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West Dunbartonshire Council · 15 June 2022
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Agenda
Audit Committee
Date: Wednesday, 15 June 2022
___________________________________________________________________
Time: 10:00
___________________________________________________________________
Format: Hybrid
___________________________________________________________________
Contact:    Ashley MacIntyre, Committee Officer
ashley.macintyre@west-dunbarton.gov.uk
Dear Member
Please attend a meeting of the Audit Committee as detailed above.
The Convener has directed that the powers contained in Section 43 of the Local
Government in Scotland Act 2003 will be used and Members will have the option to
attend the meeting remotely or in person at the Civic Space, Church Street,
Dumbarton.
Yours faithfully
JOYCE WHITE
Chief Executive
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Distribution:
Councillor Karen Conaghan (Chair)
Councillor Ian Dickson 
Councillor Craig Edward 
Councillor Jonathan McColl (Vice Chair)  
Councillor James McElhill
Councillor Michelle McGinty
Councillor John Millar
Councillor Martin Rooney
Mr C Johnstone
All other Councillors for information
Chief Executive
Chief Officers
Date of issue: 1 June 2022
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AUDIT COMMITTEE
WEDNESDAY, 15 JUNE 2022
AGENDA
1 STATEMENT BY CHAIR
2 APOLOGIES
3 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.
4 RECORDING OF VOTES
The Committee is asked to agree that all votes taken during the meeting be
done by roll call vote to ensure an accurate record.
5 OPEN FORUM
The Committee is asked to note that no open forum questions have been
submitted by members of the public.
6 ANNUAL REPORT ON THE AUDIT COMMITTEE 7 - 11
Submit report by the Chief Officer – Resources providing the Audit Committee
Chair’s 2021/22 Annual Report on the Audit Committee.
7 INTERNAL AUDIT PLANS 2020/21 AND 2021/22 - 13 - 30
PROGRESS TO 15 JUNE 2022 
Submit report by the Chief Officer – Resources advising of progress at 31
May 2022 against the Internal Audit Plans for 2020/21 and 2021/22.  
8/
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8 INTERNAL AUDIT ANNUAL REPORT TO 31 MARCH 2022  31 - 45
Submit report by the Chief Officer – Resources advising of the work
undertaken by Internal Audit in respect of the 2021/22 Annual Audit Plan and
advising of the contents of the Assurance Statement given to Members of
West Dunbartonshire Council, the Chief Executive and the Section 95 Officer
(Chief Officer - Resources) in support of the Annual Governance Statement.
9 2022/23 INTERNAL AUDIT PLAN 47 - 55
Submit report by the Chief Officer – Resources advising of the planned
programme of work for the Internal Audit Section for the year 2022/23.
10 CODE OF GOOD GOVERNANCE AND ANNUAL     To Follow
GOVERNANCE STATEMENT 2021-22
Submit report by the Chief Officer – Resources on the above.
11 AUDIT SCOTLAND MANAGEMENT LETTER: WEST 57 – 61
DUNBARTONSHIRE COUNCIL – INTERIM AUDIT TESTING
2021/22
Submit report by the Chief Officer – Resources advising of the Council’s
2021/22 midyear management letter issued by our external auditors, Audit
Scotland and the management actions agreed in relation to the issues
identified in the letter.
12 APPOINTMENT OF LAY MEMBERS     To Follow
Submit report by the Chief Officer – Resources providing an update on the
current status of Lay Member appointments to the Audit Committee.  
13 PRUDENTIAL INDICATORS 2021/22 TO 2031/32 AND 63 - 99
TREASURY MANAGEMENT STRATEGY 2022/23 TO 2031/32
Submit report by the Chief Officer – Resources providing the opportunity to
further scrutinise the Prudential Indicators for 2021/22 to 2031/32 and the
Treasury Management Strategy (including the Investment Strategy) for
2022/23 to 2031/32 and the indicative indicators for 2024/25 to
2030/31.
14/
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14 SCOTTISH PUBLIC SERVICES OMBUDSMAN            To Follow
COMPLAINTS REPORT 2020-21 
Submit report by the 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 2020 – 31
March 2021.
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer - Resources
Audit Committee: 15 June 2022
Subject:  Annual Report on the Audit Committee – 2021/22
1. Purpose
1.1 The purpose of this report is to provide members with the Audit Committee
Chair’s 2021/22 Annual Report on the Audit Committee.
2. Recommendations
2.1 It is recommended that members:
i) Review and endorse the Chair’s Annual Report on the Audit Committee for
2021/22.
ii) Agree that the report should be presented to a future meeting of the
Council in line with best practice guidance.
3. Background
3.1 It is important that the Committee fully complies with best practice guidance
on Audit Committees to ensure it can demonstrate its effectiveness as a
foundation for sound corporate governance for the Council. The Chartered
Institute of Public Finance and Accountancy (CIPFA) issued an updated
guidance note Audit Committees Practical Guidance for Local Authorities and
Police 2018 Edition which incorporates CIPFA’s Position Statement: Audit
Committees in Local Authorities and Police. This sets out CIPFA’s view of the
role and functions of an Audit Committee. The CIPFA Audit Committees
Guidance includes the production of an annual report on the performance of
the Audit Committee against its remit for submission to the Council.
3.2 The Audit Committee Chair’s 2021/22 Annual Report, attached  at Appendix
1, provides assurance to the Council over the activity of the Audit Committee.
4. Main Issues
4.1 The Audit Committee Chair’s 2021/22 Annual Report is appended with the
main issues identified being:
• The Audit Committee has met four times during the financial year with
every meeting being quorate.
• The Audit Committee sought assurance on the adequacy and
effectiveness of the Council’s systems of corporate governance and
internal control for efficient operations and for the highest standards of
probity and accountability.  This was achieved through reports received
ITEM 6
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from internal audit, other Council functions and external audit with focus in
particular on internal control and governance.
• The Audit Committee has provided assurance to the Council as detailed in
the appendix.
5. People Implications
5.1 There are no personnel issues with this report.
6. Financial and Procurement Implications
6.1 There are neither financial nor procurement implications arising directly
from this report.
7. Risk Analysis
7.1 There is a risk that the Audit Committee does not comply with best practice
guidance in relation to demonstrating its effectiveness in providing a
foundation for sound corporate governance.  The annual report provides this
assurance to the Council on the activity of the Committee.
8. Equalities Impact Assessment (EIA)
8.1 There is no requirement for an EIA.
9. Consultation
9.1 This report has been subject to consultation with appropriate Strategic Leads.
In addition, services have been consulted in the update of action plans.
10. Strategic Assessment
10.1 This report relates to strong corporate governance.
....................................
Laurence Slavin
Chief Officer - Resources
Date: 15 June 2022
______________________________________________________________
Person to Contact: Andi Priestman, Shared Service Manager – Audit & Fraud
Telephone (01389) 737436
E-mail: andi.priestman@west-dunbarton.gov.uk
Appendix: Annual Report on the Audit Committee 2021/22
Background Papers: N/A
Wards Affected: All Wards
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West Dunbartonshire Council
Audit Committee
2021/22 Annual Report from the Chair
Introduction
This annual report has been prepared to inform West Dunbartonshire Council of the
work carried out by the Council’s Audit Committee during the financial year 2021/22.
Meetings
The Audit Committee met four times during 2021/22 comprising meetings on 16
June 2021, 15 September 2021, 17 November 2021 and 2 March 2022 to consider
reports relevant to the Audit cycle and other matters as deemed appropriate.  Pre-
Agenda meetings were also held ahead of Committee involving the Chair and
appropriate officers.  All four meetings were held remotely via Zoom and audio
recordings of meetings are available on the Council’s website.
The purpose and remit of Audit Committee as detailed in the Council’s Standing
Orders is to:
• Monitor, and make recommendations on the development of the Audit activity of
the Council.
• Scrutinise the monitoring and review activity of the thematic and regulatory
committees.
To fulfil this remit, the Audit Committee sought assurance on the adequacy and
effectiveness of the Council’s systems of governance, risk management and internal
control to ensure efficient operations and the highest standards of probity and
accountability.  This was achieved through reports received from Internal Audit, other
Council functions and External Audit with focus in particular on internal control and
governance.
At each meeting of the Audit Committee it considered significant findings from
Internal Audit reports together with monitoring the progress made by management in
completing agreed actions to improve the Council’s control environment.  It also
considered the annual audit plan and reports from Audit Scotland, the Council’s
External Auditors.  In addition, a number of national reports prepared by Audit
Scotland on behalf of the Accounts Commission were also considered.  
The Audit Committee also received reports on:
• Prudential Indicators and Treasury Management.
• Risk Management.
• National Fraud Initiative.
The minutes of Audit Committee meetings are first confirmed as a correct record at
the next Audit Committee before being remitted to Council for approval. 
Appendix 1
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Membership of the Audit Committee
In accordance with West Dunbartonshire Council’s Standing Orders membership of
the Audit Committee comprises eight Elected Members and two Lay Members with
Lay Members not being members of any political party.  The quorum of the Audit
Committee is three Elected Members.  
The Chair of the Audit Committee is from the Opposition (as is the Vice Chair).  The
committee has two Lay Members.  The Administration has a minority of members on
the Audit Committee.  One Lay Member, Christopher Todd, has tendered his
resignation from the Audit Committee and I wish to thank him for his service.  
Attendance by members of the Committee at Audit Committee meetings in 2021/22
was as follows:
Member Date of Meeting
16/06/21 15/09/21 17/11/21 2/03/22
Cllr John Mooney
(Chair)
Present Present Present Present
Cllr Jim Brown Present Present Present Present
Cllr Karen Conaghan Present Present Present Present
Cllr Daniel Lennie Apologies Present Present Present
Cllr Jonathan McColl Present Present Present Present
Cllr John Millar Apologies Present Present Apologies
Cllr Martin Rooney Present Present Present Present
Cllr Brian Walker  Apologies Absent Apologies Present
Lay Member Chris
Johnstone (from
12/12/18) 
Present Apologies Present Present
Lay Member
Christopher Todd
(from 16/09/20)
Apologies Present Present Present
Every meeting of the Audit Committee during 2021/22 was quorate.
Attendance by Officers
All meetings were attended by the Chief Executive, Chief Officer – Resources and
the Shared Service Manager - Audit & Fraud.
Other senior officers also attended meetings as appropriate for items on the Agenda
for which their presence was relevant. Representatives from the Council’s external
auditors - Audit Scotland - were present at every meeting.
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Assurance Statement to the Council
The Audit Committee provides the following assurance to the Council:
• The Council has received the Minutes of the Audit Committee meetings
throughout the year.
• The Audit Committee has operated in accordance with its agreed terms of
reference, and accordingly with the audit committee principles in the CIPFA
Position Statement relating to its Audit functions.
• It did this through reports received from Internal Audit, External Audit, and
assurances from Management. It focussed on matters of governance, risk
management and internal control; giving advice to the Council on the value of the
audit process; on the integrity of financial reporting; and on governance
arrangements.
• For all audit reports, the Audit Committee considered whether it was satisfied that
an adequate management response was in place to ensure action would be
taken to manage risk and address concerns on governance, risk management
and internal control arrangements. The Committee acknowledges that all the
audit recommendations are input to Pentana, the Council’s performance
management system, and that there is a system in place of ongoing follow-up by
Internal Audit and reporting thereon.
• The Audit Committee has received and considered material to fulfil its scrutiny
role on treasury management activity.
• The Audit Committee reviewed the audited Annual Accounts for 2020/21
alongside External Audit’s report on their annual audit for 2020/21.
Conclusion 
Based on the reports received and reviewed by the Committee they are in
agreement with the Shared Service Manager – Audit & Fraud’s annual audit report
which confirms that reasonable assurance can be placed upon the adequacy and
effectiveness of the Council’s internal control system in 2021/22. I am satisfied that
active monitoring and follow up of recommendations is in place in respect of agreed
management action. 
Councillor Conaghan    
Chair of the Audit Committee
15 June 2022
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer – Resources
Audit Committee: 15 June 2022
Subject: Internal Audit Plans 2020/21 and 2021/22 – Progress to 15 June 2022
1. Purpose
1.1 The purpose of this report is to advise Members of progress at 31 May 2022
against the Internal Audit Plans for 2020/21 and 2021/22.
1.2 The report also advises Members of:
• Recently issued Internal Audit reports and action plans; and
• 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 plans for 2020/21 and 2021/22 were approved by the Audit
Committee on 17 June 2020 and 10 March 2021 respectively.  This report
provides information on the progress in implementing the plans.
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
regularly 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 A new risk-based audit methodology was implemented during 2020/21.  For each
audit, one of 4 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 7
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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 Two audit reviews have been finalised since the Audit Committee meeting in March
2022 as follows:
• Employee Expenses
• Procurement Under £50,000
Employee Expenses
4.5 Employees who use their own vehicle to carry out essential Council business in the
course of their work are entitled to claim, and will be reimbursed, expenses subject
to appropriate approval by a nominated Authorising Officer. In the main, claims for
reimbursement are made through the HR21 self-service system, paper based forms
are only used by employees who do not have access to HR21. For the test period
of November 2020 to November 2021 the total mileage claimed was 560,866 miles
with a total cost of £251,294. It was identified by the Sustainability Officer that from
2019/20 to 2020/21 there was a reduction of approximately £197,881 in employee
mileage due to home working.
4.6 The objective of this audit was to provide management and the Audit Committee
with an assessment of the adequacy and effectiveness of the governance, risk
management and controls over the key risks faced by West Dunbartonshire Council
in relation to Employee Expenses.
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4.7 The audit approach was planned to fall in line with the agreed Terms of Reference
and included:
• Review and analysis of expenses processed through HR21 for the period
November 2020 to November 2021.
• Issue and analysis of internal control questionnaires in order to confirm that
controls and procedures were being followed within services including vehicle
documentation checks, targeting service areas with high mileage claims.
• Discussions with authorising officers where required.
• Audit testing of employee claims processed to confirm that controls and
procedures were being followed and highlight where controls were weak. The
audit did not include the review of expense claims for Care at Home employees
made via CM2000 which will be subject to a separate audit review.
4.8 The overall control environment opinion was Satisfactory.  In terms of good
practice, through discussion with the Sustainability Officer it was identified that from
2019/20 to 2020/21 there was a reduction of approximately £197,881 in employee
mileage.  However, three amber issues were identified as follows:
Lack of Co-ordination and Management of Pool Vehicles (Amber)
The list of pool vehicle users for vehicles managed by the Transport Section has
not been reviewed and updated since 2019. In addition, cost savings analysis has
not been undertaken for 2020/21.
Failure to maintain up to date records and carry out cost saving analysis and
reporting of this could result in employees continuing to use their own vehicle
resulting in additional expenditure to the Council where employee expenses are
paid.
Non Compliance with Pool Car Guidance (Amber)
The audit review identified that 30% of employees recorded on the list of Pool Car
Users had used their own personal vehicle claiming a total of 15,132 miles at a
cost of £6,810 during the period November 2020 to November 2021. Pool Car
Users should only claim mileage in emergency or exceptional circumstances.
Failure to adhere to the pool car guidance does not represent best value in terms
of loss of financial benefit to the Council where employees continue to claim
mileage but have been also been allocated a pool vehicle.
Identification of High Levels of Claims by Teams & Individuals for
Recommendation of Pool Car Use (Amber)
The audit review identified that there are specific teams of employees that are
claiming high levels of mileage.  In addition, data is not currently being obtained
and analysed to identify such teams or individuals where high mileage is being
claimed.
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The high mileage claims in private vehicles of some teams and individuals within
the Council does not represent value for money and the Council is incurring
additional costs where a pool car is a viable alternative.  In addition, the high
mileage incurred does not positively contribute to the Council’s Climate Change
Strategy.
4.9 The audit identified six issues, three of which we consider to be individually
significant and an action plan is in place to address all issues by 31 October 2022.
Procurement – Under £50,000
4.10 Specific Guidance is in place to ensure all of the Council’s procurement of goods
and services under £50,000 is undertaken in accordance with the Council’s
Financial Regulations and Standing Orders.  Quick Quote is an online quotation
facility hosted on Public Contracts Scotland, which is expected to be used for all
Council procurement from £10,000 to £49,999. 
4.11 The objective of this audit was to provide management and the Audit Committee
with an assessment of the adequacy and effectiveness of the governance, risk
management and controls surrounding the key risks in relation to the use of Quick
Quote by Services for procurement under £50,000.
4.12 The audit approach was planned to fall in line with the agreed Terms of Reference
and included:
• Control Risk Self-Assessment exercise and discussions with management and
staff within the Corporate Procurement Unit (CPU) with the particular aim of
identifying and agreeing risk areas.
• Examination and evaluation of appropriate documentation, including guidance,
reports, procedures and system manuals.
• Audit testing, particularly walkthrough tests, to confirm that controls and
procedures were being followed and highlight where controls were weak.
4.13 The overall control environment opinion was Satisfactory.  We were pleased to
note as examples of good practice the current controls in place resulting in the
Council’s procurement spend compliance being above 97% and the comprehensive
guidance available on the intranet for staff for Procurement Below £50k.  However,
two amber issues were identified as follows:
Fraud Awareness Training (Amber)
There is no mandatory Council wide Fraud Awareness training for staff in relation to
procurement. Fraud training is covered more generally at induction however this
has not taken place since March 2020.  A new Fraud Awareness E-learning is
being developed and is expected to be in place by 30 June 2022.
Data Protection Issue (Amber)
The audit identified six supplier invoices where details included full names or
surnames and an initial which were available to view by any officer with access to
Agresso. Under GDPR and Data Protection Act 2018, names are regarded as
personal data and should not be processed at this level.  
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4.14 The audit identified five issues, two of which we consider to be individually
significant and an action plan is in place to address all issues identified by 30 June
2022.
4.15 The 2021/22 Annual Audit Plan is underway and current status is as follows:
Stage Number of Audits
Final Report 2
Draft Report 3
Fieldwork Complete 2
Fieldwork 0
Planning 0
Deferred to 22/23 4
B/f 20/21 Audits completed in 21/22 5
Total 16
4.16 Full delivery of the 2021/22 audit plan has been delayed due to unanticipated staff
turnover, staff absence and completion of 2020/21 audit plan.  The team is now
back to full complement and completion of the plan has regained momentum over
the last few months with a target completion date of June 2022.  As such, the audit
plan for 2022/23 is also on the agenda for the June 2022 Audit Committee to take
account of any carry forward required at that stage including the 4 audits which are
deferred.  These have been subject to a further risk assessment and will be
undertaken as part of the 2022/23 audit plan.
4.17 In relation to audit work for IJB, two planned audits are being finalised and reports
will be provided to management and reported to HSCP Board Audit and
Performance Committee. 
4.18 In relation to the Valuation Joint Board, fieldwork for the planned audit is almost
complete.
4.19 In relation to the Leisure Trust, one planned audit has been finalised.
4.20 Internal and External Audit Action Plans
In relation to audit action plans, these are monitored by Internal Audit on a monthly
basis.  There were two actions due for completion by the end of April, one of which
have been implemented and the completion date in relation to the other action has
been revised.  
Work is ongoing with services to ensure action plan dates agreed are realistic.  The
status report at 30 April 2022 is provided at Appendix 2.
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Ongoing Corporate Fraud Team Work
4.21 From 1 April 2022 to 31 March 2022, the Corporate Fraud team’s day to day work
has resulted in actual recoveries, charges and re-billings as detailed below, against
an annual target of £250,000.  
Description Amount (£)
Council Tax Reduction 46,205
Council Tax Single Person’s Discount 23,365
National Fraud Initiative (HB) 5,731
National Fraud Initiative (CT/CTR) 18,682
National Fraud Initiative (SBBS) 57,278
J/W Housing Benefit/Council Tax Reduction 0
Non DWP Housing Benefit 127,302
Non DWP Council Tax Reduction 420
SBBS Fraud 5,900
Administrative Penalty 1,260
Total £284,883
4.22 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.
National Fraud Initiative
4.23 The National Fraud Initiative (NFI) 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 timescale and report back on any savings.
4.24 The most recent biennial exercise for 2020/21 released data to councils in January
2021 providing matched datasets for organisations to investigate.  There is an
expectation that organisations would examine all “High Risk” matches and a
proportion of the other matches too.  WDC applies a risk-based approach to the NFI
matches in the medium and low risk categories.  
4.26 Audit Scotland are preparing a report on the outcomes relating to the 2020/21
exercise and this will be presented to the next meeting of the Audit Committee in
September 2022.
Benchmarking
4.27 In accordance with the Council’s Strategic Improvement Framework, services
should undertake benchmarking activity with the equivalent function in other
Councils.  Therefore, WDC Internal Audit has entered into a benchmarking
group which involves seven other Councils, these being:
• Argyll and Bute;
• Clackmannanshire;
• East Dunbartonshire;
• Falkirk;
• West Lothian;
• Inverclyde; and
• Stirling.
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4.28 Regular meetings will continue to take place during 2022 to review performance
against agreed performance indicators and identify other areas for sharing of
best practice.  Relevant action will be taken where improvements are identified. 
The outcome of this review will be reported to Committee when completed.  
5. People Implications
5.1 There are no people implications.
6. Financial and Procurement Implications
6.1 As a result of Corporate Fraud Team activity, actual recoveries, charges and re-
billings of £284,883 from 1 April 2021 to 31 March 2022 have been identified,
against an annual target of £250,000.
6.2 There are no procurement implications arising from this report.
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 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 strong corporate governance.
....................................
Laurence Slavin
Chief Officer - Resources
Date: 15 June 2022
Person to Contact: Andi Priestman, Shared Service Manager – Audit & Fraud
E-mail: andi.priestman@west-dunbarton.gov.uk
Appendices: 2021/22 Annual Audit Plan – Progress to 18 May 2022
(Appendix 1)
Status of Internal Audit Action Plans at 30 April 2022 (Appendix
2)
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Background Papers: Audit Committee – 10 March 2021: Internal Audit Annual
Plan 2021/22
Audit Committee – 21 March 2018: Counter Fraud and
Corruption Strategy
Internal Audit Reports - Copies available on request
Wards Affected: All wards
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2021-2022 Internal Audit Annual Audit Plan – Progress to 18 May 2022
Appendix 1
Audit/Status Not
Started
Planning/
TOR
Fieldwork Fieldwork
Complete
Draft
Report
Final
Report
Date Reported to
Audit Committee
Risk –Based Reviews
IHMS – Stock Control      March 2022
LD Services – Financial Monitoring of Contracts  C/f to 2022/23 Audit Plan
Building Services – Work In Progress Advisory work was carried out with the Service on interim process during Q1 2022.  A full
review of this work will be included in the review of Building Services during 2022-23.  
Building Services – Price Checks Advisory work was carried out with the Service on interim process during Q1 2022.  A full
review of this work will be included in the review of Building Services during 2022-23.
OT Waiting Times  C/f to 2022/23 Audit Plan
Financial Assessment Process  C/f to 2022/23 Audit Plan
Corporate Procurement – Supplier Management   C/f to 2022/23 Audit Plan
Overtime   September 2022
Vehicle Tracking System    September 2022
Project Management Arrangements    September 2022
Employee Expenses      June 2022
Limited Scope Financial System Reviews
Debtors     September 2022
Other Work
Integration Joint Board – Internal Audit Service The IJB internal audit annual plan for 2021/22 was approved in April 2021.  Two audits are
currently being finalised and will be reported to the HSCP Board Audit and Performance
Committee.
Valuation Joint Board – Internal Audit Service The VJB internal audit annual plan for 2021/22 is now underway and fieldwork is almost
complete.
Leisure Trust – Internal Audit Service The LT internal audit annual plan for 2021/22 is now complete.
Covid-19 Recovery Assurance Work Ad hoc advice was provided on an ongoing basis.
National Fraud Initiative Matches for the 2020-21 exercise continue to be investigated.  Audit Scotland will produce a
report on the NFI 2020-21 Exercise which will be reported to the September 2022 meeting. 
B/f 2020/2021 Audit Plan Completion Five audit reports from the 2020/21 audit plan were finalised during 2021/22 including:  Rent
Arrears, Pupil Equity Funding, Homelessness, Client Accounts Administration Process and
Corporate Procurement – Under £50k.
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLANS
AT 30 APRIL 2022
Summary: Section 1 Summary of Management Actions due for
completion by 30/04/2022
There were 2 actions due for completion by 30 April 2022,
one of which has been reported as completed by
management and the completion date in relation to one
action has been revised.
Section 2 Summary of Current Management Actions Plans at
30/04/2022
At 30 April 2022 there were no audit reports delayed due
to management not finalising the action plan within
agreed timescales.
Section 3 Current Management Actions at 30/04/2022
At 30 April 2022 there were 10 current audit action
points.  
Section 4 Analysis of Missed Deadlines
At 30 April 2022 there were 2 audit action points where
the agreed deadline had been missed.
Section 5 Summary of Action Plan Points by Audit Year
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 30.04.2022
SECTION 1
Strategic Area
No. of
Actions
Due
No. of
Actions
Completed
Deadline
missed Revised
date set*
Deadline
missed
Revised date
to be set*
Supply, Distribution and
Property
1 0 1 0
Education, Learning and
Attainment
1 1 0 0
Total 2 1 1 0
* These actions are included in the Analysis of Missed Deadlines – Section 4
In addition one action with a completion date of 31 May has been completed ahead of the
deadline:
Agreed Action Update
171. Social Work - Case Management (Report Issued August 2020)
Children’s Services - Peer review of case
files (Medium Risk)
Management Team are reviewing peer review
processes as part of case file audit and
monitoring and how this can inform service
redesign. Work has commenced as part of the
PACE workstream in respect of children looked
after at home. Intention to scale up when
capacity is increased.
An audit framework has been developed across the children
and adult service with planned schooled audit activity
sampling 10 cases x4 times a year with clear reporting
governance. An 0.5 fte post has now been recruited to , in
order to progress independent audit activity within children’s
services.
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS 
SUMMARY OF CURRENT ACTION PLANS AT 30.04.2022
SECTION 2
CURRENT ACTIONS BY STRATEGIC AREA
Children’s Health Care and Criminal Justice
Due for completion May 2022 1
Total Actions 1
Regulatory and Regeneration
Due for completion May 2022 1
Total Actions 1
Housing and Employability
Due for completion May 2022 1
Due for completion September 2022 1
Total Actions 2
Supply, Distribution and Property
Due for completion August 2022 1
Due for completion December 2022 1
Due for completion March 2023 1
Total Actions 3
Resources
Due for completion June 2022 1
Total Actions 1
Roads and Neighbourhood
Due for completion October 2022 2
Total Actions 2
Total current actions: 10
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 30.04.2022
SECTION 3
Status Key
On track
Overdue – update required
Current Internal Audit Action Plans
173. Housing Voids ( Report Issued October 2020)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/079
The previous policy had fallen into abeyance, with the strategic direction for voids led by the
Housing Improvement Board. Whereas this has led to significant improvements against the key
tenets of the historic policy, given the extent of systemic and structural changes it would be
beneficial to codify this within a revised policy. This will be developed with new tenant feedback and
wider tenant consultation.
31-May-2021
28-Feb-2022 30-Sep-2022*
Housing
Operations
Manager
Chief Officer –
Housing and
Employability
IHMS Stores and Stock Management (Report issued January 2022)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/103
Lack of Stock Control Process for Direct Purchases of UPVC Units (Red)
Longer term Building Services will ensure just in time delivery of uPVC windows and door units
recommence in line with the Councils’ renewal programme. 01-Aug-2022 01-Aug-2022
Building
Services
Manager
Chief Officer –
Supply,
Distribution and
Property
IAAP/104
Lack of Stock Control Process for Direct Purchases of UPVC Units (Red)
An inventory of sizes/ types/hands/styles of uPVC windows and doors will be developed for inactive
orders. A plan will be put in place to install all units where feasible. Any unusable units will be dealt
within in line with the Council’s management of obsolete stock procedures.
31-Mar-2023 31-Mar-2023
Building
Services
Manager
Chief Officer –
Supply,
Distribution and
Property
IAAP/106
Full implementation of Minimum/Maximum Levels and automatic reordering of stock
items (Amber)
These actions form part of stores catalogue review which is ongoing and scheduled to be completed
early in the financial year 2022/2023.
30-Apr-2022 31-Dec-2022*
Building
Services
Manager
Chief Officer –
Supply,
Distribution and
Property
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 30.04.2022
SECTION 3
Status Key
On track
Overdue – update required
Employee Expenses (Report issued May 2022)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/109
Lack of Co-ordination and Management of Pool Vehicles (Amber)
A working group has been established to review pool car procedures which is being chaired by the
Chief Officer Shared Services Roads & Neighbourhood.
The CAS team will be responsible for maintaining pool vehicle records. A review is currently being
carried out of procedures to make this process more efficient.
Cost Savings Analysis will be carried on an annual basis and reported as appropriate.
01-Oct-2022 01-Oct-2022
Shared Fleet and
Waste Services
Manager
Chief Officer –
Roads and
Neighbourhood
IAAP/110
Non-Compliance with Pool Car Guidance (Amber)
Management will advise appropriate Line Managers that they should inform those employees who
have been identified as a pool car user that where possible that the employee only use a pool car
when carrying out Council Business and that they should not claim mileage except in emergency or
exceptional circumstances.
31-May-2022 31-May-2022
Building
Standards &
Environmental
Health Manager
Housing
Development &
Homelessness
Manager
Manager
Fieldwork
Services HSCP
Chief Officer –
Regulatory and
Regeneration
Chief Officer –
Housing and
Employability
Head of Children’s
Health Care and
Community Justice
IAAP/111
Identification of High Levels of Claims by Teams & Individuals for Recommendation of
Pool Car Use (Amber)
A working group has been established to review pool car procedures which is being chaired by the
Chief Officer Shared Services Roads & Neighbourhood.
A list of high mileage claimants has been collated and the working group will assess the users in
relation to allocation of pool cars and identify if additional vehicles are required.
01-Oct-2022 01-Oct-2022
Shared Fleet and
Waste Services
Manager
Chief Officer –
Roads and
Neighbourhood
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLAN POINTS
CURRENT ACTION PLANS AT 30.04.2022
SECTION 3
Status Key
On track
Overdue – update required
Procurement Under £50k (Report issued May 2022)
Code Agreed Action Status Original Due
Date Due Date Assigned To Managed By
IAAP/122
Fraud Awareness Training (Amber)
Management will develop and implement an on-line fraud awareness module to include procurement
as a fraud risk area. This will be done in conjunction with the Organisational Development team and
launched in line with their overall timescales.
30-June-2022 30-June-2022
Shared Service
Manager – Audit
& Fraud
Chief Officer -
Resources
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLANS
ANALYSIS OF MISSED DEADLINES SECTION 4
Report Agreed Action Original Due
Date
Revised Date Management Comments
Housing Voids (October
2020)
Void Management Policy Review &
Update (Medium Risk)
The previous policy had fallen into abeyance,
with the strategic direction for voids led by
the Housing Improvement Board. Whereas
this has led to significant improvements
against the key tenets of the historic policy,
given the extent of systemic and structural
changes it would be beneficial to codify this
within a revised policy. This will be developed
with new tenant feedback and wider tenant
consultation.
31-May-2021
28-Feb-2022
30-Sep-2022 Progress on this action has been significantly impacted due to Covid
and was not able to be completed by original deadline.  However, the
review of the void processes, including revision of the void re-let
standard and development of a void policy has been discussed at the
Housing Improvement Board and Building Services Board and it was
agreed that a focused void working group would be established to
take this work forward and representation consists of a range of
colleagues from Housing Operations, Building Services and Housing
Development.  The working group is now up and running and will
focus on a range of aspects for the void process and progress the
work in relation to the audit action.
IHMS Stores and Stock
Management (January
2022)
Full implementation of
Minimum/Maximum Levels and
automatic reordering of stock items
(Amber)
These actions form part of stores catalogue
review which is ongoing and scheduled to be
completed early in the financial year
2022/2023.
30-Apr-2022 31-Dec-2022 The review of stock catalogue is continuing and progress has been
impacted due to staff shortages and other priorities. Minimum and
maximum stock levels have been updated within each store and
automatic reordering will be implemented when the work on the
stock catalogue has been completed.
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REPORT TO AUDIT COMMITTEE ON
STATUS OF INTERNAL AUDIT ACTION PLANS
SUMMARY OF ACTIONS BY AUDIT YEAR SECTION 5
Status at 30 April 2022
Audit Year No of Agreed
Actions
No of actions
complete
Current actions by
Grade
H M L
2018/2019 79 79 0 0 0
2019/2020 67 67 0 0 0
Total 146 146 0 0 0
Audit Year No of Agreed
Actions
No of actions
complete
Current actions by Grade
Red Amber Green*
2020/2021 25 17 0 1 7
2021/2022 31 10 2 7 12
Total 56 27 2 8 19
* Green actions are within the Council’s risk appetite and are therefore not included in
Audit Committee reports.
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer – Resources
Audit Committee: 15 June 2022
Subject: Internal Audit Annual Report to 31 March 2022
1. Purpose
1.1 The purpose of this report is to advise Members of the work undertaken by
Internal Audit in respect of the 2021/22 Annual Audit Plan and to advise
Members of the contents of the Assurance Statement given to Members of
West Dunbartonshire Council, the Chief Executive and the Section 95
Officer (Chief Officer - Resources) in support of the Annual Governance
Statement. This report outlines how audit assurances are obtained.
2. Recommendations
2.1 It is recommended that Members note the contents of this report.
3. Background
3.1 The Public Sector Internal Audit Standards (PSIAS) became effective on
1st April 2013 (revised in 2017) and require that:
“The chief audit executive [WDC: Shared Service Manager Audit & Fraud]
must deliver an annual internal audit opinion and report that can be used
by the organisation to inform its governance statement.
The annual internal audit opinion must conclude on the overall adequacy
and effectiveness of the organisation’s framework of governance, risk
management and control.
The annual report must incorporate:
• The opinion;
• A summary of the work that supports the opinion; and
• A statement on conformance with the Public Sector Internal Audit
Standards and the results of the quality assurance and improvement
programme”.
3.2 Progress reports were provided to the Audit Committee at each meeting
during 2021/22 on Internal Audit activity and progress against the annual
audit plan.
ITEM 8
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4. Main Issues
4.1 During 2020/21 Internal Audit implemented a new risk-based audit
methodology which means that for each audit, one of the following 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.  
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.
4.2 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 manager. 
Not reported in Audit Committee papers.
4.3 The status of the Audit Plan for 2021/22 is set out at Appendix 1.  Completion
of the audit plan was hampered by staff illness and unforeseen vacancies
arising during 2020/21 which took some time to fill during 2021/22.  There are
a number of audits at fieldwork stage and it is anticipated that these will be
completed by end of June 2022.  There are no significant issues arising
through audit work to date which would impact on the overall audit opinion
within the 2021/22 Annual Report and Assurance Statement.
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4.4 The 2021/22 Internal Audit Annual Report and Assurance Statement is set
out at Appendix 2.   There are four overall Audit Opinion types as follows: 
Satisfactory Controls evaluated are adequate, appropriate and effective
to provide reasonable assurance that risks are being
managed and objectives should be met. 
• A limited number of amber rated issues may have been
identified, but generally only green issues have been
found in individual audit assignments.
• None of the individual assignment reports have an
overall opinion of Requires Improvement or
Unsatisfactory. 
Generally
Satisfactory
with some
improvement
needed
A few specific control weaknesses were noted: generally
however, controls evaluated are adequate, appropriate and
effective to provide reasonable assurance that risks are
being managed and objectives should be met. 
• A number of amber rated issues identified in individual
audit assignments that collectively do not significantly
impact the system of internal control.
• Red rated issues that are isolated to specific systems or
processes.
• None of the individual assignment reports have an
overall opinion of Unsatisfactory.
Major
improvement
needed
Numerous specific control weaknesses were noted. 
Controls evaluated are unlikely to provide reasonable
assurance that risks are being managed and objectives
should be met. 
• A high number of amber rated issues that collectively
have a significant impact on some parts of the system
of internal control but are not widespread.
• A number of red rated issues that collectively have a
significant impact on some parts of the system of
internal control but are not widespread.
• A small number of individual assignment reports have
an overall opinion of Requires Improvement or
Unsatisfactory.
Unsatisfactory Controls evaluated are not adequate, appropriate or
effective to provide reasonable assurance that risks are
being managed and objectives should be met. 
• Amber and red rated issues identified in individual
assignments that collectively are widespread to the
system of internal control.
• A high number of individual assignment reports have an
overall opinion of Requires Improvement or
Unsatisfactory.
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4.5 On the basis of Internal Audit work performed in 2021/22, it can be
concluded that the Council’s control procedures in key areas are operating
as expected during the period under review, although it is recognised that
work is ongoing with management to continue to make good progress in
implementing agreed action plans arising from Internal Audit reviews.  The
overall audit opinion is Satisfactory. 
4.6 Performance indicators for the Audit and Fraud service were reviewed for
2021/22 and actual performance against target is set out at Appendix 3. 
5.  People Implications 
5.1 There are no people implications. 
6.  Financial and Procurement Implications 
6.1 As a result of Corporate Fraud Team activity, actual recoveries, charges
and re-billings of £284,883 have been identified during 2021/22, against
an annual target of £250,000. 
6.2 There are no procurement implications arising from this report. 
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 minimum level of assurance over the Council’s
system of internal financial control to those charged with governance. 
8. Equalities Impact Assessment (EIA) 
8.1 There is no requirement for an EIA. 
9. Consultation 
9.1 This report has been subject to consultation with appropriate Chief Officers. 
10. Strategic Assessment 
10.1 This report relates to Assuring Our Success through strong financial
governance and sustainable budget management. 
....................................
Laurence Slavin
Chief Officer - Resources
Date:  17 June 2022 
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Person to Contact: Andi Priestman, Shared Service Manager – Audit & Fraud 
Telephone (01389) 737436 
E-mail: andi.priestman@west-dunbarton.gov.uk 
Appendices: 1 – Status of Audit Plan 2021/22 
2 - Internal Audit Annual Report and Assurance Statement
for the year ended 31 March 2022 
3 – Performance Indicators 2021/22 
Background Papers: Audit Committee – 16 June 2021: Internal Audit Plan
2021/22 
Wards Affected: All wards
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Audit Plan 2021/22: Completed Audits
Report Title
Status
Findings Control
Environment
Opinion
Red Amber Green
Risk Based Reviews
IHMS Stores and Stock
Management
Complete 1 4 2 Satisfactory
Employee Expenses Complete 0 3 3 Satisfactory
Pupil Equity Funding Complete 0 2 4 Satisfactory
Homelessness Complete 0 1 0 Satisfactory
Management of Rent
Arrears
Complete 0 2 2 Satisfactory
Corporate Procurement –
Up to £50k spend
Complete 0 2 3 Satisfactory
Vehicle Tracking System Draft report being prepared.  Indicative overall control
environment opinion is Satisfactory
Project Management
Arrangements
Draft report being prepared.  Indicative overall control
environment opinion is Satisfactory
Overtime Fieldwork underway.
LD Services – Financial
Monitoring of Contracts
C/f to 2022/23 Audit Plan
OT Waiting Times C/f to 2022/23 Audit Plan
Financial Assessment
Process
C/f to 2022/23 Audit Plan
Corporate Procurement –
Supplier Management
C/f to 2022/23 Audit Plan
Advisory Reviews
Building Services – Work In
Progress Advisory work complete.  No significant issues arising.
Building Services – Price
Checks
Advisory work complete.  No significant issues arising.
Limited Scope Finance Reviews
Debtors Draft report being prepared.  Indicative overall control
environment opinion is Satisfactory
Control Self-Assessment
CSA Client Administration
Process – Care Homes
CSA exercise complete to establish levels of
compliance with agreed process.  Some
recommendations for improvement were made which
will be followed up in 2022/23.
Other Work
IJB Internal Audit Service 21/22 Audit Plan – Fieldwork almost complete
Valuation Joint Board 21/22 Audit Plan  - Fieldwork almost complete
WD Leisure Trust 21/22 Audit Plan – One planned audit is complete
Appendix 1
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Appendix 2
Assurance Statement for the year ended 31 March 2022
From the Shared Service Manager – Audit & Fraud
To the Members of West Dunbartonshire Council, the Chief Executive and
the Section 95 Officer (Chief Officer - Resources)
As Shared Service Manager - Audit & Fraud of West Dunbartonshire Council, I
am pleased to present my annual statement on the adequacy and effectiveness
of the internal financial control system of the Group Accounts prepared by the
Council for the year ended 31 March 2022.
Respective responsibilities of management and internal auditors in relation
to internal control
It is the responsibility of the Council’s senior management to establish an
appropriate and sound system of internal financial control and to monitor the
continuing effectiveness of that system. It is the responsibility of the Shared
Service Manager – Audit & Fraud to provide an annual overall assessment of the
robustness of the internal financial control system.
The Council’s framework of governance, risk management and internal
control
The Council has a responsibility to ensure that its business is conducted in
accordance with legislation and proper standards.
The governance framework comprises the systems and processes, culture and
values by which the Council is directed and controlled and how it accounts to
communities.  It enables the Council to monitor the achievement of its strategic
priorities and to consider whether those objectives have led to the delivery of
appropriate services and value for money.
The main objectives of the Council’s internal control systems are to ensure:
• Adherence to management policies and directives in order to achieve the
organisation’s objectives.
• Economic, efficient, effective and safe use of resources and assets.
• The relevance, reliability and integrity of information, so ensuring as far as
possible the completeness and accuracy of records.
• Compliance with statutory requirements.
The system of internal control is a significant element of the governance
framework.  Any system of control can only ever provide reasonable and not
absolute assurance that control weaknesses or irregularities do not exist or that
there is no risk of material errors, losses, fraud, or breaches of laws or
regulations. Accordingly, the Council is continually seeking to improve the
effectiveness of its systems of internal control in order to identify and prioritise the
risks that would prevent the achievement of the Council’s strategic objectives. 
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The work of internal audit
Internal auditing is an independent, objective assurance and consulting activity
designed to add value and improve an organisation’s operations. It helps an
organisation accomplish its objectives by bringing a systematic, disciplined
approach to evaluate and improve the effectiveness of governance, risk
management and internal control processes.
The Council’s Internal Audit Section operates in accordance with the Public
Sector Internal Audit Standards (PSIAS) which have been agreed to be adopted
from 1st April 2013 (revised in 2017) by the relevant public sector Internal Audit
Standard setters. PSIAS applies the Institute of Internal Auditors International
Standards to the UK Public Sector. 
PSIAS requires that a Quality Assurance and Improvement Programme (QAIP) is
developed in order to provide assurance that internal audit activity:
• Is conducted in accordance with an Internal Audit Charter.
• Operates in an efficient and effective manner.
• Is perceived to be adding value and improving operations.
An internal self-assessment of internal audit practices has been carried out by
Internal Audit every year since PSIAS became effective on 1st April 2013, with
improvements identified and implemented as appropriate. PSIAS also requires,
as outlined in Standard 1300 “QAIP”, that:
“External assessments must be conducted at least once every five years by a
qualified, independent assessor or assessment team from outside the
organisation. External assessments can be in the form of a full external
assessment or a self-assessment with independent external validation”.
The last external review was carried out during 2015/16.  The next external
review was due to be carried out by 31 March 2021 however this was deferred to
2022 due to the pandemic.  The internal review confirms a high level of
compliance and that the Internal Audit Section generally conforms with the
requirements of PSIAS.
The Internal Audit Section undertakes an annual programme of work based on a
risk assessment process which is revised on an ongoing basis to reflect evolving
risks and changes within the Council.  All Internal Audit reports identifying control
weaknesses and/or areas of non-compliance with expected controls are brought
to the attention of management and the Audit Committee together with
appropriate recommendations and agreed action plans.  It is management’s
responsibility to ensure that proper consideration is given to Internal Audit reports
and that appropriate action is taken on audit recommendations.  The internal
auditor is required to ensure that appropriate arrangements are made to
determine whether action has been taken on internal audit recommendations or
that management has understood and assumed the risk of not taking action. 
Agreed actions arising from Internal Audit reports are followed up on a monthly
basis as action dates fall due.  
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Regular reporting on action plan implementation is provided on a monthly basis to
senior management and to each meeting of the Audit Committee.  
Internal Audit and Corporate Fraud staff regularly attended the following external
user group meetings:
• SLACIAG, the purpose of which is to develop and improve the practice of
internal audit activity with Scottish local authorities.  It achieves this by
meeting to discuss issues of common concern, commissioning work to
develop ideas, sharing good practice, working in partnership with other
professional / governing bodies and promoting SLACIAG as the
representative body for internal audit in local authorities; and
• The Scottish Local Authority Investigators Group (SLAIG): This group consists
of fraud practitioners from local authorities in Scotland, with the objectives of:
o Raising the profile of the counter fraud agenda;
o Sharing good practice;
o Raising awareness of the risk of fraud; and
o Ensuring that fraud is investigated in a professional manner.
COVID-19
The significant incident in late March 2020 and the Council’s responses as a
Category 1 responder during the COVID-19 Pandemic continued to test how well
the Council’s risk management, governance and internal control framework was
operating during 2021/22.  Regular COVID-19 Update reports were provided to
Committee as appropriate.  
All members of the council’s Senior Leadership Team and key stakeholders
participated in a variety of Local Authority specific Covid-19/Business Continuity
response groups supported by the Civil Contingencies Service.  A comprehensive
Covid-19 Impact Risk Register was developed covering all aspects of service
delivery affected by the pandemic which has been maintained on a regular basis. 
With significant disruption to how services continued during 2021/22, the CMT
developed plans to ensure the council continued to meet requirements and
achieve the strategic priorities set out in the Strategic Plan.   This planning activity
considered the reflective learning from the first phase of responding to the
pandemic and ongoing engagement with key stakeholders in planning future
service provision.  
Basis of Opinion
My evaluation of the control environment is informed by a number of sources:
• The audit work undertaken by Internal Audit during the year to 31 March
2022.
• The assessment of risk completed during reviews of the annual audit plan.
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• The Code of Good Governance self-assessment process undertaken by
the Chief Officers for the services for which they were responsible during
the year to 31 March 2022.
• The Council’s Annual Governance Statement for the year ended 31 March
2022.
• Reports issued by the Council’s External Auditors, Audit Scotland, and
other review agencies.
• My knowledge of the Council’s governance, risk management and
performance management and monitoring arrangements.
Limitation to Resources or Scope of Internal Audit Work
There were resource challenges at the start of the year including staff illness and
an unforeseen staff vacancy arising which hampered the team’s ability to
complete all fieldwork for the 2021/22 Audit Plan by 31 March 2022.  Staffing
numbers have now stabilised and the audit plan will be completed by end of June
2022.  There were no significant threats identified to the independence of the
internal audit activity such as inappropriate scope or resource limitations.
Opinion
The report concludes that the majority of West Dunbartonshire Council’s
established internal control procedures operated as intended to meet 
management's control requirements for each area reviewed by Internal Audit in
2021/22. The overall audit opinion is Generally Satisfactory with some
improvement needed.
Signature:  Andi Priestman
Title:  Shared Service Manager – Audit & Fraud
Date:  18 May 2022
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Opinion Types
Satisfactory Controls evaluated are adequate, appropriate and effective to
provide reasonable assurance that risks are being managed
and objectives should be met.
• A limited number of amber rated issues may have been
identified, but generally only green issues have been found
in individual audit assignments.
• None of the individual assignment reports have an overall
opinion of Requires Improvement or Unsatisfactory.
Generally
Satisfactory
with some
improvement
needed
A few specific control weaknesses were noted: generally
however, controls evaluated are adequate, appropriate and
effective to provide reasonable assurance that risks are being
managed and objectives should be met.
• A number of amber rated issues identified in individual audit
assignments that collectively do not significantly impact the
system of internal control.
• Red rated issues that are isolated to specific systems or
processes.
• None of the individual assignment reports have an overall
opinion of Unsatisfactory.
Major
improvement
needed
Numerous specific control weaknesses were noted.  Controls
evaluated are unlikely to provide reasonable assurance that
risks are being managed and objectives should be met.
• A high number of amber rated issues that collectively have
a significant impact on some parts of the system of internal
control but are not widespread.
• A number of red rated issues that collectively have a
significant impact on some parts of the system of internal
control but are not widespread.
• A small number of individual assignment reports have an
overall opinion of Requires Improvement or
Unsatisfactory.
Unsatisfactory Controls evaluated are not adequate, appropriate or effective
to provide reasonable assurance that risks are being managed
and objectives should be met.
• Amber and red rated issues identified in individual
assignments that collectively are widespread to the system
of internal control.
• A high number of individual assignment reports have an
overall opinion of Requires Improvement or
Unsatisfactory.
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Appendix 3
Key Performance Indicators – 2021/22
Measure Description Actual Target
1. Draft Report Percentage of draft reports issued
within 3 weeks of completion of
fieldwork.
100% 80%
2. Final Report Percentage of final reports issued
within 2 weeks of draft report.
91% 100%
3. Audit Plan Delivery Percentage of audits completed
versus planned.
75% 85%
4. Audit Budget Percentage of audits completed
within budgeted days.
67% 80%
5. Audit Recommendations Percentage of audit
recommendations agreed.
96% 90%
6. Action Plan Follow Up Percentage of action plans
followed up – Internal and External
Audit.
100% 100%
7. Customer Feedback Percentage of respondents who
rated the overall quality of internal
audit as satisfactory or above.
100% 100%
8. NFI recommended
matches
Percentage of National Fraud
Initiative recommended matches
investigated within timescales.
100% 100%
9. NFI other matches Percentage of National Fraud
Initiative other matches
investigated within timescales.
100% 90%
10. DWP liaison Percentage of cases referred to/
actioned for DWP within DWP
timescales. 
100% 100%
11. Staff compliance with
CPD
Number of training hours
undertaken to support CPD
100 100
12. Management
engagement
Number of meetings with CMT and
senior management as appropriate
3 per
quarter
1 per
quarter
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer - Resources
Audit Committee: 15 June 2022
___________________________________________________________________
Subject:  2022/23 Internal Audit 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 2022/23.
2. Recommendations
2.1 It is recommended that the Committee approve the 2022/23 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 some audits from 2021/22
which were deferred due to staff turnover, staff absence and other factors. 
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 9
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4.6 Outlined below are the current risk factors influencing our proposed audit
coverage for 2022/23:
• Learning Disabilities Services provide a range of support services to adults
with learning disabilities.  A number of contracts are in place to implement
these services and Internal Audit will review the adequacy and
effectiveness of the financial monitoring of these contracts.
• Building Services provide a dedicated repairs and maintenance service.
Internal Audit will review procedures in place to ensure services provided
are effective.
• Clients who require Council funding of their costs within care homes are
required to complete financial assessments.  It is therefore important to
gather accurate and up to date information when calculating the
contributions due from clients and the Council.  The financial assessment
process was subject to a process redesign in 2020/21 to align with the new
eligibility criteria.  Internal Audit will therefore review the adequacy and
effectiveness of the new financial assessment process.
• Occupational Therapy is an important service provided by the HSCP and
targets have been set in relation to waiting times for referrals.  As a result
of COVID-19 this audit was deferred in 2021/22 and therefore Internal
Audit will review the adequacy and effectiveness of arrangements in place
to ensure targets are achieved during 2022/23.
• Roads and Neighbourhood provide and maintain the fleet across all
Council services.  Vehicles and equipment are a critical corporate asset
used in the delivery of front line services.  Internal Audit will review the
adequacy and effectiveness of fleet management and vehicle maintenance
arrangements.
• In relation to off payroll working (IR35), public authorities are responsible
for checking whether off payroll rules apply to individuals or companies
providing services to the organisation.  Internal Audit will review the
adequacy and effectiveness of arrangements that are in place.
• As soon as a housing application is active, the applicant will be put onto
the housing waiting list for the areas and housing types that have been
chosen.  Internal Audit will review the adequacy and effectiveness of the
waiting lists process.
• As part of the annual audit planning process, corporate procurement is a
key risk area that is reviewed each year.  For 2022/23 Internal Audit will
carry out an audit of supplier management ensure compliance with
relevant policies and procedures.
• The Parent Pay system is currently being piloted within a number of
Education establishments.  Internal Audit will review the adequacy and
effectiveness of arrangements that are in place during the pilot phase.
• In order to facilitate payment for low value, high volume transactions,
Council services use corporate purchase cards.  Internal Audit will review
the adequacy and effectiveness of arrangements that are in place to
ensure compliance with relevant policies and procedures.
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4.6 The draft 2022/23 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. 
4.7 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. 
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: 15 June 2022 
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Person to contact Andi Priestman, Shared Service Manager – Audit & Fraud  
Telephone:  01389-737436  
Email:  andi.priestman@west-dunbarton.gov.uk 
Appendix 1: Draft 2022/23 Internal Audit Strategy and Plan 
Background Papers: None 
Wards Affected: All wards  
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2022/23 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN  
Appendix 1
1. Introduction
1.1 The Public Sector Internal Audit Standards (PSIAS) 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 definition of internal auditing is contained within the PSIAS as follows:
“Internal auditing is an independent, objective assurance and consulting activity designed
to add value and improve an organisation’s operations.  It helps an organisation
accomplish its objectives by bringing a systematic, disciplined approach to evaluate and
improve the effectiveness of risk management, control and governance processes.”
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.
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2022/23 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN
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 service
arrangement with Inverclyde Council.
4.2 In relation to the total staff days allocated to the 2022/2023 plan, each member of staff
completes a resource allocation spreadsheet for the year which is split between annual
leave, public holidays, training days, general administration and operational plan days.
This spreadsheet is reviewed and updated each period by each member of staff against
time charged to timesheets.  
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2022/23 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN
The combined operational plan is 1,160 days which will be resourced as follows:
Team Member Plan Days
Auditor 180
Lead Auditor (0.5 FTE) 70
Auditor (0.5 FTE) 90
Auditor (0.5 FTE) 90
Audit Assistant 160
Section Lead – Corporate Fraud 150
Corporate Fraud Officer 180
Corporate Fraud Officer (vacant)* 90
Intelligence Officer 150
Total Plan Days 1,160
* Due to the Covid-19 Pandemic, recruitment for the Corporate Fraud Officer post was
delayed as home visits and interviews under caution were halted.  It is anticipated we will
start the recruitment process after the summer recess when those aspects of the team’s
work are restarted, subject to relevant protocols being in place.
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 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 PSIAS requires that the Chief Internal Auditor must hold a professional qualification
such as CMIIA (Chartered Internal Auditor), CCAB or equivalent and be suitably
experienced.  The internal auditor posts must also be CMIIA/CCAB or equivalent with
previous audit experience.
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 PSIAS.
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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2022/23 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN
5 Proposed Audit Coverage 2022-2023
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
Learning Disability Services – Financial
Monitoring of Contracts (c/f)
HSCP 9760 30
Fleet Management Corporate 8928 30
Occupational Therapy Waiting Times
(c/f)
HSCP 8184 30
Financial Assessment Process (c/f) HSCP 7936 30
Housing Repairs and Maintenance Supply, Distribution and Property 6882 30
Corporate Procurement – Supplier
Management (c/f)
Corporate 5952 30
Vehicle Maintenance Roads and Neighbourhood 5766 25
Void Management Supply, Distribution and Property 5616 30
Housing Waiting Lists Housing 4836 20
Parent Pay Education, Learning and Attainment 4650 25
Off Payroll Working (IR35) Corporate 4440 20
Corporate Purchase Cards Corporate 4428 30
Total 330
Limited Scope Financial System Reviews
Non Domestic Rates Resources 4662 20
Creditors Resources 4350 20
Total 40
Compliance Reviews
Health and Wellbeing Policy Corporate N/A 20
Total 20
Corporate Governance Reviews
Annual Governance Statement
(2021/2022)
Corporate - 10
Total 10
Other Work
Audit follow up Corporate - 20
HR/Payroll Verification Checks Corporate - 15
National Fraud Initiative Corporate - 100
Fraud Referrals including Joint Working Corporate - 425
Liaison with DWP - - 10
Fraud Awareness Training Corporate - 15
IJB – Internal Audit Service - - 40
VJB – Internal Audit Service - - 15
Leisure Trust – Internal Audit Service - - 10
Contingency - - 30
Completion of  2021-2022 Audit Plan - - 80
Total 760
Total Staff Days for 2022/23 1160
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2022/23 INTERNAL AUDIT ANNUAL STRATEGY AND PLAN
6 Quality and Performance
6.1 The PSIAS 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 2021/2022 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. Draft Report Percentage of draft reports issued
within 3 weeks of completion of
fieldwork.
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. NFI other matches Percentage of National Fraud Initiative
other matches investigated within
timescales.
90%
10. DWP liaison Percentage of cases referred to/
actioned for DWP within DWP
timescales. 
100%
11. Staff compliance with CPD Number of training hours undertaken
to support CPD
100
12. 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 2022/23 Internal Audit Annual
Assurance Report.
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WEST DUNBARTONSHIRE COUNCIL
Report by Chief Officer - Resources
Audit Committee: 15 June 2022
__________________________________________________________________________________
Subject: Audit Scotland Management Letter: West Dunbartonshire Council
– Interim audit testing 2021/22
1. Purpose of Report
1.1 The purpose of this report is to advise Members of the Council’s 2021/22 mid-
year management letter issued by our external auditors, Audit Scotland and
the management actions agreed in relation to the issued identified in the
letter.
2. Recommendations
2.1 The Committee is invited to note the report and the agreed management
actions.
3. Background
3.1 Part of the planned work of Audit Scotland as the Council’s external auditors,
is to undertake a review of the Council’s key controls and provide a report on
any issues or risks arising from this review.
3.2 As part of the work required, the auditors undertook a high level review of the
governance arrangements and the main financial systems operated by the
Council. The purpose of this review was to evaluate whether the Council have
sound governance arrangements in place and whether the key internal
controls operating within the main financial systems are adequate and to
identify any issues for further consideration in their main audit.
4. Main Issues
4.1 The management letter,  as appended to this report, identifies two issues/risks
for management to consider. For each of these items management responses
and timelines have been provided. These are detailed in the letter within
Exhibit 1.
5. Option Appraisal
5.1 No option appraisal was required for this report.
6. People Implications
6.1 The people issues arising from this report are in relation to implementing
improved processes in a number of systems and can be implemented from
within existing resources.
ITEM 11
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7. Financial and Procurement Implications
7.1 There are no financial or procurement implications.
8. Risk Analysis
8.1 Failure to address the recommendations outlined in the report could impact on
the final audit opinion awarded to the Council in respect of the audit in future
financial years.
9. Equalities Impact Assessment (EIA)
9.1 No equalities impact assessment was required in relation to this report.
10. Environmental Sustainability
10.1 No assessment of environmental sustainability was required in relation to this
report.
11. Consultation
11.1 This report has been subject to consultation with appropriate
12. Strategic Assessment
12.1 Sound financial practices are cornerstones of good governance and support
Council and officers to pursue the 5 strategic priorities of the Council’s
Strategic Plan.
Laurence Slavin
Chief Officer - Resources 
Date: 26 May 2022
___________________________________________________________________
Person to Contact: Laurence Slavin, Chief Officer - Resources
Council Offices, Church Street, Dumbarton,
Email: Laurence.Slavin@west-dunbarton.gov.uk
Appendices: Audit Scotland - Interim Audit Testing 2021/22
Wards Affected:       All
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4th Floor
8 Nelson Mandela Place
Glasgow  G2 1BT
T: 0131 625 1500
E: info@audit-scotland.gov.uk
www.audit-scotland.gov.uk
Laurence Slavin
Chief Officer – Resources
West Dunbartonshire Council
16 Church Street
Dumbarton
G82 1QL
26 May 2022
Dear Laurence,
West Dunbartonshire Council – Interim audit testing 2021/22
1. Audit Scotland’s Code of Audit Practice requires us to assess the systems of internal control put in place
by management. In carrying out this work, we seek to gain assurance that West Dunbartonshire Council:
• has systems for recording and processing transactions which provide a sound basis for the
preparation of financial statements and the effective management of its assets and interests
• has systems of internal control which provide an adequate means of preventing or detecting material
misstatement, error, fraud or corruption
• complies with established policies, procedures, laws and regulation.
Overall summary
2. Overall, we concluded that West Dunbartonshire Council has adequate systems of internal control in place
for the key systems used to record, process, and report financial and other relevant data for the financial
statements. However, our work identified two issues for management consideration, as detailed at appendix
1. These issues impact on our audit approach and will require us to complete targeted testing to obtain the
required assurances for our audit of the 2021/22 financial statements.
System coverage
3. A key focus of our testing was the verification to source documentation of significant income and
expenditure transactions (including staff costs) during 2021/22. Work is ongoing in some areas, however we
have not identified any issues to report from our testing to date. As testing was performed prior to the
2021/22 financial year end, the need for additional testing will be considered as part of the financial
statements audit to ensure sufficient audit coverage for the full year is achieved.
4. During the interim audit we reviewed the key controls in the following systems:
• General Ledger
• Accounts Receivable
• Accounts Payable
• Payroll
• Cash & Bank
• Non-Domestic Rates
• Council Tax
• Housing Benefit
5. This work involved carrying out walkthroughs of the key controls in each system to confirm they were
operating as expected. This covered a number of areas including reviewing reconciliation, payroll exception
Appendix 1
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reporting and changes to supplier bank details. We will use the results of this testing to determine our
approach during the 2021/22 financial statements audit. 
Risk identification
6. Appendix 1  sets out the issues for management consideration identified from
our interim audit work.
7. The issues identified in preparing this management letter are only those which have come to our attention
during the course of our normal work and are not necessarily, therefore, all the risk areas that may exist. It
remains the responsibility of management to determine the extent of the internal control system appropriate
to West Dunbartonshire Council. We would stress, however, that an effective system of internal control is an
essential part of the efficient management of any organisation.
Acknowledgement
8. The contents of this letter have been discussed with relevant officers to confirm factual accuracy. The co-
operation and assistance we received during the course of our audit from staff is gratefully acknowledged.
Yours sincerely
Christopher Gardner
Senior Audit Manager
Direct Tel: 0131 625 1610 
Email: chgardner@audit-scotland.gov.uk
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Appendix  1
Key audit findings for management consideration
Issue/risk Management response Responsible
officer and target
date
1. Delays in completing and reviewing
feeder system reconciliations
Last year we reported delays to reviews
of feeder system reconciliations. This
exercise provides assurance that the data
contained within individual accounting
systems and the general ledger are in
agreement.
Our review of a sample of reconciliations
for the Housing Benefits, Council Tax and
Non-Domestic Rates (NDR) systems
found again that some had not been
completed within the expected timescale
of no later than one month after the period
end, or reviewed within one month of
completion. We noted improvement in the
timeliness of the housing benefit system
reconciliations.
We will review the year end
reconciliations for assurance on the
figures in the financial statements.  
Risk: Potential errors are not
identified, investigated and resolved in
a timely manner.
Finance will perform a prioritisation
review of the work of the
Reconciliations team to risk profile
the current suite of reconciliations
being carried out. This will allow the
workload to be rationalised and
there to be greater focus on higher
risk and higher value
reconciliations.
Chief Officer –
Resources 
31 March 2023
2. Delays in removing user access
Our review of user access to the general
ledger and housing benefit systems found
two instances of delays to removing user
users once an employee had left the
organisation. In one instance, user rights
were removed fully almost one month
after the staff member left. 
We are content there is no evidence to
suggest any inappropriate user activity
took place during this time.
Risk: Inappropriate user privileges
could result in error or fraud or allow
access to sensitive data. 
The process to identify and remove
users will be assessed to ensure it
is robust and officers will be
reminded of the need to remove
inactive users timeously.
Chief Officer –
Resources 
30 June 2022
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WEST DUNBARTONSHIRE COUNCIL
Report by the Chief Officer - Resources
Audit Committee: 15 June 2022
___________________________________________________________________
Subject: Prudential Indicators 2021/22 to 2031/32 and Treasury
Management Strategy 2022/23 to 2031/32
1. Purpose
1.1  Following approval at Council on 23 March 2022 this report is to provide members
with the opportunity to further scrutinise the Prudential Indicators for 2021/22 to
2031/32 and the Treasury Management Strategy (including the Investment
Strategy) for 2022/23 to 2031/32 and the indicative indicators for 2024/25 to
2030/31.
2. Recommendations
2.1  Members are requested to consider the report and note that on 23 March 2022
Council:
(a) Agreed the following Prudential Indicators and Limits discussed in Appendix 1
and set out within Appendix 6 for the period to 2024/25:
• Capital Expenditure and Capital Financing Requirements (Tables A and B)
• Forecast and estimates of the ratio of financing costs to Net Revenue
Stream (Table D).
(b) Approved the policy for loans fund advances discussed in Appendix 1 in section
3.
(c) Approved the Treasury Management Strategy for 2022/23 to 2024/25 (including
the Investment Strategy) contained within Appendices 2 to 6.
(d) Agreed the following Treasury Prudential Indicators and Limits discussed in
Appendix 2 and set out within Appendix 6 for the period 2022/23 to 2024/25:
• Operational Boundaries (Table F)
• Authorised Limits (Table G)
• Counterparty Limits (Table J)
• Treasury Management Limits on Activity (Table L).
(e) Noted the draft Prudential and Treasury Management Indicators for the period
2025/26 to 2031/32 discussed in Appendices 1 and 2 and set out within
Appendix 6.
ITEM 13
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(f) Approved the statement by the Section 95 Officer regarding the gross debt
level in comparison to the Capital Financing Requirement (Appendix 2 - Point
2.3).
(g) Noted the report will be referred to Audit Committee for further scrutiny.
3. Background
3.1 With the introduction of the Prudential Code, the Council has freedom over
capital expenditure so long as it is prudent, affordable and sustainable. In
order to show it is working within these limits the Council must approve, revise
and monitor a range of prudential indicators covering the forthcoming three
years.
3.2 CIPFA defines treasury management as:
‘The management of the local authority’s borrowing, investments and
cashflows, its banking, money market and capital investment transactions; the
effective control of the risks associated with those activities; and the pursuit of
optimum performance consistent with those risks.’
3.3 The Council’s treasury activities are strictly regulated by statutory
requirements (Code on the Investments of Money by Scottish Local
Authorities) and a professional code of practice (CIPFA Treasury
Management Code of Practice).  The code requires an annual strategy to be
reported to Council in advance of the forthcoming year outlining the expected
treasury activity for the forthcoming 3 years.  A key requirement of this report
is to explain both the risks, and the management of the risks, associated with
the treasury service.  Further reports are issued as follows:
(a) Mid-year monitoring report on actual treasury activity during the year
including revised indicators where appropriate
(b) Year-end report on actual treasury activity for the previous year.
3.4 Section 56 of the Local Government (Scotland) Act 1973 Act permits local
authorities in Scotland to discharge their functions by committees.  Exceptions
include setting the council tax and borrowing money which requires the
authority, that is full Council, to discharge.  The Section 56 provisions were
extended to require Council to approve the Annual Investment Strategy via
the Code on the Investments of Money by Scottish Local Authorities (issued
on 1 April 2010) under section 40 of the Local Government in Scotland Act
2003.    
3.5 As a result of Section 56, both the Prudential Indicators and the Treasury
Management Strategy (including the Investment Strategy) are required to be
approved by full Council before the start of the financial year. 
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3.6 The CIPFA Treasury Management Code of Practice requires greater Member
scrutiny of the treasury polices, increased Member training and awareness
and greater frequency of information.
3.7 One of the key clauses 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
4.1 The Local Government in Scotland Act 2003 requires Council to adopt the
CIPFA Prudential Code and to produce prudential indicators.   Appendix 6 of
this report details the Council’s expected year end indicators for 2022/23,
revises the indicators for 2023/24 to 2025/26 and projects the indicators to
2032/33, with those for the period 2025/26 to 2031/32 being indicative at this
time.
4.2 Within this overall prudential framework there is a clear impact on the
Council’s treasury management activity, either through borrowing or
investment activity.  As a consequence the treasury management strategy
(which includes details of both debt and investment) for 2022/23 to 2031/32 is
included in Appendix 6 (with the period 2025/26 to 2031/32 being indicative at
this time) to complement the prudential indicators relating to the treasury
activity.
4.3 Details of the risks, mitigating controls and limits associated with each of the
permitted investment categories are shown in Appendix 3.  Credit rating type
and definitions are attached as Appendix 4 and a list of approved sovereign
countries for investments are attached as Appendix 5. 
Changes to Financial Regulations - Leasing
4.4 The Treasury Management Strategy report to Council in March 2021 reported
a change to financial regulations regarding leasing. The change was
postponed and was due to be implemented on 1 April 2022 (as reported to
Council on 23 March 2023). Since reported, it has been confirmed that this
change has been postponed until 1 April 2023.
4.5 This change will bring the assets and future liabilities for all leases onto the
Council’s Balance Sheet from 1 April 2023. The effect of this change will
increase the ‘level of debt’ identified by the Council; the Capital Financing
Requirement; Operational Boundary; and Authorised Limit, by the future
liability of the leased assets. Forecast and estimates of the ratio of financing
costs to Net Revenue Stream may also be affected in future years. This
change affects all councils, though this Council has a low number of leased
assets.
Capital Strategy
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4.6 For information, in December 2017, CIPFA issued a revised Prudential Code.
As a result, from 2019/20, all local authorities were required to prepare a
Capital Strategy report, which is intended to provide 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.
4.6.1 The aim of the Capital Strategy report is to ensure that all elected members
fully understand the overall strategy, governance procedures and risk appetite
entailed by the Strategy.
4.6.2 The Capital Strategy for 2022/23 (reported to, and approved by, Council on 9
March 2022) includes capital expenditure, investments and liabilities and
treasury management in sufficient detail to allow all Members to understand
how stewardship, value for money, prudence, sustainability and affordability
will be secured.
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 The prudential indicators detailed in Appendix 6 show the Council’s likely and
indicative capital financing for the period 2021/22 to 2031/32 while the
treasury management indicators detailed in Appendix 6 show the likely
borrowing requirement for the same period.
7.2 Table E in Appendix 6 indicates that in each year the gross borrowing
requirement (which includes short term borrowing for cashflow purposes) is
below the capital financing requirement and does not exceed the total of the
CFR in the preceding year plus the estimates of any additional CFR for
2022/23 and following two financial years (Appendix 2 – section 2.1 and 2.2).
7.3 As a key indicator of prudence this illustrates that the Council only undertakes
long term borrowing for capital purposes and that over the last few years
investment balances have been utilised to fund capital expenditure due to the
concerns over the general economic environment and restricted counterparty
lists.
7.4 There are no procurement issues arising from this report.
8. Risk Analysis
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8.1 There are three main risks associated with the formulation of prudential
indicators and the treasury management strategy as detailed in Appendix 1
and 2:
(a) Capital receipts which affect the capital financing and borrowing requirement
may not materialise and if this occurs then 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) must
also be taken into account; however the robust controls included within the
investment strategy (Appendix 2 – section 6) will assist in mitigating this risk;
and
(c) Capital inflation may increase capital expenditure levels, which in turn may
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
10.1 No assessment of environmental sustainability was required in relation to this
report.
11. Consultation
11.1 Legal and Resources have been consulted in relation to this report and
appendices.
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 5 strategic
priorities of the Council’s Strategic Plan. This report forms part of the financial
governance of the Council.
Laurence Slavin
Chief Officer - Resources
Date:  20 April 2022
Person to Contact: Jackie Thomson Church Street, Dumbarton
Email: Jackie.NicholThomson@west-dunbarton.gov.uk
Appendices: 1 Prudential Indicators 2021/22 to 2031/32
2 Treasury Management Strategy 2022/23 to
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2031/32
3 West Dunbartonshire Council and Common Good
Funds Permitted Investments, Associated Controls
and Limits
4 Counterparty Rating Explanations
5 Approved Countries for Investment
6 Prudential and Treasury Indicators
Background Papers: Treasury Management Strategy – Council 3 March 2021
Treasury Mid-year update – Council 22 December 2021
Budget Update – Council 9 February 2022
Budget Update – Council 9 March 2022
Treasury Management Strategy Statement and Annual
Investment Strategy (Link January 2022)
Scotland’s Economic and Fiscal Forecasts (Fiscal
Commission Scotland December 2021)
Wards Affected: All wards affected.
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Capital Prudential Indicators 2021/22 to 2031/32
1. The Capital Expenditure Plans
1.1 The Council’s gross capital expenditure plans are summarised in Table A within Appendix 6
and this forms the first of the prudential indicators.  Total expenditure is partially funded by
resources such as capital receipts, capital grants, etc.  Any remaining expenditure which
cannot be immediately funded from other resources will form a borrowing need.
1.2 A certain level of capital expenditure will be grant supported by the Government; anything
above this level will be funded from the Council’s own resources (e.g. other grants, capital
receipts, prudential borrowing).
1.3 There are two main limiting factors which may impact on the Council’s ability to undertake
unsupported capital expenditure:
• Whether the revenue resource is available to support in full the implications of capital
expenditure, both borrowing costs and running costs; and
• The Government may use a control to limit either the total of all councils’ plans nationally,
or in the event of an assessment by central government that local plans are unaffordable
at a specific council, it may implement a local control.  No such control has been
implemented since the inception of the prudential code, however, HM Treasury keep this
under review.
1.4 The summary of capital expenditure, as per the capital plan updates reported to Council 9
March 2022 for both HRA and General Services, is shown in the table A in Appendix 6.  The
HRA capital plan refresh extends to 2026/27 with the period from 2026/27 to 2031/32
extracted from the HRA Business Plan for the purposes of Prudential Indicator calculations.
1.5 Under section 22 of Schedule 3 of the Local Government (Scotland) Act 1975 a local authority
may establish a capital fund to be used for “defraying any expenditure of the authority to which
capital is properly applicable, or in providing money for repayment of the principal of loans (but
not any payment of interest on loans)”.  Furthermore paragraph 24 of Finance Circular 7/2018
confirms that capital receipts may also be used to “fund the cost of premiums, either as they
are incurred, or as they are recharged back to the General Fund/ HRA” with further flexibilities
given due to covid to use capital receipts for transformation until 31 March 2023. 
1.6 The capital plan update for General Services reported to Council assumes an element of
capital receipts is used to fund the principal element of loan charges and annual premium
costs between 2021/22 and 2024/25; and a further element to fund transformational costs in
2022/23. This has been adjusted for within these indicators, where appropriate.
2. The Council’s Borrowing Need (the Capital Financing Requirement)
2.1 The second prudential indicator is the Council’s Capital Financing Requirement (CFR).  The
CFR is simply the total outstanding capital expenditure which has not yet been paid for from
either revenue or capital resources.  It is a measure of the Council’s underlying borrowing
need.  The net capital financing need (as indicated in Table A in Appendix 6) impacts directly
on the CFR.  
Appendix 1
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2.2 Due to accounting requirements, the CFR currently includes any other long term liabilities (i.e.
PPP schemes, finance leases) brought onto the Balance Sheet.  Whilst this increases the
CFR, and therefore the Council’s borrowing requirement, these types of scheme include a
borrowing facility and so the Council is not required to separately borrow for these schemes. 
The Council currently has circa £100m for PPP schemes within the CFR. From 1 April 2022,
further accounting changes see operational leases (where the Council is lessee) also being
brought onto Balance Sheet, which will further increase CFR through other long term liabilities
(value to be confirmed, however an estimate has been included within the appendices).
2.3 The CFR projections for both General Services and HRA are shown in table B in Appendix 6
and show that the CFR for the HRA is projected to increase each year from 2021/22 to
2031/32 with the CFR for General Services being anticipated to increase each year until
2025/26, due to the levels of projected capital spend in comparison to income anticipated in
that year.
2.4 The expected impact of the capital expenditure decisions above on the Council’s debt and
investment position are shown in the treasury strategy (Appendix 2).
3. Statutory repayment of loans fund advances
3.1 The Council is required to set out its policy for the statutory repayment of loans fund
advances. The repayment of loans fund advances ensures that the Council makes a prudent
provision each year to pay off an element of the accumulated loans fund advances made in
previous financial years.  
3.2 A variety of options are provided to Councils so long as a prudent provision is made each year
as detailed below:
Option Method Detail
1 Statutory Loans fund advances will be repaid by the annuity
method.  The Council was permitted to use this option
for a transitional period only, of five years until 31 March
2021, at which time it was required to change its policy
to use alternative approaches based on depreciation,
asset life periods or a funding/income profile as detailed
below.
2 Depreciation Annual repayment of loans fund advances will follow
standard depreciation accounting procedures.
3 Asset Life Loans fund advances will be repaid with reference to the
life of an asset using either the equal instalment or
annuity method.
4 Funding/ Income
Profile
Loans fund advances will be repaid by reference to an
associated income stream
3.3 Council is recommended to approve the following policy for loans fund advances:
• For loans fund advances made before 1 April 2016, the policy will for all loans fund
advances to be repaid by the annuity method, by the appropriate write off period (based
upon useful asset lives, following the agreed Council policy).
• Recognising that the Council had forward capital expenditure plans and was already
committed to that plan and the revenue implications of that plan, the policy for loans fund
advances made from 1 April 2016 to 31 March 2021 was to mainly repay loans fund
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advances by the annuity method (with a write off period based upon useful asset lives)
unless an alternative method is more appropriate.  
• For loans fund advances made after 1 April 2021 (i.e. commencing 2021/22), the policy for
the repayment of loans advances is to apply the following options, selecting the most
suitable method from the list below for each individual advance.
o Asset life method – loans fund advances will be repaid with reference
to the life of an asset using either the equal instalment or annuity
method.  It is likely that the equal instalment method will be used;
o Funding / Income profile method – loans fund advances will be repaid
by reference to an associated income stream.
3.4 The annuity rate applied to the loans fund repayments is based on historic interest
rates and is currently 9%.
3.5 Table C in Appendix 6 details the loans fund repayment profile for 2021/22 onwards
based on the balance outstanding at 1 April 2021 and capital expenditure plans
2021/22 to 2031/32 as per Table A.  
4. Affordability Prudential Indicators
4.1 The previous sections cover the overall capital and control of borrowing, but within this
framework prudential indicators are required to assess the affordability of the capital
investment plans.   These indicate the impact of the capital investment plans on the overall
Council’s finances.  The Council is asked to approve the following indicators:
4.2 Actual and Estimates of the ratio of financing costs to net revenue stream
This indicator is detailed in Table D in Appendix 6, and identifies the trend in financing cost of
capital (loan charges and long term liability financing) against the net revenue stream (funding
sources e.g. Scottish Government revenue support grant, council tax and HRA rental income). 
The estimates of financing costs include current commitments and the impact of capital
expenditure as per Table A and this indicator shows the percentage of total council revenue
expenditure that is spent on repayment of loan charges and long term liability capital and
interest repayments. 
5. Financial reporting changes in relation to leases
5.1 From 1 April 2022 there is a significant change to the Accounting Code of Practice for
2022/23 onwards which the Council follows for their Financial Statements, which will
impact on debt levels and prudential indicators in the future. This change is in relation
to assets the Council leases in.
5.2 Currently there are 2 types of leases which are treated differently through the Financial
Statements. From April 2022, all leases (where the Council is lessee and with a few
exceptions) will require to be accounted for on the Council Balance Sheet as assets.
For illustrative purposes, leases currently held by the Council (but not owned and
therefore not currently on the Council’s Balance Sheet) include leases for properties
(such as Aurora/ Clydebank Town Centre Office/ Bridge Street), photocopiers, and
vehicles. The treatment of these leases will become similar to the current accounting
reporting for PPP assets.
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5.3 Accounting for these leases on the Balance Sheet will result in increases to assets and long
term liabilities, affecting a number of the prudential and treasury management indicators –
increasing: the ‘level of debt’ identified by the Council; the Capital Financing Requirement;
Operational Boundary; and Authorised Limit, by the value of the leases. Forecast and
estimates of the ratio of financing costs to Net Revenue Stream may also be affected. 
5.4 Currently an exercise is underway to identify all leases and values for both the assets and the
liabilities. No alterations to deal with bringing currently off-balance sheet leased assets onto
the balance sheet have been made within the report as it is currently not required. However,
this will be a requirement for closing of the accounts for 2022/23 and future updates to the
Treasury Strategy (including the mid-year). This will include Capital Financing Requirement,
External debt (Other long-term liabilities), authorised limit and operational boundary, to allow
for those leases which were previously off balance sheet, being brought onto the balance
sheet at 31.3.23.  
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Treasury Management Strategy 2022/23 – 2031/32
1. Background
1.1 The treasury management service is an important part of the overall financial management of
the Council’s affairs.  Whilst the prudential indicators in Appendix 1 consider the affordability
and impact of capital expenditure decisions, the treasury service covers the effective funding
of these decisions.  There are specific treasury prudential indicators included in this strategy
which need approval.
1.2 The Council’s treasury activities are strictly regulated by statutory requirements and a
professional code of practice (the CIPFA Code of Practice on Treasury Management – revised
December 2017). For information, CIPFA has published an updated Treasury Management
and Prudential Codes in December 2021, with full implementation required for 2023/24.  
1.3 As a requirement of the Code Council is required to adopt a Treasury Management Policy
Statement and four Treasury Management clauses.  These form part of the Council’s financial
regulations and the following documents were adopted on 5 March 2018:
• Treasury Management Policy Statement
• Treasury Management Clauses
• The Treasury Management Role of the Section 95 Officer
1.4 The policy requires an annual strategy to be reported to Council outlining the expected
treasury activity for the forthcoming 3 years, however in line with the longer capital planning
process treasury management indicators have been provided (where appropriate) covering
the period to 2031/32.  A key requirement of this report is to explain both the risks, and the
management of the risks, associated with the treasury service.  Further reports are issued as
follows:
• Mid-year monitoring report on actual activity during the year including revised indicators
where appropriate; and
• Year-end report on actual activity for the previous year.
1.5 This strategy covers:
• The Council’s debt and investment projections;
• Limits to the Council’s borrowing activity;
• The economic climate and expected movement in interest rates;
• The Council’s borrowing, debt and investment strategies;
• Treasury performance indicators;
• Specific limits on treasury activities; and
• Policy on ethical investments
2. The Council’s debt and investment projections
2.1 The Council’s forecast treasury portfolio position at 31 March 2022 with forward projections
are summarised in Table E in Appendix 6 and shows the gross debt (the treasury
management operations), against the underlying capital borrowing need (the Capital
Financing Requirement - CFR), highlighting any under or over borrowing.  
Appendix 2
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2.2 Within the prudential indicators there are a number of key indicators to ensure the Council
operates its activities within well defined limits.  One of these is that the Council needs to
ensure that its gross debt does not, except in the short term, exceed the total of the CFR in the
preceding year plus the estimates of any additional CFR within the following two financial
years.  This allows some flexibility for limited early borrowing for future years, but ensures that
borrowing is not undertaken for revenue purposes.  This is illustrated by comparing the
estimated gross debt as at 31 March 2022 with the CFR as at 31 March 2025.
2.3 The Section 95 Officer (Chief Officer - Resources) reports that the Council has
complied with this prudential indicator, and no difficulties are envisaged for the current
or future years.  This view takes into account the capital plan refresh reports for General
Services and HRA.
3. Limits to Borrowing Activity
3.1 The Operational Boundary is detailed in Table F in Appendix 6 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 CFR, but may be lower or higher depending on the levels of actual debt.  
3.2 The Authorised Limit for External Borrowing – a further key prudential indicator represents a
control on the overall level of borrowing.  This represents a limit beyond which external debt is
not allowed to exceed.  This needs to be set or revised by Members.  It reflects the level of
external debt which, while not desired, could be afforded in the short term, but is not
sustainable in the longer term.  This is the statutory limit (Affordable Capital Expenditure Limit)
determined under section 35(1) of the Local Government in Scotland Act 2003. The
Government retains an option to control either the total of all councils’ plans, or those of a
specific council, although this power has not yet been exercised.  The Council is asked to
approve the authorised limit detailed in Table G in Appendix 6. 
3.3 Advance Borrowing - This Council will not borrow more than or earlier than required purely
in order to profit from the investment return of the extra sums borrowed.  Any decision to
borrow in advance will be within forward approved Capital Financing Requirement estimates,
and will be considered carefully to ensure that value for money can be demonstrated and that
the Council can ensure the security of such funds.
3.3.1 Advance borrowing will only be taken for risk management purposes subject to sound
justification.  The Section 95 Officer may do this under delegated power where, for instance, a
sharp rise in interest rates is expected and so borrowing early at fixed interest rates will be
economically beneficial.  A cautious approach to any such borrowing will be adopted, however
where there is a clear business case for doing so borrowing may be undertaken to fund the
approved capital programme or to fund future debt maturities.
3.3.2 Full consideration will be given to balancing investment risks, such as the credit and interest
risk resulting from the temporary investment of the sums, against the risk of adverse interest
rate movements in addition to the existing debt maturity profile over the medium term.
3.3.3 As required by The Investment Regulations (Code on the Investments of Money by Scottish
Local Authorities) which came into force on 1 April 2010 the Council will appraise all risks
associated with advance borrowing activity.  The Council will fully document the justification
for the decision prior to the activity being undertaken, with subsequent reporting either within
the mid-year or annual reporting mechanism.  
4. UK, World and Scottish Economy Update (January 2022)
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4.1 UK
In the UK, forecasters estimate that the increase in utility and fuel prices, and the hike in
taxes on 1 April, will reduce real household disposable income over the next two years by a
cumulative £80bn. The resulting 2.0% decline in real incomes in 2022 will be the largest on
record. Even with this, analysts expect a surge in inflation from 5.4% in December 2021 to
peak of +7.5% in April 2022 and the risk that inflation expectations remain high are likely to
prompt the Bank of England to raise bank base rates to peak at 2% next year.
4.2  US
In the US the recent surge of Omicron inflections has meant more people were self
isolating in January than at any time since the start of the pandemic, although the impact
that it will have on employment and outputs remains uncertain. However with cases now
falling as quickly as they rose any effects should quickly be reversed. In contrast to earlier
waves, the rise did not prompt a significant pullback in service activity. The far bigger factor
this time is staff absenteeism which analysts state caused both payroll employment and
manufacturing output to decline in January but with this impact reversed by the end of
March. 
4.3 EU
Although coronavirus indicators suggest the number of new cases are declining, output
indicators do not show signs of improving early in 2022. Consumer indicators reveal that
mobility remains relatively low and conditions within the labour market remain tight.
Monetary indicators show that bank lending has continued to be strong, with fiscal
indicators showing that governments face additional costs due to gas and fuel price
increases. Events in Ukraine continue to provide upside pressure to inflation because of
increases in gas, oil and wheat process.
4.4 China
Output and activity indicators suggest that the economic momentum was weak at the
end of 2021, with business indictors suggesting that profit margins in industry are being
squeezed. And indicators showing that goods surplus at a new high with CPI pulled back
under 2%. Travel and other activities requiring personal contact remain depressed
although China has evolved in its covid containment efforts, becoming more targeted
and less disruptive – there are signed that the economy is becoming a little more resilient
to virus outbreaks.
4.5 Scotland Specific -
The COVID-19 pandemic continues to affect society, the economy, and the Scottish
Budget, but to a lesser extent than previously expected. The success of the vaccination
programme has weakened the links between case numbers, hospitalisations and deaths,
and the public health response has shifted. In addition many businesses have found
ways of adapting to new ways of working. The economic recovery has been faster and
smoother than originally expected. 
In spite of the pace of the recovery, there is some evidence that the Scottish economy
has been lagging behind the UK. Compared to pre-pandemic levels, GDP, employment
and earnings have recovered more slowly than in the UK. In part, this can be explained
by a divergent sectoral and regional recovery, with areas like finance growing strongly in
London. However, some issues predate COVID-19: declining North Sea oil and gas
activity continues to act as a dampener, and Scotland’s demographics are reducing
labour market participation relative to the UK. We expect slower growth in earnings and
employment in Scotland to continue over the next few years.
4.6 World Outlook
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World growth was in recession in 2020 but recovered during 2021 until starting to lose
momentum in the second half of the year, though overall growth for the year is expected
to be about 6% and to be around 4-5% in 2022. Inflation has been rising due to
increases in gas and electricity prices, shipping costs and supply shortages, although
these were expected to subside during 2022, prior to the Ukraine conflict. While headline
inflation will fall sharply, core inflation will probably not fall as quickly as central bankers
would hope. It is likely that we are heading into a period where there will be a reversal of
world globalisation and a decoupling of western countries from dependence on China to
supply products, and vice versa. This is likely to reduce world growth rates from those in
prior decades. 
Geopolitical concerns over Ukraine will remain to the fore, with markets expected to
remain volatile as they react to each new development. While fighting continues,
diplomatic efforts remain ongoing in the background.
5. Prospect for Interest Rates
5.1 The Council has appointed Link Asset Services as its treasury advisor and part of their service
is to assist the Council to formulate a view on interest rates. Table H in Appendix 6 gives the
current Link Asset Services central view. 
6. Borrowing and Debt Strategy 2021/22 – 2031/32
6.1 Table E in Appendix 6 forecasts that the capital borrowing need (the Capital Financing
Requirement) will be almost fully funded with external borrowing which is a mixture of
short term and long term debt.
6.2 Against this background and the risk within the economic forecast, caution will be
adopted with the 2022/23 treasury operations.  The Section 95 Officer will monitor
interest rates in financial markets and adopt a pragmatic approach to changing
circumstances. 
6.3 If it was felt that there was a significant risk of fall in long and short term rates, e.g. due
to a marked increase of risks around recession or of risks of deflation, then long term
borrowing will be postponed, and potential rescheduling from fixed rate funding into
short term borrowing will be considered.
6.4 If it was felt that there was a significant risk of a much sharper rise in long and short
term rates than that currently forecast, perhaps arising from a greater than expected
increase in world economic activity or further increases in inflation risks, then the
portfolio position will be re-appraised with the likely action that fixed rate funding will be
drawn whilst interest rates were still relatively cheap. 
6.5 Any decisions will be reported to Members via the Members Bulletin at the next available
opportunity.
6.6 Approved sources of long and short term borrowing include:
Fixed Variable
PWLB X X
Local Authorities X X
Banks X X
Pension Funds X X
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Insurance Companies X X
Market – long term X X
Market – short term X X
Market – LOBOs X X
Overdraft X X
Internal (capital receipts / revenue balances) X X
Finance Leases X X
7. Investment Strategy
7.1 The Council’s investment policy has regard to the Local Government Investment (Scotland)
Regulations (and accompanying finance circular).  Council had also adopted both the
Treasury Management Code of Practice and the Prudential Code and is required to adopt
revised editions.  The day to day investment policies and practices are contained in the
Council’s Treasury Management Practices, which reflect the requirements of these codes.
These practices are regularly reviewed.
7.2 Key Objectives – Following the economic background above, the current investment climate
has one over-riding risk consideration - counterparty security risk.  As a result of these
underlying concerns, officers are implementing an operational investment strategy which
tightens the controls already in place in the approved investment strategy.  The Council’s
investment strategy primary objectives are safeguarding the re-payment of the principal and
interest of its investments on time first and ensuring adequate liquidity second – the
investment return being a third objective.  After this main principle the Council will ensure:
• It maintains a policy covering both the categories of investment types it will invest in,
criteria for choosing investment counterparties with adequate security, and monitoring their
security; and
• It has sufficient liquidity in its investments.  For this purpose it will set out procedures for
determining the maximum periods for which funds may prudently be committed.  These
procedures also apply to the Council’s prudential indicators covering the maximum
principal sums invested.
7.2.1 In accordance with the above, and in order to minimise the risk to investments, the Council
has below clearly stipulated the minimum acceptable credit quality of counterparties for
inclusion on the lending list.  The creditworthiness methodology used to create the
counterparty list fully accounts for the ratings, outlooks and watches published by all three
ratings agencies with a full understanding of what these reflect in the eyes of each agency.
Using the Link Asset Services ratings service banks’ ratings are monitored on a real time
basis with knowledge of any changes notified electronically as the agencies notify
modifications.
7.2.2 Furthermore, the Council’s officers recognise that ratings should not be the sole determinant
of the quality of an institution and that it is important to continually assess and monitor the
financial sector on both a micro and macro basis and in relation to the economic and political
environments in which institutions operate.  The assessment will also take account of
information that reflects the opinion of the markets.  To this end the Council will engage with
its advisors to maintain a monitor on market pricing such as “Credit Default Swaps” and
overlay that information on top of the credit ratings.  This is fully integrated into the credit
methodology provided by the advisors, Link Asset Services in producing its colour codings
which show the varying degrees of creditworthiness.
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7.2.3 Other information sources used will include the financial press, share price and other such
information pertaining to the banking sector in order to establish the most robust scrutiny
process on the suitability of potential investment counterparties.
7.2.4 The aim of the strategy is to generate a list of highly creditworthy counterparties which will
enable diversification, and thus avoidance of concentration, with the prime intention of
providing security of investment and minimisation of risk.
7.3 Investment Strategy – The process for investment strategy under the regulations covers a
wide range of Council investments and will be broadly managed in the following way:
• Short Term Cash – Cash relating to day to day cash flow will be maintained on a shorter
term basis in cash type products with consideration to the liquidity requirements outlined
above.
• Longer Term Cash – Cash relating to reserves, provisions and balances on the balance
sheet may be held for longer periods of time in cash type products or in longer term bonds
or funds depending on:
▪ Cash flow requirements:
▪ The underlying expectation for interest rates; and
▪ The economic background of these investments may be held longer term.
• Service Type Investments – These types of investments will predominately be policy
driven and approved by Members.  Shareholdings, development opportunities, loans to
third parties, equity instruments and investment properties held for rental returns) will be
regularly reviewed to judge the investment performance.
• Non Service Type Investments – Investments such as Joint venture delivery companies
such as Hub West Scotland and investments in regeneration partnerships and
development opportunities
7.4 Benchmarking and Monitoring Security, Liquidity and Yield in the Investment Service
A development for Member reporting is the consideration and approval of security and liquidity
benchmarks.  Yield benchmarks are currently widely used to assess investment performance. 
Discrete security and liquidity benchmarks are additional new requirements to the Member
reporting.  
7.4.1 These benchmarks are targets (not limits) and so may be breached from time to time,
depending on movements in interest rates and counterparty criteria.  The purpose of the
benchmark is that officers will monitor the current and trend position and amend the
operational strategy depending on any changes.  Any breach of the benchmarks will be
reported, with supporting reasons in the Mid-Year or Annual Report.
7.4.2 In the context of benchmarking, assessing security is a very subjective area to assess.
Security is currently evidenced by the application of minimum quality criteria to investment
counterparties, primarily through the use of credit ratings supplied by the three main credit
rating agencies (Fitch/ Moody’s and Standard and Poors).  Whilst this approach embodies
security considerations, benchmarking levels of risk is more problematic.  One method to
benchmark security risk is to assess the historic level of default against the minimum criteria
used in the Council’s investment strategy.  Table I in Appendix 6 shows average defaults for
differing periods of investment grade products for each Fitch/ Moody’s Standard and Poors
long term rating category.  
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7.4.3 The Council’s minimum long term rating criteria is currently “A-”, meaning the average
expectation of default for a one year investment in a counterparty with a “A” long term rating
would be 0.05% of the total investment (e.g. for a £1m investment the average loss would be
£500).  This is only an average - any specific counterparty loss is likely to be higher - but
these figures do act as a proxy benchmark for risk across the portfolio. 
7.4.4 As required by the CIPFA Treasury Management Code of Practice The Council will “ensure
that it has adequate, though not excessive, cash resources, borrowing arrangements,
overdrafts or standby facilities to enable it at all times to have the level of funds available to it
which are necessary for the achievement of its business/service objectives”.  In respect to
liquidity as defined above the Council seeks to maintain:
• Bank overdraft - £1m; and
• Liquid short term deposits of at least £5m available on an overnight basis.
7.4.5 Local measures of yield investment benchmarks that will be used to assess returns are:
• Internal returns above the 7 day LIBID rate;
• Internal returns above the 1 month LIBID rate for fixed investments; and
• Internal returns above the Council’s instant access account.
7.5  Council Permitted Investments – The Investments Regulations (Code on the Investment of
Money by Scottish Local Authorities) requires Council approval of all the types of investment
to be used and set appropriate limits for the amount that can be held for each investment type.
These types of investment are termed permitted investments and any investments used which
have not been approved as a permitted investment will be considered ultra vires.
7.5.1 The permitted investments which may be used in the forthcoming year are noted below.
Details of the risks, mitigating controls and limits associated with each of these permitted
categories are shown in Appendix 3.
• Cash Type Instruments
▪ Deposits with the Debt Management Account Facility (UK Government);
▪ Deposits with other local authorities or public bodies;
▪ Money Market Funds
o Constant Net Asset Value
o Low Volatility Net Asset Value;
▪ Call accounts, deposit accounts with financial institutions (banks and building
societies;
▪ Term deposits with financial institutions (banks and building societies);
▪ UK Government Gilts and Treasury Bills;
▪ Certificates of deposits will financial institutions (banks and building societies);
and
▪ Structured deposit facilities with banks and building societies (escalating
rates, de-escalating rates, etc).
• Other Investments
▪ Investment properties;
▪ Loans to third parties, including soft loans;
▪ Loans to a local authority company;
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▪ Shareholding in a local authority company;
▪ Non-local authority shareholdings;
▪ Joint venture delivery companies such as hub West Scotland;
▪ Regeneration partnerships and development opportunities;
▪ District Heating Schemes; and
▪ Local Authority Mortgage Scheme (LAMS).
7.5.2 Permitted investments related to the Common Good are also shown in Appendix 3, and where
applicable the same counterparty selection criteria as noted in 6.6 below will be applied.
7.6 Investment Counterparty Selection Criteria
The primary principle governing the Council’s investment criteria is the security of its
investments, although the yield or return on the investment is also a key consideration.  After
this main principle the Council will ensure:
• It maintains a policy covering both the categories of investment types it will invest in,
criteria for choosing investment counterparties with adequate security, and monitoring their
security; and
• It has sufficient liquidity in its investments.  For this purpose it will set out procedures for
determining the maximum periods for which funds may prudently be committed.  These
procedures also apply to the Council’s prudential indicators covering the maximum
principal sums invested.
7.6.1 The Section 95 Officer will maintain a counterparty list in compliance with the following criteria
and will revise the criteria and submit them to Council for approval as necessary.  This criteria
selects which counterparties the Council will choose from, rather than defining what its
investments are.  
7.6.2 Credit rating type and definitions are attached within Appendices 4 and 6.
7.6.3 Credit rating information is supplied by our treasury consultants on all active counterparties
that comply with the criteria below.  Any counterparty failing to meet the criteria would be
omitted from the counterparty (dealing) list.  Any rating changes, rating watches (notification of
a likely change), rating outlooks (notification of a possible longer term change) are provided to
officers almost immediately after they occur and this information is considered before dealing. 
For instance a negative rating watch applying to any counterparty at the minimum Council
criteria will be suspended from use, with all others being reviewed in light of market
conditions.
7.6.4 The criteria for providing a pool of high quality cash type investment counterparties is:
• Category 1 - Good Credit Quality – the Council will only use financial institutions
(including certificates of deposit and corporate bonds) which:
▪ Are UK banks; and/or
▪ Are non-UK and domiciled in a country which has a minimum Sovereign long
term rating of AA; The UK will be excluded from any Sovereign rating criteria.
▪ And have, as a minimum, the following Fitch, Moody’s and Standard and
Poors (S&P) credit ratings (where rated):
o Short Term – F1 (or equivalent from Fitch, Moody’s and S&P)
o Long Term – A- (or equivalent from Fitch, Moody’s and  S&P)
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The difference between the ratings will be reflected in the money limits as noted
in Table K in Appendix 6.
• Category 2 – Part nationalised UK banks – Lloyds Bank Group and Royal Bank of
Scotland Group. These banks can be included if they continue to be part nationalised or
they meet the ratings in Category 1 above.
• Category 3- The Council’s own banker for transactional purposes if the bank falls below
the above criteria specified in category 1, although in this case balances will be minimised
in both monetary size and time.
• Category 4 - Bank Subsidiary and Treasury Operations – the Council will use these
where the parent bank has the necessary ratings outlined in category 1.
• Category 5 - Building Societies – the Council will use all Societies which meet the
ratings for banks outlined in category 1.
• Category 6 - Money Market Funds – the Council will use either CNAV or LVNAV money
market funds that are AAA rated (by at least one of the 3 rating agencies).
• Category 7 - UK Government (including gilts, treasury bills and the DMADF)
• Category 8 - Local Authorities, etc
7.6.5 Due to the uncertainty in the financial markets it is recommended that the Investment Strategy
is approved which will provide officers with the flexibility to deal with any unexpected
occurrences.  Officers can restrict the pool of available counterparties from these criteria to
safer instruments and institutions.
7.6.6 The time limits for institutions on the Council’s cash type counterparty list are as noted in
Table J in Appendix 6.
7.6.7 The Council’s bankers are currently Virgin Money (previously known as the Clydesdale Bank
Plc) which falls within Category 3.  It is recognised that the money limit of £5million may be
breached for purely operational purposes on a temporary overnight basis only.  The Chief
Officer - Resources will endeavour to avoid this scenario but this allows for circumstances that
are outwith the Council’s control where funds may be deposited unexpectedly or at short
notice into the Council’s accounts after the dealing deadline for the day has passed.  In such a
circumstance the funds will require to be kept on an overnight basis in the Council’s bank
account until appropriate arrangements can be made for investment.
7.6.8 Table J does not include a monetary limit for category 7 which are funds deposited with the
UK Government namely the Debt Management Account Deposit Facility (DMADF).  This
facility allows local authorities to deposit surplus cash on flexible terms and receive a market
related rate of interest.  Funds are held by the Bank of England and the scheme carried the
Government’s own sovereign credit rating offering the highest available security and therefore
no maximum monetary limit has been set.
7.6.9 Country and sector considerations - Due care will be taken to consider the country, group
and sector exposure of the Council’s investments.  In part the country selection will be chosen
by the credit rating of the Sovereign state in Banks 1 above and the list of approved countries
for investments are detailed in Appendix 5.  In addition:
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• No more than 25% will be placed with any country outside of the UK at any time;
• Limits in place above will apply to Group companies; and
• Sector limits will be monitored regularly for appropriateness.
7.6.10Use of additional information other than credit ratings – Additional requirements under
the Code of Practice now requires the Council to supplement credit rating information.  Whilst
the above criteria relies primarily on the application of credit ratings to provide a pool of
appropriate counterparties for officers to use, additional operational market information will be
applied before making any specific investment decision from the agreed pool of
counterparties.  This additional market information (for example Credit Default Swaps,
negative rating watches/outlooks) will be applied to compare the relative security of differing
investment counterparties.
7.6.11Economic Investment Considerations – Current forecasts on shorter-term interest rates,
on which investment decisions are based, show a potential for the current 0.75% Bank Rate to
continue to slowly increase.  The Council’s investment decisions are based on comparisons
between the rises priced into market rates against the Council’s and advisers own forecasts.   
7.6.12There is an operational difficulty arising from the current economic situation. There is
currently little value investing longer term unless credit quality is reduced.  Whilst some
selective options do provide additional yield uncertainty over counterparty creditworthiness
suggests shorter dated investments would provide better security.
7.6.13The criteria for choosing counterparties set out above provide a sound approach to
investment in “normal” market circumstances.  Whilst Members are asked to approve this
base criteria above, under the exceptional current market conditions the Section 95 Officer
(Chief Officer - Resources) may temporarily restrict further investment activity to those
counterparties considered of higher credit quality than the minimum criteria set out for
approval.  These restrictions will remain in place until the banking system returns to “normal”
conditions.  Similarly the time periods for investments will be restricted.
7.6.14Examples of these restrictions would be the greater use of the Debt Management Deposit
Account Facility (DMADF – a Government body which accepts local authority deposits),
Money Market Funds and strongly rated.  The credit criteria have been amended to reflect
these facilities.
7.7 Sensitivity to Interest Rate Movements - Whilst most of the risks facing the treasury
management service are addressed elsewhere in this report (credit risk, liquidity risk, market
risk, maturity profile risk), the impact of interest rate risk is discussed but not quantified.  
Table K in Appendix 6 highlights the estimated impact of a 1% increase/decrease in all
interest rates to the estimated treasury management costs/income for next year.  That
element of the debt and investment portfolios which are of a longer term, fixed interest rate
nature will not be affected by interest rate changes.
7.8 Ethical Investments - This is the placing of funds and selecting investments in a
manner that reflects an authority’s ethical values. Generally, two sets of criteria are
drawn up – negative and positive values whereby investments are to be avoided or
encouraged. 
7.8.1 The following policy statement was approved on 25 October 2017:
7.8.2  The Council will not knowingly invest directly in organisations (including financial
institutions and money market funds) whose activities and practices pose a risk of
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serious harm to individuals and/or groups, or whose activities are inconsistent with
the Council’s vision, values and priorities.  This could include avoiding direct
investment in organisations with material links to:
• Human rights abuse (e.g. child labour);
• Environmentally harmful activities (e.g. destruction of habitat); and
• Socially harmful activities (e.g. gambling)
7.8.3  In order to give effect to its commitment to this policy the Chief Officer - Resources
contacted all investment counterparties on 9 January 2018 advising of our policy.
7.8.4  In accordance with the further commitments that were given in October 2017 it is
considered that this policy statement remains relevant and does not require to be
amended at this time.
8. Treasury Management Limits on Activity
8.1 There are four further treasury activity limits, which were previously prudential indicators.  The
purpose of these prudential indicators is to contain the activity of the treasury function within
certain limits, thereby managing risk and reducing the impact of an adverse movement in
interest rates.  However, if these are set to be too restrictive they will impair the opportunities
to reduce costs.  
• Upper limits on variable interest rate exposure – This indicator identifies a maximum limit
for variable interest rates based upon the debt position net of investments
• Upper limits on fixed interest rate exposure – Similar to the previous indicator this covers a
maximum limit on fixed interest rates.
• Maturity structures of borrowing – These limits are set to reduce the Council’s exposure to
large fixed rate sums falling due for refinancing, and are required for upper and lower
limits.
• Total principal funds invested for greater than 364 & 365 days - These limits are set with
regard to the Council’s liquidity requirements and to reduce the need for early sale of an
investment, and are based on the availability of funds after each year-end.
The proposed indicators are shown within Table L in Appendix 6.
8.2 The upper limit applies to the maturity structure of fixed interest rate borrowing in Table M. 
The level has been set to take account of the way that local authorities have to record certain
market loans where the maturity date is deemed to be the next call date rather than the
eventual repayment date.
9. Performance Indicators
9.1 The Code of Practice on Treasury Management requires the Council to set performance
indicators to assess the adequacy of the treasury function over the year.  These are distinct
historic indicators, as opposed to the prudential indicators, which are predominantly forward
looking.  Examples of performance indicators often used for the treasury function are:
• Debt – Borrowing - Average rate of borrowing for the year compared to average available;
• Debt – Average rate movement year on year; and
• Investments – Internal returns above the 7 day LIBID rate.
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9.2 The results of these indicators will be reported in the Treasury Annual Report for 2021/22.
10. Treasury Management Advisors
10.1 The Council uses Link Asset Services as its treasury management advisors.  The company
provides a range of services which include:
• Technical support on treasury matters, capital finance issues and the drafting of Member
reports;
• Economic and interest rate analysis;
• Debt services which includes advice on the timing of borrowing;
• Debt rescheduling advice surrounding the existing portfolio;
• Generic investment advice on interest rates, timing and investment instruments; and
• Credit ratings/market information service comprising the three main credit rating agencies.
10.2 The current treasury advisor contract was awarded to Link Asset Services following a quick
quote exercise and commencing on 1 May 2021 until 30 April 2023, with an option to extend
for one year. 
10.3 The Council recognises that responsibility for treasury management decisions remains with
the organisation at all times and will ensure that undue reliance is not place upon external
service providers.
10.4 The Council also recognises that there is value in employing external providers of treasury
management services in order to acquire access to specialist skills and resources.  The
Council will ensure that the terms of their appointment and the methods by which their value is
assessed are properly agreed and documented, and subjected to regular review.
10.5 Whilst the advisers provide support to the internal treasury function the final decision on
treasury matters remains with the Council.
11. The Monitoring of Investment Counterparties
11.1 The credit rating of counterparties will be monitored regularly.  The Council receives credit
rating information (changes, rating watches and rating outlooks) from Link Asset Services as
and when ratings change, and counterparties are checked promptly.  On occasion ratings may
be downgraded when an investment has already been made.  The criteria used are such that
a minor downgrading should not affect the full receipt of the principal and interest.  Any
counterparty failing to meet the criteria will be removed from the list immediately by the Chief
Officer - Resources and, if required, new counterparties which meet the criteria will be added
to the list. 
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West Dunbartonshire Council and Common Good Funds Permitted Investments,
Associated Controls and Limits
Type of
Investment
Treasury Risks Mitigating Controls Council and
Common
Good Limits
Cash Type Instruments
Deposits with
the Debt
Management
Account Facility
(UK
Government)
(Very low risk)
This is a deposit with the
UK Government and as
such counterparty and
liquidity risk is very low, and
there is no risk to value. 
Deposits can be between
overnight and 6 months.
Little mitigating controls
required.  As this is a UK
Government investment the
monetary limit is unlimited to
allow for a safe haven for
investments.
As shown in
Table J.
Deposits with
other local
authorities or
public bodies
(Very low risk)
These are considered quasi
UK Government debt and
as such counterparty risk is
very low, and there is no
risk to value.  Liquidity may
present a problem as
deposits can only be
broken with the agreement
of the counterparty, and
penalties can apply.
Deposits with other non-
local authority bodies will
be restricted to the overall
credit rating criteria.
Little mitigating controls
required for local authority
deposits, as this is a quasi UK
Government investment.
Non- local authority deposits
will follow the approved credit
rating criteria.
As shown in
Table J.
Money Market
Funds (MMFs)
(Very low risk)
Pooled cash investment
vehicle which provides very
low counterparty, liquidity
and market risk.  These will
primarily be used as
liquidity instruments.
Funds will only be used where
the MMFs has an “AAA” rated
status from either Fitch,
Moody’s or Standard and
Poor’s.
As shown in
Table J.
Call account
deposit
accounts with
financial
institutions
(banks and
building
societies) (Low
risk depending
on credit
rating)
These tend to be low risk
investments, but will exhibit
higher risks than the first
three categories above. 
Whilst there is no risk to
value with these types of
investments, liquidity is
high and investments can
be returned at short notice. 
The counterparty selection
criteria approved above
restricts lending only to high
quality counterparties,
measured primarily by credit
ratings from Fitch, Moody’s and
Standard and Poors.  
On day to day investment
dealing with this criteria will be
further strengthened by the use
of additional market
intelligence.
As shown in
Table J.
Appendix 3
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Type of
Investment
Treasury Risks Mitigating Controls Council and
Common
Good Limits
Term deposits
with financial
institutions
(banks and
building
societies) (Low
to medium risk
depending on
period & credit
rating)
These tend to be low risk
investments, but will exhibit
higher risks than the first
three categories above. 
Whilst there is no risk to
value with these types of
investments, liquidity is low
and term deposits can only
be broken with the
agreement of the
counterparty, and penalties
may apply.  
The counterparty selection
criteria approved above
restricts lending only to high
quality counterparties,
measured primarily by credit
ratings from Fitch, Moody’s and
Standard and Poors.  
On day to day investment
dealing with this criteria will be
further strengthened by the use
of additional market
intelligence.
As shown in
Table J.
Government
Gilts and
Treasury Bills
(Very low risk)
These are marketable
securities issued by the UK
Government and as such
counterparty and liquidity
risk is very low, although
there is potential risk to
value arising from an
adverse movement in
interest rates (no loss if
these are held to maturity.  
Little counterparty mitigating
controls are required, as this is
a UK Government investment.  
The potential for capital loss will
be reduced by limiting the
maximum monetary and time
exposures.
As shown in
Table J.
Certificates of
deposits with
financial
institutions (Low
risk)
These are short dated
marketable securities
issued by financial
institutions and as such
counterparty risk is low, but
will exhibit higher risks than
the first three categories
above.  There is risk to
value of capital loss arising
from selling ahead of
maturity if combined with
an adverse movement in
interest rates.  Liquidity risk
will normally be low.
The counterparty selection
criteria approved above
restricts lending only to high
quality counterparties,
measured primarily by credit
ratings from Fitch, Moody’s and
Standard and Poors.  
On day to day investment
dealing with this criteria will be
further strengthened by the use
of additional market
intelligence.
As shown in
Table J.
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Type of
Investment
Treasury Risks Mitigating Controls Council and
Common
Good Limits
Structured
deposit facilities
with banks and
building
societies
(escalating / de-
escalating rates,
etc.) (Low to
medium risk
depending on
period & credit
rating)
These tend to be medium
to low risk investments, but
will exhibit higher risks than
the first three categories
above.  Whilst there is no
risk to value with these
types of investments,
liquidity is very low and
investments can only be
broken with the agreement
of the counterparty
(penalties may apply).  
The counterparty selection
criteria approved above
restricts lending only to high
quality counterparties,
measured primarily by credit
ratings from Fitch, Moody’s and
Standard and Poors.  
On day to day investment
dealing with this criteria will be
further strengthened by the use
of additional market
intelligence.
As shown in
Table J.
Corporate
Bonds (Medium
to high risk
depending on
period & credit
rating)
These are marketable
securities issued by
financial and corporate
institutions.  Counterparty
risk will vary and there is
risk to value of capital loss
arising from selling ahead
of maturity if combined with
an adverse movement in
interest rates.  Liquidity risk
will be low
The counterparty selection
criteria approved above
restricts lending only to high
quality counterparties,
measured primarily by credit
ratings from Fitch, Moody’s and
Standard and Poors.  
Corporate bonds will be
restricted to those meeting the
base criteria.  
On day to day investment
dealing with this criteria will be
further strengthened by the use
of additional market
intelligence.
As shown in
Table J.
Other Types of Investments
Investment
properties
These are properties that
are not used to facilitate
service delivery but are
held solely to earn rentals
or for capital appreciation
or both.  These are highly
illiquid assets with high risk
to value (the potential for
property prices to fall or for
rental voids).  
In larger investment portfolios
some small allocation of
property based investment may
counterbalance/compliment the
wider cash portfolio.
Property holding will be re-
valued regularly and reported
annually with gross and net
rental streams.
The Section 95
Officer will
determine
monetary and
time limits
managing risk
accordingly, to
the maximum
total as noted
in Table L of
£7m. 
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Type of
Investment
Treasury Risks Mitigating Controls Council and
Common
Good Limits
Loans to third
parties, including
soft loans
These are service
investments either at
market rates of interest or
below market rates (soft
loans).  These types of
investments may exhibit
credit risk and are likely to
be highly illiquid.
Each third party loan requires
Member approval and each
application is supported by the
service rational behind the loan
and the likelihood of partial or
full default.
The Section 95
Officer will
determine
monetary and
time limits
managing risk
accordingly, to
the maximum
total as noted
in Table L of
£7m.
Loans to a local
authority
company
These are service
investments either at
market rates of interest or
below market rates (soft
loans).  These types of
investments may exhibit
credit risk and are likely to
be highly illiquid.
Each loan to a local authority
company requires Member
approval and each application
is supported by the service
rational behind the loan and the
likelihood of partial or full
default.
The Section 95
Officer will
determine
monetary and
time limits
managing risk
accordingly, to
the maximum
total as noted
in Table L of
£7m.
Shareholdings in
a local authority
company
These are service
investments which may
exhibit market risk and are
likely to be highly illiquid.
Each equity investment in a
local authority company
requires Member approval and
each application will be
supported by the service
rational behind the investment
and the likelihood of loss.
The Section 95
Officer will
determine
monetary and
time limits
managing risk
accordingly, to
the maximum
total as noted
in Table L of
£7m.
Non-local
authority
shareholdings
These are non-service
investments which may
exhibit market risk, be only
considered for longer term
investments, likely to be
liquid.
Any non-service equity
investment will require separate
Member approval and each
application will be supported by
rational behind the service the
investment and the likelihood of
loss.
The Section 95
Officer will
determine
monetary and
time limits
managing risk
accordingly, to
the maximum
total as noted
in Table L of
£7m.
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Type of
Investment
Treasury Risks Mitigating Controls Council and
Common
Good Limits
Joint venture
delivery
companies such
as hub West
Scotland
Public sector organisations
across a hub territory will
work in partnership with
each other, and a private
sector delivery partner, in a
joint venture delivery
company called hub West
Scotland.
.
Any investment in hub West
Scotland requires approval
from the Section 95 Officer
(Chief Officer - Resources) and
the Chief Executive in
consultation with the Leader of
the Council and the Leader of
the Opposition and each
application will be supported by
the service rational behind the
investment and the likelihood of
loss.
The Section 95
Officer will
determine
monetary and
time limits
managing risk
accordingly, to
the maximum
total as noted
in Table L of
£7m.
Regeneration
partnerships and
development
opportunities 
Investments undertaken
with the prime intention of
local area regeneration.
Any investment in a
regeneration partnership /
development opportunity
requires Member approval with
each application supported by
rational behind the investment
and the likelihood of loss.
The Section 95
Officer will
determine
monetary and
time limits
managing risk
accordingly, to
the maximum
total as noted
in Table L of
£7m.
Investment in
Projects
procured and
managed by
third parties e.g.
District Heating
Schemes
Investments undertaken to
assist in facilitating third
party projects where the
Council has an interest in
the successful outcome of
the project. Expectation of
a financial return for the
Council.
Any investment in such projects
requires Member approval and
each application will be
supported by a business case
for the investment and the
expectation of a financial
benefit to the Council.
The Section 95
Officer will
determine
monetary and
time limits
managing risk
accordingly, to
the maximum
total as noted
in Table L of
£7m.
Local Authority
Mortgage
Scheme (LAMS)
These are service
investments at market rates
of interest.  Under this
scheme the Council is
required to place funds for
a number of  years with the
bank which is participating
in this scheme
Any investment in the LAMS
requires Member approval and
each application will be
supported by the service
rational behind the investment
and the likelihood of loss.
The Section 95
Officer will
determine
monetary and
time limits
managing risk
accordingly, to
the maximum
total as noted
in Table L of
£7m.
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Type of Rating Rating Explanation
Fitch
-Short Term
F1+ Indicates exceptionally strong capacity for timely payment of
financial commitments
F1 Indicates strong capacity for timely payment of financial
commitments
Fitch
- Long Term
AA- Indicates very strong capacity for timely payment of financial
commitments and this capacity is not significantly vulnerable
to foreseeable events
A- Indicates strong capacity for timely payment of financial
commitments.  This capacity may, nevertheless, be more
vulnerable to changes in circumstances or in economic 
conditions than is the case for higher ratings
Moody’s
- Short Term
P-1 Banks based Prime-1 for deposits offer superior credit quality
and a very strong capacity for timely payment of short term 
deposit obligations
Moody’s
- Long Term
Aa Offer excellent credit quality, with susceptibility to long term
risks with a vulnerability to greater fluctuations within 
protective elements
A Offer excellent credit quality, but elements suggest a
Susceptibility to impairment over the long term
Standard & Poors
- Short Term
A-1 Indicates a strong capacity to meet institutions financial
commitments.  Within this category, certain obligors are designated
with a plus sign (+).  This indicates that the obligor’s capacity 
to meet its financial commitments is EXTREMELY STRONG
Standard & Poors
- Long Term
AA- Indicates strong capacity for timely payment of financial
commitments
A- Indicates strong capacity for timely payment of financial
commitments.  This capacity may, nevertheless, be more 
susceptible to the adverse effects of changes in circumstances
or in economic conditions than is the case for higher rated 
category
Appendix 4
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West Dunbartonshire Council and Common Good Funds Permitted Investments,
Approved Countries for Investments
Based on lowest available rating
AAA  
• Australia
• Denmark
• Germany
• Luxembourg
• Netherlands
• Norway
• Singapore
• Sweden
• Switzerland
AA+
• Canada
• Finland
• U.S.A.
AA
• Abu Dhabi (UAE)
• France
AA-
• Belgium
• Hong Kong
• Qatar
• U.K.
Please note that this is the list will be updated as required on an ongoing basis
Appendix 5
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West Dunbartonshire Council Prudential and Treasury Indicators
General Services 39,046   51,506 76,526   47,104   30,083         17,097         13,461         13,402         13,308         13,103         13,103
Capital receipts 10 0 0 0 0 0 0 0 0 0 0
Capital grants 9,583 17,292 27,578 14,379 13,529 9,556 6,648 6,648 6,648 6,648 6,648
Revenue 63 0 0 0 0 0 0 0 0 0 0
Other funding 1,173 42 0 0 0 0 0 0 0 0 0
Net financing need for the year 28,217 34,172 48,948 32,725 16,554 7,541 6,813 6,754 6,660 6,455 6,455
HRA 46,907 47,233 52,047 34,424 32,531 29,926 17,115 17,087 17,429 17,778 17,314
Capital receipts 0 0 0 0 0 0 0 0 0 0 0
Capital grants 3,656 17,060 9,140 2,640 3,520 3,520 0 0 0 0 0
Revenue 7,927 9,179 9,228 8,722 7,949 7,418 4,923 4,502 4,253 4,191 3,923
Other funding 91 0 0 0 0 0 0 0 0 0 0
Net financing need for the year 35,233 20,994 33,678 23,063 21,062 18,989 12,192 12,585 13,176 13,586 13,391
General Services 39,046 51,506 76,526 47,104 30,083 17,097 13,461 13,402 13,308 13,103 13,103
HRA 46,907 47,233 52,047 34,424 32,531 29,926 17,115 17,087 17,429 17,778 17,314
Capital Expenditure 85,953 98,739 128,573 81,528 62,614 47,023 30,576 30,489 30,737 30,881 30,417
Capital receipts 10 0 0 0 0 0 0 0 0 0 0
Capital grants 13,239 34,352 36,718 17,019 17,049 13,076 6,648 6,648 6,648 6,648 6,648
Revenue 7,990 9,179 9,228 8,722 7,949 7,418 4,923 4,502 4,253 4,191 3,923
Other funding 1,264 42 0 0 0 0 0 0 0 0 0
Net financing need for the year 63,450 55,166 82,626 55,788 37,616 26,530 19,005 19,339 19,836 20,041 19,846
Capital Financing Requirement
CFR – General Services         392,588   420,860         463,023   486,836   492,862   488,744   483,803   479,083   474,029   466,856   462,482 
CFR – HRA         306,298   320,274         346,010   360,002   371,559   380,751   381,451   381,927   382,541   383,308   384,366 
Total CFR         698,886   741,135         809,033   846,838   864,421   869,495   865,254   861,010   856,570   850,164   846,848 
Movement in CFR 52,696   42,249 67,898   37,805   17,583 5,074         (4,241)        (4,244)        (4,440)        (6,406)        (3,316)
Movement in CFR represented by
Net financing need for the year (above) 63,450   55,166 82,626   55,788   37,616         26,530         19,005         19,339         19,836         20,041         19,846 
Less scheduled debt amortisation and other financing
movements          (10,755)  (12,917)         (14,729)  (17,983)  (20,032)      (21,455)      (23,246)      (23,583)      (24,276)      (26,447)      (23,162)
Movement in CFR 52,696   42,249 67,898   37,805   17,583 5,074         (4,241)        (4,244)        (4,440)        (6,406)        (3,316)
Table A - Net Capital Financing Need
Table B - Capital Financing Requirement
Forecast
2024/25
Forecast
2021/22
Forecast
2023/24
Forecast
2024/25
Forecast
2022/23
Forecast
2021/22
Forecast
2025/26
Forecast
2021/22
General Services and HRA Shown Separately
General Services and HRA Combined
Forecast
2022/23
Forecast
2023/24
Forecast
2024/25
Forecast
2025/26
Forecast
2026/27
Forecast
2025/26
£000 Forecast
2026/27
Forecast
2027/28
Forecast
2028/29
Forecast
2029/30
Financed by:
Forecast
2028/29
Forecast
2029/30
Forecast
2025/26
Forecast
2022/23
Forecast
2027/28
Financed by:
Forecast
2027/28
Forecast
2029/30
£000
Forecast
2029/30
Forecast
2024/25
Financed by:
£000 Forecast
2026/27
Forecast
2023/24
£000 Forecast
2021/22
Forecast
2022/23
Forecast
2028/29
Forecast
2026/27
Forecast
2023/24
Forecast
2027/28
Forecast
2028/29
Forecast
2030/31
Forecast
2031/32
Forecast
2030/31
Forecast
2031/32
Forecast
2030/31
Forecast
2031/32
Forecast
2031/32
Forecast
2030/31
Appendix 6
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West Dunbartonshire Council Prudential and Treasury Indicators
Table C - Internal Loan Fund Repayment Profile (excluding PPP repayments)
£000 £000 £000
Under 12 months 2,527 7,017 9,545
2 years to 5 years 22,121 36,314 58,436
6 years to 10 years 41,323 61,543 102,866
11 years to 15 years 49,846 57,689 107,535
16 years to 20 years 47,793 65,251 113,045
21 years to 25 years 42,074 69,823 111,897
26 years to 30 years 36,673 52,710 89,383
31 years to 35 years 36,261 34,069 70,330
36 years to 40 years 23,468 19,776 43,244
41 years to 45 years 12,729 6,670 19,399
46 years to 50 years 12,640 4,328 16,968
51 years to 55 years 17,482 6,656 24,139
56 years to 60 years 27,070 9,506 36,576
60  years plus 133,862 1,176 135,038
General Services 8.07% 7.77% 8.53% 9.17% 10.52% 11.03% 11.01% 10.83% 10.89% 11.66% 11.88%
HRA 25.07% 27.08% 28.30% 31.44% 32.35% 37.79% 38.83% 39.33% 39.47% 39.98% 40.94%
External Debt
Debt at 1 April 548,659 604,941 650,563 721,601 762,997 784,901 794,686 795,107 794,627 793,984 792,061
New Borrowing - CFR 56,282 45,621 71,038 41,396 21,903 9,786 420 (479) (643) (1,924) 1,536
Debt at 31 March 604,941 650,563 721,601 762,997 784,901 794,686 795,107 794,627 793,984 792,061 793,597
Long Term Liabilities at 1 April 96,292 92,614 89,242 86,102 82,510 78,190 73,479 68,818 65,053 61,256 56,774
Change in Long Term Liabilities (3,678) (3,372) (3,140) (3,592) (4,320) (4,712) (4,661) (3,765) (3,797) (4,482) (4,853)
Long Term Liabilities at 31 March 92,614 89,242 86,102 82,510 78,190 73,479 68,818 65,053 61,256 56,774 51,921
Gross Debt at 31 March         697,556   739,805         807,703   845,508   863,091   868,165   863,924   859,680   855,240   848,834   845,518 
Capital Financing Requirement         698,886   741,135         809,033   846,838   864,421   869,495   865,254   861,010   856,570   850,164   846,848 
Under / (Over) Borrowing 1,330         1,330 1,330         1,330         1,330 1,330 1,330 1,330 1,330 1,330 1,330
Table D - Ratio of Financing Costs to Net Revenue Stream
Forecast
2027/28
Forecast
2028/29
Forecast
2022/23
Forecast
2029/30
Forecast
2021/22
HRA TotalGeneral
Services
Forecast
2026/27
Forecast
2025/26
Forecast
2024/25
Forecast
2023/24
Forecast
2027/28
Forecast
2026/27
Table E - Gross External Debt compared to the Underlying Need to Borrow (CFR)
£000 Forecast
2021/22
Forecast
2029/30
Forecast
2022/23
Forecast
2025/26
Forecast
2028/29
Forecast
2023/24
Forecast
2024/25
Forecast
2031/32
Forecast
2030/31
Forecast
2031/32
Forecast
2030/31
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West Dunbartonshire Council Prudential and Treasury Indicators
External Debt        665,436   715,619         793,761   839,297   863,391   874,155   874,617   874,090   873,383   871,267   872,957
Long Term Liability        101,876   98,166 94,712   90,761   86,009         80,826         75,700         71,558         67,381         62,451         57,113
Total        767,311   813,785         888,473   930,058   949,400   954,981   950,317   945,648   940,764   933,718   930,070
External Debt        725,930   780,675         865,921   915,597   941,881   953,624   954,128   953,553   952,781   950,473   952,317
Long Term Liability        111,137   107,090         113,322   109,012   103,828         98,174         92,581         88,063         83,507         78,128         72,305
Total        837,067   887,766         979,243  1,024,609  1,045,709   1,051,798   1,046,709   1,041,616   1,036,288   1,028,601   1,024,622
Bank Rate 0.75% 1.00% 1.00% 1.25% 1.25% 1.25% 1.25% 1.25% 1.25% 1.25% 1.25% 1.25% 1.25%
5yr PWLB Rate 2.20% 2.30% 2.30% 2.30% 2.30% 2.30% 2.30% 2.30% 2.30% 2.30% 2.30% 2.30% 2.30%
10yr PWLB Rate 2.30% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40%
25yr PWLB Rate 2.40% 2.50% 2.50% 2.60% 2.60% 2.60% 2.60% 2.60% 2.60% 2.60% 2.60% 2.60% 2.60%
50yr PWLB Rate 2.20% 2.30% 2.30% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40% 2.40%
Long term rating 1 year 2 years 3 years 4 years 5 years
AAA 0.04% 0.10% 0.17% 0.26% 0.35%
AA 0.02% 0.04% 0.09% 0.16% 0.24%
A 0.05% 0.15% 0.27% 0.40% 0.55%
BBB 0.15% 0.40% 0.70% 1.05% 1.41%
BB 0.65% 1.84% 3.22% 4.60% 5.84%
B 2.76% 6.66% 10.26% 13.35% 15.82%
CCC 18.96% 26.64% 31.60% 35.08% 37.88%
Note - The AAA default risk is actually higher than the AA default risk due the number of AAA rated institutions left
£000
Link Asset Services Interest Rate View Dec-22
Forecast
2026/27
Forecast
2022/23
Forecast
2023/24
Forecast
2024/25£000
Table F - Operational Boundary
Forecast
2027/28
Forecast
2028/29
Table H - Interest Rate Forecast (February 2022)
Table I - Historic Risk of Default
Forecast
2027/28
Forecast
2021/22
Table G - Authorised Limit
Forecast
2029/30
Forecast
2028/29
Forecast
2025/26
Sep-24Jun-22 Mar-23
Forecast
2029/30
Forecast
2021/22
Forecast
2022/23
Forecast
2023/24
Mar-22
Forecast
2030/31
Jun-23 Sep-23 Dec-23 Mar-24
Forecast
2024/25
Forecast
2025/26
Forecast
2026/27
Sep-22
Forecast
2031/32
Mar-25
Forecast
2030/31
Dec-24Jun-24
Forecast
2031/32
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West Dunbartonshire Council Prudential and Treasury Indicators
Investment Fitch
Category (or
equivalent)
Money
Limit
F1+ / AA- £10million
F1 / A- £5 million
2 F1/A- £10 million
(per group)
3 £5 million
4 £5 million
5 As in 1 above
£10million
and
£5million
Sector Limit £25 million
Fund Limit £5 million
7 No limit
Sector imit £25 million 
Fund Limit £5 million
£000 2021/22
Estimate 1% -1%
Variable Rate Debt Payments N/A N/A N/A
Variable Rate Investment income 75 150 (75)
Table K - Sensitivity to Interest Rate Movements
1
8
Overnight
364 days
364 days
Table J -  Counterparty Limits
Time Limit
6
364 days
364 days
364 days
6 months
Very liquid no time limit
applies
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West Dunbartonshire Council Prudential and Treasury Indicators
Limits on fixed interest
rates
Limits on variable
interest rates
Lower  Upper Lower Upper Lower Upper
Under 12 months 0% 50% 0% 50% 0% 50%
12 months to 2 years 0% 50% 0% 50% 0% 50%
2 years to 5 years 0% 50% 0% 50% 0% 50%
5 years to 10 years 0% 50% 0% 50% 0% 50%
10 years to 20 years 0% 50% 0% 50% 0% 50%
20 years to 30 years 0% 50% 0% 50% 0% 50%
30 years to 40 years 0% 50% 0% 50% 0% 50%
40 years to 50 years 0% 100% 0% 100% 0% 100%
50 years to 60 years 0% 100% 0% 100% 0% 100%
60 years to 70 years 0% 100% 0% 100% 0% 100%
Principal sums invested
> 364 & 365 days
100% 100% 100%
50% 50% 50%
£nil £7m £nil £7m £nil £7m
Maturity Structure of fixed interest rate borrowing
Upper
2022/23
Upper
2023/24
Upper
Table L- Treasury Management Limits on Activity
2021/22
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