Democracy Spraffa

Item 13 - Appendix 1-5

West Dunbartonshire Council · 15 June 2022
Back to Audit Committee — 15 June 2022 and its agenda

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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:

Page 14

• 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

Page 15

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.

Page 16

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.

Page 17

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

Page 18

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.

Page 19

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.

Page 20

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.

Page 21

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.

Page 22

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

Page 23

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