between the Council and the Moray Leisure
Ltd and Moray Citizens Advice Bureau
detailing the core activities that each
Organisation is expected to deliver along with
key performance indicators against which
they will be measured. 
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6 
delivery, funding arrangements and performance
monitoring. 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Sport and Culture Service
Manager 
Benefits and Money Advice
Manager 
Yes 
Yes
31/12/2024 
31/12/2024
A new draft Service Level Agreement was
collectively drafted between management staff
across Moray Council and Moray Leisure
Centre in mid-2021 – this agreement was not
formally signed/sanctioned at the time due to
the future expansion plans, which was
highlighted in the Committee reports on the
MLC expansion plans.  This draft agreement
will be reviewed and updated by the
Management teams of both organisations with
input from legal advisers prior to sign-off. 
A review of the Service Level Agreement with
Moray Citizens Advice Bureau is currently
underway and a draft will be reported to the
relevant committee prior to completion.   
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7 
Follow Up Review 1
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Not Implemented 
Not Implemented
28/02/2026 
30/11/2025
Further to a meeting of the Moray Council on 24 September 2025, the Executive
Director Education, Housing and Communities provided a progress update report on
the Sport and Leisure transformation including future service proposals and the asset
management approach for the leisure estate. A revised date to sign off the Service
Level Agreement has been agreed for 28 February 2026. 
A draft Service Level Agreement has been prepared; however, this has yet to be
agreed and signed by both the Council and the Citizens Advice Bureau Moray.  A
revised date has been agreed with the Service for 30 November 2025. 
Follow Up Review 2
Not Implemented 
Implemented
30/09/2026 
N/A
The follow-up review noted that ongoing discussions have taken place between senior
management of the Council and representatives of Moray Leisure Centre regarding a
revised Service Level Agreement (SLA). The revised SLA includes details of services
to be delivered, expected performance standards, reporting requirements,
governance arrangements and financial responsibilities. It was noted that both parties
have agreed in principle to the content; however, the agreement has not yet been
formally signed. An update on these matters was provided to the Council by the
Executive Director of Education, Housing and Communities on 25 February 2026
(Item 12). The Sport and Culture Service Manager has advised that the revised SLA
is expected to be signed by 30 September 2026.
.
A Service Level Agreement has now been signed by both the Council and the Citizens
Advice Bureau Moray which became effective in January 2026. 
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8 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
2 High The Moray Council entered into a 25-year lease in
1993 with Moray Leisure Ltd to operate a leisure
centre from a Council owned building. The lease
was extended by two, one-year extensions until July
2020. A report by the Depute Chief Executive
(Education, Communities and Organisational
Development) to a special meeting of Moray Council
on 17 December 2019, approved a 10-year
extension to the existing lease agreement. An
extended lease agreement would provide Moray
Leisure Ltd with additional security and greater
value for money opportunities for leasing equipment
and supporting better negotiation opportunities for
improved energy deals. A new draft agreement has
been prepared in draft format but has yet to be
finalised. Currently, Moray Leisure Ltd operates on
a monthly contractual agreement with the Council. It
is appreciated that necessary delays have been
required due to consideration and amendments
needed regarding the proposed expansion scheme
of the leisure centre. The audit is also aware of
uncertainties regarding this proposed expansion
scheme, in addition to the recent commissioning of
a company called Alliance Leisure to undertake a
comprehensive leisure assets review for Moray.
However, there is a need to formalise current
arrangements with an agreed lease agreement
between the Council and Moray Leisure Ltd.
Current uncertainties regarding expansion
and the delivery of future leisure services are
appreciated, however a lease agreement
between the Council and Moray Leisure Ltd
should be agreed as a matter of priority. 
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9 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Head of Governance,
Strategy & Performance
Yes 31/12/2024 The Council’s legal advisers will co-ordinate
with the agents of Moray Leisure Limited to
support the completion of a lease agreement
within the specified timescale.
Follow Up Review 1
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Not Implemented 28/02/2026 A revised lease agreement has not yet been agreed with Moray Leisure Limited.  It is
understood that an interim arrangement exists, with a lease on a year-to-year
basis.  Further to the report by the Executive Director Education, Housing and
Communities to the meeting of the Moray Council on 24 September 2025 referred to
in Finding 1, a revised implementation date for this recommendation has been agreed
for 28 February 2026. 
Follow Up Review 2
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Not Implemented 30/09/2026 As detailed in the follow-up comments under Finding 1, discussions have also taken
place between senior management of the Council and representatives of Moray
Leisure Centre regarding a revised Lease Agreement. The main terms and conditions
of an updated long-term lease for the Moray Leisure Centre property, based on an
internal repairing and insuring basis, have been agreed. However, the agreement has
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10 
not yet been formally signed. An update on this matter was also included in the
Executive Director of Education, Housing and Communities' report to Council on 25
February 2026 (Item 12). The Sport and Culture Service Manager has advised that
the revised Lease Agreement is expected to be signed by 30 September 2026. 
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11 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
3 High During the course of this audit, a Moray Sport and
Leisure Asset Review report by the Depute Chief
Executive (Education, Communities &
Organisational Development) to the Moray Council
Committee on 26 June 2024 (item 12) agreed to
procure a company called Alliance Leisure to
undertake a comprehensive leisure assets review
for Moray. The purpose is to establish an evidence
base to guide future strategic planning, investment
decisions and management practices concerning
leisure assets, including Moray Leisure Centre. It
was noted that over the last 10 years, other
reviews have been undertaken to explore future
delivery options for leisure services. The internal
audit undertaken agrees with the committee report
recommendation to detail the findings of the asset
review to the Council within the next 6 months.
Internal Audit concurs with the
recommendation detailed within the Moray
Sport & Leisure Asset Review Report to
Moray Council Committee on 26 June 2024
(item 12) that on conclusion of the external
review, findings should be used “to provide
further evidence base that will contribute to
the design of our future leisure estate”. 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Sport and Culture Service
Manager   
Yes 31/12/2024 As stated in the Committee report in June, a
report will be taken back to Committee before
end of Dec 24 detailing the findings of the
Alliance Leisure Review alongside other future
service design evidence.
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12 
Follow Up Review 
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Implemented N/A A report by the Depute Chief Executive (Education, Communities and Organisational
Development to a Special meeting of the Council on 21 January 2025 provided an
update on the findings from an externally commissioned ‘Moray Sports Facilities
Review’.  The review considered financial sustainability alongside the prevention
agenda in relation to health and wellbeing.  It was agreed that a workshop would be
held for elected members to discuss rationalisation, governance and service
direction.  This has subsequently taken place.  A further report is intended to be
presented to the Council, which will consider long-term financial sustainability. 
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13 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
4 Medium In accordance with Financial Regulations, the
Council has a requirement for funding external
organisations to establish “reporting and monitoring
arrangements to ensure Council objectives are met
and Best Value achieved”. It is pleasing to note that
performance related information is shared with the
Council by both Moray Leisure Limited and Moray
Citizens Advice Bureau on a regular basis.
However, no structured monitoring systems have
been established to measure the performance
information provided against agreed objectives.
Governance arrangements also do not include a
requirement of how the performance of each
Organisation contributes to Council objectives,
which a relevant committee could then scrutinise. 
Consideration should be given to establishing
clear objectives supported by tailored
performance indicators that are agreed with
Moray Leisure Limited and Moray Citizens
Advice Bureau each year. The Council should
then monitor performance information
provided by each Organisation against these
agreed objectives and if necessary, report it to
the appropriate committee for scrutiny. 
Management Response
Responsible Officer Accepted (Yes/
No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management
Comment
Sport and Culture Service
Manager 
Yes  30/04/2025  Footfall statistics for Moray Leisure Centre are reported
as part of the Council’s Service Performance reporting
however appreciate these do not align to clear
objectives.  Intention is to report annually on
performance as per performance targets set in the new
Service Level Agreement.  A report will be presented to
Education, Children’s and Leisure Services Committee
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14 
Benefits and Money Advice
Manager 
Yes  30/04/2025
between April-June annually which will focus on
performance measures/achievement based on the
previous financial year. 
Relevant performance objectives and performance
reviews will be included in the updated SLA for the
Moray Citizens Advice Bureau and will be monitored and
reported as appropriate. 
Follow Up Review 1
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Part Implemented 
Not Implemented
28/02/2026 
30/11/2025
For Moray Leisure Centre, performance indicators are currently reported to the
Council on a quarterly basis. However, the intention is to further develop performance
monitoring through the updated Service Level Agreement. A revised date for
implementation has been agreed for 28 February 2026. 
Requirements relating to performance objectives for Moray Citizens Advice Bureau
have been included in the draft Service Level Agreement.  This is awaiting agreement.
A revised date for implementation has been agreed for 30 November 2025. 
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15 
Follow Up Review 2
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Part Implemented 
Implemented
30/09/2026 
N/A
As detailed previously, performance indicators for Moray Leisure Centre are currently
reported to the Council on a quarterly basis. Revised performance management
arrangements are to be introduced with the signing of an updated Service Level
Agreement. A new implementation date of 30 September 2026 has been agreed. 
Requirements relating to performance objectives for Moray Citizens Advice Bureau
are included in the Service Level Agreement.  The Service Level Agreement was
signed in October 2025 and became effective in January 2026. 
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16 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
5 Medium It was noted that a requirement of Moray Leisure
Limited’ Articles of Association is for the
appointment of 3 elected members as directors on
the Board.  Moray Citizens Advice Bureau requests
that 2 elected members attend Board meetings in an
advisory capacity. Elected members sitting as board
members can provide important links between the
Council and the funded bodies and help ensure that
the organisations are being properly run and funds
used effectively. However, there are disadvantages,
with Audit Scotland highlighting the risk of potential
conflicts of interest for elected members. As part of
this audit review discussions were held with elected
members representing the Council on the Boards of
Moray Leisure Limited and the Moray Citizens
Advice Bureau. Feedback from the elected
members noted a need for improved guidance to
further clarify their roles, responsibilities and
parameters in their duties as elected members
representing the Council on the Board of each
Organisation. 
Further to discussions with the Head of
Governance Strategy & Performance, the
Council should consider and confirm whether
to accept the reputational risks associated with
perceived conflicts of interest where elected
members sit on the boards of funded external
bodies. If it is considered to continue with the
current arrangement, additional guidance
should be provided to elected members to
further clarify the roles, duties and parameters
of their responsibilities as elected members
representing the Council on the board of
funded external bodies.     
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17 
Management Response
Responsible Officer Accepted (Yes/
No)
Timescale for
Implementation
(Date Required) 
Agreed Management Action/Management
Comment
Head of Governance, Strategy
& Performance
Yes 31/10/2024 Consideration will be given to the perceived risks
associated with appointments to outside bodies. 
Guidance will be refreshed and agreed by the council as
appropriate following this consideration. 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Implemented N/A Guidance on the role of elected members in representing the Council in partnership
arrangements and on outside organisations has been updated.  In addition, in
December 2024, training was provided to Councillors by the Council's internal and
external legal advisers, which included the code of conduct in respect of appointments
on outside bodies. 
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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 Global Internal Audit
Standards (GIAS). 
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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19 
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 Service Manager Internal Audit and
Risk. 
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APPENDIX 4
1
Final Internal Audit Report (Follow-up Review)
Procurement and Creditor Payments 
March 2026
Distribution: Chief Financial Officer
Service Manager Finance Operations
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 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 4 
2
Contents 
Page
Procurement and Creditor Payments 
1. Introduction & Scope 3
2. Key Issues  3-4 
Detailed Report 
3. Findings/Recommendations 5-7
4. Management Response 6-7
5. Follow Up Review 6-8 
Appendices 
1. Audit Terms of Reference and Definitions 
2. Statement of Responsibility 
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Appendix 4 
3
1. Introduction and Audit Scope 
The Annual Audit Plan for the year 2024/25 provides for coverage of the Council’s
core financial systems. A review of payments made to suppliers of goods and
services has been undertaken. The purpose of the audit was to confirm
compliance with Financial, Authorisation, Procurement and Creditor Payment
Processing Regulations from the sample checked. This review is part of the
annual continuous auditing activity of non-salary expenditure and will be used to
support the Audit and Risk Manager’s annual opinion of the Council’s internal
control system. 
Approximately £80 million was paid by the Council in the six months, October
2023 to March 2024, to suppliers of goods and services. Through the use of a
data analysis software application, a random sample of individual payments with
a collective total of £11.3 million was selected. The testing included a check to
ensure invoices have been correctly authorised, coded and in compliance with
regulations. The audit programme was developed from the Chartered Institute of
Public Finance and Accountancy Systems Based Auditing Control Matrices and
in consultation with the External Auditor. In addition, the data analysis software
application was also used to select a sample of high-value invoices to test, and a
check made of identical payment amounts made to the same supplier, which may
indicate a potential duplicate payment. 
From the sample checked and within the scope of the review, no issues of
significant concern were noted regarding the suppliers/ contractors used, sums
paid, authorisation and accounting treatment.  It is considered that appropriate
controls are operating effectively, and the integrity of systems has been
maintained. However, the review has found where further improvements are
recommended to operating and administrative arrangements.   
The audit was carried out in accordance with Global Internal Audit Standards
(GIAS). 
2. Key Issues 
• The Council Authorisation Policy details the management and
operating requirements for officers to follow when committing
expenditure on behalf of the Council. This Policy allows officers to be
designated as Budget Managers with the operational responsibility of
actively managing services. However, within the Policy, a provision
is also made for a named officer to act as an ‘In Absence Authoriser’
to allow services to function effectively in the absence of the Budget
Manager. Audit testing found where an ‘In Absence Authoriser’ had
authorised the majority of invoices processed within a specific budget
area, with examples of authorisation of individual transactions in
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Appendix 4 
4
excess of £100,000. The Authorisation Policy should be updated to
clearly detail that a Budget Manager should initially authorise
expenditure with an “In Absence Authoriser’ function only used on an
exception basis. 
•    This audit required reference to the Authorisation Database to
evidence that the appropriate officer had authorised expenditure with
budget management responsibility. The Authorisation Database is a
standalone software application that requires significant manual
updating of records by officers to remain operationally current.  In
addition, the Authorisation Database does not interface with the
Financial Management System. The Authorisation Database is an
important reference record to ensure the Council maintains effective
budget management and monitoring arrangements. The Finance
Development Team has recognised the limitations of the
Authorisation Database; however, software development has been
restricted due to available staff resources.   
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5 
Findings/Recommendations - Procurement and Creditor Payments 2024/25   
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1. Medium Audit testing was undertaken on a random
sample of payments to suppliers/ contractors to
ensure that expenditure had been authorised in
accordance with the Council’s Authorisation
Policy. The Authorisation Policy provides for
officers to be designated as Budget Managers
with the authority to commit expenditure in the
operational delivery of services. However, the
Policy details a provision for a named officer to
act as an ‘In Absence Authoriser’ to allow a
service to function effectively in the absence of
the Budget Manager. Audit testing noted where
an ‘In Absence Authoriser’ had authorised the
majority of invoices processed within a specific
budget area, with examples of individual
authorisation of individual transactions in
excess of £100,000. 
The Authorisation Policy should be
updated to provide greater clarity that the
Budget Manager should initially make the
authorisation of expenditure and an “In
Absence Authoriser’ function only be used
on an exception basis. 
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6 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Chief Financial Officer Yes 31/12/2024 This will be updated at the next review
date.  Last review date of the authorisation
policy was Sept 23. 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Implemented N/A The Authorisation Policy was reviewed in December 2024, with the next review
falling due in December 2027.  The updated Authorisation Policy was approved
at a Special meeting of the Council on 21 January 2025 (para 8 of the minute
refers). 
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7 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
2 Medium An Authorisation Database is maintained by
Finance Services detailing the names and
signatures of officers with budget management
responsibility that can authorise expenditure
within specific service areas. The
Authorisation Database system is over 20
years old and requires significant manual
administration to ensure it remains
operationally up to date. In addition, the
database does not interface with the Financial
Management System. The Finance
Development Team has recognised the
limitations of the Authorisation Database,
however development has been constrained
due to available staff resources. 
Further development of the Authorisation
Database should be undertaken to
enable an interface with the Financial
Management System and allow a more
automated process for updating standing
information.
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Chief Financial Officer Yes 31/12/2025 This is part of a wider authorisation review
currently with the Finance Development
Group.  Interdependencies will be duly
considered as part of this development.
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8 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Not Implemented N/A At the time of the follow-up audit, the Service was at the start of a process to
replace the Council’s Financial Management System, as the contract expires
in March 2027. The Chief Financial Officer and the Service Manager Finance
Operations have advised that the procurement process is likely to take
between 12 and 18 months. While consideration will be given to the further
development of the Authorisation Database, this will depend on the
procurement of a new financial management system. Due to the revised
timescales, no further follow-up review is proposed regarding the
implementation of this recommendation. However, it will be monitored by the
Internal Audit Section as part of the continuous audit of creditor payments. 
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9 
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 Global Sector Internal
Audit Standards (GIAS). 
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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10 
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 Service Manager Internal Audit and
Risk. 
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Page 68

APPENDIX 5
1
Final Internal Audit Report (Follow Up)
Housing Rent Collection & Arrears
Management 
April 2026
Distribution: Head of Housing, Property & Communities
Area Housing Managers 
Service Manager Housing Operations
Service Manager Housing Strategy
Senior Housing Officer (Policy)
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 2
Priority 3 1
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 5   
2
Contents 
Page
Housing Rent Collection & Arrears Management 
1. Introduction & Scope 3
2. Key Issues  3-4 
Detailed Report 
3. Findings/Recommendations 5-9
4. Management Response 6-10
5. Follow Up Review 6-11 
Appendices 
1. Audit Terms of Reference and Definitions 
2. Statement of Responsibility 
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Appendix 5   
3
1. Introduction and Audit Scope 
The 2024/25 annual internal audit plan provides for an audit review to be
undertaken of the housing rents income collection and accounting arrangements. 
Housing rents within Moray raises budgeted income of £25.1 million per annum,
from approximately 6,380 properties.  The review forms part of the yearly audit
coverage of core Council systems. 
The audit scope was to review the key operational controls regarding rent
collection and arrears management of current and former tenant rents. The aim
of the audit was to look at the controls and processes existing over the
administration of rent accounts, accounting fully and promptly for monies
collected. The accounting interface between the Housing Rents system content
and the Council's Financial Management System was also reviewed. The audit
also checked the arrears management arrangements to ensure a robust system
exists of rent arrears identification, escalation actions and collection.       
The timescale covered for audit testing undertaken was 2024/25, but reference
to the full 2023/24 financial year is made when applicable. It was noted that rent
arrears amounted to £926,000 as at 31st March 2024, with £749,000 relating to
current tenants and £177,000 in respect of former tenancies. Analysis indicates
an increasing trend in rent arrears over recent years, which may be due to
external factors such as Covid recovery, cost of living, and the system of
Universal Credit making payments in arrears. However, it was found Moray has
continued to perform well when compared to national averages and other local
authorities, with arrears of 4.7% of rent due in 23/24. 
It is pleasing to report that in general, the audit has confirmed well established
practices to be in place in administering housing rent accounts and accounting
for monies collected, with strong audit trails seen in evidencing actions taken in
the continual cycle of monitoring and pursuing rent arrears.   
The audit was carried out in accordance with the Global Internal Audit Standards
(GIAS). 
2. Key Issues 
• Overall, the audit found that within the scope of the review, the housing
rent system is well managed. However, it was found that the Council's
Rent Arrears policy has not been reviewed since its agreement by the
Communities Committee in October 2013. It is appreciated that effective
administrative procedures are followed in recovery of rent arrears, but
the Policy should be reviewed and if required, updated to reflect activities
and responsibilities involved where tenant rent accounts of both current
and former tenants are in arrears.   
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Appendix 5   
4
• The Rent Arrears Management Guide details procedures to be
undertaken to recover rent arrears through the issue of reminder letters
to tenants at specific timed intervals. Audit testing of a sample of rent
arrears cases has identified examples of where the rent arrears recovery
approach taken by officers has involved the use of emails, texts to
tenants rather than following agreed procedures in issuing formal
reminder letters to tenants. It is appreciated that the Service is exploring
different methods to maximise recovery of rent arrears, but from the
audit testing of individual rent arrears cases, there is a lack of
consistency in the following of established procedures.   
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5 
Findings/Recommendations - Housing Rent Collection & Arrears Management 2024/25 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1 Medium The Council's Rent Arrears policy was agreed
by Communities Committee in October 2013.
The Policy describes the broad activities and
responsibilities involved where tenant rent
accounts of both current and former tenants are
in arrears and applies to all rented property
owned or managed by the Housing Services.
Detailed operational procedures have been
developed to support this Policy. It was also
noted that the Policy document stated that the
next review was due in 2015, but from
discussions with the Service, it was found this
had not been undertaken due to limited staff
resources and prioritisation of work. The Rent
Arrears Policy is still relevant but should be
reviewed and if required, updated. 
The Rent Arrears Policy should be
reviewed and if required, updated, with
communication thereafter to all relevant
parties. 
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6 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Housing Operations
Manager
Yes 31/12/2025 A review of both the Rent Arrears Policy
and Evictions Policy have been scheduled
in the Policy Team's work plan for 2025, to
be led by a member of the Housing
Management Team. 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Implemented N/A The Rent Management Policy (previously referenced as the Rent Arrears
Policy) has been reviewed and updated and was approved at Housing &
Community Safety Committee on 18th November 2025 (para 12 of minute
refers). Operational procedures have been developed for the new policy, and
communicated to all relevant officers, with an implementation date of 1st May
2026.   
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7 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
2 Medium The Rent Arrears Management Guide is a
procedural document detailing a requirement to
issue a sequence of reminder rent arrears
letters to tenants at specific timed intervals to
stimulate payment. For current tenant arrears
management, this involves the issue of 4
reminder letters before a Notice of Proceedings
can be requested to advance to legal action, if
appropriate. Sample audit testing has identified
examples of inconsistent approaches being
employed across the Service whereby more
informal methods of communication such as
email, texts and calls have been utilised in
attempting to engage tenants, rather than the
issue of the formal reminder letters at the
specified intervals. Whilst comprehensive audit
trails have been seen in the recovery action
undertaken by officers in engaging with tenants
for the payment of rent arrears, examples were
noted where there is a lack of consistency in the
following of established procedures.     
The established sequence of formal
reminder letters should be issued to all
tenants in arrears without delay, when the
appropriate circumstances pertain.   
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8 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Area Housing Manager Yes 31/12/2025 The rent arrears procedure will be
reviewed as part of the wider review of the
Rent Arrears Policy. This will include a
review of the formal reminder letters
issued to tenants as part of the rent arrears
escalation process. In the meantime, Area
Housing Officers will be reminded by
31/01/2025 that the rent arrears escalation
policy must be followed and actions
completed on rent accounts each week.
This will be monitored by the Area Housing
Managers. 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Implemented N/A The rent arrears escalation procedure has been reviewed and strengthened as
an integral part of the new Rent Management Procedures. Additionally, rent
accounts and actions are being monitored on a weekly basis by Area Housing
Managers. A sample of rent accounts in arrears have been examined as part of
the follow-up audit and confirmation obtained that the established sequence of
formal reminder letters is being issued to tenants in arrears, when appropriate.   
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9 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
3 Low The terms detailed within a housing tenancy
agreement is a requirement that rent is payable
by a tenant in advance on or before the Monday
of each week. In the audit testing of a sample of
rent accounts, a number of tenants, particularly
those in receipt of Universal Credit, have been
seen to be in rent arrears at some points during
a month, but with the arrears being cleared on
receipt of a payment towards the end of the
month, then accumulating again until the next
rent payment is made. Examples have been
seen where no valid repayment arrangement
has been agreed with the tenant to build a small
credit balance to eliminate the occurrence of the
rent arrears position. Whilst arrears in these
cases remain at a low level due to regular rent
payments, the tenancy terms are not being
adhered to. 
A review should be undertaken to confirm
repayment arrangements are being
entered into with all applicable tenants,
ensuring advance payment tenancy terms
are adhered to. All repayment
arrangements agreed should be formally
documented within the NEC Housing
system.   
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10 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Area Housing Manager Yes 31/12/2025 The management of rent accounts in
arrears, particularly for accounts where
tenant/s are in receipt of Universal Credit
will be included in the updated rent arrears
procedure. In the meantime, Area Housing
Officers will be reminded by 31/01/2025
that all rent accounts regardless of how the
tenant/s rent is paid, should be paying in
advance as per the Scottish Secure
Tenancy Agreement. Repayment
agreements (RPA) to be sought to address
balances where the tenant/s is unable to
clear the balance outstanding in full. RPA’s
to be logged on NEC Housing system and
confirmation sent to tenants. Area Housing
Managers will monitor accounts for these
actions being completed. 
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11 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Implemented N/A The procedure for managing rent accounts in arrears and establishing
repayment agreements with the aim of moving to an advance rent payment
basis, in line with tenancy terms, has been been strengthened within the new
procedures. As referred to in recommendation 2 above, there is a weekly review
of arrears management actions by the Area Housing Managers. A sample of
rent accounts in arrears have been examined as part of the follow-up audit and
confirmation obtained that repayment agreements are being arranged when
appropriate, and logged within the Housing system. 
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12 
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 Global Internal Audit
Standards (GIAS). 
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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13 
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 Service Manager Internal Audit and
Risk. 
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Page 81

APPENDIX 6
Moray Council
Internal Audit Section
1
DEPARTMENT: Economy, Enterprise & Operations
SUBJECT: Pool Cars
REPORT REF: 24'014
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: Confirm that policies and procedures for the arrangements and administration of pool cars are in place, up to date and
adequate. 
5.1 All policies and procedures should be
reviewed and updated on a regular
schedule to ensure content remains
current and valid. Thereafter, they
should be promoted and included
within the Council Intranet to ensure
officers are aware of their
Medium Yes 31/12/2024
(Revised
Implementation
Date
30/09/2025,
further revised
Part Implemented–  The Service has advised
that recruitment to the Fleet Officer (Pool Cars
and Projects) role has not yet been successful;
however, further recruitment attempts are
ongoing. Due to the absence of this post,
progress in updating policies and procedures
has been impacted. A revised implementation
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Appendix 6
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
requirements and conditions.  date
30/09/2026) 
date of 30 September 2026 has been agreed
with the Service; however, this is dependent
on the successful appointment of a Fleet
Officer (Pool Cars and Projects).  The Service
Manager Roads and Fleet also advised that,
should difficulties continue in recruiting a Fleet
Officer, alternative solutions will be
considered.
Key Control:  Effective controls in place in the management, booking and use of pool cars.
5.2 Services should be reminded that if
an officer books a vehicle and is later
not required, the booking must be
cancelled immediately. 
Low Yes 30/09/2024 Implemented -   The pool car booking site has
been updated with a notice reminding officers
that, if they book a vehicle that is later not
required, the booking must be cancelled
immediately.
5.3 Senior Management should be
informed to remind all officers that the
use of pool car vehicles must be in
accordance with the Employee
High  Yes  30/04/2024  Implemented -   A Three Minute Brief has
been issued to all Heads of Services to remind
officers of the need to comply with the Pool Car
Scheme- Employee Guide when using a pool
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Appendix 6
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
Guide. 
Service Managers should receive
monthly reports from Fleet Services
of any identified instances where the
use of a pool car is not in accordance
with the Employee Guide. 
High  Yes  31/12/2024
(Revised
Implementation                 
Date 30/09/2025
further revised
date
30/09/2026)
car. In addition, the Council’s internal staff
magazine, Connect, has been used to promote
the Pool Car Scheme, which included
guidance regarding frequently asked
questions on acceptable use. Promotion of the
scheme through Connect is ongoing. 
Outstanding- As detailed previously, the
Service has advised that recruitment to the
Fleet Officer (Pool Cars and Projects) role has
not yet been successful; however, further
recruitment attempts are ongoing. It is
intended that, once appointed, the postholder
will be responsible for developing additional
monitoring reports on the use of pool cars. In
the interim, where serious breaches of the
Pool Car Scheme- Employee Guide are
identified, these are investigated and reported
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Page 84

Appendix 6
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
to management. However, resource
constraints currently limit the ability to
undertake routine monitoring and reporting. 
The Service Manager Roads and Fleet has
advised that, due to difficulties in recruiting a
Fleet Officer, alternative solutions are also
being actively considered. A revised
implementation date of 30 September 2026
has been agreed with the Service.
5.4 Fleet Service in consultation with the
Accountancy Service should review
the rechargeable hourly rate used for
funding the pool car service.
Consideration should also be given to
recharging these costs to Services
every month. 
Medium Yes 30/06/2024
(Revised
Implementation                 
Date
31/12/2026)
Part Implemented– The Service, in
consultation with the Accountancy Service,
has reviewed pool car charges. Charges are
now calculated based on the actual costs of
fuel, maintenance, damage, and capital, and
are allocated to individual services on a usage
basis. However, it is intended that, upon
appointment of a Fleet Officer (Pool Cars and
Projects), the current recharging
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Page 85

Appendix 6
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
arrangements will be subject to further review,
again in consultation with the Accountancy
Service. A revised implementation date of 31
December 2026 has been agreed. 
5.5 A review of the current pool car fleet
should be undertaken to determine
whether there are any further value
for money opportunities to increase
the efficiency of the Service. 
Low Yes 31/12/2024 Implemented-  The Service has undertaken a
review to identify further value for money and
efficiency opportunities and to explore options
to improve the effectiveness and efficiency of
the pool car scheme. This includes reducing
costs, increasing customer satisfaction and 
supporting the Council’s net zero aspirations.
This work has been led by the Service
Manager Roads and Fleet through a “Project
Mandate” in accordance with the Council’s
Project Management Governance Policy. It
has now been supported by the preparation of
a more detailed business case to explore
potential opportunities to deliver a more
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Appendix 6
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
efficient pool car scheme.  The Service
Manager Roads and Fleet has advised that the
review process is ongoing, with further service
delivery options to be considered during
2026/27.
5.6 Regular physical inspections of pool
car vehicles should be introduced to
ensure essential documentation and
equipment are maintained in all
pool car vehicles. 
Low Yes Implemented Implemented– Regular physical inspections
of pool cars are now undertaken. In addition,
checklists detailing the equipment held in each
vehicle have been introduced. 
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Page 87

APPENDIX 7
1
Final Internal Audit Report (Follow Up)
Treasury Management 
May 2026
Distribution: Chief Financial Officer
Service Manager Finance Operations
Service Manager Strategic Finance
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 2
Priority 3 3
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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Page 88

Appendix 7 
2
Contents 
Page
Treasury Management 
1. Introduction & Scope 3
2. Key Issues  4 
Detailed Report 
3. Findings/Recommendations 5-14
4. Management Response 5-14 
Appendices 
1. Audit Terms of Reference and Definitions 
2. Statement of Responsibility 
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Appendix 7 
3
1. Introduction and Audit Scope 
The annual audit plan for 2024/25 provides for a review of the Council's treasury
management function. Treasury management is described by the Chartered
Institute of Public Finance and Accountancy (CIPFA) as the management of an
organisation’s investments and cash flows, its banking, money market and
capital market transactions; the effective control of the risks associated with
those activities and the pursuit of optimum performance consistent with those
risks. 
The overall objective of the audit was to ensure the Council has procedures and
controls in place to ensure compliance with the requirements of borrowing and
treasury management rules within the CIPFA Code of Practice on Treasury
Management in the Public Services 2021, which defines the policies and
objectives for treasury management activities and the CIPFA Prudential Code
for Capital Finance in Local Authorities 2021. CIPFA’s Code of Practice for
Treasury Management in the Public Services 2021 (Code) derives its legal
status from the Local Government in Scotland Act 2003. The Code
recommends that all public service organisations create and maintain a treasury
management policy statement, stating the policies, objectives and approach to
risk management of its treasury activities. 
Testing undertaken to meet this audit objective has been to assess the extent
to which there are adequate controls and procedures in place to provide
effective control over loans and investments, in particular: 
• Adequate procedures exist for the administration of treasury  
management;
• Loans and borrowing comply with the Treasury Management Policy; 
• Adequate authorisation controls and contingency arrangements exist; 
• Interest calculations are accurate and appropriately recorded; 
• Adequate fidelity cover is provided for officers involved in loans  
management and accounting; 
• Appropriate treasury management information is made available to 
relevant officers/management. 
It was noted that as at 31 March 2024, the Council held £105 million in short
term borrowing, £154 million in long term borrowing and approximately £10
million in short term investments.  
The audit was carried out in accordance with the Global Internal Audit Standards
(GIAS).   
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Appendix 7 
4
2. Key Issues 
•    The CIPFA Code of Practice on Treasury Management in the Public
Services 2021 (Code) recommends various reporting requirements
regarding the Council’s treasury management policies, procedures
and performance. It is pleasing to note that in accordance with the
Code, an annual report on treasury management strategy, plans and
performance is provided to the full Council. However, the audit review
noted that the Code also details further reporting requirements of a
“mid-year review” of treasury management activity to the full Council.
In addition, the Code recommends that consideration should be
given in reporting treasury management policies and practices to an
Audit and Scrutiny Committee to allow additional scrutiny of treasury
management activity as part of good governance arrangements. 
• In accordance with the Financial Regulations, the Council has
adopted the requirements detailed within the CIPFA’s Code of
Practice for Treasury Management in the Public Services. The Chief
Financial Officer should create and maintain suitable Treasury
Management Practices, setting how the policies and objectives
contained within the Policy Statement shall be achieved and
prescribing how these activities shall be managed and controlled. It
is pleasing to report that the Council's Treasury Management
Practices have been reviewed and updated in 2022 to reflect the
requirements of the revised Code in 2021. However, on reviewing the
Treasury Management Practices against the Code, it was noted that
further reference to environmental, social, and governance is needed
as additional investment considerations. In addition, Treasury
Management Procedures should include a review date to facilitate
any updates required from changes in organisational and staffing
structures. 
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5 
Findings/Recommendations - Treasury Management 2024/25 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1 Low The Council details how it manages, delivers
and controls its treasury management activities
within a procedural document called Treasury
Management Practices, which reflect the
requirements of CIPFA’s Code of Practice for
Treasury Management in the Public Services. In
accordance with Financial Regulations, the
Chief Financial Officer is responsible for
creating and maintaining these Treasury
Management Practices (TMP). The audit found
that the TMP was reviewed and updated in 2022
to reflect the requirements of the revised
CIPFA’s Code of Practice for Treasury
Management in the Public Services in 2021.
However, it was noted that no review date is
recorded within the TMP for reviewing and if
required, updating the procedures to reflect any
organisational or staffing changes. 
Consideration should be given to setting a
review date for reviewing the Treasury
Management Practices to ensure they are
regularly reviewed to also reflect, if
required, any internal organisational or
staffing changes in the management of
treasury activities. 
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6 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Finance Manager Yes 31/03/2026 Treasury Management Practices will be
reviewed and updated to reflect the recent
restructure in Financial Services. A future
review date will be included in this update. 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Outstanding 31/12/2026 Financial Services has recently undergone a period of restructuring and
staffing changes. This has included changes to officer responsibilities relating
to the treasury function, which have unfortunately delayed the implementation
of this recommendation. A revised implementation date of 31 December 2026
has been agreed with the Service. 
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7 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
2 Medium In accordance with the CIPFA Code of Practice
on Treasury Management in the Public
Services 2021 (Code), the Council provides an
annual report on the strategy, plan and
performance of its treasury management
function to the full Council. However, on
reviewing the Code, it was noted there are also
reporting requirements that as a minimum the
full Council should also receive: 
• “a mid-year review” report detailing its treasury
management activities; and the performance of
the treasury management function. 
• “The board/council, or the committee to which
some treasury management responsibilities
are delegated, will receive regular monitoring
reports on treasury management activities and
risks.” 
This is currently not being undertaken.
Quarterly treasury management performance
reports were previously provided to members
through the members portal, but due to staffing
vacancies within the Accountancy Service, this
had not been undertaken for 2024. 
In accordance with the CIPFA Code of
Practice on Treasury Management in the
Public Services 2021, a 6 monthly
treasury management activities and
performance report should be provided to
the full Council. Consideration should
also be given to the full Council or a
delegated Committee to receive regular
monitoring reports on treasury
management activities and risks. 
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8 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Finance Manager  Yes 30/11/2025 In accordance with the requirements of the
CIPFA Code of Practice on Treasury
Management in the Public Services 2021,
a mid-year review of treasury management
activities will be reported to the Council in
the future. 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Outstanding 30/09/2026 As detailed in Finding 1, Financial Services has recently undergone
restructuring and staffing changes, which have also impacted the
implementation of this recommendation. However, following the appointment
of new officers, the implementation of the recommendation can now be
progressed. The Chief Financial Officer has advised that the 2025/26 Annual
Performance Report will also include mid‑year review information for 2026/27,
which is intended to be reported to Council on 30 September 2026. 
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9 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
3 Low Financial Regulations 8.2 details: 
“A Treasury Management Policy Statement,
stating the policies and objectives of the
Council’s Treasury Management activities
shall be adopted by the Council in accordance
with Section 4 of the Code.” 
The CIPFA Code of Practice on Treasury
Management in the Public Services 2021
(Code), section 6, notes that “an organisation’s
treasury management policy statement
adopts” a recommended form of words “to
define the policies and objectives of its
treasury management activities”. A review of
the wording used within the Moray Council
Treasury Management Policy Statement noted
it is from a previous version of the Code. 
The Treasury Management Policy
Statement should be updated to reflect
the current recommended format detailed
within the CIPFA Code of Practice on
Treasury Management in the Public
Services 2021. In addition, Financial
Regulations point 8.2 should be updated
to reference Section 6 of the Code rather
than “Section 4”. 
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10 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Finance Manager  Yes 31/05/2025 The Council's Treasury Management
Policy Statement will be updated in
accordance with the requirements of the
CIPFA Code of Practice on Treasury
Management in the Public Services 2021.
Financial Regulations will also be
amended to refer to Section 6 of the Code. 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Implemented N/A An updated Treasury Management Policy Statement, in accordance with the
CIPFA Code of Practice on Treasury Management in the Public Services 2021,
was included in the Treasury Management Strategy Statement and Prudential
Indicators report considered by Council on 25 February 2026 (Item 6). In
addition, it was noted that the Financial Regulations have been updated to
make the correct reference to the aforementioned Code.   
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11 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
4 Low The CIPFA Code of Practice on Treasury
Management in the Public Services 2021,
Treasury Management Practice 1, Credit and
Counterparty Risk Management section
details a need for an “organisation's credit and
counterparty policies should set out its policy
and practices relating to environmental, social
and governance (ESG) investment
considerations.” A review of the Council’s
Treasury Management Practices noted no
reference to ESG for any investment
considerations. However, the Code details this
is still a “developing area, and it is not implied
that the organisation’s ESG policy will currently
include ESG scoring or other real-time ESG
criteria at individual investment level”.
In accordance with the CIPFA Code of
Practice on Treasury Management in the
Public Services 2021, consideration
should be given to updating the Council’s
Treasury Management Practices to
include references to environmental,
social and governance as additional
factors in any investment decisions. 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Finance Manager Yes 31/12/2025 Treasury Management Practices will be
amended to include environmental, social
and governance considerations as
additional factors in investment decisions.
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12 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Part Implemented 31/12/2026 An updated Treasury Management Policy Statement, in accordance with the
CIPFA Code of Practice on Treasury Management in the Public Services 2021,
was included in the Treasury Management Strategy Statement and Prudential
Indicators report considered by Council on 25 February 2026 (Item 6). In
addition, it was noted that the Financial Regulations have been updated to make
the correct reference to the aforementioned Code.   
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13 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
5 Medium  It was noted that the CIPFA Code of
Practice on Treasury Management in the
Public Services 2021 (Code)- TMP6
Reporting Requirements and Management
Information Arrangements, details as a
minimum requirement: 
“The body responsible for scrutiny, such as
an audit or scrutiny committee, will have
responsibility for the scrutiny of treasury
management policies and practices.” 
It is appreciated that in accordance with the
requirements of the Code an annual report
on the strategy, plan and performance of the
treasury management function is provided to
the full Council. However, as noted above,
the Code details a role for the Audit and
Scrutiny Committee to undertake further
scrutiny of treasury management policies
and practices. For noting, it was also noted
that the CIPFA's Audit Committees: Practical
Guidance for Local Authorities and Police
2022 also detailed that some authorities
Consideration should be given in reporting
treasury management policies and
practices to the Audit and Scrutiny
Committee. It is appreciated that reporting
of treasury management activity is already
provided to the full Council; however
governance arrangements could be
further strengthened in scrutinising the
Council‘s treasury management service at
the Audit and Scrutiny Committee. 
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14 
have nominated a function for their audit
committees to include: 
“Reviewing the treasury management policy
and procedures to be satisfied that controls
are satisfactory”.
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Finance Manager Yes 31/12/2025 In accordance with the CIPFA Code of
Practice on Treasury Management in the
Public Services 2021, Treasury
Management Policies and Practices will
also be reported to the Audit and Scrutiny
Committee for review by Members. 
Follow Up Review
Implementation
Status
Revised
Implementation
Date 
Internal Audit Review Outcome
Outstanding 29/09/2026 This recommendation has not yet been implemented; however, the Chief
Financial Officer has advised that there is an intention to report the Treasury
Management Annual Performance Outturn Report for 2025/26, including a
mid-year review for 2026/27, to the Audit and Scrutiny Committee meeting on
29 September 2026. 
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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 Global Internal Audit
Standards (GIAS). 
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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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 must not be disclosed to any third party or reproduced in whole or in part
without the written consent of the Moray Council’s Service Manager Internal Audit and
Risk. 
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Report to: Audit and Scrutiny
Committee 
Meeting Date: 18 June 2026     
Report by: Service Manager Internal Audit and Risk      
Author: Dafydd Lewis Contact Email: dafydd.lewis@moray.gov.uk 
Subject: Internal Audit Review – Milnes High School 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The report advises Committee on an internal audit review completed for the               period from
25 March 2026 to 18 June 2026.  
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 of Milnes High School; this project
has been agreed for review within the Audit Plan for 2025/26.  
3.  RECOMMENDATIONS 
3.1  It is recommended that Committee considers the contents of this report, seeks
clarification on any points noted and endorses the recommendations contained
within the report.   
Dafydd Lewis
Service Manager Internal Audit and Risk 
4.  BACKGROUND AND CONTEXT  
4.1  A review of the administrative arrangements within Milnes High School has been
completed. The scope of this audit was to undertake a review of the Devolved School
Management Scheme in terms of the allocation of funding and the management of these
funds at the School. In addition to undertaking an overview of how the School develops,
Item 6.
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monitors and controls its £3.7 million budget, the audit reviewed the management of the
staffing costs involved in delivering the curriculum. The audit checked that non payroll
expenditure complied with Financial Regulations and Procurement Guidelines. A review
was also undertaken to ensure appropriate accounting arrangements are followed when
managing school fund monies. The review found that within the audit scope, Milnes High
School was well managed. The detailed findings and recommendations from this review
are set out within the audit report in Appendix 1.  
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 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   
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6.3  Policy and Legal 
No implications directly arising from this report.  
6.4  Financial 
No implications directly arising from this report. 
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. 
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
Milnes High School 
May 2026
Distribution: Head of Education (Chief Education Officer)
Head Teacher
School Support Co-Ordinator
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 3
Priority 3 3
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
Milnes High School 
1. Introduction & Scope 3
2. Key Issues  3 
Detailed Report 
3. Findings/Recommendations 4-10
4. Management Response 5-10 
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 Internal Audit plan for 2025/26 provides for a review of a secondary school
within Education Services. This audit details the findings from the review
undertaken of Milnes High School as part of a rolling programme of audit visits
planned for secondary schools.   
The scope of this audit was to review the operation of the Devolved School
Management Scheme in terms of funding allocation and management at the
school level. Consideration was given to how budgets are affected by National,
Council and School priorities.  As part of the audit the arrangements for
administering the School Fund were also reviewed. 
The audit involved an overview of the processes in place to develop, monitor and
control the school’s annual devolved budget of £3.7 million, together with a review
of the management of staffing costs associated with delivery of the curriculum.
Testing was undertaken to confirm that non-payroll expenditure complied with
Financial Regulations and Procurement Guidelines. In addition, a review was
carried out to ensure that appropriate accounting arrangements are in place for
the management of School Fund monies, in accordance with School Fund
Regulations. This report sets out the findings from work undertaken for the
2025/26 financial year. 
The audit was carried out in accordance with the Global Internal Audit Standards
(GIAS). 
2. Key Issues 
• The audit identified that a bequest of £20,000, donated by a former pupil
to support students experiencing financial hardship during their studies,
remains unused within the School Fund. The donation was received in
January 2018; however, no eligibility criteria or administrative process
for disbursing the funds has been established. The School must ensure
that appropriate arrangements are put in place to implement the
conditions of the bequest, enabling eligible pupils to benefit from the
financial support intended by the donor. 
• A review of the School Fund records identified that a “miscellaneous”
category is being used to record a significant proportion of income and
expenditure. Testing confirmed that transactions allocated to this
heading included identifiable school activities and should have been
recorded against the appropriate activity‑specific categories. The use of
a broad “miscellaneous” classification reduces financial transparency
and weakens the audit trail, thereby impairing the School’s ability to
monitor, verify and analyse School Fund transactions accurately. 
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4 
Findings/Recommendations - Milnes High School 2025/26 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1 Low A review of the financial administration of the
School Fund for 2025/26 confirmed that
monthly bank reconciliations are performed to
verify recorded income and expenditure against
bank statements. However, it was noted that a
number of issued cheques remain unpresented,
with some exceeding six months from the date
of issue. Following consultation with the
Council’s Banking Service, it is understood that
banks may decline to honour cheques that are
more than six months old. The continued
inclusion of these expired cheques within the
School Fund records increases the risk that
bank reconciliations do not accurately reflect
the true financial position of the fund. This may
result in an understatement of available
balances and reduce the reliability of financial
information. 
Unpresented cheques should be subject
to monthly review, with any remaining
outstanding for more than six months
investigated. Where appropriate, such
cheques are cancelled or reissued if
payment continues to be due. 
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5 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
School Support Co-
ordinator
Yes Implemented All cheques older than 6 months have now
been cancelled. Monthly checks will take
place going forward.   
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6 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
2 Medium During the audit visit, it was noted that the
School held a number of prepaid gift vouchers
purchased from an online retailer. These
vouchers formed part of a larger order and have
been used as prizes for pupils under the
“Milne’s Make a Difference Award,” which is
issued each term. However, no control record
was in place to document the purchase,
distribution, or remaining balance of the
vouchers. Gift vouchers purchased from the
School Fund for use as pupil prizes should be
subject to appropriate control and record-
keeping arrangements. As cash-equivalent
items, vouchers present an increased risk of
loss or misuse if not supported by adequate
controls.
A control record for all gift vouchers
purchased through the School Fund
should be maintained. This record should
detail the date of purchase, quantity and
value of vouchers acquired, distribution to
pupils (including date and purpose) and
the remaining balance held.   
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
School Support Co-
ordinator
Yes Implemented A control record has now been created to
record purchase and issue of gift
vouchers.   
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7 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
3 Low Financial Regulations require an Inventory
Record to be maintained of all movable assets
valued at £500 or above. It was found that the
School maintains an Inventory Record of items
valued at more than £250, a figure specified in
a previous version of the Financial Regulations.
However, it was noted that approximately 40%
of the items recorded, including information,
communication, and technology equipment, did
not include a financial value. Recording
financial values in the Inventory List enhances
accountability, facilitates audits and insurance
compliance, and supports effective financial
and asset management. 
The School should update its Inventory
List of all movable assets to include an
estimated financial value for each item
where the value exceeds £500. 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Supervisory Technician Yes Implemented The School Inventory List has been
updated to include values of all items with
a value of £500 or above. New items will
be added as necessary when purchased.   
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8 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
4 Medium  The audit review of the School Fund identified a
£20,000 donation bequeathed by a former pupil
for the purpose of establishing an annual award
to support pupils experiencing financial
hardship. The bequest was received in January
2018; however, the funds have remained
unused, and no mechanism has been
developed to administer the award in
accordance with the donor’s stated intentions. 
School Fund Regulations specify that large
balances retained for any significant period
should be transferred to an interest-bearing
deposit account. This will facilitate improved
financial stewardship by maximising income
generated for the benefit of pupils. 
The School should develop and implement
a formal award mechanism to ensure the
bequest is used in accordance with the
donor’s wishes. This should include clear
eligibility criteria and a defined application
and approval process to support
appropriate governance arrangements. 
In accordance with the School Fund
Regulations, the School should also
transfer the bequest into an
interest-bearing deposit account until such
time as the funds are required. 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Head Teacher/School
Support Co-ordinator
Yes 02/07/2026  Senior Leadership Team will review the
terms of the bequest and establish a formal
reward mechanism with clear criteria.
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9 
Enquiries will be carried out into options for
interest earning accounts.   
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10 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
5 Low The review of School Fund records identified
that a significant proportion of income and
expenditure is being recorded under a broad
“miscellaneous” category. Testing confirmed
that many of the transactions allocated to this
heading related to identifiable school activities
and should have been recorded against the
appropriate activity‑specific categories. The
reliance on a wide‑ranging “miscellaneous”
classification reduces financial transparency
and weakens the audit trail. This limits the
School’s ability to monitor, verify and analyse
School Fund transactions accurately and
weakens the effective financial oversight by
management. 
An exercise should be undertaken to
review School Fund transactions to ensure
they are allocated to the correct
activity-specific categories. A review of
existing categories should also be
completed to ensure they are appropriate
and sufficiently detailed to reflect the
range of School Fund activities. 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
School Support Co-
ordinator
Yes 02/07/2026  Appropriate additional fund headings will
be added to the School Fund accounts for
next academic session. 
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11 
Appendix 1 
AUDIT TERMS OF REFERENCE AND DEFINITIONS 
1. Audit Objectives 
1.1 The overall audit objective is to provide an objective independent opinion on
the adequacy and effectiveness of controls / processes.  
1.2 The audit will for each controls / process being considered: 
• Walkthrough the processes to consider the key controls; 
• Conduct sample testing of the identified key controls, and 
• Report on these accordingly 
1.3 All audit reviews are carried out in accordance with Global Internal Audit
Standards (GIAS). 
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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12 
Appendix 2 
STATEMENT OF RESPONSIBILITY   
The responsibility for designing and maintaining a sound system of internal control to
prevent and detect fraud and other irregularities rests with management, with internal
audit providing a service to management to support them to achieve this objective.
The Internal Audit Section will assess the adequacy and effectiveness of the system
of internal control arrangements implemented by management and perform sample
testing on those controls in the period under review with a view to providing an opinion
on the extent to which risks in this area are managed. 
The Internal Audit Section will undertake testing with the objective of detecting
significant control weaknesses. However, the audit approach alone should not be
relied upon to identify all strengths and weaknesses in internal controls nor to find any
fraud or irregularity. Even sound systems of internal control can only provide
reasonable and not absolute assurance and may not be proof against collusive fraud. 
The matters raised in this report are only those that came to our attention during the
course of the audit review and are not necessarily a comprehensive statement of all
the weaknesses that exist or all improvements that might be made. Recommendations
for improvements should be assessed by management for their full impact before they
are implemented. The performance of the audit review undertaken should not be taken
as a substitute for management’s responsibilities for the application of sound
management practices. 
This report must not be disclosed to any third party or reproduced in whole or in part
without the written consent of the Moray Council’s Service Manager Internal Audit and
Risk. 
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Report to: Audit and Scrutiny
Committee 
Meeting Date: 18 June 2026     
Report by: Service Manager Internal Audit and Risk      
Author: Dafydd Lewis Contact Email: dafydd.lewis@moray.gov.uk 
Subject: Internal Audit Review – Capital Plan Project Review 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The report advises Committee on an internal audit review completed for the               period from
25 March 2026 to 18 June 2026.  
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 of a Capital Plan Project, which has been
agreed for review within the Audit Plan for 2025/26.  
3.  RECOMMENDATIONS 
3.1  It is recommended that Committee considers the contents of this report, seeks
clarification on any points noted and endorses the recommendations contained
within the report.   
Dafydd Lewis
Service Manager Internal Audit and Risk 
4.  BACKGROUND AND CONTEXT  
4.1  This audit examined the governance and management arrangements for civil engineering
projects within the Capital Plan managed by the Consultancy Service. The review
assessed how projects are identified, evaluated and approved for inclusion in the Capital
Plan. The audit scope also included selecting a project for detailed testing. This involved
Item 7.
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reviewing the contract from award through to completion of the works, with particular
focus on compliance with the Council’s Financial Regulations, Procurement Guidelines
and Conditions of Contract. It is anticipated that future Audit Plans will incorporate
similar reviews of projects delivered by other Council services.  
4.2  The audit found that projects were selected for inclusion in the Capital Plan through a
structured, evidence‑based process informed by asset condition assessments, strategic
planning documents and affordability constraints. Within the scope of the review, audit
testing confirmed that appropriate management arrangements were in place and
operating effectively.  However, an additional verification requirement was identified to
ensure that contractors undertaking work for the Council maintain appropriate and
up-to-date insurance cover throughout the duration of the contract. The audit report is
included in Appendix 1. 
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 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.   
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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. 
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. 
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
Capital Plan Project Review 
March 2026 
Distribution: Head of Operations & Environment
Service Manager Design Consultancy
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
Full
Priority 1 0
Priority 2 1
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
Capital Plan Project Review   
1. Introduction & Scope 3
2. Key Issues  4 
Detailed Report 
3. Findings/Recommendations 5
4. Management Response 6 
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 Annual Audit Plan for 2025/26 includes a review of a selected project within
the Capital Plan. The Capital Plan sets out how the Council intends to invest in
major long-term assets that support services and communities. These assets
include schools, housing, roads, bridges, public buildings and other infrastructure
with a long operational life. 
The Capital Plan for the period 2026–2029 was approved at a meeting of the
Council on 28 January 2026. The report sets out planned investment in buildings,
schools, roads and other public assets over the next three years. In addition, the
Capital Plan is approved annually as part of the Council’s budget process to
support transparent governance and provide appropriate oversight of major
investment activity. As at December 2025, the Capital Plan for 2025/26 consisted
of approximately 100 projects of varying size, with a total budget in the region of 
£50 million. 
This audit reviewed civil engineering–type projects within the Capital Plan that are
managed by the Consultancy Service. For 2025/26, this included 25 projects with
a total budget of £2.8 million. The audit scope included an examination of the
arrangements within the Consultancy Service for identifying, assessing and
approving projects for inclusion in the Capital Plan. This involved evaluating how
investment needs are identified, extent to which proposals are supported by asset
management plans, how projects are prioritised and the degree of alignment with
strategic objectives. The audit also assessed the processes for determining
affordability, as well as the governance arrangements for the ongoing review and
management of the capital programme. 
The scope of the audit also included the selection of an individual project for
detailed testing. This involved reviewing the contract from award through to
completion of the works, with a focus on compliance with the Council’s Financial
Regulations, Procurement Guidelines and the New Engineering Contract,
Conditions of Contract. The audit included a comparison of the costs within the
contractor’s tender submission against the final outturn costs. Additional works
instructed during the contract were examined to confirm that appropriate
project-management instructions had been issued in accordance with the
Contract Conditions. The audit also reviewed the Consultancy Service’s
arrangements for monitoring, controlling, and reporting project costs. This
included an assessment of whether expenditure is accurately recorded, routinely
monitored and reported against approved budgets within the Council’s Financial
Management System. 
This audit focused on projects within the Capital Plan that are managed by the
Consultancy Service. It is anticipated that future Audit Plans will include similar
reviews of projects delivered by other Council services. 
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Appendix 1 
4
The audit was carried out in accordance with the Global Internal Audit Standards
(GIAS). 
2. Key Issues 
• The audit found that, within the scope of the review, projects were
selected for the Capital Plan through a structured process informed by
asset management planning, strategic alignment and affordability
constraints. Asset-condition assessments are used to identify where
investment is required to maintain approved standards and proposals
are evaluated against key strategic documents including the Corporate
Plan, Local Outcomes Improvement Plan and the Local Development
Plan to ensure alignment with organisational objectives. Projects are
prioritised based on a range of factors, including legislative
requirements, efficiency benefits and essential maintenance needs. It is
recognised that the current financial climate is challenging, with
increased construction costs and funding uncertainty necessitating a
cap on capital spending. As a result, some projects have been delayed
or reduced to remain within affordability limits. All decisions are made in
line with the Prudential Code to ensure affordability and long-term
prudence, and the Capital Plan is approved alongside the revenue
budget to manage the impact of borrowing. 
• From a review of the Capital Plan, a project was randomly selected and
an examination was carried out of the works from contract award
through to completion, with a focus on compliance with the Council’s
Financial Regulations, Procurement Guidelines and the Conditions of
Contract. It was found that the Council’s Civil Engineering Small Works
Framework was used for the selection of contractors invited to tender
for the works. The contractor’s insurance certificate was verified in 2024,
when the Framework was established. A Works Framework is a
pre‑procured contractual arrangement that allows the Council to
commission construction related works quickly and compliantly, without
the need to run a full tender exercise each time. However, the works
were undertaken in 2025 and no verification had been carried out to
confirm that the contractor continued to maintain valid insurance cover.
Verification of contractor insurance is a key preventative control that
supports effective risk management, legal compliance, and the
protection of public funds. 
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5 
Findings/Recommendations - Capital Plan Project Review  2025/26 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1 Medium The audit randomly selected a project from the
Capital Plan and reviewed the works from
contract award through to completion, with a
focus on compliance with the Council’s
Financial Regulations, Procurement
Guidelines, and the New Engineering Contract,
Conditions of Contract. The audit found that the
contract had been administered in accordance
with these Regulations and Conditions. The
Council’s Civil Engineering Small Works
Framework was used to select the contractors
invited to tender, with contractors’ annual
insurance certificates verified in 2024 when the
Framework was established. However, the
works were undertaken in 2025 and no
subsequent verification was carried out to
confirm that the contractor awarded the contract
continued to hold valid insurance cover.
Ongoing verification of contractor insurance is
an essential control that supports legal
compliance, effective risk management, and the
protection of public funds. The audit review has
Verification should be carried out to
ensure that any contractor engaged
through a Framework holds appropriate
insurance cover prior to the
commencement of works. A copy of the
contractor’s valid insurance certificate
should be obtained and retained within the
contract file. 
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6 
subsequently confirmed the contractor’s
insurance cover for 2025.
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Service Manager Design
Consultancy
Yes 31/12/26    Framework contractors’ insurance details
will be checked annually on the
anniversary of the Framework to make
sure they are still valid. 
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7 
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 Global Internal Audit
Standards (GIAS). 
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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8 
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 Service Manager Internal Audit and
Risk. 
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Report to: Audit and Scrutiny
Committee 
Meeting Date: 18 June 2026     
Report by: Service Manager Internal Audit and Risk      
Author: Dafydd Lewis Contact Email: dafydd.lewis@moray.gov.uk 
Subject: Internal Audit Review – Common Good Fund 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The report advises Committee on an internal audit review completed for the               period from
25 March 2026 to 18 June 2026.  
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 of the Common Good Fund; this
project has been agreed for review within the Audit Plan for 2025/26.  
3.  RECOMMENDATIONS 
3.1  It is recommended that Committee considers the contents of this report, seeks
clarification on any points noted and endorses the recommendations contained
within the report.   
Dafydd Lewis
Service Manager Internal Audit and Risk 
4.  BACKGROUND AND CONTEXT  
4.1  A Common Good Fund consists of land, buildings, money and other assets that
historically belonged to the former burghs within Moray. These assets are now owned and
administered by Moray Council, but they must be managed separately from other Council
funds and used solely for the benefit of the inhabitants of the relevant former burgh area.
Item 8.
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Burghs were a unit of local government until the local government reorganisation in 1975,
when responsibility for Common Good Funds transferred to successor local authorities.
Income generated for the Common Good derives mainly from interest earned on reserve
balances held, as well as property and ground rentals. 
4.2  The Council is responsible for administering nine Common Good Funds covering the
communities of Buckie, Cullen, Dufftown, Elgin, Findochty, Forres, Keith, Lossiemouth
and Portknockie. The audit reviewed the administration of these Funds to assess
compliance with legislative requirements and Council policies regarding distribution,
authorisation and financial accounting. The review identified a need for some
administrative improvements. The detailed findings and recommendations from this
review are set out within the audit report in Appendix 1.  
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 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:
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☐ 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. 
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. 
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
Common Good Funds 
March 2026 
Distribution: Chief Financial Officer
Chief Governance Officer
Head of Housing, Property & Communities
Service Manager Legal Services
Service Manager Property, Estates & Assets
Acting Senior Accountant  
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 1
Priority 2 2
Priority 3 1
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
Common Good Funds 
1. Introduction & Scope 3
2. Key Issues  4 
Detailed Report 
3. Findings/Recommendations 5-11
4. Management Response 5-12 
Appendices 
1. Audit Terms of Reference and Definitions 
2. Statement of Responsibility 
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Appendix 1 
3
1. Introduction and Audit Scope 
The Annual Audit Plan for 2025/26 provides for a review to be undertaken of the
accounting arrangements and procedures in place for the management of
Common Good Funds. A common good is a fund of money and assets formerly
owned by a burgh and now owned and administered by a council. Burghs were a
unit of local government for most established urban communities in Scotland for
almost 1,000 years, until local government reorganisation in 1975, when common
good funds were transferred to successor local authorities that took over the
ownership and administration of the relevant areas containing those burghs. 
In accordance with the Local Government (Scotland) Act 1973, the Common
Good Fund must be administered separately from other local authority funds for
accounting purposes. The local authority decides how the funds (and assets) are
used but, in doing so, must have regard to the interests of the inhabitants of the
area to which the common good relates. Members act as "custodians" of the
Common Good when making decisions in relation to common good fund
applications, property and assets. Their role is similar to that of a trustee of a trust
fund.   
Moray Council is responsible for the administration of nine Common Good Funds
covering the separate communities of Buckie, Cullen, Dufftown, Elgin, Findochty,
Forres, Keith, Lossiemouth and Portknockie. Common Good Funds form part of
the Council's statutory reporting requirements and as at the 31st March 2025
year-end accounts, Common Good Fund assets amounted to £22.6 million, with
£296,000 of income received during the year. Assets held under the Common
Good are of varying types, including sites, agricultural land, parks, monuments
and fountains and sports and leisure facilities. Income generated for the Common
Good derives mainly from interest earned on reserve balances held, as well as
property and ground rentals.   
The scope of this audit project involved a review of the arrangements for Common
Good Funds to ensure that their administration is in accordance with legislative
requirements and Council policies and regulations relating to distribution,
authorisation and accounting. This included a review of asset recording
processes, income analysis and scrutiny of the administration of applications for
Common Good Funding. The adequacy of Common Good Fund activity reporting
was also reviewed.  
The audit was carried out in accordance with the Global Internal Audit Standards
(GIAS). 
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Appendix 1 
4
2. Key Issues 
• The audit found that the administration of the Common Good Fund was
generally in accordance with legislation and agreed Council policies /
procedures. However, the audit found these “procedures” for the
administration of Common Good Funds are contained in various
Committee reports from 2001 to 2024. The consolidation of the
administrative arrangements into a single reference document would
constitute an improvement by clarifying practices and ensuring that the
correct and consistent application of the process continues to be
exercised over funds administration. 
• Common Good Fund applications are considered by the appropriate
Ward Members, with expenditure permitted for civic activities,
maintenance of common good assets, charitable donations, memorials
and street decorations. Where applications rely on external funding,
common good payments are released only once it is confirmed that all
required funds have been secured. Audit testing found that supporting
invoices or receipts had not been obtained in all sampled cases to
evidence appropriate use of awards. As a result, administrative
processes require to be strengthened, with Accountancy officers
required to obtain documentary evidence to confirm that awards are
used for their agreed purpose.   
• The Community Empowerment (Scotland) Act 2015 requires local
authorities to establish and maintain a Register of  all Common Good
land, buildings and movable items. Following consultation with Legal
Services, it is considered that the Council currently maintains the
appropriate information required for a Common Good Register.
However, the development of a consolidated Register as a single point
of reference would provide greater transparency and improved access
for members of the public. 
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5 
Findings/Recommendations – Common Good Funds 2025/26 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1 Medium The Community Empowerment (Scotland) Act
2015 places a statutory duty on local authorities
to establish and maintain a register of all
property held for the common good. The Act
also requires that a Common Good Fund Asset
Register be made available on a website, or by
other electronic means, for members of the
public. The audit review noted that, while there
is currently no stand-alone Register, the Council
maintains the necessary information to populate
one. It was noted that  work is ongoing within
Legal and Estates Services to develop a
Common Good Fund Asset Register. 
A comprehensive Common Good Fund
Asset Register should continue to be
developed and on conclusion, it should be
made available for access by members of
the public, in accordance with statutory
requirements. 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Service Manager Legal
Services / Service
Manager Property,
Estates & Assets
Yes 31/03/2028 For short-term improvement in information
availability, work will be undertaken with
Finance & ICT Services to move existing
Common Good Asset lists to a more easily
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6 
identified location on the Council’s website
and this will be achieved by 30th April 2026.
To produce a comprehensive Common
Good Fund Asset Register, Legal and
Estates teams will work together on
accuracy of lists and produce linked maps
which is not a legal requirement but
considered beneficial for Council and
public interests. This requires the longer
timescale of 18 – 24 months to be set due
to significant staffing issues in both Legal
and Estates, however if this situation
improves the Services have committed to
implement at an earlier date.   
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7 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
2 Medium Documented operating procedures are in place
for administering the Common Good Funds.
However, these procedures are contained in
Committee reports dating from 2001 to 2024
and cover various elements, including the policy
on levels of reinvestment and distribution, the
unspent balance carry-forward policy,
overspend rules, and the distribution
authorisation policy. There is no single
document that details all these administrative
arrangements in full. The lack of consolidation
carries the risk that approved administrative
practices may not be fully understood. This
creates the potential for inconsistency in
application, particularly in the event of changes
to the parties involved in administering the
Common Good Funds. 
Consideration should be given to the
consolidation of the approved
administrative arrangements for Common
Good Funds into a single reference
document to ensure clear documentation
of all practices and continued consistency
in application. 
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8 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Acting Senior Accountant Yes 31/08/2026 A single document will be created detailing
all approved administration arrangements
of the Common Good Funds. 
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9 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
3 High A process is in place for community applications
for grant awards from the Common Good
Funds. Applications are considered by local
ward members. Eligible expenditure includes
civic activities, maintenance of Common Good
assets, charitable donations, memorials, and
street decorations. A sample of funding awards
were tested to confirm that they were in
accordance with eligible funding categories,
supported by valid applications, appropriately
authorised, and that the intended use of the
funds by the grant recipients had been
evidenced. Audit testing confirmed that all
awards were appropriate and correctly
authorised. However, from a random sample of
5 relevant awards, supporting receipts had not
been obtained in 3 cases. Although receipts
were requested from the grant recipients, they
were not submitted, and the non-submission
was not pursued. 
Supporting evidence of the appropriate
use of Common Good funding should be
obtained in respect of all relevant grant
awards. Any non-submission of invoices /
receipts following the initial request should
be pursued with the grant recipient.   
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10 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Acting Senior Accountant Yes 31/03/2026 A new process will be put in place to
ensure all receipts are provided by the
grant recipients. This will be checked on a
monthly basis by the Accountancy Service. 
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11 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
4 Low The Common Good Fund policy is for one third
of annual revenue income to be reinvested to
maintain the fund’s value, with the remaining
two thirds made available for distribution within
communities. Any undistributed balances in a
year can be carried forward for use in the
following two years. If funds are not distributed
within this period,  the unspent balances are
added back to the fund reserve. 
Analysis of the Common Good Funds over the
past three years found that three funds, namely
Cullen, Findochty and Portknockie have had
money returned to reserves because available
funding was not utilised by the communities.
The annual amounts returned ranged up to just
over £2,000. Although details of available funds
and application forms are published on the
Common Good Fund page of the Moray Council
website, further promotion of this funding
stream should be considered to better engage
local communities.   
Consideration should be given to
requesting members in wards where
Common Good Funds are available to
promote funding opportunities within their
communities. 
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12 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Chief Financial Officer Yes 25/08/2026 Going forward the annual report to
Committee on Common Good Fund spend
and forecasting will highlight any Common
Good Fund which has significant carry
forward at risk of being returned to
reserves if not utilised. This will highlight
available funding to Members and allow
promotion and consideration within their
communities.   
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13 
Appendix 1 
AUDIT TERMS OF REFERENCE AND DEFINITIONS 
1. Audit Objectives 
1.1 The overall audit objective is to provide an objective independent opinion on
the adequacy and effectiveness of controls / processes.  
1.2 The audit will for each controls / process being considered: 
• Walkthrough the processes to consider the key controls; 
• Conduct sample testing of the identified key controls, and 
• Report on these accordingly 
1.3 All audit reviews are carried out in accordance with Global Internal Audit
Standards (GIAS). 
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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14 
Appendix 2 
STATEMENT OF RESPONSIBILITY  
The responsibility for designing and maintaining a sound system of internal control to
prevent and detect fraud and other irregularities rests with management, with internal
audit providing a service to management to support them to achieve this objective.
The Internal Audit Section will assess the adequacy and effectiveness of the system
of internal control arrangements implemented by management and perform sample
testing on those controls in the period under review with a view to providing an opinion
on the extent to which risks in this area are managed. 
The Internal Audit Section will undertake testing with the objective of detecting
significant control weaknesses. However, the audit approach alone should not be
relied upon to identify all strengths and weaknesses in internal controls nor to find any
fraud or irregularity. Even sound systems of internal control can only provide
reasonable and not absolute assurance and may not be proof against collusive fraud. 
The matters raised in this report are only those that came to our attention during the
course of the audit review and are not necessarily a comprehensive statement of all
the weaknesses that exist or all improvements that might be made. Recommendations
for improvements should be assessed by management for their full impact before they
are implemented. The performance of the audit review undertaken should not be taken
as a substitute for management’s responsibilities for the application of sound
management practices. 
This report must not be disclosed to any third party or reproduced in whole or in part
without the written consent of the Moray Council’s Service Manager Internal Audit and
Risk. 
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Report to: Audit and Scrutiny
Committee
Meeting Date: 18 June 2026 
Report by: Service Manager Internal Audit and Risk
Author: Dafydd Lewis Contact Email: dafydd.lewis@moray.gov.uk
Subject: Internal Audit Review – Payroll
1. PURPOSE
☒ For Decision      ☐  For Information
1.1  The report advises Committee on an internal audit review completed for the               period from
25 March 2026 to 18 June 2026.
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 of the Payroll System; this project
has been agreed for review within the Audit Plan for 2025/26.
3. RECOMMENDATIONS
3.1 It is recommended that Committee considers the contents of this report, seeks
clarification on any points noted and endorses the recommendations contained
within the report.
Dafydd Lewis
Service Manager Internal Audit and Risk
4. BACKGROUND AND CONTEXT
4.1  As part of the 2025/26 Annual Internal Audit Plan, a review of the Council’s payroll system
was undertaken. The scope of the review was to assess the adequacy and effectiveness of
key controls governing the calculation and payment of employee remuneration. As the
payroll system is a core financial system, integral to the administration of staffing costs,
Item 9.
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totalling approximately £162 million in 2025/26, the audit focused on determining whether
appropriate arrangements are in place to ensure that salaries are processed accurately
and in accordance with statutory and contractual requirements. 
4.2   Audit testing involved reviewing a random sample of new starters, leavers, and continuing
employees to confirm that payments made were accurate, properly authorised, and
supported by appropriate documentation. The period examined covered 1 April 2025 to 31
January 2026. It is pleasing to report that, based on the testing undertaken and within the
scope of this review, overall, effective arrangements were found to be in place for the
management of the Council’s payroll system. Detailed findings and recommendations
arising from this review are provided in the audit report in Appendix 1. 
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 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
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☐ 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. 
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. 
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
Payroll 
May 2026
Distribution: Head of People, Change & Community Strategy
Service Manager People Management 
Senior HR and Payroll Administration Adviser
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 1
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
Payroll 
1. Introduction & Scope 3
2. Key Issues  3-4 
Detailed Report 
3. Findings/Recommendations 5-7
4. Management Response 6-8 
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 Internal Audit Plan for 2025/26 included a review of the Council’s payroll
system, focusing on assessing the adequacy and effectiveness of the controls in
place to ensure the accurate payment of salaries. 
The audit was undertaken by testing a randomly selected sample of starters,
leavers and current employees to assess the accuracy of pay calculations and to
confirm that appropriate supporting documentation was retained and approved.
The sample period for the audit testing was 1 April 2025 – 31 January 2026. The
scope of the audit also included a review to confirm that any deductions from
salary payments were made in accordance with statutory requirements or were
appropriately authorised by the employee. This review included verification of
amounts deducted and remitted to third parties, including HM Revenue &
Customs and the North East Scotland Pension Fund. 
The payroll system is a core financial system of the Council and is critical to the
accurate processing of staffing costs, which in 2025/26 amounted to
approximately £162 million. Since 2017, the Council has operated its payroll
function using the iTrent software application. It was noted that approximately
5140 officer payslips are processed each month. The iTrent system performs a
dual function in supporting both payroll and human resources activities. This
design facilitates the operation of key segregation-of-duties controls by ensuring
an appropriate separation between processes relating to officer appointments,
terminations, and grading, and the processing and payment of salaries.  
The audit was carried out in accordance with the Global Internal Audit Standards
(GIAS). 
2. Key Issues 
It is pleasing to report that, based on the testing undertaken and within the
scope of this review, effective arrangements were found to be in place for the
management of the Council’s payroll system. However, the following areas
were identified as requiring further development: 
• It was noted that the Payroll Section has documented Payroll Guidelines
that provide administrative guidance to support the accurate processing
of employee pay, ensure appropriate authorisation and promote
compliance with statutory requirements, while also facilitating effective
workforce management and safeguarding public funds. A review of the
Payroll Guidelines found that they are appropriate and relevant to
current operating practices; however, it was identified that certain
reference information and supporting documentation should be updated
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Appendix 1 
4
to reflect the current organisational structure and standing information.
Audit testing did not identify any discrepancies in the accuracy of salary
payments made to employees. However, given that payroll is a core
financial system, the Payroll Guidelines should be subject to an annual
review to confirm whether any further updates or changes are required. 
• Payroll Guidelines require services to inform the Payroll Section as soon
as they become aware that an employee is terminating their contract of
employment. Audit testing of a random sample of former employees
found that, in the majority of cases, services notified the Payroll Section
promptly. However, audit testing noted examples of delays that resulted
in salary overpayments, requiring recovery through the Council’s
invoicing system. It is appreciated that instances of overpayments are
low; however, all services should be reminded of the requirement to
notify the Payroll Section of employee contract terminations promptly, as
delays may result in salary overpayments that require additional
administration and the recovery of payments made in error. 
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5 
Findings/Recommendations - Payroll 2025/26 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
1 Low The audit noted that established Payroll
Guidelines are in place to provide operational
and administrative guidance to officers within
the Payroll Section and to services across the
Council and its partner organisations. A review
of the Payroll Guidelines confirmed that the core
content remains relevant and reflects current
payroll processes. However, it was identified
that certain reference material and supporting
documentation need to be updated within the
Guidelines to reflect the Council’s current
organisational structure and standing
information. Audit testing of a sample of salary
payments confirmed that no discrepancies were
found in the accuracy of payments to
employees. However, as payroll is a key
financial system, it is recommended that the
Payroll Guidelines be reviewed annually to
ensure they remain current and reflect all
procedural, structural, and legislative changes. 
Payroll Guidelines should be updated to
ensure that all reference information and
supporting documentation reflect current
operating arrangements and the
organisational structure. The Guidelines
should then be subject to an annual review
to maintain continued accuracy and
compliance with statutory and
organisational requirements. 
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6 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Senior Payroll and HR
Administration Adviser
Yes 30/06/2026  Full review of guidelines to be carried out
and updated version uploaded to
interchange.   
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7 
Ref Risk Ratings for
Recommendations
Audit Finding Audit Recommendation
2 Medium The Payroll Guidelines require services to notify
the Payroll Section promptly when an
employee’s contract of employment terminates,
in order to prevent salary overpayments. Audit
testing of a randomly selected sample of former
employees identified one instance of an
overpayment, resulting from the employing
service not notifying the Payroll Section of the
termination on a timely basis. This overpayment
has since been recovered through the Council’s
invoicing system. 
The audit sample size was increased and
additional testing was undertaken. No
significant delays were identified in the majority
of cases reviewed between the employee
termination notification date and the Payroll
Section being informed by services. However, a
further instance of delayed notification was
identified. Recovery of this overpayment from
the former employee is being progressed
through the Council’s invoicing system. 
All services should be reminded of the
requirement for the timely notification of
employee contract terminations to the
Payroll Section. 
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8 
Management Response
Responsible Officer Accepted (Yes/ No) Timescale for
Implementation
(Date Required)
Agreed Management
Action/Management Comment
Senior Payroll and HR
Administration Adviser
Yes 30/06/2026  An email to be sent directly to all Budget
Managers reminding them of the deadlines
for receipt of forms. This will then be
backed up by article in the June HR
Bulletin.
Late forms to be monitored and reminders
to be sent to appropriate managers at the
time.
Annual reminder to be sent to all budget
managers at the start of the calendar year
with the list of deadlines.   
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9 
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 Global Internal Audit
Standards (GIAS). 
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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10 
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 Service Manager Internal Audit and
Risk. 
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Report to: Audit and Scrutiny
Committee
Meeting Date: 18 June 2026 
Report by: Service Manager Internal Audit and Risk
Author: Dafydd Lewis Contact Email: dafydd.lewis@moray.gov.uk
Subject: Internal Audit Section Follow Up Review – Adult Social Care
Commissioning
1. PURPOSE
☒ For Decision      ☐  For Information
1.1  The report advises the Committee on an internal audit follow-up review completed for the
period from 25 March 2026 to 18 June 2026.
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 sets out the findings of a follow-up review undertaken by the Internal Audit
Section to evidence the implementation of recommendations contained within an
Improvement Action Plan prepared by Health and Social Care Moray. The Improvement
Action Plan was developed in response to the findings of an audit of adult social care
commissioning undertaken by KPMG Governance, Risk & Compliance Services (KPMG).
This follow-up review was agreed as part of the 2025/26 Internal Audit Plan.
3. RECOMMENDATIONS
3.1  It is recommended that Committee note the contents of this report and seek
clarification on any points noted.
Dafydd Lewis
Service Manager Internal Audit and Risk
Item 10.
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4.  BACKGROUND AND CONTEXT  
4.1  An audit was undertaken by KPMG in 2022/23 of adult social care commissioning. The
review was requested by the Audit, Performance and Risk Committee of the Moray
Integration Joint Board (MIJB) on 31 March 2022 (para 11 of minute refers).  The need for
the review was highlighted due to concerns raised by senior management regarding the
administrative arrangements within the Adult Social Care Commissioning Service and
the findings from a peer review report in January 2022. The peer review was an audit of
systems and procedures within the Adult Social Care Commissioning Service by the
Strategic Procurement Manager Aberdeen City and Aberdeenshire Councils Shared
Services (Commissioning), with the purpose of providing evidence and assurance that
the Commissioning Service was robust, appropriate, equitable, efficient and provided
value for money for the population of Moray. 
4.2 However, upon receipt of the “peer review” report, the Adult Social Care Commissioning
Service and a former Head of Service/Chief Social Work Officer (CSWO) raised concerns
regarding its validity. These concerns relate to the sample of contracts selected for
review and the assumptions drawn from the testing undertaken. Due to these misgivings,
the MIJB’s Audit, Performance and Risk Committee agreed on 31 March 2022 to request
an external audit review of the Adult Social Care Commissioning Service. KPMG was
subsequently appointed to undertake this review. The Internal Audit Section was not
involved in the procurement process, determination of the audit scope, or the review of
working papers/draft report to evidence any findings or recommendations made by
KPMG. However, the Internal Audit Section was subsequently asked by the former Chief
Officer of the MIJB to undertake a follow-up review to provide assurance on the
implementation of the recommendations contained within the audit report. 
4.3 The scope for this external review detailed the following “broad purpose of the audit”: 
•  To enable a reasonable level of assurance to be provided to the Integration Joint Board  
on the effectiveness of the Commissioning Service. 
•    From the audit findings, the opportunity to highlight to the Commissioning Service any
required improvements to ensure an adequate and efficient service can be delivered
in meeting the needs of the Moray population. 
The review was completed in February 2023, and the audit report, which included
recommendations for service improvements, was approved by the MIJB Audit,
Performance and Risk Committee on 30 March 2023 (para 11 of the minutes refers).
However, at the Committee meeting on 26 October 2023 (para 12 of the minutes refers),
an Improvement Action Plan was agreed. This plan was developed from the
recommendations previously detailed in the KPMG audit report. It was considered
necessary to provide greater clarity regarding those recommendations and to facilitate
more effective monitoring of implementation progress and reporting to committee.  
4.4 In accordance with the Internal Audit Plan 2025/26, a follow-up review was undertaken
to provide assurance on the implementation of the recommendations detailed in the
Improvement Action Plan. This has been a challenging exercise, as the Internal Audit
Section was not involved in the original review and has no evidence to support the
recommendations. Nevertheless, a follow-up review was completed and the report is
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attached in Appendix 1. The majority of recommendations have been implemented;
however, some have been completed through alternative arrangements that are now
more closely aligned with service delivery, or there has been a need to agree on revised
implementation timescales.  A further follow-up review is not proposed. Instead, an audit
of adult social care commissioning will be considered for inclusion in a future Internal
Audit Plan. 
5.  PROPOSALS  
5.1  This report provides Committee with a summary of findings arising from a follow up
review undertaken to evidence implementation of recommendations from an audit
undertaken of adult social care commissioning. 
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 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   
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6.3  Policy and Legal 
No implications directly arising from this report.  
6.4  Financial 
No implications directly arising from this report. 
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. 
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 Section
1
DEPARTMENT: Moray Integration Joint Board
SUBJECT: Adult Social Care Commissioning- Follow up review (Based from an audit undertaken by KPMG)
REPORT REF: 26’016
Follow Up Audit Review
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Internal Audit Report Category: Governance
1
(2.1.1a-
HSCM
Code)
Introduce a Terms of Reference for
the Managers Commissioning
Meeting
High Yes 31/08/2023 Implemented – Terms of reference for the
Managers’ Commissioning Meeting were
developed and agreed as final on 27/09/2023.
However, the Head of Service later decided
that a Managers’ Commissioning Meeting was
no longer required, as the purpose and
intended outcomes of this meeting are now
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Appendix 1
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
addressed through service specific groups
including the Learning Disability
Transformation Board, Care at Home Steering
Group, Health & Social Care Moray (H&SCM)
Mental Health Steering Group, Care Home
Owners and Managers meetings and the Drug
and Alcohol Partnership meetings. 
2
(2.1.1b)
Ensure Commissioning activities are
a standing item on every agenda for
Practice Governance Board and that
it is discussed.
High  Yes 31/08/2023  Not Implemented–   Agendas for the Practice
Governance Board meetings were reviewed
for the period May 2024 to October 2025 and
commissioning activities were not detailed on
any of the agendas.  H&SCM has decided on
alternative arrangements where
commissioning activities are discussed as
appropriate at Operational Management
Team meetings that are held fortnightly. No
further follow up required
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Appendix 1
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
3
(2.1.2a)
Ensure Commissioning is
represented at Practice Governance
Board
High  Yes 29/02/2024 Not Implemented - A review of a sample
period (May 2024 to October 2025) of Practice
Governance Board meeting agendas and
minutes noted that the Commissioning
Service was not represented at the majority of
the meetings. Alternative arrangements
implemented, where the Commissioning
Service is now represented at Operational
Management Team meetings. No further
follow up is planned.  
4
(2.1.2b)
The Terms of Reference for
Managers Commissioning meetings
will cover attendance and
expectations for Deputes and
decision making
High  Yes 29/02/2024  Implemented – The Terms of Reference for
the Managers’ Commissioning Meetings were
amended to include a requirement for
attendance and expectations regarding
deputisation and decision-making. However,
as detailed previously (Ref: No. 1), the Head
of Service decided that a Managers’
Commissioning Meeting is no longer required
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Appendix 1
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
due to Commissioning activities being
discussed at more service specific meetings. 
5
(2.1.3)
An Agenda and Action Log will be
created for Managers Commissioning
meetings.
High  Yes 31/05/2023 Implemented – The follow-up review
confirmed that agendas and action logs had
been maintained until 2024 for the Managers’
Commissioning Meetings. However, as
detailed previously, the Head of Service has
decided that there is no longer a requirement
for Managers’ Commissioning Meetings. 
Internal Audit Report Category: Team Structure and Roles 
6
(2.2.1a)
Ensure every member of staff that
works in the Commissioning Team
has a Job Description and it is
available
High  Yes 31/05/25023 Implemented – Job descriptions have been
provided for the following roles, which make
up the Commissioning Team: Senior
Commissioning Officer, Commissioning
Co-ordinator, and Clerical Assistant.
7
(2.2.1b)
Ensure every member of staff that
works in the commissioning team has
had the opportunity to discuss their
High  Yes 31/05/2023  Implemented – Discussions with officers from
the Commissioning Service confirmed that
there have been opportunities to review and
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Appendix 1
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
job description at supervision to
determine understanding
discuss their job descriptions during
supervision meetings. Supervision meetings
are held regularly and are diarised.
8
(2.2.2a)
Commissioning and Procurement will
meet regularly to corroborate the
contract timeline
High  Yes 31/08/2023  Implemented – Verbal confirmation has been
provided by both Commissioning and
Procurement Services officers that regular
meetings are taking place at which contracts
and timelines are being discussed. Diary
entries were observed.
9
(2.2.2b)
The Commissioning Manager and
Chief Finance Officer will meet every
month to review block funded
commissioned budgets
High  Yes 31/08/2023 Not Implemented– Whilst there are regular
meetings diarised between Commissioning
and Accountancy staff, monthly meetings
between the Commissioning Manager
(Service Manager) and the Chief Finance
Officer to discuss block contracts are not
taking place. Discussions have been held with
the Chief Finance Officer, and it is now the
view that monthly meetings are not required,
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Appendix 1
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
as budgets for block contracts are agreed in
advance. No further follow up is planned.
10
(2.2.2c)
A presentation of the remit of the
Commissioning Team and future
direction of the commissioning
function will be created and delivered
for colleagues in Health and Social
Care Moray.
High  Yes 31/08/2023 Implemented – Two Development days have
been held to date on 11 September 2024 and
14 May 2025, with another scheduled for 11
March 2026.  The Development days were
attended by a wide-range of staff from within
Health and Social Care Moray and the
sessions included a presentation by the Chief
Social Work Officer.  Themed group
discussions were held, covering
commissioning activities and processes and
the broader elements of social work activity.
In addition, the Strategic Delivery Plan for
2025-2028, approved in May 2025, commits to
the development of a Strategic
Commissioning Strategy under the
responsibility of the Senior Management
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Appendix 1
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
Team.  The Head of Service has advised
resources have been allocated to complete a
Commissioning Strategy by the end of June
2026.
11
(2.2.3a)
A team meeting will be held every
week to discuss workload, and this
will be monitored with a work tracker
High  Yes 29/02/2024  Implemented – The workload tracker was
observed and was up to date at the time of
testing for this follow-up review. Sample
meeting notes were also examined to confirm
that workload discussions were taking place.
12
(2.2.3b)
A Contract work plan that informs the
Departmental Procurement Action
Plan and a Monitoring annual work
plan will be created.
High  Yes 29/02/2024  Implemented – The Commissioning team
maintains a document (separate from their
Contracts Database) that highlights expiring
contracts and informs the work plan. It was
noted that regular meetings are also held with
Procurement Officers from Financial Services
to discuss work planning. The Departmental
Procurement Action Plan is a proactive
process. Whilst there are still a small number
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Appendix 1
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
of contracts that have expired, the majority
now have clear end dates, which can be built
into future planning processes for
Procurement and Commissioning Services.  
13
(2.2.3c)
All staff will engage with supervision
sessions with their line manager in
accordance with policy.
High   Yes 29/02/2024 Implemented – Supervision sessions are
regularly undertaken for all staff within the
Commissioning Service. These sessions
provide an opportunity for oversight and
support by reviewing staff wellbeing,
workload, performance, development needs,
and compliance with policies and standards. 
Internal Audit Report Category: Training
14
(2.3.1)
A training matrix will be created that
clearly details intended training for all
Commissioning Team staff members.
Staff will be trained in core and
service specific training.
Medium  Yes 31/08/2023 Implemented – A training matrix was
introduced in 2025. Confirmation of training
completed has been obtained on a sample
basis for Procurement, General Data
Protection Regulation, Customer Excellence
and Ethical Commissioning. 
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Appendix 1
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
Internal Audit Report Category: Process Documentation
15
(2.4.1)
A detailed Commissioning Procedure
will be created with underpinning
process maps and guidance.
High Yes 31/08/2023  Implemented – A Commissioning Procedures
document is in place and was approved by the
Head of Service in September 2023. The
Procedures became due for review in
September 2025. At the time of the follow-up,
the Service Manager advised that a review of
the Procedures is underway
16
(2.4.2a)
The Commissioning Procedure will
be discussed at the weekly
Commissioning Team Meetings and
supervision.
High  Yes 31/08/2023 
Revised
Implementation
Date 31/03/2026 
Part Implemented – Minutes of the
Commissioning Team meeting note that the
Procedures were last discussed in January
2024. The Service has been reminded of the
importance of ensuring regular updates to the
Procedures and maintaining their consistent
application.   A date for finalisation has been
agreed, and approval will be sought by 31
March 2026.
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Appendix 1
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
17
(2.4.2b)
A library of process maps and
guidance documents should be
maintained and made available to
staff for future reference.
High  Yes 31/08/2023  Implemented – A sample of guidance
documents and process maps has been
reviewed, which form part of a wider library of
supporting documents available to
Commissioning staff.
18
(2.4.3)
Budget Managers will be informed
through a workshop of their
budgetary responsibilities.
High  Yes 31/08/2023  Implemented - This is carried out by the
Accountancy service through Budget Manager
training. 
Internal Audit Report Category: Contract Management
19
(2.5.1)
An action plan will be put in place to
ensure all contracts are current,
appropriate and signed. Agreement
needs to be reached with
Procurement colleagues and Service
Managers regarding the timeline of
this.
High Yes 28/02/2025 
Revised
Implementation
Date 31/07/2026
Part Implemented- A Commissioning Service
Database is maintained which details
information including contract end dates and
the point at which a review should begin
regarding future procurement arrangements.
In addition, the Procurement Section within
Financial Services maintains an Action Plan
(DPAP) that sets out information and timelines
for all contracts. Regular meetings take place
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Appendix 1
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
between Commissioning and Procurement
Officers to discuss current contract
management and future service delivery
requirements. A review of the Commissioning
Service Database and the DPAP noted that a
small number of contracts (six at the time of
the audit) had expired between three and five
years ago. Explanations have been sought for
each of these six contracts. It has been
advised that, for three of the contracts, future
service delivery requirements will be
determined by the end of July 2026. The
remaining three contracts relating to day
services require a more significant review of
future delivery needs, which the service
intends to complete in 2026/27. No further
follow up is planned.
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Appendix 1
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
20
(2.5.2)
Invoices are matched against Service
Agreements within the CareFirst
system, ensuring approved
expenditure matches provider
invoice. This is detailed within the
Invoice Processing Standard
Operating Procedure (SOP).
High  Yes 28/02/2025 Implemented– Invoices are logged in a
spreadsheet and checked against the contract
with the care provider, which is saved within
the CareFirst system. A sample of invoices
from the spreadsheet was selected for testing
and was confirmed against the care provider
agreements. It was noted that the invoice
processing system guidance is detailed in the
Standard Operating Procedures; however,
these Procedures are currently under review,
despite being due for review in 2024.  
21
(2.5.3)
Invoices are recorded and approved
by Managers. Moray Council
Payments Team have a further check
in place to ensure all invoices have
appropriate approval. This is detailed
within the Invoice Processing
High  Yes 28/02/2025 Implemented - All invoices are uploaded to
the Financial Management System via the
online Accounts Payable system. Invoices are
then automatically allocated to budget
managers, determined by the financial codes.
The budget manager is required to authorise
each invoice individually (there is also a facility
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Appendix 1
Moray Council
Internal Audit Section 
13 
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
Standard Operating Procedure
(SOP).
to return an invoice to the administrator where
a query is evident). Following authorisation,
the invoice is passed to the Payments Section
for processing. At this stage, Payments can
also raise a query against an invoice.
22
(2.5.4a)
A robust process will be put in place
that provides a clear audit trail for the
authorisation of contracts and
associated documentation. 
High  Yes 28/02/2025 Implemented– A Commissioning Service
Database has been developed, which records
information in relation to care
contracts.  Detailed information is recorded
regarding the contract dates and stages as
part of an audit trail.  There is both a current
tab and a separate tab to record archived
information.
23
(2.5.4b)
Health and Social Care Management
will put in place a peer support
system and management quality
check system for the Commissioning
Team and Community Care Finance.
High  Yes 28/02/2025 Implemented - A weekly team meeting was
established for Senior Commissioning Officers
and the Service Manager with responsibility
for Commissioning.   Two development days
were organised and operated on 11/9/24 and
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Appendix 1
Moray Council
Internal Audit Section 
14 
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
14/5/25.  The first focused on the roles and
responsibilities of the Commissioning remit
and was attended by Service Managers from
both Children’s and Adult Services, and the
second looked at monitoring, with another
planned for March 2026.  Day to day
management of other Commissioning staff
has been allocated to one of the three Senior
Commissioners.  It should be noted that the
Service Manager remit has changed and
Community Care Finance is now managed by
the Chief Finance Officer.
Internal Audit Report Category: Strategy
24
(2.6.1)
The Commissioning Service will
attend and be active members of the
Strategic Planning and
Commissioning Group.
Medium  Yes 29/02/2024 Implemented – A follow-up review noted from
the minutes of the Strategic Planning and
Commissioning Group that meetings were
attended by the Service Manager with
responsibility for Commissioning. However,
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Appendix 1
Moray Council
Internal Audit Section 
15 
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
since March 2025 there have been no
meetings of the Strategic Planning and
Commissioning Group. 
At the time of the audit, the Chief Officer
provided an update in that recruitment was
actively being pursued for a new Head of
Service post which will hold responsibility for
Strategic Planning.  It was advised that these
meetings will resume during 2026. No further
follow-up is planned.
Internal Audit Report Category: Invoicing
25
(2.7.1)
The Community Care Finance (CCF)
team will include a process for
variances (when an invoice does not
match the CareFirst Service
Agreement) in a Standard Operating
Procedure (SOP) for the invoicing
process.
Medium  Yes 29/02/2024 Implemented – The follow-up review noted
that a process is now in place for investigating
variances between invoices from care
providers and the service agreements detailed
in the CareFirst system. It was noted that
officers from CCF query any variation with the
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Appendix 1
Moray Council
Internal Audit Section 
16 
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 providers and/or Social Work to verify the
reason for the deviation in cost.
26
(2.7.2)
The Community Care Finance Team
will ensure all evidence is retained
throughout the invoicing process to
ensure there is an adequate audit trail
for all decision making.
Medium  Yes 29/02/2024 Implemented – Changes to the
payment-processing system require that all
invoices are saved electronically as part of the
system requirements. Evidence is also
retained relating to any further action taken by
officers in the processing of an invoice for
payment. 
Internal Audit Report Category: Contract Register
27
(2.8.1)
The Departmental Contract Database
will be reviewed, brought up to date
and maintained.
High  Yes 31/08/2024 Implemented – It was found that the
Commissioning Service Database is being
updated following quarterly reviews of planned
and current commissioning activities
undertaken by Senior Commissioning
Officers. From these meetings, instructions
are provided to the Clerical Assistant to update
and maintain the Database.
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Appendix 1
Moray Council
Internal Audit Section 
17 
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
28
(2.8.2a)
The Departmental Contract Database
will be a protected document and
updated by the Commissioning
Team's Clerical Assistant under
instruction from Senior
Commissioning Officers and
Commissioning Co-ordinators.
High  Yes 31/08/2024 Implemented – The Commissioning Service
Database is updated by the Clerical Assistant
on a quarterly basis under the direction of
Senior Commissioning staff. Editing of the
Contracts Database is password protected.
.
29
(2.8.2b)
Senior Commissioning Officers will
carry out quarterly checks on the
Departmental Contract Database
regarding the information being up to
date and accurate with no gaps in
data.
High  Yes 31/08/2024 Implemented – The process has been
confirmed whereby the Clerical Assistant is
responsible for updating the Database, based
on updates arising from the quarterly meeting
and under the direction of Senior
Commissioning staff. In addition, it has been
confirmed that Senior Commissioning staff will
also review the Database regularly to ensure
it has been updated appropriately.
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Appendix 1
Moray Council
Internal Audit Section 
18 
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
30
(2.8.3)
The Departmental Contract Database
will be saved on the Moray Council
Social Care Shared Drive.
High  Yes 31/08/2024 Implemented– The follow up review has
verified that the Database is saved within the
Commissioning area of Social Care Shared
Drive. 
Internal Audit Report Category: Performance Management System
31
(2.9.1a)
A Performance Management system
should be put in place.
High  Yes 29/02/2024 
Revised
Implementation
Date 31/07/2026
Not Implemented– Whilst improvements
have been made in relation to monitoring the
progress of contract work through the use of a
workload tracker, there has been no progress
in developing a team-wide performance
management framework. There are currently
no team key performance indicators in place.  
Internal Audit Report Category: Contract Review
32
(2.10.1a)
The Contract Management Process
in place will be reviewed,
standardised and strengthened with
process maps. This process ensures
Medium  Yes 31/08/2023 Implemented – The Contract Monitoring
process has been reviewed and strengthened. 
Process maps are in place to support process
for the comments, complaints and incidents
aspects of contracts. In addition, evidence has
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Appendix 1
Moray Council
Internal Audit Section 
19 
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
monitoring of providers for suitability.
This will be reflected in the contract.
been noted of contract monitoring through
communication with care providers to verify
the quality and consistency of service delivery.
In addition, a Multi-Agency Monitoring and
Support Group has been established.
Continuous monitoring of care providers is
required to verify compliance with contract
conditions. 
33
(2.10.1b)
A Contract Record Document will be
created that will support the reviewing
of contracts.
Medium  Yes 31/08/2023 Implemented – A Contract Record Document
has been developed.  This is still a relatively
new process for Adult Care Commissioning
Services and is being completed as contracts
fall due for renewal consideration by the
Service.
Internal Audit Report Category: Block Contracts
34
(2.11.1)
All providers are subject to an annual
contract meeting and a 6 monthly
budget meeting to ensure best value
Low  Yes 31/08/2023  Implemented - A timetable of meetings has
been observed and tested, covering both
annual contract meetings and budget
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Appendix 1
Moray Council
Internal Audit Section 
20 
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
is being achieved. This is reported to
the Chief Finance Officer as required.
This will be in every contract going
forward.
meetings with care providers. It was noted that
where examples of services are being
delivered without a formal contract in place,
these providers were still receiving contract
meetings. 
Reporting to the Chief Finance Officer has not
been undertaken.  Further discussion should
take place between Commissioning and the
Chief Finance Officer in order to establish if
periodic updates would be beneficial.  No
further follow up is planned. 
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Report to: Audit and Scrutiny
Committee
Meeting Date: 18 June 2026 
Report by: Service Manager Internal Audit and Risk
Author: Dafydd Lewis Contact Email: dafydd.lewis@moray.gov.uk
Subject: Internal Audit Annual Report – 2025/26
1. PURPOSE
☒ For Decision      ☐  For Information
1.1  This report is submitted to Committee in terms of Section III (2) and (10) of the Council’s
Scheme of Administration relating to the consideration of reports from the Council’s
Internal Auditor and the provision of the annual assurance statement provided by Internal
Audit on the Council’s control environment.
2. SUMMARY
2.1 To provide the Committee with a copy of the Internal Audit Annual Report for the year
ended 31 March 2026, together with the Service Manager Internal Audit and Risk’s, opinion
on the adequacy and effectiveness of the Council’s system of internal control.
3. RECOMMENDATIONS
3.1 That Committee considers and notes the contents of the annual report given as
Appendix 1 to this report and seeks clarification on any matters relating thereto.
Dafydd Lewis
Service Manager Internal Audit and Risk
4. BACKGROUND AND CONTEXT
4.1  The purpose of this report is to present the Audit and Scrutiny Committee with the Internal
Audit Annual Report for the year ended 31 March 2026. The report includes the Service
Manager Internal Audit and Risk’s independent assurance opinion on the adequacy and
effectiveness of the Council’s overall control environment. 
4.2  The Global Internal Audit Standards (GIAS) require the Chief Audit Executive (CAE), the
Council’s Service Manager Internal Audit and Risk, to provide an annual internal audit
Item 11.
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opinion and report on the adequacy and effectiveness of the Council’s governance, risk
management and internal control arrangements, to support the preparation of the Annual
Governance Statement. 
4.3  To meet the requirements of the GIAS, the Internal Audit Annual Report 2025/26
(Appendix 1) includes the annual opinion of the Service Manager Internal Audit and Risk
and provides details of internal audit activity and performance during the year  
5.  PROPOSALS  
5.1  The Internal Audit Annual Report provides a summary overview of the nature and extent of
audit work carried out during the year to inform the audit opinion on the internal control
environment operating within the Council. 
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 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
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6.3  Policy and Legal 
No implications directly arising from this report.  
6.4  Financial 
No implications directly arising from this report. 
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. 
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
MORAY COUNCIL
INTERNAL AUDIT ANNUAL REPORT
1 APRIL 2025 to 31 MARCH 2026
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Appendix 1 
2
CONTENTS  
Page
SECTION 1 - INTRODUCTION 3
SECTION 2 - BASIS OF OPINION 3 - 4
SECTION 3 - SUMMARY AND LIMITATIONS OF WORK THAT SUPPORTS
OPINION
4-16
SECTION 4 - OPINION 16 
Contact Details 
Service Manager Internal Audit and Risk (CAE): Dafydd Lewis 
E-mail: dafydd.lewis@moray.gov.uk
www.moray.gov.uk 
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Appendix 1 
3
SECTION 1 – INTRODUCTION 
1.1 This report is issued in compliance with the Global Internal Audit Standards, which requires the Service Manager Internal Audit and Risk
(Chief Audit Executive (CAE)) to provide an independent yearly opinion on the adequacy and effectiveness of the Council’s governance,
risk management and internal control arrangements. It summarises the internal audit work undertaken during the year and offers
assurance to support the authority’s wider governance reporting.
1.2  It is management’s responsibility to maintain governance, risk management and internal control systems. Internal audit is an element
of the internal control framework established by management to examine, evaluate and report on accounting and other operational
controls. Internal audit assists management in effectively discharging its responsibilities and functions by examining and evaluating
controls. Internal audit cannot be held responsible for internal control failures.
1.3 Internal audit’s role includes assessing the adequacy of the risk management, internal controls and governance arrangements put in
place by management and performing testing on a sample of transactions to ensure those controls are operating effectively for the
period under review. 
1.4 Global Internal Audit Standards require officers of the Internal Audit Section to communicate on a timely basis, all facts and matters that
may affect their independence. I can confirm that all staff members involved in the 2025/26 internal audit reviews were independent of
operational processes and their objectivity was not compromised in any way. 
SECTION 2- BASIS OF OPINION 
2.1 This opinion is based on my knowledge of the Council’s governance, risk, control processes and on the audit work completed for the
period from 1 April 2025 to 31 March 2026. There are limitations to the level of assurance that can be provided, dependent on the scope
and coverage of the audit work completed. My evaluation is based on the following: 
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Appendix 1 
4
.
SECTION 3- SUMMARY AND LIMITATIONS OF WORK THAT SUPPORTS THE OPINION 
3.1 Internal audit operates independently within the Council. It helps the Council achieve its objectives by bringing a systematic, disciplined
approach to evaluating and improving the effectiveness of risk management, control and governance processes. There have been no
limitations imposed by management on the scope of audit work performed. The Internal Audit Opinion has been informed by the audit
work completed during the year. 
3.2 The Internal Audit Plan approved by the Audit and Scrutiny Committee on 12 February 2025 (Item 10) describes, in detail, the framework
for developing the audit work to be undertaken. The selection of audit topics was informed by corporate planning documents, budget
data, information drawn from the corporate risk register and consultation with members and senior management regarding potential
areas for review. The percentage of the Internal Audit Plan completed for 2025/2026, together with a comparison to the previous year, is
summarised overleaf, with a more detailed analysis of the status of each audit project also provided.
Overall
Opinion
Assurance
statements signed
by Heads of
Services
Risks identified in
the Council's
Corporate Risk
Register
Reports issued by
the External
Auditor and other 
external review
agencies
Audit work
undertaken by
Internal Audit
during the year to
31 March 2026
Follow Up Reviews
to evidence
implementation of
audit
recommendations
Governance, risk
management and
performance
monitoring
arrangements
Review of
corporate
governance
arrangements
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Appendix 1 
5
.
. Percentage of Internal Audit Plan Completed (%) - 2025/ 26 and 2024/ 25 
Status of each project included within the Internal Audit Plan 2025/26 
100%
87%
0%
13%
0%
20%
40%
60%
80%
100%
120%
2025/ 26 2024/ 25
Completed Carried Forward
Audit Projects                 Status
Payroll Completed
Procurement and Creditor
Payments
Completed
Counter Fraud Review  Completed
Democracy and Governance Completed
Banking and Reconciliation Completed
Absence Management Completed
National Non-Domestic Rates Completed
Moray Growth Deal Follow Up Completed
Levelling Up Fund Completed
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Appendix 1 
6
3.3 The internal audit work has been undertaken in accordance with an established methodology that promotes quality and ensures
conformance with the Global Internal Audit Standards and the approved Internal Audit Plan. 
Progress on the 2025/ 26 Internal Audit Plan 
3.4 Progress against planned audit work for the year to 31 March 2026 can be summarised as follows: 
• I am pleased to report that the 2025/26 Internal Audit Plan has been completed. Several significant reviews were undertaken during
the year, including an assessment of the effectiveness, transparency and statutory compliance of the Council’s democratic and
governance arrangements. The review found that key constitutional policies and regulations are in place; however, improvements
are required to enhance their accessibility for both members and officers. The audit also examined the governance processes for
supporting committee meetings, including the preparation and publication of agendas, minutes and supporting documents. At the
request of the Chief Executive, the scope of the review was expanded to consider systems and procedures relating to an instance
in which a committee report omitted an Integrated Impact Assessment and feedback from a public consultation. Overall, the
Council’s governance framework was found to be operating effectively within the scope of the review. Nevertheless,
recommendations have been made to strengthen the accessibility of governance documentation and to improve accountability,
monitoring and inter‑service communication when presenting budget‑related proposals to committee.
Capital Plan Completed
Education – Secondary School Completed
Commercial Harbours                               Completed (Draft Report)
Management of School Funds                               Completed (Draft Report)
Common Good Funds Completed
Adult Social Care
Commissioning- Follow up 
Completed
Transportation- Education Completed
Complex and Challenging
Behaviour Services
Completed
Procurement and Creditor
Payments (MIJB)
Completed
Social Care (Short Breaks)                               Completed (Draft Report)
Grampian Valuation Joint Board Completed
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Appendix 1 
7
• Each year, an element of the Internal Audit Plan covers work on core financial systems, which are of key significance to the good
governance of the Council. These systems receive the highest level of management control and are also reviewed on a cyclical
basis by the External Auditor to obtain the assurances required for the audit of the annual accounts. This year’s work included a
review of the Council’s arrangements for collecting and accounting for non‑domestic rates, as well as the verification of a sample
of payroll and creditor payments. Audit testing of creditor payments confirmed that expenditure had been accurately recorded and
processed through the Financial Management System (FMS); however, instances of non‑compliance with the Council’s Financial
Regulations and Procurement Guidelines were identified. This issue has been raised in previous years and continues to be a
concern. A range of measures has now been implemented to address these weaknesses. These include Heads of Service
reinforcing officers’ awareness of the Financial Regulations and providing additional training. Monthly budget-monitoring
communications now include regular reminders, with direct links to the Financial Regulations. In addition, as part of the induction
training programme, newly appointed employees are informed of the Financial Regulations and the requirement for compliance.. 
• A review was also undertaken of the Council’s arrangements for managing sickness absence to assess whether the policies,
procedures, and controls in place are adequate and are being applied effectively. The Council has developed a comprehensive
framework for supporting attendance, underpinned by the Health and Work Policy and associated guidance, which collectively set
out transparent processes intended to promote employee well-being and minimise disruption to service delivery. However,
analysis of sickness absence data shows a sustained increase in the average number of days lost per employee in recent years.
Audit testing of a random sample of employees on sick leave found that management interventions, such as timely reviews and
appropriate follow-up actions, were not consistently carried out in accordance with the Health and Work Policy. Effective absence
management is critically important, as it directly impacts service delivery, financial sustainability and overall organisational
resilience.  Management agreed to all internal audit recommendations, and it is also pleasing to note that, since the review, the
Council has approved a transformation project aimed at improving employee attendance, reducing absence-related costs and
delivering positive impacts for both the workforce and service delivery. 
• The Global Internal Audit Standards require the Service Manager Internal Audit and Risk (CAE) to consider whether the Council’s
resources are being used efficiently, effectively and ethically as part of the evaluation of governance, risk management and
controls. Additional monitoring has now been introduced to record instances where the audit process has identified quantifiable
recoverable income, savings, or incorrect expenditure during audit reviews. As this is the first year such information is being
formally recorded, some of the savings reported were originally identified during 2024/25, with follow-up work to confirm the
implementation of recommendations undertaken in 2025/26. 
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Appendix 1 
8
Savings identified during Internal Audit Reviews 
SERVICE AREA FINDING SAVINGS VALUATION
Leisure Services Reconciliation between the Financial Management System and the Fit Life?
Leisure Services system identified additional subscription income from
users.
£32,000
Disabled Parking Scheme Reconciliation of disabled parking badge applications to the Financial
Management System identified further invoicing requirements.
£24,000
Commercial Refuse Collection  The review identified additional charges associated with the sub-contracted
commercial refuse collection service.
£10,000 (annual)
Network Support Grant Approval was secured from Transport Scotland permitting the Internal Audit
Section to undertake verification of the Network Support Claim. 
£10,000 (annual)
Network Support Grant The verification of grant claims identified further expenditure that met the
eligibility criteria.
£16,431
Absence Management An overpayment in amounts payable was identified as having been made to
an external service provider.
£2,400
Environmental Services A duplicate payment was identified through the analysis of creditor
payments. 
£18,551
Health and Social Care Moray-
Children Services
A duplicate payment was identified through the analysis of creditor
payments.
£23,355
Health and Social Care Moray-
Adult Services (Out of Area
Placements)
Creditor testing identified a requirement to recover an Out of Area care
contribution. 
£20,517
Health and Social Care Moray-
Children Services
Testing identified a VAT accounting error requiring correction.   £9,276
TOTAL £166,530 
• The Internal Audit Section reports follow-up reviews to the Audit and Scrutiny Committee to evidence the implementation of
recommendations. It is recognised that services face significant operational demands that can, and often do, justify delays in the
timely implementation of agreed actions. It is therefore pleasing to report that, for the majority of follow-up reviews completed, most
recommendations had been implemented. However, some remain outstanding, requiring further follow-up reviews, which has
resulted in additional workload for the Internal Audit Section. The implementation of recommendations is a key determinant in
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Appendix 1 
9
assessing the adequacy and effectiveness of the Council’s internal control system. Where recommendations are not implemented
in a timely manner, weaknesses in control and governance frameworks remain unresolved. Senior management has acknowledged
these issues and has introduced enhanced monitoring to support services in implementing audit recommendations within the
agreed timescales. 
• The audit role for the Moray Integration Joint Board (MIJB) involves providing assurance that governance and financial arrangements
have been developed and are operating in accordance with policies and that selected systems and processes are suitably
controlled. It is acknowledged that the MIJB is a separate statutory body; however, the Council makes a significant ongoing funding
contribution to functions delegated to the MIJB. The MIJB Audit Plan for 2025/26 included audit reviews of Complex and Challenging
Behaviour Services, non-payroll expenditure and Social Care (Short Breaks)- Contributing to Your Care. Follow-up reviews
undertaken to evidence the implementation of recommendations have again been a particularly time-consuming commitment for
the Internal Audit Section. It is anticipated that this requirement will continue in 2026/27. However, senior management has
introduced a new administrative system, in consultation with the Internal Audit Section, to facilitate improved monitoring
arrangements for services implementing recommendations within the agreed timescales. 
• The audit review of MIJB non-payroll expenditure found that expenditure was recorded accurately in the Financial Management
System. However, examples were noted of payments made in advance without the required approval, VAT processing errors and a
significant duplicate payment arising from an administrative error. In addition, testing identified a case where action is required to
recover personal financial contributions for care home fees. The audit review of Social Care (Short Breaks) noted that there is scope
to consider the development of a charging policy for accommodated respite short breaks. This reflects findings from another audit
review, which also suggested exploring charging arrangements for non-residential care services.  The current financial environment
is recognised, alongside the need to consider income generation opportunities where appropriate. In addition to the projects
detailed within the Annual Audit Plan, a follow-up audit was undertaken to evidence the implementation of recommendations arising
from a review of adult social care commissioning. This audit had been outsourced to a private firm; however, the Internal Audit
Section was responsible for undertaking the follow-up review. The majority of recommendations have been implemented. However,
some have been addressed through alternative arrangements that are now more closely aligned with service delivery, or revised
implementation timescales have been agreed. 
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Appendix 1 
10 
• It is encouraging to note that a replacement for the current social work and social care case management system has been agreed,
with the new system planned for implementation by March 2027. This system is of significant importance, as it will be the primary
social work recording database, containing highly sensitive information and will also support the administrative and financial
requirements associated with the management of social care packages. I also note that the risk category regarding the MIJB's ability
to deliver services within available resources and achieve agreed savings targets has increased from high to very high. This reflects
increased financial pressures, including delays in achieving planned savings, rising demand and high-cost care packages. As the
Service Manager Internal Audit and Risk (CAE), I am concerned about the potential risks to which the Council may be exposed. I note
the Chief Financial Officer’s report to the Council on 25 February 2026, “2026/27 Budget and 2026–29 Financial Plan”, which
identifies that “the Council no longer holds non-earmarked reserves (outside its £6 million free general reserve) reducing the
capacity the Council has to absorb unexpected or unplanned costs.” Accountability for the Moray Integration Joint Board’s
overspend rests jointly with the Council and NHS Grampian, consistent with the financial governance provisions set out within the
Health and Social Care Integration Scheme.
• The Internal Audit Section also provides internal audit services to the Grampian Valuation Joint Board. The main financial systems
of the Assessor’s Service replicate those of Moray Council; therefore, the audit assurance obtained in respect of the controls within
the Council’s systems can be relied upon as also applying to the financial systems of the Assessor’s Service. However, there remains
a requirement to test transactions specific to the Assessor’s Service on an annual basis. This is necessary to provide the Treasurer
with an opinion on the adequacy and effectiveness of the internal control systems and procedures. This work includes confirming
the administrative processes for reporting revisions to the council tax and non-domestic rating lists by the Assessor to the
constituent authorities.  Based on the internal audit work completed on the Assessor’s Service for the financial year ended 31 March
2025, no significant concerns were identified.   
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Appendix 1 
11 
3.5  The total number of recommendations from the audit reviews undertaken during 2025/26 are set out in the following table: 
Report Risk Ratings for
Recommendations
System/ Testing
Assessment     
2025/26 Audit Plan High Medium Low 
Payroll 0 1 1 Substantial 
Procurement and Creditor Payments 1 3 1 Substantial
Counter Fraud Review 0 3 4 Substantial
Democracy and Governance 4 6 2 Substantial
Banking and Reconciliation 0 0 2  Full
Absence Management 2 8 1  Limited
National Non-Domestic Rates 0 2 2 Full
Moray Growth Deal Follow Up 2 3 2 Substantial
Levelling Up Fund 0 0 2 Full
Capital Plan 0 1 0 Full
Education – Secondary School 0 3 3  Substantial
Commercial Harbours 1 2 4 Substantial
Management of School Funds 2 3 1 Limited
Common Good Funds 1 2 1 Substantial
Adult Social Care Commissioning- Follow up  - - - N/A Follow up Review
Transportation- Education 1 4 2  Substantial
Complex and Challenging Behaviour Services 1 6 5 Substantial
Procurement and Creditor Payments (MIJB) 2 1 2 Substantial
Social Care (Short Breaks) 2 1 1 Substantial
Grampian Valuation Joint Board 0 0 0 Full 
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Appendix 1 
12 
3.6    The following performance measures for the Internal Audit Section for 2025/ 26 are set out below. Performance targets have been
determined through a review of other local authority internal audit services and meeting these targets is intended to be challenging. 
Measure Description Target Actual
2024/25
Actual
2025/26
Final Report Percentage of Auditee(s) responding within
20 days of receiving the draft report.
100% 100% 84%
Final Report Percentage of final audit reports issued
within 10 days of agreeing the draft report
100% 100% 100%
Audit Plan Delivery Percentage of audits completed v planned. 85% 87% 100%
Audit Budget Percentage of audits completed within
budgeted days.
80% 77% 84%
Audit Recommendations Percentage of audit recommendations
agreed.
90% 100% 100%
Customer Feedback Percentage of respondents who rated that
the audit added value and provided
meaningful results.
100% 95% 94%
Follow Up Reviews Percentage of Follow Up Reviews completed
v planned
100% 94%  87% 
• I am pleased to report that all planned projects in the audit plan have been completed. The Annual Internal Audit Plan is
designed as a challenging programme, taking into account available staff resources and the Internal Audit Section’s
additional duties and responsibilities. Following approval of the Annual Internal Audit Plan by the Audit and Scrutiny
Committee, all Heads of Service are informed of the projects scheduled for review in the forthcoming financial year. Heads
of Service are asked to remind staff that, during an audit review, they should respond promptly to information requests and
address audit recommendations within the appropriate timescales, namely, 5 working days for information requests and 20
working days for audit recommendations. Last year, delays were noted in services responding to audit enquiries and
recommendations. This affected the timely completion of reviews and, consequently, the reporting to the Audit and Scrutiny
Committee. To address this, the Council’s Financial Regulations have been updated to formalise the requirement for officers
to respond promptly to audit enquiries and recommendations. 
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Appendix 1 
13 
• All reports were issued as final within 10 days of agreement on the draft report. Officers agreed to all recommendations;
however, to ensure transparency, a recommendation that users of the Moray Community Equipment Service should include
issued equipment in their personal insurance cover was later amended to “not agreed” during the follow-up review.
Timescales for completing follow-up reviews are affected where revised completion dates for recommendations are
required. Feedback from officers has also been positive regarding the value of participating in the audit review process. 
3.7 Governance – In relation to the preparation of the Council’s Annual Governance Statement, it is considered that sufficient
information has been obtained to conclude that the Council generally complies with the latest good governance practices issued by
CIPFA/SOLACE, and that the Corporate Leadership Team and Heads of Service have a strong awareness of the challenges facing the
Council in the coming period. Written assurances from Heads of Service have also been considered in assessing governance
practices within individual service areas.
3.8 Key governance and internal control arrangements have been maintained, albeit capacity issues have required resources to be
prioritised towards essential services and the delivery of the Council’s strategic priorities. Progress has been made in several key
priority areas, including the review and update of first-tier governance documents. In addition, the remit of the Audit and Scrutiny
Committee has been reviewed, with further development of its scrutiny functions to include additional areas of responsibility. A
“Change Plan – Corporate Leadership Team Restructure Proposal” from the Chief Executive, intended to “provide the Council with a
more clearly defined and sustainable leadership structure for the foreseeable future” in addressing operational and strategic
challenges, was approved, with Phase 1 commencing in September 2025. The revised staffing structure formally recognises the role
of Service Manager Internal Audit and Risk, as the Chief Audit Executive (CAE), in accordance with the Global Internal Audit Standards.
The role includes direct administrative reporting to the Chief Governance Officer, as well as access to the Chief Executive, Chair of
the Audit and Scrutiny Committee and the Council Leader. This arrangement supports the independence and objectivity of the
Council’s Internal Audit Service.
3.9 The Service Manager Internal Audit and Risk (CAE) facilitated a workshop with Members of the Audit and Scrutiny Committee to carry
out self-assessments of compliance using the Good Practice Principles Checklist and the Evaluation of Effectiveness Toolkit from
the Chartered Institute of Public Finance and Accountancy (CIPFA) publication Audit Committees – Practical Guidance for Local
Authorities and Police (2022 Edition). This CIPFA publication provides guidance on the functions and operations of audit committees
in local authorities and police bodies and represents CIPFA’s view of best practice for audit committees across the UK. Following the
exercise undertaken in 2025, it is pleasing to report that the results of the self-assessment and evaluation demonstrated significant
compliance with good practice principles and a high degree of effectiveness.
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Appendix 1 
14 
3.10 Counter Fraud -  While the prevention of fraud and error rests with management through the design and operation of suitable control
systems, this process is supported by an annual audit of the Council’s counter-fraud framework. The review assessed governance
arrangements, fraud risk identification, staff awareness, internal controls, reporting procedures and collaboration with external
bodies, in line with best practice as set out in CIPFA’s Code of Practice on Managing the Risk of Fraud and Corruption. The scope of
the review also considered exposure to fraud arising from both internal and external threats and incorporated learning from fraud
cases reported across the public sector, including themes highlighted in Audit Scotland technical bulletins.
3.11 While no audit can provide complete assurance regarding the absence of fraud or irregularities within an organisation, the findings of
the counter-fraud framework review concluded that the Council has established a robust framework supported by key policies. These
include the Policy to Combat Fraud, Theft, Bribery and Corruption, Whistleblowing Policy and the Code of Conduct. However, areas
for improvement were identified, including the need for enhanced counter-fraud training for staff, formalising notification procedures
for suspected irregularities between services and the Internal Audit Section and continuing to refine National Fraud Initiative (NFI)
processes.
3.12 Internal Audit co-ordinates the Council’s participation in the NFI, a data-matching exercise involving a range of public sector bodies.
This activity complements other audit work and supports Internal Audit in assessing the potential for fraud and related risks. The
findings of the NFI 2024/25 data-matching exercise have been reported separately to this Committee. No fraud was identified;
however, the exercise generally highlighted information that was out of date or reflected timing differences. For example, if an
individual changes jobs or address around the time the data is submitted for matching, both old and new information may appear as
a match; however, this can be quickly discounted upon review.
3.13  Risk Management – procedures have been developed with a risk management policy in place and risk registers maintained at both
corporate and service levels. The Business Continuity and Risk Management Officer supports further implementation and
development of risk management arrangements, including the creation of a “Risk Appetite Statement.” A Risk Appetite Statement
outlines the Council’s willingness to accept various levels of risk in pursuit of its objectives and serves as a reference point when
considering risk as part of the decision-making processes of the Council and its committees. 
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Appendix 1 
15 
3.14 It was noted that the full Corporate Risk Register was reported to the Corporate Committee for review and consideration at its meeting
on 4 November 2025. Financial, staffing, information, communication and technology risks remain ongoing challenges for the
Council. These represent key risk areas, encompassing how the Council discharges its functions in terms of good governance,
manages its financial affairs and supports its workforce and utilises technology, which is essential to delivering most, if not all,
services. It is recognised that these are high-risk categories arising not only from internal circumstances but also from the broader
economic and social challenges faced by all local authorities.
Statement on Conformance with the Global Internal Audit Standards
3.15 The Local Authority Accounts (Scotland) Regulations 2014 require that “a local authority must operate a professional and objective
internal auditing service in accordance with recognised standards and practices in relation to internal auditing.” The recognised
standards adopted by all Scottish councils are the Global Internal Audit Standards, developed by the Chartered Institute of Public
Finance and Accountancy (CIPFA) and the Chartered Institute of Internal Auditors (CIIA). 
3.16 The Global Internal Audit Standards came into effect on 1 April 2025, replacing the Public Sector Internal Audit Standards. All Scottish
local authorities are required to undergo an External Quality Assessment (EQA) every five years. As part of the Council’s membership
of the Scottish Local Authorities Chief Internal Auditors’ Group, it was agreed that this requirement would be met through a reciprocal
arrangement, whereby each internal audit service reviews another council and, in turn, receives a review. An EQA of the Council’s
Internal Audit Section was completed by the Chief Internal Auditor of Perth and Kinross Council, and the findings were reported to the
Audit and Scrutiny Committee on 11 September 2024. The overall conclusion of the external assessment was that the Council’s
Internal Audit Section fully conforms to the Public Sector Internal Audit Standards. 
3.17  In addition to an EQA, an annual internal assessment is required to ensure compliance with the Global Internal Audit Standards
(GIAS). An ongoing compliance review was undertaken during 2025/26, resulting in updates to the internal audit reporting format,
project scoping documents and internal operating procedures. The Internal Audit Charter has also been reviewed and updated and
was reported to the Audit and Scrutiny Committee for approval on 19 November 2025 (Item 11). Included within the Audit Plan for
2026/27 is a formal assessment that will involve reviewing the Internal Audit Section’s procedures and processes against the GIAS to
identify areas for improvement and to inform a Quality Assurance and Improvement Plan (QAIP). 
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Appendix 1 
16 
3.18 The Global Internal Audit Standards requires the Service Manager Internal Audit and Risk (CAE), to assess whether internal audit
staffing resources are sufficient to meet the Council’s and partner organisations audit needs. Where it is believed that resource levels
may adversely impact the delivery of the Annual Internal Audit Opinion, this must be brought to the attention of this Committee. While
the current financial climate is acknowledged, demands on the Internal Audit Service have increased over the years and staffing
resources have previously been raised as a concern with members and senior management. However, with the appointment of a
temporary part-time officer, current staffing levels are considered sufficient to meet the auditing needs of the Council and its partner
organisations. 
3.19  When evaluating the adequacy of audit coverage, note that accountability for designing, implementing and maintaining an effective
system of internal control rests with management, rather than with Internal Audit Service. 
SECTION 4- OPINION 
4.1  Any system of control can only ever provide reasonable, not absolute, assurances that control weaknesses or irregularities do not
exist or that there is no risk of error, fraud, or breaches of laws or regulations. Furthermore, it is the responsibility of management to
establish an appropriate sound system of internal control and monitor its effectiveness. It is the responsibility of the Service Manager
Internal Audit and Risk (CAE) to provide an annual assessment of the robustness of the internal control systems. 
4.2   It is my opinion that, having given due consideration to the issues set out in this report, and based on the audit work undertaken and
other sources of assurance, reasonable assurance may be placed on the adequacy and effectiveness of the Council’s system of
internal control for the year ended 31 March 2026. 
Dafydd Lewis
Service Manager Internal Audit and Risk (Chief Audit Executive)
3 May 2026 
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Report to: Audit and Scrutiny
Committee 
Meeting Date: 18 June 2026     
Report by: Service Manager Internal Audit and Risk      
Author: Dafydd Lewis Contact Email: dafydd.lewis@moray.gov.uk 
Subject: National Fraud Initiative 2024/25 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to inform the Committee of the outcomes from the Council’s
participation in the National Fraud Initiative for 2024/25.  
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 exercise undertaken by the Cabinet
Office on behalf of Audit Scotland every two years. It involves matching data from various
Council systems with information provided by other councils and external organisations.
Participation in the NFI is mandatory for public bodies, including local authorities.
The agreed approach within the Council for the NFI 2024/25 exercise was for services to
review and document the reasons for data matches, while the Internal Audit Section
investigates potential fraud, monitors progress and reports on outcomes. 
2.2 Findings from participation in the 2024/25 NFI exercise have not identified any fraud but
have highlighted issues relating to data cleansing or valid reasons for matches, for
example where officers are employed in more than one post or where there are timing
differences in when information has been updated across different databases. However,
participation in the NFI supports the Council’s counter-fraud arrangements by providing
assurance that fraud prevention controls are effective. 
3.  RECOMMENDATIONS 
3.1  It is recommended that Committee considers Committee is asked to consider the
contents of this report; seek clarification on any points noted and otherwise note the
report.
Item 12.
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Dafydd Lewis
Service Manager Internal Audit and Risk 
4.  BACKGROUND AND CONTEXT  
4.1  The National Fraud Initiative (NFI) is a data-matching project undertaken by the Cabinet
Office on behalf of Audit Scotland. Public bodies, including local authorities, are
mandatory participants in this process. Each body is required to submit data it holds
regarding individuals and businesses that receive public funds, either as paid employees
or suppliers of goods, works, or services, or in the form of benefits and rates relief.
Information is also provided on individuals with housing tenancies and housing waiting
lists, as well as on recipients of Blue Badges. 
4.2  The matching process identifies data “matches” for each participant that are considered
worthy of investigation. There is no presumption of fraud; a match simply comprises two
or more records where there appears to be an anomaly that merits further review. For
example, if an individual is on Moray Council’s house waiting list from an address in
Dundee but is receiving Council Tax Reduction at an address in Aberdeen, this will be
recorded as a match. In most cases, the issue is that the information is out of date, such
as when the individual has relocated to Aberdeen. Similarly, an individual employed as a
teacher may appear on two payroll records with different authorities. This will also appear
as a match but is not irregular if the individual is legitimately employed part-time by each
council. 
4.3  A further common reason for matches occurring is timing differences. For example, if an
individual changes jobs or address around the time the data is submitted for matching,
both the old and new information may appear as a match. In such cases, the match can
usually be quickly discounted once the records have been checked. 
4.4   The 2024/25 matching process for Moray Council at the time of drafting this report
disclosed 3,350 matches across ten data themes as follows: 
• Creditors (Payments to Suppliers)               1914
• Council Tax Reduction Scheme     491
• Council Housing Waiting List     258
• Blue Badges        190
• Housing Tenancies      372
• Procurement         21
• Housing Benefits         24
• Adult Social Care                                                        28 
• Payroll                        52                   
3,350 
4.5 While the volume of matches is significant, experience from previous exercises has shown
that the incidence of fraud is low. Accordingly, following consultation with Audit Scotland,
a proportionate approach to testing has been taken. This has involved a high-level scan of
all matched data, supplemented by more detailed testing of a sample of items to confirm
that the outcomes are as expected. Further details are provided below, which conclude
that the principal benefits of participating in the exercise are twofold:
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• It provides assurance that the control systems designed to prevent fraud are
operating effective.
• It offers an opportunity to undertake data-cleansing activity to improve the
currency and accuracy of information held within Council systems. 
4.6  An additional area included within the 2024/25 data-matching exercise concerned adult
social care data. This was a new dataset covering residential care homes and personal
budgets; however, due to legislative requirements, the information was not uploaded until
late 2025, which has delayed reporting on the outcomes of this exercise. Participation in
the NFI is an ongoing statutory requirement for all Scottish local authorities as part of
every biennial data-matching cycle. Planning for the 2026/27 data‑matching exercise has
already begun and will involve the same data themes, but will also include business rates
relief awards. 
Outcomes 
4.7 Creditor Payments matches consider payee names, addresses, bank account details,
VAT calculations, and related information, primarily to identify duplicate or erroneous
payments. While a high volume of matches was generated, it should be noted that the
Council routinely makes legitimate payments of the same amount to a single supplier.
Typical examples include monthly school transport invoices where a contracted daily rate
applies, purchases by Fleet Services of more than one vehicle with identical
specifications, and payments for monthly care packages for an individual.  
4.8 Testing of the matches found no instances of fraud or irregularity; rather, there were
legitimate reasons for the match or minor data cleansing issues, e.g. where the same
supplier had two creditor records (the second having been set up in error). These issues
have now been addressed.  
4.9 
4.10 
Council Tax Reduction Scheme (CTRS) entitles qualifying households to a reduction in
the amount of council tax they pay. The level of reduction depends on individual
circumstances. CTRS awards are cross‑referenced with other CTRS claims, public sector
payroll and pension records, taxi licensing data, housing tenancy information and
Department for Work and Pensions (DWP) records of deceased persons. These data
matches are designed to ensure that claim forms have been accurately completed and
that relevant information, e.g., income, which can affect the level of award, has been
properly disclosed. In most cases, the correct disclosures had been made. However, a
small number of cases require further investigation. It should be noted that where an
individual is also in receipt of other benefits, the NFI system requires the match to be
referred to the DWP. The DWP determines any investigation work required and the Council
receives no feedback on the outcomes of these referrals. 
Council Housing Waiting List applicants are cross-referenced against other councils'
waiting lists, housing tenancy records, housing benefit claimants, and Department for
Work and Pensions (DWP) records of deceased persons. The investigation of these
datasets found no instances of fraud, only legitimate and explainable circumstances.
Examples included individuals with multiple local authority housing applications or valid
reasons for certain matches, such as the contact details of a social worker who assisted
applicants in completing their applications. However, the most significant reason for the
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4.11 
4.12 
4.13 
4.14 
4.15 
matches was that applicants had remained on the waiting list for many years, during
which their circumstances had changed, for example, a change of address or rehousing
elsewhere in the interim. At the time of submitting data to the NFI, the Housing Service
was undertaking a data-cleansing exercise to improve the accuracy of the Council’s
Housing Waiting List. The NFI data matches supported this process by enabling officers to
review all matches and verify the completeness of the exercise. It is therefore expected
that the next NFI data-matching exercise will result in significantly fewer matches within
these datasets. 
Blue Badge parking permits are compared with permits issued by other councils and
with DWP records of deceased persons. A review of the matches found that, for the
majority, the Service had already updated records to reflect changes in circumstances, or
that discrepancies were due to timing differences between notifications and the reports
used for the data-matching exercise. In addition, testing identified legitimate reasons for
some of the matches. However, a small number of badges had to be cancelled where the
Service had not been informed of a change in a recipient’s eligibility for a Blue Badge. This
was particularly evident in cases where the UK Government’s Tell Us Once service for
reporting a death had not been used.  
Housing tenancy records are cross-referenced with other councils’ tenancy records,
housing benefit claims, housing waiting lists and DWP records of deceased persons, all
for the purpose of validating the accuracy of the information the Council holds on the
occupancy of its housing stock. Testing noted that there were legitimate reasons for the
matches, such as recent moves or changes in family circumstances, with detailed
information available to evidence why the matches had been generated. As noted
previously, at the time of submitting data to the NFI, the Housing Service was undertaking
a data-cleansing exercise, which included a review of tenancy records. This review
identified a need to update standing information arising from earlier notifications of
changes in circumstances. This will have contributed to the number of matches identified;
however, it is expected that the next NFI data-matching exercise will result in significantly
fewer matches within these datasets. 
Procurement matches compare the Council’s payroll records with supplier records,
including company director information held by Companies House. These matches are
intended to identify potential conflicts of interest in the award of Council contracts;
however, no undisclosed conflicts were identified. The matches that were highlighted
related to known and legitimate situations (for example, Councillors who also serve as
Directors of Moray Leisure) and were not considered irregular. 
Housing Benefit matches are cross‑referenced with housing tenancy records, taxi
licensing information, housing waiting lists, recipients of Council Tax Reduction and DWP
records of deceased persons. These matches are designed to ensure that claim forms are
completed accurately and that all relevant information, such as income, which may affect
the level of Housing Benefit awarded, has been properly disclosed. The number of
matches in this category continues to decrease as more claimants transfer to Universal
Credit. Testing found no instances of fraud or irregularity. 
Adult Social Care. This is a new category in which payments made to individuals in
receipt of a personal budget or residing in residential care homes are matched to DWP
records of deceased persons. Due to legislative considerations, the NFI advised local
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4.16 
authorities to delay submitting this information until late 2025. Testing of individual
matches found no instances of fraud or irregularity; rather, the matches were attributable
to timing differences between the notification of changes in circumstances and the
processing of payments. One instance was noted where a match related to an identical
name; however, further investigation confirmed that these were separate individuals and
that correct accounting and administrative arrangements had been followed. 
Payroll matches compare the Council’s payroll records with data from other public
bodies to identify potential indicators of fraud, error, or irregularity. The purpose of the
exercise is to ensure that only legitimate employees are being paid, that salary payments
are accurate and that no individual is unlawfully receiving income from multiple public
sector organisations. The investigation found no instances of fraud or irregularity, but
rather legitimate reasons for the data matches. For example, one match related to a
supply teacher who had worked both for Moray Council and for a neighbouring local
authority. Other matches arose due to timing delays in updating employee information. In
addition, some individuals were found to be working part-time for the Council while also
employed by another organisation. These cases were reviewed and no issues were
identified, as appropriate separate working arrangements were in place. 
5.  PROPOSALS 
5.1  This report provides the Committee with a summary of the key findings arising from the
Council’s participation in the 2024/25 NFI exercise. The exercise identified a number of
data-cleansing issues, some of which were already in the process of being addressed. The
primary benefit of participation continues to be the assurance gained in support of the
Council’s counter-fraud framework. 
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 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.
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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 
Participation in the NFI is mandatory for all Scottish councils, however this has
advantages in that national protocols have been developed and agreed for data
management and security.  
6.4  Financial 
No implications directly arising from this report. However, there are costs for staff time
associated with organising and submitting the data and reviewing the returned matches.
These can be set against ‘notional’ savings e.g. a cancelled blue badge is valued by NFI at
£794, but these savings are indirect at best and more likely the benefits from participation
are in improving the accuracy of the systems from which data is derived. 
6.5  Risk 
The risk of not adequately reviewing returned matches is that a significant fraud may go
undetected, potentially resulting in substantial financial loss. However, as no such fraud
has been identified through the Council’s participation in the NFI data-matching exercise,
a proportionate approach to reviewing matches is considered the most prudent and
efficient course of action.  
6.6  Staffing 
There are no direct implications arising from this report. Work associated with the NFI is
carried out as part of the day-to-day duties of data owners within services. Time is also
allocated within the Internal Audit plan to coordinate and oversee the exercise.  
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.
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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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Report to: Audit and Scrutiny
Committee
Meeting Date: 18 June 2026
Report by: Executive Director Finance, Strategy and Transformation
Author: Jamie Fraser Contact Email: jamie.fraser@moray.gov.uk
Subject: Best Value Thematic 2025/26 – Asset Management
1. PURPOSE
☒ For Decision      ☐  For Information
1.1 The purpose of this report is to inform the Committee of the outcomes from the Best Value
Thematic 2025/26 – Asset Management review and invite consideration of the findings and
actions to respond to them.
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 outcomes from the Best Value thematic review on asset management carried out by
Grant Thornton, the Council’s external auditor, is reported to Committee for review and
consideration. The outcome report is attached at Appendix 1. 
2.2 Officers welcome the findings of Grant Thornton’s review and consider them to provide a
balanced and credible assessment of the Council’s approach to asset management in
delivering its corporate objectives, whilst balancing the challenges of financial
sustainability and climate change. The report highlights several good practices across the
Council’s asset management approach, including the use of a community asset transfer
case study. The review provides proportionate and constructive recommendations to
support continued improvement in achieving Best Value, which officers agree and have
proposed clear, timely and owned actions against.
2.3  Committee is invited to consider the key messages and highlight any points to be taken
into account in the development and progress of the relevant actions.
3. RECOMMENDATIONS
Item 13.
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3.1  It is recommended that the Committee review and consider the findings of the Best
Value Thematic Review and highlight any points to be taken into consideration in the
delivery of the relevant actions.
Jamie Fraser
Chief Financial Officer
4. BACKGROUND AND CONTEXT
4.1  Councils in Scotland have a statutory duty to demonstrate Best Value, introduced in the
Local Government (Scotland) Act 2003. Statutory Guidance defines Best Value as:
“ensuring that there is good governance and effective management of resources, with a
focus on continuous improvement, to deliver the best possible outcomes for the public.”
4.2  In March 2020 the Scottish Government published refreshed Best Value guidance
requiring councils to demonstrate a focus on continuous improvement in performance
around seven themes below.
i) Vision and leadership
ii) Governance and accountability
iii) Effective use of resources
iv) Partnerships and collaborative working
v) Working with communities
vi) Sustainability
vii) Fairness and equality
4.3  In 2023 a new thematic element was added to the Best Value audit regime. As part of the
annual Best Value audit requirements, in addition to well established financial auditing
and a cycle of best value auditing a sample of 32 councils, each year the Accounts
Commission now also directs local government external auditors across Scotland to
report on how local government is responding in relation to a particular theme. This is
referred to as a thematic review and the same theme is applied across all 32 councils in a
single year. For 2023 the theme was Leadership, for 2024 the theme was Workforce
Innovation and for 2025 it was Transformation. The theme for 2026 is  Asset Management.
4.4 The Asset Management thematic review is to report on how the Council is managing its
assets to achieve its corporate objectives and respond to challenges around financial
sustainability and climate change. The review was carried out through a self-assessment
process where the council gave written responses to a set of questions along with
supporting evidence. In producing the report, Grant Thornton applied the Audit Scotland
Thematic toolkit and considered the following questions posed by the guidance.
1. To what extent does the council have a clear asset management strategy and plans
that are affordable, align with its corporate objectives, the changing needs of its
population, and net zero commitments?
2. To what extent do the council’s governance and accountability arrangements
support effective asset management?
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3. To what extent does the council have a robust approach to working with partners
and communities in managing its assets?
4.5 The report considers available information up until the end of April 2026. Any significant
progress to the recommendations made in the report will be included within the Annual
Audit Report which is scheduled to be presented to Full Council on 29 September 2026.
5. PROPOSALS
5.1  It is proposed that the Committee review and scrutinise the outcome of the
thematic review undertaken by the external auditors and consider the 
actions proposed to address these and highlight any further points to be taken into
account in responding to the findings of the audit.  
5.2  The findings of the report for question one recognise the work that is being carried out
regarding asset management planning and strategy with specific reference to the
Corporate Asset Management Plan, which has been compiled in accordance with the
CIPFA Guide to Asset Management and Capital Planning. The report also noted clear
evidence of delivery of most planned actions within the plan alongside references made to
the application of the cap on capital as a mechanism for affordability, linkages to the
Medium to Long Term Financial Strategy and transformation. Officers welcome the
recommendation to update the Corporate Asset Management Plan, with an updated plan
to be presented to members for approval in August 2026. A holistic review of strategic
asset management is to be conducted by the new Section 95 Officer over the next twelve-
eighteen months.
5.3  The findings of the report for question two recognise the governance and accountability
arrangements in place to support effective asset management.  Specific mention is made
to the multiple layers of governance to asset management and the subsequent Capital
Plan allowing for scrutiny at appropriate levels. The report notes the continued capital
slippage but also recognises the work done in 2025/26 to address this, including the
introduction of a rolling three-year Capital Plan and completion of a pilot to incorporate
capital monitoring within the council’s financial management system, improving reporting
and providing better detail to budget managers. Recognition is also made that capital
slippage, at times, is outside the control of the Council, particularly when a reliance is
placed on external partners to deliver.
5.4  The findings of the report for question three recognises the work the council does in regard
to partnership working and community engagement. Particular reference is made to the
strong and proactive approach the Council has in working with communities and how that
work feeds into decision-making on asset management. A case study on Lesser Borough
Briggs (the Gleaner Areana) was provided as evidence. A recommendation to update the
Community Asset Transfer Policy and has been agreed by officers.
5.5  Management welcomes the findings of Grant Thornton and considers them to provide a
balanced and credible assessment of the Council’s approach to asset management in
delivering its corporate objectives, whilst responding to the challenges of financial
sustainability and climate change. The report does not highlight any material weaknesses;
rather, it provides proportionate and constructive recommendations to support continued
improvement in achieving Best Value.
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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 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 are no policy and legal implications arising from this report.
6.4 Financial
There are no direct financial implications arising from this report. Effective asset
management is a key contributor toward financial sustainability.
6.5 Risk
There are no risk implications arising from this report.
6.6 Staffing
There are no direct financial implications arising from this report.
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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 the Corporate Leadership Team.
8. BACKGROUND PAPERS
8.1 Held within Accountancy section.
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Page 221

Asset Management – How well are
councils managing their assets to
achieve their corporate objectives
and respond to challenges around
financial sustainability and climate
change?
Best Value Thematic 2025/26
Moray Council
Prepared for those Charged with Governance and the
Controller of Audit
12 May 2026
APPENDIX 1
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|© 2026 Grant Thornton UK LLP
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Table of contents
2
01 Scope of the audit 3
02 Executive summary 5
03 Asset management planning 6
04 Governance and performance 12
05 Partnership working and community engagement 19
Appendices 25
A Improvement action plan 26
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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 external
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 Moray Council or all
weaknesses in your internal controls. This report has been prepared solely for
your benefit and Audit Scotland (under the Audit Scotland Code of Audit
Practice 2021). We do not accept any responsibility for any loss occasioned to
any third part 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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01 Scope of the audit
Asset management directly impacts how
councils provide services and achieve their
own corporate priorities and longer-term
financial sustainability. Limited capital
budgets make it challenging for councils to
maintain their existing assets and estates,
invest in new assets and achieve net zero
targets.
This report sets out how well the Council is
managing their assets to achieve their
corporate objectives and respond to
challenges around financial sustainability
and climate change.
The Accounts Commission’s Strategy (2021-
2026) sets out its priorities to focus on
inequalities, funding, communities and
recovery. The Code of Audit Practice sets out
the Best Value work required to report on
these priorities.
Code of Audit Practice 2020 – Best Value reporting requirements
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. This is set out in the 2020 Code of Practice, issues by Audit Scotland:
As part of their integrated wider scope annual audit work, appointed auditors use a risk-
based approach to assess and report whether the audited body has made proper
arrangements for securing Best Value and is complying with its community planning
duties, including reporting progress against previous Best Value findings and
recommendations.
The Accounts Commission also requires the Controller of Audit to report to the Accounts
Commission on each council or Integrated Joint Board at least once over the five-year
audit appointment on the body’s performance on its Best Value duty. This enables the
Accounts Commission to make findings for improvement where appropriate.
The Accounts Commission reports nationally on thematic aspects of local government
bodies’ approaches to, and performance in, meeting their Best Value and community
planning duties. Local government appointed auditors report locally on any such Best
Value thematic work prescribed by the Accounts Commission
3
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01 Scope of the audit - continued
This report covers the thematic aspect of the Best Value audit
requirements. The Accounts Commission has directed auditors to
report on how well councils are managing their assets.
In producing this report, we have applied the Audit Scotland
Thematic toolkit and considered the following questions posed by the
guidance:
• To what extent does the council have a clear asset management
strategy and plans that are affordable, align with its corporate
objectives, the changing needs of its population, and net zero
commitments?
• To what extent do the council’s governance and accountability
arrangements support effective asset management?
• To what extent does the council have a robust approach to
working with partners and communities in managing its assets?
An improvement plan is included at Appendix A of this report. This
sets out our audit recommendations in key areas, and the council’s
planned response including responsible offices and dates for
implementation.
The coverage of the work is in line with the expectations for council’s
arrangements for the seven Best Value themes in the Local
Government in Scotland Act 2023, Best Value Statutory Guidance
2020.
We would like to thank the Corporate Leadership Team for their
engagement in the Best Value Thematic process and for the detailed
supporting evidence provided to the audit team to assist us forming
our conclusions, in line with the agreed timescales.
This report is scheduled to be presented to the Audit and Scrutiny
Committee in June 2026. Any significant progress to the
recommendations made in this report will be included within the
Annual Audit Report which is scheduled to be presented to Full
Council on 29 September 2026.
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02 Executive summary
5
Question Conclusion
To what extent does the council have a
clear asset management strategy and
plans that are affordable, align with its
corporate objectives, the changing
needs of its population, and net zero
commitments?
The Council have a Corporate Asset Management Plan (CAMP), which was last updated in December
2024, and included actions which covered 2024/25. Whilst the plan aligns with the Council’s priorities and
the changing needs of its population, it is now considered to be out of date.  The Council must ensure that
the CAMP is refreshed and that the arrangements in place for asset management are up-to-date. The
Council have applied the CIPFA “cap” confirming that their Capital Plans are affordable. The Council has
noted that due to many years of below-inflationary funding, current plans are not sufficient to deliver the
level of investment required across the estate, which means the Council is required to continually prioritise
and rationalise its asset base.
The Council should ensure that actions detailed in the plan are followed up and that existing governance
arrangements are accurately reflected in the CAMP. The Council have approved a ten-year Capital Plan
which confirms a borrowing requirement of £253 million over the period. The Council have a range of
documents which highlight net zero considerations, including a route map to net zero.
To what extent do the council’s
governance and accountability
arrangements support effective asset
management?
The Council’s governance and accountability arrangements provide a clear framework that supports
effective asset management and provide assurance that asset management decisions are transparent and
aligned with the Council’s priorities. The Council has changed to a three-year planning approach for
capital due to significant levels of slippage in recent years.  The Council’s LGBF performance for asset
management is below the Scottish average, and significant investment has been made by the Council in
these areas. The investment is having an impact and performance trends are improving from a low base. 
To what extent does the council have a
robust approach to working with
partners and communities in managing
its assets?
The Council works well with its partners and communities in the management of its assets; however
arrangements could be strengthened by setting out how this works in practice in a policy document.  The
Council has mechanisms in place to engage with stakeholders, support community involvement, and work
collaboratively with partners to maximise asset use and value. The council has a clear and transparent
approach to supporting and assessing community asset transfer requests.
We have raised a number of recommendations for improvement which can be found at Appendix 1 of this report.Page 225

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Asset management
planning
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Asset management planning
To what extent does the council have a clear asset management strategy and plans that are affordable, align with its
corporate objectives, the changing needs of its population, and net zero commitments?
The Council have a Corporate Asset Management Plan (CAMP), which was last updated in December 2024, and included actions which covered 2024/25. Whilst
the plan aligns with the Council’s priorities and the changing needs of its population, it is now considered to be out of date. The Council must ensure that the
CAMP is refreshed and that the arrangements in place for asset management are up-to-date. The Council have applied the CIPFA “cap” confirming that their
Capital Plans are affordable. The Council has noted that due to many years of below-inflationary funding, current plans are not sufficient to deliver the level of
investment required across the estate, which means the Council is required to continually prioritise and rationalise its asset base.
The Council should ensure that actions detailed in the plan are followed up and that existing governance arrangements are accurately reflected in the CAMP. The
Council have approved a ten-year Capital Plan which confirms a borrowing requirement of £253 million over the period. The Council have a range of documents
which highlight net zero considerations, including a route map to net zero.
Council’s capital programmes are a necessary component of modernising
services to improve outcomes for local communities. Doing this successfully
requires good strategic medium-to long-term asset management and planning.
The Accounts Commission’s Local government budgets 2025/26 briefing
reported that capital funding for 2025/26 had increased but remained lower
than in 2023/24 and that investing in new buildings and assets is increasingly
expensive. Councils are relying on borrowing as the main source of funding for
capital projects. In 2025/26, councils intend to borrow £3.13 billion, an increase
from £2.67 billion in 2024/25.
The Council have a Corporate Asset Management Plan (CAMP) which was last
updated in December 2024 and approved by Full Council. The CAMP sets out
the asset objectives and asset standards for each asset class. The CAMP
describes the arrangements that the Council has made for asset management
planning and aims to link the asset management planning process to the
Council’s corporate priorities. It makes explicit links to financial, environmental
and economic sustainability.
The latest version of the CAMP confirmed seven actions planned for asset
management in 2024/25. No updates were made to the CAMP for financial year
2025/26 and therefore it is out of date. The Council are aware of the need to
update the CAMP, but the update has been  deferred until the transition of the
Section 95 officer role.  The previous Section 95 officer retired in March 2026,
and an updated version of the CAMP will be completed once the new Section 95
Officer (the Executive Director of Finance, Strategy and Transformation) has had
the opportunity to review the overall asset management strategy of the Council.
Recommendation 1.
The current version of the CAMP contains limited detail on longer term asset
management. It is important that the CAMP takes a longer-term view to ensure
that investment decisions are sustainable, strategically aligned, and resilient to
future demands. By considering the longer-term condition, the Council can plan
proactively rather than reactively, reducing costs and ensuring best value.
Recommendation 1.
The Council see Asset Management as an iterative process, driven by a range of
considerations, including asset condition and suitability. Asset Management is
also recognised in the Council’s Medium to Long Term Financial Strategy as one
of the main vehicles which the Council will use to make strategic shifts in
expenditure to achieve financial sustainability.
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Asset management planning (2)
The Council considers the need for its asset base to reflect and support its
priorities, and the affordability of asset plans is recognised in the Council’s asset
management process as a pivotal requirement. The Council has noted that due
to many years of below-inflationary funding, couple with an ageing asset base,
current plans are not sufficient to deliver the level of investment required across
the estate, which means the Council to continually required to prioritise and
rationalise its asset base.
The CAMP recognises six drivers which impacts on affordability; condition,
suitability, sufficiency, revenue costs, accessibility and value.
As well as affordability, the Council’s asset management process aims to
achieve efficiency in terms of use of assets, and maximisation of value in terms
of asset disposal. The Council have an overarching aim to reduce the asset base,
as there is recognition that the number of assets currently held is over and above
the level required to deliver Council services. Reducing the asset base will also
lower the overall cost to the Council.
The existing version of the CAMP was prepared according to the guidelines set
out in the CIPFA Guide to Asset Management and Capital Planning (CIPFA
Guide). The CIPFA Guide identifies six main categories of asset for asset
management planning, and all are reflected in the CAMP. The Council sub-
divided one of the categories into two parts, to reflect their local priorities.
All categories of assets defined in the CAMP are subject to their own asset
management approach, with individual services responsible for the management
of assets within their area. As an example, the draft Local Housing Strategy
2025-2030 was presented to the Housing and Community Safety Committee in
September 2025. Following a period of consultation with the public and external
stakeholders, the final version of the strategy was approved by members in
March 2026.
An asset management plan should provide an overview of the current
performance of the estate. Our review of the existing CAMP confirmed that there
was minimal detail on the performance of the Council’s existing estate and no
information around the current condition of assets or occupancy rates of
buildings. Furthermore, whilst there is some evidence and examples of the Council
looking at how it can transform its asset base to meet future needs (see following
page). There could be more consideration in the CAMP around how the Council,
its services and the community is changing (e.g. trend in school population versus
places available).
This is data the Council have readily available and we recommend that the
Council include this level of detail in the CAMP or refer to where this detail can be
found. Recommendation 1.
The CAMP details seven planned actions for 2024/25.  There is clear evidence that
the Council’s have responded to the actions, with follow up reports/reviews being
presented to various Committees during 2025. As an example, the Depot and
Stores action resulted in the approval of the full business case at the Full Council
meeting in June 2025.
One planned action within the CAMP, relating to the development of a
programme of updates for service level asset management plans was not
actioned and we have considered this in further detail on page 9.
We have noted there was no centralised response where all the actions were
brought into once overarching document to confirm the response to each action.
It is important that the Council follow up the actions identified in plans, and we
recommend that all actions identified for asset management should be included
in an Action Plan, complete with an action owner and timeframe for completion. 
Recommendation 1.
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Asset management planning (3)
Transformation
There is evidence that the CAMP has taken account of new ways of working, the
evolving needs of its population, and the increasing demand for services. The
plan reflects a shift toward more flexible and efficient use of assets (e.g.
Learning Estate rationalisation), supporting hybrid working models (e.g. Smarter
Working programme) and modern service delivery approaches.
As an example, the Council have developed an Additional Support Needs (ASN)
forecasting tool which tracks trends and patterns within ASN, is able to
anticipate future need and can guide resource allocation. The tool has informed
the funding methodology for the ASN budget allocation for 2026/27 and will be
used to steer plans for the Learning Estate.
Asset-related transformation is a key part of the Council achieving long-term
financial sustainability. The Smarter Working programme is now in its third
phase and is reducing the size and running costs of the Council’s office estate.
The Depot Review has progressed to Full Business Case approval and
implementation and is intended to modernise and consolidate operational
depots, improving efficiency and reducing the cost of maintaining multiple sites.
Planned changes to service provision or building usage which have implications
for asset management are factored into the capital planning process.  The Asset
Management Working Group acts as a project gateway if appropriate, and
impacts arising from Transformation projects are reported to the Transformation
Board for oversight. 
Service Asset Management Planning
The Council maintain Service Level Asset Management Plans (SLAMP) for ten
service areas, which set out the plans in place for managing assets within that
operational service. Collectively, these plans underpin and support the
overarching CAMP and aim to translate the Council’s strategic objectives into
service-specific asset management approaches. Together, they aim to align the
day-to-day asset management activities with the Council’s long-term corporate
priorities.
The Asset Management Working Group maintain a summary of all SLAMPs which
includes a grading score for:
- the level of baseline information available for each service (such as condition,
suitability, revenue cost)
- if performance targets have been set
- whether the SLAMP for a service is up-to-date
Of the ten services where a SLAMP should be prepared, the Council consider three
as fully up-to-date, whilst six services have partial SLAMPs in place that are
considered somewhat dated and in need of review. There is no agreed SLAMP in
place for the Parks and Open spaces service.
It is important that services have up-to-date asset management plans to ensure
that the assets which fall under that services remit are understood and managed
effectively, therefore reducing the risk of failure and unexpected costs. The
Council should carry out a review of all service level asset management plans and
ensure that they are up-to-date and fit for purpose.  Recommendation 2.
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Asset management planning (4)
Climate Approach
The CAMP clearly indicates how the Council intends to meet its net zero
commitments and refers directly to the strategies in place. The Council approved
the draft Climate Change Strategy 2025 – 2035 at the meeting held on 24
September 2025.  The strategy sets out how the Council will respond to its
statutory duties to reduce carbon emissions, adapt to the impacts of climate
change, and embed sustainable principles within the Council.
To support the Climate Change Strategy, the Council prepare a Climate
Change Plan and Route Map to Net Zero, which was approved by the Council on
27 August 2025.  The plan provides an overview of the approach the Council is
taking to support the achievement of its net zero commitments.
A governance structure for climate action is included within the Climate Change
Strategy. The Climate Change Board meets quarterly to review actions, and
progress is reported annually to the Council through the Climate Change Plan
and Route Map to Net Zero.
As an example of the type of works underway, during 2025, the Council was
successful in its bid for Salix funding to enable retrofit works at Cullen Primary
School. This included the replacement of existing oil boilers for new air source
heat pumps with new controls and heating distribution. The approach to the
Learning Estate going forward is “fabric first”.
Capital Strategy and Planning
The Council prepare a Capital Strategy which identifies the Council’s approach
to long-term capital planning and investment. The most recent version was
approved by members at the Full Council meeting in December 2024. The
Capital Strategy sets out the principles underlying the capital planning process
and describes how asset management planning and capital planning inter-
relate.  The CAMP links with the Council’s Capital Strategy to set out at both a
corporate and strategic level how the Council’s capital investment plans agree
with the Council’s policies and priorities.
Asset Management is recognised as a key driver for the Capital Strategy.  It is
also seen as an important lever in the Medium to Long Term Financial Strategy,
with reduction in the asset base of the Council, primarily its buildings, an
enabler for financial sustainability.
From 2025/26 onwards, the Council changed to a three-year planning
approach for capital. Alongside the three-year plan, the Council prepare an
indicative ten-year Capital Plan which serves as a tool to identify spending
trends, plans for the future and address affordability issues.
As part of its capital planning, the Council is required to establish the
affordability of its Capital Plan in accordance with the CIPFA Prudential Code. 
The Council approved a methodology for keeping capital expenditure within
affordable limits (known as the cap) at the Special Council meeting held on 22
October 2024.
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Asset management planning (5)
In line with CIPFA guidance, The Council established an affordability ceiling of
10%, measured as a ratio of financing costs to net revenue stream.  The Council
considered the cap in producing its Capital Plan, with the cap being spread
across the three-year period, smoothing out the cap.  This will be a feature of
capital planning going forward and ensures the Council has considered whether
expenditure on capital activities will be affordable in future years.
Shortage of capital funding for local authorities is widely recognised to be an
issue and formed part of COSLA’s pre-budget campaign “Strong Councils
Strong Communities”. Whilst the affordability ceiling has been set, which
ensures the Council’s capital plans remain affordable, the Council acknowledge
that their current level of funding is lower than required and will limit the type of
transformative work the Council would like to carry out.
The Council approved its 2026/27 Capital Plan at the Council meeting held on
28 January 2026. Total expenditure over the ten-year period to 2035/36 is
anticipated to be £427.600 million, which will primarily be funded through the
general capital grant, Moray Growth Deal funding and borrowing. The total
borrowing requirement over the ten-year period to 2035/26 is projected to be
£253.380 million.
Capital investment is one of the main factors driving the Council’s financial
pressure over the long term. To keep borrowing costs affordable, the Council are
aiming to reduce the size of its capital programme and continue to rationalise its
estate. This will mean reviewing how services are delivered in future so that they
can operate effectively from a smaller, more efficient asset base.
The council has taken a proactive approach to managing and mitigating
significant building safety risks and undertakes condition surveys of its buildings
to identify work which may be required. The Council is developing a risk-based
investment assessment of properties to help inform and target investment. This
will initially be rolled out across educational properties, before being
implemented across the wider corporate estate, primarily to assess risk of
building closure. As part of the Local Government Benchmarking Framework,
96% of the Council’s operational buildings have been assessed as suitable for
their current use.
Following guidance issued by the UK Government in relation to Reinforced
Autoclaved Aerated Concrete (RAAC), the Council conducted desktop reviews of
its entire building estate, including 54 schools. This progressed to a physical
investigation of several buildings over the summer of 2023, which confirmed
Forres Academy as having RAAC in its flat roof structure. A review of the school
was commissioned, which identified all areas within the school where RAAC was
present.
A plan for remediation and repurposing works was developed and agreed by the
joint team representing Property, Education, Learning Estates, the Forres
Academy Head Teacher and Senior Leadership Team. The total construction
costs to the Council was estimated to be in the region of £0.556 million across
three phases of planned works.
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Governance and
performance
04
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Governance and performance
To what extent do the council’s governance and accountability arrangements support effective asset management?
The Council’s governance and accountability arrangements provide a clear framework that supports effective asset management and provide assurance that
asset management decisions are transparent and aligned with the Council’s priorities. The Council has changed to a three-year planning approach for capital
due to significant levels of slippage in recent years.  The Council’s LGBF performance for asset management is below the Scottish average, and significant
investment has been made by the Council in these areas. The investment is having an impact and performance trends are improving from a low base.
It is essential that the council has effective governance arrangements in place to
enable transparency, oversight and scrutiny of progress with implementing its
capital programme and asset management strategy. This enables better-
informed decision making and corrective action where needed.
At a corporate level, the CAMP is developed, overseen and scrutinised in the first
instance by the Asset Management Working Group. The Asset Management
Working Group, chaired by the Executive Director of Finance, Strategy and
Transformation, is tasked with corporate responsibility for asset management
and has responsibility for ensuring systems are in place to develop and update
asset management plans (AMPs).  The Asset Management Working Group aims
to ensure that AMPs are robust and challenges the assumptions included within
AMPs. Members of the Corporate Leadership Team receive copies of all reports
taken to the Asset Management Working Group and notes from all meetings.
In parallel to this process, several projects in the Council’s Transformation
Strategy are reviewing the requirements for the asset base, including the
Smarter Working, Depot and Stores and Learning Estate reviews. These all feed
into the asset management planning process.
In its current form, the CAMP does not include detail on the current governance
arrangements for asset management and how progress towards actions in the
CAMP are monitored.  We recommend that the revised CAMP makes reference to
the oversight processes in place at the Council and clearly sets out the
arrangements in place for monitoring progress and year end reporting on the
outcomes of the CAMP. Recommendation 1.
Progress on the CAMP is generally reported on an annual basis, to either the
Corporate Committee or Full Council, with the report providing an update on the
progress of actions within the CAMP for the previous year. However, as
previously noted, there has been no year end reporting on the 2024/25 version
of the CAMP.  Recommendation 1.
Capital Strategy and Planning
The council’s reporting and monitoring arrangements enable good scrutiny and
oversight towards implementing the capital programme.  The Capital Strategy
identifies the Council’s approach to long-term capital planning and investment. 
The investment needed to ensure that assets meet the Council approved
standard for the asset type is ascertained through the asset management
planning process. The Capital Strategy links that process to the Council’s
Capital Plan.  
The vehicle for delivery of the council’s corporate asset management strategy is
the capital programme. The Capital Plan embodies the delivery of projects on
the General Services fund and monitoring reports are reported quarterly to
either the Corporate Committee or Full Council. Quarterly monitoring reports
are also presented to service committees which detail the financial performance
for that individual service. During 2025/26, the quarter one and quarter three
monitoring reports were presented to the Corporate Committee, whilst the
quarter two report was presented to Full Council.
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Governance and performance (2)
The reason for the change in reporting is due to the fact the Corporate
Committee does not have delegated authority to approve amendments to the
Capital Plan and can consider estimated outturns only. Therefore, any changes
to the capital budget for the year must be presented to Council for approval.
The Council include significant detail within the capital monitoring reports
presented for scrutiny including:
• detailed reasoning for areas of overspend/underspend
• revised year end forecasts for the capital outturn position
• amendments made to the in-year capital budget alongside reasoning for the
change made
• impact of delays to projects and/or slippage and the corrective action being
taken.
• update on the affordability indicator for each year of the capital plan
Reporting of the overall capital programme occurs at a reasonable frequency
and provides clear information about the Council’s progress towards
implementing asset management plans.  The reporting is at an appropriate level
and ensures there is appropriate oversight and scrutiny from members.
The governance structure enables a high-level overview of the asset management
plans, via the Asset Management Working Group and Full Council/Corporate
Committee but also allows for in depth discussion of key issues within individual
projects at Service Committees. All capital reports are presented to the Corporate
Leadership Team for overarching scrutiny prior to reporting to members.  The
Council keep arrangements under review to ensure they remain appropriate.
Historically, the Council has consistently underspent against its approved
capital budget, resulting in significant levels of slippage within the programme. 
This pattern reflects ongoing challenges in delivering planned projects within the
intended financial year, often due to delays in procurement, capacity
constraints, and dependencies on external partners or contractors. This has
impacted the Council’s ability to achieve the pace of capital investment
originally set out in its plans and resulted in the re-profiling of expenditure to
future years.
As a result of the continued slippage in the capital budget, the Council changed
its approach to capital planning, and from 2025/26 onwards have prepared a
three-year capital budget. This followed feedback from budget managers that a
single year capital plan was too restrictive and created a reluctance to commit
to preliminary spend. The change to three-year planning aimed to provide more
certainty to budget managers in terms of multi-year funding, and more realistic
spend profiles.
Following the approval of the capital budget for 2025/26, the Council approved
amendments to be made due to carry forwards from 2024/25. This resulted in
the capital budget for 2025/26 increasing to £73.336 million.
The capital monitoring position has been reported to members on three separate
occasions during 2025/26 to date. The position reported to members is reflected
in Table 1 below:
Table 1: Capital Plan – Projected Outturn
14
Initial
Budget
June       
2025
September
2025
December
2025
Capital Plan – Planned
Expenditure £73.336m £51.030m £46.995m £37.730m
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Governance and performance (3)
The capital budget was revised in August 2025 due to a significant re-profile of
expenditure relating to the Moray Growth Deal and the Levelling-Up Fund. This
resulted in an amendment of £22.280 million to the budget, which was approved
by members at the Corporate Committee in August 2025. Since this
amendment, the Council has continued to project underspends against the
budget, and at the date of last reporting, the capital plan shows an estimated
underspend against budget of £12.834 million at December 2025. Significant
underspends against budget were noted within Moray Growth Deal, Levelling-
Up Fund and the Learning Estate.
As reflected in Table 1, the Council is not on track to deliver all the commitments
set out in the capital programme, and there will be significant slippage in the
2025/26 capital outturn. Underspends have primarily arisen due to delays in the
delivery of planned projects, alongside an element of optimism within the
original estimates. The Council have noted some delays to projects are due to
decisions by external partners. In one instance, two projects (included within the
Moray Growth Deal and Levelling Up Fund) were impacted due to a key partner
retracting their commitment.  In several cases, project timelines have been
extended, resulting in the planned expenditure being re-profiled into future
years. These above factors have contributed to the recurring underspends and
highlight the need for more realistic profiling to support more accurate
forecasting.
The projected year end outturn for capital is not unexpected, and we have
previously reported that the Council has a history of underspending against its
budget. Issues with capital slippage was reported in the Controller of Audit
Report approved in April 2024. In our 2024/25 Annual Audit Report, we raised an
audit recommendation outlining that the Council must ensure that the capital
budget set in advance of the financial year is realistic, reducing the need for
significant budget amendments in the first months of the financial year.
The efficiency of capital programme delivery has been a focus for the Council
during 2025/26. The format of the quarterly monitoring reports has been revised
during the year to give a greater focus on actual programme delivery at an asset
class level compared to planned delivery. The council recognise that capital
plans are prone to slippage which has driven the change in focus of the report.
A major component of the capital programme is the Learning Estate and
detailed reports on factors impacting the Learning Estate are taken to the
Education, Children’s and Leisure Services Committee.  Reports focus on both
individual components and the overall Learning Estate Strategy. 
Outwith the main capital planning approach, the Council also maintain the
Housing Investment Programme, which is approved by Full Council as part of the
Housing Revenue Account budget on an annual basis. The programme for
2025/26 was approved at the Council meeting in February 2025 and confirmed
a total budget of £36.443 million.  The Plan reflects the investment priorities
which tenants identified within surveys, alongside other regulatory requirements.
Progress on the programme is reported quarterly to Housing and Community
Safety Committee. The most recent update was reported to the Committee in
March 2026, which confirmed the projected year end outturn for the programme
is £34.412 million, which would result in an overall underspend position of £2.031
million.
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Governance and performance (4)
Performance – Local Government Benchmarking Framework
The Council particates in the Local Government Benchmarking Framework
(LGBF). The LGBF provides evidence of trends in how resources are allocated,
performance of services and levels of customer satisfaction. The last available
data covers financial year 2024/25.
There are four indicators within the LGBF data which relate to asset management
and the Councils performance for these indicators has been considered in Table 2
and Table 3 below:
Table 2: Performance compared to Family Group / Scotland average
Indicator Council Family
Group
Scotland
CORP-ASSET 1: Proportion of operational
buildings that are suitable for their current use
96.1% 90.5% 85.7%
CORP-ASSET 2: Proportion of internal floor
area of operational buildings in satisfactory
condition.
55.4% 88.4% 91%
HSN3: Percentage of council dwellings meeting
Scottish Housing Standards
43.7% 70.8% 82.9%
HSN5: Percentage of council dwellings that are
energy efficient.
60.4% 81.3% 87.6%
16
Table 3: Ten-year performance trend
As can be seen from both tables, the Council perform above the Family
Group/Scotland average for one indicator, however performance for the
remaining three indicators is below average.
The Moray Learning Estate is a significant contributory factor to the operational
building condition indicator. Many of the buildings used are ageing and as such,
approximately 50% of the Council’s 54 schools have scored a grade C (or lower)
where condition surveys have been completed within the last five years.
Following a change in technical guidance in 2022, the Council has been
significantly below the Scottish Housing Standards, mainly due to electrical
certification (EICR). The Council have experienced difficulties in tendering for
works to be completed, however have now completed works across approximately
90% of the housing stock. The Council are in the process of resolving the
remainder, including by forced entry where tenants have not granted access.
Furthermore, the type of property available in Moray makes it more difficult to
become energy efficient. A large proportion of properties are older, sandstone type
properties, which are not suitable to newer energy technology.
Indicator 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025
CORP
ASSET1 95% 95% 95% 98% 98% 98% 98% 98% 97% 96%
CORP
ASSET2 41% 41% 53% 54% 54% 67% 55% 56% 56% 55%
HSN3 96% 96% 96% 93% 91% 94% 6% 16% 23% 44%
HSN5 50% 53% 55% 57% 55% 57% 60% N/A N/A N/A
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Governance and performance (5)
The Council have undertaken significant investment in order to improve
performance within these indicators. Approximately £6 million has been invested
on improvement measures to improve the energy efficiency of dwellings, including
insulation and upgrading heating systems. However, due to the time lag in
updating certification and method of reporting, no interim figures are currently
available that highlight expected improvement in the Council’s performance.
Local Performance Indicators
The Council have a range of local key performance indicators in relation to
housing and property. Performance is monitored quarterly and is reported to the
Housing and Community Safety Committee twice yearly. Furthermore, the
Council prepare a year end Housing and Property Annual Performance Report
which is published on the Council website. A broad range of indicators are
included within this report and examples are detailed in Table 4 below:
Table 4: Local Performance Indicators
17
Performance Indicator Target Prior 2024/25 Scotland       
Avg.
% of tenants satisfied with the overall
service provided by their landlord 90% 83% 82% 87%
% of tenants satisfied with the quality
of their home 90% 83% 81% 85%
% of properties meeting the Scottish
Housing Quality Standard (SHQS) 100% 23% 44% 90%
Average time taken to complete
emergency repairs 4hrs 2hrs
12mins
2hrs
24mins
3hrs
7mins
% rent lost through properties
becoming vacant 0.63% 0.74% 0.72% 0.81%
Performance across the local indicators is mixed. For example, the Council report
performance below both their target levels and the Scotland average for the
majority of landlord satisfaction indicators. However, the Council perform well
across repairs and maintenance indicators, outperforming both their own target
levels and the Scotland average.
The performance report notes the reason for areas of under performance and the
plans the Council have implemented to drive improvement. It also identifies where
challenges have arisen and the steps that need to be taken to address these
challenges in the future.
The biggest challenge the Council face regarding its assets is affordability.  The
Council are aware that the Learning Estate overall is in poor condition and the
cost of upgrading and/or replacing schools is unaffordable.  As a result of these
factors, there will be requirement to extend programmes of work and explore
asset rationalisation, with the Council prioritising funding to areas with the
greatest need.
The Leisure estate has similar challenges and also requires significant investment. 
The lack of funding available makes it difficult for the Council to make
improvements to existing assets.
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Governance and performance (6)
Roads Network and Bridges
The Council’s roads infrastructure is in relatively good condition when compared
to the national average. The Council are currently rated as the fifth best
performing local authority in Scotland based on the Scottish Road Maintenance
Condition Survey.  As a result, the Council made a decision to allow some
deterioration across the roads network, with an expectation that performance will
lower to the mid-point of Scottish local authorities. This is the asset standard set
in the Capital Strategy, approved by the Council in December 2024 and enables
finances to be used on other capital investment areas.
Whilst the conditions of road are suitable, there is a significant backlog of
identified road works and works on bridges. The Scottish Collaboration of
Transport Specialists (SCOTS) publish a Backlog Report which estimated the
Council’s backlog figure for roads maintenance was £46.5 million (most recently
reported in 2023).
The Council’s Road Maintenance Capital Programme is overseen by the Economic
Development and Infrastructure Services Committee. The approved 2026/27
Budget includes £2.3 million of funding for roads maintenance, significantly below
the backlog figure previously reported.
All works for bridge maintenance are prioritised in line with the Bridge
Maintenance Prioritisation Policy, which was approved by the Economic
Development and Infrastructure Services Committee in March 2023. The Council
maintain a prioritisation list to ensure bridges most at need of repair are reviewed
first. As part of 2026/27 Flood Risk Management and Bridges Budget, the Council
approved £0.600 million of investment for bridge maintenance.
18
Digital and ICT
The Council’s ICT estate includes a number of ageing systems and assets and
maintaining the current level of digital operations, resilience and security
requires ongoing replacement of hardware and upgrades to software
platforms. The Council’s Capital Plan confirms that £1.465 million has been
allocated for ICT over the next three years, supporting a prioritised
programme of baseline refresh activity across server and network
infrastructure, end user devices and essential software.
The Council note that this funding is sufficient to manage baseline ICT refresh
requirements across much of the Council’s corporate estate, addressing
priority lifecycle and risk-based replacement needs. However, the schools ICT
estate operates at a significantly different scale and demand profile, with a
larger, older device base and a higher dependency on reliable digital access
to support learning, assessment and inclusion. As a result, baseline capital
funding alone is not sufficient to address the current and emerging pressures
within Education or to enable digitally enabled learning and teaching at the
level required.
The Council has an aspiration to reduce reliance on on-premise server
infrastructure by transitioning appropriate systems to off site or cloud based
services. This would reduce pressure on the Capital Plan but introduce
corresponding revenue costs. A business systems review is currently underway
to assess the benefits, risks and revenue implications of this approach.
Any significant digital modernisation or transformation activity, including
large scale education digital enablement or server estate migration, would
require additional funding over and above the current Capital Plan. Options
under consideration include additional capital capacity, use of the Council’s
transformation reserve, and external transformation funding such as Scottish
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Partnership working and
community engagement
05
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Partnership working and community engagement
To what extent does the council have a robust approach to working with partners and communities in managing its assets?
The Council works well with its partners and communities in the management of its assets; however arrangements could be strengthened by setting out how this
works in practice.  The Council has mechanisms in place to engage with stakeholders, support community involvement, and work collaboratively with partners to
maximise asset use and value. Asset management decisions are informed by local needs, support the Council’s priorities, and contribute to positive outcomes for
communities.
It is essential that councils consider how they can collaborate across services
and with other public and third sector organisations to manage assets. This has
the potential to achieve savings, better align service provision and create
opportunities for joint working. Councils should also have transparent and
robust processes in place for supporting and assessing community asset transfer
requests and engaging with their communities on asset management plans and
priorities.
The Council demonstrates a strong and proactive approach to partnership
working and community engagement in the management of its assets. The
Council manages assets through strategic partnerships and community
engagement, focusing on sustainable, long-term use through their Community
Asset Transfer policy. The Council partner with local groups to transfer
ownership, empowering communities to manage facilities. The Asset
Management Working Group oversees property, infrastructure, and ICT assets
with partners to ensure efficiency.
Communities are involved in decision making in ways specific to the asset class. 
There are some permanent channels of engagement, for example Harbour User
Groups and the Tenants’ Forum (housing), however most engagement is in
response to particular circumstances or proposals.  Recent examples include
consultations on the learning estate, sports and leisure facilities and libraries. 
The Council works alongside partners and its communities in the management of
assets, and there is clear evidence that this works well in practice. However, we
have noted that there is no overarching document which sets out how the
Council works with its partners in the ongoing management of assets. The
Council should set out a clear approach on how it will work alongside its
partners and communities to deliver effective management of the Council’s
assets. It is important that the roles and responsibilities of both the Council and
its partners are clearly defined, which will ensure there is transparency in the
overall approach.  Recommendation 1.
The council can demonstrate how outcomes of engagement with community’s
feeds into decision-making. As an example, the Council are currently
undertaking a review of the learning estate, which will propose a future direction
for the learning estate strategy. The new strategy will set out how the Council
will manage investment in the learning estate over the next ten years to deliver
the overall strategic vision. 
An Associated School Groups by Associated School Groups (ASG) level
engagement completed in June 2025. As part of this review, the Council
engaged with stakeholders and the local community by:
• hosting briefings and Q&A sessions with elected members, community groups
and representatives and school staff
• drop-in community information events
• online surveys and stakeholder workshops.
The results of the Learning Estate review is anticipated to report in June 2026 to
the Education, Children’s and Leisure Services Committee. 20
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Development and delivery of transformation plans (2)
The Council are using a Masterplanning approach to develop an asset
management strategy for the Buckie harbour development.  The masterplan
has been developed in consultation with stakeholders and Buckie community
representatives, through direct contact around the plans, questionnaires and
discussion at the Harbour User Group.
A report approving the northern expansion of the harbour was approved by
the Council on 25 February 2026, with the report noting that the majority of
stakeholders who participated in the consultation of the masterplan expressed
support for the northern expansion of the harbour.
Community Asset Transfers
The council has a clear and transparent approach to supporting and
assessing community asset transfer requests. The Council recognise that
ownership or control of land and buildings is a powerful tool for communities
to drive change and provide stability and sustainability for the community
organisations.
There is a well-established process in place for asset transfers, with a
dedicated website address and direct support to groups provided by the
Community Support Unit and officers within Property Services.  A cross-service
officers group meets to assess applications, provide feedback to groups who
have applied and subsequently report to the Corporate Committee on the
receipt of formal applications.  Groups are encouraged to submit expressions
of interest prior to formal applications so that officers can support them to
make a strong and well-evidenced application. 
The Council have a Community Asset Transfer Policy, which was approved by
the Policy and Resources Committee in May 2014. The policy was subject to
review during 2017, however there is limited evidence of the review taken place.
The Council are currently undertaking a review over all existing policy documents,
to ensure they are updated at an appropriate frequency. As part of this, the Council
should ensure that the Community Asset Transfer Policy continues to be fit for
purpose. Recommendation 3.
The current Community Asset Transfer Policy sets out the four stages to the asset
transfer programme as follows; expression of interest, formal application, business
case (only for certain cases) and implementation.  This sets the framework used by
officers assessing potential transfers and ensures those involved are aware of their
roles and responsibilities.
Most applicants to the scheme are looking for either a discounted or nil value asset
transfer and the Community Asset Transfer team work with groups to ensure they
comply with the requirements of the Disposal of Land by Local Authorities
(Scotland) Regulations 2010. The council assesses requests against criteria
including community benefit, sustainability and the impact on council services.  As
an example, the most recent Community Asset Transfer involved the disposal of
land at Clovenside Cemetery, which was approved at the Corporate Committee
meeting held in November 2025.
As the land was part of the Forres Common Good, a public consultation was
conducted, with 84% of the 106 respondents supporting the sale of the land.
Proceeds from the sale were credited to the Forres Common Good Account, which
will be distributed within the local community over time. The outcomes from the
community engagement exercise were a significant factor in the final decision to
sell the land.
The Council has previously provided seedcorn financial support to community
groups as part of the Community Asset Transfer process, in particular to the
community groups who participated in the transfer of the Council’s town halls in
2019.
21
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Development and delivery of transformation plans (3)
Section 95 of the Community Empowerment (Scotland) Act 2015 requires
every local authority to publish an asset transfer report by the end of June
each year. The Council presented their annual report to the Corporate
Committee in June 2025, with the report covering the period 1 April 2024 to 31
March 2025.  The report confirmed the Council had no asset transfer requests
during the year. Officers responded to five expressions of interest during the
period, all of which remained live at the year end (one of these being the
Forres Common Good asset which was subsequently transferred).  A case
study example of a Community Asset Transfer is shown on the following page.
22
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Development and delivery of transformation plans (4)
23
Below is detail of a community asset transfer processed by the Council.
Case Study: Lesser Borough Briggs (the Gleaner Arena)
Council Priority: Build thriving, resilient, empowered communities
In May 2017, the Council were approach by a community group expressing
an interest in land at Lesser Borough Briggs. This land was owned by the Elgin
Common Good. The group were seeking to transfer ownership to enable
community sports facilities to be developed.  The group were in the process of
becoming a Scottish Charitable Incorporated Organisation (SCIO).
The group commenced through the Council Community Asset Transfer (CAT)
process; however, the process stalled. In this time, OSCR had confirmed
charitable status in December 2017, and the group confirmed its name as
Elgin Sports Community Trust (ESCT). 
ESCT re-contacted the Council, this time with a view to exploring a lease of
the site. ESCT were supported in the process by the council and garnered
outside support from various community groups.  A revised pre application for
ownership was submitted in January 2018. Feedback was provided to ESCT
members to enable them to strengthen their business case prior to submitting
a formal application. An application for a CAT in the form of a long lease was
submitted by ESCT in January 2019 along with a revised business case.
The application was reported to the Policy and Resources Committee in April
2019. The committee did not approve the transfer but did approve public
consultation on disposal of the site.     
Prior to public consultation, ESCT submitted a further application for CAT
under the Community Empowerment Act, supported by a revised business
case, which was approved by the Emergency Cabinet in June 2020.
The approval from Councillors at the Emergency Cabinet was ‘to approve the
request to grant a 99-year ground leases over the site.’ Permission from the
Sheriff Court to dispose of the Elgin Common Good land was granted on 14
August 2020.
A planning application for Multi-Use Games Area (MUGA) was approved by the
Council at its Emergency Cabinet meeting on 13 August 2020 and The Gleaner
Arena officially opened on 14 August 2021.
A further planning application was approved on 14 November 2023 for the
erection of a pavilion at the site.  The Pavillion was officially opened on 11
January 2025.
Outcome:
By January 2025, ESCT had successfully constructed three 3G playing surfaces
at the site, as well as a pavilion. ESCT has engaged with local businesses,
securing a sponsorship for the site with Gleaner and funding support from
Robertson Construction Group, Elliot Office Equipment and Designed.
The site aims to promote a healthier lifestyle by providing better sports facilities
that are available to all, regardless of age, gender or ability.
The Council has noted the following from the CAT process:
• Highlights that a community group was supported by the Council to
successfully transfer ownership of land
• Worked in partnership to garner both community and financial support for the
project
• Resulted in a new sports facility for the people of Moray. 
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Development and delivery of transformation plans (5)
Partnership Working
Partnership engagement in the management of assets varies across asset
groups.  The Local Housing Strategy is developed by the Housing Market
Partnership, which includes various Council services, NHS Grampian and
registered social landlords active in Moray.
The Council works collaboratively with several of its partners to manage assets
as a collective resource. As an example, the Council works alongside NHS
Grampian on the delivery of vaccinations at the vaccination centre in Brumley
Brae. This is a council property currently used by NHS Grampian as part of the
approach within the Moray Integration Joint Board to deliver the winter
vaccination programme. 
The Council has also worked in partnership with Moray Leisure Centre (an Arms
Length Organisation of the Council) on the management of the leisure centre
property. The Council are currently in the process of formalising a Service Level
Agreement which would include property management arrangements of the
leisure centre.
There continues to be a significant level of partnership working with the
community group involved in the running of the Elgin Town Hall.  This will help to
ensure continuation of their activities during the redevelopment of the Town Hall
as part of the Moray Growth Deal, with the group using a Council building (the
former Elgin Community Centre) for this purpose.
24
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Appendices
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A. Improvement action plan
26
We have set our below, based on our audit work undertaken on the transformation thematic, the key recommendations arising from our work:
Issue / risk Recommendation Agreed management response
1. Corporate Asset Management Plan (CAMP)
The CAMP has not been reviewed since December 2024
and is out of date. The current version of the CAMP only
covers a single year and does not consider the longer
term.  Furthermore, the Council have not reported on the
outcomes of the existing CAMP and therefore it is unclear
what actions were achieved.
Our review of the existing CAMP confirmed that there
was minimal detail on the performance of the Council’s
estate and no information around the current condition
of assets or occupancy rates.  We also identified that
there was limited consideration around how the Council,
its services and the community is changing.
The current version of the CAMP does not include any
detail around the governance arrangements and how
progress towards actions identified will be monitored, nor
how outcomes will be reported on conclusion. 
The Council works alongside partners and its
communities in the management of assets, and there is
clear evidence that this works well in practice. However,
we have noted that the arrangements for partnership
working are not set out. It is important that the roles and
responsibilities of both the Council and its partners are
clearly defined, which will ensure there is transparency in
the overall approach.
The Council should update the Corporate Asset
Management Plan and present the final version to
members for approval.
The Corporate Asset Management Plan should confirm
how the Council’s plan to manage its assets over the
longer term.
In updating the Corporate Asset Management Plan, we
recommend the following is considered:
• the Council include key information on the
performance of its estate, including consideration on
how service delivery and its communities are changing
• confirm how progress towards the actions identified
within the plan will be monitored
• actions identified are included within an Action Plan,
complete with an action owner and timeframe for
completion. 
• set out a clear approach on how the Council will work
alongside its partners and communities to deliver
effective management of the Council’s assets.
The Council should ensure that the outcomes from the
CAMP are reported annually.
The Corporate Asset Management Plan will be updated
to reflect the current year (2026/27) and structural
changes since it was last reviewed in December 2024.
This will be presented to members for approval in August
2026 at Corporate Committee.
A holistic review of the strategic asset management will
be conducted by the new Section 95 Officer and that is
planned over the next 12-18 months, with the outturn of
that exercise being incorporated into the updated
Corporate Asset Management Plan. This review will also
incorporate the recommendations of this Best Value
Thematic.
Action Owner: Executive Director Finance Strategy and
Transformation
Timescale for implementation: 30 November 2027
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A. Improvement action plan  
27
Issue / risk Recommendation Agreed management response
2. Service Asset Management Plans
The Council maintain Service Level Asset Management
Plans (SLAMP) for ten service areas, which set out the
plans in place for managing assets within that
operational service. Of the ten services where a SLAMP
should be prepared, the Council consider three as fully
up-to-date, six in need of review and one service where
there is no SLAMP in place.
It is important that services have up-to-date asset
management plans to ensure that the assets which fall
under that services remit are understood and managed
effectively, therefore reducing the risk of failure and
unexpected costs.
The Council should carry out a review of all service level
asset management plans and ensure that they are up-
to-date and fit for purpose. 
Service Level Asset Management Plans (SLAMP) will be
updated to compliment the revised Corporate Asset
Management Plan. The SLAMPs will reflect the
requirement for the Council to effectively manage the
decline of its asset base due to unsustainable funding to
maintain its entire estate.
Action Owner: Each Head of Service
Timescale for implementation: 30 November 2027
3. Community Asset Transfer Policy
The Council maintain a Community Asset Transfer
Policy, which was last approved by the Policy and
Resources Committee in May 2014.  Due to the length of
time that has passed since the policy was last reviewed,
the Council should confirm it remains fit for purpose.
The Council should review the Community Asset Transfer
Policy and confirm it remains fit for purpose.
The Community Asset Transfer Policy will be reviewed to
confirm it remains fit for purpose
Action Owner: Executive Director Finance, Strategy and
Transformation
Timescale for implementation: 30 November 2027
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Report to: Audit and Scrutiny
Committee 
Meeting
Date:
18 June 2026 
Report by: Executive Director Finance, Strategy and Transformation 
Author: Louise Marshall Contact Email: performance@moray.gov.uk 
Subject: Local Government Benchmarking Framework 2024-25 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 2024-25.  This report was also presented to the
Corporate Committee on 26 May 2026.  
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 95 indicators.  Two indicators are
no longer collected locally and five have yet to be published.   
2.3  An assessment of relative performance in recent years can be inferred to an extent, with
the pandemic having a significant impact on performance and direct comparison with
previous years’ data; generally an improving trend is evident up to 2021/22, followed by a
drop off in 2022/23, thereafter the pace of recovery has slowed from that of previous
years as presented in the charts below.   
Item 14.
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2.4  Assuming no significant change in rankings for the 5 indicators yet to be published,
overall, the position in terms of relative performance will remain stable and like that of
2023/24. 
2023/24 vs 2024/25 
No change        
3 indicators 
Results improved Result worsened  Not yet published    
50 indicators  42 indicators   5 (5%)        
indicators 
3.  RECOMMENDATIONS  
28% 28% 18% 23% 23% 24%
19% 24% 34% 22% 21% 19%
24%
27% 24% 28% 26% 24%
29% 20% 24% 27% 30% 28%
0% 5%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2019/20 2020/21 2021/22 2022/23 2023/24 2024/25
LGBF relative performance -national
1st quartile 2nd quartile 3rd quartile 4th quartile N/A
30% 34%
22% 23% 25% 23%
10%
18% 32% 21% 18% 19%
22%
18% 18% 29% 27% 29%
39% 30% 28% 27% 30% 24%
0% 5%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2019/20 2020/21 2021/22 2022/23 2023/24 2024/25
LGBF relative performance -family
1st quartile 2nd quartile 3rd quartile 4th quartile N/A
N/A
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3.1  It is recommended that Committee scrutinise and note the Council’s performance
in terms of a corporate overview of benchmarking results.   
Louise Marshall
Strategy and Performance Manager 
4.  BACKGROUND AND CONTEXT  
4.1  Local Government Benchmarking Framework (LGBF) data is refreshed throughout the
year with the final data published around June each year.  The results inform the National
Benchmarking Overview Report.  The Improvement Service collate data from national
sources following annual submissions that is subjected 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 through a programme of events arranged and facilitated by the
Improvement Service. 
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.  
5.  NATIONAL PERSPECTIVE 
5.1  This, the fourteenth annual report, evidence that despite significant innovation, service
redesign and partnership working, councils are operating under sustained financial,
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workforce and demand pressures that are reaching the limits of what can be delivered
within existing resources. 
5.2  Financial Pressures: structural strain
• Funding failing to keep pace with inflation, demand growth and expanding national
commitments.
• Forward spending plans indicate further pressure on council budgets, with funding
projected to fall by 2.0% in 2027/28 and 3.8% in 2028/29 against a predicted overall
Scottish spending rise over the same period of 4.68%
• Statutory services, primary education and social care absorb over 70% of
expenditure, leaving limited scope for discretionary or preventative investment.
• Infrastructure continues to deteriorate faster than repairs can be funded.
• Addressing these challenges; councils explore wider transformation, whole-system
redesign, shared services, digital modernisation, automation, better use of data and
strong partnership working 
5.3  Workforce challenges: capacity, recruitment, demographics
• Workforce pressures, recruitment and retention challenges are acute in social care,
social work, planning and environmental health and increased absence rates.
• An ageing workforce presents succession risks, under representation of minority
ethnic and disable employees.
• Service specific workforce pressures in care sector, specialist teacher shortages in
STEM and rural areas.
• Addressing these challenges; strengthened national and local workforce planning,
improved data use and modernised employment practices. 
5.4  Health and social care: rising demand, limited capacity
• Demand for adult social care continues due to ageing population and increasing
complexity.
• Provider fragility constraining system capacity despite rising need.
• Addressing these challenges; collaboration on digital tools, staff wellbeing and joint
resource planning.   
5.5  Education: recovery amid rising complexity
• Signs of recovery in Education services, growing complexity and workforce pressures
continue.
• Rise in real time spending by around 20% since base year of 2010/11 to reflect
national policy commitments.  Substantial growth in Additional Support Needs (ASN),
now affecting over 40% of pupils with specialist ASN teacher numbers continuing to
fall.
• Primary attainment above pre-pandemic levels, narrowing of poverty related gaps.
• Attendance remains lower than expected, with non-attendance linked to anxiety and
complex ASN for a small yet growing cohort.
• Early years developmental outcomes of 27-30 month health reviews improving,
quality of provision remains high.  The mixed provider model increases reliance on
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private and voluntary settings that adds to pressures around stability and quality
assurance.
• Addressing these challenges; continued progress in strengthening collaboration on
ASN, equity and curriculum development. 
5.6  Tackling poverty: persistent structural pressures
• Households facing high housing and energy costs, limited income growth and labour
market inequalities.
• Child poverty above 2014/15 levels.
• Rent arrears falling and Council Tax collection stable but demand for crisis support
remains high.
• Addressing these challenges; strengthened strategic approaches to poverty through
improved data, spatial analysis and whole system initiatives. 
6.  MORAY RESULTS  
6.1 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. 
6.2 Despite challenges, good or improving performance is recognised in school attendance,
16–19-year-olds participation rates, gender balance in senior posts, crisis and
community care grant decision timescales, hospital re-admission rates, hospital delayed
discharge, road condition, waste recycling rates, financial outturn and CO2 emissions for
electricity and natural gas.  Generally, cost indicator results across service areas are low
in comparison to other local authorities; however, this should be considered alongside
performance and customer results. 
6.3 Of the 95 results published, 29 results are placed in the lowest quartile (ranked 25th to
32nd), these are 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 an additional four indicators relating to
school attendance for looked after children, gross value added per capita and carbon
emissions in scope of local authority, being the latest results for 2023-24 that were not
published at the time of reporting to this committee last year are included at Appendix 1.    
6.4 Lowest quartile performance was reviewed by the senior management team to ensure
planned work will secure improvement, particularly in the following Corporate Plan
priority areas of Poverty, Climate Change.  For ease of reference, throughout, indicators
measuring Corporate Plan performance are emboldened. 
• 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
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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.  Full
scrutiny of Initial Analysis of Secondary School Attainment – Session 2024-25 and
Initial Analysis of Achievement of Curriculum for Excellence Levels – Session 2024-25
was undertaken by Education, Children’s and Leisure Services Committee on 25
November 2025 (para 24 of minute refers) and 3 March 2026 (para 11 of draft minute
refers) respectively.  The service continues to tackle the challenges around issues
impacting on attainment that include staff absence, inability to recruit teachers in key
subject areas and ongoing ICT issues locally leading to reduced learning time. 
• 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, delayed due to the delivery of
additional supporting information to inform the Learning Estate Review, including an
independent review of the school roll forecasting methodology, together with the
diversion of team resource to support Future Forres Academy and Future Buckie High
School projects but is scheduled to be reported to committee.  The draft update of the
Climate Change Strategy 2025-2035 and Routemap to Net Zero, developed through
an officer/member working group, sets out how the Council will respond to its
statutory duties to reduce carbon emissions, adapt to the impacts of climate change,
and to embed sustainable principles within the Council, was approved, subject to
public consultation by Council in September 2025 and will be presented for final
approval from Council in June 2026.  The Biodiversity Strategy gained final approval
from Council in May 2026. 
• 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. 
6.5 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.  
7.  SUMMARY OF IMPLICATIONS  
7.1 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  
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Staffing  
Best Value and Transformation  
Property  
Information Communications Technology/Digital  
Equalities. Social Inclusion and Economic Impact   
Climate Change and Biodiversity Impact   
7.2 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 
7.3 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.  
7.4 Financial 
None arising from this report. 
7.5 Risk 
None arising from this report although effective performance management assists in
the management of risk.  
7.6 Staffing 
None arising from this report.  
7.7 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.  
7.8 Property 
None arising from this report.
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7.9 Information Communications/Technology/Digital 
None arising from this report.  
7.10 Equalities, Social Inclusion and Economic Impact 
None arising from this report.  
7.11 Climate Change and Biodiversity Impacts 
None arising from this report. 
8.  CONSULTATION  
8.1 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. 
9.  BACKGROUND PAPERS  
9.1 LGBF Dashboards
National Benchmarking Overview Report 2024/25
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 available data for 2024/25 as well as data for 4 indicators relating to
2023/24 that were not available at the time of annual reporting last year.   
Since base year (2010-11), changes in expenditure evidence the most significant increases in Economic Development, Adult Social Care,
Education, Looked After Children and planning and reductions in Roads, Support Services, Environmental Service and Culture & Leisure. 
Positive performance in top quartile rankings is evident in individual indicators across most headings but more notably in Adult Social Care
and Environmental Services. 
Exceptions based on 32 local authorities; areas of service delivery ranked in the lowest quartile are presented below as Notes to
Benchmarking Results.  Care should be taken when making comparison over time and with others due to the complexities around altered
delivery and operating landscapes during the reporting period. 
The National Benchmarking Overview Report is available here. 
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No Challenges Actions to improve to present time Outcome
Children’s Services  
1 Proportion of children looked after in a community setting increased to 78%,
improving the ranking to 28th, but below the national average (88.8%). 
Performance has featured in the lowest quartile since 2010-11.  Latest data
relates to 2023-24. 
The Carer Recruitment Campaign continues to focus on the
recruitment of foster carers and supported lodgings carers,
increasing capacity.  Looked after children in Moray in approved
Kinship Care with family members is in line with family average,
work continues to strengthen practice, ensuring children at the
point of allocation, have a holistic extended family map
produced on Kinship care options in the event short breaks or
alternative care may be necessary.  95.5% of brothers and sisters
in Foster Care and Kinship Care remain together with at least one
sibling above the national average of 79%.  Maintaining
Relationships Project is developing an approach and policy to
ensure brothers and sisters remain together where this is their
assessed needs, albeit more challenging when need to
accommodation 3 or more children due to resource limitations. 
(Source: Quarter 2 Performance Report for Children and Families and
Justice Social Work, IJB 26 February 2026)
Improving
outcomes for
Looked After and
Care Experienced
Children and Young
People (Children
Services Plan 2023-
26)
2 Percentage of pupils entering positive destinations results and rankings
have dropped year on year since 2021-22, to 93.5% against largely
consistent comparator results. Positive destinations include higher/further
education, employment, training, personal skills development and
voluntary work.  In 2024-25 there were 1,086 leavers with 1,015 progressing
to positive destinations, key results: 34.6% to higher and 23.8% to further
education, 30.1% to employment.  6.5% (71 young people) were recorded
as unemployed seeking, unemployed not seeking or unknown. 
• Getting it right for every child so that we continue to improve
attainment for all 
Key actions for raising attainment are progressing at school
and system levels for Senior Phase; Secondary school
improvement visits are complete with moderated reports
identifying strengths and areas for improvement.  Secondary
school targets are monitored at key milestones.  Depute
Headteacher Tracking and Monitoring Network developed to
support collaboration, meeting in terms 3 and 4. 
Moray schools continue to work with key partners including
Skills Development Scotland, Moray Pathways, Moray College
UHI and wider employability partners to ensure pupils are
supported to positive onward destinations.  It should be noted
that health factors may impact on future pathways and routes
to success for young people where our schools continue to
monitor this through early intervention approaches. 
(Sources: 2023-24 Analysis of Secondary School Leaver Attainment
2023-24 / Q3 Performance updates) 
Improved
attainment at both
Broad General and
Senior Phase
identified through
ACEL and LGBF
measures
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3 4
5 6
7
Average tariff points for each unit or course are calculated from the latest
and best achievement of pupils based on the SCQF level of the award and
grade achieved (for graded courses S4-S6).  The Scottish Index of Multiple
Deprivation (SIMD) identifies small area concentrations of multiple
deprivation showing the difference between young people living in the
most and least deprived areas. 
Overall average total tariff improved slightly to 829 but remains below
national and family averages, similar slight improvements are recorded for
SIMD quintiles 2 and 5 but slightly worsened in SIMD quintiles 3 and 4, all
remain ranked in the lowest quartile. 
• Getting it right for every child so that we continue to improve
attainment for all 
Following initial attainment meetings, separate group
sessions with all Secondary Head and Depute Head Teachers
were held to explore core issues in relation to low attainment
in Senior Phase in relation to benchmarking data and
effects/symptoms, root causes and possible solutions.  Ten
summary priorities have been developed to raise attainment. 
These sessions have further developed into school-based
actions and system wide actions making use of existing and
newly created DHT networks supported and led by secondary
HTs and the Quality Improvement Manager. 
Moray Secondary Schools have benefitted from over £500k
additional funding under the theme of tackling poverty and
inequality to improve education attainment in the form of an
Intervention Fund for each school to target areas for
improvement. 
Secondary Schools continue to progress work on key priorities
framed by School Improvement Plans set out annually. 
(Source: Initial Analysis of Secondary Attainment – Session 2024-2025) 
Improved
attainment at both
Broad General and
Senior Phase
identified through
ACEL and LGBF
measures
8 The percentage of P1, P4 and P7 pupils combined achieving expected CFE
Levels in Numeracy made slight improvement to 76.9%, achieving the
Stretch Aim target of 73-77% 
• Early intervention addressing whole family well-being to
ensure that children can reach their full potential 
Strengthening Achievement of Curriculum for Excellence
levels across the Broad General Education being taken
forward through actions across strategy and support
materials, professional learning and moderation, tracking and
monitoring and support and challenge.  Key areas of work as a
wider schools and central education system continues to
progress. 
Progress across Moray schools and centrally to address
identified attainment gaps and barriers to learning and
achievement also continues through ongoing monitoring of
data throughout each school session as part of Moray Quality
Improvement Framework (MQIF), across Associated Schools
Groups (ASGs) and Family Improvement Groups (FIG)
collegiate session.  Moray Numeracy Strategy is being
developed in partnership with Education Scotland.  Schools
Improved
attainment at both
Broad General and
Senior Phase
identifies through
ACEL and LGBF
measures
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are involved in STEM spatial skills in Maths with Glasgow
University. 
Stretch Aim for Primary numeracy (P1, P4, P7 combined) for
2026 has been set at 78%. 
(Source: Initial Analysis of Achievement of Curriculum for Excellence
levels: Session 2024-2025) 
9 Funded early years provision which is graded good/better fell slightly to 84.0%,
below national and family averages, which were also subject to slight result
decreases. 
A new national Shared Quality Framework launched in
September 2025, aimed at enhancing outcomes for children in
ELC settings that provide high-quality, equitable and responsive
experiences. The framework will be used as an evaluation tool,
key to this process will be ELC settings evidencing robust self-
evaluation processes to support improvement and the Care
Inspectorate and HMiE in their inspections and evaluations. 
ELC settings will be supported by the central officer team, and
through a variety of hybrid training opportunities, to develop their
knowledge and understanding of the framework.  Officers are
building a Quality Improvement Framework akin to the schools
one and are supporting services to develop improvement plans
and associated self-evaluation processes.  As a result, the
number of settings not meeting the nation standard is reducing. 
(Source: Shared Quality Improvement Framework for Early Learning and
Childcare settings ECLS 25 Nov 2025)
Improve self-
evaluation for self-
improvement
across ELC settings
shared
understanding of
new improvement
areas
10 Latest published data for School attendance rates (per 100 ‘looked after
pupils’) was 82% in 2023-24, below national and family averages and on a
decreasing trend since 2020-21. 
Education Attendance Policy, scheduled to be agreed by ECLS
Committee in June 2026, has been updated and toolkits
(‘Attend to Achieve’) have been developed to strengthen
consistency across school settings in supporting positive
pupil attendance and providing supportive guidance where
necessary.  Schools will use the policy and toolkit for ongoing
monitoring and address levels for individual pupils, groups
and cohorts that are causing concern through single agency
approaches or multi-agency intervention. 
Parental engagement and the importance of reinforcing
positive school attendance for maximum learner attainment,
achievement and post-school opportunities is ongoing across
schools. 
(Source: Shared Quality Improvement Framework for Early Learning
and Childcare settings ECLS 25 Nov 2025)
Improved
attainment at both
Broad General and
Senior Phase
identifies through
ACEL and LGBF
measures
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10.1 Slight improvement in the proportion of Child Protection re-registrations within
18 months to 10.3%, below that of national and family averages (6.8%) and
remaining in the lowest quartile. 
The safety and wellbeing of children is ensured through timely,
proportionate, and effective support, repeat registrations
indicate risks have re-emerged or were not sufficiently reduced
following previous support. 
To address this, the partnership considers the staged closure of
families to social work and the move to child planning for families
where children have required a protection plan.  Learning from
repeat registrations identifies systemic gaps and improved
practices. 
(Source: Quarter 2 Performance Report for Children and Families and
Justice Social Work, IJB 26 February 2026)
Family: Keeping
Children and Young
People safe
Corporate Services  
11 Gender pay gap at 4% is above the national average of 1.4%, with average
hourly rate of pay for males at £19.66 above that of females, £18.87. 
A high number of employees (around 40%) are employed in service areas
such as catering, cleaning, care at home and schools support staff, areas
populated predominantly by a high number of part time female employees;
often who may hold more than one part time position across these
services. 
It is not always possible to apply comparisons in terms of the service
delivered and the composition of the workforce as not all councils deliver
the same services. 
The implementation and embedding of the Smarter Working
Project have supported the workforce in continuing to
undertake a range of flexible working options, making the
workplace more accessible for office-based staff which may
have positively impacted the reduction in the pay gap. 
The commitment to continue to improve recruitment
packages which support accessibility to work for all genders
through more creative ways of working and that support the
journey to sustainability continues.  The long-term impact on
the pay structure arising from the living wage and other pay
related issues are monitored to have in place fair and
competitive pay and conditions recognised as such and are
free of bias. 
Some progress was made in gathering workforce data but
remains an ongoing action to increase engagement to
improve the workforce personal data capture and therefore
more accurate reporting. 
Gender Pay Gap
and equality
issues are
assessed and
mitigating actions
put in place if
required
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12 Teacher absence levels increased in 2024/25 to 10.8 days per teacher, the
highest recorded since benchmarking began, ranked lowest nationally.   
High levels of workforce absence present several challenges for schools,
including increased reliance on supply cover, additional pressure on school
leadership teams and need to manage operational continuity within already
demanding environments. 
Improving Attendance Project report was presented to Council
on 3 December 2025 (item 7 of the Agenda refers) detailing
additional targeted support to assist in the maximisation of
teaching staff attendance at work, reducing absence costs and
reducing service impact on children and young people as part of
a spend to save transformation project, agreeing funding of £89k
as an initial pilot of one year support.  Progress will be reported at
6 months following implementation against defined targets.   
The project is focused on strengthening absence management
arrangements, consistent application of council policies and
supporting service managers in their responsibilities, including
reinforcing the supportive elements of the Health at Work Policy
to promote staff wellbeing, provide consistent and fair
management of absence and support sustainable returns to
work alongside improved attendance levels. 
(Source: Improving Attendance Project, ECLS 3 March 2026) 
Improved
attendance at
work, reducing
absence related
costs and
strengthen the
consistent
application of
absence
management
processes
13 Percentage of invoices sampled that were paid within 30 days remained
relatively unchanged at 89.5%.  Of the 55k invoices sampled, 49k invoices were
paid within 30 days, resulting in the indicator remaining in the lowest quartile. 
Early mapping work completed to increase efficiency and
availability of digital processes for Accounts. 
Replacement of the finance management system is in the early
stages with system operational anticipated by April 2028.  Market
research completed as expected and tender process underway. 
Services are reminded to process invoices promptly. 
(Source: Q3 Performance updates) 
Investigate
workflow for
authorisation
database
14 Scottish Welfare Fund awarded £392k of the £657 budget (59.6%), below family
and national averages. 
Scoping of centralised means testing has progressed and
demonstrates that support can be provided towards the recovery
of outstanding social care cost debts.  Improvement in key areas
could be gained by aligning some of the processes within social
care financial assessments with the benefits and money advice
Determine whether
a staffing efficiency
and maximisation
of council
resources is
achievable.
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service to perhaps identify where additional support can be
provided. 
(Source: Q3 Performance updates) 
Assets  
15 There has been a slight decrease in 55.4% in the percentage of internal floor
area of operational buildings in satisfactory condition.  119k m2 of 215k m2 was
of satisfactory condition. 
The Moray Learning Estate is a significant contributory factor to the operational
building condition indicator and with over half of the 52 schools having
condition surveys of less than B condition, the indicator ranking remains in the
lowest quartile. 
• Tackle the affordability and standard of our learning estate to
ensure sustainability while meeting climate requirements 
Design and construction – Elgin High School extension build
Design and construction – future Forres Academy operational
Design and construction – Future Buckie High School operational
Engagement and consultation – ASG Level Options Development
– long term investment strategy
Strategic Planning – Learning Estate Review Report
Engagement and consultation – effective stakeholder
engagement on Learning Estate sustainability options
Estate Rationalisation – future of Crossroads PS agreed
Design and construction – options developed to manage for Elgin
South and North primary school capacity requirements
Design and construction – schools BB upgrade programme
delivering minimum 3 B condition/suitability school upgrades per
year 
(Source: Corporate Plan Q3 2025-26) 
Moray has high
performing schools
that are fit for the
future and
financially and
environmentally
sustainable.
Adult Social Work
16 73.8% of care services were graded ‘good’ or better in Care Inspectorate
inspections, below family and national averages.   
External inspection results and commentary are included in the
Annual Performance Report. 
Services are assessed by the Care Inspectorate to ensure that
services provided meet the required standards and peoples’
outcomes are being met.
People who use
health and social
care services have
positive
experiences of
those services, and
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Much focus is placed on learning from complaints and feedback
to continually improve the quality and safety of services as well
as feedback received directly via surveys conducted as part of
monitoring and service redesign. 
(Source: Annual Performance Report 2025/25, Moray Integration Joint
Board Audit, Performance and Risk Committee, 19 June 2025)
have their dignity
respected.
Culture & Leisure  
17 The cost per library visit decreased to £5.23 due to an increase in the number of
library visits against a small reduction to net expenditure. 
In 2024-25, net expenditure totalled £2.4m, with 459k visits to library services. 
Across Scotland, results range, suggesting there are variations in calculation
methods which has been acknowledged nationally with clarity added to the
definition.   
• Transform our Sport & Leisure, Libraries, Learning Centres &
Heritage, Music Instruction & Performance service provision to
ensure a sustainable council for the future 
A report was submitted to Council on 3 December 2025 to
update on the transformation journey of Libraries, Learning
Centres and Heritage Service, proposing a tiered operating
model to provide a more standardised and efficient model for
future based on evidence and need. 
Extensive engagement with newly established library user groups
in all 11 branches across Moray was held over three meetings
with groups, that were supported by local members. 
Q3 update (93% complete) – The Change Management Plan has
been partially implemented.  With approval of the proposal,
implementation of Change Management Plans continue. 
(Source: Libraries, Learning Centres and Heritage Service Transformation,
Q3 performance updates)
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.
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18 The percentage of adults satisfied with Museums and Galleries (rolling 4 years)
fell to 45%, below national and family averages, remaining in the lowest
quartile. 
Due to budgetary constraints, operation of the Moray Museum
Service ceased on 1st April 2020.  The Falconer Museum with
Store is closed until an alternative service model is established. 
The collection continues to be monitored and buildings
maintained.
N/A
Environmental Services  
19 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 where around 10,500
households were interviewed with lower-than-expected
response rates inferring the sample size may be small.  This
should be set against positive performance in terms of the level
of recycling, costs of waste collection and disposal.  A review of
complaints has resulted in some procedural changes relating to
Household Collections. 
(Source: Q3 performance updates) 
N/A
Housing Services  
20 In 2024-25, 2,799 of 6,410 (43.7%) of properties within scope met the Scottish
Housing Quality Standards (SQHS). Performance has improved in recent years;
however, meeting energy efficiency elements is a significant part of SHQS and
results for this element have not been published since 2021-22 due to Scottish
Government review of EESSH2.  Indicator remains in the lowest quartile.   
• Continue to reduce the carbon impact arising from Housing and
Property Services 
In 2024-25, there was significant investment to improve energy
efficiency of housing stock by upgrading heating systems,
building insulation and solar panel installation.  Progress has
stifled by resource issues relating to tenant agreement to works,
contractor availability and time lag with certifications to confirm
improvements.  Contracts in place to continue to deliver
Phased
improvement of
energy efficiency
within corporate
buildings and
housing stock.
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improvements in energy efficiency within the Council’s housing
stock. Scottish Housing Regulator confirmed provisional data
indicated as of September 2025 EESSH compliance increased to
73.3%, the expectation for the year ending 31 March 2026 is for
80% compliance, which will positively impact on the council
dwelling meeting SHQS. 
(Source: Q3 performance updates)
Economic Development  
21 The percentage of unemployed people that were assisted into work from
Council operated / funded employability programmes improved to 10.4%.
Of the 135 people supported into work, 79% sustained work for over 13
weeks. 
The Local Employability Partnership, Moray Pathways
continues to support individuals into fair and sustainable
jobs.  Overall, over 300 people were supported, 285 are
participating in vocational skills programme; Sector based
Work Academy Programme (SWAP).  65 people have gone
onto further or higher education.  Support has also been
provided through; Barrier Removal activities (involving 205
service users), Creative Skills Network activities (112 service
users), CLD personal development (56 service users) and
Counselling (47 service users), 29 others are currently in the
engagement phase. 
Moray Pathways Local Employability Partnership Annual
Report was submitted to the Economic Development and
Infrastructure Services Committee on 17 June 2025. 
Moray Pathways Workforce North Event took place in
December 2025 with 100 attendees and a total of 50 local
employers from the energy sector, training providers and key
stakeholders from the public sector.  The Moray Workforce
Group are working on a roadmap / action plan to progress. 
(Source: Q3 performance updates) 
Increase the
number of
individuals who
are participating in
learning, training
and employment
opportunities
22 Cost per planning and building standards application increased to £9,931 due
to a 19% reduction in the number of applications decided to 362 and a 16%
increase in gross expenditure to £3.595m.  Result is above that of national and
family averages. 
Despite the increase in cost, the average processing time per
business and industry planning application at 8.5 weeks remains
in the top quartile performance results. 
Additional expenditure for the Levelling Up project within the
Planning policy service – Town Centre Development project
Improved
performance in line
with pillars set out
in the template
with local case
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commenced during 2024-25 from the UK Levelling Up fund. 
£700k of funding provided to property owners to undertake work
in Elgin Town Centre. 
studies and
performance data
23 Slight increase in investment in Economic Development & Tourism per 1,000
population to £89,085, with a total gross expenditure in economic development
and tourism of £8.5m.   
Economic Development – increase in spend and income for
Growth Deal, Shared Prosperity and Regeneration Capital grant
initiatives during 2024-25.
The Council is progressing an updated Tourism Strategy for Moray
which is currently under consultation with final approval
anticipated in June. Meantime work on the Cultural Quarter
project intended to grow tourism in the area as part of Moray
Growth Deal also continues. 
Maximise the
economic, social
and cultural
benefits of tourism
to Moray and
spread the benefits
across all sectors
of the community.
24 According to the Annual Survey of Hours and Earnings (ASHE), based on a
1% sample of the Pay As You Earn (PAYE).  As of March 2025, in Moray 16.2%
of employees (18+ workplace based) earned less than the real living wage. 
The increasing cost of doing business and consequential
impacts on pay levels is felt particularly acutely in Moray
given the existing low wage economy. 
The Community Wealth Building Strategy and Action Plan
2024 was approved by the Economic Development and
Infrastructure Committee in April 2024.  Delivery of the
Strategy and actions has been restricted due to initial
resourcing difficulties.  Meantime further initiatives designed
to improve pay levels continue including Moray Growth Deal
and the emerging Skills Routemap following the Skills
Summit in December 2025. These will take time to have an
impact. 
Ensure wealth
stays within our
local
communities.
Page 267

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(Source: Q3 performance updates)
Financial Sustainability  
25 Total useable reserves as a percentage of council annual budgeted revenue
pertains to the movement in reserves statement data providing an indication on
the level of how a Council is placed to meet unforeseen events.  As at March
2025, useable reserves represent 13.8% of the council annual budgeted
revenue, below that of national and family averages.   
The Budget and Financial Plan are agreed by Council in February
each year.  The Council’s updated reserves policy was approved
by Council in September 2024. 
The Council was able to set a balanced budget for 2026/27
despite ongoing cost pressure for growing demand on services
and upward price inflation, acerbated by below inflationary
revenue grant awards from Scottish Government. It is expected
that the national average will reduce towards Moray’s level as
councils are using reserves to balance their budgets (£158m
used for 2026/27).
The Council’s reserves include allocation for transformational
projects, which seek to improve the effectiveness and efficiency
of its services. 
(Source: Budget and Financial Plan, Full Council, annually in February)
Ensure a financially
sustainable future.
26 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 10.8.
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, Libraries and Leisure Estate and the Moray
Growth Deal. The breach of 10% was because of the introduction
of the accounting standard IFRS 16 Leases from April 2024
whereby additional costs previously treated as service
expenditure.  This indicator is factored into the Council’s
financial planning and is used as a tool for assessing affordability
of the capital plan,
A review of the long-term financing strategy is planned for 2026. 
Ensure a financially
sustainable future.
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(Source: Budget and Financial Plan, Treasure Management Prudential
Indicators, Full Council, annually in February)
Climate Change  
27 Latest data published in July 2025 relates to the 2023-24 period, recording
6.54 tonnes per capita of CO2 emissions area wide for emissions within the
scope of influence of the Council, ranked lowest across all authorities. 
The data is taken from the UK Government UK local authority and regional
carbon dioxide emissions national statistics publication. 
2023-24 update to the Climate Change Plan and Routemap to
Net Zero, giving insight into current performance, identifying
key barriers to progress and outlining next steps to keep the
Council on a viable pathway to net zero was reported to
Council in August 2025.  Although emissions have reduced,
emissions arising from the Council’s fleet and property are
proving difficult to reduce at pace.   
Based on the pace and level of investment, the Council’s
previous target of being net zero by 2030 was recognised as
not being achievable.  The Council agreed to amend the target
to 2045 with an update to the Council’s Climate Change
Strategy presented to Council in September 2025, providing
an opportunity to reflect on existing commitments and
reprioritise efforts to ensure that work aligns with local
needs, opportunities, and the evolving statutory landscape,
before making ready for extensive consultation. 
The Climate Change and Biodiversity strategies following
public consultation will be presented to Full Council on 30
June and 7 May 2026 respectively. 
(Source: Climate Change Plan and Routemap to Net Zero Update, Full
Council, August 2025, Climate Change Strategy 2025-2035, Full
Council, September 2025)
The Council
adapts to the
changing climate
and acts
sustainably
28 As at March 2025, there were 40.92 tonnes of CO2 emissions from Transport
per 1000 population, above national and family averages and remaining in the
lowest quartile. 
The data is obtained from the Sustainable Scotland Network Annual Report. 
The Council’s Zero Emission Fleet Replacement Strategy details
the Council’s plans to decarbonise the remainder of the fleet in
line with Scottish Government’s net zero targets, however these
plans are challenging in the setting of required budget savings. 
The Council adapts
to the changing
climate and acts
sustainably
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Being a rural authority, this brings unique challenges due to the
high dependence on private cars and the lack of public transport
infrastructure. 
The Council are playing a crucial role in decarbonising transport
by encouraging active travel, implementing interventions such as
providing electric vehicle charging points, improving bus services
and promoting shared mobility options. 
(Source: Climate Change Plan and Routemap to Net Zero Update, Full
Council, August 2025) 
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Page 271

Moray appears in the following Benchmarking Family Groups – 
Table Legend
Relative Change Short Term Trend Rank 2024/25
2023/24 to 2024/25 Result to Previous
Year
Local Authorities
(32)
Family Group (8)
Result improving by 5%
or more  improved 1st quartile 1st quartile
Result worsened by 5%
or more  worsened 2nd quartile 2nd quartile  
no change
3rd quartile  3rd quartile  
4th quartile  4th quartile 
People Services (A) Other Services (B)
Includes education, social work and housing. The
benchmarking clubs are based on the average
social context of the local authority population
(using data from SIMD 2012).
Includes environmental services and
culture/leisure services. The benchmarking clubs
are based on the dispersion of the local authority
population (using data for the Grant-Aided
Expenditure indicator for population dispersion).
Angus
Argyll & Bute
East Lothian
Highland
Midlothian
Moray 
Scottish Borders
Stirling
East Ayrshire
East Lothian
Fife 
Moray
North Ayrshire
Perth & Kinross
Stirling
South Ayrshire
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APPENDIX 2
Results improved / worsened (for results published since last reported)
Results that improved by 5% or >
• Gross cost of looked after children in a community setting per child per week reduced from
£488 to £460
• Improvement in the percentage of pupils living in the 20% most deprived areas gaining 5+
awards at Level 6
• Tariff score in SIMD Quintile 1 nearly doubled to 720, as a result ranking has moved from the
lowest to top quartile.
• School exclusion rates per 1,000 pupils improved to 17.1 improving ranked position by 3
places to 18th.
• Slight improvement in homecare costs per hour for people aged 65 or over to £30.90 due to
decreases in homecare expenditure of 7.6% and in care hours per year of 2.3%.
• Significant improvement to become the lowest rate nationally for readmissions to hospital
within 28 days per 1,000 discharges.
• The number of bed days people (75+) spend in hospital when ready to be discharged fell for a
second consecutive year, 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, maintaining top quartile performance over the last 6 years.
• Increase in number of library visits against a slight decrease in net expenditure has resulted in
a reduction in the cost per library visit.  Result remains above the national average and in the
lowest quartile.
• Cost of parks and open spaces per 1,000 population reduced due to a decrease in net
expenditure.
• Net cost per waste collection per premise holds top quartile ranking for a decade due to a
reduction in net expenditure. 
• Reduced cost of street cleaning due to decrease in net expenditure against a slight increase
in estimated population maintaining a top quartile ranking since measurement commenced
in 2010/11.
• 10% reduction in gross expenditure in roads and winter maintenance resulted in an
improvement in the cost per kilometre, maintaining a top quartile ranking.
• Slight decrease in gross expenditure in Trading Standards, Money Advice and Citizens Advice
resulted in a decrease in cost per 1,000 population.
• Significant improvement in proportion of council dwellings meeting SHQS, despite
improvement, the ranked position remains unchanged and in the lowest quartile for last 4
years.
• Number of unemployed people assisted into work from council operated / funded
employability programme double to 135 improving the percentage result and ranking to 25th.
• Slight increase in gross expenditure resulted in improvement in the investment in economic
development and tourism per 1,000 population, albeit result remains well below the national
average and within the lowest quartile.
• Modest improvement in the proportion of properties receiving superfast broadband
• Slight decrease in emissions from natural gas per capita, remaining below national and
family averages and ranking in the top quartile. 
Results that worsened by 5% or >
• Percentage of pupils living in the 20% most deprived areas achieving 5 or more awards at
level 5 decreased significantly, dropping into the lowest quartile.
• Decrease in the percentage of adults satisfied with local schools over a rolling 4 years. 
Sample size from Scottish Household Survey will be a contributory factor.
• A 15% increase in the overall cost for collecting council tax resulted in an increased cost per
dwelling.
• Sickness absence days per teacher dropped to 10.8 days, above the national average and
ranked lowest nationally.
• Sickness absence days per employee (non-teacher) dropped to 15.7 days, above the
national average and falling to a ranked position of 23rd.
• £392k of Scottish Welfare Fund budget was spend, 59.6% of budget.
• Decrease in the proportion of adult care services graded good or better to below that of the
national average.
• Satisfaction rates in both adults satisfied with libraries and adults satisfied with Museums
and Galleries.  Scottish Household Survey sample size likely a contributory factor.
• Average number of days to complete non-emergency repairs increased to 6.3 days, below
the national average of 10.1 days, maintaining a lowest quartile ranking.
• Cost of Planning & Building Standards per planning application increased significantly due
to increased gross expenditure and a decrease in planning applications decided, dropping
into the lowest quartile.
• Average time per business and industry planning application (weeks) increased slightly but
result remains within the top quartile.
• Five percentage point decrease in the percentage of immediate available employment land
of total land allocated for employment purposes, improving ranked position by one place to
19th.
• Total usable reserves as a percentage of annual budgeted revenue dropped to 13.8% but
maintaining ranked position of just outside lowest quartile. 
• Ratio of Financing Costs to Net Revenue Stream for Housing Revenue Account increased to
30.1%, above the national average, remaining in the third quartile. 
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Page 273

APPENDIX 3  
Overview of Local Government Benchmarking Framework Indicator Results 
Note Indicator Description
Moray National
Average 
Family 
Group
Average
Relative
Change
Since previous
year
Rank
Latest
result
2020/21 2021/22 2022/23 2023/24 2024/25 Latest
result
Latest
result
%
change 
Short
Term
Trend
Nat
(32)
FG
(8)
Children’s Services (A) 
Cost per primary school pupil (£) 6,358 6,876 7,163 7,178 7,252 7,606 7,780 1.0  7 2 
Cost per secondary school pupil (£) 8,656 8,947 9,131 9,250 9,211 9,338 9,533 -0.4  14 4 
Cost per pre-school education place (£) 8,906 11,081 11,270 10,197 10,410 12,055 12,174 2.1  4 2 
% of secondary pupils achieving 5 or more awards
at Level 5 66 63 62 62          64 69 66 2.2  22 5 
% of secondary pupils achieving 5 or more awards
at Level 6 34 30 28 30          31 41 37 1.1  23 5 
% of pupils living in the 20% most deprived areas
Gaining 5+ awards at Level 5 41 42 52 31 45 53 44 -7.1  21 4 
% of pupils living in the 20% most deprived areas
Gaining 5+ awards at Level 6 19 19 12 N/A2          21 24 17 9.5  14 2 
Gross Cost of “Children Looked After” in Residential
Based Services per child per week (£) 5,595 4,827 3,263 3,831          3,736 5,267 4,786 -2.5  5 3 
Gross Cost of “Children Looked After” in a Community
Setting per child per week (£) 478 520 475 488 460          480 429 -5.6  16 6
1 % of children being looked after in the community 82.2 80.6 75.3 78.0 77.6          88.3 83.6 -0.4  26 7 
% of adults satisfied with local schools (rolling 4 years) 64.5 72.7 77.2 76.1 67.3 69.0 69.5 -8.7  23 6
2 % of pupils entering positive destinations 94.1 96.2          95.1 93.8          93.5 95.7 95.3 -0.3  30 7
3 Overall average total tariff  876 882 834 826 829 922 869 0.4  26 6 
Overall average total tariff SIMD Quintile 1 887 735 571 378 720 655 543 90.5  5 1
4 Overall average total tariff SIMD Quintile 2 635 637 581 625 639 772 685 2.2  27 6
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Note Indicator Description
Moray National
Average 
Family 
Group
Average
Relative
Change
Since previous
year
Rank
Latest
result
2020/21 2021/22 2022/23 2023/24 2024/25 Latest
result
Latest
result
%
change 
Short
Term
Trend
Nat
(32)
FG
(8)
5 Overall average total tariff SIMD Quintile 3 868 868 820 780 768 895 833 -1.5  30 8
6 Overall average total tariff SIMD Quintile 4 954 944 921 917 902 1,049 991 -1.6  29 6
7 Overall average total tariff SIMD Quintile 5 959 1,005 977 970 993 1,269 1,131 2.4  28 7 
% P1, P4 & P7 pupils combined achieving expected
CFE Level in Literacy 63.9 65.1 67.9 70.6 72.7 74.5 74.2 2.1  21 6
8 % P1, P4 & P7 pupils combined achieving expected
CFE Level in Numeracy 67.8 71.8 75.5 76.5 76.9 80.3 79.4 0.4  27 7 
Literacy Attainment Gap (P1,4,7 combined) –
percentage point gap between the least and most
deprived pupils
19.8 26.3 32.1 N/A2          N/A2               
Numeracy Attainment Gap (P1,4,7 combined) –
percentage point gap between the least and most
deprived pupils
17.5 24.7 26.6 N/A2          N/A2               
% of children meeting developmental milestones 96.0 84.9 87.4 83.4         81.7 83.5 85.1 -1.7  24 7
9 % of funded early years provision which is graded
good/better  85.2 86.9 87.5 84.1 84.0 89.0 89.1 -0.1  27 7 
School attendance (%) 93.8 N/A1 91.2 90.8 91.2 91.0 91.5 0.4  16 6
10 School attendance rates (LAC, %) 89.4  83.4 82.0 N/A3 
(Aug 2026)         83.7 85.2 -1.4  26 7 
School exclusion rates per 1,000 pupils 14.2  20.2  17.1 15.2 15.2 -15.5  18 4 
School exclusion rates per 1,000 looked after
children 125.0  156.0  N/A3 
(Dec 2026)               
% participation for 16-19 year-olds 91.8 91.6 94.5 93.1 94.3 93.3 94.3 1.2  12 6
10.1 % of child protection re-registrations within 18 months 2.3 9.8 0.0          7.0 8.8 6.8 6.8 -0.2  25 5 
% LAC with more than 1 placement in the last year
(Aug-July) 14.9 15.9 11.8 14.7 10.9 16.5 19.5 -3.8  4 1 
% of children living in poverty (after housing costs) 21.3 24.1 23.9          14.9 15.1 14.8 13.7 -0.3  22 7
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Note Indicator Description
Moray National
Average 
Family 
Group
Average
Relative
Change
Since previous
year
Rank
Latest
result
2020/21 2021/22 2022/23 2023/24 2024/25 Latest
result
Latest
result
%
change 
Short
Term
Trend
Nat
(32)
FG
(8)
Corporate Services (B) 
Support Services as a % of Total Gross Expenditure 4.1 3.9 3.8 3.7 3.7 4.0 3.7 0.1  14 5 
% of the highest paid 5% employees who are
women 61.1 62.7 59.5 61.2 62.3 60.3 59.7 1.1  8 3
11 The gender pay gap (%) 6.2 7.0 5.3 4.6 4.0 1.4 0.7 -0.6  29 7 
Cost of collecting Council Tax per dwelling 9.55 9.17 8.23 7.12 8.12 5.98 8.07 14.0  22 6
12 Sickness Absence days per Teacher 4.5 6.0 7.9 9.6 10.8 7.8 8.4 12.8  32 8 
Sickness Absence days per Employee (non-teacher) 8.7 11.1 12.8 14.0 15.7 14.5 14.9 12.2  23 5 
% of income due from Council Tax received by the end
of the year 95.8 96.7 96.7 96.2 96.2 95.5 96.1 -0.0  14 4
13 % of invoices sampled that were paid within 30 days 84.0 85.5 89.4 89.4 89.5 93.1 88.7 0.0  27 5 
% of Crisis Grant Decisions within 1 day 98.5 98.0 97.8 97.9 99.5 96.0 97.6 1.6  9 2 
% of CCG Grant Decisions within 15 days 90.8 95.5 89.3 98.1 99.2 90.7 95.1 1.1  8 4
14 Proportion of SWF Budget Spent 64.3 99.0 123.9 111.5 59.6 82.9 77.2 -51.9  28 7 
Proportion of DHP Funding Spent 90.6 75.6 79.8 90.0 89.0 99.0 89.6 -1.0  24 5
Assets
(B) 
% of operational buildings that are suitable for their
current use 98.2 97.6 97.5 97.4 96.1 85.7 90.5 -1.3  3 2
15 % of internal floor area of operational buildings in
satisfactory condition 66.9 54.9 56.3 56.3 55.4 91.0 88.4 -0.9  31 8
Adult Social
W
ork (A) 
Home Care costs per hour for people aged 65 or over
(£) 33.36 24.37 26.13 32.67 30.90 32.37 34.46 -5.4  14 4 
Self-Directed Support spend on people aged 18 or
over as a % of total Social Work spend on adults 5.0 3.6 4.6 4.8 6.7 9.4 7.4 2.0  17 5 
% of people aged 65 or over with long term care needs
receiving personal care at home 63.4 61.3 59.8 60.3 61.6 62.3 59.8 1.3  22 4
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Note Indicator Description
Moray National
Average 
Family 
Group
Average
Relative
Change
Since previous
year
Rank
Latest
result
2020/21 2021/22 2022/23 2023/24 2024/25 Latest
result
Latest
result
%
change 
Short
Term
Trend
Nat
(32)
FG
(8) 
% 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) 
73.3  69.3       
% of adults supported at home who agree that they are
supported to live as independently as possible  79.3  71.9       
% of adults supported at home who agree that they
had a say in how their help, care or support was
provided 
70.2  59.5       
% of carers who feel supported in their caring role  31.6  28.2       
Residential costs per week per resident for people
aged 65 or over (£) 600 526 696 561 573 725 724 2.1  8 1 
Rate of readmission to hospital within 28 days per
1,000 discharges (%) 100.9 85.9 80.6 76.5 61.0 102.8 102.3 -20.3  1 1
16 Proportion of care services graded ‘good’ (4) or better
in Care Inspectorate inspections (%) 79.8 80.0 74.0 81.1 73.8 81.9 79.8 -7.3  28 7 
Number of days people spend in hospital when they
are ready to be discharged, per 1,000 population (75+) 506 778 1057 950 820 899 939 -13.7  15 3
Culture & Leisure (B) 
Gross cost per attendance at Sports facilities (£) 22.46 3.11 2.66 1.87 1.63 3.77 4.40 -12.7  3 1
17 Cost per Library visit (£) 3.53 3.21 7.15 5.64 5.23 2.72 4.84 -7.3  28 5 
Cost of Museums per visit (£) N/A1 N/A1 N/A1 N/A1 N/A1       
Cost of Parks & Open Spaces (£) per 1,000 population 14,539 17,848 17,353 18,652 16,882 21,998 25,647 -9.5  8 2 
% of adults satisfied with Libraries (rolling 4 years) 82.9 82.3 79.3 78.0 68.3 65.3 69.5 -9.7  14 5 
% of adults satisfied with Parks and Open Spaces
(rolling 4 years) 85.1 85.7 86.3 85.3 82.3 83.7 84.7 -3.0  22 6
18 % of adults satisfied with Museums and Galleries
(rolling 4 years) 64.1 62.3 58.3 57.0 45.0 67.0 62.9 -12.0  28 8 
% of adults satisfied with Leisure Facilities (rolling 4
years) 72.4 74.7 71.3 69.7 65.0 65.0 68.5 -4.7  18 6
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Note Indicator Description
Moray National
Average 
Family 
Group
Average
Relative
Change
Since previous
year
Rank
Latest
result
2020/21 2021/22 2022/23 2023/24 2024/25 Latest
result
Latest
result
%
change 
Short
Term
Trend
Nat
(32)
FG
(8)
Environmental Services (B) 
Net cost per Waste collection per premises (£) 41.75 39.57 42.29 41.45 35.10 77.26 76.78 -15.3  2 1 
Net cost per Waste disposal per premises (£) 122.43 119.27 107.92 105.58 102.53 104.45 103.26 -2.9  15 5 
Net Cost of Street Cleaning (£) per 1,000 population 8,874 9,531 9,805 8,675 8,083 17,869 15,451 -6.8  3 1 
Street Cleanliness Score N/A1 N/A1 N/A1 N/A1 N/A1       
Cost of Maintenance per Kilometre of Roads (£) 5,162 6,038 7,034 7,608 6,827 13,629 13,954 -10.3  5 1 
% of A Class roads that should be considered for
maintenance treatment (rolling 2 years) 26.6 23.2 24.1 26.8 27.0 30.6 28.3 0.2  14 4 
% of B Class roads that should be considered for
maintenance treatment (rolling 2 years) 22.3 18.3 18.4 21.0 20.5 34.6 29.6 -0.4  2 1 
% of C Class roads that should be considered for
maintenance treatment (rolling 2 years) 21.3 19.3 20.6 22.7 24.7 34.2 32.3 1.9  5 1 
% of unclassified roads that should be considered for
maintenance treatment (rolling 2 years) 35.0 32.0 30.3 29.3 32.0 36.2 35.7 2.7  11 2 
Cost of trading standards and environmental health (£)
per 1,000 population 22,927 28,184 25,607 24,352 23,313 21,671 19,761 -4.3  20 7 
Cost trading standards, money advice & citizens
advice (£) per 1,000 population 5,729 5,800 6,460 5,918 5,547 7,203 5,887 -6.3  10 3 
Cost of environmental health (£) per 1,000 population 17,199 22,384 19,148 18,434 17,767 14,469 13,874 -3.6  23 7 
% of total household waste arising that is recycled 54.9 52.2 57.8 56.2 56.7 44.3 52.0 0.5  2 1
19 % of adults satisfied with refuse collection (rolling 4
years) 69.8 71.7 76.0 75.7 75.3 78.3 79.0 -0.3  25 7 
% of adults satisfied with street cleaning (rolling 4
years) 58.3 58.7 62.7 57.7 55.0 57.0 63.5 -2.7  22 8
Housing
Services
(A) 
Gross rent arrears (all tenants) as at year end as a % of
rent due for the reporting year
Note: Ranking relates to 26 Local Authorities
3.2 3.8 4.5 4.7 3.3 8.6 7.4 -1.4  1 1 
% of rent due in the year that was lost due to voids
Note: Ranking relates to 26 Local Authorities 1.2 1.2 1.0 0.7 0.7 1.7 1.4 -0.0  4 1
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Note Indicator Description
Moray National
Average 
Family 
Group
Average
Relative
Change
Since previous
year
Rank
Latest
result
2020/21 2021/22 2022/23 2023/24 2024/25 Latest
result
Latest
result
%
change 
Short
Term
Trend
Nat
(32)
FG
(8)
20
% of council dwellings meeting Scottish Housing
Quality Standard
Note: Ranking relates to 26 Local Authorities
93.8 6.3 15.5 22.6 43.7 82.9 70.8 21.0  26 6 
Average number of days to complete non-emergency
repairs
Note: Ranking relates to 26 Local Authorities
6.1 8.0 5.7 5.7 6.3 10.1 14.2 10.9  4 1 
% of council dwellings that are energy efficient
Note: Ranking relates to 26 Local Authorities 57.4 60.4 N/A3 N/A3 N/A3      
Economic Development (B)
21
% Unemployed People Assisted into work from
Council operated / funded Employability
Programmes
5.3 5.9 10.8 5.0 10.4 14.2 12.6 5.4  25 6
22 Cost per Planning Application 5,379 5,949 6,930 6,913 9,931 6,938 9,024 43.7  27 5 
Average time (Weeks) per Planning Application 6.7 6.2 6.3 7.2 8.5 14.3 10.0 17.2  8 4 
% of procurement spent on local small / medium
enterprises 23.6 25.2 24.8 23.6 26.8 31.5 26.7 3.2  18 4 
No of business gateway start-ups per 10,000
population 9.6 12.7 11.3 11.0 11.4 12.3 13.8 3.6  21 5
23 Investment in Economic Development & Tourism per
1,000 population (£) 41,775 52,031 89,857 80,561 89,085 138,745 181,001 10.6  26 8
24 Proportion of people earning less than the living
wage (%) 21.5 19.4 13.8 14.4 16.2 11.3 13.2 1.8  25 7 
Proportion of properties receiving superfast
broadband (%) 85.7 85.6 87.2 87.8 93.0 97.1 96.7 5.2  24 7 
Town Vacancy Rates (%) 10.9 10.6 10.6 14.1 14.0 11.4 13.2 -0.1  21 5 
Immediately available employment land as a % of total
land allocated for employment purposes in the local
development plan 
34.8 14.9 14.9 14.9 9.7 21.3 17.4 -5.2  19 3 
Gross Value Added (GVA) per capita (£) 24,619 26,594 28,144 28,220 N/A3
(Apr 2026) 30,581 23,811 0.3  9 2 
Claimant count as a % of working age population (%)  5.3 3.0 2.5 2.3 2.4 3.1 2.6 0.1  11 4 Page 278

Page 279

Note Indicator Description
Moray National
Average 
Family 
Group
Average
Relative
Change
Since previous
year
Rank
Latest
result
2020/21 2021/22 2022/23 2023/24 2024/25 Latest
result
Latest
result
%
change 
Short
Term
Trend
Nat
(32)
FG
(8) 
Claimant count as a % of 16-24 population (%)  7.7 3.3 3.0 2.7 2.9 3.3 3.2 0.2  12 3
Financial
Sustainability (B)
25 Total useable reserves as a % of council annual
budgeted net revenue 25.1 26.3 24.8 19.0 13.8 20.5 18.1 -5.3  25 6 
Uncommitted General fund Balance as a % of council
annual budgeted net revenue 7.2 2.2 2.1 2.3 2.1 2.0 2.3 -0.2  12 4
26 Ratio of Financing Costs to Net Revenue Stream 8.0 8.3 8.7 8.7 10.8 6.0 6.3 2.0  31 8 
Ratio of Financing Costs to Net Revenue Stream –
Housing Revenue Account 21.6 20.7 22.0 23.6 30.1 20.7 24.5 6.5  18 7 
Actual outturn as a % of budgeted expenditure 89.6 91.1 93.4 97.1 100.4 100.1 100.1 3.2  9 1 
Reliance on Reserves as a % of net expenditure   4.0 1.2 0.0 0.6 0.8 -1.2  1 1
Climate Change
(B) 
CO2 emissions area wide per capita 4.13 4.72 4.37 4.10 N/A3
(Jul 2026) 4.59 5.18 -6.2  17 4
27 CO2 emissions area wide: emissions within scope
of LA per capita 6.44 7.30 6.80 6.54 N/A3
(Jul 2026) 4.04 4.9 -3.9  32 8
28 CO2 emissions from Transport per capita 29.6 36.12 44.79 38.59 40.92 29.38 26.67 4.5  29 8 
CO2 emissions from Electricity per capita 30.65 33.6 30.91 32.57 32.92 45.6 39.11 1.1  5 3 
CO2 emissions from Natural Gas per capita 45.97 50.10 45.83 44.15 41.72 55.52 47.88 -5.5  5 2 
N/A1  Data no longer collected nationally / locally.
N/A2 Result below 5; not published to protect confidentiality.
N/A3 Data not yet published. 
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Report to: Audit and Scrutiny
Committee
Meeting
Date:
18 June 2026  
Report by: Executive Director Finance, Strategy and Transformation      
Author: Alasdair McEachan Contact
Email:
Alasdair.mceachan@moray.gov.uk 
Subject: Guidance on Agenda Items 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to approve guidance for the identification of ad-hoc agenda 
items for the Committee. 
1.2  This report is submitted to Committee in terms of paragraph 1 (11) of the Council’s
Scheme of Administration relating to scrutiny functions of the committee. 
2.  SUMMARY  
2.1  Following changes to the remit of the Council’s Audit and Scrutiny Committee, adding ad
hoc/thematic reviews as Agenda Items, the Council agreed that guidance would be
prepared to assist in identifying areas for review. 
2.2  This report proposes guidance for identification of such Agenda Items. 
3.  RECOMMENDATIONS 
3.1  It is recommended that Committee approve the Guidance for Agenda Item
Submissions document attached as Appendix 1 to this report. 
Alasdair McEachan
Chief Governance Officer 
4.  BACKGROUND AND CONTEXT  
4.1  The Council meeting on 28 January 2026 approved amendments to the Audit and Scrutiny
remit within the Council Scheme of Administration (para 12 of minute refers). 
Item 15.
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4.2  These amendments included the following: 
New remit Rationale
To scrutinise overarching improvement
themes relevant to the Council's policy
and regulatory landscape (which are not
subject to scrutiny through a particular
service committee) and to make
recommendations in relation to these
themes.
There are some improvement themes (for
example poverty) which do not fall neatly
within existing corporate and service
performance reports. It is proposed that
such improvement themes can be
considered by the Audit and Scrutiny
Committee with guidance developed on
how such issues are identified for
consideration by the committee. 
4.3  This report proposes guidance for identification of improvement themes in line with the
revised remit, as highlighted in bold in the previous paragraph. 
5.  PROPOSALS  
5.1  It is proposed that the Committee approve the Guidance on Agenda Item Submissions
document attached as Appendix 1 to this report. 
5.2  The guidance document summarises the different governance documents which the Audit
and Scrutiny Committee can expect to see, including the new section on Ad hoc/thematic
items.  
5.3  Paragraph 3 of the Guidance documents proposes a mechanism for identification of Ad
hoc/thematic items as follows: 
• Items should be related to strategic issues covered in the Council’s Corporate Plan.
• Audit and Scrutiny Committee members can suggest issues at their  periodic
meetings with the Internal Audit Manager,  the Chair or direct to CLT. 
• CLT screening to check no other current council consideration of the issue. 
• CLT to decide who the most appropriate officer is for report preparation and
suitable timecscale. 
• Important to have regard to priority of issue and capacity of officers. 
It is anticipated that the numbers of such reports around 3 in any given year.  
5.4  The Guidance document also provides for an annual review of the effectiveness of the
revised remit and guidance as part of the Annual review of the constitutional documents
which takes place around the turn of the calendar year. 
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
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Policy and Legal x 
Financial  x
Risk  x
Staffing x 
Best Value and Transformation x 
Property  x
Information Communications Technology/Digital  x
Equalities. Social Inclusion and Economic Impact   x
Climate Change and Biodiversity Impact  x 
6.2  Corporate Plan and 10 Year Plan (Local Outcomes Improvement Plan (LOIP))
Effective scrutiny will better enable the Council to fulfil the ambitions set out in its
strategic plans.   
6.3  Policy and Legal 
The Guidance proposed sits as a policy document beneath the Council Scheme of
Administration. 
6.4  Financial 
There are no financial implications 
6.5  Risk 
Additional scrutiny in thematic areas has the potential to help manage risk. 
6.6  Staffing 
The capacity of officers to produce additional reports to the committee is a consideration
with the Guidance. 
6.7  Best Value and Transformation 
Additional scrutiny has potential to improve monitoring of strategic priorities and to
contribute towards continuous improvement. 
6.8  Property 
None.  
6.9  Information Communications/Technology/Digital 
None 
6.10  Equalities, Social Inclusion and Economic Impact 
None.  
6.11  Climate Change and Biodiversity Impacts 
No direct implications. 
7.  CONSULTATION  
7.1  The Guidance has been prepared in consultation with the Central Leadership Team and
the Strategic Leadership forum.  Comments made have been incorporated into the
guidance. 
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8.  BACKGROUND PAPERS  
8.1  Report to Moray Council on remit of Audit and Scrutiny Committee , 28 January 2026. 
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APPENDIX 1
Audit & Scrutiny Committee
Officer Guidelines on Agenda Item Submissions 
1. Introduction 
1.1 The Audit and Scrutiny Committee provides independent assurance on the
effectiveness of the Council’s governance, internal control environment, financial
reporting arrangements and risk management framework. Through its oversight
role, the Committee supports constructive and transparent scrutiny of strategic
risks and key decision-making processes, helping to ensure accountability,
integrity and well-informed governance across the Council. 
1.2 The Committee reviews reports from internal and external auditors, monitors the
management of risks and internal controls, scrutinises areas of policy, service
delivery and performance where improvement may be required. Overall, it acts as
a non-political source of assurance, supporting effective governance and
ensuring that public funds are used lawfully, properly and efficiently. 
1.3 The Moray Council's Scheme of Administration for the Audit and Scrutiny
Committee outlines the Committee's functions and responsibilities. These
include: 
• Ensuring that the highest standards of probity, transparency, and public
accountability are upheld across the organisation.
• Considering and reviewing reports from the internal and external auditors
relating to Council functions and activities.
• Examining and scrutinising areas of policy, service delivery or organisational
performance that have been identified as requiring improvement, providing
challenge and oversight to support better outcomes. 
2. Audit and Scrutiny Committee Reporting Topics
2.1 As an aid to officers, the following areas have been identified for reporting to
ensure that the Council meets the functions of the Audit and Scrutiny Committee:
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Standing Items Objectives
Internal Audit update reports An Internal Audit update report provides the Committee with regular assurance on
progress against the approved Internal Audit Plan. It highlights completed work,
work in progress, changes to the plan, resource issues and any emerging risks or
concerns. This enables the Committee to monitor the performance of the internal
audit function in accordance with the Global Internal Audit Standards.
Internal Audit reports  Individual internal audit reports provide the Committee with detailed findings from
completed audits, including assurance levels, control weaknesses and agreed
management actions. Reviewing these reports helps the members understand
specific risks or non-compliance, challenge management on progress, ensure
actions are implemented to strengthen governance, risk management and internal
control.
External Audit update reports  External Audit updates provide the Committee with independent assurance on the
Council’s financial management, governance and value-for-money arrangements.
Periodic or Annual Items Objective
Internal Audit Annual Report  The Internal Audit Annual Report provides the Committee with an overall
independent opinion on the effectiveness of the Council’s governance, risk
management and internal controls. It summarises key audit findings, assurance
levels and outstanding actions, enabling the Committee to identify areas of
weakness, monitor improvements and ensure robust oversight of organisational
performance and controls.
Internal Audit Annual Plan  This provides the Committee with oversight of planned audit activity for the
forthcoming year. It ensures that internal audit resources are targeted at the
Council’s key risks and gives members the opportunity to challenge priorities,
request amendments and gain assurance that the internal audit function is robust
and risk-based.
Draft Annual Accounts  This allows the Committee to review and scrutinise the financial statements before
they are finalised. It includes assessing whether the accounts present a true and
fair view, understanding significant judgements and identifying any areas requiring
further explanation or assurance prior to approval by the Council.
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Annual Governance Statement  This enables the Committee to consider the effectiveness of the Council’s
governance framework. The statement outlines how governance arrangements
operated during the year, highlights any weaknesses and sets out planned
improvements. The Committee’s role is to challenge, seek evidence and ensure
transparency.
External Audit Annual Plan The External Audit Annual Plan sets out the planned scope, approach and
timetable for the external auditor’s work for the year. It enables the Committee to
understand upcoming audit activity, key areas of audit focus and any significant
risks. This ensures appropriate oversight of the external audit process and allows
members to challenge and comment on the proposed work before it proceeds.
External Audit Annual Report The External Audit Annual Report provides the Committee with independent
assurance on the accuracy of the financial statements, the effectiveness of
governance and financial management and any significant risks or areas requiring
improvement. It enables the Committee to scrutinise external audit findings,
monitor agreed actions and ensure strong accountability and stewardship of public
funds.
Treasury Management Annual Report  This informs the Committee about the Council’s treasury activities over the year,
including borrowing, investment performance, risks and compliance with the
treasury strategy and prudential indicators. The Committee’s role is to scrutinise
performance, ensure responsible stewardship of public funds and understand any
associated financial or risk implications.
Key performance reporting Overarching issues arising from service performance reports should be presented
to the Audit and Scrutiny Committee to highlight cross-service risks, trends or
weaknesses that may affect overall governance and organisational effectiveness.
This enables the Committee to maintain strategic oversight, identify systemic
issues and ensure that appropriate improvement actions are being taken across
the Council.
Ad-hoc / Thematic Items Objective
Major project audit reviews  Reporting of major project reviews provides the Committee with assurance on the
governance and delivery of significant projects, highlights key risks or weaknesses
and ensures that projects are managed and delivered in line with the agreed
programme.
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Compliance with statutory requirements  Reporting of compliance with statutory requirements informs the Committee
about how well the Council is meeting its legal duties. Reporting should highlight
any gaps, risks, or areas requiring improvement, enabling the Committee to
oversee and ensure that the Council operates lawfully and in accordance with the
required standards.
Cross cutting themes identified by members Cross-cutting strategic themes identified by members for review enable the
Committee to examine wider organisational issues that span multiple services.
These reviews highlight systemic risks or improvement opportunities, enabling the
Committee to oversee stronger governance and improved performance across the
whole Council. 
Thematic reports from recognised best practice
organisations
Providing reports from statutory bodies and recognised best-practice organisations
relating to governance, financial management and performance in local
government supports the Committee’s oversight role. These reports keep members
informed of key issues and help maintain transparency and awareness of matters
that may be relevant to the Council’s own arrangements. 
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2.2 The Audit & Scrutiny Committee is not a service performance committee. 
Officers should avoid submitting operational or day-to-day service issues e.g.
• Routine service performance matters 
• Operational complaints 
• HR/staffing issues 
• Service-level KPIs not linked to governance or risk 
3. Guidance for selection of Ad hoc/thematic items
• Items should be related to strategic issues covered in the Council’s Corporate
Plan.
• Audit and Scrutiny Committee members can suggest issues at their  periodic
meetings with the Internal Audit Manager,  the Chair or direct to CLT. 
• CLT screening to check no other current council consideration of the issue. 
• CLT to decide who the most appropriate officer is for report prep and suitable
timecscale. 
• Important to have regard to priority of issue and capacity of officers.
• Anticipated that numbers of such reports around 3 in any given year.
• Opportunity to review effectiveness at annual review of constitutional
documents.   
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Report to: Audit and Scrutiny
Committee
Meeting Date: 18 June 2026      
Report by: Executive Director Finance, Strategy and Transformation    
Author: Jamie Fraser Contact Email: jamie.fraser@moray.gov.uk 
Subject: Grant Thornton – Audit progress report and sector updates 
1.  PURPOSE 
☒ For Decision      ☐  For Information 
1.1  The purpose of this report is to inform the Committee of the progress of the Council’s
External Auditor on delivering their responsibilities.  
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  Grant Thornton, the Council’s External Auditor, has provided an audit progress report and
a local government sector update (Appendix 1). The report outlines progress against their
audit responsibilities and highlights a number of emerging sector issues for the
Committee’s consideration. 
3.  RECOMMENDATIONS  
3.1  It is recommended that the Committee review and note the audit progress report and
sector updates.   
Jamie Fraser
Chief Financial Officer 
4.  BACKGROUND AND CONTEXT  
4.1  Grant Thornton has produced an audit progress and local government sector update
report. The report outlines progress to date on the 2025/26 audit deliverables, with all
planned work to date being complete. This includes both the issuing of the Audit Plan and
the completion of the Thematic Review.
Item 16.
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4.2  Sector updates include an up-to-date summary of emerging national issues and
developments. 
5.  PROPOSALS  
5.1  It is proposed that the Committee review and note the audit progress report report and
sector updates.  
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 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 
None arising directly from this report.  
6.4  Financial
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Whilst the details of the auditor update relate to key financial processes, there are no
financial impacts arising directly from this report. 
6.5  Risk 
None arising directly from this report.  
6.6  Staffing 
None arising directly from this report.  
6.7  Best Value and Transformation 
None arising directly from this report.  
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 the Corporate Leadership Team.  
8.  BACKGROUND PAPERS  
8.1  Held within Accountancy section.   
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Moray Council
Audit progress report and sector updates
22 May 2026
APPENDIX 1
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Content
1 Introduction 03
2 Progress as at May 2026 04
3 Audit deliverables 05
4 Sector updates 06
Audit Progress & Sector Updates 2
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Introduction
Angela Pieri
Engagement Leader
T: 0141 223 0887
E: Angela.L.Pieri@uk.gt.com
Andrew Wallace
Senior Manager
T: 0141 223 2671
E: Andrew.D.Wallace@uk.gt.com
This paper provides the Audit and Scrutiny Committee with a report on progress in delivering our responsibilities as your
external auditors.
The paper also includes a series of sector updates in respect of emerging issues which the Committee may wish to consider.
Members of the Audit and Scrutiny Committee can find further useful material on our website, where we have a section
dedicated to our work in the public sector. Here you can download copies of our publications:
Local government | Grant Thornton
If you would like further information on any items in this briefing or would like to register with Grant Thornton to receive
regular email updates on issues that are of interest to you, please contact either your Engagement Lead or Engagement
Manager.
Audit Progress & Sector Updates 3
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Progress as at May 2026
Financial Statements Audit
We undertook our initial planning for the 2025/26 audit in February and March
and presented our audit plan to the Audit and Scrutiny Committee in March
2026.
We have shared our initial year-end audit request list with management, and
early engagement has been sought with management around timescales for
return.
Our audit fieldwork is scheduled to commence at the end of June 2026. We aim
to complete our testing of in-year transactions and closing balances by the end
of August 2026, with reporting to the full Council scheduled in September 2026.
As outlined in our audit plan, the risks requiring special audit consideration and
procedures to address the likelihood of a material financial statement error have
been identified as management override of control, the valuation of land;
buildings and council dwellings; and the valuation of defined benefit pension
scheme. We have rebutted the presumed significant risks relating to fraud in
expenditure and revenue recognition.
At this stage, there are no other financial statement audit matters to bring to
your attention.
Thematic Review and Best Value Reports
Best Value Thematic for 2025/26 is on Asset Management. The engagement
team met the Council in early January to discuss the thematic and asked the
Council to complete the evidence gathering documents prepared by Audit
Scotland. A response was subsequently provided in mid-February, and the
engagement team completed the work in March 2026.
In April, the engagement team met with management to discuss our findings and a
draft report was shared with the Council. Following comment, the report has been
finalised and is included with the agenda for the Audit and Scrutiny Committee in
June 2026.
Meetings
Since commencement of our work in respect of the audit year 2025/26, we have met
with the Chief Executive and Corporate Leadership Team. Regular meetings have
been held with the Chief Financial Officer, and we will continue to do during the
financial statements audit.  We have also met with the Executive Director of Finance,
Strategy and Transformation as well as the Monitoring Officer and Internal Audit.
Lastly, regular meetings have been held between the engagement team and finance
personnel.
Audit Fees
Audit Scotland published their expected fees for 2025/26: Audit appointments |
Audit Scotland and Expected Fees 2025/26.
Our estimate of the audit fees we will charge for the entity, as set out within our
annual audit plan, presented to the Audit and Scrutiny Committee in March 2026 is
£326,310.
Events
We also recently held two Local Government Accounts webinars for preparers of
accounts on 5th and 11th February 2026, where we discussed a range of topics for
preparing the 2025/26 statements of accounts.
We also invite you to attend a webinar on local government audit committee
effectiveness on 2 July as set out on page 9. Audit Progress & Sector Updates 4
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Audit Progress & Sector Updates 5
Audit Deliverables
Below are some of the audit deliverables planned for 2025/26
2025/26 Deliverables Planned Date Status
Audit Plan
We are required to issue a detailed audit plan to the Audit and Scrutiny Committee setting out our
proposed approach in order to give an opinion on the body’s 2025/26 financial statements. This was
included as an agenda item at the March 2026 Audit and Scrutiny Committee.
March 2026 Complete
Thematic Review
The 2025/26 thematic review subject is asset management. This is included as an agenda item at the
June 2026 Audit and Scrutiny Committee June 2026 Complete
Annual Audit (ISA 260) Report
The Annual Audit Report will be reported to the Audit and Scrutiny Committee in September 2026. This
report communicates the key outputs of the audit, including our findings and conclusions in relation to
the financial statement audit and in relation to our work on wider scope and best value.
September 2026 Not Yet Due
Auditor’s Report
This includes the opinion on your financial statements. September 2026 Not Yet Due
Non-Domestic Rates Certification
This is the assurance review we conduct of statutory returns to the Scottish Government based on
agreed upon procedures to confirm accuracy, completeness and compliance.
October 2026 Not Yet Due
Housing Benefit Subsidy
This is the report we submit to the Department or Work and Pensions based upon the mandated
agreed upon procedures we are required to perform.
November 2026 Not Yet Due
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Sector Updates
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Sector Update
The pandemic has brought the biggest challenges in a generation to the public
sector. Getting the insight and strategic support you need will be vital.
Government and public services need to deliver change – without sacrificing
service quality and while saving costs.
Priorities like spreading economic growth more evenly takes both sophisticated
and localised insight. Delivering the infrastructure to tackle climate change
calls for deeper relationships between experts and government. And more
unified approaches may be needed to improve outcomes across the sector.
Our sector update provides you with an up-to-date summary of emerging
national issues and developments to support you. We cover areas which may
have an impact on your organisation, and the public sector as a whole. Links are
provided to the detailed report/briefing to allow you to delve further and find out
more.
Our public sector team at Grant Thornton also undertake research on service
and technical issues. We will bring you the latest research publications in this
update. We also include areas of potential interest to start conversations within
the organisation and with Audit and Scrutiny Committee members, as well as
any accounting and regulatory updates.
More information and insight can be found on the dedicated
Public Sector sections of the Grant Thornton website:
Audit Progress & Sector Updates 7
• Grant Thornton publications
• Insights from sector specialists
• Accounting and regulatory updates
Public Sector
Public Sector
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Public Sector Finance Leaders’ Barometer
Audit and Scrutiny Committee members can obtain new analysis of the issues
public sector finance leaders across the UK most prioritise, and how it might
affect their organisation here:
The Public Sector Finance Leaders Barometer | Grant Thornton
Note:
We acknowledge that the data collation for the output is focussed on local
government in England. Nonetheless, the key priorities and themes identified are
relevant to Scotland also.
Background:
Grant Thornton’s 2026 Public Sector Finance Leader’s Barometer draws on the
views of 100 s151 officers across local government in England to identify the top
three strategic priorities, operational pressures and in-demand skills for public
sector finance this year.
84% of those interviewed were confident that their medium-term financial
strategies will hold, but there was consensus that the biggest risks those
strategies face are largely outside the s151 officer’s control: Growth in demand
for statutory services; unfunded policy changes; and failure to deliver change
programmes.
These risks highlight the need for better demand modelling, earlier horizon
scanning, and disciplined delivery of change programmes. However, workforce
shortages, recruitment challenges, and increasing complexity, mean there’s
simply not enough capacity to deliver transformation at the required pace.
Audit Progress & Sector Updates 8
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Webinar: Effective audit committees in local government
Key information
Effective audit committees in local
government – Webinar
Date: 02 July 2026
Time: 4.00PM – 5:30 PM BST
Speakers: Paul Dosset, Partner & Head of
Local Government Audit
To register your place, following the link:
Effective audit committees in local
government | Grant Thornton
9
Supporting high-quality 2025/26 accounts
We are delighted to invite members to our webinar focusing on what makes an Audit
Committee and its members, effective.
Audit Committees play a pivotal role in safeguarding governance in the local government
sector. The May 2026 election results mean that many Committees will now require a
change in membership. Further, the scale or risk that Audit Committees oversee, and their
likely future remit, is also changing.
An effective Audit Committee can be the gatekeeper for standards and compliance; and
the guard against weakness in arrangements. Beyond compliance, the Committee also
holds an important role in promoting and developing an effective corporate culture – on
matters such as risk management; financial management; and on an authority’s wider
commitments to good governance.
Audit Committee members need to continually distil, and independently challenge,
information from internal and external auditors; the monitoring officer; senior leaders;
service lines; and sometimes other third parties.
Our webinar will examine the roles and responsibilities of the Audit Committee Chair and
members; the systems, structures and behaviours they need to perform as an effective
Committee; the importance of self-assessment; and the resources available for support.
Audit Progress & Sector Updates
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Audit Readiness Training
Key Benefits
Build lasting capability
Equip teams with the skills and confidence to
manage audits effectively, now and in the future.
Share knowledge, not just answers
Designed to transfer expertise so teams
understands the ‘why’ behind best practice.
Upskill your people
Helps every team member grow their technical
understanding and strengthen collaboration.
Flexible learning that fits any schedule
Access training when it works for users, making it
easy to build into existing workloads.
Improve outcomes and efficiency
Reduce audit queries, avoid delays, and
strengthen relationships through proactive
preparation.
10
Supporting high-quality 2025/26 accounts
We’ve developed CPD-accredited online training to
support audit teams in applying evolving standards
in practice — strengthening technical confidence,
improving audit documentation, and supporting
more predictable and transparent audit delivery for
Audit Committees.
What’s included?
The Audit Readiness training is delivered through a
90-minute online training session built around seven
learning modules;
• Foundations of Audit
• Planning for Audit Success
• Data and Documentation Management
• Complex areas of the audit
• Internal Controls & Risk Management
• Communication & Collaboration
• Hot Topics
Each module includes a knowledge test assessment,
key takeaways and where applicable downloadable
resources to support ongoing learning.
Audit Progress & Sector Updates
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CIPFA Code changes to the accounting for non-
investment assets
Changes introduced in the 2025/26 Code:
The 2025/26 CIPFA Code introduces substantial changes arising from the HM
Treasury Thematic Review on Non-investment assets, and the requirement to
keep the valuations of certain assets up to date:
❖ The introduction of a valuation expedient requiring valuations once every five
years or on a five-year rolling basis, in each case supported by indexation in
intervening years; and
❖ The Code requires the use of the best available indices and, where no index is
available, a desktop valuation is undertaken in year three.
The following asset classes are affected by the change:
❖ Other land and buildings;
❖ Vehicles, plant, furniture and equipment (where carried at current value);
❖ Surplus assets; and
❖ Right of use assets measured at current value
Assets which are not in scope of the changes include council dwellings; vehicles;
plant and equipment carried at depreciated historical cost as a proxy for current
value; infrastructure; assets under construction; heritage assets; assets held for
sale; intangible assets; and community assets carried at cost.
Why Indexation is important:
Indexation is a new requirement in the Code, intended to provide a reasonable
estimate of how market values have changed, rather than an exact valuation. A
range of indices are available, and authorities will need to exercise and be
prepared to explain their judgements on which indices are the most appropriate
to apply across their asset base. Authorities may apply indexation to 31st March
2025 carrying values, providing the assumption that existing carrying values
are true and fair is valid. Where valuations are required, they must be
undertaken at least once every five-years or when there are indicators of
impairment.
Audit and Scrutiny Committee can help by asking:
❖ Have we sought advice from an expert valuer on which indices are most
appropriate for our various assets within scope of indexation?
❖ Have we documented our rationale regarding why we select/reject or deem
there to be no indices?
❖ How has indexation been calculated/ applied in underlying records/ asset
systems?
❖ Have we ensured that asset records distinguish between revaluation versus
indexation, so that we have a clear record of when valuations are due and
when valuations were last carried out?
Audit Progress & Sector Updates 11
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Local government funding and spending review
Key information for Audit and Scrutiny Committee to be aware of:
On 14 January 2026, the Scottish Government issued Local Government
Finance Circular 01/2026, setting out the provisional 2026/27 revenue and
capital funding settlement for councils.
These provisional total funding allocations form the basis of the annual
consultation between the Scottish Government and COSLA ahead of the Local
Government Finance (Scotland) Order 2026 being presented to the Scottish
Parliament.
Subsequently, in March 2026, the Scottish Ministers approved the Local
Government Finance (Scotland) Order 2026 which confirmed the levels of
Revenue Support Grant and Non-Domestic Rate income allocated to each local
authority. The levels of each allocated to Moray Council have been noted in the
adjacent table.
Audit and Scrutiny Committee can help by asking: What does the finance
settlement mean for the entity? How are we mitigating any losses? How are we
planning for best value from gains?
The 2026/27 allocations made by the Scottish Government to Moray Council,
alongside the previous two financial years is outlined below:
*Revenue Support Grant is as stated in the Local Government Finance (Scotland) Order 2026.
The Scottish Spending Review 2026 (January 2026):
Alongside the 2026/27 Draft Budget, the Scottish Government published the
Scottish Spending Review 2026, which sets out indicative multi-year funding
plans for revenue expenditure to 2028/29 and capital expenditure to 2029/30.
The Review outlines projected funding trajectories for local government
alongside other portfolios; however, it does not provide council-level allocations
and should be viewed as a high-level planning framework rather than a final
funding settlement.
The Review indicates that all core elements of Scottish Government funding to
local authorities are expected to decline in real terms over the spending review
period. Both revenue and capital funding are projected to reduce between
2026/27 and 2028/29, compounding existing cost pressures and increasing the
medium-term financial risk faced by councils. This outlook reinforces the
challenge for local authorities in maintaining service delivery and financial
sustainability, particularly in the context of rising demand, inflationary
pressures, and limited local fiscal flexibility.
The Scottish Spending Review 2026
Audit Progress & Sector Updates 12
2025/26* 2026/27
Revenue Support Grant £179.8m £177.1m
Non-Domestic Rates Income £58.0 £66.4m
Total £237.8m £243.5m
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Accounts Commission – Report Publications
Delivering for the future – Transformation: How councils are redesigning and delivering more efficient services (May 2026):
Since 2022, auditors have undertaken Best Value audit work alongside annual audit work at Scottish Councils. Local transformation was the theme audited
alongside the 2024/25 annual audit work and the findings were set out in a management report to each council. The report draws on the findings of the 22
management reports available at the time of drafting.
Ultimately, Scotland’s councils need greater ambition to redesign services, with financial pressures growing and demand continuing to rise. Although Councils have
been changing the way they work and deliver services for years, making significant savings. Now the scale and pace of change must shift to match the challenges
ahead, helping to secure financial sustainability and meet increasing demand.
The report assesses the progress across local authorities with prioritising and progressing the delivery of their local transformation ambitions, as well as their
engagement in sector-led transformation activity. Overall, the report finds that progress across the sector has been mixed and asks Councils to reflect on messages
in the 2024 report, ‘Transformation in Councils’ and ensure they have effective arrangements in place.
Delivering for the future – Transformation: How councils are redesigning and delivering more efficient services
Local government in Scotland: Financial bulletin 2024/25 (January 2026):
In its latest update on council finances, the Accounts Commission report that councils face a budget gap of nearly £1 billion by 2027. In 2024/25, councils met 90 per
cent of their savings targets. But for the first time in six years, reported a collective overspend on the costs of delivering services. Debt levels are increasing. Many are
relying on reserves. Whilst councils are increasing the amount of money they raise through fees and charges, income generated isn’t keeping pace with rising costs
and inflation. With Scottish Government funding to deliver capital projects falling, councils are also taking on more debt to deliver local infrastructure projects such
as building schools and housing.
Included within the financial bulletin is the reintroduction of a checklist for elected members. It is increasingly important that elected members understand the
financial pressures facing their own councils, and the impact these may have on future priorities and service delivery. The checklist includes a range of questions to
consider that are linked to the content of this report. It is designed to support elected members in scrutinising and understanding how well their council is working,
exploring how well the council collaborates with other councils, communities and wider partners to change the way it delivers services within a very challenging
financial context.
Local government in Scotland: Financial bulletin 2024/25
Checklist for elected members
Audit Progress & Sector Updates 13
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Audit Commission – Report Publications (2)
The Scottish Budget 2026/27: Supplement to the Financial bulletin 2024/25 (February 2026)
This supplement to Local government in Scotland: Financial bulletin 2024/25 sets out an analysis of the recently published 2026/27 Scottish Budget and the draft
financial settlement for local government. At the point of issue, both were subject to parliamentary scrutiny as part of the budget process.
Fundamentally, despite a funding increase in 2026/27, councils will continue to face significant challenges in remaining financially sustainable over the medium term
as demands rise and costs increase. Furthermore, funding from the Scottish Government to 2028/29 is projected to fall in real terms, challenging councils to consider
and implement the measures necessary to ensure the ongoing delivery of services.
Supplement to the Financial bulletin 2024/25: The 2026/27 Scottish budget
Integration Joint Boards: Finance bulletin 2024/25 (February 2026)
Integration Joint Boards (IJBs), together with their NHS and council partners, must urgently take decisions on where to redesign, reduce or discontinue services. 
Funding to Scotland’s 30 IJBs increased by over two per cent in 2024/25 to more than £12 billion. But this was insufficient to meet rising costs and demands, with
many IJBs using dwindling reserves to help meet the almost £450 million gap between demand and available funding. This is not sustainable.
Increasing demand, rising costs and a growing number of people with long-term complex needs are placing mounting financial pressures on IJBs. The boards have
reached a critical point, with a significant risk they will become financially unsustainable within the next 12 to 24 months.
Alongside savings and using reserves, IJBs have been relying on substantial additional funding from their partners in the NHS and councils. IJBs need to plan their
finances more realistically to reduce this reliance, as health boards and councils face their own significant financial pressures.
Integration Joint Boards: Financial bulletin 2024/25
Audit Progress & Sector Updates 14
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Audit Scotland and Accounts Commission – Report Publications
Annual Assurance and Risk Reports (March 2026):
The Annual Assurance and Risks Report is an annual report by the Controller of Audit to the Accounts Commission, made public for the first time since 2021. It brings
together a wealth of evidence from annual audit reporting. This report highlights recurring themes across 2024/25 audits, helping support individual bodies and the
wider sector plan and deliver improvements.
Alongside wider audit intelligence, it also helps inform the Accounts Commission’s selection of a Best Value theme for 2026/27. Previous themes covered how councils
are responding to workforce challenges, why leadership matters and a report on how councils are redesigning and delivering more efficient services will be published
in spring/summer 2026.
Annual Assurance and Risks Report: A review of 2024/25 local government audits in Scotland
Audit Progress & Sector Updates 15
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Audit Scotland – Report Publications
Public audit in Scotland: Interim evaluation (December 2025):
Public audit in Scotland is the shared statement of purpose between the Auditor General, the Accounts Commission and Audit Scotland. Published in 2023, it sets out
the vision and mission, and the outcomes intended to be achieved for Scotland’s people.
We are at the halfway point of Public audit in Scotland’s five-year lifespan. This mid-term evaluation looks at progress so far in achieving the intended outcomes,
and in driving the mission and vision. It also considers how well performance is recorded and monitored, and areas for improvement. The evaluation is supported with
case studies throughout.
The interim evaluation sets out recommendations for Audit Scotland to improve both its audit work and its evaluation approach. In 2027, a final evaluation will be
carried out of progress which will be reported publicly.
Public audit in Scotland: Interim evaluation
Transforming the approach to climate change: Lessons from public audit (March 2026):
Independent public audit has an important function in assuring people about how the Scottish public sector is responding to the climate emergency and how public
money is being used to help achieve Scotland’s climate change ambitions.
This latest report brings together learning from across four years of reporting on climate change.
Transforming the approach to climate change: Lessons from public audit
Audit Progress & Sector Updates 16
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Audit Scotland – Best Value Reports
Best Value Reports
Best Value is about ensuring that there is good governance and effective management of resources, with a focus on improvement, to deliver the best possible
outcomes for the public. The duty of Best Value applies to all public bodies in Scotland. It is a statutory duty for local authorities, such as councils. It is a formal duty
for the Scottish Police Authority and Chief Constable, the Scottish Fire & Rescue Authority and Chief Fire Officer and in the rest of the public sector it is a formal duty
on Accountable Officers, such as the chief executives of NHS bodies or of further education colleges.
In 2023, Audit Scotland began a new approach to auditing Best Value in Scottish councils. The new approach continues to audit against the statutory duty but is
now fully integrated with the annual audit at each Council. It also includes detailed work each year, focusing on a theme across all of the councils, which will be
collated into a national report.
A number of best value reports have been released during 2026 which may be of interest to members, as outlined below:
Best Value: North Lanarkshire Council – January 2026
Best Value: Shetland Islands Council – March 2026
Best Value: Aberdeenshire Council – March 2026
Audit Progress & Sector Updates 17
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Audit Scotland – Draft Code of Audit Practice
Draft Code of Audit Practice
Audit Scotland launched a consultation on the draft new Code of Audit Practice, inviting views from the public, audit providers, public bodies and other interested
parties. The consultation, undertaken on behalf of the Auditor General for Scotland and the Accounts Commission, ran until Friday 27 March.
We engaged with the consultation process and submitted a formal response, providing considered comments on the proposals set out in the draft Code. The new
Code will apply from the 2027/28 financial year.
Consultation on Code of Audit Practice 2026 | Audit Scotland
Audit Progress & Sector Updates 18
Draft Code of Audit Practice Consultation on new Code of Audit Practice
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Audit and Scrutiny Committee resources
Grant Thornton learning on procurement and contract management:
Local government procurement and contract management
Audit Committee and organisational effectiveness in local authorities (CIPFA):
https://www.cipfa.org/services/support-for-audit-committees/local-authority-
audit-committees
CIPFA Application Note: Global Internal Audit Standards in the UK Public Sector
Global Internal Audit Standards in the UK Public Sector | CIPFA
CIPFA Good Governance
Delivering Good Governance in Local Government Addendum
The Three Lines of Defence Model (IAA)
https://www.theiia.org/globalassets/documents/resources/the-iias-three-lines-
model-an-update-of-the-three-lines-of-defense-july-2020/three-lines-model-
updated-english.pdf
Risk Management Guidance / The Orange Book (UK Government):
https://www.gov.uk/government/publications/orange-book
Audit Progress & Sector Updates 19
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2
0
© 2026 Grant Thornton UK LLP. All rights reserved.
‘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 UK LLP is a member
firm of Grant Thornton International Ltd (GTIL). 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.
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1   
Report to: Audit and Scrutiny
Committee
Meeting Date: 18 June 2026     
Report by: Chief Executive Report No: 
Author: Atholl Scott Contact Email: atholl.scott@moray.gov.uk 
Subject:  Annual Governance Statement 
1. PURPOSE 
☒ For Decision      ☐  For Information 
1.1 This report provides Committee with a copy of the Council’s Annual Governance
Statement for 2025/26 for review and approval. 
1.2 This report is submitted to Committee in terms of Section III (I) (5) of the Council’s Scheme
of Administration relating to supporting the Council’s governance arrangements through
review of the Annual Governance Statement. 
2. SUMMARY  
2.1 The Annual Governance Statement is a mandatory requirement for local government
bodies and is published by the Council alongside its annual accounts. This report includes
a copy of the draft Annual Governance Statement and is presented to the Committee for
scrutiny before the document is finalised for inclusion in the audited annual accounts. 
3. RECOMMENDATIONS  
3.1 It is recommended that Committee scrutinise the draft Annual Governance
Statement provided as Appendix 1.   
Atholl Scott 
Business Continuity & Risk Management Officer 
4. BACKGROUND AND CONTEXT  
Item 17.
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2 
4.1 The function of good governance in the public sector ensures that entities act in the public
interest at all times. Governance comprises the arrangements put in place to ensure
intended outcomes are defined and achieved.  
4.2 The Chartered Institute of Public Finance and Accountancy (CIPFA) and the Society of
Local Authority Chief Executives (SOLACE), building on work undertaken by the
International Federation of Accountants, have published a guidance framework on
‘Delivering Good Governance in Local Government’.  
4.3 The Local Authority Accounts (Scotland) Regulations 2014 requires the Council to publish
an Annual Governance Statement with its annual accounts. The Statement is based on the
guidance and summarises practice across the seven principles identified within the
framework, considers the roles of those who oversee the development and operation of
such practice, and provides an overall assessment of the effectiveness of governance
arrangements. The statement includes the annual opinion provided by the Service
Manager - Internal Audit and Risk in line with Global Internal Audit Standards.  
4.4 Good governance practice involves both elected members and officers and this is
reflected in the requirement for the statement to be certified by both the Leader of the
Council and the Chief Executive as Head of Paid Service.  
4.5 The statement is subject to review by external audit, where the external auditor is required
to report on anything believed to be inconsistent with any other findings disclosed from
the audit work completed. There has been nothing to report in this regard in previous
annual audits. 
5. PROPOSALS  
5.1 This report provides Committee with a copy of the draft 2025/26 Annual Governance
Statement, which has been produced following completion of the annual review of the
Council’s governance arrangements and system of internal control. 
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  ×
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3 
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))
Governance refers to how organisations are managed and controlled. Effective
governance is key to the delivery of the strategic priorities promoted in Community and
Council strategic plans. 
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 Annual Governance Statement forms part of the annual accounts the Council is
required to prepare under statute.  
6.4 Financial 
No implications directly arising from this report. 
6.5 Risk 
Good governance includes the effective management of risk, as evidenced in this ‘risk
implications’ paragraph in all reports that come before the Council and its
committees, and in the Council’s corporate risk register that is kept under review by
Senior Management and reported at agreed intervals to the Corporate Committee.  
6.6 Staffing 
No implications directly arising from this report.  
6.7 Best Value and Transformation 
The Council’s Annual Governance Statement is prepared in accordance with the
CIPFA/SOLACE ‘Delivering Good Governance in Local Government’ Framework and is key
to ensuring the delivery of the council’s strategic priorities.  
6.8 Property 
No implications directly arising from this report.
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4 
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 Corporate Leadership Team, Heads of Services and the Service Manager –
Internal Audit and Risk have been consulted and contributed to the content of the
Annual Governance Statement. 
8. BACKGROUND PAPERS  
8.1 None   
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APPENDIX 1
1
Moray Council
Annual Governance Statement
2025/26 
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2 
Table of Contents 
1. Scope of Responsibility
2. Framework for Good Governance
3. Review of the Adequacy and Effectiveness of the
Council’s Governance Arrangements
4. Overall Assessment of the Effectiveness of Governance
Arrangements
5. Significant governance issues
6. Concluding Remarks 
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3 
1. Scope of Responsibility 
The council is responsible for ensuring its business is conducted in accordance
with the law and proper standards, and that public money is safeguarded,
properly accounted for, and used economically, efficiently and effectively. The
council has a statutory duty to make arrangements to secure Best Value under
the Local Government in Scotland Act 2003. 
In discharging these responsibilities, elected members and the corporate
leadership teams are responsible for putting in place proper arrangements for
the governance of the council’s affairs and for facilitating the effective exercise
of its functions. In delivering these functions, there is a requirement to maintain
effective partnership working with others, principally with NHS Grampian and
the Moray Integration Joint Board, Grampian Valuation Joint Board, tsi Moray,
and the Moray Leisure Centre, as well as with other bodies involved in
Community Planning and in the delivery of projects forming part of the Moray
Growth Deal. 
This annual governance statement, which covers the period from 1 April 2025
through to the date of signing of these annual accounts, explains how the
council has used the CIPFA/SOLACE 2016 Framework ‘Delivering Good
Governance in Local Government’ as a basis for considering the effectiveness of
its own governance arrangements.
2. Framework for Good Governance 
The overall aim of the ‘Delivering Good Governance in Local Government’
Framework is to ensure that: resources are directed in accordance with agreed
policy and according to priorities; there is sound and inclusive decision making;
and there is clear accountability for the use of those resources in order to
achieve desired outcomes for service users and communities. 
The key elements of the council’s governance arrangements are described in
terms of the seven principles defined in the Framework, summarised as follows: 
2.1  Behaving with integrity, demonstrating strong commitment to
ethical values, and respecting the rule of law; 
The roles and responsibilities of elected members and senior officers and the
processes to govern the conduct of the council’s business are defined in
procedural Standing Orders, a Scheme of Administration, a Scheme of
Delegation, and Financial Regulations. These are updated annually following
consideration and review of changes necessary for the effective functioning of
the council’s affairs. These changes are prompted by new legislative
requirements, organisational change, audit recommendations, and incorporate
identified revisions necessary to improve governance practice. 
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4 
Supplementary (second tier) documents providing additional guidance on
specific constitutional matters are also maintained and are subject to periodic
review and updating as appropriate. 
Codes of Conduct for both elected members and officers are in place, and these
define the ethical values and standards of behaviour expected. The Codes draw
on the ‘Standards in Public Life’ covering issues including leadership, fairness
and integrity. Refresher training on the Code of Conduct for elected members
was delivered in conjunction with the Improvement Service. No referrals in
respect of inappropriate conduct were made to the Standards Commission
during the year.
The council’s Chief Governance Officer is the designated Monitoring Officer
responsible for ensuring that agreed procedures are followed and that all
applicable statutes and regulations are complied with. 
2.2  Ensuring openness and comprehensive stakeholder engagement;
Meetings of the council and its committees are delivered using a hybrid format
that enables attendance in person or via web link. These are live streamed and
available for public viewing, with matters discussed and determined in
confidence relating only to those deemed confidential in terms of Part 1 of
Schedule 7A of the Local Government (Scotland) Act 1973. The rationale for all
decisions proposed and taken is fully set out in committee reports. 
Stakeholder engagement is central to the council’s work at a strategic level,
notably  informing the preparation of the annual budget, and on  multiple issues
including climate, planning, housing, education, and transportation. A new
engagement portal has been commissioned – Moray Engage – and work is
underway to develop an Engagement and Consultation Strategy, including
guidance developed by young people on how best to engage with young people.
Once approved, the strategy will provide additional tools and training to help
ensure Moray's citizens are appropriately involved in decision-making
processes.
A programme of employee engagement is also ongoing to support organisational
change ensuring staff have opportunities to influence future service delivery
models and contribute to the development of organisational priorities.
Constructive engagement continues with recognised Trades unions including
work to develop a refreshed partnership agreement that supports meaningful
consultation and collaborative working on workforce and organisational
matters. 
The council also seeks and obtains feedback on delivery of its services having
adopted a comprehensive complaints procedure based on a model scheme
developed by the Office of the Scottish Public Services Ombudsman. All
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5 
complaints are responded to as appropriate and inform improvements to
service delivery. A comprehensive report on complaints handling is prepared
and presented annually to a council committee. 
2.3  Defining outcomes in terms of sustainable economic, social, and
environmental benefits;
The creation and implementation of a vision for the local area, including
expected outcomes for the community, is encompassed in the Local Outcomes
Improvement Plan (LOIP). The overarching aim and purpose of this 10-year Plan
is ‘to raise aspirations by creating an enabling environment where our residents
can achieve expanded choices, improved livelihoods and wellbeing”. 
In particular, the LOIP recognises the importance of and benefits from reducing
inequalities and poverty, with outcomes focused on the need for a growing,
diverse and sustainable economy, building a better future for our children and
young people in Moray, empowering and connecting communities, and
improving the wellbeing of our population. 
The LOIP is a partnership plan, and its strategic delivery is overseen by a
Community Planning Board, which meets quarterly. The Board comprises
representatives from a broad range of organisations as reflected in agenda items
considered during the year. These included reports on School Age Childcare,
Poverty, Digital Engagement, Economic Development  and Health and
Transportation Plans. The Board also received an annual report on progress on
delivery of the multi-agency Children’s Services Plan. 
Currently the LOIP sits alongside the Corporate Plan Moray 2024-2029, the latter
setting out the vision and priorities of the council for a five year period. The
council plan details  council priorities focussing on three key themes: tackling
poverty and inequality, building a stronger greener vibrant economy, and seeking
to build thriving, resilient, empowered communities. The plan sets targets for
outcomes consistent with maintaining a sustainable council that provides
valued services to its communities. An annual report detailing progress achieved
is prepared and presented to a meeting of the council and a delivery framework
has also been prepared to support implementation and monitoring of the plan
through to its conclusion. 
The period also saw the council implement measures aligned to its Sustainable
Development Statement, reporting on progress achieved and planned in a 2026
update of its Climate Change Strategy and Route Map to Net Zero. 
2.4  Determining the interventions necessary to optimise the
achievement of the intended outcomes; 
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6 
The strategic partnership and corporate plans are translated into service plans
prepared within each council service area. These facilitate delivery of agreed
outcomes and assist in securing continuous improvement. Service plans are
reported to a meeting of the council or appropriate service committee for
consideration and approval, in reports that provide information on planned
activity. More generally, all committee reports contain a ‘Summary of
Implications’ section that links report content to strategic plans, legal and policy
issues; financial implications, risk, staffing and property matters; equalities;
social impact; and climate change and biodiversity considerations. The format
of these reports, recently updated based on advice from the Improvement
Service, remains under review to ensure optimal levels of information are
available to decision makers. A particular focus continues to be given to
financial implications of any proposals given the current economic climate.
The council is fully aware of the financial challenges it faces, and elected
members are provided with an extensive volume of information on both the
availability of resources and options for future service delivery. This has been
made available during workshops for elected members; in reports to the council
on budget setting, including projections for the medium to longer term; and in
regular budget monitoring reports covering both capital and revenue expenditure
submitted to service committees. A formal budget protocol sets a framework of
engagement and consultation to support the process, including engagement
with Trade Union Members through the Joint Consultative Forum. 
A balanced budget was again achieved for 2026/27 through a combination of an
improved financial settlement from Scottish Government, an increase in Council
Tax, and savings delivered in line with the council’s short to medium term
financial strategy. A number of unknowns including impacts of inflation and
geopolitical events  were highlighted during the budget setting process, as were
continued pressures in respect of the council’s funding obligations to the Moray
Integration Joint Board. Longer term financial planning projections note that
further council tax rises and additional savings will be required going forward,
and progressing the approved  transformation strategy remains key to  delivery of
these savings. Regular reports on transformation projects progressed have been
presented to the council during the period covered by this statement. 
The achievement of agreed outcomes is monitored through an established
Performance Management Framework that calls for frequent reporting on key
performance measures developed for each service. In addition, the council
participates in the Local Government Benchmarking Framework which
compares a range of established performance measures with those of other
Scottish local authorities. Service Committees are provided with reports to
review, scrutinise and note actions undertaken by services to meet performance
objectives. An illustrated annual Public Performance Report is prepared and
published to demonstrate the outcomes and achievements of the council during
the year.
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2.5  Developing the entity’s capacity, including the capability of its
leadership and the individuals within it;
Senior management capacity was reviewed during 2024/25, and the council
approved a revised senior management structure in April 2025. The revised
structure was designed to strengthen leadership capacity, with the appointment
of an additional Executive Director and consequential reallocation of duties and
responsibilities for other Directors in post. Roles of Heads of Services were also
reviewed and, in some instances, revised, to optimise service direction and
oversight. Actions required from this review process included the recruitment to
a number of vacant posts within the new structure. This work was progressed
during the period, and all senior management posts have now been filled.
More broadly, leadership capacity is supported through the promotion of a
Leadership Forum, which brings together senior managers from all services to
provide a wider perspective to the consideration of issues facing the council.
Forum meetings ensure consistent messaging is available from senior
management to managers. Organisational Development continues to review
and refine workforce development opportunities, including on leadership
development, and training opportunities are available for all staff, online and in-
person, on corporate issues including data protection and cyber security. As the
council moves to phase 2 in the restructuring process, external support will aid
council-wide engagement to develop a set of employment values, and
engagement has begun to determine the form and content of  future
management training and leadership programmes.
Workforce planning activity is being undertaken to ensure the Council has the
capacity, skills and workforce profile required to deliver future service priorities.
This includes succession planning, recruitment and retention initiatives,
workforce data analysis and consideration of future workforce requirements
arising from service transformation.
The council has an agreed elected members’ development strategy that
includes an on-going training programme of learning, development and
briefings. Members appointed to certain committees also receive specific
training related to the responsibilities of these committees. A Strategic
Leadership Forum involving both elected members and senior officers facilitates
collaborative cross-party discussions on the future direction of council services.
Senior Officers also meet regularly with Chairs of the council and its
committees.
In addition, elected members represent the council on a range of outside
bodies, including on boards of other Community Planning partners, across
partnership bodies such as the Moray Economic Partnership, various national
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bodies such as COSLA and its themed Boards, and a broad range of charitable
and third sector organisations. This representation provides valuable learning
and networking opportunities for those members. 
2.6  Managing risks and performance through robust internal control
and strong public financial management; 
The council has a risk management policy designed to support the identification,
evaluation and mitigation of risks that may impact on its ability to meet its
objectives. A Corporate Risk Register is maintained providing summary
information on issues the Corporate Leadership Team considers are the
principal risks facing the council. The register describes how these risks are
managed and controlled. Risk implications are detailed in all committee reports
to inform decision-making processes. The council has also developed and
approved a risk appetite statement -informed by a workshop involving elected
members and senior management –  as a further aid to guide decision making. 
The council’s system of internal control is based on a framework of financial
regulations, regular management information, administrative procedures,
management supervision and a scheme of delegation that defines
accountabilities of senior officers. An Audit and Scrutiny Committee, through its
consideration of reports by internal and external auditors, monitors the
effectiveness of the system of internal control.
Strong financial management is secured through the work of the statutory officer
appointed in terms of Section 95 of the Local Government (Scotland) Act 1973.
This role now sits with the Executive Director (Finance, Strategy and
Transformation) appointed as part of the senior management restructuring, with
the Chief Financial Officer now designated as the Depute Section 95 Officer. .
The Section 95 officer advises the Council on all financial matters and ensures
the timely production and reporting of budget estimates, budget monitoring
reports and annual accounts. Draft and audited Annual Accounts are published
on the council website. 
2.7  Implementing good practices in transparency, reporting, and
audit to deliver effective accountability;
Council business is conducted through an established cycle of webcast
committee meetings. Webcasts remain available for viewing for 12 months
following a meeting. Meeting dates are published in advance, and agenda
papers are made available at least one week before meetings take place.
Minutes of meetings are prepared, and important decisions are publicised on
the council website and through social media.
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The council’s website provides a platform from which to disseminate a wide
range of information including news items on policy decisions, guidance on
council services, and on service disruptions/interruptions arising from weather
events or similar. The website is being updated and a new Customer
Relationship Management system implemented to improve accessibility of
services, and aid consultations.  The communications team has been expanded
to support the increased volume of information dissemination and consultations
taking place.
The council responds to the findings and recommendations of Internal Audit,
External Audit, and other Scrutiny and Inspection bodies by developing
improvement Action Plans. The Audit and Scrutiny Committee is integral to
overseeing independent and objective assurance processes that make
recommendations for improvements to the system of internal control. The
Service Manager - Internal Audit and Risk facilitated a workshop with members
of the Committee to affirm compliance with good practice guidance for audit
committees published by the  Chartered Institute of Public Finance and
Accountancy (CIPFA).
A continuing focus in the period was the council’s response to the Accounts
Commission Best Value review report published in 2024. The action plan
developed in response to the Commission’s findings covering issues including
the council’s vision, leadership, effective use of resources and sustainable
development, has been progressed with regular reporting to the council’s
Corporate Committee. Ongoing monitoring continues, with all recommended
actions either well advanced or completed.
The council responds to requests for information under Freedom of Information
legislation having processed some 1500 such requests during the period
covered by this statement. 
3. Review of the Adequacy and Effectiveness of the Council’s
Governance Framework 
3.1 In assessing the effectiveness of the governance framework, including the
system of internal control, it is necessary to consider the role of the functions
and individuals who contribute to it, as follows:
•  Elected Members 
Governance arrangements at a political level emanate from the council, its
committees and from other roles that elected members fulfil. These include
participation in the Community Planning Board and associated groups for multi-
agency issues. Elected members also have substantive roles on the Moray
Integration Joint Board for Health and Social Care, the Grampian Valuation Joint
Board, and the Moray Leisure Arm’s Length External Organisation (ALEO), each of
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which has its own governance arrangements. In addition, elected members have
membership and represent Moray Council interests in partnerships that
contribute to meeting council aims and objectives, notably in the development
and delivery of projects forming part of the Moray Growth Deal or being
progressed using other ring fenced funding. Acknowledging political difference,
elected members have been encouraged to strengthen collegiate working where
possible. This has been evident during the period with improved opportunities for
informal discussion and engagement on development of policy proposals. A
follow up survey of elected members and chief officers on collaborative
leadership and working relationships identified some positive aspects as well as
opportunities to consolidate practice as the new management structure beds in. 
• Audit and Scrutiny Committee
The council has an Audit and Scrutiny Committee where elected members
consider reports on audit matters. These reports provide assurances on the
adequacy and effectiveness of the system of internal controls including those
relative to the delivery of plans, compliance with laws and regulations, accuracy
of information and safeguarding of assets. Two external members sit on the
committee to provide an independent perspective on issues under
consideration.
This committee is a key component of good governance, distinguished from
other committees by the role elected members are required to fulfil, not in
setting policy or considering service matters, but by providing independent
oversight and challenge in support of the council’s duty to secure continuous
improvement. These functions are delivered independently from the supervisory
oversight roles of the Leadership Teams. 
•     The Corporate Leadership Team 
The Chief Executive is responsible and accountable to the council for all aspects
of management including promoting sound governance, providing quality
information/support to inform decision making and scrutiny, supporting other
statutory officers, and building relationships with all elected members. 
The Corporate Leadership Team (CLT) has overarching operational responsibility
for good governance arrangements. The team was restructured during the period
and now comprises the Chief Executive, three Executive Directors, the Chief
Officer (Health and Social Care Moray), the Monitoring Officer and the Chief
Financial Officer. As reported above, the roles and responsibilities of officers
within the team have been revised and, in some cases, redesignated to
strengthen strategic leadership arrangements. 
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•   The Corporate Leadership Team / Extended Corporate Leadership Team
This is an extended management team comprising the CLT and Heads of
Services. The role and remit of this group is to support the formulation and
implementation of policies, strategies and plans to achieve local and national
outcomes, to share and promote good practice from an inter-service
perspective, to act with the wider objectives of the council in mind to ensure the
resources are effectively deployed, and to assist CLT in keeping the governance
of the council and its services under review. 
Individual Heads of Service, including the Chief Financial Officer and Monitoring
Officer, have considered the effectiveness of governance arrangements within
their respective services by reference to the principal risks identified in the
council’s Corporate Risk Register and provided assurance statements for use in
the preparation of this corporate statement. This affirms the broad ownership of
good governance and recognition of its importance within the senior leadership
of the council.
Overall, the assurance statements confirm that governance arrangements
within services are working as intended, and in support commentary has been
given on elevated risks and on mitigating actions taken in response. The main
issues raised in these returns are:
• Staffing shortages and vacancies, and their impact on capacity to deliver
change at pace in a number of service areas.
• Continuing risk of data breaches, and the response being taken by services
to mitigate these through provision of training on data security and reminder
on data security considerations when using email. 
• A need to strengthen the approach to electronic document and records
management across all services.
• Ongoing obligations on the Housing Service to monitor homelessness data
and progress electrical safety improvements in council houses in support of
national initiatives directed by the Scottish Housing Regulator.
• A need for continued focus on Health and Safety requirements thereby
protecting the workforce and minimising the number of reportable incidents.
• Further work to review revised  governance arrangements around delivery of
Additional Support Needs in Education, and to ensure these align effectively
with Children’s Services Governance Groups.
• Progressing an absence management project with the aim of reducing
teacher absence and encouraging teaching staff to relocate to Moray.
• A need to ensure consideration is given to equalities impacts in all cases
where persons or groups potentially affected have protected characteristics. 
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• The Chief Governance Officer (Monitoring Officer) / Chief Financial
Officer 
In discharging their respective responsibilities the Chief Financial Officer
complies with the governance requirements of the CIPFA Statement on the role
of the Chief Financial Officer, and the Chief Governance Officer provides an
annual information report on discharging the duties of a Monitoring Officer to a
meeting of the council. 
•   The Chief Social Work Officer 
The Head of Service, (Children and Justice Services) fulfils the statutory role of     
Chief Social Work Officer (CSWO) as part of the duties of the post. The latest
available CSWO annual report for the year to 31 March 2025 provides a
comprehensive overview of the work of the service, describing  governance and
accountability arrangements, service quality and performance, resources and
workforce, and a section on forward planning. 
The report notes that Social Work services continue to face significant pressures
from multiple factors including an ageing population, increased service demand
and ongoing workforce shortage and recruitment challenges, concluding that high
quality services continue to be delivered as a result of the commitment and
diligence of the dedicated social work and social care workforce. 
The report was the first annual report prepared by an interim appointee to the 
post of CSWO, an arrangement that has had effect since June 2024 and continued
for most of the period covered by this statement. A permanent appointment has
been made to the CSWO post recently, with the successful applicant taking up
the role in August 2026. 
• Internal Audit
The Internal Audit activity adds value to the Council by considering strategies,
objectives, and risks; offering ways to enhance governance, risk management and
control processes; and objectively providing relevant assurances.
The Service Manager - Internal Audit and Risk is accountable on a day-to-day
basis to the Chief Governance Officer and to the Audit and Scrutiny Committee.
Internal Audit applies mandatory Global Internal Audit Standards (GIAS) in
delivering the Internal Audit Service. An internal quality assessment of the service
during the year confirmed on going compliance with the GIAS.
The Council has a system of internal control designed to manage risk to a
reasonable level. Internal controls cannot eliminate the risk of failure to achieve
policies, aims and objectives and can therefore only provide reasonable and not
absolute assurance of effectiveness. 
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The internal audit plan for each  year includes a range of audit projects covering
main financial systems, other systems operating within services and several ad-
hoc/unplanned projects. The outcomes from these projects, together with any
recommendations to enhance the control environment, are reported to
management and to the Audit and Scrutiny Committee. This Committee is chaired
by an elected member who is not part of the council Administration. All planned
reviews detailed within the Annual Internal Audit Plan for 2025/26 were completed
as scheduled. 
GIAS requires an internal audit opinion to be provided annually. From the planned
audit work completed and based on this work and other knowledge of the
organisation and its control systems, it is the opinion of the Service Manager –
Internal Audit and Risk that reasonable assurance can be placed upon the
adequacy and effectiveness of the internal control environment which operated in
the council during the year.
• Health & Social Care Partnership 
The council, as a key partner of Health and Social Care Moray, has an interest in
the governance arrangements of the Moray Integration Joint Board (MIJB). This
interest relates to its financial exposure as a principal funder and its statutory
responsibilities for Social Work services and associated duties of the Chief Social
Work Officer. The Chief Officer (Health and Social Care Moray) is part of the
Corporate Leadership Team and provides regular reports on the work of the MIJB 
to meetings of the council.
Audit arrangements for the MIJB are provided jointly by the council’s Internal Audit
Service and NHS Grampian’s Internal Auditors. The council’s Service Manager –
Internal Audit and Risk (in the role of Chief Internal Auditor for the MIJB) provides
assurance over social care services, and oversight of the MIJB governance
arrangements. Relevant findings from NHS Internal audit reports are also 
considered by the MIJB.
From audit work completed in this role, the Chief Internal Auditor has provided an
opinion of only limited assurance that the Moray Integration Joint Board has
adequate systems of governance and internal control for the year ended 31st
March 2026. 
A continuing governance consideration for the council is the financial
sustainability of the MIJB, with any overspend against budget requiring to be met
by NHS Grampian and the council, pro-rata in line with an approved funding
agreement. For 2025/26, the council’s funding contribution to the MIJB was
contained within approved expenditure limits. The council continues to work
closely with NHS Grampian and in conjunction with Aberdeenshire and Aberdeen
City Councils to provide effective oversight of the management and control of the
costs of services delivered through the IJB. 
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• External Agencies 
In addition to the various internal review processes and the external audit of the
Annual Accounts, aspects of the council’s governance arrangements are
considered in various inspection reports produced by the external auditor and
other inspectorates. The council welcomes and responds positively to these
reports.
4. Overall Assessment of the Effectiveness of Governance
Arrangements  
4.1 Having regard to the information provided in the preceding paragraphs, it is
considered that established systems and processes are consistent with the
seven principles identified in the ‘CIPFA/SOLACE’ Framework ‘Delivering Good
Governance in Local Government.’ Implementation of the Best Value Action Plan
has further strengthened these arrangements, and work will continue as outlined
below to optimise governance arrangements that deliver Best Value for Moray. 
5. Significant Governance Issues 
5.1 Issues reported as requiring attention in the Annual Governance Statement for
the prior year (2024/25) were aligned to the Best Value report, and to reports
prepared by external advisers who provided consultancy support to the Council.
These reports informed a Best Value self-assessment exercise completed by
council managers which included the following priority areas for improvement:
• Continue work to establish a clear shared vision for Moray that supports delivery
of sustainable public services.
• Maintain current activity to ensure leadership is effective and there is good
collaboration between elected members and senior officers.
• Increase the pace of transformation and identify savings with the intention of
securing longer term financial sustainability.
• Revisit governance arrangements covering partnerships; principally for Health
and Social Care Moray in respect of performance and early identification of any
significant financial and service risks.
5.2 While substantial progress has been made on all of these areas, the plan for
improvement is a three-year plan and will need further refinement as the council
responds to change both internally and in response to emerging issues
impacting on local government. 
5.3 Specifically:
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• Collaborating with partners to inform the engagement plan for the next
iteration of the  Moray Local Outcomes Improvement Plan, thereby ensuring
resources available are fully aligned with identified partnership priorities. 
• Progressing multiple improvement initiatives across all services, including
the management and oversight of substantial external funding streams
including those for the Moray Growth Deal, Just Transition and Levelling Up
Programmes.
• Concluding work being undertaken to review and revise governance
arrangements between the council and Moray Leisure. 
• Pursuing transformation opportunities at pace aimed at securing service
improvements and efficiencies.
• Demonstrating financial sustainability, secured short-term through delivery
of a balanced budget for 2026/27, and with medium to longer term financial
plans updated to evidence a continuing commitment to sound financial
management.
• Progressing work to develop e a shared set of organisational values and
behaviours, supporting a positive workplace culture, effective leadership and
employee engagement as part of the council’s wider transformation and
improvement agenda.
5.4 Looking forward, key governance challenges relate to:
• supporting elected members to sustain the benefits derived from
collaborative working, while recognising and respecting political difference;
• continuing to explore transformation opportunities where these are likely to
generate improved, modern and sustainable ways of working.
• monitoring closely capital and revenue spend, including allocations to
partner bodies, to ensure the ongoing financial sustainability of the council.
• completion of training for elected members on scrutiny arrangements, and
preparation for induction of elected members following the May 2027 local
government election.
• progressing the review of other staffing structures to create capacity
necessary to deliver agreed priorities;  Phase 1 of the senior management
restructuring has been completed, and work is underway with Heads of
Service to assess service requirements and inform the corporate planning of
Phase 2 organisational reviews.
5.5 Work is also being progressed to develop a Local Code of Governance that
describes the council’s governance structures and functions; having such a
Code in place will enable an abridged version of this Annual Governance
Statement to be prepared for inclusion with the Annual Accounts in future years. 
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6.  Concluding Remarks 
6.1 A number of key governance issues have been addressed during 2025/26,
notably the successful recruitment of a number of chief officers to the council’s
Corporate Leadership Team, reassignment of duties and responsibilities of the
officers within that team, and progress with delivery of improvements identified
in the Best Value Action Plan. These changes and actions alongside other
developments referenced throughout this governance statement reflect the
determination of both members and officers to improve governance practice, all
against a backdrop of ongoing challenges relating to transformation of services
and ensuring financial sustainability. 
6.2 Notwithstanding these challenges we remain committed in our respective roles
as Council Leader and Chief Executive to the promotion and application of good
governance practice in the delivery of Best Value services to the citizens and
communities of Moray. 
Kathleen Robertson                                                                          Karen Greaves BEM                          
Leader of the Council                                                          Chief Executive
xx September 2026
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