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Document Pack (Bookmarked) - Audit Committee - 10 December 2025

West Dunbartonshire Council · 10 December 2025
Back to Audit Committee — 10 December 2025 and its agenda

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Agenda 
Audit Committee
Date:  Wednesday, 10 December 2025 
Time:  14:00 
Venue:  Civic Space, 16 Church Street, Dumbarton G82 1QL 
Contact: Lynn Straker, Committee Officer 
lynn.straker@west-dunbarton.gov.uk 
committee.admin@west-dunbarton.gov.uk 
Dear Member 
Please attend a meeting of the Audit Committee as detailed above.
The business is shown on the attached agenda. 
Yours faithfully 
PETER HESSETT 
Chief Executive  
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Distribution: 
Councillor Gordon Scanlan (Chair)
Councillor Sophie Traynor (Vice Chair)
Councillor Ian Dickson
Councillor Michelle McGinty
Councillor John Millar
Councillor Lauren Oxley
Councillor Martin Rooney 
Councillor Clare Steel 
All other Councillors for information 
Chief Executive
Chief Officers 
Date of Issue: 27 November 2025
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AUDIT COMMITTEE 
WEDNESDAY, 10 DECEMBER 2025 
AGENDA 
1 APOLOGIES 
2 DECLARATIONS OF INTEREST 
Members are invited to declare if they have an interest in any of the items of
business on this agenda and the reasons for such declarations. 
3 MINUTES OF PREVIOUS MEETING       5 - 8 
Submit for approval, as a correct record, the Minutes of Meeting of the Audit
Committee held on 24 September 2025.   
4  OPEN FORUM 
The Committee is asked to note that no open forum questions have been
submitted by members of the public. 
5 INTERNAL AUDIT PLAN 2024/25        9 - 28 
PROGRESS TO 31 OCTOBER 2025  
Submit report by Chief Officer - Resources advising of progress to 31 October 2025
against the Internal Audit Plan for 2024/25.   
6 2025/26 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN   29 - 37     
Submit report by Chief Officer - Resources advising on the planned programme of
work for the Internal Audit Section for the year 2025/26. 
7 EXTERNAL AUDIT PROGRESS REPORT         To Follow   
Submit report by Chief Officer - Resources advising on the above. 
8 PUBLIC INTEREST DISCLOSURES AND OTHER     39 - 45 
INTERNAL AUDIT INVESTIGATIONS 1 APRIL TO 
31 OCTOBER 2025         
Submit report by Chief Officer - Resources advising on the outcome of investigations
into allegations and disclosures in line with public interest disclosure and business
irregularities policies received by Internal Audit between 1 April and 31 October 2025. 
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9 SCOTTISH PUBLIC SERVICES OMBUDSMAN     47 - 59 
COMPLAINTS REPORT 2024-2025     
Submit report by Chief Officer - Citizen, Culture and Facilities presenting the Scottish
Public Services Ombudsman (SPSO) report on complaints handling by West
Dunbartonshire Council for the year 1 April 2024 - 31 March 2025. 
10 TREASURY MANAGEMENT MID-YEAR REPORT 2025/2026   61 - 76         
Submit report by Chief Officer - Resources providing an update on treasury
management to 30 September 2025. 
11 ACCOUNTS COMMISSION REPORT - AUDIT OF GLASGOW    77 - 106 
CITY COUNCIL SENIOR OFFICER EXIT PACKAGES 
Submit report by Chief Officer - Resources providing detail on West Dunbartonshire
Council’s response to the recommendations arising from a recent Controller of
Audit’s report to the Accounts Commission on governance and transparency of
decision making of exit packages of senior officers in Glasgow City Council.   
12 EXTERNAL AUDIT ENQUIRIES - 2024/25 ACCOUNTS    107 - 119 
Submit report by Chief Officer - Resources informing of External Audit’s requirement
for the provision of information regarding the Council’s approach to dealing with
fraud, litigation, laws and regulations as part of their audit of the Council’s 2024/25
Statement of Accounts and 2024/25 Trust Accounts. 
___________________________________________________________________ 
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AUDIT COMMITTEE 
At a Meeting of the Audit Committee held in Council Chambers, Clydebank Town
Hall, 5 Hall Street, Clydebank on Wednesday, 24 September 2025 at 10.00 a.m. 
Present: Councillors Michelle McGinty, John Millar, Lauren Oxley, Martin
Rooney, Gordon Scanlan and Sophie Traynor. 
Attending:  Peter Hessett, Chief Executive; Laurence Slavin, Chief Officer –
Resources; Andi Priestman, Shared Service Manager – Audit
and Fraud; Julie Slavin, Chief Financial Officer – HSCP; Carol
Alderson, Finance Manager; Claire Cusick, Senior Education
Officer; Tom Reid, External Auditor – Forvis Mazars and Lynn
Straker, Committee Officer. 
Apologies: Apologies for absence were intimated on behalf of Councillors
Ian Dickson and Clare Steel. 
Councillor Gordon Scanlan in the Chair 
DECLARATIONS OF INTEREST 
It was noted that there were no declarations of interest in any of the items of
business on the agenda. 
MINUTES OF PREVIOUS MEETING 
The Minutes of Meeting of the Audit Committee held on 11 June 2025 were
submitted and approved as a correct record. 
OPEN FORUM 
The Committee noted that no open forum questions had been submitted by
members of the public. 
STRATEGIC RISKS 2022-2027 
A report was submitted by the Chief Officer – People and Technology providing an
update on the strategic risks for 2022-2027. 
Item 3
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After discussion and having heard the Chief Officer – People & Technology and Chief
Officer - Resources in further explanation and in answer to Members questions, the
Committee agreed to note the strategic risks as detailed at Appendix 1 of the report. 
INTERNAL AUDIT PLAN 2024/25 PROGRESS TO 31 JULY 2025 
A report was submitted by the Chief Officer – Resources advising of progress to 31
July 2025 against the Internal Audit Plan for 2024/25. 
After discussion and having heard the Shared Service Manager – Audit and Fraud
and the Chief Officer – Resources in further explanation and in answer to Members’
questions, the Committee agreed to note the report. 
EXTERNAL AUDIT PROGRESS REPORT 
A report was submitted by the Chief Officer – Resources advising Members of the
outcome of investigations into allegations and disclosures in line with public interest
disclosure and business irregularities policies received by Internal Audit between 1
November 2024 and 31 March 2025. 
After discussion and having heard the Audit Director - Forvis Mazars in further
explanation, the Committee agreed to note the report. 
2024/2025 TREASURY MANAGEMENT ANNUAL REPORT 
A report was submitted by the Chief Officer – Resources advising Members of the
treasury function and its activities in 2024/25 and requesting that the Committee
remits the report to the full Council for its approval. 
After discussion and having heard the Chief Executive, the Chief Officer – Resources
and Finance Manager in further explanation and in answer to Members’ questions,
the Committee agreed:- 
(1) to note the contents of the 2024/25 Annual Treasury Management Report and; 
(2) to remit the 2024/25 Annual Treasury Management Report to full Council for
approval. 
VALEDICTORY
ANDI PRIESTMAN, SHARED SERVICE MANAGER - AUDIT AND FRAUD 
Laurence Slavin, Chief Officer - Resources, informed the Committee that this would
potentially be the last meeting of Audit Committee that Andi Priestman, Shared
Service Manager - Audit and Fraud, would attend as she would soon be moving to a
different post within the Council.  Members passed on their best wishes and thanked
Ms Priestman for her dedication and long service to the Audit Committee and wished
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her the very best in future.  In response, Ms Priestman thanked the Committee for its
kind words. 
The meeting closed at 10.38 a.m.
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer - Resources
Audit Committee - 10 December 2025
Subject: Internal Audit Plan 2024/25 - Progress to 31 October 2025
1. Purpose
1.1 The purpose of this report is to advise Members of progress to 31 October 2025
against the Internal Audit Plan for 2024/25. 
1.2 The report also advises Members of:
 recently issued Internal Audit reports and action plans
 the status of implementation progress relating to action plans from previously
issued Internal Audit reports.
2. Recommendations
2.1 It is recommended that Members note the contents of this report.
3. Background
3.1 The annual audit plan for 2024/25 was approved by the Audit Committee on 4
December 2024.  This report provides information on the progress in
implementing the plan.
3.2 When audit reports are issued by Internal Audit, an action plan is agreed with
management in relation to issues highlighted by the audit report.  Progress on
implementing the actions is monitored by Internal Audit on a monthly basis and
reported to the Audit Committee.
4. Main Issues
4.1. The annual audit plan sets out the audit coverage for the year utilising available
staff resources to enable the Shared Service Manager – Audit & Fraud to provide
the annual internal audit opinion regarding the adequacy and effectiveness of
internal control within the Council.
4.2 In accordance with the risk-based audit methodology, for each audit, one of four
audit opinions is expressed:
Strong In our opinion there is a sound system of internal
controls designed to ensure that the organisation is
able to achieve its objectives. 
Satisfactory In our opinion isolated areas of control weakness
were identified which, whilst not systemic, put
some organisation objectives at risk. 
Item 5
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Requires Improvement In our opinion systemic and/or material control
weaknesses were identified such that some
organisation objectives are put at significant risk.
Unsatisfactory In our opinion the control environment was
considered inadequate to ensure that the
organisation is able to achieve its objectives.
4.3 Detailed findings and recommendations reported to management are graded using
the following criteria:   
Red In our opinion the control environment is insufficient to address the
risk and this could impact the Council as a whole.
Corrective action must be taken and should start immediately.
Overseen to completion by Corporate Management Team.
Amber In our opinion there are areas of control weakness which we consider
to be individually significant but which are unlikely to affect the
Council as a whole.
Corrective action must be taken (some exceptions may be agreed
with Internal Audit) within reasonable timeframe.
Overseen to completion by Chief Officer/Head of Service.
Green In our opinion the risk area is well controlled or our audit highlighted
areas for minor control improvement and/or areas of minor control
weakness.
Process improvements/efficiencies may be actioned at management
discretion in consultation with Internal Audit.
Managed by service owner.
Not reported in Audit Committee papers.
4.4 There were no audit reviews finalised since the September 2025 Audit Committee. 
Due to an unanticipated vacancy arising in the team, some audits were delayed in
starting but have been reallocated to other members of the team to finalise.
4.5 In relation to audit work for the Integration Joint Board, work is now complete for the
2024/25 audit plan.
4.6 In relation to the Valuation Joint Board, the audit for 2024-25 is now complete.
4.7 In relation to the Leisure Trust, the audit for 2024-25 is now complete.
4.8 Internal Audit Action Plans
In relation to audit action plans, these are monitored by Internal Audit on a monthly
basis.  The status report at 31 October 2025 is provided at Appendix 2.
Ongoing Corporate Fraud Team Work
4.9 The Corporate Fraud team’s day to day work continues to focus on referrals relating
to council tax reduction/single person discounts, joint working with DWP in relation
to housing benefit and council tax reduction, referrals relating to housing tenancies
and investigating relevant national fraud initiative matches.
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4.10 The Internal Audit Team and the Corporate Fraud Team continue to work together
as appropriate in order to ensure a joined-up approach to fraud investigation and
detection for example in relation to whistleblowing enquiries.
National Fraud Initiative
4.11 The National Fraud Initiative is a series of biennial exercises run by the Cabinet
Office and Audit Scotland to identify or prevent fraud and error by matching
electronic data held by public bodies. Participating bodies are required to
investigate data discrepancies within a set timescale and report back on any
savings.
4.12 In relation to the 2024 exercise, a significant number of matches have been
received in relation to a range of datasets including Housing Benefit, Council Tax
Reduction, Payroll, Business Rates, Creditors and Blue Badges.  High risk matches
have been prioritised for investigation and progress is as follows:
Matches
Received
Number
Investigated
Number
in
Progress
No
Issue
Fraud
(1)
Error
(2)
Value of
Fraud/Error
9712 803 31 613 79 80 £157,396.59
(1) Fraud relates to:
76 CTR cases where income was not fully declared.  Recovery is in
progress;
1 Housing Benefit case where income was not fully declared.  Recovery is in
progress; and
2 cases of tenancy fraud.  Properties have been recovered.
(2) Errors relate to:
79 blue badges which had not been cancelled on the system; and
1 case where CTR was not updated in relation to a deceased case.
Benchmarking
4.13 In accordance with the Council’s Strategic Improvement Framework, the
Council’s Internal Audit service continues to be part of a benchmarking group
which involves seven other Councils.
5. People Implications
5.1 There are no people implications.
6. Financial and Procurement Implications
6.1 The Corporate Fraud Team activity can result in actual recoveries, charges and
re-billings.  The total amount of actual recoveries, charges and re-billings
identified will be included in the Internal Audit Annual Report and Assurance
Statement for 2025-26.
6.2 There are no procurement implications arising from this report.
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7. Risk Analysis
7.1 There is a risk that failure to deliver the Internal Audit Plan would result in an
inability to provide a reasonable level of assurance over the Council’s system of
internal financial control to those charged with governance.  The main basis for
providing assurance is coverage of the planned risk-based audits.  Every
endeavour is made to ensure that no material slippage occurs in risk-based
audits by concentrating resources on these audits.
8. Equalities Impact Assessment (EIA)
8.1 There are no direct equalities impacts arising from the report however where an
agreed action results in a change in process this will be considered for equalities
impact by the relevant service.
9. Consultation
9.1 This report has been subject to consultation with appropriate Chief Officers.
10. Strategic Assessment
10.1 This report helps ensure strong governance and will help support delivery of the
Council Plan, and in particular priority 4: Inclusive and Adaptable, with the Council
seeking to provide high quality and adaptable services that deliver value for money.
....................................
Laurence Slavin
Chief Officer - Resources
Date: 6 November 2025
Person to Contact: Andi Priestman, Shared Service Manager – Audit & Fraud
E-mail: andi.priestman@west-dunbarton.gov.uk
Appendices: 2024/25 Annual Audit Plan – Progress to 31 October 2025
(Appendix 1)
Status of Internal Audit Action Plans at 30 September 2025
(Appendix 2)
Internal Audit Reports - Copies available on request
Wards Affected: All wards
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2024-2025 Internal Audit Annual Audit Plan – Progress to 31 October 2025
Item 5
Appendix 1
Audit/Status Not
Started
Planning Fieldwork Fieldwork
Complete
Draft
Report
Final
Report
Date Reported to
Audit Committee
Risk-Based Reviews
Void Management      June 2025
Housing Repairs and Maintenance      June 2025
Budgetary Control 
Participatory Budgeting Deferred to future audit plan.
Corporate Procurement   
Regularity Audits
Payroll High Earners – Quarterly Review Quarterly exercise is underway.
Residential Care Homes – Overtime Included in Payroll High Earners quarterly review exercise.
Other Work
Integration Joint Board – Internal Audit Service The 2024/25 audit plan is complete.
Valuation Joint Board – Internal Audit Service The 2024/25 audit plan is complete.
Leisure Trust – Internal Audit Service The 2024/25 audit plan is complete.
National Fraud Initiative Matches for the 2024 Exercise have now been received and investigations are underway. 
Completion of 23/24 Audit Plan Audits Completed: Debt Recovery; UK Shared Prosperity Fund; Commercial Waste Income
Billing and Collection.
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLANS
AT 30 SEPTEMBER 2025
Summary: Section 1 Summary of Management Actions due for completion
by 30/09/2025
There were 14 actions due for completion between 1 July
and 30 September 2025, 10 of which have been reported
as completed by management and the completion date for
3 actions has been revised.  For one action, a management
update is overdue.
Section 2 Summary of Current Management Actions Plans at
30/09/2025
At 30 September 2025 there were no audit reports delayed
due to management not finalising the action plan within
agreed timescales.
Section 3 Current Management Actions at 30/09/2025
At 30 September 2025 there were 27 current audit action
points. 
Section 4 Analysis of Missed Deadlines
At 30 September 2025 there were 14 audit action points
where the original agreed deadline has been missed.
Section 5 Summary of Action Plan Points by Audit Year
Item 5
Appendix 2
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
SUMMARY OF ACTION PLANS DUE FOR COMPLETION BY 30.09.2025
SECTION 1
2
Strategic Area
No. of
Actions
Due
No. of
Actions
Completed
Deadline
missed
Revised Date
set*
Update
overdue*
Education 1 1
Housing and Employability 13 10 3
Total 14 10 3 1
* These actions are included in the Analysis of Missed Deadlines – Section 4
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
SUMMARY OF CURRENT ACTION PLANS AT 30.09.2025
SECTION 2
3
CURRENT ACTIONS BY STRATEGIC AREA
Roads and Neighbourhood
Due for completion December 2025 1
Total Actions 1
Education
Due for completion September 2025 1
Total Actions 1
Housing & Employability
Due for completion November 2025 1
Due for completion December 2025 10
Due for completion January 2026 1
Due for completion February 2026 1
Due for completion March 2026 8
Due for completion June 2026 1
Due for completion July 2026 3
Due for completion August 2026 1
Total Actions 25
Total current actions: 27
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 30.09.2025
SECTION 3
4
Status Key
On track Complete
Overdue – update required Missed original due date
Current Internal Audit Action Plans
CSA Education Procedures (Report Issued May 2024)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/231
Adequacy of School Fund Procedures
A review of the procedures will be undertaken and updated to reflect up to date practice and provide
sufficient guidance to staff involved in maintaining and managing school funds.
A copy of the updated school fund procedures will be disseminated to Heads of establishments.
31-Mar-2025 30-Sep-2025
Senior
Education
Officer
Chief Officer –
Education,
Learning and
Attainment
UK Shared Prosperity Fund Assurance Review (Report Issued June 2024)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/237
Inadequate policies and procedures to support closure of the fund (Amber)
Management are in regular discussions with Government officials about continuity of UKSP Funds.
Should these discussions prove to be unsuccessful and there is no further funding from this source,
WDC has a full set of HR policies relating to staff terms and conditions and processes for dealing
with the loss of funding. We will begin to implement the appropriate course of action three months
in advance of the fund closing. 
As an update, the funding has been extended into Year 4 (25/26) and a report will be presented to
IRED Committee in February 2025 on further year funding.
31-Dec-2024 31-Dec-2025
Chief Officer
Housing &
Employability/
Chief Officer,
Resources
Chief Executive
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 30.09.2025
SECTION 3
5
Status Key
On track Complete
Overdue – update required Missed original due date
Void Management (Report Issued May 2025)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/255
/3
Adequacy of Tenant Rechargable Repairs Process (Amber)
Review recharge process to include guidance for staff to follow should previous tenant query/
dispute recharge amount invoiced for and be incorporated into Void Procedure and Recharge
processes. 30-Jun-2025 31-Dec-2025
Maintenance
Manager/
Housing
Operations
Manager
Chief Officer
Housing and
Employability
IAAP/255
/4
Adequacy of Tenant Rechargable Repairs Process (Amber)
Design and implement new PowerBi clear out report. 31-Aug-2025 31-Dec-2025
Housing
Operations
Manager
Chief Officer
Housing and
Employability
IAAP/256
/3
Adequacy of Job Costing Process (Amber)
Continue to report void management data at appropriate forums including Building Services Board. 31-Mar-2026 31-Mar-2026
Housing
Operations
Manager
Chief Officer
Housing and
Employability
IAAP/257
/3
Lack of monitoring and authorisation of repairs costs to void properties (Amber)
Implement any necessary changes to the variation process and agreed authorisation processes. 31-Jul-2025 31-Jul-2025
Housing
Operations
Manager
Chief Officer
Housing and
Employability
IAAP/258
/3
Ensuring Value for Money when using external contractors (Amber)
If appropriate arrange and carryout a full tender exercise to engage a void property contractor from
an existing framework or arrange an open tender exercise. 30-Nov-2025 30-Nov-2025
Contracts
Manager Chief Officer
Housing and
Employability
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 30.09.2025
SECTION 3
6
Status Key
On track Complete
Overdue – update required Missed original due date
Housing Repairs and Maintenance (Report Issued May 2025)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/263
/1
Adequacy of Housing Client Function (Red)
Carry out a review of the Client Function to identify any areas that require improvement to ensure
quality, value for money repair and maintenance services are provided.
31-Jul-2025 31-Mar-2026
Building Services
Manager
Chief Officer
Housing and
Employability
IAAP/263
/2
Adequacy of Housing Client Function (Red)
Implement any necessary Client Function changes identified. 31-Mar-2026 31-Mar-2026
Building Services
Manager
Chief Officer
Housing and
Employability
IAAP/263
/3
Adequacy of Housing Client Function (Red)
Develop Building Services 2025/2026 improvement action plan to include appropriate financial
management, service costs recovery and budget management actions.
30-Jun-2025 31-Dec-2025
Building Services
Manager
Chief Officer
Housing and
Employability
IAAP/263
/4
Adequacy of Housing Client Function (Red)
Present Building Services 2025/2026 improvement action plan to the Building Service Board for
approval.
30-Jun-2025 31-Dec-2025
Building Services
Manager
Chief Officer
Housing and
Employability
IAAP/263
/5
Adequacy of Housing Client Function (Red)
Complete actions within Building Services 2025/2026 action plan. 31-Mar-2026 31-Mar-2026
Building Services
Manager
Chief Officer
Housing and
Employability
IAAP/263
/6
Adequacy of Housing Client Function (Red)
Carry out a review of variation procedure and authorisation limits and implement any necessary
changes ensuring robust procedures are in place and provide value for money services. 30-Jun-2025 31-Dec-2025
Contracts Co-
ordinator/
Support Services
Co-ordinator
Chief Officer
Housing and
Employability
IAAP/264
/5
Lack of Checking of Overtime Claims (Red)
Monitor and review revised processes to ensure effectiveness. 31-Jul-2025 31-Jul-2025
Building Services
Manager
Chief Officer
Housing and
Employability
IAAP/265
/1
Adequacy of Stock Control Procedures (Amber)
Complete the procurement of an appropriate barcoding hardware and software solution. 30-Jun-2025 30-Jun-2026
Contracts
Manager
Chief Officer
Housing and
Employability
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 30.09.2025
SECTION 3
7
Status Key
On track Complete
Overdue – update required Missed original due date
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/265
/2
Adequacy of Stock Control Procedures (Amber)
Implement the procurement of an appropriate barcoding hardware and software solution. 31-Jul-2026 31-Jul-2026
Contracts Co-
ordinator
Chief Officer
Housing and
Employability
IAAP/265
/3
Adequacy of Stock Control Procedures (Amber)
Present a decision paper to the IHMS Project Board to approve development of the automatic
reordering module.
30-Jun-2025 31-Dec-2025
IHMS Change
Officer
Chief Officer
Housing and
Employability
IAAP/265
/4
Adequacy of Stock Control Procedures (Amber)
Following approval, complete necessary work implement, test and go live on QL system. 31-Aug-2026 31-Aug-2026
IHMS Change
Officer
Chief Officer
Housing and
Employability
IAAP/265
/5
Adequacy of Stock Control Procedures (Amber)
Fully implement phase 2 of the review of Building Services structure in warehouse services. 31-May-2025 28-Feb-2026
Contracts Co-
ordinator
Chief Officer
Housing and
Employability
IAAP/265
/9
Adequacy of Stock Control Procedures (Amber)
Training will be provided and distribution of the new procedures to all stores staff will be recorded in
a register. Staff will sign the register to confirm receipt of the procedures.
31-May-2025 30-Sep-2025
Contracts Co-
ordinator
Chief Officer
Housing and
Employability
IAAP/266
/1
Lack of Recovery Plan to reduce overspend (Amber)
Develop a cost recovery plan for 2025/2026 and gain approval of the plan from the Building
Services Board.
30-Jun-2025 31-Dec-2025
Building Services
Manager
Chief Officer
Housing and
Employability
IAAP/266
/2
Lack of Recovery Plan to reduce overspend (Amber)
Complete actions in the cost recovery plan for 2025/2026 reporting progress at the Building
Services Board and other appropriate forums.
31-Mar-2026 31-Mar-2026
Building Services
Manager
Chief Officer
Housing and
Employability
IAAP/266
/3
Lack of Recovery Plan to reduce overspend (Amber)
Drive down tenant and resident reactive repair demand in line with the criteria within the new
repairs policy.
31-Mar-2026 31-Mar-2026
Building Services
Manager
Chief Officer
Housing and
Employability
IAAP/267
/3
Adequacy of monitoring of Schedule of Rates for Specifying and Controlling Repairs &
Maintenance Work (Amber)
Implement any necessary changes identified in the variation processes.
31-Jul-2025 31-Jul-2025
Maintenance
Manager
Chief Officer
Housing and
Employability
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 30.09.2025
SECTION 3
8
Status Key
On track Complete
Overdue – update required Missed original due date
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/267
/4
Adequacy of monitoring of Schedule of Rates for Specifying and Controlling Repairs &
Maintenance Work (Amber)
Reduce the average percentage of variation on non emergency reactive repairs by 5% in 2025/2026
compared the level in 2024/2025.
31-Mar-2026 31-Mar-2026
Maintenance
Manager Chief Officer
Housing and
Employability
IAAP/268
/4
Lack of Post Inspections (Amber)
Review post inspection targets to ensure these are effective and repair standards are being met /
improved.
30-Sep-2025 30-Sep-2025
Maintenance
Manager
Chief Officer
Housing and
Employability
IAAP/269
/1
Inefficient Allocation of Resources (Amber)
Include an action in the Building Services 2025/2026 improvement action plan to have an effective
imprest stock provision in place.
30-Jun-2025 31-Dec-2025
Building Services
Manager
Chief Officer
Housing and
Employability
IAAP/269
/2
Inefficient Allocation of Resources (Amber)
Develop alternative scheduling and appointment system to replace DRS. 31-Jul-2025 31-Jul-2026
IHMS Change
Officer
Chief Officer
Housing and
Employability
IAAP/269
/3
Inefficient Allocation of Resources (Amber)
Seek approval from Building Services Board to implement new system. 31-Aug-2025 31-Aug-2025
Building Services
Manager
Chief Officer
Housing and
Employability
IAAP/269
/4
Inefficient Allocation of Resources (Amber)
Implement new scheduling and appointment system. 30-Sep-2025 31-Jul-2026
Building Services
Manager/IHMS
Change Officer
Chief Officer
Housing and
Employability
IAAP/270
/2
Lack of Risk Assessments for Staff with Secondary Employment (Amber)
Review and if necessary complete risk assessments for employees that have informed management
of secondary paid work.
31-Aug-2025 31-Aug-2025
Building Services
Co-ordinators
Chief Officer
Housing and
Employability
IAAP/271
/1
Adequacy of Monitoring of Vehicle Usage (Amber)
Develop a formal fuel emission and tracking guidance procedure and rollout for use within service. 30-Sep-2025 30-Sep-2025
Contracts
Manager
Chief Officer
Housing and
Employability
IAAP/271
/2
Adequacy of Monitoring of Vehicle Usage (Amber)
Continue to monitor automated reports from webfleet system and take appropriate action in line
with Fuel Emission and Tracking Protocol and appropriate Council policies. 31-Mar-2026 31-Mar-2026
Maintenance
Manager/
Contracts
Manager
Chief Officer
Housing and
Employability
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 30.09.2025
SECTION 3
9
Status Key
On track Complete
Overdue – update required Missed original due date
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/273
/1
Lack of Standard Operating Procedure Manual (Amber)
Review procedure file within x-drive to identify if there are gaps in available procedures that are not
available within QL to ensure team members have appropriate guidance to effectively complete
tasks.
30-Jun-2025 30-Sep-2025
Maintenance Co-
ordinators Chief Officer
Housing and
Employability
IAAP/273
/2
Lack of Standard Operating Procedure Manual (Amber)
Develop and add any necessary procedures and processes to procedures file within the x-drive. 31-Dec-2025 31-Dec-2025
Maintenance Co-
ordinators
Chief Officer
Housing and
Employability
IAAP/274
/2
Compliance with HMRC Benefit in Kind Guidelines (Amber)
Review process for homestart personal use disclaimer protocol to ensure this is fit for purpose and
exercise is carried out annually.
31-Jul-2025 31-Jul-2025
Projects Manager Chief Officer
Housing and
Employability
IAAP/274
/3
Compliance with HMRC Benefit in Kind Guidelines (Amber)
Carry out a review of the homestart protocol with workforce, TUs and transport service ensuring
this remains fit for purpose.
31-Jan-2026 31-Jan-2026
Maintenance
Manager/Project
s Manager
Chief Officer
Housing and
Employability
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Page 25

REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
ANALYSIS OF MISSED DEADLINES AT 30.09.2025
SECTION 4
Status Key 10
On track Complete
Overdue – update required Missed original due date
–new date set
Report Agreed Action Original Due
Date
Revised Date Management Comments
CSA Education
Procedures (May
2024)
Adequacy of School Fund Procedures
A review of the procedures will be undertaken and
updated to reflect up to date practice and provide
sufficient guidance to staff involved in maintaining
and managing school funds.
A copy of the updated school fund procedures will
be disseminated to Heads of establishments.
31-Mar-2025
31-May-2025
30-Sep-2025 The policy has now been drafted and will be discussed with Heads of
Establishment at the September Business Meeting.
Void Management
(May 2025)
Adequacy of Tenant Rechargable Repairs
Process (Amber)
Review recharge process to include guidance for
staff to follow should previous tenant
query/dispute recharge amount invoiced for and
be incorporated into Void Procedure and Recharge
processes.
30-Jun-2025
31-Aug-2025
31-Dec-2025 Review is underway as part of Void working group but deadline required
to be extended.
Void Management
(May 2025)
Adequacy of Tenant Rechargable Repairs
Process (Amber)
Design and implement new PowerBi clear out
report.
31-Aug-2025 31-Dec-2025 PowerBi report has been developed and training completed with
managers within Housing Operations.
Discussed at IHMS Board, target date requires to be extended to
31/12/25 as IHMS team moving to Granicus forms, so unable to get
improvements implemented until this happens.
Housing Repairs and
Maintenance (May
2025)
Adequacy of Housing Client Function (Red)
Carry out a review of the Client Function to
identify any areas that require improvement to
ensure quality, value for money repair and
maintenance services are provided.
31-Jul-2025 31-Dec-2025 Client function within building services discussed at BS Board but
realistically will take another 3-6 months to embed.
Housing Repairs and
Maintenance (May
2025)
Adequacy of Housing Client Function (Red)
Develop Building Services 2025/2026
improvement action plan to include appropriate
financial management, service costs recovery and
budget management actions.
30-Jun-2025 31-Dec-2025 Client function within building services discussed at BS Board but
realistically will take another 3-6 months to embed.
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
ANALYSIS OF MISSED DEADLINES AT 30.09.2025
SECTION 4
11
Status Key
On track Complete
Overdue – update required Missed original due date
Report Agreed Action Original Due
Date
Revised Date Management Comments
Housing Repairs and
Maintenance (May
2025)
Adequacy of Housing Client Function (Red)
Present Building Services 2025/2026 improvement
action plan to the Building Service Board for
approval.
30-Jun-2025 31-Dec-2025 Client function within building services discussed at BS Board but
realistically will take another 3-6 months to embed.
Housing Repairs and
Maintenance (May
2025)
Adequacy of Housing Client Function (Red)
Carry out a review of variation procedure and
authorisation limits and implement any necessary
changes ensuring robust procedures are in place
and provide value for money services.
30-Jun-2025 31-Dec-2025 Client function within building services discussed at BS Board but
realistically will take another 3-6 months to embed.
Housing Repairs and
Maintenance (May
2025)
Inefficient Allocation of Resources (Amber)
Include an action in the Building Services
2025/2026 improvement action plan to have an
effective imprest stock provision in place.
30-Jun-2025 31-Dec-2025 Work is ongoing but should be in place within 3-6 months.
Housing Repairs and
Maintenance (May
2025)
Inefficient Allocation of Resources (Amber)
Develop alternative scheduling and appointment
system to replace DRS.
31-Jul-2025 31-Jul-2026 Go live date revised to July 2026.  Agreed that this was required due to
testing, training and implementation required
Housing Repairs and
Maintenance (May
2025)
Inefficient Allocation of Resources (Amber)
Implement new scheduling and appointment
system.
30-Sep-2025 31-Jul-2026 Go live date revised to July 2026.  Agreed that this was required due to
testing, training and implementation required
Housing Repairs and
Maintenance (May
2025)
Adequacy of Stock Control Procedures
(Amber)
Fully implement phase 2 of the review of Building
Services structure in warehouse services.
31-May-2025
01-Aug-2025
28-Feb-2026 It has been necessary to extend completion date due to delays within
Job Evaluation in terms of reviewing the role profile of warehouse
assistant.  
The posts are only now becoming available for recruitment.  This should
be completed through SWITCH and any necessary recruitment by the
end of February 2026.
Housing Repairs and
Maintenance (May
2025)
Adequacy of Stock Control Procedures
(Amber)
Complete the procurement of an appropriate
barcoding hardware and software solution.
30-Jun-2025 30-Jun-2026 In-house option being taken forward and target set for June 2026.
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
ANALYSIS OF MISSED DEADLINES AT 30.09.2025
SECTION 4
12
Status Key
On track Complete
Overdue – update required Missed original due date
Report Agreed Action Original Due
Date
Revised Date Management Comments
Housing Repairs and
Maintenance (May
2025)
Adequacy of Stock Control Procedures
(Amber)
Present a decision paper to the IHMS Project
Board to approve development of the automatic
reordering module.
30-Jun-2025 31-Dec-2025 The process is currently being reviewed and decision paper will be
presented to Project Board by end of December 2025.
Housing Repairs and
Maintenance (May
2025)
Lack of Recovery Plan to reduce overspend
(Amber)
Develop a cost recovery plan for 2025/2026 and
gain approval of the plan from the Building
Services Board.
30-06-2025 31-Dec-2025 Further work is required to undertake relevant analysis and prepare
recovery plan for approval which is now anticipated to be by 31
December 2025.
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLANS
SUMMARY OF ACTIONS BY AUDIT YEAR SECTION 5
13
Status at 30 September 2025
Current actions by GradeAudit Year No of Agreed
Actions
No of actions
complete Red Amber Green*
2020/2021 25 25 0 0 0
2021/2022 51 50 0 0 1
2022/2023 51 48 0 0 3
2023/2024 62 48 0 2 12
2024/2025 80 42 6 19 13
Total 269 213 6 21 29
* Green actions are within the Council’s risk appetite and are therefore not included in
Audit Committee reports.
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Page 29

WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer - Resources
Audit Committee - 10 December 2025
___________________________________________________________________
Subject:  2025/26 Internal Audit Annual Strategy and Plan
1. Purpose
1.1 The purpose of this report is to advise members of the planned programme of
work for the Internal Audit Section for the year 2025/26.
2. Recommendations
2.1 It is recommended that the Committee approve the 2025/26 Audit Plan.
3. Background
3.1 The Public Sector Internal Audit Standards include the requirement for the
Chief Internal Auditor to prepare a risk-based plan to determine the priorities
of the internal audit activity, consistent with the organisation’s goals.
4. Main Issues
4.1 The audit universe contains all areas that have been identified for review and
an assessment has been undertaken of the risk relating to each area based
on a number of criteria.  Account has also been taken of the risks identified in
the Council’s risk registers and risks identified by external scrutiny bodies
through local scrutiny arrangements. 
4.2 It is intended that audit work will be focused on areas of greatest risk taking
into account management’s own view of risk and meetings have been held
with Chief Officers as appropriate.  Each area has been assessed against a
broad range of risk criteria and a risk score has been generated based on
probability factors such as current control environment, results of last audit
and time since last audit. 
4.3 The audit plan also includes the carry forward of the completion of fieldwork
for audits from 2024/25.
4.4 The Audit Plan also includes the activity of the Corporate Fraud Team and
includes an allocation of days to provide the Internal Audit Service to the WD
Integration Joint Board, the WD Leisure Trust and the Valuation Joint Board.
4.5 Internal Audit monitors delivery of the plan continuously during the year using
a number of performance indicators. Progress is reported to members on a
regular basis.
Item 6
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4.6 Outlined below are the current risk factors influencing our proposed audit
coverage for 2025/26:
 Budgetary Control - The Council’s regular Financial Update report sets out
the scale of the anticipated savings options required in current and future
years whilst there is a continued need for the Council to meet increases in
expenditure arising from inflation and service delivery pressures. Internal
Audit will review the adequacy and effectiveness of the budgetary control
processes to ensure that members and officers are provided with relevant,
reliable and timely management information in relation to the budget
process.
 West Dunbartonshire HSCP works closely with colleagues in the acute
service across NHS Greater Glasgow & Clyde to ensure that service users
are discharged to their home as soon as services are available in the
community. Internal Audit will review the current arrangements in place to
ensure these are adequate and effective.
 Internal Audit will review the adequacy and effectiveness of processes in
place to ensure commercial and industrial property rental income is being
collected promptly and is properly accounted for. 
 As part of the annual audit planning process, corporate procurement is a
key risk area that is reviewed each year.  For 2025/26 Internal Audit will
carry out quarterly checks on Corporate Purchase Card expenditure to
ensure compliance with relevant policies and procedures.
 Regularity audits will be carried out in relation to high earners, section
payments and Education control self-assessment exercise.
 Risk-based planning will be undertaken to prepare 2025/26 audit plans in
relation to the West Dunbartonshire Integration Joint Board, West
Dunbartonshire Leisure Trust and the Dunbartonshire and Argyll and Bute
Valuation Joint Board.
4.7 The draft 2025/26 Internal Audit Strategy and Plan is included at Appendix 1.
There are no significant threats to the independence of the internal audit
activity, such as inappropriate scope or resource limitations.  The Plan
contains contingency provision that will be utilised during the year in response
to unforeseen work demands that may arise e.g. special investigations and
provision of ad hoc advice.  The plan also includes a balance of days required
to complete additional fieldwork from the 2024/25 audit plan.
4.8 The risk scoring system is maintained on a real-time basis and is altered as
circumstances change.  Regular reviews of the risk scores allow Internal Audit
to address the changing risk exposure of the organisation more effectively and
ensure audit effort is focused on those areas identified as higher risk.
5. Personnel Implications
5.1 There are no personnel issues with this report.
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6. Financial and Procurement Implications
6.1 There are neither financial nor procurement implications arising directly
from this report.
7. Risk Analysis
7.1 The Plan has been constructed taking cognisance of the risks associated with
major systems. Consultation with relevant Chief Officers has been carried out
to ensure that risks associated with delivering the Council’s objectives have
been considered.
8. Equalities Impact Assessment (EIA)
8.1 There are no issues.
9. Consultation
9.1 This report has been subject to consultation with appropriate Chief Officers.
10. Strategic Assessment
10.1 This report relates to all five of the Council’s Strategic Priorities.
Laurence Slavin
Chief Officer - Resources
Date: 6 November 2025
Person to contact Andi Priestman, Shared Service Manager – Audit & Fraud
Email:  andi.priestman@west-dunbarton.gov.uk
Appendix 1: Draft 2025/26 Internal Audit Strategy and Plan
Background Papers: None
Wards Affected: All wards
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2025/26 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN
1. Introduction
1.1 The Global Internal Audit Standards (UK Public Sector) set out the requirement for the
Shared Service Manager – Audit & Fraud to prepare a risk-based audit plan to determine
the priorities of the internal audit activity, consistent with the organisation’s goals.
1.2 The Shared Service Manager – Audit & Fraud must review and adjust the plan as
necessary in response to changes in the organisation’s business, risks, operations and
priorities.
1.3 The audit plan must incorporate or be linked to a strategic or high-level statement of how
the Internal Audit Service will be delivered and developed in accordance with the Internal
Audit Charter and how it links to the organisational objectives and priorities.
1.4 The strategy shall be reviewed on an annual basis as part of the audit planning process.
2. Internal Audit Objectives
2.1 The purpose of Internal Audit, as defined within Global Internal Audit Standards (UK
Public Sector) is to ‘strengthen the organisation’s ability to create, protect, and sustain
value by providing the board and management with independent, risk-based and
objective assurance, advice, insight and foresight’.
2.2 The primary aim of the internal audit service is to provide assurance services which
requires the Chief Internal Auditor to provide an annual internal audit opinion based on an
objective assessment of the framework of governance, risk management and control.
2.3 The internal audit service also provides advisory services, generally at the request of the
organisation, with the aim of improving governance, risk management and control and
contributing to the overall opinion.
2.4 The internal audit service supports the Chief Officer Resources in his role as West
Dunbartonshire Council’s (the Council) Section 95 Officer.
3. Risk Assessment and Audit Planning
3.1 The internal audit approach to annual audit planning is risk-based and all areas which
may be subject to audit review are contained within an Audit Universe which is subject to
formal review, at least annually.
3.2 The risk scoring system is maintained on a real-time basis and is altered as
circumstances change.  Regular reviews of the risk scores allow Internal Audit to address
the changing risk exposure of the organisation more effectively and ensure audit effort is
focused on those areas identified as higher risk.
Item 6
Appendix 1
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2025/26 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN Appendix 1
3.3 The Audit Universe is risk assessed each year to determine the Annual Audit Plan and
ensure that suitable audit time and resources are devoted to reviewing the more
significant areas of risk.   Each area within the Audit Universe is assessed for impact
against a number of broad risk categories as follows:
Strategy Risks associated with the setting and achievement of strategic
objectives.
Economy Risks associated with the economy in which the Council
operates.
Reputation Risks associated with threats to the Council’s name and
standing in the sector.
Customer Risks associated with customer relationships.
Legal/Regulatory Risks associated with the requirement to comply with a wide
range of statute.
Financial Risks associated with financial loss or inefficiency.
Technology Risks associated with application systems, their integrity,
security and development.
Management
Information
Risks associated with the provision of information for decision-
making purposes.
Human Resources Risks associated with people, e.g. recruitment, succession,
development, motivation and morale etc.
Operations Risks associated with the business operating process.
Business
Continuity/Resilience
Risks associated with disaster scenarios which would threaten
the continuing operation of the Council.
Security Risks associated with security over customer and the Council’s
assets.
Stakeholder Risks associated with management of stakeholder expectations
(e.g. Government or local communities)
Fraud Risks associated with asset misappropriation, corruption and
financial statement fraud.
3.4 Account has also been taken of the risks identified in the Council’s Risk Registers and
risks identified by external scrutiny bodies through local scrutiny arrangements.
3.5 There will be regular ongoing discussion with External Audit to ensure respective audit
plans are reviewed as circumstances change in order to minimise duplication of effort
and maximise audit coverage for the Council. 
4 Service Delivery
4.1 The provision of the internal audit service is through a directly employed in-house team.
The Shared Service Manager – Audit & Fraud is provided through a shared management
arrangement with Inverclyde Council.
4.2 In relation to the total staff days allocated to the 2025/2026 plan, a resource allocation
spreadsheet is completed for each member of staff which is split between annual leave,
public holidays, training days, general administration and operational plan days. 
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2025/26 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN Appendix 1
The combined operational plan is 645 days which will be resourced as follows:
Team Member Plan Days
Lead Internal Auditor (0.5 FTE)* 55
Internal Auditor (1.0 FTE)* 32
Internal Auditor (0.5 FTE) 90
Audit Assistant 108
Corporate Fraud Officer 180
Corporate Fraud Officer 180
Total Plan Days 645
* The Lead Internal Auditor and Internal Auditor posts are currently vacant.  Options are
currently being progressed to fill these vacancies by 1 February 2026.
The Shared Service Manager – Audit & Fraud does not directly carry out the assignments
included in the annual audit plan but provides the quality review and delivery oversight of
the overall plan.  As such, no direct time is included within the plan.  Where there are any
resource issues which may impact on delivery of the plan, this will be reported to the
Audit Committee at the earliest opportunity. 
4.3 Given the range and complexity of areas to be reviewed it is important that suitable,
qualified, experienced and trained individuals are appointed to internal audit positions.
The Global Interrnal Audit Standards (UK Public Sector) requires that the Chief Internal
Auditor must hold a professional qualification such as CMIIA (Chartered Internal Auditor),
CCAB or equivalent and be suitably experienced. 
4.4 Internal audit staff members identify training needs as part of an appraisal process and
are encouraged to undertake appropriate training, including in-house courses and
external seminars as relevant to support their development.  All training undertaken is
recorded in a personal training record for CPD purposes.
4.5 Internal audit staff members require to conform to the Code of Ethics of the professional
body of which they are members and to the Code of Ethics included within the Global
Interrnal Audit Standards (UK Public Sector).  An annual declaration is undertaken by
staff in relation to specific aspects of the Code.
4.6 Following each review, audit reports are issued in draft format to agree the accuracy of
findings and agree risk mitigations.  Copies of final audit reports are issued to the
relevant Chief Officer and Service Manager responsible for implementing the agreed
action plan.  A copy of each final audit report is also provided to External Audit.
4.7 The overall opinion of each audit report feeds into the Internal Audit Annual Report and
Assurance Statement which is presented to the Audit Committee and is used by the s95
Officer in the preparation of the Annual Governance Statement.
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2025/26 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN Appendix 1
5 Proposed Audit Coverage 2025-2026
5.1 The proposed audit coverage is set out in the table below.  This includes a range of risk
based reviews, limited scope financial reviews and regularity audits.
5.2 The Plan contains a contingency provision that will be utilised during the year in response
to unforeseen work demands that arise e.g. special investigations and provision of ad hoc
advice.
Audit Area Strategic Area Risk
Score
Staff
Days
Risk-Based Reviews
Budgetary Control (c/f 24/25) Corporate 7105 30
Care At Home - Delayed Discharge
Arrangements
HSCP 6800 25
Estates – Commercial and Industrial Property
Rents and Leases
Resources 6256 25
Total 80
Regularity Audits
High Earners – Quarterly check Corporate N/A 20
Section Payments HSCP N/A 20
Education Control Self-Assessment Education N/A 20
Corporate Purchase Cards – Quarterly check Corporate N/A 20
Total 80
Corporate Governance Reviews
Annual Governance Statement (2024/25) Corporate - 5
Total 5
Corporate Fraud Activity
National Fraud Initiative Corporate - 150
Fraud Referrals including Joint Working - - 100
Whistleblowing and Other Investigations - - 90
Liaison with DWP - - 10
Fraud Awareness Training Corporate - 10
Total 360
Other Work
Audit follow up Corporate - 10
IJB – Internal Audit Service - - 20
VJB – Internal Audit Service - - 15
Leisure Trust – Internal Audit Service - - 15
Contingency - - 10
Completion of 2024-2025 Audit Plan - - 50
Total 120
Total Staff Days for 2025/26 645
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2025/26 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN Appendix 1
6 Quality and Performance
6.1 The Global Interrnal Audit Standards (UK Public Sector) require each internal audit
service to maintain an ongoing quality assurance and improvement programme based on
an annual self-assessment against the Standards, supplemented at least every five years
by a full independent external assessment.
6.2 In addition, the performance of Internal Audit continues to be measured against key
service targets focussing on quality, efficiency and effectiveness.  For 2025/2026 these
have been set as follows:
Measure Description Target
1. Draft Report Percentage of draft reports issued
within 3 weeks of completion of
fieldwork.
90%
2. Final Report Percentage of final reports issued
within 2 weeks of issue of draft report.
90%
3. Audit Plan Delivery Percentage of audits completed v
planned.
85%
4. Audit Budget Percentage of audits completed within
budgeted days.
80%
5. Audit Recommendations Percentage of audit recommendations
agreed.
90%
6. Action Plan Follow Up Percentage of action plans followed
up – Internal and External Audit.
100%
7. Customer Feedback Percentage of respondents who rated
the overall quality of internal audit as
satisfactory or above.
100%
8. NFI recommended matches Percentage of National Fraud Initiative
high risk matches investigated within
timescales.
100%
9. DWP liaison Percentage of cases referred to/
actioned for DWP within DWP
timescales.
100%
10. Staff compliance with CPD Number of training hours undertaken
to support CPD
80
11. Management engagement Number of meetings with CMT and
senior management as appropriate
1 per
quarter
6.3 Actual performance against targets will be included in the 2025/26 Internal Audit Annual
Assurance Report.
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Page 39

WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer - Resources
Audit Committee - 10 December 2025
Subject: Public Interest Disclosures and other Internal Audit Investigations
1 April to 31 October 2025
1. Purpose
1.1 The purpose of this report is to advise Committee of the outcome of
investigations into allegations and disclosures in line with public interest
disclosure and business irregularities policies received by Internal Audit
between 1 April and 31 October 2025.
2. Recommendations
2.1 It is recommended that Members note the content of this report.
3. Background
3.1 A disclosure in the public interest is where a concern is raised by a Council
employee about a danger or illegality that has a public interest aspect to it.   A
confidential reporting facility is managed by Internal Audit as part of the
Council’s Public Interest Disclosure Policy.  Internal Audit maintains a central
record of all concerns raised under the Public Interest Disclosure Policy.  All
such disclosures are investigated by Internal Audit, including liaising with
Services and HR as appropriate.
3.2 Members of the public can also contact Internal Audit to raise issues of
concern and such matters are investigated as appropriate, although they are
not regarded as public interest disclosures in terms of legislation.
4. Main Issues
Public Interest Disclosure Cases
4.1 There were 5 outstanding cases from the previous report to Audit Committee
on 11 June which require an update to this meeting. 
Ref/
Date Service Area Detail Status
01/0424
14/0924
21/1024
23/1024
27/1224
09.12.24
Roads &
Neighbourhood
Drug misuse by
employees whist
on duty.
Referred to Service –
closed due to lack of
specific information
relating to employees. 
Service is however
currently reviewing the
drug testing policy with
HR.
Item 8
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Ref/
Date Service Area Detail Status
19/1024
23.10.24
Housing Potential breach
of code of
conduct/social
media policy.
Referred to Service –
investigated and
appropriate management
action undertaken.
25/1124
29.11.24
Housing Service Referral -
Potential breach
of working
practices.
Closed - Incorporated
into Audit Plan 2024/25.
30/1224
16.12.24
Housing Misuse of Council
vehicle.
Closed – hire vehicle
used by employee so
unable to investigate.
33/1224
31.12.24
HSCP Allegation of
misuse of
corporate
purchase card.
Closed – misuse
identified and report
issued to management
with recommendations
which have been
actioned by
management.
4.2 There were 16 new disclosures investigated during the period 1 April to 31
October 2025 as follows:
Ref/
Date Service Area Detail Status
03/0425
29.04.25
WD Leisure Trust Allegation of Drug
Misuse
Closed – referred to Police
Scotland.
08/0625
04.06.25
HSCP Complaint about
employee
behaviour.
Closed – referred to
Service and dealt with as a
complaint. 
11/0625
17/0725
24.07.25
Roads and
Neighbourhood
Allegation of
misuse of council
vehicle and not
working
contracted hours.
Ongoing – joint
investigation being carried
out between Audit & Fraud
and HR.
14/0725
15/0725
11.07.25
HSCP Complaint about
employee
behaviour.
Closed – referred to
Service as dealt with as a
complaint.
19/0825
14.08.25
Housing Allegation of
inappropriate
behaviour of
employee
towards
colleagues and
members of the
public.
Ongoing – Service
investigation is being
progressed.
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Ref/
Date Service Area Detail Status
20/0825
26.08.25
Housing Allegation of
misuse of council
vehicle and
fraudulent
overtime claims.
Closed – no misuse or
fraud established. 
22/0825
26.08.25
Roads and
Neighbourhood
Allegation of
fraudulent/
irregular working
practices and
potential health
and safety
breaches.
Ongoing – joint
investigation being
progressed between Audit
& Fraud and HR.
23/0825
26.08.25
Roads and
Neighbourhood
Allegation of
misuse of vehicle
by employee on
non-working day.
Closed – no fraud
established.
24/0825
26.08.25
HSCP Allegation of
inappropriate use
of council vehicle.
Closed – no fraud
established.
26/0825
31.08.25
HSCP Allegation of
employee being
under influence of
drugs whilst at
work.
Closed – no evidence to
substantiate allegation.
27/0925
01.09.25
Roads and
Neighbourhood
Allegation of
employee being
under influence of
alcohol whilst at
work.
Closed – no evidence to
substantiate allegation.
28/1025
03.10.25
Housing Potential misuse
of council vehicle
and theft of
council materials
Referred to service –
investigation ongoing.
29/1025
10.10.25
HSCP Complaint about
employee
behaviour.
Closed – links to previous
referrals.  INV-14/0725
refers.
32/1025
31.10.25
Housing Potential misuse
of Council
vehicle.
Closed – no fraud
detected.
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4.3 Activity relating to public interest disclosure for recent reporting periods is as
follows:
Period No. of Cases
1st January 2019 to 30th June 2019 5
1st July 2019 to 30th June 2020 8
1st July 2020 to 31st December 2020 4
1st January 2021 to 18th August 2021 15
19th August 2021 to 31st January 2022 7
1st February 2022 to 15th July 2022 7
16th July 2022 to 18th January 2023 5
19th January to 18th July 2023 19
19th July 2023 to 24th January 2024 10
27th January to 31st October 2024 18
1st November 2024 to 31st March 2025 11
1st April to 31st October 2025 16
Other investigations (non public interest disclosure cases)
4.4 There were 3 outstanding other referrals investigated by Internal Audit during
the period 1st April to 31st October 2025:
Ref/
Date Service Area Detail Status
36/0125
29.01.25
Roads and
Neighbourhood
Allegation of misuse of
council facilities and
theft of council
resources for personal
gain.
Investigation has been
undertaken by Service. 
No fraud identified but
implementation of
recommendations from
previous investigation
are ongoing.
37/0225
19.02.25
Roads and
Neighbourhood
Allegation of misuse of
council vehicle.
Closed – no misuse
identified.
38/0225
19.02.25
Citizens, Culture
and Facilities
Management
Allegation of theft of
council materials.
Closed – no fraud
detected.
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4.5 There were 12 new referrals investigated during the period 1 April to 31
October 2025 as follows:
Ref/
Date Service Area Detail Status
01/0425
19.04.25
Roads and
Neighbourhood
Allegation of
misuse of council
facilities and poor
working practices.
Ongoing - Linked to
36/0125.  Actions to
implement previous
recommendations are
ongoing.
06/0525
29.05.25
Roads and
Neighbourhood
Allegation that
employee takes
excessive breaks
from work.
Ongoing - Service
investigation complete and
report being prepared for
management.
07/0625
03.06.25
Roads and
Neighbourhood
Allegation that
employees take
backhanders to
remove rubbish.
Closed – insufficient
information provided in the
referral to investigate.
09/0625
05.06.25
Roads and
Neighbourhood
Allegation that
employee takes
excessive breaks
from work.
Closed – insufficient
information provided in the
referral to investigate
however review of Webfleet
did not reveal any evidence
to substantiate the
allegation.
10/0625
12.06.25
Roads and
Neighbourhood
Allegation of
misuse of council
vehicles.
Closed – investigation did
not reveal any evidence to
substantiate allegation.
12/0625
25.06.25
Housing Misuse of council
vehicle.
Closed – investigation
unable to progress as no
tracking information
available for vehicle. 
Vehicle returned to
Transport Services to allow
Webfleet to attend to check
and repair tracking device.
13/0625
28.06.25
Chief Executive Complaint about
Chief Officer
Closed – insufficient
information provided in the
referral to investigate.
16/0725
24.07.25
Housing Allegation that
employee is
running own
business during
working hours.
Ongoing – joint investigation
being progressed between
Audit & Fraud and HR.
18/0825
06.08.25
Housing Complaint about
employee
behaviour.
Closed – referred to Service
to investigate as a
complaint.
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Ref/
Date Service Area Detail Status
21/0825
26.08.25
Housing Allegation that
employee is
stealing council
materials and
dropping off at
home address to
undertake homers.
Ongoing – joint investigation
being progressed between
Audit & Fraud and HR.
25/0825
27.08.25
Regulatory and
Regeneration
Allegation of
potential breach of
annual leave
process.
Closed - Referred to service
as operational matter.
31/1025
26.10.25
Housing Allegation of
misuse of council
facilities.
Closed – investigated by
Service and misuse
identified and relevant
management action taken.
4.6 Activity relating to other investigation referrals for recent reporting periods is
as follows:
Period No. of Cases
1st January 2019 to 30th June 2019 14
1st July 2019 to 30th June 2020 8
1st July 2020 to 31st December 2020 2
1st January 2021 to 18th August 2021 1
19th August 2021 to 31st January 2022 2
1st February 2022 to 15th July 2022 2
16th July 2022 to 18th January 2023 5
19th January to 18th July 2023 0
19th July 2023 to 24th January 2024 10
27th January to 31st October 2024 11
1st November 2024 to 31st March 2025 9
1st April to 31st October 2025 12
4.7 A follow up process is in place to ensure recommendations made have been
implemented.  Outcomes are used to inform internal audit planning for future
years. 
5. People Implications
5.1 There are no personnel implications with this report.
6. Financial and Procurement Implications
6.1 There are neither financial nor procurement implications with this report.
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7. Risk Analysis
7.1 There are risks to the Council in financial, legal, operational and
reputational terms of not providing a service to enable a disclosure in the
public interest and to ensure that all public interest disclosure and other
concerns raised with Internal Audit are properly investigated.
8. Equalities Impact Assessment (EIA)
8.1 There is no requirement to undertake an equality impact screening.
9. Consultation
9.1 This report has been subject to consultation with appropriate Chief Officers. 
10. Strategic Assessment
10.1 The Public Interest Disclosure Policy and Business Irregularity Procedures
contribute to the Council's strategic priorities by ensuring that early warnings
of malpractice may mitigate the extent of financial losses to the Council,
contribute to better asset management by utilising employees to manage risks
to the organisation's reputation and support fit for purpose services through
the continuation and promotion of robust employment practice.
....................................
Laurence Slavin
Chief Officer - Resources
Date:  6 November 2025
Person to Contact: Andi Priestman, Shared Service Manager – Audit &
Fraud
Email:  andi.priestman@west-dunbarton.gov.uk
Appendix: None
Background Papers: Public Interest Disclosure Policy; Business Irregularity
Procedures
Wards Affected: All
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WEST DUNBARTONSHIRE COUNCIL 
Report by Chief Officer - Citizen, Culture & Facilities 
Audit Committee - 10 December 2025
___________________________________________________________________ 
Subject: Scottish Public Services Ombudsman Complaints Report 2024-25 
1. Purpose 
1.1 The purpose of this report is to present the Scottish Public Services
Ombudsman (SPSO) report on complaints handling by West Dunbartonshire
Council for the year 1 April 2024 – 31 March 2025. 
2. Recommendations 
2.1 It is recommended that Committee: 
• Notes the contents of the report and the ongoing commitment at a service
and strategic level to monitor complaints and ensure compliance with
Scottish Public Services Ombudsman (SPSO) timelines.   
3. Background 
3.1 West Dunbartonshire Council administer the SPSO complaint handling model
operating in line with all other Local Authorities.  Complaints continue to be
managed centrally by the Customer Relations team for all Council services.
Complaints regarding West Dunbartonshire Health and Social Care
Partnership (HSCP) are managed independently by the partnership. 
3.2 Statutory appeals and reviews, such as planning decision appeals, continue
to be directed to the relevant decision-making body, and are not processed
through the SPSO office. 
3.3 Centralised complaints handling ensures an open and transparent process.
Complaints are valued because they provide an insight into services, and how
the Council is performing. The feedback offers valuable information helping to
inform service planning, improve how services are delivered and ensure
customer’s voices are heard and views considered.  Customers who remain
dissatisfied with the final outcome of their complaint are openly directed to the
SPSO to have their case considered for review. 
3.4 West Dunbartonshire Council acts as factor for the buildings where we retain
an interest with tenanted properties.  Anyone who remains dissatisfied with
the outcome of their complaint may also be signposted to the First-tier
Tribunal for Scotland (Housing and Property Chamber). The Tribunal is an
independent and impartial judicial body whose function is to review complaints
from homeowners who consider their property factor has failed to perform its
Item 9
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factoring duties or failed to comply with the Property Factors’ Code of
Conduct.   
3.5      As a member of the Local Authority Complaints Handlers Network, the
Council continues to fully engage in sharing of good practice and developing
consistent approaches to complaints handling and reporting. Network
meetings are held regularly, with SPSO in attendance at each meeting.   
4. Main Issues 
4.1 The SPSO delivers an annual report to each Local Authority detailing the
number of complaints reported to its office.  Appendix 1 provides a breakdown
of enquiries handled by SPSO relating to West Dunbartonshire Council for
2024-25 together with comparison data for 2023-24.  Appendix 2 is a
summary breakdown of complaints received by the Council in 2024-25. 
Appendix 3 shows Social Work complaints handled by the HSCP for the same
period.    
4.2 In the year 2024-25, SPSO received 35 complaints regarding the Council, an
increase of six from 2023-24. The highest proportion of complaints made by
West Dunbartonshire citizens related to housing matters. 
4.3 Of the 35 complaints to SPSO, 16 were handled at the Advice and Guidance
stage. This is the initial receipt stage at SPSO where all enquiries are
assessed. At this stage, four were deemed mature meaning they had
completed the Council’s complaints process. In these cases advice was
offered by SPSO and the complaint was not considered further. A further five
were deemed as premature, which is terminology used by the SPSO when
the complainant has not exhausted the Council’s complaints process. Another
seven were handled as enquiries where SPSO would have offered
information and support and can refer people to other organisations that may
be better placed to help such as the Financial Services Ombudsman.   
4.4 The SPSO’s Early Resolution stage is where SPSO start to gather information
they need to decide if full investigation is required. Of complaints considered
by SPSO at this stage, two were closed by SPSO as unable to proceed where
they determined they could not take the complaint forward.     
4.5 A further 17 complaints were handled by the SPSO at the Early Resolution
Stage.  At this stage the SPSO applied discretion in three cases where it
deemed insufficient benefit would be achieved by investigation. One was
closed as an alternative course of action was proposed.  A further one was
resolved where both SPSO and the complainant were satisfied with proposed
outcome. There were a further 12 complaints closed by SPSO under good
complaints handling meaning SPSO were satisfied complaints had been fully
and appropriately investigated and responded to by the Council and SPSO
could not achieve a better outcome.   
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4.6 There were no complaints fully investigated by the SPSO during the year
2024-25.   
4.7 The low number of complaints considered by SPSO is positive and reflects on
the high level of effective complaints handling within West Dunbartonshire
Council.   
4.8 As outlined in Appendix 2, the Council handled 1633 complaints internally in
2024-25.  Of these, 1486 were closed within 2024-25. The difference in
complaints handled and closed is due to complaints being received during the
reporting period but still being worked on. The remaining 147 were closed in
2025-26 and will be included in appropriate reporting periods. When
registering a complaint, residents preferred method is the online complaints
form which accounted for 71% of all complaints received. The telephone is the
next preferred method accounting for 16%.     
4.9 As noted above, the number of complaints received in 2024-25 was 1633.
This represents an increase of 160% when compared to complaints received
in 2023-25 (628). The significant increase in complaints was due to multiple
factors including the introduction of the garden waste permit and the change
to bin collections over the festive period. It is important to continue to
encourage capturing expressions of dissatisfaction. Complaints data provides
services with valuable information to inform service improvement and
understand the expectations of customers. 
4.10 Of the 1146 complaints closed, 93% were resolved within SPSO timescales,
including with extension where applicable, representing an increase of 10%
from 2024-25 (83%). Customer Relations maintain a focus on right first time
and is committed to ensuring the quality of responses remains high whilst
seeking to improve response times again in 2025-26.   
4.11 In line with this, the service continues to work to encourage a culture of
welcoming complaints and ensuring services across the Council use the data
provided to identify and progress complaints improvement activity.   
5. People Implications 
5.1 There are no people implications arising from this report. 
6. Financial and Procurement Implications 
6.1 There are no financial implications arising from this report. 
7/ 
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7. Risk Analysis 
7.1 There is a reputational risk in not responding to complaints in defined time
periods within the two stage process. Complaints data is closely monitored,
including response times and quality of response from services. Customer
Relations continue to work to support services to improve response
timescales and maintain quality of complaints management.   
7.2 There is a risk that services do not learn from the complaints received and do
not adapt processes or policies to stop it happening again. To reduce this risk
complaints data is reported quarterly to Performance & Monitoring Review
Group. Complaints data is also shared with Chief Officers and included within
service Delivery Plans to ensure visibility and to assist in informing service
improvements. 
8. Equalities Impact Assessment (EIA) 
8.1 The two stage process has been equality impact assessed at a National level.
Locally, all aspects have been considered and assistance to navigate the
complaints process is available for all customers. 
9. Consultation 
9.1 Not applicable to this report. 
10. Strategic Assessment 
10.1 Effective complaints handling contributes to all four Council strategic priorities.
Amanda Graham 
Chief Officer - Citizen, Culture and Facilities  
Date:  6 November 2025 
___________________________________________________________________ 
Person to Contact: Stephen Daly  
Citizen & Library Manager  
Citizen, Culture and Facilities 
Council Offices, 16 Church Street, Dumbarton  
01389 737263     
Appendices: Appendix 1 – SPSO Complaints Data
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Appendix 2 - Summary of Council Complaints 2024-25   
Appendix 3 -  Summary of HSCP Complaints 2024-25 
Background Papers: None 
Wards Affected: All Wards
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West Dunbartonshire Council complaints closed 2024-25 
Stage Outcome Group
West
Dunbartonshire
Council
Advice A&G - Complaint submissions - mature 4
A&G - Complaint submissions - premature 5
A&G - Enquiries 7
Unable to proceed 0
Total 16
Early
Resolution
Cause and impact test not met (s 5 (3)) 0
Discretion – Alternative action proposed 1
Discretion – Alternative route used or available 0
Discretion – Good complaint handling 12
Discretion – Insufficient benefit would be
achieved by investigation 
3
Discretion – Referred back 0
Discretion – Resolved - both parties satisfied
with proposed outcome
1
Member of the public test not met (s 5 (6)) 0
Premature 0
Right of appeal to court/tribunal/Scottish
ministers (s 7 (8))
0
Subject matter not in jurisdiction  0
Time limit (s 10) 0
Unable to proceed 2
Total 19
Investigation Fully upheld 0
Not duly made or withdrawn 0
Not upheld 0
Some upheld 0
Total 0
Total 35 
Item 9
Appendix 1
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West Dunbartonshire Council complaints closed 2023-24 
Stage Outcome Group Total
Advice A&G - Complaint submissions - mature 0
A&G - Complaint submissions - premature 10
A&G - Enquiries 6
Organisation not in jurisdiction 0
Total 16
Early
Resolution
Cause and impact test not met (s 5 (3)) 0
Discretion – Insufficient benefit would be achieved by
investigation 
2
Discretion – Alternative action proposed 0
Discretion – Alternative route used or available 0
Discretion – Good complaint handling 4
Discretion – Referred back 1
Discretion – Resolved - both parties satisfied with
proposed outcome
0
Member of the public test not met (s 5 (6)) 1
No response to contact 0
Organisation not in jurisdiction 0
Premature 0
Right of appeal to court/tribunal/Scottish ministers (s 7
(8))
0
Subject matter not in jurisdiction  1
Time limit (s 10) 1
Unable to proceed 0
Total 10
Investigation Fully upheld 1
Not duly made or withdrawn 0
Not upheld 1
Resolved 1
Some upheld 0
Total 3
Total 29 
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Year 2024-25
Performance &
Monitoring 2024/25
Total
Complaints
Received
Complaints
Received
Stage 1
Complaint
s Received
Stage 2
Total
complaints
closed
Closed at
Stage 1
Closed
within  5
Working
Days
Citizen, Culture & Facilities 25 24 1 25 24 20
Education, Learning & Attainment 52 44 8 41 29 22
Housing & Employability 490 447 43 456 426 226
People & Technology  0 0 0 0 0 0
Regulatory & Regeneration 14 13 1 13 13 7
Resources 54 48 6 43 36 18
Roads & Neighbourhood 998 972 26 908 888 853
Totals 1633 1548 85 1486 1416 1146
0
1259
209
0
0
18
0
66
42
4
0
35
1633
Complaints Received Complaints Closed
Complaint Category Upheld per category
Stage 1
Upheld per category
Stage 2
Below declared service standard 0 0
Citizen expectation not met - quality of service 1002 12
Citizen expectation not met – timescales 66 5
Council policy – does not meet criteria 0 0
Council policy – charges 0 0
Delay in service delivery 0 0
Error in Service Delivery 21 0
Council policy – level of service provision 0 0
Employee behaviour 43 0
Failure to deliver service 0 4
Service standards not declared 0 0
Total 1144 22
Contractor 12 1
Item 9
Appendix 2
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Extension
Stage 1
Exceeded
S1
deadline
after
extension
ie +10days
Total
working days
to close
Stage 1
complaints
Average
working
days to
close S1
Closed at
Stage 2
Closed
within 20
working
days
Extension
Stage 2
Exceeded
S2
deadline
after
extention
ie +25
Total
working days
to close
Stage 2
complaints
3 1 83 3 1 0 0 1 43
5 2 145 5 7 4 3 0 111
138 62 2765 6 30 11 13 6 730
0 0 0 0 0 0 0 0 0
3 3 89 7 0 0 0 0 0
12 6 252 7 2 2 0 0 16
18 17 4557 5 11 4 3 4 335
179 91 7891 6 51 21 19 11 1235
Channel Received
188
1165
13
1
265
1
Social Media 0
1633
Complaints Closed
Performance
% of complaints closed within SPSO timescales
average working days to close Stage 1 complaints
average working days to close Stage 2 complaints
% of Stage 1 complaints upheld
% of Stage 2 complaints upheld
Equalities
E-mail Equality concern raised
Internal Complaints form
Online Complaints form
In Writing
By telephone
TOTAL
Face to Face
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Outcome
Average
working
days to
close S2
Escalated
from Stage
1 to 2
Upheld
Stage 1
Not
Upheld
Stage 1
Upheld
Stage 2
Not
upheld
Stage 2
Resolved
43 0 21 3 0 1 0
16 0 16 13 5 2 5
24 0 239 187 12 18 0
0 0 0 0 0 0 0
0 0 5 8 0 0 0
8 0 17 19 0 2 5
30 0 846 42 5 6 9
24 0 1144 272 22 29 19
93%
6
24
81%
43%
0
Complaints Closed
Equalities
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WDHSCP COMPLAINTS 2024/25 
Social Work Services  Total
Children’s Health, Care & Criminal Justice 8
Community Health and Care Services 27
Mental Health, Learning Disability & Addictions 9
Total 44    
Themes  
Communication 8
Policy 9
Failure to provide service 17
Failure to Achieve Standards/Quality of Service 7
Conduct 3
Request for 3rd Party Information/Data Breach 2    
Response  
Acknowledged within 3 days 37
Response within 28 days 22    
Outcomes  
Upheld 6
Partially Upheld 14
Not Upheld 22
Withdrawn  2   
* Please note a complaint may cover multiple themes. 
233 Frontline complaints 
Item 9
Appendix 3
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West Dunbartonshire Council
Report by the Chief Officer - Resources
Audit Committee - 10 December 2025
Subject: Treasury Management Mid-Year Report 2025/2026
1. Purpose
1.1 The purpose of this report is to provide Members with an update on
treasury management to 30 September 2025.
2. Recommendations
2.1 Members are requested to:
(a) note the treasury management stewardship information within the
appended report
(b) approve the 2025/26 revised estimates of treasury and prudential
indicators as advised within the appended report (Tables A, B, C, D, E,
F, H, L and N)
(c) remit the 2025/26 Treasury Management Mid-Year Report to full
Council for approval.
3. Background
3.1 In accordance with the Treasury Policy governing the Council’s treasury
management activities the Chief Officer - Resources is required to provide
a mid-year report to Members regarding the Treasury function.
3.2 The mid year report covers the period 1 April 2025 to 30 September 2025,
details the current position (where appropriate) and revises the 2025/26
estimates where required.
3.3 One of the key clauses of the Treasury Policy is that a responsible body is
required to ensure effective scrutiny of the treasury management strategy
and polices.  Within West Dunbartonshire Council the body identified to
fulfil this role is the Audit Committee.
4. Main Issues
Treasury Management Stewardship Report
4.1 A copy of the report is attached as Appendix 1.
Item 10
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4.2 The report provides details of key changes to the Council’s capital activity
(the prudential indicators), the economic outlook, the actual and proposed
treasury management activity (borrowing and investment) and the risk
approach to treasury management (the treasury management indicators).
4.3 The external debt figures included within Table C of the report
includes short term and long-term debt. 
5. Option Appraisal
5.1 No option appraisal was required for this report.
6. People Implications
6.1 There are no people implications arising from this report.
7. Financial and Procurement Implications
7.1 There are no direct financial or procurement implications arising from
this report.
8. Risk Analysis
8.1 There are three main risks associated with the formulation of
prudential indicators and the treasury management strategy as
detailed in Appendix 1.  These risks are noted below; however the
Council has robust monitoring processes and provides regular reports
to Council with further scrutiny by the Audit Committee:
(a) Capital receipts which affect the capital financing and borrowing
requirement may not materialise, if this occurs additional borrowing
will be required in order to fund the financing requirement.
(b) The risk of counterparties default (i.e. loss of principal sum invested)
however the Council has robust controls included within its treasury
management and investment strategies that help minimise this risk.
(c) Capital inflation may increase capital expenditure level  which will
affect the capital financing and borrowing requirement leading to an
increase in borrowing, assuming no additional capital receipts are
available. 
9. Equalities Impact Assessment
9.1 No equalities impact assessment was required in relation to this
report.
10. Environmental Sustainability
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10.1 No assessment of environmental sustainability was required in relation
to this report.
11. Consultation
11.1 The views of Legal Services have been requested on this report who
advised there are no issues or concerns.
12. Strategic Assessment
12.1 Proper budgetary control and sound financial practice are
cornerstones of good governance and support Council and officers to
pursue the five strategic priorities of the Council’s Strategic Plan.
12.2 Treasury management contributes to the Financial Strategy via the
interdependency that exists between pro-active treasury management
and the formulation of long-term financial plans.
_______________________
Laurence Slavin
Chief Officer – Resources
Date: 5 November 2025
Person to Contact: Lynsey Dickson, Business Partner, Resources
Council Offices, Church Street, Dumbarton
Email: Lynsey.Dickson@west-dunbarton.gov.uk
Appendix: Appendix 1: Treasury Management Stewardship Mid-
Year Monitoring Report 2025/26
Treasury Management and Prudential Indicators
1 April 2025 to 30 September 2025
Background Papers: 1. Loans register and portfolio
2. Debt rescheduling schedules
3. Prudential Indicators 2024/25 to 2033/34 and Treasury
Management Strategy 2024/25 to 2033/34 (Council 26
March 2025)
Wards Affected: No wards directly affected.
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Mid-Year Monitoring Report 2025/26
Treasury Management and Prudential Indicators: 1 April 2025 to 30 September
2025
1. Introduction
1.1 The Council’s treasury management activities are regulated by a variety of  
professional codes, statutes and guidance:
 The Local Government in Scotland Act 2003 (the Act) provides the powers
to borrow and invest and provides controls and limits on this activity.
 The Act permits Scottish Ministers to set limits either on the Council or
nationally on all councils restricting the amount of borrowing which may be
undertaken (no restrictions have been made as yet during 2025/26).
 Statutory Instrument 29 2004, requires the Council to undertake 
borrowing activity with regard to the CIPFA Prudential Code for Capital
Finance in Local Authorities, and therefore to operate the overall treasury
function with regard to the CIPFA Code of Practice for Treasury
Management in the Public Services; and the treasury activity with regard
to the CIPFA Code of Practice for Treasury Management in Local
Authorities.
 Statutory Instrument 123 2016, sets out statutory arrangements for local
authority borrowing and lending and the requirement to maintain a loans
fund and replaces the statutory arrangements set out in Schedule 3 of the
Local Government (Scotland) Act 1975.
1.2 The regulatory framework of treasury management requires the Council to
receive a mid-year treasury review, in addition to the forward looking annual
treasury strategy and backward looking annual treasury report.  This report
meets that requirement and also incorporates the needs of the Prudential
Code to ensure adequate monitoring of the capital expenditure plans and the
Council’s prudential indicators.  The Treasury Strategy and Prudential
Indicators were previously reported to Council on 26 March 2025.  The current
position is shown (where appropriate) and revisions to the 2025/26 estimate
are provided where required.
1.3 In December 2021, the Chartered Institute of Public Finance and
Accountancy, (CIPFA), issued revised Prudential and Treasury Management
Codes.  These require all local authorities to prepare a Capital Strategy which
provides the following:
 a high-level overview of how capital expenditure, capital financing and
treasury management activity contribute to the provision of services
 an overview of how the associated risk is managed
 the implications for future financial sustainability
The Council’s Capital Strategy was agreed by Council on 5 March 2025.
1.4 This report sets out:
 key changes to the Council’s capital activity (prudential indicators)
Item 10
Appendix 1
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Appendix 1
 an economic update for the first part of  2025/26
 the actual and proposed treasury management activity (borrowing and
investment)
 the risk approach to treasury management (treasury management
indicators).
2. Key Prudential Indicators
2.1 This part of the report updates:
 the Council’s capital expenditure plans and how these plans are being
financed
 the impact of the changes in the capital expenditure plans on the
prudential indicators and the underlying need to borrow
 compliance with the limits in place for borrowing activity
 the policy on the statutory repayment of loans fund advances.
2.2 Capital Expenditure – Table A illustrates the current position and revised
estimates for capital expenditure for 2025/26. 
Table A
2025/26
Original
Estimate
(£,000)
Current
Position
(£,000)
2025/26
Projected
Outturn*
(£,000)
General Services 73,780 14,975 70,325
HRA 70,338 16,959 49,843
Capital Expenditure 144,118 31,934 120,168
Financed by:
Capital Grants 55,745 13,937 60,294
Revenue / Other 2,957 0 396
Net Financing Need 85,416 17,997 59,478
2.2.1 The movement in the level of anticipated capital expenditure is mainly due to
reprofiling carried out in 2025/26 over the life of the projects. The anticipated
spend and resources are reported to Members through budgetary control reports.
2.3 Impact of changes in Capital Expenditure Plans – Table B shows the
Capital Financing Requirement (CFR), which is the underlying external need
to borrow for a capital purpose while Table C shows the expected debt
position over the period. 
Table B       
2025/26
Original
Estimate
(£,000)
2025/26
Projected
Outturn
(£,000)
Opening CFR (1 April 2025) 947,408 881,494
New Borrowing 73,525 42,342
Long term liabilities repayment in year 0 (1,636)
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Closing CFR (31 March 2026) 1,020,933 922,200
Movement in CFR 73,525 40,706
Net financing need for the year (Table A) 85,416 59,478
Loan repayments in year - excluding long
term liabilities (PPP) (11,891) (17,136)
New Borrowing - Movement in CFR
(from previous year) 73,525 42,342
Table C
2025/26
Original
Estimate
(£,000)
Current
Position
(£,000)
2025/26
Projected
Outturn
(£,000)
External Debt
Estimated/Actual Debt at 1
April 2025 635,303 771,372 790,778
Maturing Debt (322,687) (120,000) (314,677)
Movement in Borrowing
New Borrowing - Maturing Debt 322,687 120,000 314,677
New Borrowing – CFR (Table B) 73,525 0 42,342
Debt at 31 March (1) 708,828 771,372 833,120
Long Term Liabilities at 1 April 84,041 82,853 82,853
Long Term Liabilities repayment in year
(Table B) 0 (682) (1,636)
Long Term Liabilities
at 31 March (2) 84,041 82,171 81,217
Actual Debt at 31 March (1) + (2) 792,869 853,543 914,337
CFR from Table B 1,020,933 n/a 922,200
Under/(Over) Borrowing 228,064 n/a 7,863
2.3.1  The external debt figures included within Table C includes both short term and
long-term debt.  This is due to the current strategy of using short-term
borrowing to fund long term capital investment enabling the Council to take
advantage of lower interest rates. The reduction in the estimated external debt
for 2025/26 is due to a reduction in the net capital financing need for the year.
2.3.2 The capital financing requirement is calculated on a year-end position based
on the Council’s balance sheet. The capital financing requirement  has
reduced from the original estimate due to the forecast level of capital
expenditure in 2025/26 being less than budgeted.  The Chief Officer -
Resources can report that the Council is currently on target to meet the
2025/26 revised estimates for both indicators.
2.3.3 Table C highlights that the borrowing of the Council is forecasting a borrowed
position less than the capital financing requirement at 31 March 2026.
2.4 Compliance with the limits in place for borrowing activity – A key control
over the treasury activity is a prudential indicator to ensure that, over the
medium term, gross borrowing will only be for capital purposes. 
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Gross external borrowing should not, except in the short term, exceed the
total of capital financing requirement in the preceding year plus the estimates
of any additional capital financing requirement  for 2025/26 and next two
financial years.  This allows some flexibility for limited early borrowing for
future years. 
The Council has approved a policy for borrowing in advance of need which
will be adhered to if this proves prudent. The revised indicator is detailed in
Table D and is illustrated by comparing the estimated gross debt as at 31
March 2025 with the capital financing requirement as at 31 March 2026.  The
Chief Officer - Resources reports that no difficulties are envisaged for the
current year in complying with this prudential indicator. 
Table D
2025/26
Original
Estimate
(£,000)
2025/26
Projected
Outturn
(£,000)
CFR at 31 March 2025
Estimate/Actual (Table B ) 947,408 881,494
Estimated movement in CFR
2025/26 (Table B) 73,525 40,706
2026/27 76,158 64,042
2027/28 48,094 48,094
Anticipated CFR at 31 March 2025 1,145,185 1,034,336
Gross Debt at 31 March 2023 (Table C) 792,869 853,543
2.4.1 The Operational Boundary is detailed in Table E below and is the limit beyond
which external debt is not normally expected to exceed. In most cases, this
would be a similar figure to the capital financing requirement, but may be
lower or higher depending on the levels of actual debt.
Table E
2025/26
Original
Estimate
(£,000)
Current
Position
(£,000)
2025/26
Projected
Outturn
(£,000)
External Debt 793,106 853,543 938,898
2.4.2 The Authorised Limit (detailed in Table F) is a prudential indicator which sets
the limit beyond which borrowing is prohibited, and needs to be set and
revised by Members.  It reflects the level of borrowing which, while not
desired, could be afforded in the short term, but is not sustainable in the
longer term.  It is the expected maximum borrowing need with some
headroom for unexpected movements. This is the statutory limit determined
under section 3 (1) of the Local Government Act 2003.
Table F
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Appendix 1
2025/26
Original
Estimate
(£,000)
Current
Position
(£,000)
2025/26
Projected
Outturn
(£,000)
External Debt 865,206 853,543 1,024,252
3. Economic Outlook from MUFG Treasury Advisors
3.1 UK
With the August rate cut now done, we are comfortable revising our previous
forecast for a November rate cut, instead pushing that back to February 2026,
on the basis that CPI inflation should have peaked by then and will be on a
slow downwards trajectory back to 2% by 2027. Further gradual reductions in
Bank Rate to 3.25% are then anticipated but, and it is a big but, only if
inflation and employment data are supportive of such cuts.
For threats to that central scenario abound. What if wage increases remain
stubbornly high and in the region of 5% even as the economy stutters towards
a position of flatlining or tepid growth? There are several sectors of the
domestic economy, including social care provision, where staff shortages
remain - even as unemployment ticks higher (currently 4.7%). And what about
the hikes in general taxation likely to arise from the 26th November Budget.
There is an estimated £15bn - £25bn second “black hole” to fill, so will there
be further borrowing announced by the Chancellor to add to taxation funding?
If so, how will gilt markets react to these variables…and will there be
additional geo-political factors to also bake in, particularly the Fed’s monetary
policy decision in September (currently 85% prospect of a rate cut) and the
ongoing tariff policies emanating from the White House. And, of course, how
will the ongoing conflicts in the Middle East and between Russia and Ukraine
influence matters? 
Moreover, it looks likely that the Bank of England will reduce the pace of its
Quantitative Tightening from an annual £100bn (October 2024 to September
2025) to a range between £60bn and £75bn from October 2025 (Market
Participants Survey, August 2025). If that policy move also sees a shift in the
gilts being sold to having shorter durations, this should prove supportive of the
gilt market generally.
Accordingly, our updated central forecast is made with several hefty caveats.
We are confident, as we have been for some time, that our forecast for Bank
Rate and the 5-year PWLB Certainty Rate is robust. But for the 10-, 25- and
50-years part of the curve, the aforementioned factors may all have a role to
play in whether we end up above, close to or below our new forecasts. As it
is, we have lifted our starting points and finishing points within the medium to
longer dated forecasts. Clients will be aware from presentations at our
Strategic Issues webinars that net annual gilt issuance of c£180bn is around a
four-fold increase compared to recent annual issuance, and with pension fund
and insurance company investment favouring shorter durations, it has been
left to transient foreign investors and hedge funds to fill the investor vacuum.
Whilst this backdrop prevails, we see no obvious reason why medium to
longer gilt yields will not remain at elevated levels, even allowing for a gradual
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reduction in inflation over the course of the forecast. Consequently, our
forecasts at Q3 2028 are 20 basis points higher than previously projected for
the 10 years and 50 basis points higher for 25 to 50 years.
Our revised PWLB rate forecasts below are based on the Certainty Rate (the
standard rate minus 20 bps) which has been accessible to most authorities
since 1 November 2012. Please note, the lower Housing Revenue Account
(HRA) PWLB rate started on 15 June 2023 for those authorities with an HRA
(standard rate minus 60 bps) and is set to prevail until at least the end of
March 2026. Hopefully, there will be a further extension to this discounted rate
announced in the Budget.
3.2 Scotland
Total funding in 2025-26 is just over £60 billion. This is £485 million higher
than presented in our May 2025 report. Most of this increase comes from
additional funding being carried into 2025-26 from the previous year. There is
also additional social security Block Grant Adjustment funding as a result of
UK Government changes to Winter Fuel Payment in England and Wales and
lower borrowing costs than previously planned.
In 2026-27, although the total available funding is similar to our May 2025
report, the split between resource and capital has changed, with resource
lower and capital higher. By 2030-31 total funding is projected to be £994
million lower than in our May report with resource funding down £700 million
and capital funding down £293 million.
This follows the UK Government Spending Review on 11 June 2025, which
set Scotland’s block grant resource funding through to 2028-29 and capital
funding through to 2029-30.
In May 2025, ahead of the UK Government’s Spending Review, we assumed
the resource and capital Block Grant would change broadly in line with the
Office for Budget Responsibility’s (OBR) March 2025 forecast of growth in
overall UK department spending. Making this assumption allowed us to
present an overview of the Scottish Government’s funding position. Now that
we have the details of the UK Government’s Spending Review, we have
updated that position.
Over the period from 2024-25 to 2030-31, resource funding is expected to
grow by 24 per cent in nominal terms. After adjusting for inflation, the growth
is 10 per cent. Devolved social security spending is taking up an increasing
share of the resource budget. This reduces funding growth available for all
other areas of spending to 6 per cent in real terms over the next five years.
In the current year (2025-26), spending on social security is 13.2 per cent of
resource funding, and is expected to increase to 15.6 per cent by the end of
the forecast period in 2030-31.
One of the immediate pressures we discussed in our May 2025 report was
public sector pay. The MTFS provides some additional information on public
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Appendix 1
sector pay, noting that it accounts for 55.0 per cent of the entire Scottish
resource budget in 2025-26.
As we noted in our May 2025 report, pay deals agreed so far in 2025-26 have
been above the Scottish Government’s Public Sector Pay Policy of 3 per cent
in 2025-26. For example, NHS workers in Scotland on Agenda for Change
terms have agreed a pay rise of 4.25 per cent in 2025-26 and 3.75 per cent in
2026-27.
We have commented before on the cumulative future impact of current pay
awards. A higher current award not only increases the paybill in the current
year, but also the cost of every future award because it increases the base to
which those future awards are applied.
The remaining pay negotiations this year will now be conducted against the
background of the Scottish Government’s newly announced workforce
reduction policy. Although the Government has retained its policy of no
compulsory redundancies, the impact of this change may influence
negotiations.
3.3 International update
Since March, the US Government has announced a series of tariff policy
changes for various countries and products. The baseline projections in this
Report are conditioned on the tariff rates implemented as of 29 July, which for
the US means an estimated effective tariff rate of around 14%. This is down
from the 23% estimate based on trade policies that had been implemented at
the time of the May Report, but up from the 2% estimate prior to the policy
changes. Tariff rates fell after the May Report as there was a de-escalation of
tensions between some countries, particularly the US and China, and trade
agreements between others, initially the US and the UK. After that agreement,
the estimated effective US tariff rate on the UK fell from 11% estimated at the
time of the May Report to 8%–9% now.
Military action between Iran and Israel (later joined by the US) in June, led to a
rise in spot oil prices, peaking at a little under $80 a barrel, up from a little over
$60 at the time of the May Report. Since then, tensions have eased, and spot
oil prices have fallen back and averaged a little under $70 a barrel over the 15
working days to 29 July. Oil prices are currently below levels seen at the start
of the year reflecting a combination of increased supply from OPEC countries
and the expectation of weaker global demand. Liquified natural gas prices
similarly increased in June but subsequently fell back. Oil and gas prices have
ended the period since May slightly higher than their levels at the time of the
previous Report.
* Link Group Interest Rate Forecast 11TH August 2025
** Scottish Fiscal Commission Report 29th May 2025 & revised version June
2025
*** Bank of England Monetary Policy Report – August 2025
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3.4 Based upon the above information, the Council’s treasury advisor, MUFG, has
provided the following interest rate forecast as at August 2025. With no changes
made after this date, they have revised the forecast pushing back a rate cut
until February 2026. It sets out a view that short, medium and long-dated
interest rates will fall back over the next year or two, on the basis that CPI
inflation should have peaked by then and will be on a slow downwards trajectory
back to 2% by 2027. Further gradual reductions in Bank Rate to 3.25% are then
anticipated, but, only if inflation and employment data are supportive of such
cuts.
Table G: -
Source: MUFG Corporate Markets
3.5 Downside risks to current forecasts for UK gilt yields and PWLB rates
currently include:
 Labour and supply shortages prove more enduring and disruptive and will
depress economic activity (accepting that in the near-term this is also an upside risk
to inflation and, thus, rising gilt yields).
 The Bank of England acts too quickly, or too far, over the next two years to raise
Bank Rate and causes UK economic growth, and increases in inflation, to be
weaker than we currently anticipate.
 UK / EU trade arrangements – if there was a major impact on trade flows and
financial services due to complications or lack of co-operation in sorting out
significant remaining issues.
 Geopolitical risks, for example in Ukraine/Russia, China/Taiwan/US, Iran, North
Korea and Middle Eastern countries, which could lead to increasing safe-haven
flows.
3.6 Upside risks to current forecasts for UK gilt yields and PWLB rates are as
 The Bank of England is too slow in its pace and strength of increases in Bank
Rate and, therefore, allows inflationary pressures to build up too strongly and for a
longer period within the UK economy, which then necessitates an even more rapid
series of increases in Bank Rate faster than we currently expect.
 The Government acts too quickly to cut taxes and/or increases expenditure in the
light of the cost-of-living squeeze.
 The pound weakens because of the UK’s growing borrowing requirement
resulting in investors pricing in a risk premium for holding UK sovereign debt.
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Appendix 1
 Longer term US treasury yields continue to rise strongly and pull gilt yields up even
higher than currently forecast.
4. Treasury Management Activity
4.1 This part of the report updates:
 the Council’s expected borrowing need and details of under/(over)
borrowing
 debt rescheduling and new borrowing
 debt charges
 investments
4.2 The Expected Borrowing Need – This was set out in Table C and
demonstrates that at 31 August 2025 the Council is projecting an under-
borrowed position. It should be noted that due to current economic climate the
borrowing rates are significantly different than this time last year, with long
term borrowing rates for periods greater than 25 years currently between
6.31% and 6.58%, depending on length of term for borrowing (as at 2
September 2025). This introduces an element of interest rate risk, as longer
term borrowing rates may rise further; however, this position is being carefully
monitored. 
4.3 Debt rescheduling and new borrowing – The Council has undertaken debt
rescheduling during 2025/26 of £33.100m (to 30 September 2025).  In the year
to date naturally maturing debt of £135.000m has been repaid which has been
mainly funded by loans from other local authorities. 
4.4 Debt Charges – The revised estimate for debt charges for both the General
Fund and the HRA is shown in Table H.  
Table H
2025/26
Original
Estimate
(£,000)
Current
Position
(£,000)
2025/26
Revised
Estimate
(£,000)
Borrowing 51,893 24,647 49,294
Other Long-Term Liabilities 9,061 4,531 9,061
Total 60,954 29,178 58,355
4.5 Investments – The objectives of the Council’s investment strategy are to
ensure the re-payment of the principal and interest of its investments on time
with the level of investment return being a secondary objective.  Following on
from the economic background above, the current investment climate has one
over-riding risk which is the risk of default. 
4.5.1 The Council held £29.1m of cash investments at 30 September 2025, and the
constituent parts of the investment position are detailed in Table I:
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Table I
£000 Country < 1 Year 1–2 Years 2–3 Years
Banks UK 4,129 Nil Nil
Money Market Fund UK 20,000 Nil Nil
Local Authorities UK 5,000 Nil Nil
Total UK 29,129 Nil Nil
4.5.2 Table J details the revised budget position for investment income.  The
original estimate has increased by £0.621m due to ongoing interest rate
changes.
Table J
2025/26
Original
Estimate
(£,000)
Current
Position
(£,000)
2025/26
Revised
Estimate
(£,000)
Investment Income 21 321 642
4.5.3 A regulatory development to address risk is the consideration and approval of
benchmarks relating to investment security, liquidity and the level of return. 
Benchmarks are used to assess the level of return and investment
performance, however the application of security and liquidity benchmarks are
more subjective in nature. 
 Security - The Council’s maximum security risk benchmark for the current
portfolio in relation to investment periods of up to one year (when
compared to historic default tables) was set at 0.00% and the Chief Officer
- Resources can report that there have been no defaults of principal sums
invested in the year to date.
 Creditworthiness - Significant levels of downgrades to Short- and Long-
Term credit ratings have not materialised since the crisis in March 2020.
 Liquidity – The Chief Officer - Resources can report that liquidity
arrangements were adequate during the year to date and that the liquidity
facilities and benchmarks set by the Council as noted below were
maintained:
o Bank overdraft - £1.000m
o Liquid short term deposits of at least £5.000m available on an
overnight basis.
 Return on Investments – The Chief Officer - Resources can report that
the investment return to date averages 4.31%.  Table K illustrates how this
average return compares with the local benchmarks.
Table K
Benchmark Benchmark
Return
Average
Return
Compound 12 month SONIA* 4.47% 4.31%
Council’s Instant Access Account 4.18% 4.31%
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Appendix 1
* SONIA is Sterling Overnight Index Average and has replaced LIBOR & LIBID
5 Key Treasury Management Indicators
5.1 This part of the report updates:
 actual and estimates of the ratio of financing costs to net revenue stream
 upper limits on interest rate exposure
 maturity structure of borrowing
 total principal sums invested.
5.2 Actual and estimates of the ratio of financing costs to net revenue
stream – This indicator (Table L) identifies the trend in the cost of capital
against the net revenue stream.
Table L
2025/26
Original
Estimate
2025/26
Revised
Estimate
General Fund 10.36%* 9.43%
HRA 53.00% 51.01%
*The General Fund 2025/26 Estimate has been restated in line with the
funding used in the Performance Indicator.
5.3 Upper Limits on Fixed and Variable Rate Exposure – These indicators
identify a maximum limit for fixed and variable interest rates based upon the
debt position. They were set at 100% and 50% respectively for 2025/26.  The
Chief Officer – Resources reports that the Council operates within these
limits.
5.4 Maturity Structures Of Borrowing – These maximum limits are set to
reduce the Council’s exposure to large fixed rate loans (those instruments
which carry a fixed interest rate for the duration of the instrument) which are
due to naturally mature in any given period as detailed in Table M and show
that the Council operates within limits set.
Table M
Maturity Structure of Fixed
Interest Rate Borrowing
2025/26
Original Limits Current
Position
Under 12 months 50% 35%
12 months to 2 years 50% 4%
2 years to 5 years 50% 29%
5 years to 10 years 50% 6%
10 years to 20 years 50% 2%
20 years to 30 years 50% 4%
30 years to 40 years 50% 3%
40 years to 50 years 100% 14%
50 years to 60 years 100% 3%
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Appendix 1
60 years to 70 years 100% 0%
5.5 Total Principal Funds Invested – These limits are set to reduce the need to
temporarily borrow to cover any unexpected expenditure and show limits to be
placed on investments with final maturities beyond each year-end.  The
Council currently invests sums for periods greater than 365 days in Clydebank
Property Company and hub West Scotland as detailed in Table N.
Table N
2025/26
Original
Estimate
(£,000)
Current
Position
(£,000)
2025/26
Revised
Estimate
(£,000)
Clydebank Property Company 273 273 273
Hub West Scotland 198 198 198
Total Principal sums invested
> 365 days (maximum limit £5m) 471 471 471
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer - People & Technology
Audit Committee - 10 December 2025
___________________________________________________________________
Subject: Accounts Commission Report - Audit of Glasgow City Council
senior officer exit packages
1. Purpose
1.1 The purpose of this report is to detail West Dunbartonshire Council’s (the
Council) response to the recommendations arising from a recent Controller of
Audit’s report to the Accounts Commission on governance and transparency
of decision making of exit packages of senior officers in Glasgow City Council.
2. Recommendations
2.1 Note the Council’s responses to each recommendation in the Accounts
Commission letter
2.2 Agree that the current approach to the governance of exit packages, in
particular those involving senior officers, is sufficient.
2.3 Agree that the Council’s Scheme of Delegation should be subject to review.
2.4 Note the revisions to the Code of Conduct as set out in paragraph 4.7.
3. Background
3.1 The release of 5 senior officers at Glasgow City Council, including the Chief
Executive, allowing access to unreduced pension benefits resulted in a report
from the Controller of Audit in relation to the scrutiny, governance and
transparency of decision making of exit packages of senior officers in
Glasgow City Council. The Accounts Commission considered its options in
respect of the powers available and consequently published findings. While
the report related to specific issues at Glasgow City Council there is an
expectation that all Councils consider the issues highlighted by the report and
discuss these at their respective Audit Committee. There is a further
expectation that steps will be taken to review the Scheme of Delegation and
decision-making processes connected with the release of officers.
3.2 The Accounts Commission letter to all Councils is attached as Appendix 1,
with the full report on the 2023/2024 audit of Glasgow City Council available
as Appendix 2.
4. Main Issues
Item 11
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Learning from the audit
4.1 The report highlights many of the same areas arising from earlier reports
produced by the Accounts Commission including the December 1997 report
and subsequent follow-up review about the management of early retirement.
These were: Bye now, pay later? The management of early retirement in local
government and Bye now, pay later? A follow-up review of the management
of early retirement, published in June 2003.
4.2 Officers have reviewed the key recommendations documented in the report
and Appendix 1 and are comfortable the Council’s current approach satisfies
the Accounts Commission’s expectations. The undernoted confirms the
Council’s position in relation to each of the five recommendations.
4.2.1 Recommendation 1 - Frameworks for decision-making: policies in relation
to the exit packages of senior officers should be approved by councillors and
reviewed regularly.
Response: the discretions available to employers under the Local
Government Pension Scheme (Scotland) Regulations 2018, are reviewed
regularly with approval secured via Corporate Services Committee. Following
notification of changes from Strathclyde Pension Fund Office, a report has
been submitted to the meeting of Corporate Services Committee on 12th
November 2025, notifying the revised schedule of discretions as applied by
the Council.
4.2.2 Recommendation 2 - Informing councillors: councillors should receive a
report at least annually that details the number of early retirals, and
redundancy decisions made in the year, along with the associated costs and
savings attached to these decisions.
Response: details of early retirements, costs and savings are submitted to
Corporate Services Committee annually as part of the ‘Workforce Planning
and Monitoring Report’. This was last presented to committee in May 2025.
4.2.3 Recommendation 3 - Decision-making: councils should rigorously appraise
individual business cases to ensure the expected savings associated with a
retiral or redundancy outweigh the costs, ensuring value for money.
Response: the Council have a cost benefit analysis (CBA) process linked to
the ‘switch policy’ and HR guidance on application. The CBA requires a robust
business case with payback generally within 2 years (aligned to Scottish
Government Public Sector Pay Policy although not directly applicable to local
authorities) and demonstrating value for money. These must be approved by
the service chief officer/HSCP head of service; Chief Officers People &
Technology and Resources, before being finally considered by the Chief
Executive. Approved CBAs are retained in personnel files and by finance to
ensure robust cost and saving reconciliation.
4.2.4 Recommendation 4 - To improve accountability and assist in monitoring,
the costs of early retirement should be charged to the appropriate service
budget.
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Response: costs and savings are held against the relevant council/HSCP
central cost centre enabling the robust holistic reconciliation referred to in
paragraph 4.2.3.
4.2.5 Recommendation 5 - Elected members should be involved in approving
early retirement and redundancy decisions for senior staff, providing the
independent scrutiny that is essential to issues and decisions where there are
potential conflicts of interest.
Response: senior level restructures, including any early retirements/voluntary
severance are reported to the Council’s Recruitment and Individual
Performance Committee for confirmation of proposals. Several senior officer
posts have been deleted since 2016 as a result of restructuring which requires
the deletion of the posts and work merged with another role and delivered in a
different way. We do not routinely use fixed term contracts at this level (in
recognition of recommendations from the earlier audit reports).
Scheme of Delegation
4.3 The Council’s scheme of delegation was last reviewed in 2021 following a
previous senior restructure. Based upon the expectations of the Audit
Commission and the changes made to the Council’s senior team following the
2024 restructure it is recognised that the scheme of delegation requires to be
reviewed.  The information for the review has been gathered and the revised
Scheme will be shared with Chief Officers to ensure it picks up any changes
since the information gathering stage.  It will then be submitted for approval in
accordance with the provisions of Paragraph 2.4 of the Scheme of Delegation.
4.4 The current scheme includes the following provision which is sufficient and
does not require amendment to facilitate the recommendations of the report . 
“The Chief Executive is the Leader of the Senior Leadership Group and has
management responsibility for all Council employees. Without prejudice to the
foregoing generality the Chief Executive’s powers, duties and responsibilities
include the following:
10. To consider requests for voluntary early retirement or severance.
14. If a decision which is not delegated to officers requires to be made
urgently between meetings of the Council or relevant Committee, the Chief
Executive, in consultation (i) with the Provost or Leader of the Council as
appropriate, and (ii) the Convener of the relevant Committee, may take
action, subject to the matter being reported to the next meeting of the
Council or relevant Committee.”
4.5 As stated in paragraph 4.2.5 above, restructures involving senior officers are
remitted to the Recruitment and Individual Performance Committee and this
would include changes at Chief Executive level. However, given the statutory
requirement to appoint a Head of Paid Service in terms of Section 4 of the
Local Government and Housing Act 1989, it would be unusual to allow the
early retirement of this post-holder with access to unreduced pension benefits,
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with (strain on the fund) cost to the authority, inconsistent with best value
principles as the payback principles are unlikely to be met. 
Key Principles of Public Life in Scotland
4.6 The Council’s Code of Conduct, most recently reviewed in November 2020,
reflects the key principles in Section 2 and as such, are a cornerstone of the
culture relevant to all officers.
4.7 However, the code omitted the additional principles of duty and respect,
added by Scottish Government for public sector bodies in Scotland.  This
technical change has now been agreed with trade union colleagues without
further recourse to committee in accordance with policy framework.
5. People Implications
5.1 There are no direct people implications arising from this report.
6. Financial and Procurement Implications
6.1 There are no direct financial or procurement implications arising from the
report, other than those reported linked to any early retirements/voluntary
severance situations. 
7. Risk Analysis
7.1 There could be reputational risks associated with any decision to release
employees which result in unreduced pension access, associated costs
depending on which option is approved and a lack of robust justification.
7.2 The Council’s approach to early release in such circumstances mitigates the
risks associated with these types of decisions. 
8. Equalities Impact Assessment (EIA)
8.1 An Equality Impact Assessment was not required for the purposes of this
report as it simply notes the content of the report and the safeguards already
in place in the Council.
9. Consultation
9.1 The Trade Unions were advised of the audit report and the Council’s
response at the meeting on 16 September 2025.  
9.2 Colleagues in finance, legal, and HR were involved in the preparation of the
report.
10. Strategic Assessment
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10.1 This proposal aligns with the Council’s strategic objective of delivering
efficient and cost-effective services, contributing to its priority of being a
“continuously improving Council delivering best value.”
Victoria Rogers
Chief Officer People & Technology
Date: 11 November 2025
Person to contact: Victoria Rogers, Chief Officer People & Technology
Appendix: Appendix 1 – Accounts Commission Letter to Councils
Appendix 2 – Audit of Glasgow City Council, senior      
officer exit packages
Background Papers: None
Wards Affected: All
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4th Floor
102 West Port
Edinburgh  EH3 9DN
T: 0131 625 1500
E: info@audit-scotland.gov.uk
www.audit-scotland.gov.uk 
To All Leaders and Chief Executives          08 September 2025          
Copied to: Directors of Finance; External auditors 
Dear Leader and Chief Executive, 
On 14 August, the Accounts Commission considered a report from the Controller of Audit
(under powers in s102 (1) of the Local Government (Scotland) Act 1973) in relation to the
scrutiny, governance and transparency of decision making of exit packages of
senior officers in Glasgow City Council. The Controller highlighted issues and serious
concerns on how decisions were made around these exit packages and set out the
council’s response. The Commission welcomed the actions of the new chief executive in
commissioning an internal review, an independent investigation of these issues and
reporting the outcome publicly. I look forward to discussing this matter further with the
Glasgow City Council when we meet in the coming weeks. 
In response to the Controller’s report, the Commission considered carefully the most
appropriate way to use the powers available to it, including holding a hearing, making
recommendations to Scottish Ministers or censuring in light of the concerning issues
presented in the report. On this occasion, alongside publishing findings, it is vital that all
councils take action to recognise the important learnings from this report. The Commission
expects that this letter - also copied to Directors of Finance and external auditors - and the
issues the report highlights, will be discussed by your audit and scrutiny committee. We
expect that steps will be taken to review your Scheme of Delegation and decision-making
processes.   
The Commission recognises that as councils continue to face financial challenges, service
redesign and restructuring are key tools available to councils to respond to these
challenges. However, transparency and good governance around decision-making is
essential. The decisions of elected members and officers should uphold the nine Key
Principles of Public Life in Scotland – selflessness, integrity, objectivity, accountability,
openness, honesty, leadership, public services, respect. Sadly, the Commission believes
that the way in which the restructuring packages were dealt with in this case did not. 
Where decisions around restructuring and exit packages are being taken, councils must
ensure there is clear evidence of effective governance, independent scrutiny, and
value for money, as well as robust and transparent record keeping. Lessons learnt
are set out clearly in our report at paragraphs 46 - 48.   
Concerningly, this recent report is not the first time that this issue has been considered by
the Accounts Commission. In 1997 and 2003, reports were published on managing early
retirement and their key messages are as relevant today as they were then, not only for
decisions relating to early retirement packages but also to any senior officer exit packages. 
Below are five key recommendations from the 2003 report, adapted for today’s context: 
Item 11
Appendix 1
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1. Frameworks for decision-making: policies in relation to the exit packages of
senior officers should be approved by councillors and reviewed regularly. 
2. Informing councillors: councillors should receive a report at least annually that
details the number of early retirals, and redundancy decisions made in the year,
along with the associated costs and savings attached to these decisions. 
3. Decision-making: councils should rigorously appraise individual business cases to
ensure the expected savings associated with a retiral or redundancy outweigh the
costs, ensuring value for money. 
4. To improve accountability and assist in monitoring, the costs of early retirement
should be charged to the appropriate service budget. 
5. Elected members should be involved in approving early retirement and
redundancy decisions for senior staff, providing the independent scrutiny that is
essential to issues and decisions where there are potential conflicts of interest.  
I would urge all councils to take action now to ensure that all officers and members are
familiar with the Key Principles of Public Life, and that you can evidence that your
organisational culture respects and supports them fully. 
If you have any questions or queries in relation to the report on Glasgow City Council or on
any other aspect of the Commission’s work, please do not hesitate to get in touch:
acsupport@audit-scotland.gov.uk 
I look forward to engaging with you in the future. 
Yours sincerely, 
Andrew Burns
Deputy Chair, Accounts Commission
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The 2023/24 audit
of Glasgow City
Council
Senior officer exit packages 
Prepared by the Controller of Audit
September 2025
Item 11
Appendix 2
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The 2023/24 audit of Glasgow City Council | 2 
Contents 
Commission findings 3
Introduction 6
How decisions were made 10
The council’s response 16 
Accessibility
You can find out more and read this report using assistive technology on
our website www.audit.scot/accessibility.
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Commission findings | 3 
Commission findings 
The Accounts Commission accepts the Controller of Audit’s report on a
matter arising from the 2023/24 audit of Glasgow City Council in relation to
the scrutiny, governance and transparency of decision-making of exit
packages of senior officers. The Commission welcomes that the Controller
used her powers to bring this issue to its attention, and notes she was able
to draw on the independent investigation of the issue undertaken by
Brodies LLP (on behalf of the council), as well as the annual audit report.
The Brodies LLP report was itself supported by the report of a King's
Counsel (KC), whom Brodies had instructed to review and provide an
opinion on its investigation.
Following consideration of the Controller’s report (presented at page 6) at
its meeting on 14 August, the Commission has made the findings
presented below.
1 The Commission welcomes the actions of the new chief executive of Glasgow
City Council in commissioning an internal review and an independent
investigation of these issues following discussions with appointed auditors,
and for reporting the findings of the investigation publicly. We note that the
2023/24 annual audit report shows the council has accepted many of the
recommendations and look forward to seeing the auditors’ review of progress
in the 2024/25 annual audit. We expect the council to have strong evidence of
good governance, scrutiny, and value for money and to present clear
business cases for future restructuring.
2 Given that councils are required (under the under Section 4 of the Local
Government and Housing Act 1989), to have a ‘head of paid service’, and
that this is ordinarily the post of chief executive, we find it hard to understand
how this post was part of a senior management restructuring package,
developed in February 2021 (and presented in the ‘Restructure Report’),
aimed at cost savings and efficiency. Within the final Restructure Report, an
Executive Director post, deleted in January 2021, was linked to the early
retirement of the chief executive, and subsequently included as part of
payback period calculations. As the Brodies report states, the savings
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Commission findings | 4 
associated with the deleted post had already been achieved. Based on the
information considered, it is our view that the rationale for the former chief
executive’s retirement contributing to efficiencies was, at best, unclear. 
3 We consider that the restructuring package was dealt with in a manner
inconsistent with the Key Principles of Public Life in Scotland, in particular
selflessness, integrity and objectivity. The Restructure Report appears to
have been approved by some individuals who then benefitted from its
proposals. This exhibits a failure to address and document potential conflicts
of interest (that should have been obvious to such senior and experienced
officers) and displays a lack of judgement in relation to how their actions
adhered to the principles. The council should take action to ensure that all
officers and members are not only familiar with the principles but that the
organisational culture respects and supports them fully. The council must also
ensure that independent scrutiny is applied to issues and decisions where
there are potential conflicts of interest.
4 Given the seniority of the officers associated with these exit packages, our
clear view is that a full report should have been presented to the relevant
committee for approval. Within the Scheme of Delegation used during this
period, consideration of whether to involve elected members was a
‘judgement call’ by officers based on whether an issue could be considered
politically controversial. Given the significance of the post of chief executive,
linking it to efficiency savings should have been subject to independent
scrutiny. Had elected members been involved at key stages, their scrutiny
could have mitigated some of the justified criticisms around perceived
conflicts of interest.
5 As councils continue to face financial challenges, service redesign and
restructuring will be a necessary part of responding, so transparency around
decision-making is essential. The decisions of elected members and officers
should uphold the nine Key Principles of Public Life in Scotland –
selflessness, integrity, objectivity, accountability, openness, honesty,
leadership, public services, respect. Where decisions around restructuring
and exit packages are being taken, councils must ensure there is clear
evidence of effective governance, independent scrutiny, and robust and
transparent record keeping. 
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Commission findings | 5 
6 It is alarming to see reports which need to consider the lawfulness of actions
within councils, and such circumstances do little to reassure taxpayers about
how public money is being used. Given the serious issues highlighted in the
Controller’s report, the Commission considered carefully the most appropriate
way to use the powers available to it, including holding a hearing, making
recommendations to Scottish ministers or censuring in light of the concerning
issues presented. In reaching our findings, we have considered the legal
advice provided to Glasgow City Council and the action already taken. On
this occasion, we have decided to take proactive steps to ensure that all local
government bodies recognise the important lessons presented here, including
writing to all council chief executives and leaders to highlight the importance
of good governance and transparency in decision-making. 
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Introduction | 6 
Introduction 
1.  The Code of Audit Practice requires auditors to produce an Annual Audit
Report (AAR) summarising the significant matters arising from their audit
work. For local authorities, auditors address the AAR to elected members
and the Controller of Audit.
2.  I have received the Annual Audit Report and the audited annual
accounts for Glasgow City Council (the council) for 2023/24. The
appointed local auditor (Stephen Reid of Ernst & Young LLP (EY)) has
issued a qualified audit opinion in relation to the council’s financial
statements for the council and its group in respect of two City Building
group entries for a second year. This reflected the impact of delays from
previous years’ auditing of the accounts for these arm’s-length external
organisations following a series of whistleblowing allegations in 2022. 
3.  The auditor also identified several risks, including the need for a robust
medium- to longer-term financial strategy to reflect potential financial
scenarios and support financial sustainability, as well as the need to agree
a revised date for implementation of the new pay and grading structure.
A total of 30 recommendations remain open, including 19 Grade 1(high
risk) recommendations. I will monitor the council’s progress with
addressing these issues through the audit team. I intend to bring a Best
Value report to the Commission in August 2026 and will keep this under
review with the appointed auditor including consideration of the pace of
progress in implementing improvements.
4.  The auditor also raised significant matters in the AAR in relation to the
scrutiny, governance and transparency of decision-making in respect of
the exit of five senior officers over the course of a three-year period
between 2021 and 2024. I have decided to use the reporting powers
available to me under s102 (1) of the Local Government (Scotland) Act
1973 to bring these matters to the Accounts Commission’s attention.
5.  My report relies on a number of publicly available documents. Auditors
have not undertaken primary evidence gathering such as interviews with
current or former officials of Glasgow City Council. The report draws
heavily on the independent review ‘Investigation into exit packages of
former senior officials at Glasgow City Council’ undertaken by Brodies LLP,
particularly for the ‘Background’ and ‘How decisions were made’ sections
of the report. The independent review report is publicly available from
Glasgow City Council. It was produced for the purposes of the council, and
I appreciate the agreement of both the council and Brodies to use the
content. I note that the parties who exited the council as part of the
restructure of the Chief Executive’s Department were not interviewed, and
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Introduction | 7 
not all had the opportunity to give evidence to the investigation carried out
by Brodies. My report also draws on the work reported by the appointed
auditor in the Annual Audit Report 2023/24.
Background
6.  In early 2021, a proposal was drafted setting out a restructure of the
council’s Chief Executive’s Department, which included setting out the
financial arrangements relating to the exit of five senior officers. The
officers were:
• the former solicitor to the council and director of governance
• the former principal advisor to the chief executive
• the former head of human resources
• the former head of legal and administration and latterly director of
legal and administration
• the former chief executive. 
7.   The departures took place between April 2021 and May 2024. The total
cost of the exit packages was £1.035 million with £0.268 million relating to
redundancy payments and £0.77 million relating to strain on pension
fund costs. The estimated ongoing savings in the proposal were £0.65
million per annum. 
Strain on pension fund costs are the additional cost incurred by a
pension fund when a member retires early or receives benefits without
actuarial reductions, often due to factors like redundancy or employer-
approved early retirement. These costs arise because the fund needs to
pay out benefits sooner or with less reduction than initially anticipated,
requiring additional funding to cover the shortfall.
8.  The leader of the council and city treasurer raised concerns after
publication of the unaudited financial statements, which included details of
the pension costs and payments in relation to loss of office, were
published. The new chief executive launched an internal review into these
matters which led to the commissioning of an independent review,
including legal advice. 
9.  In March and April 2025, the outcome of the independent review was
reported to three of the council’s committees for consideration.
Subsequently, proposed changes to strengthen its governance
arrangements in relation to workforce and service reform, were considered
and agreed at a meeting of the council on 15 May 2025. A timeline of
these events is set out in Exhibit 1. It is important to note that the Brodies
independent investigation states that ‘we did not find any evidence
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Introduction | 8 
allowing us to conclude that any recipient of any severance/retirement
package, or any other officer, acted improperly’.
Exhibit 1 
Timeline of key events
2021 to 2024 
January/February
2021
As part of planning for the restructuring of the council’s Chief Executive’s
Department, a business case was developed which set out the
proposed financial arrangements for the exit of five senior officers within
the department. 
April 2021 The former solicitor to the council and director of governance left the
council. She received a sum of £95,000 voluntary separation payment. 
July 2021 The former principal advisor to the chief executive left, receiving early
unreduced access to her pension and redundancy, totalling benefits of
just under £192,000. 
January 2023 The former head of human resources left, receiving early unreduced
access to his pension and redundancy, totalling benefits of just under
£148,000. 
September 2023 The former head of legal and administration (latterly the director) left,
receiving early unreduced access to her pension and redundancy
totalling benefits of £283,000.
May 2024 The former chief executive left, receiving early unreduced access to her
pension at a cost of £317,000 to the council. 
July 2024 The council published its unaudited financial statements, including the
remuneration report, disclosing costs associated with the early
retirement of the former chief executive and former director of legal and
administration. 
August 2024 The accounts and financial statements were reported to the council’s
Finance and Audit Scrutiny Committee. 
September 2024 An internal review was commissioned by the new chief executive to be
performed by the council’s monitoring officer and head of audit and
inspection.
October 2024 The appointed auditor was notified about the internal review and about
the restructure report. 
December 2024 The council instructed Brodies LLP to investigate and prepare an
independent report on these matters.
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Introduction | 9 
Timeline of key events
2025 
February 2025 Brodies LLP provided the report of its investigation. This included the
report of a King’s Counsel (KC), Brodies had instructed to review and
provide an opinion on its investigation. 
March 2025 The council’s Finance and Audit Scrutiny Committee considered in
public, a report by the chief executive on the findings of the independent
investigation by Brodies of senior officer exit payments. This included
provision of the full Brodies report and KC opinion. 
April 2025 The council’s Wellbeing, Equalities, Communities, Culture and
Engagement Policy Committee considered a report setting out the
findings and recommendations of the independent review of the
arrangements for the chief officer departures.
April 2025 A special meeting of the council’s Finance and Audit Scrutiny Committee
was held to consider the annual accounts and annual audit report,
including the external auditor’s comments on the exit payments. 
May 2025 The council’s City Administration Committee considered a paper on the
review of arrangements for chief officer departures and proposed
changes.
May 2025 The former chief executive reached an agreement with Strathclyde
Pension Fund which, with the approval of the council, resulted in
repayment to the council of the strain on the fund cost associated with
her early retirement.
May 2025 Glasgow City Council agreed proposed changes to the terms of
reference of committees and the scheme of delegated functions, in
response to the independent review. 
Source: Audit Scotland
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How decisions were made | 10 
How decisions were made
The approach taken to the restructuring of the senior management of
the Chief Executive’s Department 
The role of the Chief Executive’s Department
10.  The Chief Executive’s Department in a council is the strategic planning
and management centre of the organisation. It provides the corporate
lead, advice and support to its other departments and functions. It also
provides the lead for governance and support to councillors with their
policy-setting, decision-making and scrutiny role.
11.  In Glasgow City Council, the main services of the Chief Executive’s
Department include for example: Policy, Corporate governance and
communication; Legal and administration; Human resources; Corporate
procurement; Digital services; Customer care; Financial inclusion and
Economic development.
Restructuring requires good governance 
12.  Whether as part of improvement and/or savings programmes, councils
need to undertake organisational and staff restructuring from time to time.
It allows the organisation to realign its resources to respond to change or
to new priorities and find ways to work more efficiently. This can include
redeployment or reductions of senior officers through early retirement or
redundancy packages. 
13.  It is important that decisions made about restructuring, including exit
packages for senior staff, are undertaken in the most transparent manner
with clear governance arrangements that reflect the principles of public life
in Scotland (Exhibit 2). In addition to demonstrating high standards of
governance, councils also need to demonstrate that decisions about
restructuring and exit packages are value for money for the public purse. 
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How decisions were made | 11 
Exhibit 2 
Principles of public life 
There are expectations on how elected members and officers of public bodies,
including councils, conduct themselves and the work they undertake. In 1995, the
Committee on Standards in Public Life (the Nolan Committee) identified seven
principles of conduct underpinning public life. In Scotland these principles were
expanded to include a further two into the Nine Principles of Public Life in Scotland   
1. Selflessness 
Acting solely in the 
public interest.
2. Integrity
Avoiding obligations that
might influence official duties.
3. Objectivity 
Making decisions impartially
and on merit.   
4. Accountability 
Being answerable to the
public and open to scrutiny.
5. Openness 
Acting transparently and
justifying decisions.
6. Honesty 
Being truthful and declaring
conflicts of interest.   
7. Leadership 
Promoting and upholding
these principles through
example.
8. Public service 
Acting in the interests of the
public body and fulfilling its
core tasks.
9. Respect 
Treating colleagues and staff
with courtesy and valuing 
their roles. 
Source: Scottish Government/Audit Scotland
How decisions were made
The process for approving the business case for restructuring
the senior management of the Chief Executive’s Department is
not formally documented
14.  The independent investigation by Brodies LLP sets out that following a
discussion in January 2021, the head of human resources sent the former
chief executive a business case in February 2021, entitled Proposed
Senior Management Restructure Report. This report set out the proposed
financial arrangements relating to the exit of five senior officers within the
Chief Executive’s Department. The report proposed that: 
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How decisions were made | 12 
• the post of solicitor to the council and director of
governance (Grade 13) be made redundant, with its functions
merged into other senior roles. A new role of solicitor to the council
and monitoring officer (Grade 12) would be created
• the post of solicitor to the council and monitoring officer be subject
to a ‘bump redundancy’, and a legal manager post (Grade 10)
deleted
• the post of principal adviser to the chief executive (Grade 11) be
made redundant, with its functions merged into a new head of
performance and governance role
• the post of head of human resources (Grade 11) be subject to
a bump redundancy, and a strategic HR manager post (Grade 11)
deleted
• the chief executive (Grade 15) take early retirement in or around
late 2022 on grounds of efficiency, with an estimated cost
of £349,095.
Bump redundancy (or transferred redundancy) generally refers to an
employee at risk of redundancy being moved into another role within the
organisation. The person currently in that role is then made redundant
instead. 
15.  In February 2021, the former executive director of finance sent an
email to the chief executive stating: ‘I can confirm that each individual case
and the overall project are consistent with council policy and the business
case is comfortably within target parameters. I am therefore fully
supportive of the proposals as outlined in the paper.’ There is no explicit
evidence of the chief executive, the director of governance and solicitor to
the council approving the restructure report, as required at that time by the
scheme of delegated functions. The independent review concludes that it
is implicit in the collective correspondence about the report. There does
not appear to be a clear document trail recording definitively the decision-
making in relation to approval of the restructure report. 
Approval of the exit and the terms for four of the five officers
were in line with policy
16.  The independent review concluded that approval requirements were
met for the exit terms of the solicitor to the council, the principal advisor to
the chief executive, head of/director of legal and administration and head
of human resources. 
17.  The exit terms offered to four of the former officers were in line with
the council’s policies in terms of redundancy payments, pension strain
costs and payback periods.
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How decisions were made | 13 
18.  The independent review concludes that ‘it is not clear whether [the
solicitor to the council’s] departure can be said to fall within the scope of
the council’s policies on redundancy and early retirement’ as it was not
formally a redundancy. She received a severance payment of £95,000 as
an agreed sum to be paid on her resignation. She did not receive
redundancy or early access to her pension. 
Approval of the chief executive’s exit did not follow the scheme
of delegated functions 
19.  There was no specific provision for approval of the early retirement or
severance of the chief executive under the scheme of delegated functions. 
20.  The former chief executive highlighted in her statement to the
independent review that in her view, as the role didn’t fall under ‘chief
officials’ that the scheme permitted her to delegate approval to the
executive director of finance and head of human resources, as for non-
chief officials. Her view is the approval was given at the time the
restructure report was written in 2021. 
21.  The independent review also draws attention to an email in March
2024 from an HR officer sent to both the new head of human resources
and the executive director of finance with the request for the former chief
executive’s early retirement, which was approved on the same day. The
independent review notes, however, that it appears that the executive
director of finance and the new head of human resources did not consider
they were formally approving the application but that their function was to
check the application complied with relevant council policies.
Elected members were not involved in decision-making or
approval processes 
22.  The scheme includes the general requirement on officers ‘where
he/she considers that a matter may be politically controversial even
although it has been specifically delegated to him/her, to consult with the
appropriate city convener. If after consultation the officer determines the
matter is politically controversial, it must be referred to committee as
appropriate for approval’. 
23.  What can be considered politically controversial is a judgement,
however it is reasonable to consider the early retirement of the chief
executive on efficiency grounds, and the operational and financial
implications of this could meet this description, and it is not clear what
consideration was given to this issue. The independent review concluded
that officers should have referred the restructure report to the relevant city
convenor for consultation as a matter of potential political controversy.
24.  Councillors do not, however, appear to have been involved in the
decision-making or approval processes for the exit packages for any of the
five senior officers, including the chief executive. There is no evidence of
the proposals and terms being discussed with councillors and the
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How decisions were made | 14 
restructure report was not shared with councillors or presented at
committee for approval. 
Appropriate scrutiny, transparency and accountability was
lacking
25.  As highlighted at paragraph nine, it is important to note that the
independent investigation states that ‘we did not find any evidence
allowing us to conclude that any recipient of any severance/retirement
package, or any other officer, acted improperly’. However, in the interests
of transparency and good governance, the absence of a clear document
trail, setting out the decisions and approvals required for the restructure
report, including the consideration of potential conflicts of interest and the
need to involve councillors, is concerning. 
26.  I support the auditor’s conclusions in his 2023/24 AAR that ‘the council
was unable to demonstrate effective scrutiny, governance and
transparency in decision-making or value for money in respect of the exit
of five senior officers over the course of a three-year period between 2021
and 2024’. It is not clear whether the restructure was value for money. All
councils should ensure that they can demonstrate the value for money for
any service reform or restructure. In this case, the council’s restructure
paper highlights two key reasons for the structural change: 
• the ongoing requirement to make significant savings; and 
• a need to address the demographics of the senior team and put in
place robust succession planning arrangements. 
27.  The restructure report concluded that the total cost of the proposals
would be £731,486, with ongoing annual savings of £652,658, resulting in
a payback period of 1.12 years. However, the detail of the report sets out
total redundancy and strain on the fund costs of £1.025 million for the five
senior officers. The council advises that the lower cost of £731,846 is after
in-year salary savings are included.
28.  The appointed auditor notes in the AAR that the actual total cost of the
exit of the five senior officers was £1.035 million as opposed to the cost of
the proposals in the restructure report of £1.025 million. The difference
reflects updated figures since the time of the business case in 2021, as
well as changes to planned leaving dates. 
29.  It is not possible to reach a conclusion on the rationale for the exit
terms given to the five senior officers, as there is a lack of consideration
within the restructure report of the benefits to the council for the reform
(outwith the overall annual financial savings of £0.65 million). 
30.  There is no reference within the restructure report to alternative
mechanisms for change being considered. The auditor comments in the
AAR that ‘while we note in circumstances where restructures involve
senior officers, alternative options such as redeployment are often not
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How decisions were made | 15 
practical or possible, we would expect consideration of all options to be
evaluated. In this specific instance, it’s unclear why early retirement and
redundancy was the best solution to address concerns around succession
planning’. 
31.  It is particularly difficult to see the justification for the chief executive’s
early retirement on the grounds of cost savings and succession planning,
as the post of chief executive remains within the structure. In February
2024, the request to approve the terms of the chief executive’s early
retirement, made to the head of human resources and the executive
director of finance for approval, was made on the grounds of efficiency. 
32.  A final amendment made to the restructure report before its approval
by officers was to include a link between the deletion of the post of
executive director of development and regeneration services and the early
retirement of the chief executive. The deletion of the role was approved by
the council’s City Administration Committee in January 2021, but the
rationale for the link to support the case for the chief executive’s retirement
contributing to savings is unclear. 
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The council’s response | 16 
The council’s response 
How the council are taking action to address the issues raised 
The council’s response and actions taken
The council commissioned an independent review and reported
publicly on the findings
33.  In September 2024, the council’s new chief executive commissioned
the council’s monitoring officer and head of audit and inspection to
undertake an internal review of the arrangements for the departure of
senior officers.
34.  Following consideration of the findings of the internal review and
discussion of the findings with the appointed auditor, the council sought an
independent legal view. Brodies LLP was instructed to undertake an
independent investigation. Brodies provided their report in February 2025.
This included the opinion of a KC on the questions of law asked by the
council, based on the findings in the Brodies LLP report. 
35.  A summary of findings from the Brodies LLP report, are set out in
Exhibit 3. The full report, with the opinion provided by the KC, is available
from Glasgow City Council. 
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The council’s response | 17 
Exhibit 3 
Key findings of independent legal review 
Severance terms offered to each of the officers were in accordance with
applicable council policies. 
The justification for the early retirement of the former chief executive was
not supported by the restructure report or accompanying correspondence
and there was no clear justification for linking her retirement with the
deletion of the post of executive director of development and regeneration
services. 
The restructure report should have been the subject of elected member
input, rather than being approved solely by officers, particularly as the
officers who were involved in approving it also benefitted from its terms by
being proposed for early retirement/severance packages. No evidence was
found that elected members were asked to approve the report or individual
applications for severance/retirement. There was also no evidence that
elected members had any knowledge of the details of the departures prior
to the publication of the remuneration report as part of the unaudited
annual accounts for 2023/24. 
It is considered that the former chief executive’s application for early
retirement was not, on the face of it, lawfully approved in terms of the
council’s Scheme of Delegated Functions. However, it was considered
unlikely that a judicial review would overturn the decision, given the
detriment to the former chief executive and the time passed. 
That the pension strain costs which formed part of four of the five
redundancy/early retirement packages under investigation were mandatory
in terms of the council’s policy and the Local Government Pension Scheme
Regulations. 
It is considered that there is no reasonable basis for the recovery of the
sums paid by the council in respect of the five early retirement/redundancy
packages. 
Source: Brodies LLP report: Investigation into exit packages of former senior officers at
Glasgow City Council and Opinion of senior counsel in re. Investigation into exit packages of
former senior officers at Glasgow City Council
36.  The council presented the legally privileged report from Brodies LLP
and the opinion from the KC in public to the Finance and Audit Scrutiny
Committee on 11 March 2025. The council’s decision to consider the
findings of the independent review in public, indicates a desire to ensure
greater transparency and openness on the matter, which is welcome.
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The council’s response | 18 
The council are making updates to governance structures
and policy 
37.  An internal review of the council’s governance arrangements relating
to workforce and service reform activity has been undertaken. In response
to the issues highlighted by the independent review and recommendations
from the appointed auditor, the council is making amendments to
governance arrangements and policy in respect of early retirement and
voluntary redundancy. 
38.  At the May 2025 council meeting, amendments to the Scheme of
Delegated Functions and Committee Terms of Reference were agreed.
The amendments to arrangements include:
• Clarity in the scheme that the term chief officers refers to all officers
grade 12 and above, including the chief executive.
• Changing the title of the Senior Officer Appointment Committee to
the Senior Officer Workforce Committee and changing the remit to
consider not only appointments of senior officers but also the
approval of proposals involving early retirement or redundancy of
officers of grade 12 or above.
• Adding the director of legal and administration to the senior officers
required to approve changes to staffing structures, numbers and
gradings.
• Deleting the previous delegation, which authorised the chief
executive to approve applications from chief officials for early
retirement and voluntary severance. 
• Adding an express delegation relating to the early retirement and
voluntary severance of the chief executive, giving authority to the
Chair of the Corporate Workforce Planning Board to recommend
proposals to the Senior Officer Workforce Committee.
39.  The auditor makes the recommendation in the AAR that the council
should ‘set clear guidance on minimum expectations for any future
restructure papers. This should include at a minimum an outline of how the
restructure achieves value for money, what alternatives to early retirement
or voluntary redundancy were considered and how the restructure meets
the council’s strategic priorities. The council accepted this
recommendation and have committed to set clear guidance for future
restructure papers and to establish a Corporate Workforce Planning Board
to oversee the implementation.
40.  In addition, the council have committed to make improvements to the
administration of exit packages in response to areas for improvement
identified by the appointed auditor in the AAR. The recommendations
include:
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The council’s response | 19 
• The council should engage with Strathclyde Pension Fund to
ensure that strain on fund calculations are only made for relevant
individuals and consider whether any amendments are required to
improve the accuracy of estimated costs. 
• Management should review the current operational processes for
recording approvals and agreements to early retirements and
redundancies. This should include clear guidance on requirements
for electronic approvals. 
41.  The auditor notes in the AAR that ‘further work will be required to
ensure that such arrangements are adhered to and the Nolan principles
are upheld in future’. The council report that it ‘will put in place
arrangements to enhance and monitor awareness, understanding and
application of the council’s governance rules across senior management
and leadership teams. This will be extended to include the employees’
Code of Conduct, with appropriate training and communication carried out
with employees across the council family’.
No legal basis for recovery 
42.  The independent review concluded that there is no reasonable basis
for the recovery of the sums paid by the council in respect of the five early
retirement/redundancy packages. The current chief executive advised that
in early May 2025, legal representation for the former chief executive
arranged for an agreement to be made with Strathclyde Pension Fund and
the council. This resulted in the repayment, from Strathclyde Pension Fund
to the council, of the strain on the pension fund of £317,000, stemming
from her early retirement. 
Glasgow City and other councils need to ensure good
governance, value for money and clear business cases for
future reform and restructuring 
The council needs to ensure it is better prepared for future
restructuring 
43.  Councils should not turn to early retirement as the first and only option
when faced with budget cuts. The need for early retirements could be
better controlled by taking a strategic approach to planning the size and
composition of the workforce, including senior roles. 
44.  Best Value thematic work undertaken at the council has highlighted
that while detailed workforce planning occurs at a service level, there is no
overall workforce plan or strategy. The council need to be able to show,
how any restructure provides value for money including how any
restructures support the council’s strategic plan, financial plans and
workforce plans. 
45.  As the council looks to continue to transform and ensure it is fit for the
future, it will need to demonstrate that:
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The council’s response | 20 
• the planned restructure achieves value for money
• the revised structure reflects the council’s strategic priorities
• alternatives to early retirement or voluntary redundancy have been
considered 
• the process for approving early retirements and redundancies is
clearly documented
• the decision-making process is subject to appropriate scrutiny and
is in line with the principles of public life.
Lessons learnt for all councils
46.  Given the current challenging financial context across the public
sector, other councils will also be undertaking restructuring and reform
programmes. They too need to ensure that they have effective governance
arrangements in place. In particular, all councils will wish to consider: 
• Are their schemes of delegation and codes of conduct fit for
purpose and do they reflect the principles of public life? 
• Does the scheme of delegation include a clear process for
considering proposals and approvals for restructure, redundancy
and retirement and does it appropriately manage potential conflicts
of interest? 
• Is there appropriate officer and councillor scrutiny of the decision-
making processes in relation to restructure, redundancy and
retirement? 
• Is there a good understanding and implementation of the
requirements set out in the scheme of delegation relating to
restructure, redundancy and retirement, through training and
monitoring? 
• Does the prevailing culture among senior officers reflect the
standards and behaviours required by the principles of public life? 
47.  The Accounts Commission produced a report in 1997 and follow-up
review about the management of early retirement. These were: 
• Bye now, pay later? The management of early retirement in local
government – December 1997
• Bye now, pay later? A follow-up review of the management of early
retirement – June 2003
48.  Messages from these reports remain relevant and councils should
remain cognisant of these as they undertake restructuring and
reorganisation that includes the early exit of senior members of staff,
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The council’s response | 21 
senior council members and senior staff in bodies in the group accounts.
Listed below are recommendations from the 2003 report of note:
• Framework for decision-making: early retirement policies should be
approved by councillors and be reviewed regularly.
• Informing councillors: councillors should receive a report at least
annually that details the number of early retiral decisions made in
the year, along with the associated costs and savings attached to
these decisions.
• Decision-making: councils should rigorously appraise individual
cases to ensure the expected savings associated with a retiral
outweigh the costs. 
• To improve accountability and assist in monitoring, the costs of
early retirement should be charged to the appropriate service
budget. 
• Elected members should be involved in approving early retirement
decisions for senior staff.
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The 2023/24 audit of Glasgow City
Council
Senior officer exit packages 
Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN
Phone: 0131 625 1500 Email: info@audit.scot 
www.audit.scot 
ISBN: 978 1 915839 81 7
AS.5.0
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer – Resources
Audit Committee - 10 December 2025
Subject: External Audit Enquiries – 2024/25 Accounts
1. Purpose
1.1 The purpose of this report is to:
 inform members of External Audit’s requirement for the provision of
information regarding the Council’s approach to dealing with fraud, litigation,
laws and regulations as part of their audit of the Council’s 2024/25 Statement
of Accounts and 2024/25 Trust Accounts.
 allow members to comment on the response related to ‘Those Charged with
Governance’.
2. Recommendations
2.1  It is recommended the Audit Committee:
 consider the enquiries for those charged with governance for the 2024/25
Council Accounts and 2024/25 Trust Accounts
 approve the submission of the draft responses set out in appendix 1 for the
Council and appendix 2 for the Trust Funds to the Council’s external
auditors.
3. Background
3.1 As part of the annual audit approach taken by the Council’s external auditors,
Forvis Mazars (Mazars), they seek responses to a range of enquiries
concerning the Council’s approach and reporting arrangements for a number of
key areas relating to themes surrounding fraud, litigation, laws and regulations
together with some areas specific to the accounts such as related parties and
estimates used in the accounts. The responses to these provided by officers will
inform the approach taken by Mazars to the audit of the 2024/25 Accounts.
4. Main Issues
4.1. In addition to the officer enquiries, Mazars require a response to several enquiries
relating to the arrangements for identifying, responding to and managing risks
around fraud from ‘those charged with governance’. Details of the specific enquiries
and a proposed response to each is provided in Appendix 1 for the Council and 2
for the Trust Funds for members to review and comment on ahead of agreeing the
final version for submission to Mazars.
5. People Implications
5.1 There are no people implications.
Item 12
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6. Financial and Procurement Implications
6.1 There are no financial implications arising from this report.
6.2 There are no procurement implications arising from this report.
7. Risk Analysis
7.1 There are no specific risk implications arising from this report.
8. Equalities Impact Assessment (EIA)
8.1 There are no direct equalities impacts arising from the report.
9. Consultation
9.1 This report has been subject to consultation with appropriate Chief Officers.
10. Strategic Assessment
10.1 This report relates to strong corporate governance.
....................................
Laurence Slavin
Chief Officer - Resources
Date: 10 December 2025
Person to Contact: Laurence Slavin, Chief Officer - Resources
E-mail: laurence.slavin@west-dunbarton.gov.uk
Appendices: 1 – External Audit Enquiries for Those Charged with
Governance (WDC)
2 – External Audit Enquires for Those Charged with Go
vernance (Trust Funds)
Background Papers: None
Wards Affected: All wards
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Item 12
Appendix 1
International Standard for Auditing 240 - The auditor’s responsibility to consider
fraud in an audit of financial statements
1) How does the Committee, in its role as those charged with governance, exercise
oversight of management's processes in relation to:
 undertaking an assessment of the risk that the financial statements may be materially
misstated due to fraud or error (including the nature, extent and frequency of these
assessments);
 identifying and responding to risks of fraud in the organisation, including any specific
risks of fraud which management have identified or that have been brought to its
attention, or classes of transactions, account balances, or disclosure for which a risk of
fraud is likely to exist;
 communicating to employees of views on business practice and ethical behaviour (for
example by updating, communicating and monitoring against the organisation’s code
of conduct); and
 communicating to those charged with governance the processes for identifying and
responding to fraud or error?
Response
The Council’s financial statements are prepared by experienced and professionally
qualified accountants who are regulated by the standards of their respective institutes. 
The financial statements reflect the transactions which have been processed by the
Council’s financial systems.  These systems are protected by internal controls and
procedures which are periodically reviewed and tested by internal audit and our external
auditors.  Consequently, although the material misstatement cannot be ruled out, its
likelihood is low.
The Audit Committee provides oversight and challenge in relation to the financial
statements and seeks assurances from the Chief Officer - Resources that the accounts
are not materially misstated.  Updates are provided to Audit Committee and/or full Council
on key areas of the statement, any changes in accounting policies and their impact on the
statements.
The Audit Committee plays a key oversight role in relation to fraud and error identification.
The Committee receives regular progress reports on anti-fraud activities taking place
within the Council. 
The Council has a code of conduct which describes the standards of conduct and practice
which all Council employees should follow. The code of conduct is a key component of the
Council’s Code of Good Governance.
The Council’s Whistleblowing Policy enables any individual to register, in confidence,
any concerns regarding alleged misconduct and fraudulent or corrupt activity. This can be
found on the Council’s website and intranet.
2) How does the Committee oversee management processes to identify and respond to
the risk of fraud and possible breaches of internal control? Is the Committee aware of any
breaches of internal control during 2024/25? Please provide details.
Response
It is the responsibility of management to develop and maintain sound systems of risk
management, governance and internal control. This includes the requirement to identify
and respond to any identified breaches of internal control. 
However it is noted that internal control systems, no matter how well designed and
operated, are affected by inherent limitations. These include the possibility of poor
judgement in decision making; human error; control processes being deliberately
circumvented by employees and others; management overriding controls and
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Appendix 1
unforeseeable circumstances.
In terms of oversight, the Council’s Internal Audit function plays a key role in this
regard. Internal Audit work is not a substitute for management’s responsibilities for
the design and operation of these systems, and is not responsible for identifying all
significant control failures. 
However, the Internal Audit team has an important role in providing assurance on the
Council’s control environment and providing a view on the Council’s processes for
identifying control failures, and endeavours to plan its work so that work is focused on
those areas where there is higher risk. A risk-based audit plan is produced annually based
on best practice, taking cognisance of the strategic and operational risk registers and
engagement with senior managers. The methodology for prioritising audit work is set out
in the audit strategy and plan. Findings are reported as Red, Amber or Green which aligns
with the Council’s risk management strategy.  Red and Amber findings are reported to
Audit Committee together with management’s agreed actions to address these issues.
The Audit Committee receive a range of assurances/reports during the year which touch
upon aspects of internal control.  Reports in 2024/25 have included:
 Annual Audit Plans from internal and external audit
 Annual Internal Audit Report and Assurance Statement
 Internal Audit progress reports
 Code of Good Governance and the Annual Governance Statement
 Accounting policies, Annual Accounts and External audit Annual Report
 Treasury management annual report and updates
 Regular reports on National Fraud Initiative
 Risk management update on Strategic Risk register
 Annual Complaints Report
 Responses to External Audit Enquiries to Those Charged with Governance
Where deemed necessary the Audit Committee will ask that a relevant officer of the
Council is present at Audit Committee meetings to respond to questions on a report being
presented.
3) Has the Committee knowledge of any actual, suspected or alleged fraud during the
period 1 April 2024 – 31 March 2025? Where appropriate please provide details.
Response
A number of suspected/alleged instances of fraud occurred during 2024/25. These are
detailed within the regular reports to Audit Committee. Cases included those relating
to housing benefit/council tax and misuse of council resources.
4) Has the Committee any suspicion that fraud may be occurring within the organisation?
Please provide details.
 Has the Committee identified any specific fraud risks within the organisation? Please
provide details.
 Does the Committee have any concerns that there are areas within the organisation
that are at risk of fraud? Please provide details.
 Are there particular locations within the organisation where fraud is more likely to
occur? Please provide details.
Response
As with any large and complex organisation there are a range of fraud risks and emphasis
on reducing fraud risk is continuous. The results of the NFI, internal audit work and
reported fraud show some low value frauds.
Management and the Audit Committee is kept up to date with fraud risks through updates
on counter fraud arrangements, Internal Audit and other ad hoc reports.
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Appendix 1
Fraud risks are acknowledged in key areas. Members and officers are aware of these and
the risks are managed through established risk management processes.
5) Is the Committee satisfied that internal controls, including segregation of duties, exist
and work effectively? Please provide details.
 If not, where are the risk areas?
 What other controls are in place to help prevent, deter or detect fraud?
Response
Key controls such as the segregation of duties, management review and
supervision and authorisation and approval are evident in each of the Council’s core
systems.  It is acknowledged that maintaining an effective control environment is
challenging in a time of reducing resources and a changing operating environment. For
this reason, internal audit will have a continued role in supporting the Council in ensuring
that an adequate but appropriate control environment is in place.
In overall terms, Internal Audit have concluded that reasonable assurance can be
provided on the Council’s system of internal control for 2024/25.
6) Is the Committee satisfied that staff are encouraged to report their concerns about
fraud, and the types of concerns they are expected to report? Please provide details.
Response
The Council promotes a zero tolerance toward fraud and promotes a culture that enables
individuals to identify potential fraud and empowers them to report their concerns in a safe
and secure manner to the appropriate people at the right time.
The means by which employees can report fraud are publicised on the Council’s intranet.
Fraud issues are widely communicated both internally and externally to provides a
deterrent to fraudsters by highlighting the Council’s commitment to identify fraud and take
proactive action to pursue fraudsters.
7) From a fraud and corruption perspective, what are considered by the Committee to be
high risk posts within the organisation? Please provide details.
 How are the risks relating to these posts identified, assessed and managed?
Response
Fraud and corruption, and associated risks, come in many forms and, consequently, it is
not easy to specifically identify specific posts where there are greater risks than others.
However there is a general recognition that there is an inherent risk of fraud within an
organisation like a Council and the risk of fraud is managed through existing controls and
procedures which are in place across the organisation.  The Committee takes assurance
from the work of internal audit, the established fraud policies in place and ongoing
embedding of a culture of fraud awareness through a programme of anti-fraud training and
the work of the Council’s fraud team. This helps ensure that issues identified as a result of
Internal Audit work or fraud investigations, result in recommendations to management to
address gaps in control to ensure that risks are properly mitigated to acceptable levels.
8) Is the Committee aware of any related party relationships or transactions that could
give rise to instances of fraud? Please provide details.
 How are the risks associated with fraud related to such relationships and transactions
mitigated?
Response
We are not aware of any related party relationships or transactions that could give rise to
instances of fraud.
Disclosure of significant related party relationships is required for both members and
officers in positions of influence.
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Appendix 1
9) Is the Committee aware of any entries made in the accounting records of the
organisation that it believes or suspects are false or intentionally misleading? Please
provide details.
 Are there particular balances where fraud is more likely to occur? Please provide
details.
 Is the Committee aware of any assets, liabilities or transactions that it believes were
improperly included or omitted from the accounts of the organisation? Please provide
details.
 Could a false accounting entry escape detection? If so, how?
 Are there any external fraud risk factors which are high risk of fraud? Please provide
details.
Response
We are not aware of any accounting entries which are suspected to be false or
intentionally misleading. Should management become aware of any suspect accounting
entries, these would be subject to immediate investigation through Internal Audit.
We are not aware of any assets, liabilities or transactions that have been improperly
included or omitted from the Council’s accounts. Should any issues arise it is expected
that these would be identified through review and approvals processes.
The Council is a complex multidisciplinary organisation so there is a risk that management
is unaware of any potential false accounting occurring however this is unlikely given the
controls in place for processing transactions. An added control in this area is the review by
the external audit team who provide added assurance for transactions which are in excess
of the materiality value.
Current and emerging risks are identified from a number of sources including the National
Anti-Fraud Network (NAFN) and other law enforcement agencies. These are disseminated
to relevant Council teams to raise awareness.
10) Is the Committee aware of any organisational, or management pressure to meet
financial or operating targets? Please provide details.
 Is the Committee aware of any inappropriate organisational or management pressure
being applied, or incentives offered, to you or colleagues to meet financial or operating
targets? Please provide details.
Response
The Committee understands that the Council has financial and operating targets to meet
and these are progressed through normal management arrangements. However we are
not aware of any inappropriate organisational or management pressure to meet financial
or operating targets and there is no evidence of any incentive ever being offered to do so..
Monthly budget monitoring is conducted with Chief Officers and service managers and
reconciliations of key balances are conducted monthly, and significant variances are
investigated.  There is regular reporting on Budgetary Control to relevant committees.
International Standard for Auditing 250 – Consideration of laws and regulations in
an audit of financial statements
11) How does the Committee gain assurance that all relevant laws and regulations have
been complied with. For example:
 Is the Committee aware of the process management has in place for identifying and
responding to changes in laws and regulations? Please provide details.
 What arrangements are in place for the Committee to oversee this process?
 Is the Committee aware of the arrangements management have in place, for
communicating with employees, non-executive directors, partners and stakeholders
regarding the relevant laws and regulations that need to be followed? Please provide
details.
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Appendix 1
 Does the Committee have knowledge of actual or suspected instances where
appropriate laws and regulations have not been complied with, and if so is it aware of
what actions management is taking to address it? Please provide details.
Response
The Council is subject to a range of legal and regulatory frameworks. The Council has a
Local Code of Good Governance and has appointed a Monitoring Officer (Chief Officer
Regulatory and Regeneration) to ensure that the Council acts lawfully.  All committee
reports are subject to legal review and comment to ensure key issues are identified.
The Council’s Chief Officer Regulatory and Regeneration is a member of the Senior
Management Team and is sighted on any new strategic projects or initiatives with the
Council’s Legal Services having specialist officers who provide legal advice and support to
particular service areas.
As required, training is provided to officers on particular legal issues, some of it being
mandatory, for example around data protection and equalities.
Accepting that there will be minor operational instances of non-compliance, we are not
aware of any instances of significant non-compliance during the financial year.  This is
supported by the annual review of the Local Code of Good Governance.
International Standard for Auditing 501 – Specific consideration of the potential for,
and actual, litigation and claims affecting the financial statements
12) Is the Committee aware of any actual or potential litigation or claims that would affect
the financial statements? Please provide details.
Response
The Council’s financial statements disclose contingent liabilities and any provisions for
legal claims.  The Council’s s95 Officer engages with members of the Council’s Senior
Management Team, including the Chief officer Regulatory and Regeneration Service
(Council’s Monitoring Officer) as part of the annual accounts preparation process to
identify any ongoing or potential cases which require disclosure in the financial
statements. 
International Standard for Auditing 570 – Consideration of the going concern
assumption in an audit of financial statements
13) How has the Committee assessed and satisfied itself that it is appropriate to adopt the
going concern basis in preparing the financial statements?
Response
Going concern has been assessed as part of Council’s budget setting process in March
2025. The budget setting process requires the Council’s s95 Officer (Chief Officer -
Resources) to provide a view on the robustness of estimates and the adequacy of
reserves.
No issues in relation to going concern were highlighted as part of the report presented to
the Council in October 2025.
14) Has the Committee identified any events or conditions since the assessment was
undertaken which may cast significant doubt on the organisation’s ability to continue as a
going concern? Please provide details.
Response
The Council agreed a balanced 2025/26 budget on 5 March 2025 and that report
presented future budget gaps that will need to be closed in subsequent years.  This is
consistent with all Scottish local authorities and reflects the financial climate local
authorities are operating in with ongoing real terms funding reductions.  The Council
delivers a number of non-statutory services which, if required could be reduced or stopped
in the event that insufficient funding is made available.  Therefore, whilst the Council does
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Appendix 1
have future budget gaps, there are viable options available to close the gap meaning there
is not a risk to the Council’s ability to continue as a going concern.
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Item 12
Appendix 2
International Standard for Auditing 240 - The auditor’s responsibility to consider
fraud in an audit of financial statements
1) How do the Trustee’s, in their role as those charged with governance, exercise
oversight of management's processes in relation to:
 undertaking an assessment of the risk that the financial statements may be materially
misstated due to fraud or error (including the nature, extent and frequency of these
assessments);
 identifying and responding to risks of fraud in the organisation, including any specific
risks of fraud which management have identified or that have been brought to its
attention, or classes of transactions, account balances, or disclosure for which a risk of
fraud is likely to exist;
 communicating to employees of views on business practice and ethical behaviour (for
example by updating, communicating and monitoring against the organisation’s code
of conduct); and
 communicating to those charged with governance the processes for identifying and
responding to fraud or error?
Response
The Annual Governance Statement within West Dunbartonshire Council’s (WDC) annual
financial statements contains a review of the adequacy and effectiveness of the
governance framework including the system of internal control. These systems are
periodically reviewed and tested by internal audit, and our external auditors. Consequently
although the material misstatement cannot be ruled out, its likelihood is low.
All financial transactions relating to the delivery of the Trusts are hosted within the WDC
ledger, therefore the Trusts rely on the processes and controls implemented by WDC
including approval and authorisation processes, defined limits for all authorised
signatories and adherence to WDC Financial Regulations. The financial statements reflect
the transactions which have been processed by the WDC financial system.
The Trust’s financial statements are prepared by experienced and professionally qualified
accountants who are regulated by the standards of their respective institutes. 
The WDC Chief Internal Auditor provides regular reports to the Audit Committee which
include information on control issues identified within the partner organisations and any
potential impact on the Trusts.
If the Trustees became aware of any fraud or suspected fraud then appropriate reporting
processes would be followed e.g. the Chief officer - resources would be notified in
conjunction with reporting to Internal Audit, Fraud Liaison Officer or Legal teams for cases
involving suspected data breaches.
Through the Code of Conduct for Staff, all WDC employed staff are obliged to comply with
the partner’s Corporate Governance documentation, which includes the responsibilities of
managers and other staff arising from the Financial Regulations, SFIs and Fraud Policies
– all available on WDC websites and intranet
2) How does the Trust oversee management processes to identify and respond to the risk
of fraud and possible breaches of internal control? Is the Trust aware of any breaches of
internal control during 2024/25? Please provide details.
Response
It is the responsibility of management to develop and maintain sound systems of risk
management, governance and internal control. This includes the requirement to identify
and respond to any identified breaches of internal control. 
However it is noted that internal control systems, no matter how well designed and
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Appendix 2
operated, are affected by inherent limitations. These include the possibility of poor
judgement in decision making; human error; control processes being deliberately
circumvented by employees and others; management overriding controls and
unforeseeable circumstances.
In terms of oversight, the Council’s Internal Audit function plays a key role in this
regard. Internal Audit work is not a substitute for management’s responsibilities for
the design and operation of these systems, and is not responsible for identifying all
significant control failures. 
Where deemed necessary the Audit Committee will ask that a relevant officer of the Trust
is present at Audit Committee meetings to respond to questions on a report being
presented.
3) Has the Trust knowledge of any actual, suspected or alleged fraud during the period 1
April 2024 – 31 March 2025? Where appropriate please provide details.
Response
There have been no suspected/alleged instances of fraud during 2024/25.
4) Has the Trust any suspicion that fraud may be occurring within the organisation?
Please provide details.
 Has the Trust identified any specific fraud risks within the organisation? Please
provide details.
 Does the Trust have any concerns that there are areas within the organisation that are
at risk of fraud? Please provide details.
 Are there particular locations within the organisation where fraud is more likely to
occur? Please provide details.
Response
As with any large and complex organisation there are a range of fraud risks and emphasis
on reducing fraud risk is continuous. The results of the NFI, internal audit work and
reported fraud show some low value frauds.
Management and the Audit Committee is kept up to date with fraud risks through updates
on counter fraud arrangements, Internal Audit and other ad hoc reports.
Fraud risks are acknowledged in key areas. Members and officers are aware of these and
the risks are managed through established risk management processes.
5) Is the Trust satisfied that internal controls, including segregation of duties, exist and
work effectively? Please provide details.
 If not, where are the risk areas?
 What other controls are in place to help prevent, deter or detect fraud?
Response
Key controls such as the segregation of duties, management review and
supervision and authorisation and approval are evident in each of WDC’s core
systems.  It is acknowledged that maintaining an effective control environment is
challenging in a time of reducing resources and a changing operating environment. For
this reason, internal audit will have a continued role in supporting the Council in ensuring
that an adequate but appropriate control environment is in place.
In overall terms, Internal Audit have concluded that reasonable assurance can be
provided on the Trust’s system of internal control for 2024/25.
6) Is the Trust satisfied that staff are encouraged to report their concerns about fraud, and
the types of concerns they are expected to report? Please provide details.
Response
The Council promotes a zero tolerance toward fraud and promotes a culture that enables
individuals to identify potential fraud and empowers them to report their concerns in a safe
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and secure manner to the appropriate people at the right time.
The means by which employees can report fraud are publicised on the Council’s intranet.
Fraud issues are widely communicated both internally and externally to provides a
deterrent to fraudsters by highlighting the Council’s commitment to identify fraud and take
proactive action to pursue fraudsters.
7) From a fraud and corruption perspective, what are considered by the Trust to be high
risk posts within the organisation? Please provide details.
 How are the risks relating to these posts identified, assessed and managed?
Response
Fraud and corruption, and associated risks, come in many forms and, consequently, it is
not easy to specifically identify specific posts where there are greater risks than others.
However there is a general recognition that there is an inherent risk of fraud within an
organisation like a Council and partner organisations the risk of fraud is managed through
existing controls and procedures which are in place across the organisation.  The Trust
takes assurance from the work of internal audit, the established fraud policies in place and
ongoing embedding of a culture of fraud awareness through a programme of anti-fraud
training and the work of the Council’s fraud team. This helps ensure that issues identified
as a result of Internal Audit work or fraud investigations, result in recommendations to
management to address gaps in control to ensure that risks are properly mitigated to
acceptable levels.
8) Is the Trust aware of any related party relationships or transactions that could give rise
to instances of fraud? Please provide details.
 How are the risks associated with fraud related to such relationships and transactions
mitigated?
Response
We are not aware of any related party relationships or transactions that could give rise to
instances of fraud.
Disclosure of significant related party relationships is required for both members and
officers in positions of influence.
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9) Is the Trust aware of any entries made in the accounting records of the organisation
that it believes or suspects are false or intentionally misleading? Please provide details.
 Are there particular balances where fraud is more likely to occur? Please provide
details.
 Is the Trust aware of any assets, liabilities or transactions that it believes were
improperly included or omitted from the accounts of the organisation? Please provide
details.
 Could a false accounting entry escape detection? If so, how?
 Are there any external fraud risk factors which are high risk of fraud? Please provide
details.
Response
We are not aware of any accounting entries which are suspected to be false or
intentionally misleading. Should management become aware of any suspect accounting
entries, these would be subject to immediate investigation through Internal Audit.
We are not aware of any assets, liabilities or transactions that have been improperly
included or omitted from the Trust’s accounts. Should any issues arise it is expected that
these would be identified through review and approvals processes.
Current and emerging risks are identified from a number of sources including the National
Anti-Fraud Network (NAFN) and other law enforcement agencies. These are disseminated
to relevant teams to raise awareness.
10) Is the Trust aware of any organisational, or management pressure to meet financial or
operating targets? Please provide details.
 Is the Trust aware of any inappropriate organisational or management pressure being
applied, or incentives offered, to you or colleagues to meet financial or operating
targets? Please provide details.
Response
The Trustees are not aware of any inappropriate organisational or management pressure
to meet financial or operating targets and there is no evidence of any incentive ever being
offered to do so.
International Standard for Auditing 250 – Consideration of laws and regulations in
an audit of financial statements
11) How does the Trust gain assurance that all relevant laws and regulations have been
complied with. For example:
 Is the Trust aware of the process management has in place for identifying and
responding to changes in laws and regulations? Please provide details.
 What arrangements are in place for the Trust to oversee this process?
 Is the Trust aware of the arrangements management have in place, for communicating
with employees, non-executive directors, partners and stakeholders regarding the
relevant laws and regulations that need to be followed? Please provide details.
 Does the Trust have knowledge of actual or suspected instances where appropriate
laws and regulations have not been complied with, and if so is it aware of what actions
management is taking to address it? Please provide details.
Response
WDC is subject to a range of legal and regulatory frameworks. The Council has a Local
Code of Good Governance and has appointed a Monitoring Officer (Chief Officer
Regulatory and Regeneration) to ensure that the Council acts lawfully.  All Trustee reports
are subject to legal review and comment to ensure key issues are identified.
The Council’s Chief Officer Regulatory and Regeneration is a member of the Senior
Management Team and is sighted on any new strategic projects or initiatives with the
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Council’s Legal Services having specialist officers who provide legal advice and support to
particular service areas.
As required, training is provided to officers on particular legal issues, some of it being
mandatory, for example around data protection and equalities.
Accepting that there will be minor operational instances of non-compliance, we are not
aware of any instances of significant non-compliance during the financial year.  This is
supported by the annual review of the Local Code of Good Governance.
International Standard for Auditing 501 – Specific consideration of the potential for,
and actual, litigation and claims affecting the financial statements
12) Is the Trust aware of any actual or potential litigation or claims that would affect the
financial statements? Please provide details.
Response
Given the size and the nature of the transactions of the Trust there are no known
litigations or claims that would affect the financial statements.
International Standard for Auditing 570 – Consideration of the going concern
assumption in an audit of financial statements
13) How has the Trust assessed and satisfied itself that it is appropriate to adopt the going
concern basis in preparing the financial statements?
Response
No issues in relation to going concern were highlighted to the Trustees.
14) Has the Trust identified any events or conditions since the assessment was
undertaken which may cast significant doubt on the organisation’s ability to continue as a
going concern? Please provide details.
Response
The Trustees are not aware of any events or concerns since the assessment was
undertaken that would cast doubt on the Trusts ability to continue as a going concern.
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