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Agenda Document Pack - Audit and Scrutiny Committee - 13/09/2023

Moray Council · 13 September 2023
Back to Audit and Scrutiny Committee — 13 September 2023 and its agenda

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Audit and Scrutiny Committee 
Wednesday, 13 September 2023 
NOTICE IS HEREBY GIVEN that a Meeting of the Audit and Scrutiny Committee
is to be held at Council Chambers, Council Office, High Street, Elgin, IV30 1BX
on Wednesday, 13 September 2023 at 09:30. 
BUSINESS 
1. Sederunt 
2. Declaration of Group Decisions and Members Interests * 
3. Minute of the meeting held 27 June 2023 5 - 8
4. Written Questions ** 
5. Internal Audit Section Update Report
Report by Audit and Risk Manager
9 - 26
6. Internal Audit Section Completed Projects Report
Report by Audit and Risk Manager
27 - 56
7. Question Time ***
Consider any oral question on matters delegated to the Committee in
terms of the Council's Scheme of Administration. 
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Summary of Audit and Scrutiny Committee functions:
Audit Functions - Consider reports from the Council's internal auditor
& Audit Scotland concerning Council Functions.
Scrutiny Functions - Scrutinising the policies of the Council and their
effectiveness in meeting the action plans of the Council as set out in
the Corporate Development Plan and evaluating the actions of
Committees in implementing the action plans set out in the Corporate
Development Plan.
Performance Monitoring - To receive reports on the performance of
and trends within all of the Council’s services in terms of service
standards and performance information.
Standards - To ensure that the highest standards of probity and public
accountability are demonstrated.     
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GUIDANCE NOTES 
* Declaration of Group Decisions and Members Interests - The Chair of the
meeting shall seek declarations from any individual or political group at the
beginning of a meeting whether any prior decision has been reached on how
the individual or members of the group will vote on any item(s) of business on
the Agenda, and if so on which item(s).  A prior decision shall be one that the
individual or the group deems to be mandatory on the individual or the group
members such that the individual or the group members will be subject to
sanctions should they not vote in accordance with the prior decision.  Any such
prior decisions will be recorded in the Minute of the meeting. 
** Written Questions - Any Member can put one written question about any
relevant and competent business within the specified remits not already on the
agenda, to the Chair provided it is received by the Proper Officer or Committee
Services by 12 noon two working days prior to the day of the meeting.  A copy
of any written answer provided by the Chair will be tabled at the start of the
relevant section of the meeting.  The Member who has put the question may,
after the answer has been given, ask one supplementary question directly
related to the subject matter, but no discussion will be allowed. 
No supplementary question can be put or answered more than 10 minutes after
the Council has started on the relevant item of business, except with the
consent of the Chair. If a Member does not have the opportunity to put a
supplementary question because no time remains, then he or she can submit it
in writing to the Proper Officer who will arrange for a written answer to be
provided within 7 working days. 
*** Question Time - At each ordinary meeting of the Committee ten minutes will be
allowed for Members questions when any Member of the Committee can put a
question to the Chair on any business within the remit of that Section of the
Committee.  The Member who has put the question may, after the answer has
been given, ask one supplementary question directly related to the subject
matter, but no discussion will be allowed. 
No supplementary question can be put or answered more than ten minutes
after the Committee 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/she can submit it in
writing to the proper officer who will arrange for a written answer to be provided
within seven working days. 
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MORAY COUNCIL 
Audit and Scrutiny Committee 
SEDERUNT 
Councillor Graham Leadbitter  (Chair)
Councillor Shona Morrison  (Depute Chair)  
Councillor Peter Bloomfield  (Member)
Councillor Theresa Coull  (Member)
Councillor John Cowe  (Member)
Councillor John Divers  (Member)
Councillor Amber Dunbar  (Member)
Councillor Jérémie Fernandes  (Member)
Councillor Donald Gatt  (Member)
Councillor David Gordon  (Member)
Councillor Sandy Keith  (Member)
Councillor Marc Macrae  (Member)
Councillor Neil McLennan  (Member)
Councillor John Stuart  (Member)  
Mr Ivan Augustus  (Non-Voting Member)
Ms Margaret Wilson  (Non-Voting Member)
Clerk Name: Lindsey Robinson
Clerk Telephone: 07966 120593
Clerk Email: committee.services@moray.gov.uk 
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MORAY COUNCIL 
Minute of Meeting of the Audit and Scrutiny Committee 
Tuesday, 27 June 2023 
Council Chambers, Council Office, High Street, Elgin, IV30 1BX 
PRESENT 
Mr Ivan Augustus, Councillor Peter Bloomfield, Councillor Theresa Coull, Councillor
John Cowe, Councillor John Divers, Councillor Amber Dunbar, Councillor Jérémie
Fernandes, Councillor Donald Gatt, Councillor David Gordon, Councillor Sandy
Keith, Councillor Graham Leadbitter, Councillor Marc Macrae, Councillor Neil
McLennan, Councillor Shona Morrison, Councillor John Stuart, Ms Margaret Wilson 
IN ATTENDANCE 
The Chief Executive, Head of Governance, Strategy and Performance, Head of
Environmental and Commercial Services, Audit and Risk Manager, Atholl Scott,
Business Continuity and Risk Management Officer, Lindsey Robinson, Committee
Services Officer as clerk to the meeting, all Moray Council and Andrew Wallace,
Grant Thornton - External Auditor. 
1.         Chair 
Councillor Graham Leadbitter, as Chair of the Audit and Scrutiny Committee,
chaired the meeting. 
2.         Welcome 
The Committee joined the Chair in welcoming Ivan Augustus to his first meeting
since joining the Committee as an external member. 
3.         Declaration of Group Decisions and Members Interests * 
In terms of Standing Order 21 and 23 and the Councillors’ Code of Conduct, the
Committee noted the following declarations: 
Councillors Morrison, Divers, Gatt, Keith and Bloomfield all declared that they were
either members or substitute members of the Moray Integration Joint Board. 
Councillor Gatt declared that he was the Convenor of the Grampian Valuation Joint
Board. 
There were no further 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. 
4.         Minute of the meeting held 10 May 2023 
The minute of the meeting of the Audit and Scrutiny Committee dated 10 May 2023
was submitted and approved. 
Item 3.
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Councillor McLennan raised a point of accuracy with regards to the wording of item
6 “Internal Audit Section Completed Projects”  He was of the opinion that the
comments made by the Chair for members to be mindful of their language should
have been added. 
The clerk agreed to look back at the webcast and add in the information. 
5.         Written Questions ** 
The Committee noted that no written questions had been submitted. 
6.         Annual Governance Statement 
The meeting had before it a report by the Chief Executive providing the Committee
with a copy of the Council's Annual Governance Statement for 2022/23 for
information and review. 
During consideration Councillor Gordon sought clarification on item 5 on page 16 of
the appendix to the statement asking whether it would be relevant to add in the
interaction between CMT and the administration in terms of capability of leadership
and the individuals. 
In response the Business Continuity and Risk Management Officer agreed to add it
in to the report. 
Thereafter, the Committee agreed unanimously to note the content of the Annual
Governance Statement provided at Appendix 1. 
7.         Internal Audit Annual Report- 2022-23 
The meeting had before it a report by the Audit and Risk Manager providing the
Committee with a copy of the Internal Audit Annual Report for the year ended 31
March 2023, together with the Audit and Risk Manager's opinion on the adequacy
and effectiveness of the Council's system of internal control. 
Following consideration the Committee agreed unanimously to note the contents of
the annual report provided at Appendix 1. 
8.         Internal Audit Section Completed Projects Report 
The meeting had before it a report by the Audit and Risk Manager advising the
Committee on the work of the Internal Audit Section for the period form 11 May
2023 to 27 June 2023. 
During consideration of the report, Ms Wilson sought clarification on Appendix 1
"Emergency Planning", and whether, in section 5.03, Chief Executive or CMT could
be added in to the sentence "However this process requires commitment from the
heads of services.." 
In response the Chief Executive agreed that this could be added. 
Councillor Gordon enquired as the whether the Members could get sight of the
current emergency planning flood action plan. 
The Head of Environmental and Commercial Services agreed to circulate this.
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Councillor Macrae sought clarification on the weekly Moray Emergency response
Co-ordinator (MERC) rota which had previously been available to Members and
whether this could be reinstated. 
In response the Head of Environmental and Commercial Services advised that it
was not a decision that could be made immediately as there were options to
consider and agreed to come back to the Committee with a report into options for
this or something similar. 
The Chief Executive offered to provide a briefing to all Members of the Council on
Emergency Planning and the role of elected members. 
The Chair agreed that a briefing would be useful. 
Councillor Stuart sought clarification on the timescales mentioned in Appendix 2
"Self Directed Support", and he was of the opinion that there was a “back to basics”
approach. 
In response the Audit and Risk Manager advised that the approach would be a
question for the service and the timescales were provided by the service. 
The Chair agreed to raise this with the MIJB Chief Officer and for IJB members to
take it back to the next meeting. 
Thereafter, the Committee agreed unanimously to note the contents of the report
and to a briefing on Emergency Planning.  
9.         Question Time *** 
Role of the Audit and Scrutiny Committee 
Ms Wilson sought clarification on the possible extension of the role of the
Committee and what areas would it cover. 
In response the Chair advised that there had been discussions and that there were
various areas under consideration after the committee description was agreed
earlier in the year. 
The Chair further advised that he plans to have regular meetings with the Chairs of
the service committees regarding the role of scrutiny and he is looking for these to
start after recess. 
The Audit and Risk Manager advised that he would be holding a briefing for
members on the CIPFA Publication – Audit Committees: Practical Guidance for
Local Authorities 2022 Edition, which will also require an annual evaluation and
assessment by the committee. He has also been working with the Organisational
Development team to design a questionnaire for members to look at additional
training requirements. 
The Head of Governance, Strategy and Performance advised that there had
recently been a briefing session on scrutiny but that there may be room for further
training, but he was unsure as to whether the external members could attend. 
Councillor Divers sought clarification on the attendance of Heads of Service at the
Committee, and mentioned that in the past it was the committee Chairs who were
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present but most were members of this committee so he was of the opinion that the
Heads of Service should attend to answer any questions Members of this committee
may have. 
The Chair advised that he would raise it off the table with the MIJB Chief Officer. 
The Chief Executive confirmed that it should be the committee Chairs who were
present and the requirement for the Heads of Service to attend would need further
discussion. 
The Chair further advised that the Chair of the MIJB rotates so it not always Moray
Council so attendance could be a problem. 
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REPORT TO:  AUDIT AND SCRUTINY COMMITTEE ON 13 SEPTEMBER 2023
SUBJECT:       INTERNAL AUDIT SECTION UPDATE REPORT
BY:                    AUDIT AND RISK MANAGER 
1. REASON FOR REPORT 
1.1 The report provides Committee with an update on the work of the Internal
Audit Section. 
1.2 This report is submitted to Committee in terms of Section III I (2) and (7) 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 carried out by
Internal Audit. 
2. RECOMMENDATION 
2.1 Committee is asked to consider the contents of this report, seek
clarification on any points noted and otherwise note the report. 
3. BACKGROUND 
3.1  Public Sector Internal Audit Standards requires the Audit and Risk Manager to
prepare and present reports to committee on internal audit’s activity,
performance relative to its Audit Plan, and any other relevant matters. 
3.2  This report provides an update on audit activity and projects progressed since
the last meeting.   
4. UPDATE OF PROGRESS AGAINST THE 2023/24 AUDIT PLAN 
Audit Plan Update  
4.1 The Internal Audit Plan is a means of determining the priorities of the internal
audit activity and how these fit with the wider goals of the Council. Enclosed
as Appendix 1 is an update on the progress undertaken by the Internal Audit
Service regarding the completion of audit review projects against the Annual
Item 5.
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Audit Plan.   
CIPFA Publication – Audit Committees: Practical Guidance for Local
Authorities and Police (2022 edition) 
4.2 The CIPFA Publication – Practical Guidance for Local Authorities and Police
2022 Edition sets out its guidance on the function and operation of audit
committees in local authorities and police bodies and represents CIPFA’s view of
best practice for audit committees in local authorities throughout the UK.   
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 good standard of performance against recommended
practice together with a knowledgeable and experienced membership are
essential requirements for delivering effectiveness. To this effect, CIPFA has
provided a high-level review checklist that incorporates the key principles set out
in CIPFA’s Position Statement: Audit Committees in Local Authorities and Police
(2022 edition). In addition, the Public Sector Internal Audit Standards also call for
the committee to assess their remit and effectiveness in relation to purpose,
authority and responsibility. The Audit and Risk Manager is planning to facilitate
a workshop with elected members to complete a Self-Assessment of
Compliance with the Good Practice Principles Checklist and an Evaluation of
Effectiveness from the CIPFA Audit Committees Guidance. A copy of the full
CIPFA Publication – Practical Guidance for Local Authorities and Police 2022
will be shared with members of the Committee in advance of the meeting. The
outcome of the self-assessment and evaluation exercises, together with an
action plan detailing any identified improvements, will thereafter be reported to a
future Audit and Scrutiny Committee. 
Follow Up Reviews  
4.5 Internal Audit reports are regularly presented to elected members detailing not
only findings but also the responses by management to the recommendations
with agreed dates of implementation. Internal Audit will also undertake follow up
reviews to evidence the effective implementation of these recommendations.
Please see detailed the following completed follow up reviews: 
Business Continuity 
4.6 An audit review was undertaken of the Council's management arrangements for
Business Continuity. Business Continuity Management concerns how the
Council identifies and prepares for potential incidents and how the risk is
managed to ensure it can continue delivering essential services in an emergency
or during a disruption of normal day-to-day activities. The follow up review found
that several recommendations had not been fully implemented. However, with
the appointment last year of a part time Business Continuity and Risk
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Management Officer, this has facilitated progress to further develop business
continuity arrangements within services. Revised implementation dates for the
recommendations have been agreed. The follow up report to review the
implementation of the agreed recommendations is given in Appendix 2. 
Primary School Estate Security 
4.7 This audit reviewed the controls to restrict unauthorised access to primary school
buildings and grounds. It was found that the age, type of school buildings and
locations of play areas do vary considerably across the Authority. This does
present challenges in ensuring the implementation of consistent security
arrangements. The audit reviewed policies, procedures and an appraisal of the
security controls operating within a sample of primary schools. The audit found
examples of good practices and improvements that have been made to the
physical security of the primary school estates. However, the follow up review
found that not all recommendations have been implemented. The follow up
report to review the implementation of the agreed recommendations is given
in Appendix 3. 
Council Tax 
4.8 An audit was undertaken of the Council Tax System. The Council Tax Service
administers and collects council tax for residential properties in Moray. The
Service also administers and collects domestic water and sewerage charges on
behalf of Scottish Water. The Council maintains a database of residential
properties and updates it for changes of owners and residents, and also
processes applications for exemptions and discounts. The audit noted some
improvements required in administrative arrangements. The follow up report to
review the implementation of the agreed recommendations is given in Appendix
4. 
5 SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcomes Improvement
Plan (LOIP))
Internal audit work supports good governance and the delivery of
efficient services. 
(b) Policy and Legal
No implications directly arising from this report. 
(c) Financial Implications
No implications directly arising from this report. 
(d) Risk Implications
The independent review of selected systems and procedures mitigates
the risk associated with inadequate or ineffective control procedures. 
(e) Staffing Implications
No implications directly arising from this report.. 
.
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(f) Property
No implications directly arising from this report. 
(g) Equalities/Socio Economic Impact
No implications directly arising from this report 
(h) Climate Change and Biodiversity Impacts 
No implications. 
(i) Consultations
There have been no direct consultations during the preparation of this
report. 
6. CONCLUSION 
6.1 This report provides committee with an update on internal audit work
progressed in the latest review period. 
Author of Report:
Background Papers: 
Dafydd Lewis
Internal Audit files
Audit and Risk Manager
Ref:  SPMAN-1042990102-175 
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Appendix 1   
MORAY COUNCIL 
INTERNAL AUDIT SERVICE 
ANNUAL AUDIT PLAN 2023/24 
CORE FINANCIAL SYSTEMS  
Area Type of coverage Status/ Comments
Housing Benefits - Rent Rebates and
Rent Allowances 
Substantive testing of selected benefit
claims to confirm the accuracy of the
Council’s benefit subsidy claim
External Audit now undertaking review
as part of core audit fee
Payroll   Continuous auditing to confirm the
adequacy of the systems and
procedures for the payment of salaries
Audit programmed to start in the next
quarter(s)
Procurement and Creditor Payments  Continuous auditing of samples of non-
pay expenditure to test compliance with
procurement and payment processing
regulations
Audit programmed to start in the next
quarter(s)
Debtors  A review of the system for  income
collection through invoicing and debt
recovery arrangements 
Fieldwork completed
Stocks and stores - year end valuations    Attendance at stocktaking and
reconciliation of stocks held to ledger
balances 
Work Completed
OTHER SYSTEMS  
Area Type of coverage 
Transformation Programme Review of the Transformation
Programme to assess progress and 
planned outcomes are on course to be
achieved
Final report issued
Item 5.
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Appendix 1
CORE FINANCIAL SYSTEMS  
Area Type of coverage Status/ Comments
Housing and Property- Reactive
Maintenance Works 
Audit of works undertaken within
Building Services for the completion of
reactive maintenance works (Council
Housing) 
Audit programmed to start in the next
quarter(s)
Environmental Services – Grant Claims Certification of grant claims as required:
strategic timber; bus operators,
regeneration schemes as appropriate 
Awaiting request from Services
Pool Cars  Review of operating arrangements for
the administration and use of  Pool
Cars
Fieldwork in progress
E-Mail Security  A review of procedures and system
controls used to administer the email
system. 
Audit programmed to start in the next
quarter(s)
Moray Growth Deal A follow up review to evidence
implementation of the 
recommendations agreed within a
recent audit undertaken of the
governance and administrative
arrangements within the management
of the Moray Growth Deal 
Draft Report Completed
Education – Secondary School  Establishment visits as part of cyclical
review 
Audit programmed to start in the next
quarter(s)
Purchasing Cards  Review the systems and procedures for
the management, use and control of
Purchasing Cards
Audit programmed to start in the next
quarter(s) 
ICT Disaster Recovery   Review to evaluate the effectiveness of
the processes and controls surrounding
Information Technology Disaster
Recovery Management
Audit programmed to start in the next
quarter(s)
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Appendix 1
CORE FINANCIAL SYSTEMS  
Area Type of coverage Status/ Comments
Food Standards Scotland Guidelines  A review of systems and practices used
to evidence compliance with the new
Food Standards Scotland Guidelines
Fieldwork in progress
Leisure Services – Sports and
Community Centre 
A review of the arrangements for the
accounting of income and expenditure
at Keith Sports and Community Centre.
The audit will also check procedures
comply with the Payment Card Industry
Data Security Standard
Audit programmed to start in the next
quarter(s) 
Burial Services Review of the arrangements for the
management of the burial service
including a check of the  income
collection procedures for the collection
of interment fees and sale of lairs
Final report issued
Refugee Integration Scheme Review of systems and procedures to
account for grants received and costs
relating to Refugee Integration
Final report issued
Education- Early Learning and
Childcare Premises Security
Review the controls in place to mitigate
the risk of unauthorised access or
egress to Early Learning and Childcare
Establishments 
Audit programmed to start in the next
quarter(s)
Moray Integration Joint Board   
Commissioning Services  Review of the arrangements for the
commissioning of services for children
to ensure these are designed and
delivered to meet the specified needs
and demonstrate best value 
Fieldwork in progress
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Appendix 1
CORE FINANCIAL SYSTEMS  
Area Type of coverage Status/ Comments
Disabled Parking System Review of the system for administering
the disabled parking permits are also
known as Blue Badges
Final report issued
Occupational Therapy Services –
Stores 
A review of the Occupational Therapy
Stores Systems to ensure appropriate
accounting systems are followed 
Fieldwork in progress 
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Appendix 2
Moray Council
Internal Audit Section 
DEPARTMENT: Education, Communities & Organisational Development 
SUBJECT:  Business Continuity 
REPORT REF: 22'008 
Follow Up Audit Review 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Key Control: The Council's Business Continuity Policy has been formally approved, is reviewed at regular intervals and is supported by procedures and
guidelines for consistent application across the organisation. 
5.01 The Council's Business
Continuity Policy should be
reviewed and updated as
required. Policies and procedures
once implemented should be
reviewed at regular, stated,
Medium Yes 28/02/2022 Part implemented. The policy has been
acknowledged as requiring updating. This needs
to be done having regard to statutory obligations,
critical functions of the Council, the response to
the pandemic, and identified links with risk
management and emergency planning. These
matters are under consideration with CMT/SMT
and the timescale for finalising the policy has been
Item 5.
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Appendix 2
Moray Council
Internal Audit Section 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
intervals.    extended to 31st October 2023. This will ensure
the final approved version reflects up-to-date
strategic priorities and makes best use of
resources available to support this area of work. 
Key Control: Business Continuity Plans are in place for all critical service areas and these plans are fully tested and regularly reviewed. 
5.02 Current and finalised Business
Continuity Plans, should be held
covering all critical services
identified by the organisation.   
Medium Yes 31/10/2022 Part implemented. Critical functions of the Council
were affirmed during the pandemic. These have
been reviewed in the context of impacts from
potential power outages that threatened disruption
over the winter period. This identified the specific
plans that need to be updated as a priority and
work on these is ongoing. Plans for other critical
service areas will be updated dependent on
assessed risk as work continues to align business
continuity requirements with risk management
practice. A programme of work will be developed
for the 23/24 year with a revised implementation
date for business plans covering all critical
activities to be in place by 31st March 2024. 
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Appendix 2
Moray Council
Internal Audit Section 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
5.03 All Business Continuity Plans
should be reviewed and tested on
at least an annual basis, with
outcomes analysed and
documented, to ensure plans are
capable of supporting an effective
recovery position.   
Medium Yes 28/02/2023 Not implemented. The focus currently is on
bringing the business continuity plans up-to-date;
part of this process will involve discussions with
relevant managers to ensure proposals are
achievable in practice. Updating of plans will
continue with a revised completion date of 31st
March 2024 and formal testing of plans thereafter
will be on an 'as and when' required basis. 
Key Control: Business Continuity is embedded into the culture of the organisation with all relevant officers appropriately trained and sound central governance
arrangements in place.
5.04 A training programme should be
developed to assist officers in the
preparation and implementation
of the business continuity
management process.     
Medium Yes 30/06/2022 Implemented. Service Managers are being
supported in the development of service risk
registers and business continuity plans through
briefing sessions held by the Business Continuity
& Risk Management Officer appointed in June
2022.   
5.05 The roles and responsibilities of
the Business Continuity Officer as
detailed within the Business
Medium Yes 28/02/2022 Implemented. A Business Continuity and Risk
Management Officer was appointed on a part-time
basis in June 2022. The Officer is currently
progressing the business continuity agenda and
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Appendix 2
Moray Council
Internal Audit Section 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Continuity Policy should be
undertaken. 
implementing the recommendations within this
audit report. 
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Appendix 3
Moray Council
Internal Audit Section 
DEPARTMENT: Education, Communities & Organisational Development
SUBJECT:  Primary School Estate Security 
REPORT REF: 22'017 
Follow Up Audit Review 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Key Control: The controls around school access are sufficient to prevent unauthorised entry to primary schools. 
5.01 Guidance should be prepared and
issued to all schools detailing
good security practices. 
Medium Yes 31/08/2022  Not implemented. Revised guidance has
been drafted, but consultation with head
teachers and unions is still required before
finalisation. Revised implementation date of
30/09/2023. 
Item 5.
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Appendix 3
Moray Council
Internal Audit Section 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Due to the different nature of
individual schools with regard to
buildings, play areas, etc.;
consideration should be given for
each school to develop its own
documented security procedures. 
31/08/2022 
Not implemented. Individual action plans for
each school are being drafted based on risk
assessments carried out. These alongside
centrally agreed security guidance will form
the security guidance documentation for each
school. Revised implementation date of
30/09/2023. 
5.02 Remedial action should be
undertaken to resolve the security
concerns found during the audit
regarding a door entry security
system. 
Medium Yes Implemented Implemented. Work completed prior to the
issuing of the original audit report. 
5.03 A review of the CCTV arrangements
including coverage requirements for
all primary school estates should be
undertaken. 
High Yes 31/08/2022 Implemented - A review of CCTV
requirements for each primary school has
been completed and a rolling program of
installing or upgrading is underway.  
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Appendix 3
Moray Council
Internal Audit Section 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation 
5.04 A standardised recording system
should be introduced within all
primary schools to ensure a
consistent approach is followed in
the recording of incidents or
concerns. In addition, notices/
posters should be displayed within
Schools to remind staff and pupils to
follow good security practices. 
Low Yes 31/08/2022 Not implemented. The revised school security
guidance details the requirement to record
security concerns. As noted in
recommendation 5.01, this guidance requires
further consultation with head teachers and
unions before finalisation. Revised
implementation date of 30/09/2023.
5.05 Regular training to promote good
security practices should be
provided to all staff within schools. 
Medium Yes Ongoing from
31/08/2022
Not implemented. Once the revised school
security guidance has been agreed, training
will be provided to schools. Revised
implementation date agreed- ongoing from
30/09/2023. 
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Appendix 3
Moray Council
Internal Audit Section 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
5.06 Each primary school should
undertake a documented
assessment of the buildings and
grounds including play areas to
assess current security risks and
the controls implemented or
required to mitigate these risks. 
Low Yes 31 August 2022
for risk
assessment
guidance.
31 December
2022 for risk
assessments to
be completed.
Implemented. Senior Health and Safety
Advisor has carried out a health and safety
assessment in relation to security at each
primary school. A risk assessment report has
been prepared for each school, together with
an action plan pertaining to each site. 
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Appendix 4
Moray Council
Internal Audit Section 
DEPARTMENT: Economy, Environment & Finance
SUBJECT:  Council Tax 
REPORT REF: 22'009 
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: Billing is carried out in accordance with regulations and on an accurate and prompt basis. 
5.01 Procedures to be followed in
administering the Council Tax system
should be formally documented to
provide a comprehensive point of
reference for staff. 
Medium Yes  Ongoing Part- Implemented. The follow-up review found
that a number of written procedures have now
been developed within the Council Tax
Service. However, the documentation of all
systems and practices will be an ongoing
requirement, but progress is constrained by
limited staff resources.
Item 5.
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Appendix 4
Moray Council
Internal Audit Section 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls absent, not
being operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Date of
Completion
Status / Explanation
Key Control: Collection of Council Tax is carried out in accordance with statutory and Authority regulations, is fully evidenced in terms
of documentation of all payment sources and transactions and refunds are appropriately controlled. 
5.02 A regular Review of credit balances
should be undertaken to identify any
processing errors or irregular account
activity. The review will ensure
monies collected are applied
correctly and promptly returned to tax
payers where appropriate.   
Low Yes 31/01/2023 Implemented. A process of regularly reviewing
credit balances, with a view to reducing
returning these balances to taxpayers, has
been implemented. A procedure document
has been developed to provide staff with
guidance. 
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REPORT TO:    AUDIT AND SCRUTINY COMMITTEE ON 13 SEPTEMBER 2023 
SUBJECT: INTERNAL AUDIT SECTION – COMPLETED PROJECTS REPORT 
BY: AUDIT AND RISK MANAGER 
1. REASON FOR REPORT 
1.1 The report advises Committee on the work of the Internal Audit Section for the
period from 28 June 2023 to 13 September 2023. 
1.2 This report is submitted to Committee in terms of Section III (2) and (7) 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
carried out by Internal Audit. 
2. RECOMMENDATION 
2.1 That Committee consider the contents of this report, seeks clarification
on any points noted and otherwise notes the report. 
3. BACKGROUND 
3.1 This report provides details of the following internal audit work concluded during
the period 28 June 2023 to 13 September 2023: 
4. COMPLETED AUDIT REVIEWS 
Burial Service 
4.1 An audit review of the Burial service has been undertaken. The Council has
responsibility for 63 burial grounds. The Service is administered in accordance
with a locally developed Burial Grounds Standards of Service, which reflects the
obligations and rights of the Burial and Cremation (Scotland) Act 2016. The
scope of this audit was to review systems and procedures in the administration
of the Burial Service. This included checking operational processes to ensure
compliance with the Burial Grounds Standards of Service. In addition, a check
was also made to verify the costs of delivering the Service and a review of
Item 6.
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systems and procedures for the collection of income. The executive summary
and recommendations for this project are given in Appendix 1. 
Disabled Parking Permit Scheme   
4.2 An audit review of the Disabled Parking Permit Scheme has been completed.
Disabled parking permits, also known as blue badges, help people with
disabilities or health conditions park closer to their destination. Local authorities
are responsible for the day-to-day administration and enforcement of the
scheme. However, the framework for the scheme is set by Transport Scotland.
The audit reviewed the systems and procedures in the administration of the
Disabled Parking Permit Scheme. This has also included the processes for
investigating blue badge misuse. The executive summary and recommendations
for this project are given in Appendix 2. 
Transformation Programme 
4.3 An audit has been undertaken to review the Council’s Improvement and
Modernisation Programme. The Council established an Improvement and
Modernisation Programme in 2018 to bring transformational change, deliver
savings, and provide the basis for a medium to long term financial plan to
support financial sustainability in the delivery of services to communities. The
Improvement and Modernisation Programme currently consists of nine separate
work streams. 
4.4 Detailed within each of these workstreams are individual projects from across a
range of services. The management and delivery of projects to deliver service
improvements are undertaken through a framework detailed within the Project
Management Governance Policy. The scope of the audit has reviewed the
governance arrangements around the management, monitoring and reporting
arrangements of the Improvement and Modernisation Programme. The audit has
also checked that strategic projects included within the Improvement and
Modernisation Programme are managed in accordance with the Project
Management Governance Policy. The executive summary and
recommendations for this project are given in Appendix 3. 
Refugee Integration Scheme 
4.5 An audit has been undertaken to review the Refugee Integration Scheme. The
scope of this audit examined the financial and administrative processes involved
in delivering the Ukrainian Refugee Scheme. The emerging Asylum Dispersal,
Afghan Citizens Resettlement Scheme and Afghan Relocation & Assistance
Policy Scheme did not form part of the audit testing due to limited activity at the
time of the review. The Council has supported approximately 140 Ukrainian
displaced persons, with allocated funding from the Central Government in
2022/23 of over £1.9 million spread across the Warm Scottish Welcome Fund,
Tariff per Displaced Person funding, Host Thank You Payment Funding and
Educational Tariff Funding. All these funds have specific requirements and the
audit has reviewed the accounting arrangements for administering these
schemes and the claiming of expenditure. The executive summary and
recommendations for this project are given in Appendix 4. 
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5. SUMMARY OF IMPLICATIONS 
(a) Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan
(LOIP))
Internal audit work supports good governance and the delivery of efficient
services. 
(b) Policy and Legal
No implications. 
(c) Financial Implications
No implications directly arising from this report. 
(d) Risk Implications
The independent review of selected systems and procedures mitigates
the risks associated with inadequate or ineffective control procedures. 
(e) Staffing Implications
No implications. 
(f) Property
No implications. 
(g) Equalities/ Socio Economic Impacts
No implications. 
(h) Climate Change and Biodiversity Impacts
No implications. 
(i) Consultations
There have been no direct consultations during the preparation of this
report. 
6. CONCLUSION 
6.1 This report provides Committee with a summary of findings arising from
an audit project completed during the review period. 
Author of Report:       Dafydd Lewis, Audit and Risk Manager
Background Papers:  Internal audit files 
Ref:                            SPMAN-1042990102-177
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Page 31

Appendix 1 
AUDIT REPORT 24'007
BURIAL SERVICE 
Executive Summary 
The annual audit plan for 2023/24 provides for an audit review to be undertaken of the
arrangements for the management of the Council's Burial Service, including a check
of the income received from the collection of interment fees and sale of lairs. The
Council has responsibility for 63 burial grounds. The service is administered in
accordance with a locally developed Burial Grounds Standards of Service, which
reflects the responsibilities and rights of the Burial and Cremation (Scotland) Act 2016.   
The scope of this audit was to review systems and procedures in the administration of
the Burial Service. The included checking operational processes to ensure compliance
with the Burial Grounds Standard of Service. In addition, a check was also made to
verify the costs of delivering the Service and a review of systems and procedures for
the collection of income. Expenditure relates mainly to burial grounds routine
maintenance and the costs of carrying out interments. It was noted that £724,000 is
budgeted to be raised per annum from interment fees, the sale of lairs and headstone
preparations. 
This was a cross-service audit as the delivery of the Burials Service involves officers
from Environmental and Commercial Services and the Registrars. It was noted that
work is currently ongoing to automate current administrative systems and practices
with the intention of developing improved communication processes. Audit testing was
limited in certain areas to ensure no duplication of effort nor detailed analysis on
processes already identified by the Service as in need of review. A more complete
audit review of the Burials Service will therefore be included in a future Audit Plan.   
The audit was carried out in accordance with Public Sector Internal Audit Standards
(PSIAS). 
The main areas identified for management attention are as follows:- 
• A Schedule of Rates is used internally to monitor costs and performance in the
works undertaken for interments, headstone preparations and routine grounds
maintenance. It was noted that elements of the Schedule of Rates has not been
updated to account for all current cost components. A review of the Schedule
of Rates should be undertaken to ensure recharges reflect current expenditure
and the work undertaken. 
• A review of recording arrangements of lair purchases and interments for burial
grounds noted for some locations manual registers are maintained whilst for
others both manual and electronic recording systems are kept. It was found that
the Head of Service is aware of this issue and a commitment was noted to
review current arrangements with the aim of developing a singular recording
system.   
Item 6.
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Appendix 1 
The Internal Audit Section provides Management with an opinion on the internal
control environment and also categories risk ratings for recommendations as high,
medium or low. The audit recommendations for this review have been classified as
follows: 
Risk Ratings for Recommendations
High Medium Low
Key controls absent,  not being
operated as designed or could be
improved. Urgent attention required.
Less critically important controls
absent, not being operated as
designed or could be improved. 
Lower level controls absent, not
being operated as designed or
could be improved. 
- 2 2
.
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Appendix 1 
Recommendations 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Key Control: Key costs of service provision are appropriately controlled and accounted for. 
5.01 The Schedule of Rates
should be reviewed to ensure
full and current costs of
service provision are
reflected and recharged to
the Burials service. 
Medium Yes The service is
aware that all
schedule of
rates within the
Confirm asset
management
system need
to updated and
work is
underway via
Finance to
move all
burials related
costs to the
burials service.  
Service
Manager
(Waste, Open
Spaces,
Catering &
Facilities)
31/03/2024
5.02 Consideration should be
given to the development of
recharge rates for interments
within the Schedule of Rates
which reflect the varying
costs of service provision
incurred by weekday and
Low Yes As above the
service is
aware that
recharge rates
require to be
reviewed.
Arrangements
Open Space
Manager
31/12/2023
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Appendix 1 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
weekend interments.    will be made to
review and
update rates
for burials on
Saturdays,
Sundays and
Public
Holidays in
Confirm via the
Admin Team. 
5.03 Checks should be
undertaken to ensure all jobs
carried out in the month are
identified for recharge in the
Confirm system and the
Confirm content is reflected
accurately in the recharge
processed in the Financial
Management System.   
Low Yes Burials team to
be reminded
that job tickets
are returned
timeously to
the Admin
team to allow
processing
within the
Financial
Management
System in the
relevant
month. This
will be
Administration
Officer
30/09/2023
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Appendix 1 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
communicated
via Teams
meetings. 
Key Control: Processes are in place to control all income due to the service with fees formally approved and regularly reviewed and
income amounts fully and appropriately accounted for. 
5.04 A review of current
arrangements for the
recording of lair purchases
and interments should be
undertaken with the aim of
developing a singular
recording system.     
Medium Yes Cross service
review
required. Head
of Service
aware and has
initiated
process
mapping
exercise to
guide future
decision
making on
processes and
singular
software /
recording
system. 
Service
Manager
(Waste, Open
Spaces,
Catering &
Facilities)
31/03/2025 
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Page 37

Appendix 2 
AUDIT REPORT 24'010
DISABLED PARKING PERMIT SCHEME 
Executive Summary 
The annual audit plan for 2023/24 provides for an audit review of the arrangements
for managing the Disabled Parking Permit Scheme. Disabled parking permits, also
known as blue badges, allow eligible people to park close to amenities they would
otherwise have difficulty accessing. Local authorities are responsible for the day-to-
day administration and enforcement of the scheme. However, the framework for the
scheme is set by Transport Scotland, in addition to providing support to assist in
consistent operating practices across all local authorities. A blue badge is subject to
a charge of £20 and can be valid for up to three years. 
The scope of this audit was to review systems and procedures in the administration
of the Disabled Parking Permit Scheme. This included the processes for
assessment, management and investigation of blue badge misuse. The expenditure
for providing the service relates mainly to staffing and the cost of producing badges
from approved suppliers. The Council issues approximately 1700 blue badges
annually with an income of £29,000 collected in 2022/23. 
The audit was carried out in accordance with Public Sector Internal Audit Standards
(PSIAS). 
The key areas identified for management attention include the following:- 
• The Moray Council Financial Regulations detail that invoices must be raised
within one month of providing goods or services. Once a blue badge is issued,
an invoice of £20 should be issued to the applicant. Audit testing found that
the Service did not raise invoices until several months after issuing the blue
badge. It was noted that over recent years there have been significant
increases in the number of applications received for blue badges, but staffing
levels have remained unchanged. However, to ensure effective income
collection arrangements and compliance with the Council’s Financial
Regulations, invoices should be raised promptly once the blue badge has
been issued.     
• Analysis of the Financial Management System noted a shortfall of
approximately £24,000 in the income received compared to the blue badges
issued. Further investigation noted that there were approximately 1200 blue
badges provided to applicants in 2020 and 2021, where no invoices had been
issued. Explanation sought as to why no invoices had been raised revealed
this was due to workload issues and the extraordinary challenges faced by the
Service during the pandemic. Invoices should be raised for these blue badges
issued in 2020 and 2021 as a matter of urgency.   
Item 6.
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Appendix 2 
• Audit testing noted that the Service is following Transport Scotland Guidelines
in assessing eligibility and managing the Disabled Parking Permits Scheme.
However, it was found that the Blue Badge Scheme Policy was last updated
in 2013. Policies and procedures should be updated to reflect current
operating practices and legislation. 
The Internal Audit Section provides Management with an opinion on the internal
control environment and also categories risk ratings for recommendations as high,
medium or low. The audit recommendations for this review have been classified as
follows: 
Risk Ratings for Recommendations
High Medium Low
Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Less critically important controls
absent, not being operated as
designed or could be improved. 
Lower level controls absent, not
being operated as designed or
could be improved. 
2 2 1 
.
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Appendix 2 
Recommendations 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Key Control: Effective management controls operate to ensure the delivery of the Disabled Parking Permit System is in accordance
with Transport Scotland Guidelines. 
5.01 The Blue Badge Scheme Policy
should be reviewed and
updated. This should include
reference to responsibility for
investigating misuse and
arrangements if required to
cancel a service users blue
badge. 
Medium Yes The Blue Badge
Scheme Policy will
be updated to
ensure all aspects
of the service and
its processes are
incorporated,
including badge
misuse
arrangements.
Interim
Community
Care Finance
Officer/Supp
ort Manager 
31/03/2024
5.02 All service users identified that
have received a blue badge in
2020 a 2021 but not billed
should be invoiced as a matter
of priority. 
High Yes Work is underway
to review un-
invoiced
applications from
2020 and 2021 to
establish the
current position. On
completion of this
review, invoices will
be raised for all
Commissioni
ng Manager
31/01/2024
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Appendix 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)
Comments Responsible
Officer
Timescale for
Implementation
outstanding
approved blue
badges issued from
this period.
5.03 In accordance with Financial
Regulations, service users
should be invoiced within one
month of receiving a blue
badge.  An action plan should
also be agreed to resolve any
backlog of blue badges issued
to applicants who have yet to be
invoiced. 
The audit review noted that the
fee for a blue badge is payable
on application in some Local
Authorities. Consideration
should be given to investigating
the option for an individual to
pay the charge for a blue badge
Medium 
Low
Yes 
Yes 
An action plan is
now in place to
clear the current
year invoice
backlog, staff time
has been ring
fenced to facilitate
this. All new
applications are
being invoiced
within one month.  
Discussions are
currently underway
between the
Community Care
Finance team, the
Payments team and
Senior
Management to
develop the option
Interim
Community
Care Finance
Officer/Supp
ort Manager 
Interim
Community
Care Finance
Officer/Supp
ort Manager 
31/08/2023 
31/12/2023
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Appendix 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)
Comments Responsible
Officer
Timescale for
Implementation
on completion of the application
form. 
of up-front payment
for blue badges. 
5.04 All sensitive personal data held
within the Community Care
Finance Office should be stored
securely with access restricted
to only authorised officers. 
High Yes There will be a
purchase of
lockable filing
cabinets to replace
those which are
non-lockable and all
staff will attend data
protection training
and be reminded of
the clear desk
policy with
immediate effect.
The lock on the
door will be used
without delay and
without exception. 
Interim
Community
Care Finance
Officer/Supp
ort Manager 
31/08/2023 
Page 41

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Page 42

Page 43

Appendix 3 
AUDIT REPORT 24’009
TRANSFORMATION PROGRAMME
(Improvement and Modernisation Programme)  
Executive Summary  
The annual audit plan for 2023/24 provides for a review of the transformation
projects included within the Improvement and Modernisation Programme, which is
designed to contribute to a financially stable Council for the future. 
The Council established an Improvement and Modernisation Programme in 2018
with the purpose of bringing transformational change across the Council, delivering
savings and providing the basis for a medium to long term financial plan to support
the financial sustainability in the delivery of services to communities. The
Improvement and Modernisation Programme currently consists of nine separate
work streams. Detailed within each of these work streams are 15 strategic projects
from across a range of services. The management and delivery of these projects is
undertaken through a framework detailed within the Project Management
Governance Policy. The Council has identified a need to make savings of
approximately £20 million across 2023/24 and 2024/25 to deliver a balanced budget
and ensure the sustainability of Council services. The Improvement and
Modernisation Programme is an integral part of the delivery of this objective.
Significant progress has been made by senior management to advance the
transformation of services and build on the approved Improvement and
Modernisation Programme. 
The scope of the audit has reviewed the governance arrangements around the
management, monitoring and reporting arrangements of the Improvement and
Modernisation Programme. The audit has also checked that strategic projects
included within the Improvement and Modernisation Programme are managed in
accordance with the Project Management Governance Policy. The review found
variances in the administration of projects when compared to the procedures
detailed within the Project Management Governance Policy. This does not indicate
that the key deliverables of the projects are not being achieved. However, consistent
administration of projects in accordance with the Project Management Governance
Policy would provide greater confidence to senior management in their objective to
ensure that projects included within the Improvement and Modernisation Programme
secure savings the Council requires to achieve. 
The audit was carried out in accordance with Public Sector Internal Audit Standards
(PSIAS).
The audit has noted the following areas for senior management to consider in regard
to governance arrangements of the Improvement and Modernisation Programme: 
• The Council has an established Project Management Governance Policy that
was agreed in 2016 with additional project management assurances
concerning governance and leadership noted at the Corporate Committee on
Item 6.
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Appendix 3 
30 August 2022. This Policy provides a framework for accountability and
responsibilities, ensuring that project decision making is robust, logical and
that projects provide value to the Council. It offers a mechanism for ensuring
that accurate and appropriate project status reports are presented regardless
of the service running the project or the type of project. Detailed within the
Policy is a governance framework for managing projects from approval of a
mandate by a Project Initiation Board to agreeing on business plans and
monitoring progress at a High Level Governance Board through to a Benefit
Realisation Board to evidence a project has delivered the key deliverables
and benefits. However, the audit review of individual projects noted variances
in the practices undertaken in approving project mandates and outline/ full
business cases compared to the requirements detailed within the Project
Management Governance Policy. In addition, a need for more consistency
was found in project monitoring and reporting progress to the Programme
Boards. Reference was also noted within the Project Management
Governance Policy to a Gateway Initiation Board as the first step in agreeing
on a mandate for approval of a project. However, this Board's function is
undertaken by the Corporate Management Team. It is understood that senior
management has already recognised the need to update the current Policy
and are developing a “Single Project Gateway Process” to ensure more
effective project management arrangements. 
• As part of the audit, a review was undertaken of the administration of projects
from approval of a mandate to progress monitoring and end of project
reporting to the Benefit Realisation Board. Project management arrangements
were noted to be based on the Prince2 project management methodology,
aligned with the Scottish Government Construction Procurement Manual and
the Office of Government Commerce Gateway Framework. It was pleasing to
find that in accordance with good practice, a standardised “Highlight Report”
is used to monitor progress, major risks/ issues/ change requests and targets
for the next period. However, the “Highlight Report” template is not used to
monitor the progress of all projects. It is considered that the format of the
“Highlight Report” is fit for purpose, however consideration should also be
given to including an additional requirement for monitoring the key
deliverables from implementing the project. 
The Internal Audit Section provides Management with an opinion on the internal
control environment and also categories risk ratings for recommendations as high,
medium or low. The audit recommendations for this review have been classified as
follows: 
Risk Ratings for Recommendations
High Medium Low
Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Less critically important controls
absent, not being operated as
designed or could be improved. 
Lower level controls absent, not
being operated as designed or
could be improved. 
1 2 - 
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Appendix 3 
Recommendations 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Key Control:  Review key controls operate to ensure effective project management of the Improvement and Modernisation Programme. 
5.01 The Project Management
Governance Policy should be
reviewed and updated to reflect
any proposed changes to
project management
arrangements. 
High Yes Review has
been
undertaken
and will be
considered by
CMT/SMT
before being
reported to
Committee 
Depute Chief
Executive
(Education,
Communities &
Organisational
Development)
30/11/2023
5.02 The standardised “Highlight
Report” format should be used
to monitor progress for all
Improvement and Modernisation
Programme strategic projects.
In addition, consideration should
be given to further developing
the “Highlight Report” to provide
more effective analysis of key
deliverables during project
implementation. 
Medium Yes Report format
to be reviewed
and Senior
Responsible
Officers will be
reminded to
use the
highlight report
for projects
following
agreement of
the business
case and to
ensure its
Depute Chief
Executive
(Education,
Communities &
Organisational
Development)
30/11/2023
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Appendix 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)
Comments Responsible
Officer
Timescale for
Implementation
content
enables
tracking the
progress
towards key
deliverables. 
Reporting will
also be put in
place for more
structured
oversight of
progress from
project
mandate
approval to
business case
to ensure
progress or re-
prioritisation. 
5.03 Consideration should be given
to reviewing the format of future
committee reporting
arrangements to allow greater
transparency in monitoring
Medium   The format for
reporting
financial
performance to
Committee will
Chief Financial
Officer
30/11/2023
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Appendix 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)
Comments Responsible
Officer
Timescale for
Implementation
financial savings derived from
implementing Improvement and
Modernisation Programme
projects.
be updated to
ensure greater
transparency. 
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Appendix 4 
AUDIT REPORT 24’008
REFUGEE INTEGRATION SCHEME 
Executive Summary  
The Annual Audit Plan for 2023/24 provides for a review to be undertaken of
systems and procedures to account for grants received and costs relating to
Refugee Integration. Asylum is a matter reserved to the UK Government, however
local authorities are required to deliver access to essential services like housing,
healthcare and education that enable the integration of refugees and asylum seekers
in the community. This is undertaken through various humanitarian protection
schemes.   
The scope of this audit was to review the financial and administrative processes
involved in delivering the Ukrainian Refugee Scheme. The emerging Asylum
Dispersal, Afghan Citizens Resettlement Scheme and Afghan Relocation &
Assistance Policy Scheme did not form part of the audit testing due to limited activity
at the time of the review.  The Council has supported approximately 140 Ukrainian
displaced persons, with allocated funding from the Central Government in 2022/23 of
over £1.9 million spread across the Warm Scottish Welcome Fund, Tariff per
Displaced Person funding, Host Thank You Payment Funding and Educational Tariff
Funding. All these funds have specific requirements and the audit has reviewed the
accounting arrangements for administering these schemes and the claiming of
expenditure.   
The Asylum, Refugee and Resettlement Section within Health & Social Care Moray
is operationally responsible for service delivery. However, a cross-service delivery
function including Education, Housing and Environmental Health Services is required
to ensure an effective integration of refugees and asylum seekers in the community.
It is understood that alternative management arrangements for the Asylum, Refugee
and Resettlement Section are currently being considered within the Council and
Health and Social Care Moray.     
The audit was carried out in accordance with Public Sector Internal Audit Standards
(PSIAS). 
The main areas identified for management attention are as follows:- 
• Further improvements are required in budgetary management
arrangements. It is appreciated that the delivery of Refugee Schemes
requires services to be provided by various sections of the Council and
Health and Social Care Moray. However, the Asylum, Refugee and
Resettlement Section do not regularly monitor the full costs of delivering
these services compared to the available funding. Improved financial
recording arrangements should be implemented to allow more accurate
financial forecasting and aid the maximisation of the impact of available
funding.    
Item 6.
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Appendix 4 
• Audit testing was undertaken of the administration of the imprest account. It
was found that while an audit trail of cash usage was maintained providing
evidence of the distributions to Ukrainian Displaced Persons, the limit of
cash authorised to be held by the service was exceeded on multiple
occasions. In addition, significant expenditure items were noted to have
been paid from the imprest account, which should have been met by
alternative procurement methods in accordance with Financial Regulations
and Petty Cash Procedures. Usage of the imprest should be monitored to
ensure compliance with Council regulations and procedures.   
The Internal Audit Section provides Management with an opinion on the internal
control environment and also categories risk ratings for recommendations as high,
medium or low. The audit recommendations for this review have been classified as
follows: 
Risk Ratings for Recommendations
High Medium Low
Key controls absent, not being
operated as designed or could be
improved. Urgent attention required.
Less critically important controls
absent, not being operated as
designed or could be improved. 
Lower level controls absent, not
being operated as designed or
could be improved. 
2 2 4 
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Appendix 4 
Recommendations 
Risk Ratings for Recommendations
High Key controls absent, not being
operated as designed or could
be improved. Urgent attention
required.
Medium Less critically important controls
absent, not being operated as
designed or could be improved.
Low Lower level controls
absent, not being
operated as designed or
could be improved.
No. Audit Recommendation Priority Accepted
(Yes/ No)
Comments Responsible
Officer
Timescale for
Implementation
Key Control: Grant funding is effectively managed, monitored and applied for the intended purpose
5.01 A consolidation exercise
should be undertaken to
identify all expenditure and
designate as costs being met
from the available funding. A
standard financial monitoring
process should thereafter be
put in place to ensure funding
and its usage is reported and
effectively monitored by the
service on a monthly basis. 
High Yes Meeting with
Finance on 17
August 2023
arranged to
consolidate
current spend
position across
departments.
Thereafter
forecasting
can be agreed
to aid a
standard
financial
monitoring
statement. 
Interim
Strategy &
Planning Lead
01/12/2023
5.02 Ongoing financial forecasting
should be undertaken to
allow more informed
management decisions to be
taken and ensure the full
potential of the available
funding is utilised.  
High Yes Through the
business case
being
developed for
the service, a
financial
forecast will
Interim
Strategy &
Planning Lead
01/12/2023
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Appendix 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)
Comments Responsible
Officer
Timescale for
Implementation 
identify funding
potential.
Monthly
forecasting will
be undertaken
going forward.  
5.03 Improved consolidation of
documentation regarding
funding awards and related
submissions requires to be
undertaken to ensure the
service holds the full
complement of final version
documents for clarity and
completeness.   
Low Yes A review of all
funding award
documentation
will be
undertaken,
cross-
referencing
with the
Scottish
Government
Policy Team. 
Interim
Strategy &
Planning Lead
01/11/2023
5.04 In establishing the new
Asylum, Refugee and
Resettlement Section, the
temporary employment
contracts currently in place
for team members should be
reviewed and aligned
consistently to funding terms. 
Low Yes A full business
case will be
developed to
address the
team structure
and long-term
sustainability
of the team. 
Interim
Strategy &
Planning Lead
31/03/2024
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Appendix 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)
Comments Responsible
Officer
Timescale for
Implementation 
5.05 Petty cash reimbursement
claims submitted must be
based on actual expenditure
incurred and always reconcile
to the authorised petty cash
imprest for the section. 
Medium Yes Reconciliation
to the imprest
amount to be
actioned. 
Project
Manager
(Resettlement
& Refugees)
30/09/2023
5.06 Expenditure incurred through
the petty cash fund, other
than the cash Welcome
Payments, should comply
with Council procedure of no
single item exceeding £10.
Alternative standard
procurement routes should
be used for any higher value
purchases. Receipts for all
expenditure incurred should
be submitted with petty cash
reimbursement claims to
account for purchases and
ensure input VAT is
recovered where applicable. 
Medium Yes Purchase card
now issued
and
procedures in
place for
gaining
authorisation
to spend.
Training needs
identified for all
team members
and to be
recorded and
annually
reviewed. 
Interim
Strategy &
Planning Lead
01/12/2023
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Appendix 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)
Comments Responsible
Officer
Timescale for
Implementation  
5.07 To improve the audit trail, the
master record of hosts and
guests should be amended to
ensure the date of arrival
which is relevant to the initial
host payment calculation is
clearly recorded. 
Additionally, all payment
calculations which relate to
less than a full month of
hosting should be checked to
confirm accuracy prior to
payment processing. 
Low Yes This has been
addressed
within the
master
spreadsheet. 
Process is now
in place for
partial
payment
calculations to
be double-
checked prior
to host
payments
being made. 
Interim
Strategy &
Planning Lead
Implemented
5.08 Welcome Hub costs sought
for reimbursement by central
government should be
calculated based on actual
expenditure incurred and
require to be appropriately
Low Yes Meeting to be
held with
Finance to
close off
welcome hub
payments
Project
Manager
(Resettlement
& Refugees)
31/10/2023
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Appendix 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)
Comments Responsible
Officer
Timescale for
Implementation
evidenced.    appropriately
as Welcome
Hub no longer
exists. 
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