Agenda Document Pack - Corporate Committee - 04/11/2025
Moray Council · 4 November 2025
Back to Corporate Committee — 4 November 2025 and its agenda
Text extracted from the council's PDF. Layout and reading order may differ from the original.
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Corporate Committee Tuesday, 04 November 2025 NOTICE IS HEREBY GIVEN that a Meeting of the Corporate Committee is to be held at Council Chambers, Council Office, High Street, Elgin, IV30 1BX on Tuesday, 04 November 2025 at 09:30. BUSINESS 1. Sederunt 2. Declaration of Group Decisions and Members Interests * 3. Resolution Consider, and if so decide, adopt the following resolution: "That under Section 50A (4) and (5) of the Local Government (Scotland) Act 1973, as amended, the public and media representatives be excluded from the meeting for Items 16 - 19 of business on the grounds that it involves the likely disclosure of exempt information of the class described in the relevant Paragraphs of Part 1 of Schedule 7A of the Act.” 4. Minutes of meeting of 26 August 2025 7 - 12 5. Written Questions ** 6. Annual Procurement Report for 2024-25 Report by the Chief Executive 13 - 34 7. Information Governance Annual Report 2024-2025 Report by the Executive Director Economy, Enterprise and Operations 35 - 56 8. Annual Complaints Handling Annual Report 2024-25 Report by the Executive Director Economy, Enterprise and Operations 57 - 72 Page 1
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9. Unacceptable Customer Actions Policy Report by the Executive Director Economy, Enterprise and Operations 73 - 94 10. Property Performance Indicators Report Report by the Executive Director Economy, Enterprise and Operations 95 - 100 11. Performance Report - Financial Services - Period to September 2025 Report by the Chief Executive 101 - 106 12. Performance Report - GSP - Period to September 2025 Report by the Executive Director Education, Housing and Communities 107 - 112 13. Performance Report - HR ICT OD - Period to September 2025 Report by the Executive Director Education, Housing and Communities 113 - 120 14. Best Value Action Plan Review and Progress Reporting Report by the Executive Director Economy, Enterprise and Operations 121 - 142 15. Corporate Risk Register Update Report by the Executive Director Economy, Enterprise and Operations 143 - 172 Item(s) which the Committee may wish to consider with the Press and Public excluded 16. Voluntary Early Retirement Report [Para 1] • 1. Information relating to staffing matters; 17. Rent Rebate Keith • 4. Information relating to any applicant or recipient of any financial assistance provided by the Authority; 18. Public Trust Site in Forres [Para 9] • 9. Information on terms proposed or to be proposed by or to the Authority; Page 2
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19. Common Good Site in Forres [Para 9] • 9. Information on terms proposed or to be proposed by or to the Authority; Summary of Corporate Services Committee functions: To regulate, manage and monitor the finances of the Council both capital and revenue; to deal with staffing policies and practices other than for teaching staff; to deal with equal opportunities policies and practices; to deal with procurement policies and priorities; to deal with all matters relating to the Council’s duty to initiate, maintain and facilitate Community Planning; to ensure that the organisation, administrative and management processes of the Council are designed to make the most effective contribution to achieving the Council’s objectives; to provide all central support services; to exercise the functions of the Council in connection with the Registration of Births, Deaths and Marriages; to deal with valuation and electoral registration matters. 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. Page 3
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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. Page 4
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MORAY COUNCIL Corporate Committee SEDERUNT Councillor Marc Macrae (Chair) Councillor Kathleen Robertson (Depute Chair) Councillor Theresa Coull (Member) Councillor John Cowe (Member) Councillor Jérémie Fernandes (Member) Councillor Donald Gatt (Member) Councillor Sandy Keith (Member) Councillor Elaine Kirby (Member) Councillor Scott Lawrence (Member) Councillor Paul McBain (Member) Councillor Shona Morrison (Member) Councillor Bridget Mustard (Member) Councillor Derek Ross (Member) Councillor Draeyk van der Horn (Member) Councillor Ben Williams (Member) Clerk Name: Tracey Sutherland Clerk Telephone: 07971 879268 Clerk Email: committee.services@moray.gov.uk Page 5
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MORAY COUNCIL Minute of Meeting of the Corporate Committee Tuesday, 26 August 2025 Council Chambers, Council Office, High Street, Elgin, IV30 1BX PRESENT Councillor Theresa Coull, Councillor John Cowe, Councillor John Divers, Councillor Jérémie Fernandes, Councillor Donald Gatt, Councillor Sandy Keith, Councillor Elaine Kirby, Councillor Scott Lawrence, Councillor Marc Macrae, Councillor Paul McBain, Councillor Shona Morrison, Councillor Bridget Mustard, Councillor Kathleen Robertson, Councillor Derek Ross, Councillor Draeyk van der Horn IN ATTENDANCE The Chief Executive, Depute Chief Executive (Education, Communities and Organisational Development), Head of Governance, Strategy and Performance, Chief Financial Officer, Finance Manager, Susan Souter, Senior Accountant, Information Systems Manager, Equalities Officer, Information Governance Manager and Data Protection Officer and Democratic Services Manager. 1. Chair The meeting was chaired by Councillor Donald Gatt. 2. Declaration of Group Decisions and Members Interests In terms of Standing Orders 21 and 23 and The Councillors' Code of conduct the Council noted that there were no declarations for Group Leaders or Spokesperson 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. 3. Minutes of meeting of 10 June 2025 The minute of the meeting of 10 June 2025 was submitted and approved. 4. Written Questions The Committee noted that no written questions had been submitted. 5. Revenue Budget Monitoring to 30 June 2025 The meeting had before it, a report by the Depute Chief Executive (Economy, Environment and Finance) advising the Committee of the revenue budget monitoring position as at 30 June 2025 - Quarter 1 2025/26. Item 4. Page 7
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Councillor Keith queried the £5k that had been returned to the Council for the cleaning machine from Elgin Bid. He stated that the decision to spend that money was one made by the 6 Elgin Councillors from the Ward Budgets in 2023/24 and therefore the money should be available to the Elgin Councillors to re-purpose. In response the Head of Governance, Strategy and Performance confirmed that it would be acceptable for the Elgin Councillors to agree to spend the £5k in terms of the original Committee decision on how the Ward Budgets would be spent. This was agreed. Following further consideration, the Committee unanimously agreed: i) to note the budget monitoring position of £1,768,000 over budget for 2025/26 as at 30 June 2025; ii) to note that this position consists of an underspend on Devolved School budgets within Education of £48,000, an underspend in General Services Housing and Property of £149,000, an overspend of £535,000 in Environmental and Commercial Services, an overspend on Social Care and Children’s Services delivered on behalf of the Moray Integration Joint Board (MIJB) of £1,365,000, and overspends in other services of £65,000; iii) to note an increase of £65,000 in the General Revenue Grant, as detailed in paragraph 4.3; iv) to note the approach taken this year, using 2024/25 budget variances as a key starting point to identify recurring overspends and potential savings. Heads of Service have been tasked with developing plans to mitigate overspends and explore opportunities linked to changing service demands; and v) The 6 Elgin Ward Councillors to re-allocate the £5k returned from Elgin Bid in line with the original Committee decision on how ward budgets can be spent. 6. Capital Plan 2025-2026 Quarter 1 The meeting had before it, a report by the Depute Chief Executive (Economy, Environment and Finance) informing the Committee of the expenditure to 30 June 2025 under the capital plan for financial year 2025/26 and to recommend budget adjustments for inclusion in the Capital Plan for 2026/27 and future years. In introducing the report, the Finance Manager noted a couple of errors in the report and informed the Committee that: Para 6.7 should read £10.722m; and Para 6.8 should read £12.515m He apologised for the errors. Following consideration, the Committee unanimously agreed to: Page 8
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i) consider and note expenditure to 30 June 2025 of £4,054,000, shown in Appendix 1; ii) approve amendments of £22,280,000 to the 2025/26 capital plan as set out in section 6; iii) consider and note Appendix 2 – major capital projects spanning more than 1 financial year; and iv) consider and note the indicative affordability indicator for each year of the three-year 2025/28 capital plan, including changes to the recognition of certain financing costs brought about due to accounting treatment. 7. Trust Funds Summary Expenditure 2024-25 Estimated Disposable Income 2025-26 The meeting had before it, a report by the Depute Chief Executive (Economy, Environment and Finance) informing Committee of the disbursements made from Trusts in 2024/25 and the estimated disposable income available for disbursement in 2025/26. Councillor Gatt moved to increase the minimum disposable income to £100 and to carry forward undistributed funds each year until the disposable income reaches £100, this was seconded by Councillor Robertson. Following further consideration, and there being no one otherwise minded, the Committee unanimously agreed: i) to note the disbursements made from each of the Trust Funds in 2024/25 shown in Appendix 1; ii) the estimated income available for disbursement in 2025/26 shown in Appendix 2; and iii) to increase the minimum disposable income to £100 and to carry forward undistributed funds each year until the disposable income reaches £100. 8. Best Value Action Plan Review and Progress Reporting The meeting had before it, a report by the Depute Chief Executive (Education, Communities and Organisational Development) asking Committee to consider a revised Best Value Action plan taking account of progress against the actions in the previous plan and the outcome of the self-assessment undertaken in June 2025. Following consideration, the Committee unanimously agreed: i) to approve the refreshed Best Value Action Plan taking account of progress against the actions in the previous plan and the outcome of the self- assessment undertaken in June 2025 (Appendix 1); and Page 9
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ii) that the PSIF framework is used for the corporate annual self assessment from 2026 onwards. 9. Best Value Transformation Thematic Review The meeting had before it a report by the Depute Chief Executive (Education, Communities and Organisational Development) informing the Committee of the outcomes from the Best Value Transformation Thematic review and invite consideration of the findings and actions to respond to them. Following consideration, the Committee unanimously agreed to note the findings of the Best Value Transformation Thematic Review. 10. Transformation Strategy Development The meeting had before it, a report by the Depute Chief Executive (Education, Communities and Organisational Development) asking Committee to consider and note progress on the delivery of the Council's Transformation Strategy since the last report on 10 June 2025, as part of the ongoing monitoring of progress. Following consideration, the Committee unanimously agreed to note progress on the delivery of the Council's Transformation Strategy. 11. Employee Survey 2025 The meeting had before it a report by the Depute Chief Executive (Education, Communities and Organisational Development) informing the Committee of the results from the Employee Survey 2025 which was live from 10 March - 4 April 2025. Following lengthy consideration, the Committee unanimously agreed to: i) note the results of the 2025 employee survey, planning process and progress made; and ii) approve the planned actions arising. Councillor Mustard left the meeting at the conclusion of this item. 12. Workforce Planning Report The meeting had before it a report by the Depute Chief Executive (Education, Communities and Organisational Development) informing the Committee of the progress made against the corporate workforce and organisational development strategy and plan for the period 2024-2025 and to consider the refreshed 2025-2026 action plan. Following consideration, the Committee unanimously agreed to: i) note the progress made against the 2024/25 workforce plan; and ii) approve the proposed workforce plan for 2025-26 as set out in Appendix A. Page 10
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13. Mainstreaming Report and Equalities Outcomes Update The meeting had before it, a report by the Depute Chief Executive (Economy, Environment and Finance) presenting the Councils equalities mainstreaming report, provide a progress update against the Council's previously published 2021-25 equality outcomes and propose new equality outcomes for 2025 - 2029. Following consideration, the Committee agreed to: i) note the Mainstreaming Report and Equalities Outcomes 2021 - 2025 progress update (Appendix I); and ii) approve the proposed Equality Outcomes for 2025 - 2029 (Appendix II). 14. Digital Strategy 2025 - 2028 The meeting had before it a report by the Depute Chief Executive (Education, Communities and Organisational Development) asking Committee to approve the proposed Digital Strategy and Plan for 2025 - 2028. Following consideration, the Committee unanimously agreed to approve the Digital Strategy 2025 - 2028 and Action Plan 2025 - 2026. 15. Data Protection Policy v2.0 The meeting had before it a report by the Depute Chief Executive (Education, Communities and Organisational Development) requesting that Committee consider and approve an updated Council wide Data Protection Policy version 2.0. Following consideration, the Committee unanimously agreed to approve the updated Data Protection Policy as set out in Appendix 1 and summarised in Section 4 of the report. 16. Community Council Scheme of Establishment The meeting had before it, a report by the Depute Chief Executive (Education, Communities and Organisational Development) inviting the Committee to consider and approve the proposed Moray Council Scheme of Establishment of Community Councils 2025-2029 following a period of review. Following consideration, the Committee unanimously agreed: i) the amendments to the Scheme for the Establishment of Community Councils following the 2nd round of consultation as detailed in Appendix I; and ii) the amended election timetable as detailed in Appendix II. Page 11
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Report to: Corporate Committee Meeting Date: 4 November 2025 Report by: Chief Executive Author: Jamie Fraser Contact Email: jamie.fraser@moray.gov.uk Subject: Annual Procurement Report 2024/25 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to submit to the Committee the annual procurement report (annual report) for 2024/25. This report is prepared in line with our duties under the Procurement Reform (Scotland) Act 2014 (the Act). Once approved by the Committee a copy of this report will be provided to the Scottish Government and a copy published on the Moray Council website for public access. 1.2 This report is submitted to Committee in terms of Section III (B) (21) of the Council’s Scheme of Administration relating to procurement arrangements. 2. SUMMARY 2.1 This report provides the annual procurement report for Moray Council for the period 1 April 2024 to 31 March 2025. APPENDIX 1. 3. RECOMMENDATIONS 3.1 It is recommended that Committee consider and note the annual procurement report, APPENDIX 1, for the financial year 2024/25. Jamie Fraser Service Manager Strategic Finance 4. BACKGROUND AND CONTEXT 4.1 The Act requires public bodies with an annual expenditure of over £5m to publish an annual procurement report and prepare an annual procurement strategy. To meet the Item 6. Page 13
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Council’s duties under section 18 of the Act, the procurement team has prepared the annual procurement report for 2024/25. 4.2 The procurement team continues to work closely with accountancy to streamline processes and maintain oversight of project planning and expenditure with the aim of working closely with lead officers early in on in their projects. The aim for this is to ensure procurement processes are completed with enough time to achieve best value for money and a focus on savings in consideration of the current budgetary pressures. 4.3 From January 2025 the procurement team adopted a category management model. This model aims to focus procurement resource – allowing for more specialisation in key procurement areas such as construction, engineering and health and social care. 5. PROPOSALS 5.1 The annual report, APPENDIX 1, provides detail of procurement spend, including the results of performance against agreed Council procurement objectives. It also sets out a review of its Strategic Action Plan Review for the year including the Strategic Action Plan for future years. Finally, it provides an update on the planned procurement activity for 2025/26. 5.2 The Council uses its spending power through goods, works and services to make Moray a great place to work and do business. The Council’s procurement strategy details six procurement objectives. The results of 2024/25 procurement activity measured against each of these objectives is summarised below: Procurement Objectives 1. Savings ▪ Total recurring savings achieved for 2024/25 £1,389,000 (£1,000,000 target) ▪ Total non-recurring savings achieved for 2024/25 £1,224,000 (nil target) 2. Contracts ▪ There were 242 (55%) unplanned procurement activities during the year 3. Compliance ▪ 76.65% (75% target) of accounts payable transactions with a purchase order number during the year 4. Accessibility ▪ 50.50% value of annual spend with SMEs during the year 5. Community benefits ▪ 262 contracts commenced during the year which have a non-cash benefit by category 6. Sustainability ▪ 4.08% of contracts commenced during the year which have a sustainable target 5.3 Savings: The Council has had a savings target of £1m for a number of years. As contracts are re-let it becomes harder to deliver on cash savings particularly in the current inflationary market. Total recurring savings for 2024/25 were £1.389m which exceeded the annual target. Total one off savings in the year were £1.224m. Page 14
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5.4 Contracts: The departmental action plans and forward plans were developed and completed within required timeframes. In the year 242 (55%) unplanned procurement were processed in the year, falling short of the target of 25%. Work is currently being undertaken as part of the move to a category management procurement model to address this, with improvements anticipated from 2025/26. 5.5 Compliance: 76.65% of all accounts payable transactions were completed in the year with a purchase order number. This exceeds the target of 75%. 5.6 Accessibility: 50.50% of annual spend procured was with SMEs. This is lower than the target of 55%. Much of this is driven by market conditions and supplier availability, however early work has begun on a more ‘grass-roots’ approach to supplier development and better collaboration with local partners including Business Gateway. 5.7 Community benefits: 89% (target 85%) of contracts commenced during the year had a non-cash benefit by category See Table 3, Appendix 1. 97% of these contracts had savings in procurement time (the resource required to procure the goods and service) and 57% had living wage and fair work first benefits. 5.8 Sustainability: Only 4.08% of contracts commenced during the year included a sustainable target. This falls short of the target of 20%. Work will continue exploring how future procurements can include sustainability elements, however a revision of the target may be required given the continual market challenges in meeting the goal. Any revision in target will be discussed fully with the Climate Change team. 6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X Policy and Legal 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)) 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. Page 15
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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 The Moray Council procurement policy has not been reviewed since 2007 and will be reviewed as a PSAP activity in 2025/2026. The aim for this review is to align with the broader statutory requirements, support the annual procurement report process and provide clear controls for procurement activities, in line with Moray Council and Scottish Government regulations. 6.4 Financial There are no direct financial implications as a result of this report. Procurement forms a key role in achieving value for money for Moray. 6.5 Risk The council must meet the legislative requirements of the Act, including those relating to the procurement strategy. Failing to maintain a procurement strategy may impact on the council’s ability to meet legislative requirements, achieve savings and benefits in the future. 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. Page 16
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7. CONSULTATION 7.1 This report has been prepared in consultation with extended CLT and any comments made have been incorporated into the report 8. BACKGROUND PAPERS 8.1 Held within Procurement section. Page 17
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APPENDIX 1 MORAY COUNCIL ANNUAL PROCUREMENT REPORT 2024/25 Page 18
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1 Contents 1 Introduction ....................................................................................... 2 2 Summary of regulated procurements .................................................. 3 3 Review of procurement compliance .................................................... 3 4 Community benefits and the real living wage ....................................... 6 5 Payment performance ........................................................................ 7 6 Supported businesses summary ......................................................... 7 7 Spend and savings summary .............................................................. 7 8 Future regulated procurements .......................................................... 9 9 Appendices ........................................................................................ 9 Appendix A – Procurement Targets....................................................... 10 Appendix B – Strategic Action Plan Review of 2024/25 .......................... 11 Appendix C – Strategic Action Plan for 2025/27 .................................... 13 Appendix D – Planned Procurement Activity for 2025-2026 ................... 14 Page 19
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2 Introduction As a public sector authority with an annual spend greater than £5 million, Moray Council is required to produce an annual procurement report according to Section 18 of the Procurement Reform (Scotland) Act 2014 (Act). This annual procurement report covers the period from 1 April 2024 to 31 March 2025. This report details how the council has complied with its obligations under the Act, and provides a summary of the council’s procurement activities within the reporting period, detailing how these have aligned with the Council’s procurement strategy for 2023- 2026. The Council’s procurement activities are conducted according to the Act, which establishes the statutory and legislative framework for sustainable public procurement that supports Scotland’s economic growth. The Council uses its spending power through goods, works and services to make Moray a great place to work and do business. The Council’s procurement strategy details six objectives for procurement: 1. Savings 2. Contracts 3. Compliance 4. Accessibility 5. Community benefits 6. Sustainability The procurement strategy aligns with the corporate plan that sets the vision and priorities of the council. This vision is of a Moray where people, prosper, free from poverty and inequality; young people grow up safe, well-educated and reach their full potential; people lead healthy lives and have access to quality care when they need it; businesses and communities prosper; and the natural environment thrives for the betterment of all. The Council continues to face significant operational challenges due to increased demand for services alongside reduced budgets. To secure the best outcomes for the Council and therefore Moray citizens, the procurement team works closely with departments to plan and streamline processes in order to secure savings. The procurement team is dedicated to improving good outcomes for Moray and acknowledges the broader role of procurement in supporting service delivery and realising Council priorities. Page 20
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3 Summary of regulated procurement completed The table below provides a summary of the number and value of live contracts in 2024/25 by contract category. This is comprised of awards under local and national frameworks which includes new requirements, extensions and re-tenders and/or collaborations with other public bodies. Table 1 – Summary of regulated procurement completed Contract Type Quantity Estimated annual value Category A (National) 26 £8,997,184 Category B (Sectoral) 167 £57,168,931 Category C (Local Single Supplier) 180 £37,497,139 Category C (Framework) 10 £19,655,004 Category C1 (Local Collaboration) 10 £636,495 Category O (Other) 163 £16,734,258 Non advertised 28 £2,695,332 Quick quotes (under £50,000) 65 £1,344,681 2024/2025 Total 759 £178,219,710 In total there were 759 contracts listed on the Council’s contract register in the reporting period. There were 452 unique suppliers and of these unique suppliers a total of 326 were SMEs. There were 294 regulated procurements in the reporting period at an estimated total value of £62,480,000. In addition to this, there were 26 quick quotes published on the Public Contracts Scotland (PCS) portal in order to source competitive quotes for low value/low risk procurement exercises (below £50,000). To provide transparency of contracts held by the council, we publish a contract register on our public website which contains information on live contracts, and is regularly updated to include new awards. Review of regulated procurement compliance Section 17 of the Act requires the Council to carry out regulated procurement activity in accordance with the Council’s procurement strategy. The Moray Council procurement strategy 2023-2026 includes our procurement responsibilities in line with the Act and details our commitment to ethical procurement, community benefits, health and safety, living wage and a positive workforce culture. The vision statement is to: “To embed commercial excellence throughout the organisation, ensuring that our services always deliver Best Value for Moray through the consistent application of this strategy, embedding community benefit and climate focus in our procurement processes to deliver the corporate priorities of Tackling Poverty and Inequality, Building a Stronger, Greener, Vibrant Economy and Building Thriving, Resilient, Empowered Communities, supporting an economy based on well-being and inclusion.” Page 21
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4 In addition to the Council’s procurement strategy and procurement policy, the Council’s procurement procedures detail the procedures that must be followed by all staff when procuring/purchasing goods, services and works. Procurement support is required for all regulated procurements over £50,000, and quick quotes (under £50,000) are reviewed before publication. This level of advice and oversight ensures compliance with regulation and legislation, with procurement limits determining the procurement pathway: • Up to £10,000 = Best price • £10,000 to £50,000 = Quick quote • £50,001+ = Regulated tender for goods and services • £2,000,000+ = Regulated tender for works A summary of progress against the Council’s six procurement objectives is summarised in Table 2 below, with further detail provided at Appendix A. These procurement measures aim to support and evidence the delivery of the procurement strategy. Table 2 – Summary of procurement strategy objectives and achievements 1. Savings ▪ Non-cash benefits that have been included in contracts awarded in the year – Table 3 below. ▪ Total savings achieved for 2024/25 = recurring (£1,389,000) and actual (£1,224,000) – Table 4 below 2. Contracts ▪ The annual departmental action plan was completed in January 2025and forward plans were developed with the departments ▪ There were 242 unplanned procurement activities during the year 3. Compliance ▪ 76.65% of accounts payable transactions with a purchase order number during the year 4. Accessibility ▪ 52.23% value of annual spend with SMEs during the year 5. Community benefits ▪ 262 contracts commenced during the year which have a non-cash benefit by category 6. Sustainability ▪ 4.08% of contracts commenced during the year which have a sustainable target ▪ Non-cash benefits The Council considers a range of non-cash benefits when developing tender specifications that is wider than the social, environmental or economic factors (also Page 22
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5 referred to as community benefits) required under the Act. This is summarised in Table 3 below which includes added value benefits such as process efficiencies and price stability. The Act only requires community benefits inclusion in tenders with a value of over £4 million, however the Council considers inclusion wherever possible in all procurement activities. Table 3 – Non-cash benefits Benefit Category No. of contracts Sub-category Collaboration/tender process 254 241 in procurement development time 12 digital processes 1 insourcing Cost avoidance 15 4 added value 3 price increase rejection 4 price vs. market savings 1 cost removal 2 process redesign 1 early payment discount Purchase to pay process 9 7 e-invoicing 2 consolidated billing Demand/rationalisation 9 6 specific contract issues 3 rebates Community 43 7 apprentices 6 school visits 22 training 8 other – wide ranging Environmental 19 8 greenhouse gases 4 waste 2 energy 5 sustainable construction Social 11 4 sub-contracting programme 5 fair work issues 2 other – wide ranging Living wage and fair work first 148 33 accredited 5 working to accreditation 90 paying living wage 6 not paying living wage but will commit to pay within contract 14 neither paying or accredited Page 23
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6 Procurement Strategic Action Plan (PSAP) The Council’s procurement strategy sets out how procurement activity will be undertaken in line with Council plans, policy and duty under the Act. Given the often- changing requirements, an annual Procurement Strategic Action Plan (PSAP) is developed to track and monitor activities. A review of the 2024/25 PSAP activities are provided at Appendix B. The PSAP for the next two years (2025 to 27) is provided at Appendix C. Community benefit summary The Council is committed to maximising community benefits from procurement activities along with delivering wider benefits for the community when purchasing goods, services and supplies for Moray. As detailed in Section 3, the Council considers a wide range of non-cash benefits when developing a tender specification that is broader than the community benefits that is required by the Act. The Act requires community benefits inclusion in tenders with a value of over £4 million, however Moray considers inclusion wherever possible in all supported tenders over £50,000. The Council has a community wealth building strategy which, as a progressive economic approach, aims to retain and circulate wealth within local communities. The Procurement Team remains a partner to the objectives of growing the percentage of procurement spend with Moray-based suppliers from each anchor institution, increasing anchor spend with community led or third sector businesses, and supporting delivery of fair work first through anchor spend. Total number of regulated contracts awarded with a value of £4 million or greater 5 Total number of regulated contracts awarded with a value of £4 million or greater that contain Community Benefit Requirements 2 Total number of regulated contracts awarded with a value of less than £4 million that contain Community Benefit Requirements 24 The Council secured living wage accreditation in September 2022 and continues to encourage the real living wage within the supply chain through its procurement activities. In the reporting period there were 134 contracts awarded that were either accredited living wage, working towards accreditation, already paying the living wage, or committed to paying the living wage. Page 24
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7 Supported businesses summary Public organisations can reserve the right to participate in procurement for the award of a public contract/framework to a supported business. Supported businesses are organisations with the main aim of integrating disabled or disadvantaged persons and where at least 30% of those employed and engaged with the programme have a disability or are disadvantaged. The Council spent an estimated total of £1,238,000 with the following supported businesses in the reporting period: • Moray Reach Out (Training Places & Waste Watchers) = £444,329 • Out of the Darkness = £151,811 • Living Ambitions (Previously Lock Park Rural Skills = £630,216 • Scotland’s Bravest Manufacturing Company = £1,396 • Hey Girls = £9,705 • Scott Direct = £607 Not all of these suppliers formally meet the supported business employment criteria under the Act, but they meet the engagement element, and the Council is confident that the use of these suppliers goes some way to meeting the Act requirements. Payment performance Spend and savings summary The current economic climate continues to produce uncertainty in the supply chain and increased demand on certain markets. The procurement team continues to progress 66,769 valid invoices received during the reporting period 92.21% of valid inovices received during the reporting period were paid on time 294 regulated contracts awarded during the reporting period contained a contract term requiring prompt payment of invoices in public contract supply chains Page 25
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8 some tenders without any response to our publications, but we navigate these challenges by working closely with departments to provide the support they need. Total procurement spend during the reporting period £139,529,112 Total procurement spend with SMEs during the reporting period £82,536,420 Total delivered cash savings delivered for the period of the report £832,591 The Council records the cash (Table 4 below) and non-cash benefits (Section 3) of contracts along with recording cash savings under the following categories: 1. Cash saving anticipated – but budget not adjusted 2. Cash saving anticipated – budget adjusted 3. No baseline – savings cannot be established, review of contract on anniversary of award to reassess 4. No savings anticipated 5. Non-cash benefits 6. Capital – projects delivering savings against estimate/budget, total saving taken in the year the project was awarded 7. Rebate – centralised collection of contract rebates Table 4 – Cash savings Category Recurring savings Annual savings Recurring savings Annual savings 2023/24 2024/25 Budget not adjusted £791,405 £654,056 £526,825 £391,127 Budget adjusted £937,906 £870,448 £861,778 £832,591 Total £1,729,311 £1,524,505 £1,388,603 £1,233,718 Capital N/A £879,097 N/A £462,207 Rebate N/A £76,107 N/A £81,570 Overall cash savings recorded for 2024/25 are contained in the report and detailed in the table above. The Council has maintained a savings target of £1 million for a number of years in the expectation that it would become harder to achieve savings from recurring contractual award. As the Council re-lets contracts it becomes harder to deliver on cash savings particularly in the current inflationary market. Page 26
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9 These savings are calculated using the estimated values at point of contract award. The values are only amended for any annual increases applied to long term service contracts, if the team are made aware of such changes. Maintaining the value for budget adjusted makes the most difference to the Council’s budget. However, any category of saving achieved from the procurement process means that the contract starts from a much better position and even if increases are imposed, they start at a lower level. Given the challenges outlined above it is encouraging that savings continue to be made at a significant level. Future regulated procurements The procurement team commenced work with Heads of Service within the reporting period to develop a departmental action plan (DPAP) for their service area that maps the Council’s procurement activity for the years ahead. In January 2025 the procurement team launched a new procurement support model for the Council, which included a refreshed DPAP process. The new category management approach to supporting departments aimed to increase engagement, drive financially secure outcomes and reduce unplanned procurement activities. The DPAP is no longer a static source of information completed at the start of the financial year, and now a live source of information about procurement activities that is populated through a rolling series of engagement/partnership between procurement and service areas. The DPAP includes information from the expiring contract register, capital works plan and other projects to inform the forward plan at Appendix D and which can also be found on the Council website. The publicly available Forward Plan and the Capital Plan informs the market of the Council’s intentions but cannot guarantee that all projects listed will result in a competitive tender. It also directs attention to those projects that may benefit from climate change and a community wealth building focus. Between April 2025 to 2027 the council is estimated to have: • Number of contracts expiring in the period = 260 • Total estimated value of these expiring contracts = £301,111,446 The above statistics are taken from the contract register. This list contains all contracts with an end date between April 2025 to March 2027, however it should be noted that some may be subject to possible extensions, and some may not be re-let. Decisions about the direction for each requirement are taken during the annual planning process with Heads of Service. Page 27
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10 Appendices Appendix A – Procurement Targets Savings measure Target Achieved 2023/24 Achieved 2024/25 1 Percentage of all council expenditure covered by contracted suppliers 95% 99.25% 91.01 2 Value of procurement savings achieved through contracts live during the year £1million £1.729M £1.389M 3 Number of collaborative contracts awarded as a percentage of all commenced in year 40% 55.30% 46.94% 4 Percentage of contracts (including call off from framework) commenced in year that contain a contract benefit (all categories) 85% 96.97% 89.12% 5 Percentage of unplanned contract activity during the year 25% 53.65% 55.00% 6 Percentage of account payable transactions with a purchase order (where relevant ie non- recurring) number during year 75% 75.87% 76.65% 7 Percentage of contracts (excluding call offs) commenced during year to SMEs 30% 32.20% 15.99% 8 Percentage value of annual spend with SMEs for year 55% 50.50% 52.23% 9 Percentage value of spend with Moray, Highland and Aberdeen council areas 50% 43.90% 43.79% 10 Number of “events” held or participated in during year 10 9 6 11 Percentage of commenced contracts within the year that have a community benefit 20% 10.98% 8.84% 12 Percentage of collaborative contracts commenced in the year that have a community benefit 20% 8.33% 6.46% 13 Percentage of contracts commenced in the year that have incorporated a sustainable target 20% 5.68% 4.08% 14 Score on Scottish Government Flexible Framework for Sustainability. Level 3 (Practicing) Level 3 (Practicing) Level 3 (Practicing) Page 28
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11 Appendix B – Procurement Strategic Action Plan review, 2024/25 Action Progress 1 To develop existing contract register to improve data access and meet statutory/council requirements Testing and development has continued after a temporary pause at the end of 2024 due to competing priorities. The project restarted in January 2025 and the new contract register is on track for launch at the end of 2025. 2 Review and update the procurement procedures to reflect the inclusion of commissioning teams within Health and Social Care and children’s services The new procurement support model has led to a change in approach with commissioning teams. We have spent time establishing relationships under a category management model, so these activities have been put on pause until we identify if there are any areas needing resolution. 3 Review the requirement for Integrated Impact Assessments for each contract Currently being considered, and process to action any new requirements planned for Q1 2026/27. 4 Review the GDPR requirements and review impacted areas The procurement team worked with Moray Council data advisors to address requirements and update the standard form terms and conditions. 5 Prepare and publish the Council’s annual procurement strategy including continued alignment with ethical procurement, modern slavery, CWB, fair work and other requirements Complete Q4 6 Review the internal project procurement strategy (PR08) to facilitate planning, options and alignment with strategic objectives, and responsibilities under the statutory framework First stage review complete and project assigned to project team for progression in 2025/26. 7 Review and develop a new departmental action plan process, exploring options to further plan procurement activity and focus on savings through streamlining process. Complete. New model launched in January 2025 after substantial research and development in 2024/25. Early feedback has been resoundingly positive. 8 Review the procurement savings strategy, contract register and data capture to align with statutory reporting requirements Deferred to 2026/27 to align with the development of the new 3-year procurement strategy 9 Review the contract register and data capture to align with statutory reporting requirements Deferred to 2026/27 to align with the development of the new 3-year procurement strategy 10 Investigate options for a new e-signing process Complete. Options have been presented to internal, Moray Council stakeholders 11 To support and deliver requirements identified in the climate change action plan and align with the Ongoing and considered complete for this year. Met with Principal Climate Change Strategy Officer in 2025 to discuss activities and how to align approach Page 29
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12 Scottish Government statutory framework on climate change 12 Research/investigate scope for including cyber security requirements in procurement processes Initial research complete and consultation with other local authorities continues. 13 Health & Social Care (MIJB) support Ongoing and considered complete for this year as the new procurement support model provides more bespoke service support Page 30
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13 Appendix C – Procurement Strategic Action Plan, 2025 to 2027 2025 to 27 1 Review the Council procurement policy and associated procedures 2 Review the requirement for Integrated Impact Assessments for each contract 3 Continue to action objectives under the Community Wealth Building Strategy 4 Review and update the procurement procedures to reflect the inclusion of commissioning teams within Health and Social Care and children’s services 5 Prepare and publish the Council’s new procurement strategy after the expiry of the 2023 to 2026 procurement strategy 6 Review the procurement savings strategy, contract register and data capture to align with statutory reporting requirements 7 Launch the new internal project procurement strategy (PR08) to facilitate planning, options and alignment with strategic objectives, and responsibilities under the statutory framework 8 Review the contract register and data capture to align with statutory reporting requirements 9 Research/investigate scope for including cyber security requirements in procurement processes Page 31
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14 Appendix D – Planned Procurement Activity for 2025/26 Contract name Estimated Project start Alves Primary School – Roof, Fabric & Window Upgrades to Decarbonise Existing Building Q2 Estates/Property Surveying Services Q2/3 Feasibility Study – Landscape Architect Q2 Education for All Flexible Framework Open Window and Door replacement in housing stock Q2/3 eICR (Electrical Installation Condition Reports) for Social Housing Stock TBC BEMS (Building Energy Management System) Servicing and Maintenance Q2 Community Asset Framework Q2 Void Cleaning Q2 Children & Young People’s Community Mental Health & Wellbeing support ( 5-25 years) Q1 Pinegrove Housing Upgrades Q2/3 Bezack Street Housing Upgrades Q3/4 Glazing Maintenance TBC Airsource Repairs and Servicing Q2/3 Open Spaces and Tree Surgeons (cutting grass) Q3 Fire Risk Assessments of Common Parts of Residential properties Q2 School & Public Transport Services Q3 Large Coach, School, Public and Community Transport Services Q3 Smaller Vehicle, School, Public and Community Transport Services Q3 School Transport (3 Routes) Q3 Fresh Meat - Supply and Delivery Q2 Headstone Stability Q3 Small Value framework Q2 Haulage for NESS Energy for Waste (EfW) TBC Shredder Maintenance TBC Skip Maintenance TBC Linkwood Road, Elgin Realignment and Refuge Q2 Cycle Parking across Moray Q2 Early Learning and Childcare Provision - Reopening of Framework Q1 Family Support Services Q2 EES:ABS (Energy Efficient Scotland: Area Based Scheme) Management Agent Q2 Maintenance of Fitness Equipment - Leisure Services TBC Design and Build of Salt Barn, Keith TBC Employability Services Q3 Roof Replacements Q3 Asbestos Competent Assistance Q3 Energy Performance Certificates Non Domestic Properties TBC UPS (Uninterruptible Power Supply) Battery Maintenance Q3 Sprinkler Maintenance Q4 Boiler replacement at Forres Community Centre TBC Burghead Primary School Fabric Upgrade and Mechanical and Engineering Q4 Page 32
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15 Contract name Estimated Project start Clerk of Works for Bilbohall TBC Corporate Fencing TBC Damp and Mould - Housing TBC Dyke Primary School Fabric Upgrade and Mechanical and Electrical Q3 Employers Agents Q3 Greenwards Playpark Design Q4 LED Lighting TBC Stock Condition Survey 2026 Q4 Tenants Survey Q4 Building Repair and Maintenance Q3/4 Gas Safety Audits Q4 For National and Sectoral contract opportunities outwith Moray Council please see https://www.publiccontractsscotland.gov.uk/helpandresources/forwardplan Page 33
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Report to: Corporate Committee Meeting Date: 4 November 2025 Report by: Executive Director Economy, Enterprise and Operations Author: Alison Morris Contact Email: Alison.morris@moray.gov.uk Subject: Annual Information Governance Report (2024/25) 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to inform the Committee about Information Governance (IG) activities within the Council, and in particular on improvements, made for 2024/25. The report also confirms the existing Data Protection Policy has been updated. 1.2 This report is submitted to Committee in terms of Section III (B) (40) of the Council’s Scheme of Administration relating to ensuring suitable framework is in place for performance management across the Council. 2. SUMMARY 2.1 The updated Annual Information Governance Report 2024/25 highlights the ongoing IG compliance and challenges across the Council. 3. RECOMMENDATIONS 3.1 It is recommended that the Committee considers and notes the current Information Governance compliance for 2024/25 as set out in the Annual Report in APPENDIX 1 and summarised in Sections 4 and 5 below. Alison Morris Information Governance Manager and Data Protection Officer Item 7. Page 35
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4. BACKGROUND AND CONTEXT 4.1 Information Governance primarily focuses on Data Protection (DP), Records Management (RM) and Access to Information requests. The Information Governance (IG) Team supports the Council in maintaining compliance with information legislation, and, its promotion of good recordkeeping; ensuring that the Council’s information assets remain secure, relevant and accessible. This applies to the management of all information, in all formats, which the Council may collect, create, handle, store, share, erase, process, archive, and manage in any way. 4.2 The IG team are responsible for the development, implementation and monitoring of corporate IG and RM strategies, policies and statutory obligations across the Council, Licensing Board and MIJB. 4.3 The IG Team comprises of 2.7 FTE posts: Information Governance Manager and Data Protection Officer, Information Governance Officer and Information Co-ordinator. This staffing complement is small when benchmarked against other local authorities. 4.4 The IG Team play a vital role in managing the information risk of the Council. Whilst some IG issues are reported through service performance reports it is considered appropriate, given the organisational risk, for the Council to receive an annual report on IG. This report is attached as Appendix 1 with highlights given in Section 5 below: 5. HIGHLIGHTS FROM THE COUNCIL’S INFORMATION GOVERNANCE REPORT 2024/25 5.1 Data Protection To ensure the Council complies with Data Protection obligations; policies, procedures and guidance for the effective management of personal data are in place at both corporate and service levels, supported by training and awareness activities. The Council has Data Sharing or Data Processing Agreements (DSA/DPA) with external parties, and, Privacy Notices (PN) are published to inform data subjects how their personal data is processed. Furthermore, the Council has a register of Data Protection Impact Assessments (DPIAs), which are used to identify the data protection risks of a project or process, as well as a Record of Processing Activities (ROPA) and Information Asset Register (IAR). 5.2 • 188 DPIAs were reviewed in 2024/25 (an increase of 54 on 2023/24) • 41 new or updated PNs have been added to the Council’s website (over double the amount from 2023/24) • 30 agreements, such as DSA and DPAs, were reviewed and assisted on (an increase of 30% on 2023/24) 5.3 All staff within the Council should receive DP training and all data breaches (situations where personal data has/may have been mishandled) require to be reported to the IG team. • 114 data breaches were reported and internally recorded (21 fewer than 2023/24) • 3 breaches were reported to the Information Commissioner’s Office (ICO) (same as 2023/24) Page 36
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Lessons are learnt from all breaches reported, in the anticipation this will assist with avoiding repeat, or, more serious breaches. 5.4 Outwith the 2024/25 timescales please note: • The Council’s Data Protection Policy has been updated; the companion DP Guide and online DP training module will now also be updated. • The Data (Use and Access) Act (DUAA) 2025 was passed by Parliament June 2025. DUAA will gradually come into force over the next year; amending but not replacing the current DP legislation. The IG Team will follow new national guidance and ensure the requirements of this new Act are met in the council’s policies and practices. 5.5 Record Management The Public Records (Scotland) Act 2011 requires the Council to have a Records Management Plan (RMP). RMPs are resubmitted or updated every 5 years. The most recently submitted RMP (Dec 2020) is currently being reviewed by the National Records of Scotland (NRS). An interim report from NRS highlighted their primary concerns as: • Resourcing levels. • Long term archival arrangements and resourcing. • Having an appropriate system for records management across all council sections. Whilst Microsoft SharePoint fulfils this for a number of sections it was not rolled out across the whole Council and M365 is not implemented to the level required. A letter from NRS regarding their concerns is anticipated for Autumn 2025. 5.6 The Council’s Closed Records Store (CRS) covers 3 different sites and there have been previous discussions with Property Services regarding finding a suitable long-term solution for the CRS. • Over 450 new boxes were accessioned into the CRS, whilst approximately a quarter of that amount were securely destroyed. 5.7 Access to Information Requests The majority of requests are proactively published on the Council’s website, and, stats provided to the Scottish Information Commissioner’s Office. In 2024/25 there were: - 1,294 Freedom of Information (FOI) requests, - 19 FOI Review requests, and, - 31 Environmental Information Requests (EIRs). 94% of FOIs and 97% of EIRs were dealt with within statutory time limits; a 1% decrease and 8% increase respectively on 2023/24’s response rates. Page 37
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5.8 The ICO is concerned that Scottish Councils are currently not meeting the statutory timeframes for the completion of Subject Access Requests (SARs), so they have been requesting quarterly statistics as well as auditing and reprimanding Scottish Councils with poor compliance rates. Due to the Council’s positive compliance rate the ICO’s demand for quarterly statistics has reduced to an annual submission. - 101 SARs received, 97% responded to within the statutory timescales. 5.9 In 2024/25 over 2,000 hours of Council staff time was taken responding to Access to Information requests: - Over 1,870hrs for FOI and EIRs, and, over 350hrs for SARs 6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X Policy and Legal 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)) 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. 6.3 Policy and Legal None 6.4 Financial There are no financial implications arising from this report, however, the promotion and implementation of effective IG compliance impacts positively on the Council’s ability to mitigate its exposure to financial risk, particularly monetary penalties levied by the ICO for non-compliance. For serious breaches of Data Protection legislation the ICO have the power to issue fines of up to £17.5 million. Page 38
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6.5 Risk The Council does not currently have an approved RMP with particular risk around Archive storage and suitability of council document management systems. Work is underway to ensure these issues and potential solutions are brought before the Central Leadership Team for consideration of a corporate response. There remains a risk over compliance with Data Protection legislation in relation to completing an update and documentation of processing activity and updating of policies. Activities have been prioritised to tackle higher risk areas first. 6.6 Staffing Increased workloads are impacting on the ability of the small team to respond to requests for support from services and keep pace with compliance demands. The team currently prioritise requests and tasks, with statutory obligations taking highest priority. 6.7 Best Value and Transformation None 6.8 Property The Council’s Closed Records Store need of a long term solution. 6.9 Information Communications/Technology/Digital None 6.10 Equalities, Social Inclusion and Economic Impact None 6.11 Climate Change and Biodiversity Impacts None 7. CONSULTATION 7.1 This report has been prepared in consultation with Executive Director Economy, Enterprise and Operations, Chief Governance Officer, Service Manager Democratic Services and the Council’s Information Assurance Group and any comments made have been incorporated into the report 8. BACKGROUND PAPERS 8.1 Appendix 1: Annual Information Governance Report 2024/25 Page 39
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APPENDIX 1 Information Governance Annual Report 2024/25 Version 3.0 2025 Page 40
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Document Control Sheet Date of Creation: September 2025 Owner (Service): Information Governance Manager & DPO Reviewer Head of Service: Chief Governance Officer (Monitoring Officer) Approver Executive Director: Executive Director for Economy, Enterprise and Operations Date Approved: Approver (Committee): Corporate Committee Date Approved: Next Review Date: Version History Version Date Author Changes Made Approved By 1.0 Nov 2023 Information Governance Manager & DPO Initial document for 2022/23 Corporate Committee 2.0 Aug 2024 Information Governance Manager & DPO Updated for 2023/24 Corporate Committee 3.0 Sept 2025 Information Governance Manager & DPO Updated for 2024/25 Contents 1. Introduction 8 2. Access to Information 8 3. Data Protection 11 4. Records Management 9 5. Resourcing 18 Appendix A: IG Polices and Guidance Documents Error! Bookmark not defined.2 Appendix B: Information Governance Acronyms 21 Page 41
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1. Introduction Information Governance (IG) is an umbrella term that covers anything the Council does with information; ensuring appropriate governance and processing of the Council’s information is an ongoing activity. IG policies and guidance documents are set out in Appendix A and acronyms in Appendix B. 2. Access to Information 2.1 FOISA and EIR - Information Requests The Freedom of Information (Scotland) Act 2002 (FOISA) and the Environmental Information (Scotland) Regulations 2004 (EIR) give anyone the right to request recorded information held by the Council, subject to certain exemptions. All information held regardless of whether the Council created or received it, and, regardless of format, is subject to such requests. All FOISA and EIR requests for information held by the Council or Moray Integration Joint Board (MIJB) are logged, co-ordinated, collated and responded to by the FOI Team (Information Co-ordinator). The Council must respond to any request received within 20 working days. The Scottish Information Commissioner (SIC) enforces and promotes FOISA and EIRS as an independent public official. The SIC is responsible for dealing with complaints and promoting good practice, and, collects and publishes quarterly FOISA and EIR statistics. FOISA and EIR Information Requests 2016 – 2025 • In comparison to 2023/24, the Council received 37 fewer FOISA Requests. • In comparison to 2023/24, the Council received 6 fewer EIR requests. 1144 1214 1312 1091 880 1006 1247 1331 1294 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 FOISA Requests 2016 -2025 Number of Requests 19 19 104 161 66 59 42 37 31 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 EIR Requests 2016 -2025 Number of Requests Page 42
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2.2 FOISA and EIR - Internal Reviews If the Requester is dissatisfied with the Council’s response, including a lack of response within the timescales, then the Requester can ask the Council to review its response. Legislative timescales again apply and if the Requester is still dissatisfied then they have the right to appeal to the SIC. The SIC can order the Council to disclose some or all of the requested information should the SIC determine information was incorrectly withheld. An SIC notice is legally binding; any appeal lodged is heard by the Court of Session. In comparison to 2023/24, the Council received 3 more FOI Review Requests. 2.3 Data Protection Rights Requests Data protection law gives people (data subjects) the right to make a “Subject Access Request (SAR)” to access their personal data, which must be provided within 1 calendar month. The Information Commissioner’s Office (ICO) oversees and enforces data protection rights. • The number of SARs received continues to increase. SARs are very resource intensive involving a great deal of officer time to collate and redact information. 31 40 59 52 63 53 83 94 101 Number of SARs Number of SARs 13 18 21 10 12 14 19 16 19 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24 2024-25 Internal Reviews 2016 -2025 Number of Requests Page 43
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2.4 Access to Information Performance Indicators The time taken to complete requests has been recorded since 2023/24. During 2024/25 at least an extra 30 working days were needed to complete requests. • Compliance with statutory timescales has increased to 94% (FOISA) and 97% (EIR). *covid legislation extended timescales for release of information ** DPA 2018 and GDPR from May 2018 Year FOI (hrs) EIR (hrs) SAR (hrs) Total (hrs): Total (days): 2024/25 1492.15 28.8 *350+ 1871.00 258.1 2023/24 1262 11.45 370.8 1644.25 226.8 *not all timings have been collated yet due to current resource challenges within the IG Team These figures do not include the time spent by the IG Team when logging, advising and responding to requests. 89 100 100 98 94 81 81 95 97 EIR Response Rate 2016 - 2025 % responded on time 98 97 95 96 88 87 87 93 94 FOISA Response Rate 2016-2025 % responded on time Page 44
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SAR statistics 2024/25 Cases received within date range and responded to: 101 97% compliance rate Cases responded to on time: 98 Cases responded to that were late: 3 Please note that of the 3 that were late: • 2 were negatively impacted by the Council Christmas break. • 1 was negatively impacted by school summer break. Cases suspended awaiting collection/clarification/ mandate/ID: 22 These cases will have been prompted and/or chased and are just waiting to be closed off when resources allow. Owing to continued prioritisation and success rates from the IG Team, the ICO only requires annual SAR statistics. 3. Data Protection 3.1 Data Breaches All staff must report data breaches to the Council’s Data Protection Officer (DPO) as soon as they are identified or suspected. Breaches present significant reputational and financial risk to the Council. They can cause harm to data subjects, attract complaints or compensation claims, and, result in loss of confidence. Significant breaches must be reported by the DPO to the ICO. The ICO can advise, investigate and even prosecute wrongdoing. The IG Team investigate every report and mitigate against the risk of escalation or reoccurrence. Page 45
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• There has been decrease in the number of reported breaches in comparison to 2022/23 and 2023/24. • The number of ‘near miss breaches’ has increased from 2023/24. • To date, no penalties attributed and no further action has been taken by the ICO. • In 2024/25, the three reported breaches related to: ➢ Staff member putting a work SIM card into a personal device against guidance directly given to them. ➢ Meeting webcast accidentally broadcast after termination of meeting. ➢ Personal information shared on Interchange, Service unaware Interchange publicly accessible. External data breaches are those suffered by third parties holding Council data (processors). There is an increasing risk nationally and internationally of cyber security incidents and much work is ongoing on cyber security. The Council has been recording these incidents since 2024 with a total of 5 recorded for 2024/25. 0 50 100 150 Data Breaches Near Misses 131 14 135 7 114 12 Data Breaches and Near Misses 2022-23 to 2024-25 2022 - 2023 2023 - 2024 2024 - 2025 0 1 2 3 4 2024/25 External Data Breaches External Data Breaches Cyber Security Incident Theft Email sent by Commissoned Provider No breach/Near Miss 0 1 2 3 4 2022-2023 2023-2024 2024-2025 DATA BREACHES REPORTED TO THE ICO Number of Breaches Reported to ICO Page 46
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• The majority of data breaches (101) came from misdirected emails/letters. This continues the trend from 2023/24. • Where more than one root cause, the breach is recorded against all applicable. • Human error continues to be the reported root cause of most data breach incidents. • Each breach is considered on a case- by-case basis and suitable follow up actions are discussed by the IG Team with relevant Services(s). Types of 'inappropriately disclosed data' Data Breaches Reported 2024/25 Breaches involving email (71) Documents collected/posted/issued to incorrect recipient(s)/address (14)Personal data managed incorrectly by staff (8) Other (7) Personal data shared/published online (5) Root Cause of Breaches 2024/25 Human Error (68) Human Error - Autofill Selection Error (email breaches) (16) Procedure Not Followed (9) Inaccurate Data (7) Unknown (5) Lack of Knowledge (3) Technical Error (2) Procedure Inadequate (2) Other (2) Theft (1) Page 47
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The IG Team continues to support Services, providing targeted training and support to ensure staff are aware of the set processes to be followed when handling information e.g. how to clear email autofill cache. In addition to maintaining the suite of Data Protection guidance available on the Council’s Interchange, the IG Team regularly provide direct advice and guidance. Baseline controls continue to be in place across the Council, including Data Protection online training available for all staff via CLIVE (LearnPro). Staff are recommended to undertake the Data Protection Refresher training module annually and attend any Service specific Data Protection workshops. 3.2 Information Security The Council is committed to enhancing cyber security and combating the cyber threats it faces on a regular basis. Cyber security sits within ICT and is monitored on a quarterly basis in the Council’s Corporate Risk Register. The IG Team collaborate and work closely with colleagues in ICT to foster a culture of cyber resilience within the Council and reduce the Council’s overall exposure to insider/outsider cyber threats. 3.3 Accountability The Accountability principle requires a proactive approach to data protection; with appropriate measures and records in place to demonstrate compliance. Accountability obligations are ongoing. The IG Review involving the IG Team reviewing processing activities with Services (commenced in 2022) is ongoing. Progress of this item of work has been slower than hoped as it has been accommodated around ongoing day to day tasks including; access to information requests, management of data breaches, advising on Data Protection Impact Assessments (DPIAs), Data Processing/Sharing Agreements (DPAs/DSAs), privacy notices, management of the Council’s closed records stores, and, providing support and guidance to all Services on all aspects of Information Governance. Number reviewed 2024/2025 DPIAs 188 • 54 more than in 2023/24 • Internally published DPIA Register DPAs/DSAs etc 30 • 7 more than in 2024/25 Privacy Notices 41 • Over double the amount updated/created from 2023/24 Page 48
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3.4 Internal Audit – Council’s compliance with UK GDPR Whilst progress has been made there are outstanding and part implemented recommendations (5.01 – 5.07) from Internal Audit’s report on the Council’s compliance with Data Protection (previously GDPR). Internal Audit have indicated that, whilst there is no current follow up activity being reported through the Audit and Scrutiny Committee it is their intention to revisit this area in future Audit plans. The IG team are prioritising this work with higher risk areas being tackled first 5.01 The Data Protection Policy and guidance should be reviewed to ensure the detailed information remains current and appropriate. Thereafter, a timetable for continued review should be set. The Data Protection Policy (version 2.0) has been updated and approved Summer 2025. Other guidance is covered in the worklist in Appendix A attached. 5.02 In compliance with UK GDPR, a Record of Processing Activities (ROPA) should be compiled by the Authority based on a data mapping exercise. and, 5.03 In compliance with UK GDPR, an Information Asset Register (IAR) should also be compiled and maintained on an ongoing basis. The ROPA, IAR and Appropriate Policy Document (APD) are being reviewed and updated as part of the ongoing IG Review process. 5.04 A review of Privacy Notices held within Council services should be progressed and the documents made available on the Council website for public inspection. Ongoing action. As each Privacy Notice is updated and composed for revised/new processes they are made publicly available: www.moray.gov.uk/PrivacyNotices. 5.05 Consideration should be given to undertaking reviews within Services to audit compliance with the Data Protection Policy and Guidance. This should provide assurance that the Authority is effectively handling personal data in line with regulations. Acknowledged as part implemented by Internal Audit. Compliance recommendations are made to Services following data breaches to improve IG practices and reduce the likelihood of a recurrence; also specific IG advice is given upon request and through IG compliance reviews. 5.06 A review of the guidance documents and forms held within the Information Management section of the Interchange should be undertaken and updated accordingly. Page 49
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The attached worklist of IG policies and guidance at Appendix A highlight when document updates and reviews are aimed to be completed. Due to competing priorities the IG Team were unable to meet the original timeframe of March 2025. 5.07 A review should be undertaken of the officers that have not undertaken the data protection training on the LearnPro training system. Any officer identified should be reminded to undertake their data protection training requirement. In 2024/25, IG Team commenced the development of ‘Toolbox Talks’ data protection training for non-office-based staff, who do not have access to a computer in their roles. The DP Learnpro module is being refreshed in line with the updated DP Policy, which will then be promoted and uptake will be monitored. Page 50
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4. Records Management 4.1 Records Management Plan Under the Public Records (Scotland) Act 2011, Public Authorities must develop and publish a records management plan (RMP) every 5 years. The Council's RMP covers both the Council and Moray Licensing Board, it was last updated and submitted in December 2020. The regulator is the National Records of Scotland (NRS). The RMP for MIJB is aligned with the Council’s RMP. Ten elements (excluding 1, 9, 13, 14 & 15) on MIJB’s RMP are directly covered by the Council’s RMP. As such the below noted issues will also affect MIJB’s RMP. There are 15 elements to a RMP, with a Red, Amber, Green acceptance scale. The NRS has indicated that:- GREEN 3 Elements (accepted by the Keeper) AMBER 7 Elements (accepted on an ‘improvement model’ basis) RED 5 Elements (unacceptable) 1. Identifies Senior Management Responsibility 14. Shared Information i.e. ISAs, ISA Register etc. 15. New element covering public records created by third parties. 2. Identification of the person with Records Management responsibilities. 3. Records and Information Management Policy. 6. Destruction Arrangements. 8. Information Security. 9. Data Protection. DP Policy outdated, limited training and documented and resourcing of DPO role. 11. Audit Trail. 12. Competency framework for records management staff. 4. Business Classification Scheme. 5. Retention Schedules. 7. Archiving and Transfer Arrangements. 10. Business Continuity Plan. 13. Assessment and Review. The top 3 NRS concerns, with our responses to these are: 1. Level of IG staffing resource - discussed in paragraph 5 below. Page 51
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2. Lack of progress with a Council wide automated document management system. - Sharepoint was introduced across a number of Council services with the Designing Better Services transformation programme in 2014 but a number of services were not included. This gap has been recognised in the Council’s current transformation programme with a wider roll out of M365/SharePoint online. The landscape has also changed with a number of services using information storage systems with built in electronic document management. 3. Archiving provision – discussed in paragraph 4.2 below Further information is expected from NRS in Autumn 2025. There is a high risk that the Council’s RMP is not accepted by the Keeper. If not accepted, then the Keeper will then alert Scottish Ministers, resulting in further action e.g. including a full ICO inspection. , Work is underway to ensure these issues and potential improvements are brought before the Central Leadership Team for consideration of a corporate response. including working with other services to consider corporate solutions, such as the implementation of M365 as a potential replacement for Shared Drives. The position on the Archives repository and Closed Records Store are being considered through Property Asset Management Review. 4.2 Closed Records Store The Council’s Closed Records Stores (CRS) are required for the secure hardcopy storage of anything the Council must retain for ongoing business or under the Retention Schedules. CRS provision is managed by the IG Team. There are 3 CRS in 3 separate locations within Moray but none conform to the required standards. This has been picked up in the current property review, alongside the Archival storage requirement. Space for new accessions remains limited and owing to the IG Team’s limited resources there is currently a backlog of records awaiting review. In 2024/25 over 450 new boxes were accessioned into the CRS. Only a quarter of that amount were securely destroyed. 5. Resourcing Consistent with the 2023/24 report, the Council’s IG Team remains resourced at 2.7FTE which is lean when benchmarked against comparable councils. There has been an increasing trend in the number of time critical information/ subject access requests and review requests. This puts additional pressure on staff time and impacts on time available for records management, policy and development work. This is highlighted as a risk from members to be aware of. Page 52
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Title Version Date Status Target Date Notes Data Protection Policy v2.0 Aug-25 Up To Date Update in Spring 2026 with DUAA changes CCTV Policy v2.0 Jan-25 Up To Date Updated for Body Worn Cameras and 'other' cameras, incl. ANPR, dashcams etc Data Breach Reporting Form v3.0 Oct-24 Up To Date Guidance on Managing Emails v4.0 Sep-17 Priority 1 30th Sept 2025 Revised target date to be with CLT 9 Nov 25. Update re:M365, retentions, recall, bulk emails etc Data Protection Guide v1.0 Jun-18 Priority 2 Mar 26 To be updated once Policy approved: Update Section 10. Add new AI section and personal devices section. WhatsApp Policy (etc) Priority 2 June 26 To be drafted with ICT Information Management: WhatsApp messaging service Mar-20 Priority 2 June 26 Incorporate into WhatsApp (etc) Policy? Guidance on Data Security Breach Management v3.0 May-18 Priority 3 Aug 26 Refresh after DP Policy updated Redaction Guidance Priority 3 Dec 26 To incl. justification for what is redacted specifically for SARs Your Personal Rights Document Priority 3 Mar 27 Information Governance: Email Address Auto-Complete (Email Caches) v1.0 Nov-22 Priority 3 Sept 27 Guidance on Sharing Constituent Information with Elected Representatives (Councillors) v1.0 Jun-22 Priority 4 Mar 28 Records Management Reference Handbook 2013 Priority 4 Mar 29 Subject Access Request (SAR) Procedure v1.1 Jan-20 Priority 4 Sept 29 Add in a note re - different types of requests e.g. a Spec of Docs? Page 53
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Information Management: Working Away from an Office v0.2 Mar-20 Priority 4 Mar 30 Information Management: Working Away from the Office Dos and Don’ts Mar-20 Priority 4 Sept 30 Appropriate Policy Document v0.4 Feb-23 Priority 5 Mar 31 Current draft to be updated to include CCTV processing. MIJB Appropriate Policy Document Priority 5 Sept 31 Council APD as template Guidance for Services using Shared Drives Priority 5 Mar-32 Re: Element 11 RMP. Inc manual retentions, Naming Conventions, Version Control Guidelines etc A Guide to the Freedom of Information (Scotland) Act 2002 (FOISA) v3.0 Jan-17 Priority 5 Sept 32 Awaiting the revised legislation to go through A guide to the Environmental Information (Scotland) Regulations, 2004, (EISR) v1.0 Jan-17 Priority 5 Mar 33 Guidance on Signatures v1.0 Dec-16 Priority 5 Sept 33 Update to cite DPA 2018/ UK GDPR Scanning Guidelines v2.0 Apr-17 Priority 5 Mar 34 Update to cite DPA 2018/ UK GDPR A Guide to Pupils’ Educational Records v1.0 Mar-17 Priority 5 Sept 34 Update to cite DPA 2018/ UK GDPR Governance and Management of the Closed Record Store (CRS) v3.0 Sep-23 Priority 5 Mar 35 Guide on the Identification and Disposal of Confidential Waste v2.1 May-19 Priority 5 Sept 36 Page 54
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Appendix B – Information Governance Acronyms Acronym Definition APD Appropriate Policy Document CRS Closed Records Store (CRS). DPA/DSA Data Processing Agreement / Data Sharing Agreement DPIA Data Protection Impact Assessment. Process designed to assist with systematically analysing, identifying and minimising the data protection risks of a project or plan. DPO Data Protection Officer. UK GDPR introduced a duty on public authorities to appoint a DPO. DPOs assist with monitoring internal compliance with Data Protection legislation, informing and advising on Data Protection obligations and reviewing/approving DPIAs. They act as a contact point for data subjects and the Information Commissioner’s Office. DPOs must be independent, experts in Data Protection, adequately resourced and report to the highest management level. FOI Freedom of Information. IAR Information Asset Register. ICO Information Commissioner’s Office (ICO); independent supervisory authority for data protection in the UK. RMP Records Management Plan. ROPA Record of Processing Activities. SAR Subject Access Request. SIC Scottish Information Commissioner. UK GDPR United Kingdom General Data Protection Regulation. Page 55
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Report to: Corporate Committee Meeting Date: 4 November 2025 Report by: Executive Director Economy, Enterprise and Operations Author: John Black Contact Email: John.black@moray.gov.uk Subject: Complaints Handling Annual Report 2024-25 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to consider the Complaints Handling Annual Report 2024-25. 1.2 This report is submitted to the Corporate 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 That the Corporate Committee approve the publishing of the Complaints Handling Annual Report 2024-25 to comply with the SPSO statutory requirement. 3. RECOMMENDATIONS 3.1 It is recommended that the Corporate Committee: i) Consider and note the content of the Complaints Handling Annual Report; ii) Welcome performance as indicated in the report; and iii) Approve the report for submission to the Scottish Public Services Ombudsman (SPSO). Author Name John Black Job Title Complaints Officer Item 8. Page 57
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4. BACKGROUND AND CONTEXT 4.1 All Councils are required to publish their performance against the national performance indicators set by SPSO. The attached report presents the Council’s performance against these performance indicators for the 2024-25 reporting period. (Appendix 1) 4.2 Complaints handling is part of the Council’s performance management framework. Members receive updates on complaints performance through routine reports to service committees. 4.3 During 2024-25, the Council received 761 complaints: an increase of 14 (2%) against the previous year and 168 (28%) since 2022-23. Although complaints have risen to 8.04 per 1,000 population, the Council remain well below the national average of 10.79. 4.4 During 2024-25, the Council maintained last year’s performance of dealing with 80% of complaints at frontline stage compared to the 20% dealt with at the investigation stage including those escalated to investigation. 4.5 The Council continue to deal with a high percentage of complaints at frontline, as recommended by the SPSO’s guidance on the Model Complaints Handling Procedure to “take every opportunity to resolve service users’ complaints at the first point of contact if at all possible.” We are slightly below the Scottish average of 86% and hope to improve performance through continued staff training, discussions at quarterly complaint administrator meetings and with senior officers responsible for management of their department complaints. 4.6 The Council’s average response times for dealing with stage 1 complaints increased slightly but remain just above the MCHP target of 5 working days. 4.7 There has been some improvement with the average time taken to close an Escalated Stage 2 complaint (10% decrease) however, along with Stage 2 complaints (12% increase), this remains significantly above both the 20-working day target and that recorded nationally. As highlighted within Indicator 3, we have fewer Stage 2 complaints and a small proportion of Escalated Stage 2 complaints meeting target timescales and this continues to have an impact on our target times. 4.8 Our Complaints Officer regularly works with Complaint Administrators to progress more complex complaints. An overdue complaint report is produced each Monday, identifying any complaint handling timescale delays to respective department complaint administrators and Heads of Service. Education and Adult Care complaints often feature in these reports. 4.9 There was a 35% reduction in Education complaints from the previous reporting year however school holiday periods continue to create complaint handling delays in Education complaints. This has been raised at a national level with SPSO who responded that authorised extensions should be added to take account of the holidays. Page 58
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4.10 In 2024-25, the proportion of our Stage 1 complaints that were upheld increased to 53% against a national average of 31%. Overall, there was a 11% increase (65%) of Stage 1 complaints that were upheld in some way (upheld, partially upheld or closed as resolution) which compares similarly to 64% nationally. The spike in Housing and Property complaints linked to three main areas: Repairs/Capital/Planned Maintenance, Allocations and Housing Estate Management were a contributing factor to this increase. Compulsory staff training was introduced by Housing and Property to address this, and it is hoped that this will have a positive impact on future service provision. 4.11 Monitoring of resolution cases continues to ensure that they have been categorised correctly. Such monitoring and scrutiny does not take place in other Councils. There remains a low number of cases (3% for stage 1 and 2 complaints) closed at resolution compared to the Scottish National Average of 21%. The Complaints Officer has provided staff training relating to the resolution category. Staff are making greater use of this with 17 complaint cases closed as resolution this year, compared to 7 complaint cases the previous reporting year. 4.12 Upheld Stage 2 complaints increased by 3% to 18% compared to 16% upheld nationally. There was a significant rise from 37% to 58% of overall complaints dealt with at this Stage that were either upheld, partially upheld or closed as resolution. This compares favourably to the national average of 47%. This demonstrates that although the Council are taking longer to conclude stage 2 investigations, a great deal of scrutiny is being applied to each. 4.13 17 of the complaint cases were referred back to the Council by the SPSO. No recommendations were made, and the SPSO were fully satisfied of the handling of 12 of the cases. 9 minor feedback points were provided on the other 5 cases. These were readily accepted and actioned by the departments concerned. 4.14 The SPSO have recently published a statement of Complaint Handling Principles. One of these principles being that the quality and thoroughness of an investigation should not be compromised by attempts to meet timescales. 4.15 Housing and Property saw a significant increase of 13% from 24% to 37%. This is linked to Repairs/Capital/Planned Maintenance, Allocations and Housing Estate Management. The increase in complaints relates to a significant rise in maintenance activity across Moray to deliver the Energy Efficiency Standard in Social Housing (EESSH), with spend rising from £16.6million in 2023/24 to £24.4 million in 2024/25. This programme of work has involved multiple teams and contractors and poor communication with tenants has been noted as a recurring issue in the complaints received. 4.16 Learning from complaints is essential if we are to improve the way we deliver our services. Essentially, all complaints normally fall into three categories. A complaint can be either about; (a) policy or procedures (b) practice in the implementation of a policy or procedure (c) staff behaviours. 4.17 Learning outcomes are captured in reports taken from mandatory completion of complaint database closure e-forms. This occurs for complaints upheld, partially upheld and resulted as resolution. Page 59
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4.18 As part of the current restructuring, the Complaints Officer role now sits with Customer Experience, ICT and Digital Services. Work will be carried out to look at improved ways to capture learning outcomes to identify ways to improve service provision. 5. BENEFITS 5.1 The report affords the Council the opportunity to demonstrate that it has complied with the Scottish Public Services Ombudsman statutory requirement to publish an annual complaints report against a set of Key Performance Indicators. 5.2 The report provides a comparison of the complaint’s performance against complaint performance nationally. 5.3 The report is published on the Council’s website for public viewing with the aim of providing the public with confidence in reporting complaint matters. 6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X Policy and Legal 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 X Climate Change and Biodiversity Impact X 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 Page 60
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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 The SPSO have made it a statutory requirement to have all local authorities publish a Complaints Annual Report. 6.4 Financial It is not anticipated that there will be any financial implications. 6.5 Risk Failure to adhere to the statutory SPSO requirement may result in SPSO making a declaration of non-compliance against the Council. Non-compliance with the statutory duty relating to national standards being adopted would present risk in terms of reputational damage and a loss of public confidence in reporting complaints. 6.6 Staffing There are no staffing implications related to this report. 6.7 Best Value and Transformation Effective Complaint handling can identify learning and improvement opportunities for services 6.8 Property There are no property implications related to this report. 6.9 Information Communications/Technology/Digital As part of the ongoing project to procure and implement a new CRM system, we will undertake a comprehensive review of our complaints handling procedure, include processes for complaint submission, escalation, communication, and reporting.” 6.10 Equalities, Social Inclusion and Economic Impact The Equal Opportunities Officer has recommended that complaints should be monitored to identify any patterns or gaps where services may have unintentionally not met the needs of particular protected groups to inform service developments to ensure an accessible, proportionate and inclusive complaints process while reducing any inequality or disadvantage. 6.11 Climate Change and Biodiversity Impacts There are no climate change or biodiversity impacts related to this report. 7. CONSULTATION 7.1 This report has been prepared in consultation with the Corporate Leadership Team, Chief Governance Officer, Service Manager Equal Opportunities Officer, the Service Manager Customer Service and Experience and the Service Manager Democratic Services and any comments made have been incorporated into the report Page 61
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8. BACKGROUND PAPERS 8.1 Appendix 1 – Complaints Handling Annual Report 2024-25 Page 62
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APPENDIX 1 Complaints Handling Annual Report 2024-25 Page 63
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APPENDIX 1 Introduction At Moray Council, we aim to provide the highest level of service however there are times when we don’t meet the expectations of our customers. When this happens, it’s important we learn from the complaints we receive and improve our service delivery. The Scottish Public Services Ombudsman (SPSO) is the responsible body for complaints handling for the public sector in Scotland. Their Model Complaints Handling Procedure (MCHP) defines how they expect complaints to be dealt with. In line with this, all complaints we receive are managed under the two Stage Complaints Handling Procedure: We aim to resolve as many complaints as possible at Stage 1, however, if a customer remains dissatisfied following the 2 Stage process, we advise how complaints can be passed to the SPSO for further consideration. To ensure we handle complaints effectively, our Complaints Officer conducts regular reviews of all received complaints and works closely with our Complaint Administrators. We also provide ongoing training sessions for Services and Elected Members to enhance understanding of the complaints process and promote best practice across the organisation. Stage 1 - Also known as Frontline Resolution These complaints should be straightforward. A Stage 1 complaint could mean immediate action to resolve the matter. These complaints should be answered within 5 working days. Most complaints should be dealt with at Stage 1. Stage 2 – Also known as Investigation Stage A Stage 2 complaint may be a concern that has not been successfully resolved at Stage 1 and is therefore escalated or refers to a matter that is more complex and requires a full and detailed investigation. These complaints should be answered within 20 working days. Page 64
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APPENDIX 1 Complaints Performance All complaints are recorded on our Complaints Management System. Details are shared with our Corporate Leadership Team and Heads of Service on a quarterly basis and with our Service Committees every six months. Our Complaints Officer also holds regular meetings with Complaints Administrators and, at a national level, attends the quarterly meetings of the Local Authority Complaint Handlers Network (LACHN). As part of a revised MCHP issued on 1 April 2021, local authorities are required to record and publish complaints performance annually against 4 Key Performance Indicators (KPIs). This report details how we performed against these KPIs between 01 April 2024 and 31 March 2025 and provides examples of changes introduced due to the complaints we have received. For comparison purposes, we have also included our performance from the previous two years and the latest national data for Scotland. Indicator 1: Total number of complaints received (including complaints per 1,000 population) This indicator records the total number of complaints received at both Stage 1 and Stage 2. To allow for consistent benchmarking across all local authorities in Scotland, the figure per 1,000 population is included. Table 1: Complaints received including per 1,000 population (2024-25 population based on Mid-Year Estimates 2023. Totals for Scotland based on responses received by LACHN as of 15 September 2025) During 2024-25, we received 761 complaints: an increase of 14 (2%) against the previous year and 168 (28%) since 2022-23. Although complaints have risen to 8.04 per 1,000 population, we remain well below the national average of 10.79. Scotland 2022-23 2023-24 2024-25 2024-25 Total Complaints Received (Stage 1 and Stage 2) 593 747 761 49,481 Population 96,410 94,280 94,670 4,587,310 Complaints per 1,000 population 6.15 7.92 8.04 10.79 Moray Council Page 65
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APPENDIX 1 Looking further at the complaints received in 2024-25, Housing and Property Services recorded 285; an increase of 105 (58%) against the year before. Environmental and Commercial Services complaints fell by 17 (6%) to 279. Table 2: Number and % of Total Complaints received by Department For Housing and Property, the large increase in 2024-25 can be linked to three main areas: Repairs/Capital/Planned Maintenance, Allocations and Housing Estate Management. Table 3: Housing and Property Services – Most Common Complaints 2024-25 (with previous years comparison) The increase in complaints related to Repairs/Capital/Planned Maintenance coincides with a significant escalation in maintenance activity across Moray to deliver the Energy Efficiency Standard in Social Housing (EESSH). Investment in this programme has risen from £16.6million in 2023/24 to £24.4 million in 2024/25 with a schedule of work involving multiple teams and external contractors. Investigations into the complaints received, identified poor Department Housing and Property Services 191 32.2% 180 24.1% 285 37.5% Environmental and Commercial Services 191 32.2% 296 39.6% 279 36.7% Education 64 10.8% 80 10.7% 52 6.8% Economic Growth and Development 23 3.9% 37 5.0% 27 3.5% Adult Care (Health and Social Care Moray) 22 3.7% 26 3.5% 27 3.5% Financial Services 36 6.1% 38 5.1% 27 3.5% Children and Families and Criminal Justice (Health and Social Care Moray) 29 4.9% 44 5.9% 26 3.4% Education Resources and Communities 14 2.4% 24 3.2% 17 2.2% Governance, Strategy and Performance 21 3.5% 20 2.7% 17 2.2% Chief Executive 0 0.0% 0 0.0% 4 0.5% HR, ICT and Organisational Development 2 0.3% 2 0.3% 0 0.0% Grand Total 593 100.0% 747 100.0% 761 100.0% 2022-23 2023-24 2024-25 Housing and Property 2022-23 2023-24 2024-25 Repairs/Capital/Planned Maintenance 130 111 191 Allocations 14 7 24 Housing Disputes 6 17 19 Complaint Against Staff 17 17 19 Housing Estate Management 14 11 18 Other 1 8 5 Strategy & Development 3 1 3 Asset Management 0 0 3 Homelessness 3 5 1 Process/Procedure 1 1 1 Housing Support 2 1 1 Estates 0 1 0 Grand Total 191 180 285 Page 66
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APPENDIX 1 communication with tenants as a recurring issue. In addition, a rise in reported cases of damp and mould and inconsistencies in the handling of repairs under the Right to Repair element of the Housing (Scotland) Act 2001 have also attributed to the higher rate of complaints. To address this, compulsory staff training has been introduced (see Learning from Complaints section), and a Repair Improvement Plan is in development. This will include revised procedures around communication and reinforce the correct approach when handling repairs and reports of damp and mould. Following an increase in complaints last year, Environmental and Commercial Services reviewed their complaint handling procedures. Improvements identified for Waste Management, Open Spaces and Road Maintenance were implemented in February 2025. These changes have already shown positive results, and it is anticipated this trend will continue in future reporting. Indicator 2: Number and Percentage of complaints at each stage that were closed in full within set timescales of 5 and 20 working days The MCHP requires complaints are closed within 5 working days at Stage 1 and 20 working days at Stage 2. While the aim is to manage complaints as quickly as possible, the main consideration must always be to deliver a quality decision based on facts and evidence. Table 4: Complaints Closed NB: Complaints Received (Table 2) and Complaints Closed (Table 4) may differ due to complaint received but not closed in the reporting period. Table 5: Number and Percentage of Complaints at each Stage that were closed in full within set timescales Scotland 2022-23 2023-24 2024-25 2024-25 Stage 1 466 586 611 40,900 Stage 2 80 123 129 4,331 Escalated Stage 2 26 26 25 2,555 Total 572 735 765 47,786 Moray Council No. closed within set timescales % closed within set timescales No. closed within set timescales % closed within set timescales No. closed within set timescales % closed within set timescales No. closed within set timescales % closed within set timescales Stage 1 377 81% 494 84% 518 85% 28,222 69% Stage 2 54 68% 61 50% 51 40% 2,825 65% Escalated Stage 2 8 31% 4 15% 7 28% 1,800 71% Total 439 77% 559 76% 576 75% 32,847 69% Moray Council Scotland 2022-23 2023-24 2024-25 2024-25 Page 67
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APPENDIX 1 During 2024-25, the proportion of Stage 1 complaints closed on time rose to 85%, significantly above the national average of 69%. Performance of Escalated Stage 2 complaints within target also improved, however the proportion of Stage 2 complaints closed on time fell and both were well below the reported Scottish averages. Overall, we continue to resolve around three quarters of all complaints within MCHP targets, a rate that remains well above the national average. Indicator 3: Average time in working days for a full response to complaints at each stage This indicator details the average time in working days taken for a full response to be provided to a complaint at each stage. Table 6: Average Response Times (Working Days) Despite a slight increase in our average response time for Stage 1 complaints, we continue to perform well against the national average of 8.6 days. There has been some improvement with the average time taken to close an Escalated Stage 2 complaint however, both Stage 2 and Escalated Stage 2 complaints remain significantly above target and the Scottish average. Late complaints often occur due to the complexity of the case being considered. Delays can also occur due to holiday periods, the number of services involved and if any legal mandates or advice is required. With Child Friendly Complaints, there is also a legal requirement to seek the views of the child involved before an investigation can progress. To limit late complaint handling, the Complaints Officer regularly monitors complaint reports to Administrators and Heads of Service and delivers staff training and guidance where required. Scotland 2022-23 2023-24 2024-25 2024-25 Stage 1 6.26 5.36 5.42 8.60 Stage 2 27.45 27.92 31.83 19.90 Escalated Stage 2 28.73 32.77 29.64 19.00 Moray Council Page 68
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APPENDIX 1 Indicator 4: The outcome of complaints at each stage Once a complaint investigation is complete, we must provide the customer with an explanation of the findings and confirm the outcome category as one of the following: Upheld – when a complaint is found to be true or is confirmed. Partially Upheld - where several issues have been raised and some, but not all, are upheld. Resolved - where a complaint includes several issues, but we manage to agree an outcome without the need to investigate and respond on each separately. Not Upheld - when a complaint is found to be untrue or where a reasonable standard of service has been provided. Indicator 4 reports the number and percentage of our complaints closed at each stage against the outcome decision. Table 7: The outcome of complaints at each Stage NB percentages may not total 100% due to rounding In 2024-25, a high proportion of our Stage 1 complaints were closed as Upheld: 53% against a national average of 33% while Stage 2 Partially Upheld complaints doubled to 40% compared to 25% nationally. Escalated Stage 2 complaints that were Not Upheld rose to 48%. Stage 1 Not Upheld 202 43% 276 47% 213 35% 13,888 34% Partially Upheld 36 8% 51 9% 56 9% 7,121 17% Upheld 212 45% 255 44% 325 53% 13,453 33% Resolved 16 3% 4 1% 17 3% 6,438 16% Total Closed at Stage 1 466 586 611 40,900 Stage 2 Not Upheld 39 49% 78 63% 54 42% 2,323 54% Partially Upheld 22 28% 24 20% 52 40% 1,092 25% Upheld 19 24% 19 15% 23 18% 688 16% Resolved 0 0% 2 2% 0 0% 228 5% Total Closed at Stage 2 80 123 129 4,331 Escalated Stage 2 Not Upheld 10 38% 5 19% 12 48% 1,319 52% Partially Upheld 13 50% 12 46% 10 40% 537 21% Upheld 3 12% 8 31% 3 12% 488 19% Resolved 0 0% 1 4% 0 0% 211 8% Total Closed at Esc. Stage 2 26 26 25 2,555 Moray Council Scotland 2023-24 2024-25 2024-252022-23 Moray Council Scotland 2023-24 2024-25 2024-252022-23 Moray Council Scotland 2022-23 2023-24 2024-25 2024-25 Page 69
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APPENDIX 1 We also continue to have a lower proportion of complaints closed as Resolved. The option to close a complaint as Resolved (introduced in 2021) covers complaints where a resolution is agreed without the need to investigate each area. To ensure this category is applied correctly, our Complaints Officer regularly monitors Resolved complaints. If required, complaints are investigated fully, resulting in specific outcome of Not Upheld, Upheld or Partially Upheld being applied. Previous discussions with the Local Authority Complaint Handlers Network confirmed this level of monitoring is not routine for others and is perhaps why Resolved complaints recorded by Moray Council are much lower. SPSO Complaints If a complainant remains dissatisfied following the 2 Stage process, their complaint can be passed to the SPSO. The SPSO provide feedback and, if required, recommendations to help councils learn and improve. When recommendations are made, the council must act within a specified time and provide evidence that demonstrates the learning and improvements taken. During 2024-25, 16 complaints relating to Moray Council were considered by the SPSO. Good complaint handling was noted for 11 and only 9 minor feedback points raised for others, to be passed to the relevant departments. An annual report covering complaints made to the SPSO will be discussed at the Audit and Scrutiny Committee meeting on 19 November 2025. Child Friendly Complaints On 16 July 2024, the United Nation Convention on the Rights of Children (UNCRC) (Incorporation) (Scotland) Act 2024 was incorporated into domestic law in Scotland. This Act ensures that children’s rights are central to policy and decision making and that their needs are met by public service complaints procedures. Child Friendly Complaints can be made by a child, a parent reporting an issue on behalf of a child or a parent or child reporting an issue that can impact a child. In all cases, we are required to seek the views of the child. To ensure we do this correctly, we follow the Child Friendly Complaints Handling Principles and Child Friendly Complaints Handling Procedure developed by the SPSO. More information about these can be found on the SPSO website - https://www.spso.org.uk/child-friendly-complaints Page 70
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APPENDIX 1 Learning from Complaints Complaints are a valuable source of information; they provide us with the opportunity to identify trends or emerging issues and develop and improve our service delivery. Some examples of changes we have implemented due to complaints in 2024-25 are provided below. Right to Repair Following investigations into complaints around Housing Repairs, a gap in staff knowledge of qualifying repairs and the Council’s obligations under the Right to Repair element of the Housing (Scotland) Act 2001, was identified. To address this, compulsory staff training was developed and delivered to all staff who manage, schedule, approve and inspect repairs within Housing & Property. Policy and Procedures and Contact Centre scripts were also reviewed. Going forward, staff knowledge and any training requirements, will be discussed regularly as part of Team meetings, 121s and the Council’s formal staff development programme. Education Improved procedures relating to appropriate handling of medication are now in place while the need for correct recording and timely sharing of information has been reinforced with schools. Environmental & Commercial Services With complaints increasing last year, a comprehensive review was undertaken of all Environmental & Commercial Services complaints. This included identifying best practice with other authorities via the Local Authority Handlers Network (LACHN) and improvement opportunities were identified within Waste Services, Open Spaces and Road Maintenance. Procedures will continue to be reviewed where necessary. Council Tax Online Council Tax Services have been improved to ensure availability of accurate payment and statement information. Streamlining this service will continue as part of the latest Financial Services Service Plan. Children & Families A revised communication policy relating to Fostering & Adoption Panel meetings should now ensure attendees are aware of the purpose of the Panel and how meeting feedback can be provided. Catering Services The Adapted Diet procedure has been reviewed and staff retrained on allergies to ensure the correct process is used and risk reduced. Page 71
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APPENDIX 1 Customer Satisfaction In December 2021, as part of our plans for recovery and renewal from the Covid pandemic, we replaced paper copies of our survey with a link to an online questionnaire, sent to those supplying an email address. In 2024-25, 673 links to our survey were issued resulting in 87 responses and a return rate of 13%. This is a slight improvement on recent years (with 8% recorded in 2022-23 and 12% in 2023-24) and is comparable with the response rate in 2021-22 when paper surveys were issued. Alternative methods, within available resources, which may increase responses are kept under review however low response rates to complaint surveys are evident nationally. Our survey requests feedback on the process of dealing with a complaint rather than the complaint outcome. In 2024-25, a high proportion of those responding to our survey said they found it easy to make their complaint and most agreed they had the opportunity to fully explain all areas of the complaint. Most also stated the response they received was easy to understand and following Administrator training last year, more people in 2024-25 believed all points of the complaint were covered. We do however still need to ensure we communicate better around timescales and the next stages of a complaint. Conclusion We are committed to learning from the views and experiences of our customers. To do this, we aim to record complaints accurately and adhere to the Complaints Handling Procedure. Where a complaint is closed as upheld or partially upheld, learning and improvement opportunities are identified to improve service provision. This can lead to a change in process or policy to prevent or reduce the likelihood of similar complaints occurring. This Annual Report complies with the SPSO’s requirement to publish our complaints performance against their 4 key performance indicators. It also highlights some of the recent changes we’ve made due to the complaints we’ve received. We will continue to welcome customer feedback and work towards providing the best service possible. Contact Us For more information on our complaints procedure, or to make a complaint via our complaints e-form, visit www.moray.gov.uk/complaints. For more detailed advice or to request a copy of the procedure in another format contact 01343 543451 or email complaints@moray.gov.uk. Page 72
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Report to: Corporate Committee Meeting Date: 4 November 2025 Report by: Executive Director Economy, Enterprise and Operations Author: John Black Contact Email: John.black@moray.gov.uk Subject: Unacceptable Customer Actions Policy 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to consider a review of the Unacceptable Customer Actions Policy (UCAP). 1.2 This report is submitted to the Corporate Committee in terms of Section III (B) (6) of the Council's Scheme of Administration relating to revised policy amendments that doesn’t fall within the terms of reference of any other Committee. 2. SUMMARY 2.1 That the Corporate Committee approve the publishing of the revised Unacceptable Customer Actions Policy. 3. RECOMMENDATIONS 3.1 It is recommended that the Committee approve the revised Unacceptable Customer Actions Policy attached as Appendix 1. Author Name John Black Job Title Complaints Officer 4. BACKGROUND AND CONTEXT 4.1 The Unacceptable Customer Actions Policy was last reported to Committee in 2015. A revision of this policy is necessary to allow for greater protection to staff and elected members. It allows those members of the public who are the subject of this policy to meaningfully engage with staff. 4.2 The Council requires a revised Unacceptable Customer Actions Policy to manage current customer behaviour and afford protection to our staff and Elected Members. Item 9. Page 73
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4.3 This policy assists the Council to protect the Council from reputational damage. It also allows the Council to demonstrate to independent scrutiny bodies, such as the Scottish Public Services Ombudsman (SPSO) and Care Inspectorate that it has acted fairly, consistently and proportionately. 5. PROPOSALS 5.1 A review of this policy is considered necessary to address different ways unacceptable customer behaviour is being experienced and an increase in instances of unacceptable behaviour. The proposed changes are highlighted as tracked changes in Appendix 1 with the following changes highlighted: 5.2 An increase in inappropriate social media communications about staff and Elected Members is addressed in section 5.2 of the revised policy. 5.3 There have been recent incidents where Heads of Service formed the view that the level of customer unacceptable behaviour merited the customer being placed immediately onto restrictions however the current policy did not cater for this. This has been addressed in section 5.4 of the revised policy. 5.4 There have been incidents where customers have made unreasonable use of the complaints process, and this aspect has been addressed in section 4.4 of the revised policy. 5.5 An SPSO case reviewer asked the Council to evidence the recording and review of restrictions placed on a customer. Section 9 has been amended in the revised policy to provide clarity on this. 5.6 The revised policy for publication is attached as Appendix 1 and an Integrated Impact Assessment (IIA) has been included as Appendix 2. The IIA considers the impact of decisions on equality, human rights, and socioeconomic disadvantage. 6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X Policy and Legal 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)) Page 74
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There is no direct impact of the Policy on these strategic plans. 6.3 Policy and Legal The Policy is not a statutory requirement however it often compliments other statutory polices such as our Complaint Handling Policy. 6.4 Financial No direct financial implications. 6.5 Risk This policy is necessary to protect staff and Elected Members to allow them to carry out their duties. It also affords us protection against reputational damage and allows the Council to demonstrate to independent scrutiny agencies that it has taken reason and proportionate actions. 6.6 Staffing The policy will help allow staff time to be focused on wider service delivery for the benefit of all customers. 6.7 Best Value and Transformation No direct implications. 6.8 Property There are no property implications related to this report. 6.9 Information Communications/Technology/Digital There is an increased use of social media to criticise staff and Elected Members. 6.10 Equalities, Social Inclusion and Economic Impact An integrated Impact Assessment has been drafted and is attached at Appendix 2. 6.11 Climate Change and Biodiversity Impacts There is no climate change or biodiversity impacts related to this report. 7. CONSULTATION 7.1 This report has been prepared in consultation with the Corporate Leadership Team, Chief Governance Officer, Service Manager Democratic Services and Equal Opportunities Officer and any comments made have been incorporated into the report 8. BACKGROUND PAPERS 8.1 Current Unacceptable Customer Actions Policy. Page 75
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APPENDIX 1 Updated November 2025 Unacceptable Customer Actions Policy Date of Creation 2015 Owner (Service) Chief Executive Reviewer Head of Service Chief Governance Officer Approver Executive Director Economy, Enterprise & Operations Date Approved Approver (Committee) Corporate Committee Date Approved TBC Next Review Date 2029 or earlier if required. Version History Version Date Author Changes Made Approved By 1.0 [Insert Date] [Insert Author] Initial document [Insert Name] 1.1 [Insert Date] [Insert Author] [Describe Changes] [Insert Name] Page 76
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APPENDIX 1 Updated November 2025 1. Introduction 1.1. This policy sets out Moray Council’s approach to managing the relatively few customers whose actions or behaviours present as unacceptable. The term ‘customer’ includes anyone acting on behalf of another person or who contacts our offices in connection with any aspect of the Council services. The principles set out in this policy apply to Council dealings with its customers in all circumstances. 2. Policy Aims 2.1. To deal fairly, honestly, consistently and appropriately with all customers, including those whose actions the Council considers unacceptable. The Council believes that all customers have the right to be heard, understood and respected. The Council also considers that our employees and elected members have the same rights. 2.2. To provide a service that is accessible to all customers. However, where the Council considers a customer’s actions to be unacceptable, the Council retains the right to restrict or change access to our services (where it is appropriate to do so). 2.3. To ensure that other customers, Moray Council employees and elected members are not disadvantaged by the acts of customers who behave in an unacceptable manner. 2.4. To ensure that the Council’s effectiveness is not compromised by customers who act in a manner that makes excessive and unacceptable demands on Council resources. 2.5. Examples of unacceptable behaviours and steps taken to address these are provided in the relevant sections of this policy however these are not intended to be viewed as exhaustive lists. 3. Moray Council Pledge 3.1. We will: • Provide high quality customer service however you wish to contact us • Offer you choices in how you contact us to get information, request services or tell us what you think • Provide a responsive service where issues are resolved at the first point of contact wherever possible • Be polite, helpful, sensitive and discrete in all our dealings with you • Treat you fairly and equally, keeping our language clear • Keep your information and personal data safe and secure • Respond to routine enquiries promptly or tell you why it will take longer • Urgent enquiries will be responded to as a priority, and we will keep you informed of progress • Use customer views including complaints to help improve and shape future service delivery • Check regularly that the terms of our Charter are being delivered to you Page 77
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APPENDIX 1 Updated November 2025 3.2. What we expect in return: To deliver high quality customer services, we need your help. Here are some things you can do to make it easier for us to do our job: • Give us all the information we need to help you • Let us know if you require additional assistance, or support or information in an alternative format • Attend appointments on time, letting us know if you will be late or can’t attend • Ask us to explain anything you are unsure of • Communicate with our staff in a respectful manner • Tell us how we can improve our services 3.3. Equalities Statement: This policy is underpinned by the Council’s commitment to promoting equality, diversity, and human rights in line with the Equality Act 2010 and the Public Sector Equality Duty (PSED) in Scotland. The Council recognises their responsibilities to ensure that no individual is treated unfairly or discriminated against based on any protected characteristic, including age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, or sexual orientation. While this policy seeks to address unacceptable behaviour that impacts staff wellbeing or service delivery, it does so with careful consideration to avoid disproportionately affecting individuals who may communicate or behave differently due to any of the above characteristics. Where staff suspect, or are aware that this is the case, they should seek the advice of the Council’s Equal Opportunities Officer. Reasonable adjustments will be made where appropriate to ensure that the policy is applied fairly and equitably to all. 4. Defining Unacceptable Actions 4.1. People may act out of character in times of trouble or distress. An action is not viewed as unacceptable purely because a person is forceful or determined. However, the actions of customers who are angry, demanding, disrespectful or persistent may result in unreasonable demands or unacceptable behaviour towards Moray Council staff. Moray Council has grouped these actions under three broad headings with an explanation as to how they will be managed: 4.2. Aggressive or abusive behaviour 4.2.1. We understand that customers can sometimes become angry. However, if that anger escalates into aggression towards staff or property, this is unacceptable. 4.2.2. We will try to remain calm and understanding of the customer’s situation; however, any aggression or abuse directed towards staff or property will not be tolerated. Page 78
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APPENDIX 1 Updated November 2025 4.2.3. Aggressive or abusive behaviour includes language (whether verbal or written) that may cause staff to feel afraid, threatened or abused and may include threats, personal verbal abuse, derogatory remarks and rudeness. 4.2.4. Inflammatory statements, remarks of a sexual, racial or discriminatory nature and false allegations are also abusive behaviour. 4.2.5. Unfair criticism of staff or eElected mMembers via a social media platform. 4.3. Unreasonable demands 4.3.1. A demand becomes unreasonable when it starts to impact excessively on the work of staff dealing with the matter, especially if these disadvantages other customers or service users. 4.3.2. For example: • Repeatedly demanding responses within an unreasonable timescale • Submitting an excessive number of emails over a short period of days • Not making it clear who an email is intended for and sending it to or copying in numerous recipients • Demanding responses from several members of staff on the same subject • Insisting on seeing, meeting or speaking to a particular member of staff when that is either not possible or it is inappropriate • Repeatedly changing the substance of an enquiry or complaint or raising unrelated concerns • Repeatedly posing a question, when a response has already been given, because the individual may not like the answer they have received 4.4. Unreasonable use of the complaints process 4.4.1. Contact becomes unreasonable when the effect of repeated complaints is to cause harassment or false defamation to our staff, or to prevent the council from pursuing a legitimate aim or implementing a legitimate decision. 4.4.2. For example, the customer: • Contacts the council repeatedly, continually changing the substance of the issue under discussion • Wishes contact with a particular member of staff or refuses to deal with the appointed staff member • demands unreasonable outcomes • demands responses within an unreasonable timescale Page 79
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APPENDIX 1 Updated November 2025 When this happens, the Council may decide that the customer behaviour has had an unreasonable impact on the work of the Ccouncil, its staff, or that it disadvantaged other service users or members of the public. We consider access to our complaints system to be important, and it will only be in exceptional circumstances that we would consider such repeated use as unacceptable – but we reserve the right to do so in such cases. 4.4.3. In exceptional cases, we reserve the right to refuse to consider a complaint or future complaints from an individual. Examples would include: • abusive and threatening behaviour towards employees or other service-users • persistent intimidation, bullying or harassment continues despite warnings having been provided • any type of assault on an employee or other service-user 4.4.4. We will consider the impact of withdrawing the complaint service on the individual and whether there would be a broader public interest in considering the complaint further. We will always tell the complainant what action we are taking and why. 4.5. Unreasonable levels of contact 4.5.1. The level of contact is unacceptable when the amount of time spent talking to a customer on the telephone, or reviewing and responding to written or electronic communication, impacts on the ability to deal with the relevant matter, or on the ability of staff to deal with other members of the public. 5. Managing Aggressive or Abusive Actions 5.1. Our staff will try to help a customer as much as they can; they appreciate that they may be in an unpleasant situation. If the customer is persistently abusive or aggressive to our staff, they will terminate contact and request police attendance if necessary. Abusive or aggressive behaviour can be physical violence, threatening behaviour/language, verbal abuse or harassment towards a person or by wilful destruction of property. 5.2. Where correspondence is received by any means, including social media, which is abusive to staff or contains inflammatory or malicious allegations that are unfounded, we will inform the customer that their language or the content of the message is considered offensive, unnecessary and unhelpful. Where possible we will remove such language and in other cases, we will ask the customer to edit their correspondence to remove any offensive text and resend it, otherwise we will not respond. 5.3. Where there are repeated incidents of aggressive or abusive behaviour, longer term decisions to restrict customer contact with the Council may be taken after careful consideration of the circumstances by a Head of Service, Chief Officer or Depute Chief Page 80
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APPENDIX 1 Updated November 2025 Executive Director/Chief Officer or nominated senior officer. In these circumstances, we will also take account of any services we are currently providing to the customer and whether they would be impacted. Wherever possible, the customer will be given the opportunity to change their behaviour before a decision to restrict contact is made. before a decision to restrict contact is taken. 5.4. If a Head of Service, Chief Officer, Executive Director or nominated senior officer forms the view that the level of unacceptable behaviour towards staff can no longer be tolerated, then they reserve the right to immediately impose restrictions without the need to provide a warning. This will only take place in exceptional circumstances, and the customer will be informed in writing of the reasons for this. 5.5. Where a customer has been identified as exhibiting unacceptable behaviour, this information will be shared with all departments who may have cause to deal with that customer. Where it is anticipated that a customer may become abusive or aggressive, a minimum of two staff members will be present. Such meetings may be required to take place in an open space covered by CCTV or similar systems. 6. Managing Unacceptable Actions 6.1. Unacceptable actions adversely affecting our ability to do our work and provide a service to others may result in restricted contact with the Council to manage them. We may restrict contact to: • in person • by telephone • by letter, text or email • assigning a single point of contact • any combination of these. We will try to maintain at least one form of contact. In extreme situations, we will tell the customer in writing that they are not entitled to personal face to face or telephone contact with staff. This means that contact with the Council will be restricted to either written communication or through a third party. 6.2. Where a customer unreasonably and repeatedly phones, visits offices, raises the same issue, is unfairly critical of staff or eElected mMembers via a social media platform or sends excessive written or electronic communication about which the relevance is not clear, we may decide to: • Limit customer contact to telephone calls at set times on set days • Restrict contact and written communication dealings to a nominated single point of staff contact • See the customer by appointment only • Restrict contact to written correspondence only • Inform the customer that calls will be ended immediately, and that written or electronic communication will not be responded to • Advise the customer that further irrelevant documentation will not be retained Page 81
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APPENDIX 1 Updated November 2025 • Advise the customer that their information will be logged, however no further correspondence will be sent • Take any other action that is considered appropriate to the circumstances 6.3. Where continued correspondence on a wide range of issues is excessive, the customer may be advised that only some of these issues will be considered in any given period and the customer will be asked to limit or prioritise their requests accordingly. 7. Deciding to Restrict Customer Contact & Advising the Customer 7.1. When a member of staff makes an immediate decision to end contact with a customer in response to unacceptable behaviour, the customer will be advised that contact is ceasing because of their unacceptable behaviour. The staff member will then submit an email to their line manager detailing the circumstances as this may inform future decisions to warn or restrict contact with the customer. Department managers will maintain a record of all warnings sent to customers. The record will be made between 1 April and 31 March period. 7.2. Decisions to restrict contact with the Council will only be taken after careful consideration of the situation by a senior manager. Wherever appropriate, we will give the customer the opportunity to modify their behaviour or action before a decision is taken. Customers will be told in writing why a decision has been made to restrict future contact, the restricted contact arrangements and, if relevant, the length of time that these restrictions will be in place. 8. Appealing a Decision to Restrict Contact 8.1. Where a customer has been informed that contact is to be restricted, they will be advised of their right of appeal. 8.2. Any appeal must be made in writing and submitted to the Depute Chief Executivethe Executive Director/Chief Officer or nominated senior officer of the service where the unacceptable action occurred. This must be made within 10 working days of the date of the letter advising restricted contact. Only in exceptional circumstances will an appeal made out with this timescale be considered. A wrA written letter of appeal should clearly set out why the customer feels the decision to restrict contact is unreasonable. 8.3. The appeal will be considered by the Depute Chief Executive Director or nominated senior officer for that service. If a conflict of interest is identified, then an Depute Chief Executive Director or nominated senior officer from another service will consider the appeal. The Depute Chief Executive Director or nominated senior officer considering the appeal will be provided with all the background information and any further information they require to review the case. Any reversal or amendment of the restriction arrangements will be at the discretion of the Depute Chief Executivethe Executive Director or nominated senior officer considering the appeal. The Chief Officer or their nominated senior officer will consider appeals in the same manner for Children Services. Page 82
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APPENDIX 1 Updated November 2025 8.4. The customer will be notified in writing of the outcome within 10 working days of receipt of their appeal. The Depute Chief Executive Director/Chief Officer or nominated senior officer reviewing the case's decision is final. 8.5. Thereafter all paperwork in relation to the process will be held by the Council's Complaints Officer. 9. Recording and Reviewing a Decision to Restrict Contact 9.1. Placing a customer on restrictions will be recorded and reviewed after 6 months. This will be effective from the date they were notified or from the date of a subsequent unsuccessful appeal decision. If unacceptable behaviour continues or restrictions are not adhered to then a Head of Service reserves the right to extend the review date by a further 6 months . SPSO have recommended through a complaint case that review dates should be no longer than 6 months. Heads of Service do have the option of proceeding at any time during the review date period to section 9.2. 9.2. In exceptional circumstances a Head of Service can place a customer on restrictions indefinitely and this would only be reviewed if the customer demonstrated a willingness to engage with our staff in an acceptable manner. 9.3. The Complaints Officer will maintain a record of customers who are subject of restrictions. 9.4. A report will be submitted by Service Departments to the Corporate Leadership Management Team to keep them aware of the number of cases where the Unacceptable Customers Actions Policy has been applied. This will detail all warnings and/or restrictions. If you need information from the Moray Council in a different format, such as Braille, audio tape or large print, please contact: 如果閣下需要摩里議會用你認識的語言向你提供議會資訊的話， 請要求一位會說英語的朋友或親人與議會聯繫 Jeżeli chcieliby Państwo otrzymać informacje od samorządu rejonu Moray w swoim języku ojczystym, Państwa przyjaciel lub znajomy, który mówi dobrze po angielsku, może do nas Se necessita de informação, do Concelho de Moray, traduzida para a sua língua, peça o favor a um amigo ou parente que fale Inglês para contactar através do: Jeigu Jums reikalinga informacija iš Moray regiono Savivaldybės [Moray Council], kurią norėtumėte gauti savo gimtąja kalba, paprašykite angliškai kalbančių draugų arba giminaičių susisiekti su mumis Чтобы получить информацию из Совета Морэй на Вашем языке, попросите, пожалуйста, Вашего друга или родственника, говорящих по английски, запросить ее Page 83
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APPENDIX 1 Updated November 2025 Si necesitas recibir información del Ayuntamiento de Moray en tu idioma. Por favor pide a un amigo o familiar que hable inglés que: Complaints Officer Chief Executive’s Office High Street Elgin IV30 1BX Page 84
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APPENDIX 2 SPFINANCE-565096732-34 28/10/2025 12:26 INTEGRATED IMPACT ASSESSMENT COVERING • EQUALITIES & SOCIO ECONOMIC DUTIES • HUMAN RIGHTS AND RIGHTS OF THE CHILD DATE UPDATES/EXECUTIVE SUMMARY VERSION DETAILS 08/10/2025 IIA for revised Unacceptable Customer Actions Policy One STAGE 1 - DO I NEED AN INTEGRATED IMPACT ASSESSMENT? Name of policy or proposal: Unacceptable Customer Actions Policy Is this a Mark X below New activity, programme or policy? Change to an existing activity, programme or policy? X Budget proposal? Duties: tick the boxes you think apply No Maybe Yes Equalities: Will your proposal have an impact on groups with protected characteristics? Consider the impact of your proposal on people and how they access your services and information without barriers. X Socio-economic Not every person/family has access to regular income or savings. Will your proposal have an adverse impact on them X Does your proposal impact on the human rights of people? X Does your proposal impact on the rights of children and young people X Reasoning Briefly describe your reasoning for the responses given above: There is a need to carry out an assessment of impacts through the Integrated Impact Assessment process to ensure that the policy is used and implemented in an appropriate way, taking into consideration the impact on protected characteristics groups, including children, so that it is properly understood and communicated. UCAP warnings/and or restrictions could apply to individuals from all listed protected groups. If you have answered “maybe” or “yes” to any of the Stage 1 questions above then proceed to complete the Stage 2 Integrated Impact Assessment questions below. Page 85
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APPENDIX 2 SPFINANCE-565096732-34 28/10/2025 12:26 If you have answered “no” to the Stage 1 questions above then provide the details below and submit to [email] Lead Officer for developing the contract Not Applicable Other people involved in the screening (this may be council staff, partners or others i.e. contractor or community) Not Applicable Date Not Applicable STAGE 2: INTEGRATED IMPACT ASSESSMENT Brief description of the affected service 1. Describe what the service does: The revised UCAP policy is applicable to the behaviour of customers using all services provided by the council to protect and safeguard all staff from unacceptable behaviours, speech, abuse and / or harassment. 2. Who are your main stakeholders? All customers, children and young people using our services from any protected group, staff and elected members. 3. What changes as a result of the proposals? Is the service reduced or removed? In proposed use of the revised policy, consideration was given to the impact of such use, and which groups could be affected. Staff need to ensure that a person’s context is known and fully considered when applying the policy. This will allow it to be used in a constructive way, setting out clearly what behaviours are considered as unacceptable, and can lead to moderated behaviours and more positive engagement. It is acknowledged that warnings and/or restrictions placed on individuals may create barriers around accessing council services. Policy uses needs to be carefully considered in this context. Many factors can create certain behaviours which can be difficult for council staff to manage without prior knowledge, such as vulnerabilities, mental health issues, addictions, trauma-related and / or domestic abuse situations This has been acknowledged within the policy, and content created to promote greater awareness of conditions which might cause unacceptable behaviours. Policy needs to ensure that diverse groups, who are not engaging positively can access advocacy services and support. The policy recognises that council staff are subjected to challenging behaviours and provides a process by which such behaviours can be properly managed. In highlighting that certain behaviours will not be tolerated; it provides staff and elected members with appropriate protection. By highlighting the policy to challenging customers, it can be used in a preventative way to help promote successful engagement rather than limit or prevent it Page 86
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APPENDIX 2 SPFINANCE-565096732-34 28/10/2025 12:26 altogether. Application of the policy and limiting contact may free up staff time to deal with other customers. There will be senior management awareness around who is being managed through the policy to ensure an appropriate consistency of approach. 4. How will this affect your customers? Those who are the subject of warnings and/or restrictions will be given the opportunity to engage meaningfully in a way that is suitable for any individual needs they may have. 5. Impact on staff providing the service – Staff and elected members will be afforded the protection they need to help provide a service to those identified as challenging customers. 6. Please indicate if these apply to any of the protected characteristics Protected groups Potential impacts and considerations Race Positive Impact – ensures staff are protected from abusive or harassing behaviour, hate language, etc. Clear standards improving workplace culture. Potential negative impact – individuals whose first language is not English may struggle to understand the policy, warning, restrictions. Can increase risk of discrimination re policy application (racial bias / language). Disability Potential Negative Impact – individuals with certain disabilities, learning difficulties, neuro-diversity or other specific vulnerabilities may be perceived to be problematic or have unacceptable behaviour due to lack of individual circumstances and labelled as having not understand the policy, warnings, restrictions. Carers (for elderly, disabled or minors) Potential Negative Impact – individuals who are carers may have to provide further support if the customer is on restrictions and is trying to support them with communications. Sex No impact identified Pregnancy and maternity (including breastfeeding) No impact identified Sexual orientation No impact identified Age (include children, young people, midlife and older people) No impact identified Religion, and or belief No impact identified Gender reassignment No impact identified Page 87
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APPENDIX 2 SPFINANCE-565096732-34 28/10/2025 12:26 Inequalities arising from socio- economic differences Potential Negative Impact – Disadvantaged individuals may be more dependent on council services/support than other groups and as a result may experience more frustration due to systemic issues. Risk that: • complaints treated as unacceptable behaviour rather than legitimate grievances • lack of digital access or literacy issues may cause lack of understanding re process, warnings, restrictions • communication with people who most need Council’s help is restricted. Human rights List of convention rights Describe, where applicable, if and how specific rights are engaged Article 5: Right to liberty and security Supports staff’s human rights to a safe working environment, clarifying boundaries of acceptable conduct. Warnings and/or restrictions may identify a need to ensure that a customer’s liberty or security is not compromised. Article 6: Right to a fair trial Not applicable Article 8: Right to respect for private and family life, correspondence and the home Warnings and/or restrictions may identify a need to ensure that the council continue to respect a customer’s right to a private and family life, correspondence and the home and provide support where needed. The UCAP is designed to provide reassurance that staff are able to conduct their duties and provide services without fear of intimidation or threat to them or their families – whether in person, or via inappropriate social media activity? Article 10: Freedom of expression Warnings and/or restrictions may risk infringing this right and how a customer wishes to express themselves, their right to a fair hearing and procedural fairness. Potential risk of arbitrary or disproportionate access to services. Potential for reputational risk if policy is seen as silencing or discriminating. Page 88
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APPENDIX 2 SPFINANCE-565096732-34 28/10/2025 12:26 List of convention rights Describe, where applicable, if and how specific rights are engaged Article 11: Freedom of assembly and association Not applicable. Article 12: Right to marry Not applicable. Article 14: Prohibition of discrimination (in relation to the convention rights) It is recognised that Article 14 is a provision under EHRC prohibiting discrimination in the enjoyment of the rights and freedoms set out in the convention. This may lead to it being associated with other articles where warnings and/or restrictions may have an impact on a customer with a protected characteristic. Article 1 of Protocol 1: Protection of property Warnings and/or restrictions may have an impact on how a customer wishes to protect their property. Article 2 of Protocol 1: Right to education Not applicable. Article 3 of Protocol 1: Right to free elections by secret ballot Not applicable. Children’s Rights and Wellbeing Relevant articles – UNCRC Article 2 – Non discrimination Risk of mislabelling younger children or those with additional support needs which could discriminate. Warnings and/or restrictions may identify a need to ensure that discrimination did not occur. Article 3.1 – Best interest of the child Risk of failing to consider the child’s best interests. Warnings and/or restrictions may identify a need to ensure that they were made in the best interests of the child. Article 6.2 – Right to survival and development Warnings and/or restrictions may identify a need to ensure that it didn’t adversely impact in way that would be detrimental to the child’s survival or development. Article 12 – Respect of the views of the child Risk of failing to give due weight to views of child. Warnings and/or restrictions may identify a need to ensure that the views of the child were considered and recorded. Article 13 – Freedom of Expression Warnings and / or restrictions may infringe this right. Page 89
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APPENDIX 2 SPFINANCE-565096732-34 28/10/2025 12:26 Article 18 – Parental Responsibilities and state assistance. Governments must support parents by creating support services giving the help they need. Potential impact if restrictions / warning in place. Article 23 – Children with a Disability Potential Negative Impact – individuals with certain disabilities, learning difficulties, neuro-diversity or other specific vulnerabilities may be perceived to be problematic or have unacceptable behaviour due to lack of individual circumstances and labelled as having not understand the policy, warnings, restrictions. Article 42 – Knowledge of rights Policy should support this right. 7. Evidence. What information have you used to make your assessment? Performance data The is no statutory requirement to provide UCAP performance data therefore none is currently available. Moving forward, department management will be asked to keep an annual record of warnings and restrictions. Internal consultation Consulted with CLT on revised policy and Equalities Officer. Consultation with affected groups Not applicable Local statistics No UCAP warning statistics retained. There has been no more than 3 customers on UCAP restrictions annually between 2022 and 2025. National statistics None recorded Other Not applicable 8. Evidence gaps Do you need additional information to complete the information in the previous questions? Equalities and socio-economic data is not always collected or robust so it can be difficult to identify individuals who may fall within any of the protected groups unless it is disclosed by the individual. It can vary across services and systems. 9. Mitigating action Can the impact of the proposed policy/activity be mitigated? Please explain Potential Mitigations to the impacts identified above include: • Formats - Policy, warnings, restrictions can be provided in alternative language, plain language, easy read version and/or visual formats where required to ensure understanding Page 90
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APPENDIX 2 SPFINANCE-565096732-34 28/10/2025 12:26 • Proportionality - Any restrictions should be no more than necessary to protect staff / service continuity and only used when all other options have been exhausted. • Staff training and awareness – training around disabilities, vulnerabilities, neuro- diversities, mental health and trauma-informed practice that may cause alternative behaviours. Recording – better equalities and socio-economic data to help staff better identify individuals that require enhanced communication considerations / support to ensure a full understanding of a customer’s circumstances and clear communication of reasons for any imposed warning/restrictions. 10. Justification If nothing can be done to reduce the negative impact(s) but the proposed policy/activity must go ahead, what justification is there to continue with the change? Positive Impacts - Could reduce costs / operational burdens caused by excessive / abusive contact, freeing resources, improving service quality and efficiency by reducing time spent on vexatious cases. The purpose of any warning/restrictions is aimed at helping customers to engage in a meaningful way whist ensuring the protection of staff and elected members. SECTION 3 CONCLUDING THE IIA Concluding the IIA 1. No potential negative impacts on any of the protected groups were found. 2. Some potential negative impacts have been identified. The impacts relate to: X Reducing discrimination, harassment, victimisation or other conduct prohibited under the Equality Act 2010 X Promoting equality of opportunity X Fostering good relations X 3. The proposals interfere with human rights and/or the rights of the child X 4. Negative impacts can be mitigated by the proposals set out in Q9 X 5. The negative impacts cannot be fully mitigated but are justified as Q10 X 6. Further consultation with affected groups is needed. No 7. It is advised not to go ahead with the proposals. Page 91
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APPENDIX 2 SPFINANCE-565096732-34 28/10/2025 12:26 Decision Set out the rationale for deciding whether or not to proceed with the proposed actions: The benefits of approving a revised UCAP is that staff and elected members will be afforded greater protection and a safe working environment to provide services which is balanced proportionately against the low number of customers that require warnings and / or imposed restrictions to ensure that they engage meaningfully with our staff. A final decision on the policy approval will be made at Committee on 4.11.2025. Date of Decision: 4/11/2025 Page 92
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APPENDIX 2 SPFINANCE-565096732-34 28/10/2025 12:26 Sign off and authorisation: Service Customer Experience, ICT & Digital Services Department Customer Experience, ICT & Digital Services Policy/activity subject to IIA Unacceptable Customer Actions Policy We have completed the integrated impact assessment for this policy/activity. Name: John Black Position: Complaints Officer Date: 8/10/2025 Authorisation by head of service Name: Chris Leonard Position: Head of Customer Experience, ICT & Digital Services Date: 9/10/2025 Permission to publish on website - Yes Please return this form to the Equal Opportunities Officer, Chief Executive’s Office. Page 93
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Report to: Corporate Committee Meeting Date: 4 November 2025 Report by: Executive Director Economy, Enterprise and Operations Author: Danny Bryceland MBE Contact Email: daniel.bryceland@moray.gov.uk Subject: Property Performance Indicators Report 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to inform the Committee of the Council’s property assets and provide an update to Committee of the current performance indicators. 1.2 This report is submitted to Committee in terms of Section III (B) (28) of the Council’s Scheme of Administration relating to formulating, supervising the implementation of and review as necessary the policies and practices of the Council in relation to asset management and to maintain an overview of the Council's property disposal programme. 2. SUMMARY 2.1 On 5 November 2024, the Committee were presented with the first Property Performance Indicator Report (para 11 of the minute refers). This is the second annual report for information. 3. RECOMMENDATIONS 3.1 It is recommended that Committee consider and note the reporting of the Property Performance indicators. Danny Bryceland MBE Asset Management Officer 4. BACKGROUND AND CONTEXT 4.1 On 12 December 2018, the Council approved a report which detailed recommendations aimed at improving how the Council manages and maintains its property assets (para 6 of minute refers), with updates on the actions provided to various committees since then. Item 10. Page 95
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4.2 At the meeting of this Committee on 11 June 2024, an update on each of the remaining actions was provided along with details of how property performance indicators would be developed and implemented (para 15 of minute refers). 4.3 The table below highlights each indicator as outlined throughout the report with figures for financial years 2022/23 - 2024/25. Indicator 2022/23 2023/24 2024/25 Annual electricity consumption (kWh) 11,475,718 11,481,741 11,641,880 Annual gas consumption (kWh) 23,675,047 22,8759,85 21,669,630 Annual Scope 1 carbon emissions from operational estate (CO2e) 5,135 4,828 4,428 Annual maintenance spend - Learning Estate (£) 1,035,317 1,175,341 1,084,173 Annual maintenance spend - Corporate Estate (£) 751,885 722,153 817,978 Annual capital spend - Learning Estate BB upgrade (£) 2,850,000 2,875,000 2,450,000 Gross internal floor area of operational property (m2) 221,564 215,719 278,535 Gross income from Industrial Portfolio (£) 2,085,000 2,269,000 2,572,892 Occupation of industrial portfolio as a % of floorspace 90.19 95.35 97 4.4 Energy Consumption – The performance indicators for energy usage outline the total consumption across all operational properties for the specified financial year. An Energy Strategy is in place to minimise consumption, with these indicators monitored to track progress. Detailed information on energy consumption is available in the annual report on Energy Consumption and Expenditure, last presented to the Economic Development and Infrastructure Services (ED&IS) Committee on 12 November 2024 (para 13 of minute refers). 4.5 Carbon Emissions – This performance indicator outlines the total Scope 1 carbon emissions from the Council's building operations, measured in tonnes of CO2. These direct emissions result from onsite fuel combustion, specifically from gas, oil, and biomass boilers used for heating buildings and water. To achieve the Council's Net Zero target, reducing these Scope 1 emissions is a priority. This report will demonstrate progress in lowering carbon emissions, while the annual Energy Consumption and Expenditure report, presented to the ED&IS Committee (as para 4.4), will detail the specific actions being taken to reduce Scope 1 emissions. 4.6 Annual Maintenance Spend – The performance indicators for maintenance expenditure detail the annual revenue spent on repairing and maintaining the Learning and Corporate Estate. This includes costs for cyclical maintenance to ensure statutory compliance, planned revenue maintenance, and reactive maintenance. Tracking these figures will reveal spending trends and enable members to monitor expenditure relative to the estate's overall floor area. Page 96
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4.7 Annual Capital Spend Learning Estate BB Upgrade – The learning estate consists of 53 schools – 8 Secondary Schools and 45 Primary Schools. Over the last 2 years fabric and component surveys have been undertaken to update the core condition ratings of the buildings in accordance with the Scottish Government requirement to update every 5 years. Updating is complete with the programme concluding in quarter 2 of 2025. Breakdown of school condition: • 2 schools (3.7%) are categorised as Condition D (Bad). • 32 schools (56.6%) are categorised as Condition C (Poor). • 18 schools (33.96%) are categorised as Condition B (satisfactory) – mandated condition by Scottish Government. • Of all B Condition schools, 17 of them have elements at Condition C and 1 of them has elements at Condition D. 4.8 The capital expenditure over the last 36 months and planned for the next 15 years is phased work that has, and will, focus on the priority core elements - roofs, walls, windows, doors, electrical and mechanical heating – in schools with a Condition D and C rating. Other core elements, where there is a medium/high risk of full or partial failure and works to ensure building standards compliance. Included works: • East End Primary – Door and window replacement, Wall Rendering. • New Elgin Primary – Water and Heating Pipework. • Milnes High School – Door and window replacement, Roof. • Speyside High School – Door and window replacement, Heating system upgrade. • Buckie High School – Security door and access upgrade. • General – Drainage improvements to several Primary Schools. 4.9 Gross Floor Area – This performance indicator outlines the total internal floor area of the Council’s Learning and Corporate Estate, indicating whether the overall footprint is expanding or contracting. This data is crucial for maximising asset utilisation. Over time, the floor area is expected to decrease. Additionally, this figure helps calculate the Council’s maintenance expenditure per square meter, which was £6.83/sqm for 2024/25. 4.10 Industrial Portfolio – These performance indicators show the gross income from properties and the percentage of occupied floor area, both of which have increased over the past 12 months. Detailed performance insights of the industrial portfolio are available in the annual Industrial Portfolio Annual Report, last presented to the ED&I Committee on 2 September 2025. (para 8 of the draft minute refers) 5. PROPOSALS 5.1 Committee to note the performance figures provided and note that with future year reports data trends and analysis will be undertaken to compare and track progress in the management of Moray Council’s assets. 6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Page 97
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Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X 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)) 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 This report has no specific implications relating to Policy and Legal. 6.4 Financial This report has no specific financial implications. 6.5 Risk There are no new specific risks outlined in this report. 6.6 Staffing There is no staffing implications identified within this report. 6.7 Best Value and Transformation There are no best value and transformation implications arising from this. 6.8 Property This report has no specific property implications. 6.9 Information Communications/Technology/Digital Page 98
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There are no information communications implications arising from this. 6.10 Equalities, Social Inclusion and Economic Impact There are no implications from this report. 6.11 Climate Change and Biodiversity Impacts The importance of minimising the use of carbon and making our properties as efficient as is viable is an underlying requirement for all Asset Management decisions going forward. The report has no direct Impacts. However, by highlighting our performance in relation to energy and carbon usage, this should aid in managing these factors more effectively in the future. 7. CONSULTATION 7.1 This report has been prepared in consultation with Head of Housing, Property and Communities, Chief Financial Officer, Service Manager Property, Estates and Assets, Service Manager Education Estate, Service Manager Legal Services, Service Manager Democratic Services and any comments made have been incorporated into the report. 8. BACKGROUND PAPERS 8.1 There are no background papers relevant to this report. Page 99
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Report to: Corporate Committee Meeting Date: 04 November 2025 Report by: Chief Executive Author: Suzanne Wilson Contact Email: performance@moray.gov.uk Subject: Performance Report (Financial Services) – Period to September 2025 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to scrutinise performance in areas of Service Planning, Service Performance and other related data to the end of September 2025 and note actions being taken to improve performance where required. 1.2 This report is submitted to Committee in terms of Section III (A) (4) of the Council’s Scheme of Administration to monitor performance in accordance with the Council’s Performance Management Framework. 2. SUMMARY 2.1 At the end of September 2025, actions relating to the Financial Services Service Plan for 2025-28 was 44% complete. Progress against Service Plan Priorities and operational Service Performance Indicators is presented in the table and charts below. Item 11. Page 101
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3. RECOMMENDATIONS 3.1 It is recommended that Committee scrutinises and notes performance in areas of Service Planning, Service Performance and other related data to the end of September 2025 and note actions being taken to improve performance where required. Suzanne Wilson Research and Information Officer 4. BACKGROUND AND CONTEXT 4.1 Each service plan sets out the planned strategic and service level priorities and outcomes it intends to deliver in the coming year aligning closely with financial planning, corporate and community planning partnership strategic priorities. 4.2 Service Plan actions are weighted to reflect priority ratings. Actions with higher priorities receive greater weightings which contribute more to the overall delivery of the Plan. Progress on Service Plan priorities and outcomes and key areas of operational performance is reported by exception, highlighting successes and giving assurances around the challenges and actions to support. Links to Service Plan Actions, priority ratings and weightings and Performance Indicators can be accessed within the background papers section of this report. Page 102
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4.3 Complaints are reported in terms of time taken to respond, outcomes and learning points. Links to Complaints tables can be accessed within the background papers section of this report. 4.4 Latest Local Government Benchmarking Framework (LGBF) results for 2024/25 are published throughout the year with final refresh of data around June 2026. The full suite can be viewed via the LGBF Dashboard. Published indicators for this service have been incorporated with the relevant section of this report depending on whether used to evidence progress against strategic, service level or service performance priorities. LGBF indicator targets and RAG status in the backing tables is now based on ranking thresholds aligning with exception reporting. 4.5 The Sustainable Development Statement was approved by the Corporate Committee on 5 November 2024 (para 16 of the Minute refers). The Statement draws out the way in which sustainable development is embedded in the Corporate Plan 2024-29 and wider corporate policies, strategies, and plans with progress being reported through several updates and reports, one of which is quarter 4 performance reporting. Service Plan actions and indicators that underpin the delivery of Sustainable Development Goals are highlighted in the backing table documents and comment where relevant is incorporated in this report. An overview of progress will be presented in the annual Corporate Plan progress update. 5. PROPOSALS Successes – Service Plan Strategic & Service Level Outcomes and operational Service Performance 5.1 Good progress has been made with Financial Planning. For Capital monitoring, a newly developed template for Budget/Target input has been successfully piloted and revised, with full implementation expected for financial year 2026/27. In relation to the Revenue budget, further amendments were made to the forecasting methodology with Auditors now assessing this recommendation, from the 2024/25 Annual Audit Review, as complete. (Strategic Level Action FIN25-28 Strat 4.1.1 and 4.1.2) 5.2 Implementation of the requirements of IFRS 16 is complete with final audited accounts confirming full compliance. (Service Level Action FIN25-28 5.1) 5.3 The longer-term objective to replace the Financial Management System has progressed, with market research of the options available now complete. The tendering and procurement process is expected to commence by the end of 2025. (Service Level Action FIN25-28 5.7.1) Challenges and actions to support – Service Plan Strategic & Service Level Outcomes and operational Service Performance Page 103
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5.4 At time of reporting, Participatory Budgeting (PB) spend stands at 12.61% of the allocated £2,339,000, with expenditure linked to Play Park upgrades during quarter 2 yet to be confirmed. While this remains well below target, this is a notable improvement against the 5.07% recorded at the end of quarter 2 2024/25 and perhaps reflects the revised approach taken by Accountancy to liaise directly with services regarding PB activity. (Strategic Level PI FS215) 5.5 Due to staff absence and other work pressures, progress is yet to be made with implementation of the annual Procurement Action Plan and service efficiency work for Taxation. Work is expected to commence with both during the second half of 2025/26. (Service Level Actions FIN25-28 5.2 and 5.5) 5.6 Progress with Financial Services actions within the Corporate Asset Management Plan have also been impacted by staff absence and prioritisation of other work however planning processes have been agreed and work will continue beyond the original target date of 30 September 2025. (Service Level Action FIN25-28 5.4) Complaints and MP/MSP Enquiries 5.7 Due to reporting timelines, quarter 2 complaint information is not yet available therefore quarter 1 data is presented. 5.8 During quarter 1, 14 complaints were closed: ten at Frontline, three at Investigative and one as Escalated. The average response time for Frontline complaints met the five-day Complaint Handling target however Investigative and Escalated complaints took slightly longer than their twenty-day target with an average of 24.67 days. 5.9 Two complaints were Upheld with four Part Upheld. Five complaints related to communication around council tax, either due to delayed responses or lack of detail. One complaint was a result of issues with viewing council tax bills on the Moray Council website. Staff have been reminded of the importance of dealing with correspondence in a timely and accurate manner while suggestions relating to the website will be taken forward by the Taxation Manager. 5.10 Financial Services received seven MP/MSP Enquiries: four relating to Council Tax with others covering Business Rates, Fees and Investment queries. Other Performance (not included in the Service Plan) 5.11 The audit of the annual accounts was completed ahead of the statutory deadline of 30 September and reported to Council on 24 September. Case Studies 5.12 Nothing to report. Consultation and Engagement Page 104
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5.13 Nothing to report. 6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X 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)) Improved Collaborative Leadership, as part of continuous improvement through Best Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. a) Links to Council Corporate Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following Council Plan strategic priorities: ☐ Tackle Poverty and Inequality. ☐ Build Stronger Greener Vibrant Economy. ☐ Build Thriving, resilient, empowered Communities. b) Links to Local Outcomes Improvement Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following local Outcomes Improvement Plan priorities: ☐ Developing a diverse, inclusive, and sustainable economy ☐ Building a better future for our children and young people in Moray. ☐ Empowering and connecting communities. ☐ Improving wellbeing of our population 6.3 Policy and Legal The Council has a statutory requirement to publish a range of information that will demonstrate that it is securing best value and assist in comparing performance both over time and between authorities where appropriate. Page 105
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6.4 Financial None arising from this report. 6.5 Risk None arising from this report. 6.6 Staffing None arising from this report. 6.7 Best Value and Transformation How councils plan for, manage and report on performance is a key area of focus in external audit work, particularly on best value. 6.8 Property None arising from this report. 6.9 Information Communications/Technology/Digital None arising from this report. 6.10 Equalities, Social Inclusion and Economic Impact None arising from this report. 6.11 Climate Change and Biodiversity Impacts None arising from this report. 7. CONSULTATION 7.1 This report has been prepared in consultation with the Chief Financial Officer and relevant Service Managers and any comments made have been incorporated. 8. BACKGROUND PAPERS 8.1 Service Plan Actions Service Plan Performance Indicators Service Performance Indicators Service Complaints Page 106
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Report to: Corporate Committee Meeting Date: 4 November 2025 Report by: Executive Director Education, Housing and Communities Author: Neil Stables Contact Email: performance@moray.gov.uk Subject: Performance Report (Governance, Strategy and Performance) – Period to September 2025 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to scrutinise performance in areas of Service Planning, Service Performance and other related data to the end of September 2025 and note actions being taken to improve performance where required. 1.2 This report is submitted to the Committee in terms of section III (A) (4) of the Council’s Scheme of Administration to monitor performance in accordance with the Council’s Performance Management Framework. 2. SUMMARY 2.1 At the end of September 2025, overall progress against the Governace, Strategy and Performance 2025/26 Service Plan was 51% complete. Progress against Service Plan Priorities and operational Service Performance Indicators is presented in the table and charts below. Due to the committee reporting timetable, performance indicator data is based on results as at June 2025. Item 12. Page 107
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3. RECOMMENDATIONS 3.1 It is recommended that Committee scruitinises and notes performance in areas of Service Planning, Service Performance and other related data to the end of September 2025 and note actions being taken to improve performance where required. Author Name Neil Stables Job Title Research & Information Officer 4. BACKGROUND AND CONTEXT 4.1 Each service plan sets out the planned strategic and service level priorities and outcomes it intends to deliver in the coming year aligning closely with financial planning, corporate and community planning partnership strategic priorities. 4.2 Service Plan actions are weighted to reflect priority ratings. Actions with higher priorities receive greater weightings which contribute more to the overall delivery of the Plan. Progress on Service Plan priorities and outcomes and key areas of operational performance is reported by exception, highlighting successes and giving assurances around the challenges and actions to support. Links to Service Plan Actions, priority ratings and weightings and Performance Indicators can be accessed within the background papers section of this report. Page 108
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4.3 Complaints are reported in terms of time taken to respond, outcomes and learning points. Links to Complaints tables can be accessed within the background papers section of this report. 4.4 Latest Local Government Benchmarking Framework (LGBF) results for 2024/25 are published throughout the year with final refresh of data around June 2026. The full suite can be view via the LGBF Dashboard. Published indicators for this service have been incorporated with the relevant section of this report depending on whether used to evidence progress against strategic, service level or service performance priorities. LGBF indicator targets and RAG status in the backing tables is now based on ranking thresholds aligning with exception reporting. 4.5 The Sustainable Development Statement was approved by the Corporate Committee on 5 November 2024 (para 16 of the Minute refers). The Statement draws out the way in which sustainable development is embedded in the Corporate Plan 2024-29 and wider corporate policies, strategies, and plans with progress being reported through several updates and reports, one of which is quarter 2 performance reporting. Service Plan actions and indicators that underpin the delivery of Sustainable Development Goals are highlighted in the backing table documents and comment where relevant is incorporated in this report. An overview of progress will be presented in the annual Corporate Plan progress update. 5. PROPOSALS Successes – Service Plan Strategic & Service Level Outcomes and operational Service Performance 5.1 The re-establishment of a Continuous Improvement framework across services with timetable and guidance has been completed. The Extended Corporate Leadership Team (ECLT) agreed the resourcing and schedule for the delivery of PSIF self assessment through to July 2026. From feeback received on the pilot session with HR, OD and ICT, an Interchange PSIF page and page on Engage have been developed which include checklist and guidance. Economic Growth and Development self-assessment began in quarter 2 with further PSIF sessions scheduled for services. (Action – GSP 2025-26 STRAT 1.1) 5.2 The project to provide emergency out-of-hours (OOH) support to Moray Council has been successfully completed. Initial complications with the intended supplier were resolved, with the Corporate committee approving an alternative supplier that met all necessary deadlines. The service went live on 30th June. The transition has been seamless, in part due to project team engaging with services and developing clear process maps of all OOH scenarios. The alternative supplier provides the service at a reduced fee compared to the anticipated cost. (Action – GSP 2025-26 DT&E 1.2) 5.3 Local Outcome Improvement Plan (LOIP) Delivery Frameworks were agreed by the Community Planning Board in August 2025. Reporting will be on a half yearly basis, the first progress report for the period to September will be reported to the Board in November 2025. (Action – GSP 2025-26 PM 1.1) Challenges and actions to support – Service Plan Strategic & Service Level Outcomes and operational Service Performance 5.4 The finalisation and sign off of the Moray Citizens Advice Bureau (CAB) Service Level Agreement has been delayed, however progress has been made over the reporting quarter Page 109
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following a CAB meeting in August. It is anticipated that the CAB Board will sign off the Service Level Agreement at their meeting in late September. (Action – GSP 2025-26 DT&E 1.5) 5.5 The review of the Performance Management Framework (PMF) has continued, however progress will gain pace over September and October to meet the review completion date for the end of November. A desktop review of other local authority PMFs has been completed. (Action – GSP 2025-26 PM 1.5) 5.6 The percentage of answered calls that were answered within 60 seconds improved in quarter 1 from the previous quarter to 58.1%. The answering rate remains well below the target 75%. The rate of calls answered within 60 seconds has increased by 7% compared to the same quarter last year, this is largely due to the lower call volume being received. (PI – CPS058a) Complaints and MP/MSP Enquiries 5.7 In line with the Performance Management Framework, complaints are reviewed quarterly by departmental management in terms of time taken to respond, outcome and learning points. Detailed tables can be accessed within the Background Papers section of this report. 5.8 Due to the timing of reporting the Governance, Strategy and Performance report to this Corporate committee, a full set of complaints for the first half of the reporting year were not available. Complaint analysis for this report covers quarter 1 period only. Four complaints, three frontline and one investigative, were closed during the quarter. All responses were delivered within target timescales. The three frontline complaints were upheld or partially upheld, all relating to Customer Services handling of calls. One was for a delay in responding to the customer, this was caused by a telephone line fault. The other two complaints related to customer advisor communication with customers, staff reminded of procedures and script in dealing with customers. All complaints were acknowledged with an apology and reinforcement action dually taken. Case Studies 5.9 Nothing to report. Consultation and Engagement 5.10 Nothing to report. 6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X Policy and Legal X Financial X Risk X Staffing X Page 110
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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)) Improved Collaborative Leadership, as part of continuous improvement through Best Value, will better enable the Council to fulfil the ambitions set out in its strategic plans. a) Links to Council Corporate Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following Council Plan strategic priorities: ☐ Tackle Poverty and Inequality. ☐ Build Stronger Greener Vibrant Economy. ☒ Build Thriving, resilient, empowered Communities. b) Links to Local Outcomes Improvement Plan – The proposals in this report support and contribute to improved outcomes for communities as outlined in the following local Outcomes Improvement Plan priorities: ☐ Developing a diverse, inclusive, and sustainable economy ☒ Building a better future for our children and young people in Moray. ☒ Empowering and connecting communities. ☒ Improving wellbeing of our population 6.3 Policy and Legal The Council has a statutory requirement to publish a range of information that will demonstrate that it is securing best value and assist in comparing performance both over time and between authorities where appropriate. 6.4 Financial There are none arising from this report. 6.5 Risk There are none arising from this report. 6.6 Staffing There are none arising from this report. 6.7 Best Value and Transformation How councils plan for, manage and report on performance is a key area of focus in external audit work, particularly on best value. 6.8 Property None arising from this report. 6.9 Information Communications/Technology/Digital None arising from this report. 6.10 Equalities, Social Inclusion and Economic Impact Page 111
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An Equality Impact Assessment is not required as this report is to inform the Committee on performance. 6.11 Climate Change and Biodiversity Impacts None arising from this report. 7. CONSULTATION 7.1 This report has been prepared in consultation with The Executive Director Education, Housing & Communication, Head of Governance, Strategy and Performance, Service Managers and any comments made have been incorporated into the report. 8. BACKGROUND PAPERS 8.1 Service Plan Actions Performance Indicators (Quarter 1) Service Complaints (Quarter 1) Page 112
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Report to: Corporate Committee Meeting Date: 4 November 2025 Report by: Executive Director Education, Housing and Communities Author: Suzanne Wilson Contact Email: performance@moray.gov.uk Subject: Performance Report - Human Resources, ICT and Organisational Development – Period to September 2025 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to scrutinise performance in areas of Service Planning, Service Performance and other related data to the end of September 2025 and note actions being taken to improve performance where required. 1.2 This report is submitted to Committee in terms of Section III (A) (4) of the Council’s Scheme of Administration to monitor performance in accordance with the Council’s Performance Management Framework. 2. SUMMARY 2.1 At the end of September 2025, the Human Resources, ICT and Organisational Development 2025-28 Service Plan was 46% complete. Progress against Service Plan Priorities and Indicators and operational Service Performance Indicators is presented in the table and charts below. Item 13. Page 113
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3. RECOMMENDATIONS 3.1 It is recommended that Committee scrutinises and notes performance in areas of Service Planning, Service Performance and other related data to the end of September 2025 and note actions being taken to improve performance where required. Suzanne Wilson Research & Information Officer 4. BACKGROUND AND CONTEXT 4.1 Each service plan sets out the planned strategic and service level priorities and outcomes it intends to deliver in the coming year aligning closely with financial planning, corporate and community planning partnership strategic priorities. 4.2 Service Plan actions are weighted to reflect priority ratings. Actions with higher priorities receive greater weightings which contribute more to the overall delivery of the Plan. Progress on Service Plan priorities and outcomes and key areas of operational performance is reported by exception, highlighting successes and giving assurances around the challenges and actions to support. Links to Service Plan Actions, priority ratings and weightings and Performance Indicators can be accessed within the background papers section of this report. Page 114
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4.3 Complaints are reported in terms of time taken to respond, outcomes and learning points. Links to Complaints tables can be accessed within the background papers section of this report. 4.4 Latest Local Government Benchmarking Framework (LGBF) results for 2024/25 are published throughout the year with final refresh of data around June 2026. The full suite can be viewed via the LGBF Dashboard. Published indicators for this service have been incorporated with the relevant section of this report depending on whether used to evidence progress against strategic, service level or service performance priorities. LGBF indicator targets and RAG status in the backing tables is now based on ranking thresholds aligning with exception reporting. 4.5 The Sustainable Development Statement was approved by the Corporate Committee on 5 November 2024 (para 16 of the Minute refers). The Statement draws out the way in which sustainable development is embedded in the Corporate Plan 2024-29 and wider corporate policies, strategies, and plans with progress being reported through several updates and reports, one of which is quarter 4 performance reporting. Service Plan actions and indicators that underpin the delivery of Sustainable Development Goals are highlighted in the backing table documents and comment where relevant is incorporated in this report. An overview of progress will be presented in the annual Corporate Plan progress update. 5. PROPOSALS Successes – Service Plan Strategic & Service Level Outcomes and operational Service Performance 5.1 Good progress has been made to address workforce planning issues with an amended Plan approved at the meeting of this committee on 26 August 2025 (item 12 of the agenda refers). A report covering the agreed priorities arising from the 2025 Employee Survey will be submitted to the Corporate Leadership Team (CLT) and service level information shared with Heads of Service and Service Managers. An employee booklet is also being drafted. (Strategic Level Action HROD25-28 Strat 4.5) 5.2 Work to develop and expand the Council’s digital approach is reported at 67% complete against a due date of March 2027. Since April, eight more public facing forms have gone live including music centre registrations, assisted waste collections and issue reporting for local access forum. Work continues in several other key areas such as council tax and non-domestic rates, damp and mould reporting and integration with Gov.UK Pay. Trialling of Copilot has been extended with 75 licenses while for all other staff, details of the free Microsoft 365 version have been shared. (Strategic Level Action ICT25-28 Strat 4.1) Page 115
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5.3 Following approval at the meeting of this committee on 10 June 2025 (para 14 of the minute refers), implementation of the revised Succession Planning approach has progressed with supporting documentation and awareness raising complete. Work continues to finalise baseline data and reporting methods. (Service Level Action HROD25-28 Serv 5.1) 5.4 Development work relating to communication and engagement has progressed well with the corporate vision and priorities incorporated into the comms plan and included in quarterly reports. Moray Engage is now live and the Comms Team continue to provide support to ensure this platform is embedded across the organisation. Monthly manager meetings are also now in place. (Service Level Action HROD25-28 Serv 5.3) 5.5 Staff across HR, ICT and OD took part in the pilot Public Service Improvement Framework (PSIF) self-evaluation. A good response was received to the online checklist with 15 participants taking part in consensus sessions. Agreed priorities have now been included in an improvement plan shared with the Service for action. (Service Level Action HROD25-28 5.5 and ICT25-28 5.6) Challenges and actions to support – Service Plan Strategic & Service Level Outcomes and operational Service Performance 5.6 Due to the focus on developing the new Digital Strategy for 2025-28, progress to enhance the value of data with a corporate data strategy is reported at 5%. Discussions have taken place with the Scottish Government regarding the Data Maturity programme and assessment and with the Digital Strategy approved (item 14 of Corporate Committee agenda 26 August 2025 refers) this action is anticipated to make progress during the second half of the year. (Strategic Level Action ICT25-28 4.2) 5.7 Following discussion with the Corporate Leadership Team, it has been agreed to review existing timescales and undertake a more targeted approach to creating a culture where employees are empowered and ready for change. Culture Change is a long-term process and work in this area has increased with the recent management restructure. A renewed focus will also help progress the wider transformation agenda. (Service Level Action HROD25-28 Serv 5.2) 5.8 Initial work to support workforce related actions within the Best Value Plan is complete but development and further analysis of employee survey responses will continue out with target timescales (June 2025). (Service Level Action HROD25-28 5.4) 5.9 To help improve visibility of upcoming system replacements, a standardised evaluation template has been developed and shared with system owners. Completion of this evaluation has taken longer than expected due to the availability of these owners and work will continue with a revised due date of December 2025. (Service Level Action ICT25-28 5.4.1) Page 116
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5.10 Implementing ICT and digital related actions within the Best Value Plan is reported at 20% complete against a due date of March 2026. Ongoing recruitment to vacant posts across ICT has resulted in the prioritisation of some other work however a Cyber Resilience and Information Security Team is established and a supplier selected for testing the cyber incident response plan. A draft security policy is also nearing completion. Business Continuity work will progress once recruitment is complete. (Service Level Action ICT25- 28 5.5) 5.11 ICT actions relating to workforce planning have begun with ensuring key projects are resourced appropriately e.g. Carefirst, CRM/Lagan replacements. Skills and knowledge transfer is planned within the sphere of cyber resilience to expand the knowledge and understanding of the fundamentals of cyber resilience. (Service Level Action ICT25-28 5.8.1). 5.12 Two online training modules were made available at the end of quarter 1 covering ‘Remote Working’ (for corporate staff and Elected Members) and ‘Ransomware’ (for Education staff). Across both courses, uptake has been low at 40%. To address this, online training has been reviewed and will now be published three times per year avoiding holiday periods. (Service Plan Performance Indicator ICT003) 5.13 Latest available data shows incidents of Violence and Aggression fell by 23% in quarter 1 to 918. Of these, 774 incidents were reported by Education, a decrease of 292 compared to the previous quarter. As part of work to support the Health and Wellbeing of employees, a short life working group provided guidance and policy development to assist in the implementation of the Additional Support Needs (ASN) action plan. Leadership of this group has now transferred to Education however support continues to be provided as required. (Service Level Action HROD25-28 5.6.2 and Service Performance Indicator HROD006) Complaints and MP/MSP Enquiries 5.14 Due to reporting timelines, quarter 2 complaint information is not yet available therefore quarter 1 data is presented. 5.15 Human Resources, ICT and Organisational Development received no complaints during quarter 1. 5.16 One MSP/MP enquiry was received regarding employee policy. Other Performance (not included in the Service Plan) 5.17 Advice and support are being provided to assist with the ongoing recruitment to Senior Management posts arising from the recent restructure. Along with additional employee survey work, this has had a substantial impact on planned work relating to employment policy reviews. While the timeframe for Page 117
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this work is the end of quarter 4, there was a commitment to accelerate some policies for this committee. This has proved challenging and further prioritising of work and demands is underway to focus on the most urgent areas, including the Whistleblowing Policy which should be completed by December. 5.18 Foundational work on the development of the i-Trent HR/Payroll system has begun with a view to automating submission, authorising and processing of timesheets and travel/expense claims. Case Studies 5.19 Nothing to report. Consultation and Engagement 5.20 Nothing to report. 6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X 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)) 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. Page 118
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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 The Council has a statutory requirement to publish a range of information that will demonstrate that it is securing best value and assist in comparing performance both over time and between authorities where appropriate. 6.4 Financial None arising from this report. 6.5 Risk None arising from this report. 6.6 Staffing None arising from this report. 6.7 Best Value and Transformation How councils plan for, manage and report on performance is a key area of focus in external audit work, particularly on best value. 6.8 Property None arising from this report. 6.9 Information Communications/Technology/Digital None arising from this report. 6.10 Equalities, Social Inclusion and Economic Impact None arising from this report. 6.11 Climate Change and Biodiversity Impacts None arising from this report. 7. CONSULTATION 7.1 This report has been prepared in consultation with the Head of Human Resources, ICT and OD and relevant Service Managers and any comments made have been incorporated. 8. BACKGROUND PAPERS Page 119
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8.1 Service Plan Actions Service Plan Performance Indicators Service Performance Indicators Service Complaints Page 120
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Report to: Corporate Committee Meeting Date: 04 November 2025 Report by: Executive Director Economy, Enterprise and Operations Author: Alasdair McEachan Contact Email: alasdair.mceachan@moray.gov.uk Subject: Best Value Action Plan Progress Reporting 1. PURPOSE ☒ For Decision ☐ For Information 1.1 To note progress against the actions in the Best Value Action Plan. 1.2 This report is submitted to Committee in terms of paragraph III B (7) of the Council’s Scheme of Administration, monitoring the Council’s Best Value Action Plan. 2. SUMMARY 2.1 The Council’s refreshed Best Value Action Plan was approved by the Corporate Committee on 26 August 2025. The Action plan includes improvement actions taken from external audit recommendations and internal self-assessment and elements of transformation. 2.2 This report summarises the progress in relation to each of the Best Value themes within the Action Plan and includes one further action taken from the Council’s Annual Audit report which was considered by the Council on 24 September 2025, item 6a. 3. RECOMMENDATIONS 3.1 It is recommended that the Committee reviews and notes progress against the actions in the Best Value Action Plan detailed in Appendix 1. Alasdair McEachan Chief Governance 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: Item 14. Page 121
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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: • Vision and leadership • Governance and accountability • Effective use of resources • Partnerships and collaborative working • Working with communities • Sustainability • Fairness and equality 4.3 The Corporate Committee on agreed a refreshed Best Value Action Plan on 26 August 2025 that set out the Council’s priorities for the next 3 years to enable it to meet its Best Value duty (item 8). The Plan takes into account a number of actions from external audit reports and from internal self-assessment and the Committee has agreed to receive quarterly updates. 4.4 The Council’s annual audit report prepared by external auditors Grant Thornton was considered by the Council at its meeting on 24 September 2024. This report contained two further material recommendations in relation to best value which have been incorporated in the Best Value action plan : • Capital Planning recommendation to set a realistic capital plan to reduce the need for budget amendments. Management response contained agreement to develop more detailed timelines for capital projects to improve forward planning. • Management restructure. Recommendation that plans are in place in case recruitment to new posts is unsuccessful. Changes to be reflected in constitutional documents and evaluation of success, following implementation. 4.5 The updated Best Value Action Plan, showing progress is attached as Appendix 1 to this report. Progress can be summarised as follows: • Vision and Leadership: PSIF work progressing as planned. Guidance being drafted to improve quality of presentation of “summary of implications” information within committee reports • Governance and Accountability. Community engagement platform is now live Work progressing with business continuity and cyber resilience plans for critical services however not as quickly as planned. • Effective use of resources: Transformation strategy subject to separate reporting • Financial reporting: less slippage in capital plan. Transformation plan and budget gap to inform medium to long term financial plan • Partnership and Collaborative Working: slower progress due to partners having competing priorities. • Sustainable development: Climate strategy agreed and subgroup of Moray Economic Partnership to identify shared priorities. Date extension sought: 31.3.26. 4.6 Moving forward, the Council has begun to re-activate use of the Public Sector Improvement (PSIF) framework which is a national tool from the Improvement Service that Page 122
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is used across local government. The purpose of PSIF is to provide a structured approach for Councils to assess their performance, identify areas for improvement, and ultimately deliver better outcomes for communities. It acts as a self-assessment tool to help understand what is working well, compare performance with others and pinpoint areas for attention. The framework is useful in ensuring local services are efficient, effective and responsive to the needs of citizens. The Council previously used PSIF extensively, particularly in services where there were no alterative improvement tool or inspections. Recently, the Improvement Service has supported its reactivation beginning in HR, ICT and Organisational Development. Therefore, from 2026 onwards it is proposed to use the PSIF framework for the corporate annual self-assessment. 5. PROPOSALS 5.1 It is proposed that the Committee considers and approve the refreshed Best Value Action Plan in Appendix 1 and that the PSIF framework is used for the corporate annual self- assessment from 2026 onwards. 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 X Best Value and Transformation √ Property X Information Communications Technology/Digital X Equalities. Social Inclusion and Economic Impact X 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. The Best Value Action Plan supports the Council to deliver the priorities in the corporate plan and supports the Council values of Improving: drive improvement; Ambitious: ensure sustainable and efficient services; and Responsive: promote community participation and involvement and involve our communities. 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. Page 123
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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 The Best Value Action Plan supports the Council to fulfil its statutory duty to demonstrate Best Value, introduced in the Local Government (Scotland) Act 2003. 6.4 Financial There are no specific financial implications, however, the Best Value Action Plan supports the Council in its duty to make best use of resources and there are a number of specific actions that relate to financial management that are moving forward. 6.5 Risk There are risks associated with not making adequate progress on the actions set out in the Best Value Action Plan. The Council has had feedback from a number of external stakeholders that identified areas for improvement and failure to address these through the planned actions is likely to lead to adverse reporting and implications for the Council. Several of the Best Value themes feature on the Council’s Corporate Risk Register including leadership, financial sustainability and workforce development. Progressing the actions in the Plan will also secure improvements in the management of these risks. 6.6 Staffing There are no specific staffing implications arising from this report. 6.7 Best Value and Transformation The implications are as set out in the report 6.8 Property None. 6.9 Information Communications/Technology/Digital None 6.10 Equalities, Social Inclusion and Economic Impact This is covered in the Best Value inspection regime itself and the Council’s duty to deliver best value. 6.11 Climate Change and Biodiversity Impacts Sustainable development is a theme with the Best Value Action Plan 7. CONSULTATION Page 124
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7.1 This report has been prepared in consultation with Extended Corporate Leadership Team (E/CLT) who have contributed to the action plan update set out in Appendix 1 and any comments made have been incorporated into the report. 8. BACKGROUND PAPERS 8.1 Corporate Committee report on Best Value Action plan 23 April 2024 (item 5a) 8.2 Corporate Committee report on 27 August 2024 Best Value Action Plan (item 11) 8.3 Corporate Committee report on 5 November 2024 Best Value Action Plan (item 8) 8.4 Corporate Committee report on 28 January 2025 Best Value Action Plan (item 7) 8.5 Corporate Committee report on 10 June 2025 Best Value Action Plan (item 6) 8.6 Corporate Committee report on 28 August 2025 Best Value Action Plan (item 8) Page 125
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Appendix 1 Best Value Action Plan 2025-2026: Progress Update Report Update: Corporate Committee – 4 November 2025 Ref: 002 1. Vision and Leadership: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log *New Aug 2025* Collaborative Leadership – ensuring Members and Officers work effectively to secure key decisions 1.1 Strengthen links to strategic documents in Committee reports AMcE 01/10/2025 31/03/2026 40 Sept 2025: Discussion at CLT around need for further guidance for authors on how to manage the new report template and “Summary of implications” section. Risk remains static within Corporate Risk Register. July 2025: New Committee template in place with ability to show links. Additional report drafting guidance being considered on how to complete the sections. Committee Services working on guidance aim to put revised guidance in place by Dec 25. Community and Partner Engagement on Council priorities 1.2 Working with Community Planning Partners (CPP) to develop shared engagement ED (FST) 01/07/24 30/06/26 85 Sept 2025: Online Moray Engage now active and presentation/report was provided to CPP Board meeting. Update report on community engagement drafted for consideration by CPOG. July 2025: Discussion held with Community Engagement Group to reflect on the findings from the CPB self-assessment undertaken with the Improvement Service and consider how best to go forward taking account of the recent experience and report on community engagement within the CPB. It was noted that CPOG to note community engagement position Consider resourcing for community planning Page 126
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1. Vision and Leadership: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log there had been significant change in working practices over the years and that there had been less value in the CEG as a result. Work is underway on a refreshed Community Engagement Strategy for the CPB. The Council online engagement tool will also be shared with partners in August giving an opportunity for shared engagement to be highlighted . It is proposed that that date for finalising this work is revised to take account of the challenges of resourcing community planning, which are noted as an area for consideration the planned review of council structures. Continuous Improvement – implement self-evaluation 1.3 Consider and establish service score cards to provide overview to develop and track service improvement corporately Head/ CSP&C 01/08/24 31/03/26 60 Sept 2025: HR/OD self-assessment complete. Moray Engage in use for checklist, interchange page created to hold introduction. EGD PSIF underway and programme to July 2026 in place. July 2025: Use the HR /OD self-assessment (currently underway) to consider how best to capture actions to allow these to be tracked and monitored. Consider where best to capture actions and whether Pentana (performance information system) work meets Scorecard expectation. Page 127
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2. Governance and Accountability: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Risk Management 2.1 Business Continuity Plans to be in place for all critical services AMcE 28/03/24 31/12/25 50 Sept 2025: Work is ongoing to refine the template plan to services to tailor their response/mitigation measure for a wider range of potential disruption events. This is a more sophisticated approach than that previously adopted and should ensure better resilience. July 2025: Critical services identified. Updating of Business Continuity Plans is being progressed alongside risk management practice and has regard to complementary emergency planning arrangements. Resilience levels can be affected by change as identified in the latest update of the Corporate Risk Register with issues including financial constraints and reductions in staffing impacting on capacity to maintain continuity of services. Corporate support to ensure plans are periodically updated to reflect the impact of change will be on- going beyond the end date reported here. Sept 2025: Finalise revised BC plan template for Nov 25. July 2025: Progress on individual services BC plans has not progressed as quickly as anticipated due to finite central resource and pressures on services to undertake their assessments. Work will continue to refresh Business Continuity Plans held within critical services. Although a date is specified, this work should be a constant cycle of review. A workshop with elected members to develop a risk appetite statement is scheduled for October 2025 and this will include consideration of risks to business continuity arising from operational change and the extent to which these can be mitigated in the current operating environment. CLT consideration of critical services and update 08 May 2025. Page 128
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2. Governance and Accountability: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Risk Management 2.2 Business impact assessments (resilience) completed for all services. AMcE 28/03/24 30/04/26 70 Sept 2025: As below. July 2025: Critical services have been identified through business impact assessment and Business Continuity Plans are being developed for these services. Sept 2025: Process will be embedded as a cyclical programme. Page 129
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Digital Resilience Management 2.3 Complete implementation of Cyber Resilience Plan H/CE, ICT&DS 28/03/24 31/12/25 45 Sept 2025: Recruitment and selection process has taken longer than expected however, appointment of remaining Senior ICT Officer post is imminent. The consequential vacancy for the ICT Team Leader (Server & Network Team) arising from the internal appointment to cyber team has also been delayed. As a result, the ICT Team Leader (Cyber Resilience and Information Security Team) has primarily been focusing on the SWAN 2 project, which is a key priority to provide additional bandwidth for schools, and which has a deadline of December 2025. Progress on the cyber action plan, the Information Security Policy, and the desktop exercise for Incident Response, has therefore been limited. Cyber awareness training on Remote Working for corporate staff, and Ransomware for teachers and staff in schools has been undertaken. Going forward, future training modules will be launched in January, May, and September to avoid holiday periods. A requirements specification has been drafted for the procurement of external ICT security services. There is an expectation that all Councils will undertake Cyber Essentials certification as well as the PSN accreditation process. The requirements specification needs to be adjusted accordingly before running the competitive procurement exercise. Sept 2025: Catch up on work for cyber action plan, the Information Security Policy, and the desktop exercise for Incident Response. Undertake next phishing simulation in October. Finalise on security awareness modules for 2026. July 2025: Complete recruitment and selection process. Review and update Cyber Resilience Action Plan with revised prioritisation and timescales to be able to move to business as usual position and close this action off. Final draft of Information Security Policy. Undertake desktop exercise for Cyber Incident Response Planning. Define work programme for 2025/25 cyber awareness training. Award contract for IT Health Check and Penetration testing. Page 130
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2. Governance and Accountability: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log July 2025: Cyber Resilience and Information Security Team established. Recruitment for Senior ICT Officer post in progress. Work progressing on ICT Information Security Policy: target for final draft is Sep 25. Supplier selected for testing of cyber incident response plan. Results from simulated phishing exercise showed an improvement on baseline results. Work in progress for next simulation. Next training modules launched for cyber awareness. PSN accreditation process complete. Work has started on procurement of supplier for next submission. Further penetration testing undertaken for online services and work in progress for penetration for employee self service on HR / Payroll system. Digital Resilience Management 2.4 Complete Business Continuity Plans/work for corporate and service cyber resilience H/CE, ICT&DS 28/03/24 31/03/26 50 Sept 2025: As indicated in 2.3 above, there has been limited resource available to progress this. July 2025: Limited progress during Q1. Priority for Q2. Establishment of dedicated team will help to progress this. Sept 2025: Draft final version of BC plan. July 2025: Draft final version of BC plan. Page 131
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2. Governance and Accountability: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Management restructure New Sept 2025 2.5 Ensure the Council is actively recruiting to the vacant posts within the management structure and the plans are in place should the recruitment process be unsuccessful. Ensure constitutional documents are updated, interim arrangements are in place and post implementation evaluation is carried out. CE 01/09/2025 50 Sept 2025: A number of vacant posts have been filled however there are still significant gaps within the directorate of Finance, Strategy and Transformation and the post of permanent Chief Social Work Officer. CE has put interim arrangements in place for covering vacant posts and report due to December full Council to amend Scheme of Delegation. Second round of recruitment with revised advertisement focus is underway. Page 132
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3. Effective Use of Resources: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Transformation and Sustainable Services 3.1 Stage 3: Future council programme (normal business) CE / ED (FST) 01/08/24 28/08/26 50 Sept 2025: Council on 24/9/25 approved Stage 3 of the Transformation Strategy and update set of projects to support delivery of the strategy July 2025: The Council on 25 June 2025 agreed reports on the Depot Review, Customer Services and the way forward for the Out of Hours project. Workshops have been held with councillors/ECLT (March) and the Leadership Forum for service managers on 11 June 2025. Work is underway to review the outcomes and incorporate these into Phase 3 of the Transformation Strategy for reporting to Council in September Sept 2025: Development of projects and new areas for consideration by Transformation Board June 2025: report to Council in September on Transformation Strategy Smarter working phase 2 update report to council 4/12/2024 (item 19) Libraries report council 22/10/2024 (item 10 - confidential) Review of OOH report 22/10/2024 council (Item 12 - confidential) Corp cttee update on 5/11/2024 (item 16) Accts comm overview report Page 133
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3. Effective Use of Resources: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Transformation and Sustainable Services 3.2 Establish corporate oversight to ensure pace, prioritisation, new opportunities, ongoing development and delivery of benefits CE / ED (FST) 01/08/24 30/01/26 50 Sept 2025: Updated agenda and reporting format prepared for Transformation Board to improve oversight, tracking and consistency of reporting format for committee. Council on 24/9/25 approved Stage 3 of the Transformation Strategy and update set of projects to support delivery of the strategy July 2025: Work is ongoing to prepare the next stage of the Transformation Strategy. This will include oversight of the existing projects to ensure that appropriate prioritisation is in place in relation to alignment with council priorities and that target dates are appropriate to ensure pace. This will be reported to the Council in September. Work on project governance has been initiated but resource challenges make steady progress on this difficult. Page 134
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3. Effective Use of Resources: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Transformation and Sustainable Services 3.3 Build in engagement with communities and staff about the need for change and impact any mitigation of proposed changes. CE / ED (FST) 01/08/24 30/01/26 70 Sept 2025: Community engagement work continues though the Moray Engage online engagement platform. In addition, Leisure user groups have been formed and initial meetings underway. July 2025: Community engagement work continues as part of the Council's approach to ensuring local needs and user perspectives are built into service design and change. 2 public meetings have been held for learning estate, library user groups are established and meeting and leisure user groups are being instigated. The procurement of the online engagement tool is completed and implementation work is well advanced with launch planned over the summer Sept 2025: Leisure user groups to meet. Continued promotion and use of the online engagement tool. July 2025: Leisure user groups to be established Online engagement tool to launch Transformation and Sustainable Services *New Aug 2025* 3.4 Annual reporting on Transformation Strategy and Moray Growth Deal to be aligned Ref: BV Thematic Action 3 CE / ED (FST) 01/04/26 30/06/26 n/a Sept 2025: Discussions are ongoing about aligning reporting streams. Meantime transformation board updates are being re formatted to show similar alignment. Reporting will be aligned in 2026 and discussions between relevant officers ongoing. BV thematic report Corp cttee 26/08/25 Page 135
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3. Effective Use of Resources: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Transformation and Sustainable Services *New Aug 2025* 3.5 Review Transformation Programme Governance Ref: BV Thematic Action 7 CE / ED (FST) tbc 30/03/26 n/a Sept 2025: A light touch review has been completed with a substantive review postponed until recruitment to the Head of People, Change and Community Strategy is completed BV thematic report and transformation report Corp cttee 26/08/25 Financial Management 3.6 The Council will strengthen monitoring of the delivery of the Capital Plan and take action to address any slippage. Ongoing quarterly. 3.7 New Sept 25 Ensure capital budget set in advance is realistic, reducing the need for significant budget amendments in the first months of the financial year. LP 01/07/24 31/03/2026 30 Sept 2025: Q1 report introduced a target spend of 90% of budget to date – slippage of over 10% in any asset class will be reported to Corporate Committee for individual scrutiny July 2025: Out-turn for 2024/25 (reported June 2025) shows a significant decrease in slippage from previous years - 90% compared to 71% completion in 2023/24 Capital budget managers are being challenged to develop more detailed timelines for their projects to improve forward planning. October to December 2025: Review of capital plan 2026 to 2029 including detailed phasing review Officers use only: Guidance for Budget Monitoring to Committee Capital Plan 2024/2025 04/12/2024 Q1 capital report to Corporate Committee 26 August 2025 Page 136
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3. Effective Use of Resources: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Financial Management *New Aug 2025* 3.8 Next iteration of Medium to Long Term Financial Strategy to be updated to explicitly include link with Transformation Strategy and reducing budget gap and Transformation as drivers Ref: BV Thematic Action 2 LP 01/01/26 28/02/26 n/a Sept 2025: Update planned for February 2026 to meet timescale for 2026/27 budget. Commence update including link with latest transformation Strategy update BV thematic report Corp cttee 26/08/25 Page 137
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4. Partnership and Collaborative Working: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Partnership Working for Moray 4.1 Work with Community Planning Partners (CPP) to develop shared priorities for incorporation into Local Outcome Improvement Plan (LOIP) CE/ ED (FST) 28/03/24 31/10/26 30 Sept 2025: Changes in senior representation at CPOG / CPB have delayed the ability to progress the development of new LOIP. CPP sessions to be planned. Dec 2024: The most recent development session on 24/10 considered opportunities to further develop community engagement in the delivery of priorities. Development sessions been held with community planning partners to consider priorities and how can take forward collectively. Agreement reached on focus and main priorities for LOIP. This will inform the updating of the LOIP and development of approach to delivery Plan and undertake CPOG / CPB session to identify and agree process and resource to progress work. Page 138
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4. Partnership and Collaborative Working: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Partnership Working for Moray 4.2 Investigate and develop potential single Moray Plan CE / ED (FST) 28/03/24 31/10/26 12 Sept 2025: Changes in senior representation at CPOG / CPB have delayed the ability to progress the development of new LOIP and consideration of a potential single Moray Plan. CPP sessions to be planned. Nov 2024: Research completed of other councils established that 2 have single plans (noted below). Discussion taken place with Improvement Service for support on this area. Potential for IS to undertake element of work if funded. This has been raised at the development sessions with the CP Board and there has been general support for the approach. To be considered further as the LOIP is re- developed. Currently 2 of 13 family group authorities have a single plan, Midlothian and Fife. Clackmannanshire also have a variation which is being looked at. Plan and undertake CPOG / CPB session to identify and agree process and resource to progress work. Page 139
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4. Partnership and Collaborative Working: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Partnership Working for Moray 4.3 Identify opportunities to maximise the impact of resources and budgets through alignment of activity. CE / ED (FST) 28/03/24 31/10/26 10 Sept 2025: Early discussions have commenced with partners to identify areas to align activity – e.g at Chief Officers Group, MIJB, NHS Grampian, Imrpovement Service Dec 2024: There has been work to identify partner resources to support this action and it is hoped this can be advanced in the first quarter of 2025 Nov 24: meeting taken place with partners re locality work. Identified scope for development and this will be taken forward Continue discussions to identify and agree process and resource to progress work. Page 140
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4. Partnership and Collaborative Working: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Partnership Working for Moray 4.4 Continue development and delivery of Locality Plans, involving service users and local communities in the design of services CE / ED (FST) 28/03/24 30/10/25 75 Sept 2025: The work on development of Locality Plans for the areas agreed by the Council and CPP is well developed and will be ongoing work. April 2025: The work on development of Locality Plans for the areas agreed by the Council and CPP is well developed and will be ongoing work. The Council is also considering how to secure community influence on services and priorities through the next stage of its community engagement approach. MIJB is currently undertaking work in relation to children and HSCM locality models in specific locality areas over the next few months and officers will aim to build on this from a partnership perspective to connect more directly with a Moray wide CPP approach.. This work is noted as 75% complete as the final stages are to be refined by the CPP. Page 141
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5. Sustainable Development: Actions Lead Start Date End Date % Complete Current Position Next Step Evidence Log Sustainable Development 5.1 Identify any gaps that require consideration and action. ED EEO 28/03/24 31/12/25 55 Sept 2025: The MEP subgroup has met twice and agreed a focus on climate change including sustainable development alongside other areas. Talks with Moray CAN and others on an area wide climate strategy are progressing. July 2025: An initial meeting of the MEP Sub Group covering this activity has been held. Later actions are progressing in line with deadlines in Action Plan. Sept 2025: The MEP subgroup needs to identify shared priorities with work plans allied to these. Work on the Area wide strategy can now proceed apace following on opening of consultation on the draft Climate Change Strategy and as Moray CAN have now held their annual conference on 3.10.25. There is a need to extend the end date for this work to reflect availability of partnership resources and this is sought to 31.3.26. July 2025: Work planning in MEP sub group to begin in August meeting. Work on the Climate Change Strategy update incorporating sustainable development is progressing with a report to council in September. The area wide Climate Change Strategy work will build on the Moray Climate Action Network Annual Conference being held at the start of October. Climate Change Overview - CPB 03/12/2024 (item 2) Climate Change Strategy / updated Routemap to Net Zero - FC 4/12/2024 (item 15) Page 142
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Report to: Corporate Committee Meeting Date: 4 November 2025 Report by: Executive Director Economy, Enterprise and Operations Author: Atholl Scott Contact Email: atholl.scott@moray.gov.uk Subject: Corporate Risk Register - September 2025 update 1. PURPOSE ☒ For Decision ☐ For Information 1.1 The purpose of this report is to provide the Committee with the latest updated version of the council’s Corporate Risk Register. 1.2 This report is submitted to Committee in terms of Section III (B) (36) of the council’s Scheme of Administration relating to council wide or corporate risk assessment and the mitigation and management of these risks. 2. SUMMARY 2.1 A key element of good governance is the effective management of risk. Risk is routinely managed in many forms in the delivery of council services, and specific risk issues are considered in all reports requiring a decision that are submitted to council or its committees. 2.2 The updating of the Corporate Risk Register provides the opportunity for senior leaders to reflect on the principal risks affecting the organisation, to consider how these risks are being managed, and to ensure the measures in place to mitigate them remain both appropriate and proportionate. 3. RECOMMENDATIONS 3.1 It is recommended that Committee consider and approve the updated Corporate Risk Register dated September 2025 attached as Appendix 1 to this report. Author: Atholl Scott Job Title: Business Continuity/Risk Management Officer Item 15. Page 143
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4. BACKGROUND AND CONTEXT 4.1 Managing risk is a continuous process necessary to ensure that appropriate governance standards are met in the use of public money and in the delivery of council priorities. Risk informs day to day decisions at all levels of the organisation. The council has a risk management policy and guidance to aid its risk management practice. This includes a requirement for the periodic consideration of an updated Corporate Risk Register summarising the principal risks facing the council. 4.2 This Committee last considered the full Corporate Risk Register at its meeting on 10 June 2025 (paragraph 7 of the minute refers). The meeting discussed a number of changes to the risk register and agreed further discussion on these would take place at a workshop briefing on risk appetite scheduled for 29 October 2025. Part of the discussion was around the frequency of review of the risk register, and this will be confirmed at the workshop. 4.3 4.4 4.5 4.6 It will be appreciated that while managing all risks in a proportionate manner is essential to the effective functioning of the organisation, risk mitigation measures will not in all cases materially reduce the risk but simply contain it to the extent possible. It is important in particular to recognise that there are external factors not fully within the council’s control, which will influence the level of residual risk the council has to carry. The council must be cognisant of these external factors; however, the risk register primarily reflects the risk position for council functions while being aware of wider societal risks. By way of example, the council has multiple measures in place to effectively manage its financial affairs, notwithstanding these, uncertainty around future financial settlements and other pressures including inflation and service demands means that residual financial risk is likely to remain high going forward. HR (People) and IT (technological) risks likewise continue to have high residual risk scores notwithstanding control measures in place; these risks too are in part impacted by external factors. In contrast, where strategic risk areas have returned a lower risk score, this is because of actions being taken in mitigation. It does not mean that no further work is required to manage these risks. Rather it reflects a positive assessment by management that the risks are being managed as intended, having regard to council policy and practice. It remains important to recognise that not all risk is bad or should be avoided. Traditionally councils with responsibility for public funds have been seen to be risk averse, however, there is now broad acceptance that informed and managed risk taking is both appropriate and necessary to support delivery of Best Value. A report by the Accounts Commission on Transformation in Councils noted, ‘there is a low appetite for risk in some councils where transformational activity is held back by fear of failure. Not every transformational change will succeed but not progressing radical transformation is a greater risk.’ The report was followed up by a Best Value thematic review of this council’s transformation journey, the outcomes from which were reported to this Committee on 26 August 2025 (para 9 of the draft minute refers). This report was largely positive, affirming that the council is moving forward its transformation agenda across a number of different project areas, and in each case full consideration of any risks arising as a consequence is being made. Page 144
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4.7 The Corporate Risk Register currently references the concept of risk appetite for each of nine risk themes. These will be refined as necessary in the next update of the risk register being informed by the discussion at the workshop referred to earlier in this report. 5. PROPOSALS 5.1 5.2 The Committee is asked to consider and approve the latest iteration of the Corporate Risk Register dated September 2025. The Committee by the time this report is presented shall have had the opportunity to consider its appetite for risk at the workshop scheduled for 29 October 2025. Thereafter a risk appetite statement will be formalised for consideration and approval at the February 2026 meeting. 6. SUMMARY OF IMPLICATIONS 6.1 The table below shows whether risks and implications apply if the recommendations are agreed: SUBJECT YES NO Corporate Plan and 10 Year Plan (Local Outcome Improvement Plan) X Policy and Legal 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)) 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. Page 145
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6.3 Policy and Legal The Council is required to have effective arrangements in place to manage risk as an element of good governance practice. 6.4 Financial There are no financial implications arising directly from this report. One off Costs: Service Area Budget Budget Years Proposed Spend this Year Virement From Other Comments Annually Recurring Costs: Service Area Budget With Effect From Annual Net Impact Virement From (if applicable) Other Comments 6.5 Risk This report is about the management of risk. 6.6 Staffing There are no staffing implications arising directly from this report. 6.7 Best Value and Transformation Effective and responsible management of risk is essential to ensuring the council optimises its use of resources in securing Best Value. Measured risk taking is an essential element of service transformation. 6.8 Property There are no property implications arising directly from this report. 6.9 Information Communications/Technology/Digital There are no ICT/Digital implications arising directly from this report. 6.10 Equalities, Social Inclusion and Economic Impact There are no Equalities, Social Inclusion or Economic Impacts arising directly from this report. 6.11 Climate Change and Biodiversity Impacts There are no Climate Change and Biodiversity Impacts arising directly from this report. 7. CONSULTATION 7.1 This report has been prepared in consultation with the Extended Corporate Leadership Team and any comments made have been incorporated into the report. Page 146
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8. BACKGROUND PAPERS 8.1 None Page 147
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Appendix 1 MORAY COUNCIL CORPORATE RISK REGISTER AS AT SEPTEMBER 2025 Page 148
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Appendix 1 SUMMARY OF PRINCIPAL RISKS Nature of Risk Main issues Risk Score Risk Movement 1. Collaborative Leadership Good progress has been made to secure the increased benefits of collaborative working, with a number of member/officer working groups developed and member briefing sessions taking place to complement the established timetable of formal council meetings. A positive direction of travel in this area has been acknowledged in the follow up review of the council’s Best Value arrangements and work is ongoing to sustain progress achieved to date. Agreed changes to senior management roles are still being implemented and the risk impacts of these are uncertain, with a number of key management posts remaining unfilled. Overall, the risk score is unchanged since the last review. (likelihood 3 x impact 4) 12 2. Financial Financial constraints across the public sector continue to impact on the council in terms how it resources service provision. This is being managed using short, medium, and long-term financial plans, notwithstanding financial settlements from Scottish Government are for one year only. The setting of a balanced budget for 2025/26 has been achieved without use of reserves through a combination of an improved financial settlement from Scottish Government, an increase in Council Tax, and savings generated through measures developed in line with the council’s transformation plan. A number of unknowns including impacts of inflation have been highlighted during the budget setting process, and future budget pressures are expected in a number of service areas including the council’s ongoing 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. The external auditor has reported in the recently published external audit report that actions taken by the council have reduced risks around financial management. Consequently, while likelihood of financial challenges going forward remains at the highest level the potential impact, at least in the short term, has been reduced marginally. (likelihood 5 x impact 4). 20 3. HR (People) Inability to recruit and retain well qualified or experienced staff across several service areas remains an issue, manageability of workloads requires service prioritising within available resource for longer term sustainability. The corporate workforce plan has been refreshed, - designed to enhance leadership capacity, provide development opportunities to equip staff for change; aid staff health and well-being; and address 20 Page 149
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Appendix 1 recruitment and retention challenges. Innovative choices are being made where possible; where this proves impracticable work is outsourced albeit this can have cost implications and in some cases is not feasible e.g. teaching, property services. A plan to progress with phase 2 following implementation of agreed changes to senior management structures (phase 1) is scheduled for later in 2025/26; this should align resources more closely to agreed council priorities. The recent employee survey and follow up work assists in further identifying areas where improvement and development action is required. The risk remains that the council is unable to recruit to some posts as a consequence of multiple factors, this in turn will impact on service continuity and performance. (see also risk 7 below). The assessed risk score remains high at 20. (likelihood 5 x impact 4). 4. Regulatory Council operates in a heavily regulated environment and delivers a broad range of statutory services. Corporately, constitutional documents are subject to regular review and updating and across services policies and guidance aid compliance with regulatory requirements. Performance management arrangements monitor progress internally, and oversight comes from auditors, regulators and inspectors both external and internal to the organisation. Recommendations made are used as learning points and applied, subject to resource constraints, to improve compliance and secure continuous improvement. Senior leaders have an improved understanding of the capacity challenges facing the organisation and the elevated risk impacts should there be non-compliance with regulations. The risk score is unchanged (likelihood 3 x impact 3). 9 5. Environmental Council’s commitment to addressing climate change remains undiminished. A number of initiatives have been taken forward aimed at mitigating adverse impacts. These include work on promoting active travel, improved biodiversity, high waste recycling rates and decarbonisation of council buildings, alongside policy developments linked to the forthcoming Local Development Plan. Work has also progressed to secure external funding to expand the number of charging points for electric vehicles. The previously reported risks of ability to drive forward change and the costs of doing so still apply, with Scottish Government climate targets extended. Availability of capital funding will inform what more can be achieved. Opportunities are being pursued to secure additional Just Transition funding for use in delivering further mitigations in line with the recently updated Climate Change Strategy. The risk score reflects the multiple actions being taken by the council to address this risk and remains 6 Page 150
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Appendix 1 unchanged from the prior review. (likelihood 3 x impact 2). 6. Reputational Reputation depends on consistent application of good governance standards, and the council publishes a governance statement each year with its annual accounts explaining how it complies with best practice guidance. The council is committed to maintaining these standards, notably in being open and transparent around its decision-making processes, and in adopting effective consultation with citizens and service users. Integrated Impact Assessments are used to inform policy decisions as appropriate. While reputational issues occur from time to time, these are managed through engagement and action as appropriate. Given the breadth and scale of services delivered and expectations of service users; the likelihood of reputational issues arising from time to time remains possible albeit with the impact typically localised. The risk score has been reduced given the positive progress made with implementation of the recommendations in the Best Value Improvement Plan. (likelihood 4 x impact 2). 8 7. Operational Continuity and Performance Council performance falls below targeted levels for sustained period; performance reporting is delayed. Transformational change does not proceed at pace due to capacity issues. Council has been advised during budget setting that a reduction in capacity, without a reduction in council activities and duties, can result in a less resilient organisation. This has the potential to impact on partnership and cross service working, capacity to respond to emergencies, and on capacity to support and develop staff. While significant adverse cumulative impacts are not inevitable this risk will require careful monitoring. The risk score remains unchanged (likelihood 4 x impact 3). 12 8. IT (Technological) Major disruption in continuity of ICT operations; changes to systems and processes and new ways of working create added pressures for ICT staff; data security is compromised. With ICT systems integral to the effective delivery of most if not all services, the impact from disruption to services is at the highest level and notwithstanding risk mitigation measures in place, the potential for disruption, including from external threats, cannot be discounted. The service has reviewed and updated its ICT Strategy and Plan, and a new Digital Strategy and Plan has recently been agreed to guide service activity and development for the next three years. Additional capacity has been created in relation to cyber resilience as well as at 20 Page 151
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Appendix 1 strategic leadership level through the recent management restructure. Despite this, the risk level here is unchanged. (likelihood 4 x impact 5). 9. Economic Sustainability The Corporate Plan has as one of its three objectives the building of a stronger, greener, vibrant economy. This links to separate policies on climate change/ biodiversity and community wealth building, and aligns with the Moray Economic Strategy developed on a multi-agency partnership basis. The Strategy sets out an ambitious vision and programme of work designed to support economic development in Moray over a ten-year period and will be complemented by the Local Development Plan currently in preparation. The Moray Growth Deal is being taken forward alongside other projects being delivered through the levelling up fund and the future plan for Elgin. Further opportunities are also under consideration aimed at stimulating the local economy alongside opportunities through the Highlands and Islands Regional Economic Partnership. The risk score remains unchanged (likelihood 2 x impact 3). 6 Page 152
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Appendix 1 RISK CLASSIFICATION RISK RATING LOW MEDIUM HIGH VERY HIGH RISK MOVEMENT DECREASE ↓ NO CHANGE ↔ INCREASE ↑ The process for managing risk is documented separately in the council’s risk policy and guidance notes. The risk rating is calculated by reference to assessed likelihood and impact (on a scale of 1 to 5) for each identified risk. The minimum score (lowest risk) being 1x1=1, the maximum (highest risk) 5x5 =25. Scores of 3 and below are ranked low, green; between 4 and 6, medium, yellow; between 8 and 12 high, amber; and 15 and above very high, red, as per the table below. LIKELIHOOD Almost certain 5 5 10 15 20 25 Likely 4 4 8 12 16 20 Possible 3 3 6 9 12 15 Unlikely 2 2 4 6 8 10 Remote 1 1 2 3 4 5 1 2 3 4 5 Minimal Minor Moderate Major Catastrophic IMPACT Page 153
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Appendix 1 1. Description of Risk: Collaborative Leadership. A lack of collaborative working between councillors/councillors and councillors/officers creates the risk that: • The Council’s strategic priorities are not fully achieved. • The Council’s decision-making processes are less effective with decisions being delayed or avoided. • Staff time resources are not optimised on council priorities. • Partnership working is not as effective as it could be. Lead: Chief Governance Officer Risk Rating: low/medium/high/very high Rationale for Risk Rating: Leadership risk has been a theme running through council Best Value Assurance Reports for some time. External support was sought in 2024/25 to support improvements in strategic leadership and decision- making processes. Actions from this work have now bedded-in and a survey of elected members in February 2025 established that there had been an improvement in the collaborative leadership between councillors and senior officers. There is also closer working across political groups and with non-aligned members evidenced by the development of the new Corporate Plan and in the setting of the budget for 2025/26. A workforce engagement action has been identified to increase understanding across the workforce of the role of a councillor. The overall risk score is unchanged pending completion of appointments to senior posts within the recently agreed corporate management structure. HIGH Likelihood 3 x Impact 4 = Score 12 Risk Movement: increase/decrease/no change Risk Appetite: There is a strong appetite for the council to be successful in delivering best value services for its citizens against a challenging background of increasing demand and diminishing resources and a need to identify service priorities. Political stability is key to this success. Note: the risk appetite evaluation for all risk categories will be re-assessed following development and approval of the formal risk appetite statement. Controls: Current and Proposed Mitigating Actions: Page 154
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Appendix 1 Suite of governance documents in place and regularly updated. Cycle of Council and Committee meetings established to discharge leadership functions. Ten-year strategic plan - Moray 2027 (the Local Outcomes Improvement Plan) being delivered jointly by the council and its community planning partners. Corporate Plan for 2024/26 implemented identifying council priorities and aligning these to the budget setting process. Best Value Action plan addresses collaborative leadership, with external support secured. Additional measures adopted to support inclusive cross party working. Committee report format updated to ensure decision making processes have regard to all relevant policy implications. Scrutiny briefing delivered for elected members outlining the benefits to be derived from discrete and targeted scrutiny reviews. Collaborative working/ leadership survey planned annually to sustain benefits of cross party working. Approach to developing updated Local Outcomes Improvement Plan – including community engagement – being considered in conjunction with the partners in the Community Planning Board. Plans in train to promote leadership development following appointment to the post of Chief Executive. Risk appetite being formalised to guide policy approach to planned transformation and change. Consideration to be given to providing dedicated resources to partnership working to enable more focused action to be taken on joint initiatives. Partnership working through Community Planning Board continues including monitoring of delivery of the Local Outcomes Improvement Plan, and consideration of multi-agency topics including Children’s Services and Population Health. Workshop planned to consider further approaches to addressing Poverty. Resourcing of scrutiny reviews remains under consideration. Page 155
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Appendix 1 2. Description of Risk: Financial: Notwithstanding the statutory requirement for the council to set a balanced budget annually, there is an on- going risk of financial failure with demand for services outstripping available budget. While a budget has been agreed for 2025/26, risks highlighted previously by the Chief Financial Officer remain, including uncertain levels of government funding in future years, price inflation, the potential for increases in interest rates leading to higher borrowing costs, and limitations on availability of capital funding for asset maintenance and renewal. Uncertainties around the council’s current and future funding obligations to the Moray Integration Joint Board add to this risk. The UK autumn budget being scheduled for late November also increases the risk that council settlements for financial year 2026/27 may be later than usual in being confirmed by the Scottish Government. Savings targets for future financial years have been identified as part of the council’s short term financial plan through to 2027/28 year, to be achieved through efficiencies, increased revenue generation and changes to service provision through the council’s continuing transformation programme. The risks in doing so are significant having the potential to impact on all sectors of the community, particularly so on those who are most disadvantaged. The council recognises its duty to minimise inequality by targeting support towards those who need it most. Financial risk is being actively managed with financial monitoring and reporting undertaken throughout the year. Lead: Executive Director Finance, Strategy and Transformation (Section 95 Officer) Risk Rating: low/medium/high/very high Rationale for Risk Rating: The Council has consistently delivered significant savings in recent years but the need to make further savings remains, and the challenge of continuing to do so while meeting service demands will be increased given the factors outlined above. Likelihood of on- going financial constraints remains unchanged given the anticipated level of savings required in future years, with impact being reduced slightly reflecting improved financial governance arrangements evidenced in the recently published external audit report covering financial year ended 31 March 2025. VERY HIGH Likelihood 5 x Impact 4 = Score 20 Page 156
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Appendix 1 Risk Movement: increase/decrease/no change Risk Appetite: The council has no risk appetite for financial failure given its statutory requirement to manage its resources in a responsible and prudent manner and to continue to deliver statutory services. However, it recognises, as a consequence of financial constraints, that services being curtailed have the potential to result in a diminution of performance. Expectations of communities and service users will require to be managed. It is of note that public finances generally are constrained with uncertainty around future financial settlements that will be allocated to Local Government. Page 157
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Appendix 1 Controls: Financial plan in place with budget projections in place for current and next two financial years. Financial pressures identified. Ten-year capital plan reviewed for affordability; cap mechanism agreed. Short/ medium/ long term financial plans developed. Regular budget monitoring reports (on capital and revenue) presented to council. Financial Reserves policy reviewed and updated. Financial regulations in place and regularly reviewed. Treasury Management strategy agreed and monitored. Procurement Policies and Practice. Energy Monitoring and Reporting. Internal Auditing; External Audit and Inspection Annual pricing review on charges for services. Current and Proposed Mitigating Actions: Ongoing financial plan monitoring and reporting to ensure council oversight and visibility of progress to address budget challenges. Work of the ‘Transforming the Council’ and Programme Boards including the BVAR and the Transformation Strategy to inform cost reductions aligned to potential redesign of services. Working closely with and seeking assurances from the Moray Integration Joint Board to ensure, so far as is practicable, that the financial contribution to be made from Council resources does not exceed budget projections. Full business case for Depot Review project agreed including detailed plans for future programme of works. Strategy agreed for reletting of school transport contracts. Continue development of participatory budgeting processes through community engagement and involvement as appropriate. Address pending changes in key finance roles to ensure financial governance standards are maintained. Page 158
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Appendix 1 3. Description of Risk: Human Resources (People): Continuing challenges exists in recruiting various teaching and promoted teaching posts, specialist professional and senior management posts, fleet services and discrete areas of social care. The age demographic at senior and service manager level is likely to bring an increased level of turnover for the next 18 -24 months and a corporate succession planning approach has been agreed that should help to mitigate this. With staff the council’s most important resource, there is a need to ensure employees are equipped to embrace change and deliver services in different and innovative ways that as far as possible are sustainable at a time when resources are reducing. There are actions within the corporate workforce plan to empower staff and prepare them for change. This will prove challenging with further budget cuts that may have potential workforce implications, although current predictions are that these are likely to be in contained service areas rather than across the whole workforce. There remains a risk that corporate and service plan targets will not be met, leading to reduced service quality and performance. . Lead: Executive Director (Education, Housing, and Communities). Risk Rating: low/medium/high/very high Rationale for Risk Rating: Reduced ability of smaller teams to deal with competing and complex demands and to forward plan across a wider Council agenda and be ready with a strategic response. Difficult to recruit in a range of areas including certain subject teachers; vehicle technicians; specialist professional posts; senior management; clerical and administrative roles; temporary and relief staff; and community care employees. Staff turnover leads to loss of expertise and ‘corporate memory’. Workforce planning is used to offset this, especially for key roles. Inability to meet service demands and secure continuous improvement. Given the foregoing issues the risk rating remains at a very high level with current staffing challenges almost certain to continue, leading to a likelihood score of 5 with consequential moderate to high impacts in service areas directly affected. VERY HIGH Likelihood 5 x Impact 4 = Score 20 Page 159
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Appendix 1 Risk Movement: increase/decrease/no change Risk Appetite: The council as a responsible employer has a duty to provide a safe, attractive, and rewarding place to work, with employees central to the successful delivery of the council’s strategic and service priorities. Accordingly, while acknowledging challenges in aspects of public sector recruitment and changes to working practice to secure efficiencies, there remains a strong appetite to ensure staff morale and motivation is maintained at a high level and that the council is seen as an attractive place to work. Controls: Corporate Workforce Strategy in place. Leadership Development Programme established. Employee Communications & Engagement Framework (including staff newsletters, briefings, Interchange bulletins, senior manager visits and manager forums) Health and Work Policy Health and Safety Policies and Annual Report. Absence Management Policy Living Wage Employer accreditation secured to support recruitment strategies. Flexible working policy refreshed and rolled out as part of Smarter Working Initiative. Fire risk assessments completed in line with planned schedule. Mental health and wellbeing Pulse Survey results used to inform improvement actions. Current and Proposed Mitigating Actions: Implementing senior management staffing restructure to conclusion and planned review of other staffing structures scheduled. Annual Review of Workforce Strategy and Plan for 2024 to 2027 completed and activity to address the main themes of: • Leadership capacity and development; ensuring leaders, managers and supervisors are equipped with skills and behaviours necessary for new ways of working. • Supporting the workforce through a period of change including active management of vacancies and maintaining good employee relations. • Organisational Development, with the workforce empowered and enabled to embrace change through a range of in-person and on-line training opportunities. • Reviewing recruitment and retention strategies, continuing with apprenticeship and training programmes, and developing succession planning, where appropriate. • Health and Wellbeing initiatives being taken forward to support staff in the workplace, with linked objectives of proactively supporting attendance at work and reducing incidents of violence and aggression against staff. • Support consistent application of employee review and development programme to aid workforce development. Whole workforce survey completed and now on annual schedule; this helps monitor trends/issues across a range of employment themes as well as identifying areas for improvement action. Page 160
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Appendix 1 4. Description of Risk: Regulatory: Expected governance standards are unmet. Council is subject to censure. The council is heavily regulated by statute, by national guidance and through local policy and procedures and, within its systems, has established checks and balances to support delivery of intended outcomes. Adapting council priorities and plans to accommodate new duties is key to limiting the risk of regulatory failure with elected members, on the advice of senior officers, being responsible for creating capacity to accommodate changes to policy and service delivery revisions. Lead: Chief Governance Officer Risk Rating: low/medium/high/very high Rationale for Risk Rating: Governance arrangements have been developed over many years and are subject to regular oversight and monitoring. Systems and processes are subject to on-going review and development within the council and its services. Corporate support and review in relation to performance, audit, and inspection. Change increases the risk of system breakdown and non-compliance with regulatory requirements. In the current economic climate and having regard to the challenges facing the wider public sector a neutral scoring has been allocated with a regulatory breach not likely but possible and the impact potentially in the range from significant to minor dependent on the circumstances presenting. HIGH Likelihood 3 x Impact 3 = Score 9 Risk Movement: increase/decrease/no change Risk Appetite: The council has zero appetite for regulatory failure and takes seriously its responsibility to ensure all services are following statutory regulations and standards. A robust approach is taken to securing governance arrangements which includes suitable systems of internal control, albeit capacity issues can emerge where new duties are placed on the council. Page 161
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Appendix 1 Controls: Governance statement prepared annually in line with best practice guidance. Monitoring officer oversees governance processes. Constitutional documents available to direct good governance. External scrutiny and inspection programme. Internal and external audit arrangements. Suite of Governance and Scrutiny documents in place and regularly updated. Annual service planning process. Current and Proposed Mitigating Actions: Continue to monitor likely impacts from new policy initiatives that have the potential to require significant council resource inputs. Consider statutory duties and other directions, including Integrated Impact Assessments where applicable, when reviewing and updating strategic plans and council priorities. Ensure capacity to deliver new duties is fully considered and anticipate and report on any implications that have potential to lead to non-compliance. Complete delivery of actions in Best Value action plan. Pro-active management response to issues raised in inspection reports. Continued active participation in delivery of joint services with statutory and other partners as appropriate. Page 162
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Appendix 1 5. Description of Risk: Environmental: Ability of the council to respond to climate change emergency, to keep up with the pace of changing carbon reduction, waste, and environmental targets. Impact of climate change and severe weather events; ability to deal with unforeseen emergencies is compromised by inadequate resilience. The council continues to invest in projects to address climate change issues, to manage energy use and ensure, so far as is practicable, that it can contribute to the response to crisis situations in conjunction with the emergency services and other partners. Leads: Head of Operations and Environment; Head of Growth, Planning and Climate. Risk Rating: low/medium/high/very high Rationale for Risk Rating: The Council’s commitment to address climate change remains. A number of initiatives have been taken forward aimed at reducing carbon emissions. These include work on promoting active travel, high waste recycling rates and decarbonisation of council buildings, alongside policy developments linked to the forthcoming Local Development Plan. Work with others is also taking place to expand the number of charging points for electric vehicles. The co- benefits of environmental activities include improving local biodiversity, access to the countryside, reducing energy bills for tenants, creating more connected vibrant communities. While these are positive mitigations against environmental risk, and have been supplemented recently with an agreed Biodiversity Strategy, an update of the Climate Change Strategy currently out for consultation, progressing bids for the Just Transition Fund, and net zero considerations fully embedded in LEIP funding terms for Forres Academy, cuts in capital budgets means the ability of the council to reduce our emissions in fleet and buildings is diminished. The previously reported risks of ability to drive forward change and the costs of doing so still apply, with Scottish Government climate targets extended and availability of funding having the potential to limit what can be achieved. Linked to this there is a need to be mindful that the council’s ability to respond to emergencies, e.g. dealing with severe weather events must be managed within MEDIUM Likelihood 3 x Impact 2 = Score 6 Page 163
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Appendix 1 available staffing resources. The risk score meantime remains at the previously assessed level noting that this risk has the potential to increase longer term depending on progress that can be made with adaptation mitigations and in delivery of the newly proposed Climate Strategy Actions. This will be closely monitored. Risk Movement: increase/decrease/no change Risk Appetite: Proportionality is reflected in risk appetite such that the development and application of preventative measures mitigate risks to pre-determined and achievable levels for the council while recognising the collective societal effort that will be required to address environmental risks. Controls: Climate Change Strategy for 2020-2030 refreshed. Climate change route map to zero updated and subject to ongoing monitoring. Climate change and energy teams in place. Recycling awareness promoted and high rates achieved. Residual waste no longer sent to landfill but processed through energy from waste plant. Street light replacement programme completed to reduce carbon emissions and energy costs. Electric pool cars introduced as part of council fleet de-carbonisation together with cycling/walking initiatives. Housing investment programme which aims to achieve energy efficiency standards. Moray Local Development Plan considers climate change issues. Council part of North of Scotland Regional Resilience Partnership Council Co-ordination Centre established and operational; crisis communications secured. Energy efficiency measures built into new school building programmes. Emergency response co-ordinators and support staff identified and trained. Growth Deal – Bus Revolution being implemented to improve access to greener travel. Current and Proposed Mitigating Actions: Coastal erosion/ protection – strategy under development Depot Review being progressed– contributing to de- carbonisation through reduction in portfolio of buildings to service and maintain. Route map to zero monitoring and reporting. Supporting locally sourced procurement to limit environmental impacts. Investigation of hydrogen as a fuel for heavy vehicles and plant. Climate change team considering adaptation measures: adjustments in response to observed and projected climate change impacts. Planning for emergency disruption from extreme weather events continues. Continue working with partners where appropriate to secure additional funding that will support climate change mitigation initiatives. Biodiversity plan approved in principle, currently out to consultation. Council to participate in multi-agency review of implications arising from wildfires. Page 164
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Appendix 1 Just Transition Funding secured to support feasibility studies aiding transition to a zero-carbon economy. Smarter working protocol established to reduce staff travel. Planning applications incorporate submissions on energy efficiency on new build properties. Rollout of public vehicle electric charging points as part of the North of Scotland EV charging Infrastructure Partnership agreed. Page 165
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Appendix 1 6. Description of Risk: Reputational: Not meeting agreed performance targets (e.g. on educational attainment); not delivering on transformation projects, overspending or failing on a school build; major adult or child protection failing, missing a major policy direction or funding opportunity because resources/capacity are limited. The council provides services to all sectors of the community and while committed to high service standards, the diversity of service provision and the expectations of the public may increase the risk that the council’s reputation could be called into question. This risk generally is considered to be managed through service planning, performance management, organisational development, the application of codes of conduct, complaints procedures and similar, however any reduction in services to any individual or group of individuals may justly or otherwise impact on the council’s reputation. Lead: Chief Governance Officer Risk Rating: low/medium/high/very high Rationale for Risk Rating: The risk rating has regard to established systems, procedures and controls designed to prevent adverse reputational damage, and how updated policies increasingly reference the need for prioritisation of scarce resources. This recognises that with service reduction and curtailment, the likelihood of increased criticism of council services remains at the highest level while the potential impact is also unchanged at the present time. In part this is based on it being evident that service delivery challenges apply across the public sector, and through various mechanisms including community engagement, media reports nationally and locally, and complaints responses there is an increased understanding of the challenges faced. The council’s progress with completion of its Best Value Improvement Plan has enabled this risk score to be reduced. HIGH Likelihood 4 x Impact 2 = Score 8 Risk Movement: increase/decrease/no change Risk Appetite: The council endeavours to avoid reputational risk and is committed to continuous improvement in the delivery of services either on its own or with partners. It seeks to deliver these services having regard to its equality duty and has set targets for doing so through a customer charter. However, it is accepted that reputational damage is a potential consequence of service reduction or cessation. Page 166
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Appendix 1 Controls: A suite of policy, strategy, governance, organisational development, project management and performance management measures are in place to enable delivery of the services to a standard which mitigates the risk of significant damage to the council’s reputation. Consultation protocols established and range of consultation and engagement with public and workforce carried out over period of time. Customer charter in place and customer focus strategy developed to improve citizen engagements and provide a consistent experience across services. Formal complaints procedures in place. Performance management reporting framework updated. Corporate Leadership Team monitors external inspection processes and outcomes. Freedom of Information processes. Risks fully considered in committee reports requiring a decision. Suite of Governance documents in place and regularly updated. Current and Proposed Mitigating Actions: Ongoing review, redesign and implementation of policy, strategy governance, organisational development, project management and performance management. Regular meetings with officers and inspection agencies to support and challenge progress towards improvement. Means of communicating changes impacting service users to be monitored. Improved outcome reporting of service delivery and linked performance indicator measures. Progress Transformation Programme to optimise service delivery arrangements. Page 167
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Appendix 1 7. Description of Risk: Operational Continuity and Performance: The council is unable to deliver services; performance falls below acceptable levels for a sustained period; insufficient business continuity planning; changes in working practices impact on service delivery. Going forward it is recognised that operational continuity and performance may be affected as a consequence of service re-design and changes in service delivery and challenges remain to ensure alignment of available resources to service delivery standards. Lead: All Heads of Service Risk Rating: low/medium/high/very high Rationale for Risk Rating: The risk rating is an aggregate of various factors, services continue work to remain resilient and minimise disruption; experience of adapting to new ways of working has increased service flexibility yet challenges remain. Performance is monitored but can be impacted in certain areas should services be scaled back due to changes in policy priorities; in such circumstances this risk requires continued active management. The risk score is unchanged. HIGH Likelihood 4 x Impact 3 = Score 12 Risk Movement: increase/decrease/no change Risk Appetite: The risk appetite acknowledges the responsibility the council has to prioritise delivery of statutory services and ensure so far as practicable that the needs of the vulnerable service users are met. Controls: List of critical functions agreed by Corporate Management Team Programme for updating business impact assessments/business continuity plans in place for critical services. Organisational Development Team promoting workforce and leadership development. Communication strategy for informing service users of impending changes to services developed. Current and Proposed Mitigating Actions: Review Performance Management Framework to ensure it aligns appropriately to revisions to service provision in the Corporate Plan. Public Service Improvement Framework assessments restarted with support from Improvement Service and plan in place to complete reviews across participating services. Review timetable for performance reporting aligning with reporting framework for data collected as statutory performance information as appropriate. Progress Transformation Programme. Building resilience in procurement processes being refreshed to capture current risk of key supplier failure. Page 168
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Appendix 1 8. Description of Risk: IT (Technological) Major disruption in continuity of ICT operations; data security is compromised. Changes in working practices post pandemic more reliant on ICT infrastructure, capacity, and support. The risk of cyber-attacks remains and cannot be eliminated, with attacks being nuanced over time and requiring the council to be constantly alert to new threats. The prevalence of working from home results in greater isolation and increases the risk of malicious emails and data breaches. Reliance on third-party suppliers and contractors for ICT services (including cloud, managed services, and software vendors) introduces risks if these partners fail to deliver, experience financial distress, or suffer their own security incidents. Disruption to council operations may occur due to supplier failure, contract disputes, or changes in service provision, particularly for cloud-based and outsourced services. Outdated infrastructure and unsupported software increase vulnerability to security threats, reduce efficiency, and complicate integration with new systems. Deployment of AI solutions such as Copilot for Microsoft 365 can introduce risks of bias and lack of transparency. Lead: Head of Customer Experience, ICT and Digital Services. Risk Rating: low/medium/high/very high Rationale for Risk Rating: A recurring theme from senior management relative to their experiences during the course of the pandemic is that the success of their services in many respects is predicated on the availability of robust and adaptable ICT systems. This creates an elevated risk that has been recognised centrally, albeit it brings with it a number of challenges in terms of resourcing changed ways of working both to infrastructure and in terms of staffing to support that change as required. Meanwhile cyber security continues to have a high profile, and the ICT service has a suite of controls in place to mitigate known risks in this area. Intelligence in relation to recent successful cyber- attacks has highlighted that the disruption to the affected organisations can be widespread, with any recovery process likely to take a significant amount of time to restore business operations fully. VERY HIGH Likelihood 4 x Impact 5 = Score 20 Page 169
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Appendix 1 Risk Movement: increase/decrease/no change Risk Appetite: There is zero appetite for service interruption or data loss, as this has the potential for catastrophic impact on service delivery and the cost of system disruption or data protection breaches can be significant. The security and continuity of ICT services is therefore of vital importance, and this is reflected in the range of controls in place. Controls: Corporate Information Security Policy. Senior Information Risk Officer. External accreditation processes for Network Security (Public Services Network, Cyber Essentials Plus) Environmental Controls for Data Centre (cooling, fire, flood, and backup power) Boundary Firewalls and Internet Gateways (email and web filtering) Data control enhanced through network controls. Malware Protection Cyber resilience standards aligned to SG Cyber Resilience Framework Cyber Incident Response Plan Patch management (Applications and Infrastructure) Third Party Maintenance Agreements (Applications and Infrastructure) Main financial system supported in-house. Information Assurance Group Records Management Policy Data breach reporting arrangements Working from home policy/guidance Checks embedded in the procurement process when introducing new systems. Published guidance on AI guardrails, complemented by awareness sessions for staff and Elected Members. Current and Proposed Mitigating Actions: Information Security Policy review /update underway Computer Use Policy refresh underway. Assess controls as part of plans for continuing development of digital services. Penetration testing for applications implemented to deliver digital services. Participation in the Scottish Government Cyber Resilience Programme Extend accreditation process to include the Education ICT network. Work to improve network IT connectivity in schools continuing. Continue with implementation of programme of work to address awareness raising, e-learning and phishing campaigns to educate users of ICT systems – attempting to mitigate and reduce the ‘human error’ element. Complete the review of the ICT Business Continuity Plan Cyber Resilience – ongoing monitoring and application of emerging best practice. Continue to monitor feasibility of insurance cover for cyber-attacks. Comprehensive assessment of the existing business systems estate and underlying technologies. Introduction of CMDB (configuration management database) to better manage system interdependencies. Ongoing review of new technologies with the development of appropriate governance and guardrails. Page 170
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Appendix 1 9. Description of Risk: Economic Sustainability. Higher inflation and increases in interest rates have the potential to an impact on capital projects including the Moray Growth Deal. The cost of doing business and higher energy costs adversely impact on the business community. Increased strain on household incomes /budgets may impact on council tax revenues and income from council house rents; business failures may create similar pressures on business rates. Many of these are factors outside the control of the council but continue to have an influence on how it reacts and plans for the future. Lead: Head of Growth, Planning and Climate Risk Rating: low/medium/high/very high Rationale for Risk Rating: The cost-of-living crisis, a reduction in the working age population, housing, and childcare remain as potential impediments to economic growth, with both the council and its partners actively working to address these issues. The Local Outcomes Improvement Plan and the Corporate Plan, underpinned by the ten-year Moray Economic Strategy, guide investment priorities and involve significant input from multiple council services including Planning, Housing and Education. Levelling Up and other regeneration funding in Moray Growth Deal aims to stimulate to local economy and meantime work through Highlands and Islands Regional Economic Partnership has highlighted Regional Transformation Opportunities for the area of in excess of £100bn with £12.4bn in Moray. A Moray Skills Summit is being convened in December to look at the skills pipeline, and a wider Economic Summit is in planning for 2026. While these are all significant positives, wider economic challenges including those from the upcoming governmental budget round, have the potential to impact on the Moray economy. Overall, the risk score has been maintained as unchanged. MEDIUM Likelihood 2 x Impact 3 = Score 6 Risk Movement: increase/decrease/no change Risk Appetite: Page 171
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Appendix 1 The need to maintain a vibrant economy is prominent in both community and council strategic plans. There is a strong appetite to create conditions that make Moray an attractive place to do business, recognising that wider economic policy not within the council’s control may influence business investment decisions going forward. Controls: Moray Growth Deal - Funding for Growth Deal being progressed bringing total investment to the area of over £100m. Growth deal governance arrangements in place and elements of programme being delivered in line with timetable. Moray Economic Strategy ten-year strategy developed with partners and aligned to council strategic plans. Partnership working with Highlands and Islands Enterprise, Moray College UHI, Skills Development Scotland and others. Oversight of programmes using ring fenced funding from the UK Shared Prosperity Fund, Just Transition Funding, and the Strategic Priorities Fund. Expansion of pre-school provision. Buckie Harbour Master Plan approved. Current and Proposed Mitigating Actions: Progress Growth Deal projects in line with programme. Continue work with partners to develop and deliver support aligned to economic strategy objectives that include: • Increasing employment levels and number of companies • Ensuring alignment between skills provision and the changing economy • Increased productivity leading to growing wages and contributing to closing the gender pay gap. • A labour market that provides the required numbers of workers to take advantage of available opportunities-notably attraction and retention of those aged 16-29. • Continuing effort to secure Community Wealth Building resource to support enhancement of the environmental, social, and economic benefits in this area. . Page 172