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Treasury Management Strategy and Annual Investment Strategy

Argyll and Bute Council · 13 March 2025
Back to Audit and Scrutiny Committee — 13 March 2025 and its agenda

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ARGYLL AND BUTE COUNCIL   AUDIT AND SCRUTINY COMMITTEE
FINANCIAL SERVICES           13 MARCH 2025
TREASURY MANAGEMENT STRATEGY AND ANNUAL INVESTMENT STRATEGY
2025-26
1.0 EXECUTIVE SUMMARY
1.1 The Local Government in Scotland Act 2003 requires the council to have regard
to the CIPFA Code of Practice on Treasury Management (revised 2021), the
Code.  The Treasury Management Strategy, including prudential and treasury
Indicators, and the Annual Investment Strategy is a key reporting requirement,
providing a comprehensive statement of treasury management policies and
planned activity for the financial year ahead.  
1.2 This report, prepared in compliance with the Code, covers the following:
• Capital Expenditure and Financing;
• An economic and interest rate update;
• Borrowing Strategy;
• Investment Strategy; and
• Prudential and Treasury Indicators 2025-28.
1.3 The report concludes that:
a) The Treasury Management Strategy provides a comprehensive
statement of treasury management policies and planned activities,
covering the relevant treasury and prudential indicators, the current and
projected debt positions, and the Annual Investment Strategy for 2025-
26.
b) A key driver of treasury management activity is the council’s capital
investment plans.  Prudential indicators reflect the output from these
plans and are designed to ensure that the council’s capital investment
plans are affordable, prudent and sustainable.  Within the range of
prudential indicators, there are several key indicators to ensure that the
authority operates its activities within well defined limits.
c) Whilst the Capital Financing Requirement represents an underlying
need to borrow, the council is currently maintaining an under-borrowed
position. This strategy is prudent while medium and longer dated
borrowing rates are expected to fall from their current levels, albeit that
considerable uncertainty remains around interest rate forecasts.
d) The council’s revenue budget includes appropriate provision for
financing costs of capital expenditure.  The key principles of the

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1.4 
borrowing strategy will be to minimise debt interest costs over the
medium term and to achieve a more even spread in the debt maturity
profile. 
e) The council’s investment priorities will be security, liquidity and yield
(return).  A prudent approach to managing investment risk has been
adopted.  Exposure to credit risk will be limited by ensuring that all
investments are placed with the higher rated bodies.  A balanced view
of risk against return will be taken in respect of all investments.  It is
anticipated that return on investments will be limited in 2025-26, as a
result of Bank Rate forecasts and the over-riding principle of risk
aversion. 
The Audit and Scrutiny Committee is requested to:  
a) Note that the report has been considered by the Policy and Resources
Committee on 20 February 2025 and approved by full Council on 27
February 2025. Any recommendations arising from further scrutiny by
the Audit and Scrutiny Committee will require to be presented to full
Council at the earliest opportunity; and   
b) Consider and endorse the Treasury Management Strategy and Annual
Investment Strategy for 2025-26, and the Prudential and Treasury
Indicators for 2025-26 to 2027-28.

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ARGYLL AND BUTE COUNCIL                      AUDIT AND SCRUTINY COMMITTEE                                                                          
FINANCIAL SERVICES                                                   13 MARCH 2025 
TREASURY MANAGEMENT STRATEGY AND ANNUAL INVESTMENT STRATEGY
2025-26 
2. INTRODUCTION 
2.1 Background 
2.1.1 The Chartered Institute of Public Finance and Accountancy (CIPFA) defines
treasury management as ‘The management of the local authority’s borrowing,
investments and cash flows, including its banking, money market and capital
market transactions; the effective control of the risks associated with those
activities; and the pursuit of optimum performance consistent with those risks.’ 
2.1.2 The authority is required to operate a balanced revenue budget, which broadly
means that cash raised during the year will meet cash expenditure.  In addition,
the authority’s capital plans indicate the borrowing and longer term cash flow
planning, required to meet its capital spending obligations.  The treasury
management operation ensures that cash flow is adequately planned, with cash
being available when it is needed.   
2.1.3 Surplus monies are invested in low risk counterparties or instruments
commensurate with the council’s low risk appetite, providing adequate liquidity
initially before considering investment return.  The management of longer term
cash flow may involve arranging long or short term loans or using longer term
cash flow surpluses. On occasion, when it is prudent and economic, any debt
previously drawn may be restructured to meet risk or cost objectives. 
2.1.4 The contribution the treasury management function makes to the authority is
critical, as the balance of debt and investment operations ensure liquidity or the
ability to meet spending commitments as they fall due, either on day to day
revenue or for larger capital projects.  The treasury operations will see a balance
of the interest costs of debt and the investment income arising from cash deposits,
impacting available resources.  Since cash balances generally result from
reserves and balances, it is paramount to ensure adequate security of the sums
invested, as a loss of principal will in effect result in a loss to the General Fund
balance. 
2.2 Reporting Requirements 
2.2.1 The authority is required to receive and approve, as a minimum, three main
treasury reports each year:

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1) The Treasury Management Strategy, including prudential and treasury
Indicators, and the Annual Investment Strategy (this report) – A forward
looking report for the financial year ahead.   
2) A Mid-year Treasury Management report – To update members on the
capital and treasury position, amending prudential and treasury indicators,
as necessary; and any required policy revisions.  
3) An Annual Treasury Management report – A backward looking review,
providing details of actual treasury activity, and prudential and treasury
indicators, compared to the approved estimates. 
2.2.2 The above reports require to be adequately scrutinised before being
recommended to full Council for approval.  This role will be undertaken by the
Policy and Resources and Audit and Scrutiny Committees.  In addition to the
three major reports detailed above, quarterly reporting (end of June/end of
December) is also required.  These additional reports do not have to be
reported to full Council but do require to be adequately scrutinised.  This role
will be undertaken by the Audit and Scrutiny Committee. 
3.  RECOMMENDATIONS 
3.1 The Audit and Scrutiny Committee is requested to:  
a) Note that the report has been considered by the Policy and Resources
Committee on 20 February 2025 and approved by full Council on 27
February 2025. Any recommendations arising from further scrutiny by
the Audit and Scrutiny Committee will require to be presented to full
Council at the earliest opportunity; and   
b) Consider and endorse the Treasury Management Strategy and Annual
Investment Strategy for 2025-26, and the Prudential and Treasury
Indicators for 2025-26 to 2027-28. 
4. TREASURY MANAGEMENT STRATEGY 2025-26 
4.1 Capital Expenditure and Financing 
4.1.1 The authority’s capital expenditure plans are the key driver of treasury
management activity. The output of the capital expenditure plans is reflected in
the prudential indicators, which are designed to assist members’ overview and
confirm capital expenditure plans are prudent, affordable and sustainable. 
4.1.2 The Capital Expenditure prudential indicator is a summary of the authority’s
capital expenditure plans, both those agreed previously, and those forming
part of this budget cycle.  The following table summarises the capital
expenditure plans, as outlined within the proposed capital plan 2025-28.

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2025-26
Estimate
£m
2026-27
Estimate
£m
2027-28
Estimate
£m
Executive Directorate (Douglas Hendry)
Education 2.946 1.988 1.988
Facility Services - Shared Offices 3.681 0.667 0.382
Major Projects/CHORD 10.865 10.018 0.000
Executive Directorate (Kirsty Flanagan)
ICT 1.352 0.820 0.688
Roads and Infrastructure 48.500 39.110 33.979
Development and Economic Growth 1.104 0.000 0.000
Health and Social Care
Partnership 2.084 0.000 0.382
Live Argyll 0.474 0.468 0.382
Total 71.006 53.071 37.801
Note: The above financing need excludes other long-term liabilities, such as PFI and
leasing arrangements that already include borrowing instruments.
4.1.3 The table below summarises the above capital expenditure plans and how
these plans are being financed by capital or revenue resources. Any shortfall
of resources results in a funding borrowing need.
2025-26
£m
2026-27
£m
2027-28
£m
Gross Capital Expenditure 71.006 53.071 37.801
Financing:
Specific Project Income 8.302 5.000 0.000
General Capital Grant 11.178 8.633 8.633
Asset Sales 0.750 0.500 0.500
Earmarked Reserves/Revenue 5.577 5.030 0.000
Total 25.807 19.163 9.133
Net Financing Need 45.199 33.908 28.668

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4.2 The Authority’s Borrowing Need (the Capital Financing Requirement) 
4.2.1 The second prudential indicator is the authority’s Capital Financing
Requirement (CFR).  The CFR is simply the total historic outstanding capital
expenditure which has not yet been paid for from either revenue or capital
resources. It is essentially a measure of the authority’s indebtedness and so
its underlying borrowing need.  Any capital expenditure, which has not
immediately been paid for through a revenue or capital resource, will increase
the CFR.   
4.2.2 The CFR does not increase indefinitely, as prudent annual repayments from
revenue need to be made, which reflect the useful life of capital assets
financed by borrowing.  This authority has chosen to make debt repayments
through scheduled debt amortisation (loans fund charges).   
4.2.3 The CFR includes any other long term liabilities (e.g., PPP schemes, finance
leases). Whilst these increase the CFR, and therefore the authority’s
borrowing requirement, these types of schemes include a borrowing facility by
the PPP or lease provider and so the authority is not required to separately
borrow for these schemes.  The council hold long term liabilities within its CFR
in this respect totalling an estimated £106.346m as at 31 March 2025. 
4.2.4  Council is asked to approve the CFR projections outlined in the table below. 
2025/26
Estimate
£m
2026/27
Estimate
£m
2027/28
Estimate
£m
Opening CFR 360 394 415
Movement in CFR 34 21 16
Closing CFR 394 415 431    
Net financing need for the year (above) 45 34 29
Less Loans Fund principal repayments and
other financing movements including new
PPP/ finance lease arrangements and
principal repayments 
11 13 13
Movement in CFR 34 21 16 
4.2.5 In addition to the CFR, there will be a refinancing requirement in respect of
the repayment of PWLB loan principal of £1.680m each year.  These
repayments of principal relate to a 10 year PWLB loan (original principal
£21m), which was taken on a fixed Equal Instalments of Principal (EIP) basis. 
All other PWLB loans will be repayable on maturity, with no maturity loans due
to mature in the period to 31 March 2028. 
4.2.6 There is also a potential for market loans to be recalled.  The council has one
outstanding market or LOBO loan for £5.255m, maturing 2048, with call dates
every 6 months.  This loan could potentially be recalled at the 22 June or 22
December call dates in any year.

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4.2.7 Any PWLB or LOBO loans maturing during the year will ultimately require
replacement borrowing to maintain the council’s cashflow position.  In
addition, the council will continue to actively monitor potential restructuring
opportunities, in order to generate cash savings, at a minimum risk, and
improve the balance of the loan debt maturity profile.
4.3 Liability Benchmark
4.3.1 The authority is required to estimate and measure the Liability Benchmark for
the forthcoming financial year and the following two financial years, as a
minimum.  There are four components to the Liability Benchmark, also
reflected in the graph below: 
1. Existing loan debt outstanding: the authority’s existing loans that are
still outstanding in future years.
2. Loans CFR: this is calculated in accordance with the loans CFR definition
in the Prudential Code and projected into the future based on approved
prudential borrowing and planned Loans Fund advances/Loans Fund
principal repayments.
3. Net loans requirement: this will show the authority’s gross loan debt less
treasury management investments at the last financial year-end, projected
into the future and based on its approved prudential borrowing, planned
Loans Fund principal repayments and any other major cash flows forecast.
4. Liability benchmark (or gross loans requirement): this equals net loans
requirement plus short-term liquidity allowance. Any years where actual
loans are less than the benchmark indicate a future borrowing
requirement.  Any years where actual loans outstanding exceed the
benchmark represent an overborrowed position, which will result in excess
cash requiring investment.

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4.4 Core Funds and Expected Investment Balances 
4.4.1 The application of resources to either finance capital expenditure or to support
the revenue budget will have an ongoing impact on cash balances available
for investment.  It is anticipated that treasury investments will be held to
manage day to day cashflow requirements, with balances expected to
fluctuate throughout the year.  Whilst the council holds significant usable
reserve balances, due to the strategy of internal borrowing, as outlined within
the Borrowing Strategy section, investment balances are expected to be low
throughout the year. 
4.5 Statutory Repayment of Loans Fund Advances 
4.5.1 The authority is required to set out its policy for the statutory repayment of
loans fund advances prior to the start of the financial year. 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 
4.5.2 A variety of options are provided to councils, so long as a prudent provision is
made each year.  A review of the council’s loan fund advances was undertaken
during 2019-20 to ensure the council continues to make a prudent provision each
year for the repayment of loans fund advances. 
4.5.3 For all new loans fund advances the policy for repayment will be in accordance
with the following methodology, as appropriate: 
1. Asset life method – loans fund advances will be repaid with reference to
the life of an asset using a 5.1% annuity rate; 
2. Funding / Income profile method – loans fund advances will be repaid
by reference to an associated income stream. 
4.5.4 Using the asset life method, the council is required to ensure that the debt is
repaid over a period that is reasonably commensurate with that over which the
capital expenditure provides benefits.  The following table details the repayment
period applicable to each asset type.

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4.6 Current Treasury Portfolio Position
4.6.1 The overall treasury management portfolio as at 31.3.24 and for the position as
at 31 December 2024 are shown below for both borrowing and investments. 
TREASURY PORTFOLIO    
Actual 31 March
2024
Actual 31
December 2024
Treasury investments £m %   £m %  
Banks 18.133 55% 10.016 30%
Local Authorities 10.000 30% 0.000 0%
Money Market Funds 1.400 4% 20.000 60%
Third Party Loans (RSLs) 3.543 11% 3.408 10%
Total treasury investments 33.076 100% 33.424 100%      
Treasury external borrowing    
PWLB 108.877 92% 107.197 95%
Market Loans (LOBO) 5.255 4% 5.255 5%
Temporary Borrowing* 5.256 4% 0.297 0%
Local Bonds 0.018 0% 0.018 0%
Total external borrowing 119.406 100% 112.767 100%
*Note: This represents short term borrowing from various institutions. 
4.6.2  The council’s forward projections for borrowing are summarised in the following
table. This table shows the actual external debt, against the underlying capital
borrowing need, (the Capital Financing Requirement), highlighting any over or
under borrowing. 
Asset Type
Repayment
Period
(Years)
Land (including cemeteries) 100
Road Structures - Bridges, Retaining Walls, Sea Walls, Flood Defences 60
Piers and Harbours - Major Structural Work 60
Piers and Harbours - Medium Term Works e.g painting/cathodic protection 20
Piers and Harbours - Limited Lifespan Improvements 10
Roads and Footways 20
Street Lighting 30
Vehicles & Plant 7
IT Equipment 5
Major Regeneration Works (Public Realm etc) 60
New Builds including Schools 60
Buildings -  Electrical 40
Buildings -  Plant 20
Buildings - Roofing 35
Buildings - Windows & External Doors 20
Buildings - Structural 25

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2025/26
Estimate
£m
2026/27
Estimate
£m
2027/28
Estimate
£m
Debt at 1 April  153 220 275
Expected change in Debt 67 55 37
Other long-term liabilities (OLTL) 106 101 95
Expected change in OLTL (5) (6) (6)
Actual Gross Debt at 31 March  321 370 401
The Capital Financing
Requirement
394 415 431
Under / (over) borrowing 73 45 30 
4.6.3  Within the range of prudential indicators there are several key indicators to ensure
that the authority operates its activities within well defined limits.  One of these is
that the authority 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 for 2025/26 and 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 or speculative purposes.      
4.6.4 The council’s Section 95 Officer reports that the council has complied with this
prudential indicator in the current year and does not envisage difficulties for
the future.  This view takes account of current commitments, existing plans
and the proposals in the 2025-26 Budget Pack in respect of the Capital Plan
2025-28.   
4.7 Treasury Indicators: Limits to Borrowing Activity 
4.7.1  The Operational Boundary. This 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
and the ability to fund under-borrowing by other cash resources. 
Operational Boundary
2025/26
Estimate
£m
2026/27
Estimate
£m
2027/28
Estimate
£m
Debt 293 320 341
Other long-term liabilities 101 95 90
Total 394 415 431 
4.7.2  The Authorised Limit for external debt. This is a key prudential indicator
and represents a control on the maximum level of borrowing. This represents
a legal limit beyond which external debt is prohibited, and this limit needs to
be set or revised by full Council.  It reflects the level of external debt which,
while not desired, could be afforded in the short term to manage day to day
cashflow requirements but is not sustainable in the longer term.  
• This is the statutory limit determined under section 3 (1) of the Local
Government Act 2003. The Government retains an option to control either
the total of all local authority plans, or those of a specific authority, although
this power has not yet been exercised.

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• Council is asked to approve the following Authorised Limit: 
Authorised Limit 
2025/26
Estimate
£m
2026/27
Estimate
£m
2027/28
Estimate
£m
Debt 298 325 346
Other long-term liabilities 104 98 93
Total 402 423 439 
4.8  Prospects for Interest Rates 
4.8.1 The council’s treasury advisor has provided an update on the current
economic position, given within Appendix 1.  Part of this advisory service is
also to assist the authority to formulate a view on interest rates. The following
forecasts have been provided for short term (Bank Rate) and long term
(PWLB certainty rates) borrowing. 
(a) Long term PWLB rates:    
PWLB
rates
Dec
2024
%
March
2025
%
March
2026
%
March
2027
%
Dec
2027
%
5 year 5.0 4.9 4.5 4.1 3.9
10 year 5.3 5.1 4.7 4.3 4.1
25 year 5.6 5.5 5.1 4.7 4.5
50 year 5.4 5.3 4.9 4.5 4.3 
The current and expected interest rates for long term borrowing from the
PWLB highlight a gradual decrease from the current position. The PWLB
rates quoted (gilt yields plus 80 bps) take account of the application of a 0.2%
certainty rate reduction, introduced by the government in return for council’s
providing their borrowing forecast information.  Argyll and Bute Council is able
to access the certainty rate reduction. 
(b) Short term borrowing rates: 
Bank
Rate
Dec
2024
%
March
2025
%
March
2026
%
March
2027
%
Dec
2027
%
4.75 4.50 3.75 3.50 3.50 
The ‘Bank Rate’ is the official Bank of England rate paid on commercial bank
reserves.  The current and Bank Rate forecasts also highlight an expected
gradual decrease from the current position.  Short term borrowing rates will
generally fall in line with Bank Rate cuts. 
4.8.2 Considerable uncertainty remains around interest rate forecasts. As all PWLB
certainty rates are currently significantly above the longer term Bank Rate
forecast (10 years 3.25%), borrowing strategies will need to be reviewed in

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that context.  Overall, better value can be obtained at the shorter end.  MUFG
will continue to monitor economic and market developments as they unfold
and advise the authority accordingly.  Typically, forecasts are reviewed
following the quarterly release of the Bank of England’s Monetary Policy
Report but will be considered on an ad hoc basis, as required.
4.9 Borrowing Strategy
4.9.1 The council is currently maintaining an under borrowed position.  This means that
the capital borrowing need, (the Capital Financing Requirement), has not been
fully funded with loan debt as cash supporting the authority’s reserve balances
and cash flow has been used as a temporary measure (internal borrowing). This
strategy is prudent while medium and longer dated borrowing rates are expected
to fall from their current levels, albeit only once prevailing inflation concerns are
addressed by restrictive near term monetary policy.  
4.9.2 Short term borrowing from money markets or other local authorities is
currently expected to be cheaper than long term borrowing and will therefore
be attractive throughout the financial year. However, as with internal
borrowing, short term savings by delaying new long term external borrowing
requires to be balanced with potential additional long term costs.
4.9.3 Current PWLB rates are forecast to gradually decrease over the next couple of
years. As a result, consideration will be given to the timing of any new fixed rate
long term borrowing. Although more expensive in the short term, this may be more
cost effective over the longer term and also provides an element of budget
certainty in respect of future years. 
4.9.4 The council’s annual revenue estimates include appropriate provision for
financing costs of capital expenditure.  The key principles of the strategy will be to
minimise debt interest costs over the medium term and to achieve a more even
spread in the debt maturity profile. It is anticipated that a range of solutions will be
employed in order to mitigate against interest rate risk, and to provide longer term
cost certainty, as outlined above.
4.9.5 Against the economic background and the risks within interest rate forecasts,
caution will be adopted with the 2025-26 treasury operations. The Section 95
Officer, in conjunction with the treasury advisors, will monitor interest rate
forecasts and adopt a pragmatic approach to changing circumstances, with
any new borrowing reported to committee at the next available opportunity.
4.10 Policy on Borrowing in Advance of Need
4.10.1 The authority will not borrow more than or in advance of its needs purely in
order to profit from the investment 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 authority can ensure the security
of such funds.  Risks associated with any borrowing in advance activity will be
subject to prior appraisal and subsequent reporting through the mid-year or
annual reporting mechanism.

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4.11 Rescheduling 
4.11.1 The principle reasons for debt rescheduling include: 
• The generation of cash savings; and 
• To enhance the balance of the debt maturity profile, mitigating the risk of
refinancing at a higher rate of interest in any year in the future. 
4.11.2 Opportunities for debt rescheduling within the current debt portfolio will be
monitored on an ongoing basis throughout the year.  There may be potential
opportunities to generate savings and enhance the balance of the debt
maturity profile by switching from long term debt to short term debt. However,
these options would need careful consideration in light of the short term nature
of potential savings and the likely cost of re-financing those short term loans
on maturity, if required, together with any debt repayment premiums that may
be incurred.  Whilst premature redemption rates remain elevated,
rescheduling opportunities to generate savings are not expected to be
available.  This would only expect to be undertaken, where a rebalancing of
the portfolio, to provide more certainty, is considered appropriate.  Any
rescheduling undertaken will be reported to Council, at the earliest
opportunity. 
4.12 New Financial Institutions as a Source of Borrowing 
4.12.1 Currently the PWLB Certainty Rate is set at gilts + 80 basis points.  However,
consideration may still need to be given to sourcing funding from the following
sources:
• Local authorities (primarily shorter dated maturities out to 3 years or so –
generally still cheaper than the Certainty Rate).
• Financial institutions (primarily insurance companies and pension funds
but also some banks, out of forward dates where the objective is to avoid
a “cost of carry” or to achieve refinancing certainty over the next few
years).
Our advisors will keep us informed as to the relative merits of each of these
alternative funding sources. 
4.13 Approved Sources of Long and Short Term Borrowing 
4.13.1 A summary of the council’s approved sources and types of borrowing are set
out within Appendix 2.   
4.14 Treasury and Prudential Indicators 2025-28 
4.14.1 A key driver of treasury management activity is the council’s capital
investment plans.  The treasury management function ensures that sufficient
cash is available to meet capital spending commitments.  Prudential indicators
reflect the output from these plans and are designed to ensure that the
council’s capital investment plans are affordable, prudent and sustainable.
Required updates to the prudential and treasury indicators for 2024-25 were

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outlined within the Treasury Management Strategy Mid-year Review Report,
approved by Council on 20 December 2024.  The prudential and treasury
indicators for 2025-26 to 2027-28 are outlined in Appendix 3 and reflect the
proposed Capital Plan 2025-28.  These indicators are relevant for the purpose
of setting an integrated treasury management strategy. 
5. ANNUAL INVESTMENT STRATEGY 
5.1 Investment Policy 
5.1.1 The council’s investment policy implements the requirements of the following: 
• Local Government Investments (Scotland) Regulations 2010, (and
accompanying Finance Circular 5/2010), 
• CIPFA Treasury Management in Public Services Code of Practice and Cross
Sectoral Guidance Notes 2021 (“the Code”) 
5.1.2 The council’s investment priorities, in order of importance, will be security,
minimising the risk of any loss on the principal sum invested; portfolio liquidity,
ensuring that cash is available when required; and yield (return), the rate of
interest earned from the investment.  The authority will aim to achieve the
optimum return on its investments, commensurate with proper levels of security
and liquidity, and with regard to the authority’s risk appetite.  The risk appetite of
the council will be low, with security of investments the key priority. 
5.1.3 In the current economic climate, it is considered appropriate to maintain a degree
of liquidity to cover cash flow needs but to also consider opportunities for
‘laddering’ investments for periods up to 12 months with high credit rated financial
institutions, whilst investment rates remain elevated. 
5.1.4 The borrowing of monies purely to invest or on-lend and make a return is not
permitted and the council will not engage in such activity. The limit of investments
will reflect the level of available council reserve fund balances and borrowing in
advance to meet capital financing requirements, in line with the borrowing
strategy, together with provision for managing the council’s day to day cash flow
requirements. 
5.1.5 The guidance from the Scottish Government and CIPFA places a high priority on
the management of risk. This authority has adopted a prudent approach to
managing risk and defines its risk appetite by the following means: 
1. Minimum acceptable credit criteria are applied in order to generate a list
of highly creditworthy counterparties.  This also enables diversification and
thus avoidance of concentration risk. The key ratings used to monitor
counterparties are the short term and long term ratings.   
2. Other information: ratings will not be the sole determinant of the quality of
an institution; 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 achieve this consideration the council will engage with its

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advisors to maintain a monitor on market pricing such as ‘credit default
swaps’ (CDS) and overlay that information on top of the credit ratings. 
3. Other information sources used will include the financial press, share price
and other such information pertaining to the financial sector, in order to
establish the most robust scrutiny process on the suitability of potential
investment counterparties.
4. This council has defined the list of types of investment instruments that the
treasury management team are authorised to use and lending limits
(amounts and maturity).  A limit for the amount of its investments which
are invested for longer than 365 days has also been set.
5. Investments will only be placed with counterparties from countries with a
specified minimum sovereign rating and all investments will be
denominated in sterling.
However, the council will also pursue value for money in treasury management
and will monitor the yield from investment income against appropriate
benchmarks for investment performance throughout the year. 
5.1.6 
5.1.7
Investment instruments identified for potential use during the year, together with
associated treasury risk mitigations and monetary limits, are outlined in
Appendix 4.  Information on Environmental, Social and Governance (ESG)
considerations is also provided.  Within the constraints of the policy, due
consideration will be given to the diversification of investments, in order to limit a
concentration of investments with too few counterparties or countries, and to
ESG factors. 
There has been considerable change in the types of investment instrument
brought to the market in recent years. Given the fluidity of this area, members
will be kept informed and requested to approve the use of any new
instruments, as appropriate, in order to allow maximum flexibility.  
5.2 Creditworthiness Policy 
5.2.1 The council applies the creditworthiness service provided by MUFG (formerly Link
Group). This service employs a sophisticated modelling approach utilising credit
ratings from the three main credit rating agencies - Fitch, Moody’s and Standard
& Poor’s.  The credit ratings of counterparties are supplemented with the following
overlays: - 
1. “watches” and “outlooks” from credit rating agencies;
2. CDS spreads that may give early warning of changes in credit ratings;
3. sovereign ratings to select counterparties from only the most creditworthy
countries. 
5.2.2 This modelling approach combines credit ratings, and any assigned Watches and
Outlooks, in a weighted scoring system, which is then combined with an overlay
of CDS spreads. The end product of this is a series of colour coded bands, which
indicate the relative creditworthiness of counterparties. These colour codes are
used by the authority to determine the suggested duration for investments.

Page 16

5.2.3 All credit ratings will be monitored on an ongoing basis throughout the year. 
Through its use of the MUFG creditworthiness service, the council is alerted
to changes to ratings of all three agencies and will also be advised of
information in movements in Credit Default Swap spreads and other market
data on a daily basis.  If a downgrade results in the counterparty / investment
scheme no longer meeting the authority’s minimum criteria, its further use as
a new investment will be withdrawn immediately.  Sole reliance will not be
placed on the use of this external service.  All available information will be
considered when making investment decisions. 
5.2.4 
5.2.5
The council will continue to limit exposure to credit risk by ensuring that all
investments are placed with the higher rated bodies from a weekly credit list of
worldwide potential counterparties.  For illustration purposes, a snapshot of this
counterparty list as at 7 February 2025 is provided in Appendix 5.   
The council essentially adopts a hybrid approach in formulating its
creditworthiness policy.  In addition to the MUFG creditworthiness service, which
provides details of the most highly credit rated institutions (counterparties) and
suggested investment durations, the council also places a monetary limit on each
type of investment or counterparty, as outlined within Appendix 4.  These
investment criteria will be kept under review throughout the year and amended, if
required, to ensure that they continue to be fit for purpose. 
5.3 Investment Strategy 
5.3.1 Investments will be made with reference to the core balance and cash flow
requirements and the outlook for short term interest rates (i.e., rates for
investments up to 12 months). Greater returns are usually obtainable by
investing for longer periods.  Accordingly, while most cash balances are
required in order to manage the ups and downs of cash flow, where cash
sums can be identified that could be invested for longer periods, the value to
be obtained from longer term investments will be carefully assessed. 
5.3.2  The current forecast shown in paragraph 4.8.1 includes a forecast for Bank Rate
to fall to a low of 3.5%.  However, as there are so many variables at this time,
caution must be exercised in respect of all interest rate forecasts. The
suggested budgeted investment earnings rates for returns on investments
placed for periods up to about three months during each financial year are as
follows: 
Average earnings in each
year
%
2025/26 4.10%
2026/27 3.70%
2027/28 3.50%

Page 17

5.3.3 For its cash flow generated balances, the authority will seek to utilise its
business reserve instant access accounts, Money Market Funds and short-
dated deposits, (overnight to 100 days), in order to benefit from the
compounding of interest. 
5.3.4  An investment treasury indicator and limit requires to be set in respect of total
principal funds invested for greater than 365 days. These limits are set with regard
to the authority’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
council is asked to approve the following Treasury Indicator and limit: 
Upper limit for principal sums invested for longer than 365
days 
2025/26
£m
2026/27
£m
2027/28
£m
Principal sums invested for
longer than 365 days 20 20 20
Current investments in
excess of 1 year maturing in
each year
0 0 0 
5.4 Investment Performance / Risk Benchmarking 
5.4.1 The Section 95 Officer will continue to monitor the economic environment and
adopt a pragmatic approach to changing circumstances. A balanced view of
risk against return will be taken in respect of all investments. The authority
may use an investment benchmark to assess the investment performance of
its investment portfolio of overnight, 7 day, 1, 3, 6 or 12 month compounded
SONIA (Sterling Overnight Index Average), as appropriate.  However, it is
anticipated that return on investments will be limited in 2025-26, as a result of
Bank Rate forecasts and the over-riding principal of risk aversion.  Investment
activity will be reported at the end of the financial year, as part of the Annual
Treasury Report. 
5.5 Non-treasury investments 
5.5.1 Non-treasury investments are defined as the following categories: 
• All shareholding, unit holding and bond holding, including those in a local
authority owned company;
• Loans to a local authority company or other entity formed by a local authority
to deliver services;
• Loans made to third parties; and
• Investment property. 
5.5.2 Any such finance arrangements or loans would be subject to specific committee
approval. The authority may make loans to third parties, where this is consistent
with meeting the service objectives of the council and for which, specific statutory
provision exists.  For service reasons, loans to third parties may be offered at an
interest rate below the market rate. Where the loan is advanced at less than a
market interest rate, there is an associated loss of investment return, which would

Page 18

otherwise have been earned on these resources. Any cost to the council in this
respect will be reflected in the authority’s annual accounts. All loans to third parties
will be recognised as investments and detailed within the Annual Investment
Report.
6. Capital Strategy
6.1 The CIPFA 2021 Prudential and Treasury Management Codes places a
requirement on local authorities to prepare a Capital Strategy.  The Capital
Strategy demonstrates how capital expenditure, capital financing and treasury
management activity contribute to the provision of services and longer term policy
objectives of the council.  It also provides an overview of how associated risk is
managed and the implications for future financial sustainability.  An updated
Capital Investment Strategy was approved by Policy and Resources Committee
in August 2023.  This will be reviewed and updated, as appropriate, as part of a
planned review of capital arrangements, to be undertaken during the 2025-26.
7. Training
7.1 The CIPFA Code requires the proper officer to ensure that members with
responsibility for treasury management receive adequate training.  This especially
applies to Members responsible for scrutiny.  Members of the Audit and Scutiny
Committee received training from the council’s treasury advisors, Link Group in
October 2024, to assist with this scrutiny role.  Members are advised to notify
Financial Services as/when they feel further training sessions would be beneficial.
Furthermore, the training needs of treasury management officers are periodically
reviewed to ensure appropriate treasury management knowledge and skills for
those responsible for management, delivery, governance and decision making. 
8. Policy on Use of External Service Providers
8.1 The authority uses MUFG (formerly Link Group), as its external treasury
management advisors, to acquire access to specialist skills and resources.
However, it is recognised that responsibility for treasury management decisions
remains with the council.  All decisions will be undertaken with due regard to all
available information, including from our treasury advisers.  For short term market
borrowing and investments, the council utilises a number of brokers to access
sterling cash markets. This ensures that the council ensures best value in daily
cash flow management.
9. Scheme of Delegation and Role of the Section 95 Officer
9.1 The treasury management scheme of delegation, together with the treasury
management role of the Section 95 officer and nominated Member, are outlined
in Appendix 6.
10. CONCLUSION
10.1 The Treasury Management Strategy provides a comprehensive statement of
treasury management policies and planned activities, covering the relevant
treasury and prudential indicators, the current and projected debt positions, and
the Annual Investment Strategy for 2025-26.

Page 19

10.2 
10.3 
10.4 
10.5 
A key driver of treasury management activity is the council’s capital investment
plans.  Prudential indicators reflect the output from these plans and are designed
to ensure that the council’s capital investment plans are affordable, prudent and
sustainable.  Within the range of prudential indicators, there are several key
indicators to ensure that the authority operates its activities within well defined
limits. 
Whilst the Capital Financing Requirement represents an underlying need to
borrow, the council is currently maintaining an under-borrowed position. This
strategy is prudent while medium and longer dated borrowing rates are expected
to fall from their current levels, albeit that considerable uncertainty remains around
interest rate forecasts.   
The council’s revenue budget includes appropriate provision for financing costs
of capital expenditure.  The key principles of the borrowing strategy will be to
minimise debt interest costs over the medium term and to achieve a more even
spread in the debt maturity profile. 
The council’s investment priorities will be security, liquidity and yield (return).  A
prudent approach to managing investment risk has been adopted.  Exposure to
credit risk will be limited by ensuring that all investments are placed with the
higher rated bodies.  A balanced view of risk against return will be taken in
respect of all investments.  It is anticipated that return on investments will be
limited in 2025-26, as a result of Bank Rate forecasts and the over-riding
principal of risk aversion. 
11. IMPLICATIONS 
11.1 Policy  Sets the policy for borrowing and
investment decisions.
11.2 Financial  Provides the Treasury Management
Strategy for 2025-26, including the
Annual Investment Strategy.
11.3 Legal  None 
11.4 HR  None
11.5 Fairer Duty Scotland: 
10.5.1 Equalities – protected
characteristics 
None 
10.5.2 Socio-economic Duty  None 
10.5.3 Islands  None
11.6 Climate Change  None
11.7 Risk Provides an overview of treasury
management and investment risk,
and how these risks are managed.
11.8 Customer Service - None None
11.9 The Rights of the Child (UNCRC)  None

Page 20

Kirsty Flanagan
Executive Director/S95 Officer
13 February 2025 
Councillor Ross Moreland, Policy Lead for Finance and Commercial Services 
APPENDICES:
Appendix 1 – Economic Background
Appendix 2 -  Approved Sources and Types of Borrowing
Appendix 3 – Treasury and Prudential Indicators 2025-28
Appendix 4 – Permitted Investments
Appendix 5 – Example Weekly Counterparty List
Appendix 6 – Scheme of Delegation; Section 95 Officer and Nominated Member Roles                                          
For further information contact: 
Carolyn Earl, Acting Head of Financial Services
Carolyn.Earl@argyll-bute.gov.uk

Page 21

APPENDIX 1
ECONOMIC BACKGROUND (to 12th December 2024)
The third quarter of 2024 (July to September) saw: 
• GDP growth stagnating in July following downwardly revised Q2 figures
(0.5% q/q)
• A further easing in wage growth as the headline 3myy rate (including
bonuses) fell from 4.6% in June to 4.0% in July;
• CPI inflation hitting its target in June before edging above it to 2.2% in July
and August;
• Core CPI inflation increasing from 3.3% in July to 3.6% in August;
• The Bank of England initiating its easing cycle by lowering interest rates
from 5.25% to 5.0% in August and holding them steady in its September
meeting;
• 10-year gilt yields falling to 4.0% in September.  
Over the aforementioned period, the economy’s stagnation in June and July
pointed more to a mild slowdown in UK GDP growth than a sudden drop back
into a recession.   However, in the interim period, to 12 December, arguably the
biggest impact on the economy’s performance has been the negative market
sentiment in respect of the fallout from the Chancellor’s Budget on 30 October.
If we reflect on the 30 October Budget, our central case is that those policy
announcements will prove to be inflationary, at least in the near-term.  The
Office for Budgetary Responsibility and the Bank of England concur with that
view. The latter have the CPI measure of inflation hitting 2.5% y/y by the end of
2024 and staying sticky until at least 2026.  The Bank forecasts CPI to be
elevated at 2.7% y/y (Q4 2025) before dropping back to sub-2% in 2027. 
Nonetheless, since the Budget, the October inflation print has shown the CPI
measure of inflation bouncing up to 2.3% y/y with the prospect that it will be
close to 3% by the end of the year before falling back slowly through 2025.  The
RPI measure has also increased significantly to 3.4% y/y.
How high inflation goes will primarily be determined by several key factors.  First
amongst those is that the major investment in the public sector, according to
the Bank of England, will lift UK real GDP to 1.7% in 2025 before growth
moderates in 2026 and 2027.  The debate around whether the Government’s
policies lead to a material uptick in growth primarily focus on the logistics of
fast-tracking planning permissions, identifying sufficient skilled labour to
undertake a resurgence in building, and an increase in the employee
participation rate within the economy.
There are inherent risks to all the above.  The worst-case scenario would see
systemic blockages of planning permissions and the inability to identify and
resource the additional workforce required to deliver large-scale IT, housing
and infrastructure projects.  This would lead to upside risks to inflation, an
increased prospect of further Government borrowing & tax rises in the June

Page 22

2025 Spending Review (pushed back from the end of March), and a tepid GDP
performance.
Regarding having a sufficiently large pool of flexible and healthy workers, the
initial outlook does not look bright.  Research from Capital Economics has
alluded to an increase of some 500,000 construction workers being needed to
provide any chance of the Government hitting its target of 300,000 new homes
being built in each of the next five years (234,000 net additional dwellings in
England in 2022/23).  But the last time such an increase was needed, and
construction employment is currently at a nine-year low, it took 12 years to get
there (1996 to 2008). Also note, as of October 2024, job vacancies in the
construction sector were still higher than at any time in the 20 years preceding
the pandemic.  
Currently, it also seems likely that net inward migration is set to fall, so there is
likely to be a smaller pool of migrant workers available who, in the past, have
filled the requirement for construction worker demand. The Government plans
to heavily promote training schemes, particularly to the one million 16- to 24-
year-olds who are neither in education nor work.  But it is arguable as to whether
the employee shortfall can be made up from this source in the requisite time,
even if more do enter the workforce.
Against, this backdrop, there may be a near-term boost to inflation caused by a
wave of public sector cash chasing the same construction providers over the
course of the next year or so, whilst wages remain higher than the Bank
currently forecasts because of general labour shortages, including in social care
where Government accepts there is a 150,000 shortfall at present.
Unemployment stands at a low 4.3% (September), whilst wages are rising at
4.3% y/y (including bonuses) and 4.8% (excluding bonuses).  The Bank would
ideally like to see further wage moderation to underpin any further gradual
relaxing of monetary policy.  Indeed, over the next six months, the market is
currently only pricing in Bank Rate reductions in February and May – which
would see Bank Rate fall to 4.25% - but further cuts, thereafter, are highly likely
to be even more data-dependent.
If we focus on borrowing, a term we are likely to hear throughout 2025 is “bond
vigilante”.  Essentially, this represents a generic term for when the market is ill
at ease with the level of government borrowing and demands a higher return
for holding debt issuance.  In the UK, we do not need to go back too far to recall
the negative market reaction to the Truss/Kwarteng budget of 2022.  But long-
term borrowing rates have already gradually moved back to those levels since
their recent low point in the middle of September 2024.  Of course, the UK is
not alone in this respect.  Concerns prevail as to what the size of the budget
deficit will be in the US, following the election of Donald Trump as President,
and in France there are on-going struggles to form a government to address a
large budget deficit problem too.  Throw into the mix the uncertain outcome to
German elections, and there is plenty of bond investor concern to be seen.
Staying with the US, Donald Trump’s victory paves the way for the
introduction/extension of tariffs that could prove inflationary whilst the same

Page 23

could be said of further tax cuts.  Invariably the direction of US Treasury yields
in reaction to his core policies will, in all probability, impact UK gilt yields.  So,
there are domestic and international factors that could impact PWLB rates
whilst, as a general comment, geo-political risks continue to abound in Europe,
the Middle East and Asia.
In the past month, the US Core CPI measure of inflation has indicated that
inflation is still a concern (3.3% y/y, 0.3% m/m), as has the November Producer
Prices Data (up 3.0 y/y v a market estimate of 2.6% y/y, 0.4% m/m v an estimate
of 0.2% m/m) albeit probably insufficient to deter the FOMC from cutting US
rates a further 0.25% at its December meeting.  However, with Trump’s
inauguration as President being held on 20 January, further rate reductions and
their timing will very much be determined by his policy announcements and their
implications for both inflation and Treasury issuance.
Looking at gilt movements in the first half of 2024/25, and you will note the 10-
year gilt yield declined from 4.32% in May to 4.02% in August as the Bank’s
August rate cut signalled the start of its loosening cycle. More recently,
however, 10 year gilt yields have spiked back up to 4.35%.  
The FTSE 100 reached a peak of 8,380 in the third quarter of 2024 (currently
8.304), but its performance is firmly in the shade of the US S&P500, which has
breached the 6,000 threshold on several occasions recently, delivering returns
upwards of 25% y/y.  The catalyst for any further rally (or not) is likely to be the
breadth of AI’s impact on business growth and performance.
MPC meetings: 9 May, 20 June, 1 August, 19 September, 7 November 2024
• On 9 May, the Bank of England’s Monetary Policy Committee (MPC) voted
7-2 to keep Bank Rate at 5.25%.  This outcome was repeated on 20th June.
• However, by the time of the August meeting, there was a 5-4 vote in place
for rates to be cut by 25bps to 5%.  However, subsequent speeches from
MPC members have supported Governor Bailey’s tone with its emphasis on
“gradual” reductions over time.
• Markets thought there may be an outside chance of a further Bank Rate
reduction in September, following the 50bps cut by the FOMC, but this came
to nothing.
• On 7 November, Bank Rate was cut by 0.25% to 4.75%.  The vote was 8-1
in favour of the cut but the language used by the MPC emphasised “gradual”
reductions would be the way ahead with an emphasis on the inflation and
employment data releases, as well as geo-political events.
In the following chart, despite a considerable gilt market rally in mid-September,
rates started and finished the six-month period under review in broadly the
same position.

Page 24

PWLB RATES 02.04.24 - 30.09.24   
HIGH/LOW/AVERAGE PWLB RATES FOR 02.04.24 – 30.09.24 
3.00
3.40
3.80
4.20
4.60
5.00
5.40
5.80
6.20
6.60
7.00
PWLB Certainty Rate Variations 2.4.24 to 30.9.24
2-Apr-24 30-Sep-24 Average
1 Year 5 Year 10 Year 25 Year 50 Year
02/04/2024 5.39% 4.72% 4.80% 5.28% 5.07%
30/09/2024 4.95% 4.55% 4.79% 5.33% 5.13%
Low 4.78% 4.31% 4.52% 5.08% 4.88%
Low date 17/09/2024 17/09/2024 17/09/2024 17/09/2024 17/09/2024
High 5.61% 5.14% 5.18% 5.61% 5.40%
High date 29/05/2024 01/05/2024 01/05/2024 01/05/2024 01/05/2024
Average 5.21% 4.76% 4.88% 5.35% 5.14%
Spread 0.83% 0.83% 0.66% 0.53% 0.52%

Page 25

APPENDIX 2
Approved Sources of Long and Short-term Borrowing
On Balance Sheet Fixed Variable   
PWLB • •
UK Municipal Bond Agency  • •
Local Authorities • •
Banks • •
Pension Funds • •
Insurance Companies • •
UK National Wealth Fund • • 
Market (long-term) • •
Market (temporary) • •
Market (LOBOs) • •
Stock Issues • • 
Local Temporary • •
Local Bonds •
Local Authority Bills                                                                   • •
Overdraft  •
Negotiable Bonds • • 
Internal (capital receipts & revenue balances) • •
Commercial Paper •
Medium Term Notes • 
Finance Leases • •

Page 26

Prudential and Treasury Indicators - 2025-28 Estimates
Prudential indicators for prudence
1) Capital expenditure
Gross capital expenditure
Less Financing
Net financing need (in year borrowing requirement)
2) Capital financing requirement (CFR)
Total CFR at 1 April
Total CFR 31 March
Movement in CFR
Represented by:
Net in year borrowing requirement (above)
Less Principal repayments and other financing movements
Total
3) Authorised limit for borrowing
Authorised limit for long-term liabilities
Authorised limit for external debt
4) Operational boundary for borrowing
Operational boundary for long-term liabilities
Operational boundary for external debt
5) Gross debt and the CFR
Gross debt at 31 March
Total CFR at 31 March
Gross debt less the CFR at 31 March
Prudential indicators for affordability
6) Ratio of financing costs to net revenue
stream
Treasury indicators - borrowing limits
7) Maturity structure of fixed rate borrowing Upper Lower Upper Lower Upper Lower
a) Under 12 months 30% 0% 30% 0% 30% 0%
b) 12 months and within 24 months 30% 0% 30% 0% 30% 0%
c) 24 months and within 5 years 30% 0% 30% 0% 30% 0%
d) 5 years and within 10 years 40% 0% 40% 0% 40% 0%
e) 10 years and above 100% 0% 100% 0% 100% 0%
8) Limits on fixed and variable rate borrowing Upper Lower Upper Lower Upper Lower
a) Fixed rate 100% 0% 100% 0% 100% 0%
b) Variable rate 60% 0% 60% 0% 60% 0%
Treasury indicator - investment
9) Upper limit on principal sums invested for
over 365 days
£m £m £m
71 53 38
26 19 9
45 34 29
APPENDIX 3
2025-26 2026-27 2027-28
Estimate Estimate Estimate
21
£m £m £m
360 394 415
34 16
394 415 431
101 95 90
394 415 431
£m £m £m
293 320 341
104 98 93
402 423 439
£m £m £m
298 325 346
20
£m £m £m
321 370 401
394 415 431
-73 -45 -30
1634 21
% % %
4.9% 5.2% 5.6%
£m £m £m
20 20
45 34 29
11 13 13

Page 27

APPENDIX 3
Notes to Prudential and Treasury Indicators
Prudential Indicators - Prudence
Affordability Prudential Indicators
Ratio of Financing Costs to Net Revenue Stream
Maturity Structure of Borrowing
This indicator identifies the trend in the cost of capital (borrowing and other long term obligation costs),
against the net revenue stream. The estimates of financing costs include current commitments and the
proposals in the 2025-26 Budget Pack. 
These gross limits are set to reduce the authority’s exposure to large, fixed rate sums falling due for
refinancing, and are required for upper and lower limits.
Indicators 1 - 5 above cover the overall capital and control of borrowing prudential indicators.
The authority’s capital expenditure plans are the key driver of treasury management activity. The output
of the capital expenditure plans is reflected in the prudential indicators, which are designed to assist
members’ overview and confirm capital expenditure plans.
Within the overall framework, prudential indicators are required to assess the affordability of the capital
investment plans. These provide an indication of the impact of the capital investment plans on the
authority’s overall finances.

Page 28

APPENDIX 4
Permitted Treasury Investments
Note: Limits are given as a monetary value in £ or as a percentage of the overall investment portfolio.
Type of Investment Treasury Risks Mitigating Controls Council
Limits
Common
Good
Limits
Cash type instruments
a. 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.
£unlimited,
maximum 6
months.
£unlimited,
maximum
6 months.
b. 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.
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.
£unlimited,
maximum 2
year.
Limit of
£10m per
local
Authority or
public body
£unlimited,
maximum
2 years.

Page 29

Type of Investment Treasury Risks Mitigating Controls Council
Limits
Common
Good
Limits
Deposits with other non-local
authority bodies will be restricted
to the overall credit rating criteria.
c. Money Market Funds
(MMFs) –
CNAV/LVNAV/VNAV(Low
to 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 a “AAA” rated status from
either Fitch, Moody’s or Standard and
Poor’s.
£15m per
fund
100%
d. Ultra short dated bond
funds (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
have a “AAA” rated status from either
Fitch, Moody’s or Standard and
Poor’s.
£15m per
fund
100%
e.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 categories (a),
(b) and (c) 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
restricts lending only to high quality
counterparties, utilising MUFG
creditworthiness service. 
£20m per
UK banking
group;
£15m per
non-UK
banking
group
100%
f. Term deposits with
financial institutions
(banks and building
societies) (Low to
These tend to be low risk
investments, but will exhibit
higher risks than categories (a),
(b) and (c) above.  Whilst there is
The counterparty selection criteria
restricts lending only to high quality
counterparties, utilising MUFG
creditworthiness service.  
£20m per
UK banking
group;
100%

Page 30

Type of Investment Treasury Risks Mitigating Controls Council
Limits
Common
Good
Limits
medium risk depending
on period & credit
rating)
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.  
£15m per
non-UK
banking
group
g.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.
£10m
maximum 1
year.
100%
maximum
1 year.
h.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
categories (a), (b) and (c) above. 
There is risk to value of capital
loss arising from selling ahead of
maturity if combined with an
adverse movement in interest
rates (no loss if these are held to
The counterparty selection criteria
restricts lending only to high quality
counterparties, utilising MUFG
creditworthiness service.  
£10m per
counterparty
maximum  
1 year.
20%
maximum
1 year.

Page 31

Type of Investment Treasury Risks Mitigating Controls Council
Limits
Common
Good
Limits
maturity).  Liquidity risk will
normally be low.
i. Structured deposit
facilities with banks and
building societies
(escalating rates, 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 categories (a),
(b) and (c) 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
restricts lending only to high quality
counterparties, utilising MUFG
creditworthiness service.  
£20m per
UK banking
group;
£15m per
non-UK
banking
group
50%
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
restricts lending only to high quality
counterparties, utilising MUFG
creditworthiness service.  
£5m and
maximum
1 year.
20% and
maximum
1 year.
Other types of investments
a. Investment properties These are non-service properties
which are being held pending
disposal or for a longer term
In larger investment portfolios some
small allocation of property based
investment may
£10m 20%.

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Type of Investment Treasury Risks Mitigating Controls Council
Limits
Common
Good
Limits
rental income stream.  These are
highly illiquid assets with high
risk to value (the potential for
property prices to fall or for rental
voids).  
counterbalance/compliment the wider
cash portfolio.
Property holding will be re-valued
regularly and reported annually with
gross and net rental streams.
b. 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.
£10m and
maximum  
5 years.
10% and
maximum
5 years.
c. 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.
50% 20%
d. Non-local authority
shareholdings
These are non-service
investments which may exhibit
market risk, be only considered
for longer term investments and
will be likely to be liquid.
Any non-service equity investment
will require separate Member
approval and each application will be
supported by the service rational
behind the investment and the
likelihood of loss.
5% 100%

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Type of Investment Treasury Risks Mitigating Controls Council
Limits
Common
Good
Limits
e. Loans to third parties as
part of the Council’s
Empty Homes Strategy
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 Section
95 Officer approval and each
application is supported by the
service rational behind the loan and
the likelihood of partial or full default.
Each funding request will be
accompanied by financial projections
and be subject to an assessment of
the project and borrower.
£1.5m and a
maximum of
10 years.
N/A
f. Loans to third parties as
part of the Council’s SHF
Front Funding Facility
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 Section
95 Officer approval and each
application is supported by the
service rational behind the loan and
the likelihood of partial or full default.
Each funding request will be
accompanied by financial projections
and be subject to an assessment of
the project and borrower.
£5m and a
maximum of
3 years.
N/A
g. Loans to third parties as
part of the Council’s
Long Term Loan Funding
to RSL’s
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 Section
95 Officer approval and each
application is supported by the
service rational behind the loan and
the likelihood of partial or full default.
Each funding request will be
accompanied by financial projections
£5m and a
maximum of
30 years.
N/A

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Type of Investment Treasury Risks Mitigating Controls Council
Limits
Common
Good
Limits
and be subject to an assessment of
the project and borrower.
h. Hub Co sub debt These are non-service
investments which may exhibit
market risk, be only considered
for longer term investments and
will be likely to be highly illiquid.
Any non-service equity investment
will require separate Member
approval and each application will be
supported by the service rational
behind the investment and the
likelihood of loss.
£10m N/A
i. Investment in a project
run by a Local Authority
or Local Authority Joint
Committee
These are investments which
may exhibit market risks and will
only be considered for medium to
longer term investments
Each investment requires approval by
the Section 95 Officer up to
£250,000, and, above this level,
member approval.  Each application
will be supported by the service
rationale behind the investment and
the likelihood of loss.
£10m N/A

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Treasury Risks
All of the specific investment instruments outlined above are subject to the following
risks: 
1. Credit and counterparty risk This is the risk of failure by a counterparty (bank or
building society) to meet its contractual obligations to the organisation particularly as a
result of the counterparty’s diminished creditworthiness, and the resulting detrimental
effect on the organisation’s finances. There are no counterparties where this risk is zero
although AAA rated organisations have a very high level of creditworthiness.
2. Liquidity risk This is the risk that instant access to cash will not be available when it is
needed. Investments can range from being instant access to term, that is, money is
locked in until an agreed maturity date. However, some forms of investment, for
example, gilts can usually be sold immediately if the need arises.
3. Market risk This is the risk that, through adverse market fluctuations in the value of
the principal sums an organisation borrows and invests, its stated treasury management
policies and objectives are compromised, against which effects it has failed to protect
itself adequately. However, in certain circumstances, exposure to market risk may be
sought, with a view to obtaining a long term increase in value.
4. Interest rate risk This is the risk that fluctuations in the levels of interest rates create
an unexpected or unbudgeted burden on the organisation’s finances, against which the
organisation has failed to protect itself adequately. This authority has set limits for its
fixed and variable rate exposure in the Prudential Indicators within this report.
5. Legal and regulatory risk This is the risk that the organisation itself, or an
organisation with which it is dealing in its treasury management activities, fails to act in
accordance with its legal powers or regulatory requirements, and that the organisation
suffers losses accordingly. The level of both risk exposure and liquidity influences the
rate of return on investments. Generally, the lower the risk or the higher the liquidity, the
lower the rate of return.
Controls on Treasury Risks
1. Credit and counterparty risk The council utilises the creditworthiness service
provided by its treasury advisors to determine which counterparties and countries are of
high creditworthiness to enable investments to be made safely.
2. Liquidity risk The council has a cash flow forecasting model to enable it to determine
how long investments can be made for and how much can be invested.
3. Market risk The council generally does not purchase investment instruments which
are subject to market risk in terms of fluctuation in their value. The authority may
purchase treasury bills as their value does not vary much during their short life.
4. Interest rate risk The council manages this risk by having a view of the future course
of interest rates and formulates a treasury management strategy accordingly. The
strategy aims to minimise net interest costs, consistent with control of risk.

Page 36

5. Legal and regulatory risk The council will not undertake any form of investing until it
has ensured that it has necessary powers and also complied with all regulations.
Unlimited investments
Regulation 24 states that an investment can be shown in tables 1 & 2 as being ‘unlimited’
in terms of the maximum amount or percentage of the total portfolio that can be put into
that type of investment.  However, it also requires that an explanation must be given for
using that category.  
The authority has given the following types of investments an unlimited category:
1. Debt Management Agency Deposit Facility.  This is considered to be the lowest risk
form of investment available to local authorities as it is operated by the Debt
Management Office which is part of H.M. Treasury i.e., the UK Government’s
sovereign rating stands behind the DMADF.  It is also a deposit account and avoids
the complications of buying and holding Government issued treasury bills or gilts.
2. High creditworthiness banks and building societies.  While an unlimited amount
of the investment portfolio may be put into banks and building societies with high
creditworthiness, the council will ensure diversification of its portfolio by ensuring that
no more than £20m of the total portfolio can be placed with any one institution or group
at any one time.
Environmental, Social and Governance (ESG) Considerations
The Treasury Management Code states that “The organisation's credit and counterparty
policies should set out its policy and practices relating to environmental, social and
governance (ESG) investment considerations. This is a developing area, and it is not
implied that the organisation’s ESG policy will currently include ESG scoring or other real-
time ESG criteria at individual investment level.” 
ESG investment considerations are about understanding the ESG risks that an entity is
exposed to and evaluating how well it manages these risks. It is not the same as Socially
Responsible Investing, (typically where you apply negative screens), and equally, it is not
the same as Sustainable Investing, (investing in products / companies based on
expected sustainable and beneficial societal impact, alongside a financial return).
The council is supportive of the Principles for Responsible Investment (www.unpri.org) and
will seek to bring ESG factors into the decision making process for investments. Within
this, the council is also appreciative of the Statement on ESG in Credit Risk and Ratings,
which commits signatories to incorporating ESG into credit ratings and analysis in a
systemic and transparent way. Each of the mainstream credit rating agencies are
signatories to this statement.  
All the main rating agencies now incorporate ESG risks, alongside more traditional
financial risk metrics, when assessing counterparty ratings. As such, their incorporation is
already being done, to an extent, by the council’s use of the creditworthiness service
provided by the council’s treasury advisors. In addition, our treasury advisors continue to

Page 37

look at ways in which these factors can be incorporated into their creditworthiness
assessment service.
Whilst the council is supportive of responsible investment, it should be noted that ESG
information will still be secondary to the requirement for the council to adhere to the Code
priorities of Security, Liquidity and Yield.  Ethical principles must play a subordinate role
to these priorities.  Furthermore, limiting the potential counterparty options could reduce
diversification and increase risk, therefore, these considerations need to be carefully
balanced.

Page 38

APPENDIX 5
MUFG Weekly Credit List
07/02/2026
Long
Term
Short
Term
Long
Term
Short
Term
Long
Term
Short
Term
Suggested
Duration
Suggested
Duration
(Watch/Outloo
k Adjusted)
Suggested Duration
(CDS Adjusted with
manual override)
Australia AAA Aaa AAA Not Applicable Not Applicable Not Applicable
Australia and New Zealand Banking Group Ltd. AA- F1+ Aa2 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
Commonwealth Bank of Australia AA- F1+ Aa2 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
Macquarie Bank Ltd. A+ F1 Aa2 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
National Australia Bank Ltd. AA- F1+ Aa2 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
Westpac Banking Corp. AA- F1+ Aa2 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
Belgium AA- Aa3 AA Not Applicable Not Applicable Not Applicable
BNP Paribas Fortis A+ F1 A1 P-1 A+ A-1 R - 6 mths R - 6 mths R - 6 mths
KBC Bank N.V. A+ F1 Aa3 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Canada AA+ Aaa AAA Not Applicable Not Applicable Not Applicable
Bank of Montreal AA- F1+ Aa2 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Bank of Nova Scotia AA- F1+ Aa2 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Canadian Imperial Bank of Commerce AA- F1+ Aa2 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
National Bank of Canada A+ F1 Aa2 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Royal Bank of Canada AA- F1+ Aa1 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
Toronto-Dominion Bank AA- F1+ Aa2 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Denmark AAA Aaa AAA Not Applicable Not Applicable Not Applicable
Danske A/S A+ F1 A1 P-1 A+ A-1 R - 6 mths R - 6 mths R - 6 mths
Finland AA+ Aa1 AA+ Not Applicable Not Applicable Not Applicable
Nordea Bank Abp AA- F1+ Aa3 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
OP Corporate Bank plc WD WD Aa3 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
France AA- Aa3 AA- Not Applicable Not Applicable Not Applicable
BNP Paribas A+ F1 A1 P-1 A+ A-1 R - 6 mths R - 6 mths R - 6 mths
Credit Agricole Corporate and Investment Bank A+ F1 A1 P-1 A+ A-1 R - 6 mths R - 6 mths R - 6 mths
Credit Agricole S.A. A+ F1 A1 P-1 A+ A-1 R - 6 mths R - 6 mths R - 6 mths
Credit Industriel et Commercial A+ F1 A1 P-1 A+ A-1 R - 6 mths R - 6 mths R - 6 mths
Societe Generale A- F1 A1 P-1 A A-1 R - 6 mths R - 6 mths R - 6 mths
Germany AAA Aaa AAA Not Applicable Not Applicable Not Applicable
Bayerische Landesbank A+ F1+ Aa2 P-1 NR NR O - 12 mths O - 12 mths O - 12 mths
Commerzbank AG WD WD A1 P-1 A A-1 R - 6 mths R - 6 mths R - 6 mths
Deutsche Bank AG A- F2 A1 P-1 A A-1 R - 6 mths R - 6 mths R - 6 mths
DZ BANK AG Deutsche Zentral-
Genossenschaftsbank AA- F1+ Aa2 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Landesbank Baden-Wuerttemberg A+ F1+ Aa2 P-1 NR NR O - 12 mths O - 12 mths O - 12 mths
Landesbank Berlin AG Aa3 P-1 O - 12 mths O - 12 mths O - 12 mths
Landesbank Hessen-Thueringen Girozentrale A+ F1+ Aa2 P-1 NR NR O - 12 mths O - 12 mths O - 12 mths
Landwirtschaftliche Rentenbank AAA F1+ Aaa P-1 AAA A-1+ P - 24 mths P - 24 mths P - 24 mths
Norddeutsche Landesbank Girozentrale A+ F1+ Aa2 P-1 NR NR O - 12 mths O - 12 mths O - 12 mths
NRW.BANK AAA F1+ Aa1 P-1 AA A-1+ P - 24 mths P - 24 mths P - 24 mths
Netherlands AAA Aaa AAA Not Applicable Not Applicable Not Applicable
ABN AMRO Bank N.V. A F1 Aa3 P-1 A A-1 R - 6 mths R - 6 mths R - 6 mths
BNG Bank N.V. AAA F1+ Aaa P-1 AAA A-1+ P - 24 mths P - 24 mths P - 24 mths
Cooperatieve Rabobank U.A. A+ F1 Aa2 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
ING Bank N.V. AA- F1+ Aa3 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Nederlandse Waterschapsbank N.V. Aaa P-1 AAA A-1+ P - 24 mths P - 24 mths P - 24 mths
Norway AAA Aaa AAA Not Applicable Not Applicable Not Applicable
DNB Bank ASA Aa1 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
Qatar AA Aa2 AA Not Applicable Not Applicable Not Applicable
Fitch Rating Moody's Ratings S&P Ratings

Page 39

Qatar National Bank A+ F1 Aa3 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Singapore AAA Aaa AAA Not Applicable Not Applicable Not Applicable
DBS Bank Ltd. AA- F1+ Aa1 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
Oversea-Chinese Banking Corp. Ltd. AA- F1+ Aa1 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
United Overseas Bank Ltd. AA- F1+ Aa1 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
Sweden AAA Aaa AAA Not Applicable Not Applicable Not Applicable
Skandinaviska Enskilda Banken AB AA- F1+ Aa3 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Svenska Handelsbanken AB AA F1+ Aa2 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
Swedbank AB AA- F1+ Aa3 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Switzerland AAA Aaa AAA Not Applicable Not Applicable Not Applicable
UBS AG A+ F1 Aa2 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
United Arab Emirates AA Aa2 AA Not Applicable Not Applicable Not Applicable
First Abu Dhabi Bank PJSC AA- F1+ Aa3 P-1 AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
United Kingdom AA- Aa3 AA Not Applicable Not Applicable Not Applicable
Collateralised LA Deposit* Y - 60 mths Y - 60 mths Y - 60 mths
Debt Management Office Y - 60 mths Y - 60 mths Y - 60 mths
Multilateral Development Banks Y - 60 mths Y - 60 mths Y - 60 mths
Supranationals Y - 60 mths Y - 60 mths Y - 60 mths
UK Gilts Y - 60 mths Y - 60 mths Y - 60 mths
Al Rayan Bank Plc A2 P-1 R - 6 mths R - 6 mths R - 6 mths
Bank of Scotland PLC (RFB) AA- F1+ A1 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Barclays Bank PLC (NRFB) A+ F1 A1 P-1 A+ A-1 R - 6 mths R - 6 mths R - 6 mths
Barclays Bank UK PLC (RFB) A+ F1 A1 P-1 A+ A-1 R - 6 mths R - 6 mths R - 6 mths
Clydesdale Bank PLC A- F1 A1 P-1 A A-1 R - 6 mths R - 6 mths R - 6 mths
Co-operative Bank PLC (The) BBB+ F1 A3 P-2 G - 100 days G - 100 days G - 100 days
Goldman Sachs International Bank A+ F1 A1 P-1 A+ A-1 R - 6 mths R - 6 mths R - 6 mths
Handelsbanken Plc AA F1+ AA- A-1+ O - 12 mths O - 12 mths O - 12 mths
HSBC Bank PLC (NRFB) AA- F1+ A1 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
HSBC UK Bank Plc (RFB) AA- F1+ A1 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Lloyds Bank Corporate Markets Plc (NRFB) AA- F1+ A1 P-1 A A-1 O - 12 mths O - 12 mths O - 12 mths
Lloyds Bank Plc (RFB) AA- F1+ A1 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
National Bank Of Kuwait (International) PLC A+ F1 A A-1 R - 6 mths R - 6 mths R - 6 mths
National Westminster Bank PLC (RFB) A+ F1 A1 P-1 A+ A-1 R - 6 mths O - 12 mths O - 12 mths
NatWest Markets Plc (NRFB) A+ F1 A1 P-1 A A-1 R - 6 mths R - 6 mths R - 6 mths
Santander Financial Services plc (NRFB) A+ F1 A1 P-1 A- A-2 R - 6 mths R - 6 mths R - 6 mths
Santander UK PLC A+ F1 A1 P-1 A A-1 R - 6 mths R - 6 mths R - 6 mths
SMBC Bank International Plc A- F1 A1 P-1 A A-1 R - 6 mths R - 6 mths R - 6 mths
Standard Chartered Bank A+ F1 A1 P-1 A+ A-1 R - 6 mths O - 12 mths O - 12 mths
The Royal Bank of Scotland Plc (RFB) A+ F1 A1 P-1 A+ A-1 R - 6 mths O - 12 mths O - 12 mths
Coventry Building Society A- F1 A3 P-2 G - 100 days G - 100 days G - 100 days
Leeds Building Society A- F1 A3 P-2 G - 100 days G - 100 days G - 100 days
Nationwide Building Society A F1 A1 P-1 A+ A-1 R - 6 mths R - 6 mths R - 6 mths
Principality Building Society BBB+ F2 Baa1 P-2 N/C - 0 mths N/C - 0 mths N/C - 0 mths
Skipton Building Society A- F1 A2 P-1 R - 6 mths R - 6 mths R - 6 mths
Yorkshire Building Society A- F1 A2 P-1 R - 6 mths R - 6 mths R - 6 mths
United States AA+ Aaa AA+ Not Applicable Not Applicable Not Applicable
Bank of America N.A. AA F1+ Aa1 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
Bank of New York Mellon, The AA F1+ Aa1 P-1 AA- A-1+ P - 24 mths P - 24 mths P - 24 mths
Citibank N.A. A+ F1 Aa3 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths
JPMorgan Chase Bank N.A. AA F1+ Aa1 P-1 AA- A-1+ P - 24 mths P - 24 mths P - 24 mths
Wells Fargo Bank, NA AA- F1+ Aa1 P-1 A+ A-1 O - 12 mths O - 12 mths O - 12 mths

Page 40

APPENDIX 6
TREASURY MANAGEMENT SCHEME OF DELEGATION
SECTION 95 OFFICER AND NOMINATED MEMBER ROLES
Council
• Overall responsibility for Treasury Management Strategy.
• Adoption of Treasury Policy Statements.
• Receive an Annual Report and other reports on the Treasury Management
Operation and on the exercise of delegated treasury management powers.
Policy and Resources Committee
• Responsibility for the overall investment of money under the control of the Council.
• Keeping under review the level of borrowing.
• Approval of Annual Strategy Statement.
• Receiving and reviewing reports on treasury management policies, practices and
activities.
• Approval of Treasury Policy Statements.
• Implementation and monitoring of Treasury Management Policies and Practices.
Audit and Scrutiny Committee
• Review the overall internal and management control framework related to the
treasury function.
• Review internal and external audit reports related to treasury management.
• Review provision in the internal and external audit plans to ensure there is adequate
audit coverage of treasury management.
• Monitor progress with implementing recommendations in internal and external audit
reports.
• Reviewing the treasury management policy and procedures and making
recommendations to the responsible body.
Role of the nominated Elected Member (Policy Lead for Finance and Commercial
Services):
• Acting as spokesperson for treasury management.
• Taking a lead for elected Members in overseeing the operation of the treasury
function.
• Review the treasury management policy, strategy and reports.
• Support and challenge the development of treasury management.
Role of the Section 95 Officer:
• Recommending clauses, treasury management policy/practices for approval,
reviewing the same regularly, and monitoring compliance.

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• Submitting regular treasury management policy reports.
• Suubmitting budgets and budget variations.
• Receiving and reviewing management information reports.
• Reviewing the performance of the treasury management function.
• Ensuring the adequacy of treasury management resources and skills, and the
effective division of responsibilities within the treasury management function.
• Ensuring the adequacy of internal audit, and liaising with external audit.
• Recommending the appointment of external service providers.
• Reviewing and considering risk management in terms of treasury activities.
• preparation of a capital strategy to include capital expenditure, capital financing, non-
financial investments and treasury management, with a long term timeframe 
• ensuring that the capital strategy is prudent, sustainable, affordable and prudent in the
long term and provides value for money
• ensuring that due diligence has been carried out on all treasury and non-financial
investments and is in accordance with the risk appetite of the authority
• ensure that the authority has appropriate legal powers to undertake expenditure on
non-financial assets and their financing
• ensuring the proportionality of all investments so that the authority does not undertake
a level of investing which exposes the authority to an excessive level of risk compared
to its financial resources
• ensuring that an adequate governance process is in place for the approval, monitoring
and ongoing risk management of all non-financial investments and long term liabilities
• provision to members of a schedule of all non-treasury investments including material
investments in subsidiaries, joint ventures, loans and financial guarantees ensuring that
members are adequately informed and understand the risk exposures taken on by an
authority
• ensuring that the authority has adequate expertise, either in house or externally
provided, to carry out the above
• creation of Treasury Management Practices which specifically deal with how non-
treasury investments will be carried out and managed, to include the following: -
o Risk management (TMP1 and schedules), including investment and risk
management criteria for any material non-treasury investment portfolios;  
o Performance measurement and management (TMP2 and schedules),
including methodology and criteria for assessing the performance and
success of non-treasury investments;         
o Decision making, governance and organisation (TMP5 and schedules),
including a statement of the governance requirements for decision making
in relation to non-treasury investments; and arrangements to ensure that
appropriate professional due diligence is carried out to support decision
making;

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o Reporting and management information (TMP6 and schedules), including
where and how often monitoring reports are taken;
o Training and qualifications (TMP10 and schedules), including how the
relevant knowledge and skills in relation to non-treasury investments will be
arranged.
The nominated Elected Member (Policy Lead for Finance and Commercial
Services)
• Acting as spokesperson for treasury management.
• Taking a lead for elected Members in overseeing the operation of the treasury
function.
• Review the treasury management policy, strategy and reports.
• Support and challenge the development of treasury management.