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A1 EQA Report AB v2.0

Argyll and Bute Council · 16 March 2023
Back to Audit and Scrutiny Committee — 16 March 2023 and its agenda

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January 2023 Page 1 
EXTERNAL QUALITY
ASSESSMENT 2
OF 
ARGYLL & BUTE COUNCIL’S 
INTERNAL AUDIT SERVICE 
Report Recipients: 
Martin Caldwell, Chair of the Audit and Scrutiny Committee 
Pippa Milne, Chief Executive
Ann Blue, Head of Financial Services
Paul MacAskill, Chief Internal Auditor

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EXECUTIVE SUMMARY 
2
1. INTRODUCTION 
1.1 The mandatory Public Sector Internal Audit Standards (PSIAS), initially published in April
2013 and updated in March 2017, apply to all internal audit service providers in the UK
public sector.  To supplement the PSIAS, and provide specific guidance surrounding its
application within a local government setting, the Chartered Institute of Public Finance
and Accountancy (CIPFA) compiled a Local Government Application Note, last updated
in 2019. 
1.2 The objectives of the PSIAS are: 
 to define the nature of internal auditing within the UK public sector; 
 to set basic principles for carrying out internal audit; 
 to establish a framework for providing internal audit services, which add value to
the organisation, leading to improved organisational processes and operations; 
 to establish the basis for the evaluation of internal audit performance; and 
 to drive improvement planning. 
1.3 The PSIAS require the Chief Audit Executive (the Chief Internal Auditor in Argyll & Bute
Council) to develop and maintain a quality assurance and improvement programme
(QAIP) that covers all aspects of the internal audit activity.  The QAIP must include both
periodic internal self-assessments and five-yearly external assessments.  The external
assessments must be carried out by a qualified, independent assessor from outwith the
organisation, and enable evaluation of the internal audit activity’s conformance with the
PSIAS, including the Mission of Internal Audit, Definition of Internal Auditing and Code
of Ethics.  In addition, the QAIP should also assess the efficiency and effectiveness of
the internal audit activity and identify opportunities for improvement. 
1.4 To assist its members in meeting the five-yearly external assessment requirement, the
Scottish Local Authorities Chief Internal Auditors’ Group (SLACIAG) established a
collaborative system of formal peer reviews.  This approach not only assists with
ensuring that independent assessors, and their teams, have appropriate knowledge and
experience of the local government internal audit environment but also removes the
financial burden from councils associated with procuring these services externally.  The
independence of assessors was considered when allocating assessment teams to
councils participating in the peer review process, ensuring that, amongst other governing
principles, local authorities with perceived/known conflicts of interest could not review
one another.  At the outset, assessors were required to formally declare any interests so
that these could be appropriately addressed during the allocation process.  East
Dunbartonshire Council was selected to carry out the external assessment of Argyll &
Bute.   
1.5 To support the peer review process, SLACIAG developed a comprehensive External
Quality Assessment (EQA) framework, including an EQA Checklist for Assessing
Conformance with the PSIAS and the Local Government Application Note (EQA
Checklist) and a key Stakeholder Questionnaire proforma.  East Dunbartonshire
Council’s Internal Audit service has carried out the external assessment of Argyll & Bute
Council’s Internal Audit service utilising this framework.   
1.6 This report provides a high level summary of requirements for each standard per the
PSIAS and CIPFA Local Government Application Note and details findings, conclusions
and recommendations from the external assessment.  This assessment has involved
discussions with key members of staff, including the Chief Audit Executive, review of the
most recent self-assessment carried out utilising the EQA Checklist and consideration

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EXECUTIVE SUMMARY 
3
of other relevant supporting documentation/information (Evidence Pack) including
working paper files and completed stakeholder questionnaires.  A comprehensive list of
supporting documentation/information and completed stakeholder questionnaires
considered as part of the assessment can be found at appendices B and C respectively. 
1.7 The Assessor would like to thank the Chief Internal Auditor (CIA) for the comprehensive
audit pack that was provided, for the further information that was provided via interview
and on request and for access to the Internal Audit Team members – this all enabled a
smooth and efficient audit process.  Thanks is also extended to all who gave up their
time to complete the stakeholder questionnaires and to be interviewed – this enhanced
the quality of the audit, allowing fuller picture of the Internal Audit Service to be obtained
and thus a more accurate assessment.

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2.  OVERALL CONCLUSION
2.1 The overall conclusion of the external assessment is that Argyll and Bute Council’s
Internal Audit service fully conforms with the PSIAS.  Two points for improvement have
been noted with regards to Standard 2400  - Communicating Results and Standard 1100
- Independence and Objectivity.  Both Standards have nonetheless been assessed as
fully conforms due to the minor nature of the findings.  A full summary of assessment,
per assessment area, can be found at Appendix A.  A summary of totals is as follows:   
Fully
Conforms     
Generally
Conforms     
Partially
Conforms     
Does Not
Conform   
TOTALS 14 0 0 0 
2.2 The areas for improvement highlighted in the report are as follows: 
 The annual governance statement for 2021/22 referred to the Contract
Management Roads and Amenity Services audit conclusion of limited assurance.
Whilst this was noted in a table in the annual audit report, it was not mentioned
in the opinion or report wording.  Instead, reference was made to ‘Subject to
matters listed in the annual governance statement’ in the conclusion of the
covering report. It may help the Audit and Scrutiny (A&S) Committee and provide
clarity if such matters are specifically referred to in the Annual Audit Report. 
 The register of interest which is used to identify potential conflicts of interest on
internal audit work was noted during the review as having been last updated in
February 2021.  The risk is deemed to be low as during the review, Internal Audit
staff demonstrated awareness of when they would flag any potential conflicts of
interest to the Chief Internal Auditor.   This action point has now been completed.
Going forward, the CIA should ensure that the register of interest is updated at
least annually in order to fully demonstrate compliance with PSIAS in this regard. 
2.3 Full details of the assessment recommendations and management responses can be
found in the Action Plan at Appendix D.

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3.  SECTION A – MISSION OF INTERNAL AUDIT AND CORE PRINCIPLES 
The PSIAS state that the Mission of Internal Audit articulates what internal audit aspires
to accomplish within an organisation, which is ‘to enhance and protect organisational
value by providing risk-based and objective assurance, advice and insight’.   
Taken as a whole, the Core Principles for the Professional Practice of Internal Auditing,
as set out in the PSIAS, articulate internal audit effectiveness.  For an internal audit
function to be considered effective, all Core Principles should be present and operating
effectively.  Failure to achieve any of the Core Principles would imply that an internal
audit activity was not as effective as it could be in achieving the Mission of Internal Audit. 
3.1 Evidence obtained from assessing conformance with other standards in the PSIAS has
been used, along with specific consideration surrounding the achievement of the Core
Principles, to conclude that the Internal Audit service at Argyll & Bute Council fully
conforms with accomplishing the Mission of Internal Audit as detailed above. 
4. SECTION B – DEFINITION OF INTERNAL AUDITING 
The PSIAS state that internal auditing is an independent, objective assurance and
consulting activity designed to add value and improve an organisation’s operations. It
helps an organisation accomplish its objectives by bringing a systematic, disciplined
approach to evaluate and improve the effectiveness of risk management, control and
governance processes. 
4.1 Evidence obtained from assessing conformance with other standards in the PSIAS has
been used to conclude that the Internal Audit service at Argyll & Bute Council fully
conforms with the definition of Internal Auditing as detailed above.  The main reason
for this assessment has been the review of the activities, approach and status of the
Internal Audit service throughout the independent review.  Completed Stakeholder
Questionnaires support this conclusion. 
4.2 The Internal Audit service does not currently carry out consulting activity; however, the
Internal Audit Charter makes provision for the possibility of the service carrying out such
work and specifies the parameters for accepting consulting engagements. 
4.3 The Internal Audit service has in place an Internal Audit Charter and the definition of
Internal Auditing included in this document mirrors the PSIAS definition.  Furthermore,
the Internal Audit Plan takes into account the PSIAS requirements, ensuing that the plan
of work aligns to PSIAS.   
5.  SECTION C – CODE OF ETHICS 
The PSIAS state that the purpose of the Institute of Internal Auditor’s Code of Ethics is
to promote an ethical culture in the profession of internal auditing. A code of ethics is
necessary and appropriate for the profession of internal auditing, founded as it is on the
trust placed in its objective assurance about risk management, control and governance. 
Internal auditors in UK public sector organisations must conform to the Code of Ethics
as set out in the PSIAS. If individual internal auditors have membership of another
professional body then he or she must also comply with the relevant requirements of
that organisation. 
5.1 Evidence obtained from assessing conformance with other standards in the PSIAS have
been used to conclude that Argyll & Bute Council’s Internal Audit service fully conforms
with the requirement to comply with the Code of Ethics.  The following standards have
been considered in particular:
The Attribute Standards -
 1000 – Purpose Authority and Responsibility,

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 1100 – Independence and Objectivity, and
 1200 – Proficiency and Due Professional Care. 
The Professional Standards -
 2000 – Managing the Internal Audit Activity and 
 2300 – Performing the Engagement. 
5.2 Completed Stakeholder Questionnaires also support the conclusion. In addition, the
Audit Charter was reviewed and confirmed as being in line with good practice, adhering
to the guidance. 
6. SECTION D – ATTRIBUTE STANDARDS 
Attribute Standards apply to organisations and to individual internal auditors
providing the internal audit service in a local authority. 
6.1 1000 - Purpose, Authority, and Responsibility 
The PSIAS state that the purpose, authority and responsibility of the internal audit
activity must be formally defined in an Internal Audit Charter, consistent with the Mission
of Internal Audit and the mandatory elements of the International Professional Practices
Framework.  The chief audit executive must periodically review the internal audit charter
and present it to senior management and the board for approval.  The internal audit
charter must also: 
 define the terms ‘board’ and ‘senior management’ for the purposes of internal
audit activity;
 cover the arrangements for appropriate resourcing; 
 define the role of internal audit in any fraud-related work; and 
 describe safeguards to limit impairments of independence or objectivity if internal
audit or the chief audit executive undertakes non-audit activities. 
6.1.1  Argyll & Bute Council’s Internal Audit Charter is periodically reviewed, with the most
recent review taking place in March 2022.  The requirements referred to above are
adhered to in the Charter, and the Charter was approved by the A&S Committee on 15
March 2022. 
6.1.2 Having considered the findings above, it has been concluded that the Internal Audit
service at Argyll & Bute Council fully conforms with Standard 1000 on Purpose,
Authority and Responsibility. 
6.2 1100 - Independence and Objectivity 
The internal audit activity must be independent and internal auditors must be objective
in performing their work.  Various aspects of independence and objectivity are covered
in this standard as well as 1200, including reporting functional lines of the CAE, the
relationship between the CAE and the board and any impairment to individual internal
auditor’s objectivity or independence. Reporting and management arrangements must
be put in place that preserve the CAE’s independence and objectivity, in particular with
regard to the principle that the CAE must be independent of the audited activities. 
6.2.1 The CIA reports functionally to the A&S Committee and administratively to the Head of
Financial Services, who attends the Council’s Strategic Management Team.  The CIA
has direct and unrestricted access to the Chief Executive and the Chair of the A&S
Committee and this has been confirmed through the completed Stakeholder
Questionnaires.  These reporting and access arrangements are clearly defined in the

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Internal Audit Charter as are safeguards to limit impairment of independence or
objectivity.   
6.2.2 In support of organisational independence, the CIA attends A&S Committee meetings
to present all internal audit reports (including, for example, the Internal Audit Charter,
Annual Report, Internal Audit Plan and reports from the planned audits) to Elected
Members.  The reports are submitted in the CIA’s name.   
6.2.3 The CIA has operational responsibility for the Counter Fraud Team and Risk
Management and this is communicated to stakeholders via the Internal Audit Charter.   
6.2.4 A minor point for improvement has been noted in that it has been observed that the
register of interest, used to record potential conflicts of interest, appears to have been
last updated in February 2021.  Going forward, this should be updated on at least an
annual basis.  Nonetheless, from interviews with members of the Internal Audit Service,
members of the team are aware of when they should flag potential conflicts with the CIA
and so the risk is largely mitigated. See Appendix – Action 1. 
6.2.5 Argyll & Bute Council’s Internal Audit service fully conforms with Standard 1100 on
Independence and Objectivity. 
6.3 1200 - Proficiency and Due Professional Care 
The CAE must be professionally qualified, suitably experienced and responsible, in
accordance with the organisation’s human resources processes, for recruiting
appropriate staff.  He or she is responsible for ensuring that up-to-date job descriptions
exist, reflecting roles and responsibilities, and that person specifications define the
required qualifications, competencies, skills, experience and personal attributes. 
The CAE should periodically assess individual auditors’ skills and competencies against
those set out in the relevant job descriptions and person specifications. Any training or
development needs identified should be included in an appropriate ongoing
development programme that is recorded and regularly reviewed and monitored. In
addition, all internal auditors have a personal responsibility to undertake a programme
of continuing professional development (CPD) to maintain and develop their
competence. This may be fulfilled through requirements set by professional bodies or
through the organisation’s own appraisal and development programme. Auditors should
maintain a record of such professional training and development activities. 
The internal audit activity should be appropriately resourced to meet its objectives. It
should have appropriate numbers of staff in terms of grades, qualifications, personal
attributes and experience or have access to appropriate resources in order to meet its
objectives and to comply with these standards. The PSIAS states that the CAE must
obtain competent advice and assistance if the activity is unable to perform all or part of
an engagement. 
6.3.1 The CIA is required to hold a relevant CCAB professional accountancy qualification and
the CIA holds two such qualifications, Chartered Institute of Public Finance and
Accountancy (CIPFA) and Chartered Institute of Internal Auditors (CIIA), and is suitably
experienced.  The CIA is a member of SLACIAG and regularly attends and contributes
to meetings.  Argyll & Bute Council’s Internal Audit service is represented on the two
SLACIAG Sub-groups: the Computer Audit Sub-Group (CASG) and the Scottish Local
Authorities Investigators Group (SLAIG).  The CIA has a background in both financial
and IT audit in the public sector.  Questionnaires received from stakeholders have
confirmed the opinion that the CIA is suitably experienced with 29 years of experience
in public sector audit. 
6.3.2 For the roles across the Argyll & Bute Council’s Internal Audit service, there are job and
person specifications in place.  There are a total of five members of staff in the Internal
Audit service, including the CIA.  The Internal Audit service delivers internal audit

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services to the Council, HSCP and ALEO.  The team is highly qualified with a training
plan is in place to address any skills gaps within the team and delivers a high quality
service for the Council and which is evident by the questionnaires returned after the
completion of each review. 
6.3.3 The Internal Audit Team participate in a Performance Review and Development
process.   
6.3.4 The CIA and Audit Team have specific CPD requirements to adhere to.  Each Auditor is
a member of a professional body and is required to maintain a CPD file and in terms of
CIPFA an annual declaration of compliance. 
6.3.5 Argyll & Bute Council’s Internal Audit service fully conforms with standard 1200 on
Proficiency and Due Professional Care. 
6.4 1300 - Quality Assurance and Improvement Programme 
The PSIAS state that the Chief Audit Executive must develop and maintain a quality
assurance and improvement programme (QAIP) that covers all aspects of the internal
audit activity. 
The QAIP must include both periodic internal self-assessments and five-yearly external
assessments, carried out by a qualified, independent assessor from outside the
organisation, and enable evaluation of the internal audit activity’s conformance with the
PSIAS, including the Definition of Internal Auditing and Code of Ethics. In addition, the
QAIP should also assess the efficiency and effectiveness of the internal audit activity
and identify opportunities for improvement. 
The public sector requirement in the PSIAS states that results of the QAIP and progress
against any improvement plans must be reported in the annual report. 
6.4.1 Internal audit reports are reviewed by the CIA prior to issue and working papers are
reviewed by the CIA.   
6.4.2 Post audit surveys are sent to audit contacts after the completion of each audit to assess
the performance and quality of reports.  Internal audit have a positive performance target
of 80% from these surveys and performance is monitored against this target. 
6.4.3 Internal Audit monitor their development plan and the status of all development actions
is reported to the A&S Committee as part of a standard agenda item.   
6.4.4 An external assessment against Public Sector Internal Audit Standards was previously
carried out by the Chief Internal Auditor for FTF Audit and reported to the A&S
Committee in September 2018.  The internal audit service was concluded as
demonstrating overall compliance with PSIAS requirements, whilst four areas relating to
risk were identified for improvement. An action plan was developed to address these
areas and these improvement actions have been completed. 
6.4.5 Argyll & Bute Council’s Internal Audit service fully conforms with Standard 1300 on
Quality Assurance and Improvement Programme. 
7. SECTION E – PERFORMANCE STANDARDS 
Performance Standards describe the nature of the internal audit services being
provided and provide criteria against which the performance of an internal audit
function can be measured. 
7.1 2000 - Managing the Internal Audit Activity 
The chief audit executive must effectively manage the internal audit activity to ensure it
adds value to the organisation.  The internal audit activity is effectively managed when

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it achieves the purpose and responsibility included in the internal audit charter, it
conforms with the PSIAS, its individual members conform with the Code of Ethics and
the PSIAS and it considers trends and emerging issues that could impact the
organisation.  The internal audit activity adds value to the organisation and its
stakeholders when it considers strategies, objectives and risks; strives to offer ways to
enhance governance, risk management, and control processes; and objectively
provides relevant assurance. 
7.1.1 An annual Internal Audit Plan is compiled by the CIA outlining the planned programme
of work to be undertaken.  The CIA attends SMT meetings on a fortnightly basis which
ensures he is well sighted on the Council’s strategies, objectives and risks and of any
issues that occur which may change the risk profile of the Council and, subsequently,
areas for audit focus.  In addition, the CIA reviews Business Plans, Local Outcome
Agreement and Corporate and Operational Risk Registers. 
7.1.2 The A&S Committee agrees and endorses the Internal Audit Plan. 
7.1.3 The Internal audit service reports on performance to the Committee on a quarterly basis
including full copies of audit reports issued, progress implementing audit
recommendations, performance against agreed performance indicators and a summary
of all internal audit activity in the previous quarter. 
7.1.4 Argyll & Bute Council’s Internal Audit service fully conforms with Standard 2000 on
Managing the Internal Audit Activity. 
7.2 2100 - Nature of Work 
The internal audit activity must evaluate and contribute to the improvement of the
organisation’s governance, risk management, and control processes using a systematic,
disciplined, and risk-based approach. Internal audit credibility and value are enhanced
when auditors are proactive and their evaluations offer new insights and consider future
impact. 
More specifically, the internal audit activity must assess and make appropriate
recommendations to improve the organisation’s governance processes, evaluate the
effectiveness and contribute to the improvement of risk management processes and
assist the organisation in maintaining effective controls by evaluating their efficiency and
effectiveness and promoting continuous improvement. 
7.2.1 Audit work regularly focuses on areas of governance such as robustness of policies and
procedures, performance reporting (which focuses on the achievement of strategic
objectives), budget monitoring (financial information), and compliance with relevant
legislation. 
7.2.2 An audit assessing compliance with the Council’s risk management arrangements is
performed every three years. 
7.2.3 Controls are assessed through the internal audit plan and through considerations on
individual assignments. 
7.2.4 Fraud risks are considered and Internal audit carry out a programme of continuous
monitoring which provides audit coverage across the main financial transactional
processes on an annual basis. This helps to ensure there are good controls in relation
to processing transactions which, in turn, reduces the risk of fraud. 
7.2.5 Argyll & Bute Council’s Internal Audit service fully conforms with Standard 2100 on
Nature of Work.

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7.3 2200 - Engagement Planning 
Internal auditors must develop and document a plan for each engagement, including the
engagement’s objectives, scope, timing and resource allocations. The plan must
consider the organisation’s strategies, objectives and risks relevant to the engagement. 
The CIPFA Local Government Application note states that for each engagement, a brief
should be prepared, discussed and agreed with relevant managers. The brief should
establish the objectives, scope and timing for the assignment and its resource and
reporting requirements. Audit work should be undertaken using a risk-based audit
approach. 
7.3.1 Terms of Reference planning documents are in place which include objectives, scope,
timing, resources allocated and consideration of the organisation’s strategies, objectives
and risks relevant to the engagement. The final Terms of Reference document is agreed
with the relevant Head of Service. 
7.3.4 Argyll & Bute Council’s Internal Audit service fully conforms with Standard 2200 on
Engagement Planning. 
7.4 2300 - Performing the Engagement 
Internal auditors must identify, analyse, evaluate and document sufficient information to
achieve the engagement’s objectives. 
At each stage of the audit, auditors should consider what specific work needs to be
conducted and evidence needs to be gathered to achieve the engagement objectives
and support an independent and objective audit opinion.  Systems should be in place to
ensure that auditors obtain and record, within the working papers, sufficient evidence to
support their conclusions, professional judgements and recommendations.  Working
papers should always be sufficiently complete and detailed to enable an experienced
internal auditor with no previous connection with the audit to ascertain what work was
performed, re-perform it if necessary and support the conclusions reached.  The CAE
should also specify how long all audit documentation should be retained, whether held
on paper or electronically.  All audit work should be subject to an appropriate internal
quality review process. 
Internal auditors must be alert to the possibility of intentional wrongdoing, errors and
omissions, poor value for money, failure to comply with management policy and conflicts
of interest when performing their individual audits. They must also have sufficient
knowledge to identify indicators that fraud or corruption may have been committed. 
7.4.1 The Internal Audit Manual sets out the procedure in relation to undertaking a planned
audit, including preparing working papers and setting up working paper files.   
7.4.2 Electronic engagement records are kept in a restricted folder and on Sharepoint.  ICT
are responsible for the security controls, and the CIA is responsible for specifying who
should have access to this. 
7.4.3 Work Programmes have been standardised. These detail the test of control, the work
performed, results, conclusion, issues raised and risk.   
7.4.4 A standard template is also utilised for the CIA performing a review of the file – an audit
review schedule, where any questions the CIA may have are noted for the auditor to
answer.  This helps to ensure consistency and quality of both the audit files and of the
final report. 
7.4.5 Argyll & Bute Council’s Internal Audit service fully conforms with Standard 2300 on
Performing the Engagement.

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7.5 2400 - Communicating Results 
The basic aims of every internal audit report should be to: 
 give an opinion on the risk and controls of the area under review, building up to
the annual opinion on the overall adequacy and effectiveness of the
organisation’s framework of governance, risk management and control;
 prompt management to implement the agreed actions for change leading to
improvement in the control environment and performance; and
 provide a formal record of points arising from the audit and, where appropriate,
of agreements reached with management, together with appropriate timescales. 
Each report should include the scope and purpose of the audit to help the reader to
understand the extent, or limitations, of the assurance(s) provided by the report.  During
the course of the audit, key issues should be brought to the attention of the relevant
manager to enable them to take corrective action and to avoid surprises at the closure
stage.  Before issuing the final report, the internal auditor should normally discuss the
contents with the appropriate levels of management to confirm the factual accuracy, to
seek comments and to confirm the agreed management actions. A draft report is useful
for this purpose.  Recommendations should be prioritised according to risk. The
recommendations and the resultant management action plans should be agreed prior to
the issue of the final report.  Any areas of disagreement between the internal auditor and
management that cannot be resolved by discussion should be recorded in the action
plan and the residual risk highlighted.  Those weaknesses giving rise to significant risks
that are not agreed should be brought to the attention of a more senior level of
management and the board. 
As set out in the PSIAS, the CAE must deliver an annual internal audit opinion and report
that can be used by the organisation to inform its annual governance statement. This
must include the annual internal audit opinion concluding on the overall adequacy and
effectiveness of the organisation’s governance, risk and control framework, a summary
of the audit work from which the opinion is derived (including reliance placed on work by
other assurance bodies); and a statement of conformance with the PSIAS and the
results of the internal audit QAIP. 
7.5.1 Each report issued by Internal Audit outlines the auditors’ conclusions and significant
issues identified.  Reviews which identify significant or serious control weaknesses form
part of the annual reporting and formal opinion reached in terms of the control
environment. 
7.5.2 As part of the standard audit approach, the team member carrying out the audit will have
a feedback meeting with the key audit contact to discuss the arising issues.  There will
also be iterative communication with the key contact to clear the audit report.  These
communications are primarily made by e-mail due to the geographic spread of the
Council. 
7.5.3 With regards to handling disagreements, it is rare that a manager would not implement
a recommendation.  Internal Audit always aim to find common ground in relation to
recommendations and implementation. In instances of unresolvable disagreement, the
report would highlight that agreement could not be reached and the potential risk to the
organisation.  This would be reported to the A&S Committee. 
7.5.4 The annual governance statement referred to the Contract Management Roads and
Amenity Services having been given limited assurance.  Whilst this was noted in a table
in the annual audit report, it was not mentioned in the opinion wording.  Instead,
reference was made in the covering paper conclusion to ‘Subject to matters listed in the
annual governance statement’.  It may help the A&S Committee and provide clarity if

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such matters are specifically referred to in the Annual Audit Report and Opinion. See
Appendix – Action 2. 
7.5.5 Argyll & Bute Council’s Internal Audit service fully conforms with Standard 2400 on
Communicating Results. 
7.6 2500 - Monitoring Progress 
The PSIAS place responsibility for monitoring progress with the CAE to ensure that
management actions have been effectively implemented or, if not, that senior
management have accepted the risk of not taking action.  The CAE must, therefore,
implement a follow-up process for ensuring the effective implementation of audit results
or ensuring senior management are aware of the consequences of not implementing an
action point and are prepared to accept the risk of such consequences occurring. The
results of this process should be communicated to the board.  The CAE should develop
escalation procedures for cases where agreed actions have not been effectively
implemented by the date agreed. These procedures should ensure that the risks of not
taking action have been understood and accepted at a sufficiently senior management
level. The effective involvement of the board in the follow-up process is critical to
ensuring that it works. The CAE should consider revising the internal audit opinion in
light of findings from the follow-up process.  The findings of follow-up reviews should
inform the planning of future audit work. 
7.6.1 There is a comprehensive follow up programme in place whereby actions are followed
up on a quarterly basis with the agreed responsible person in order to gauge and monitor
progress with the agreed actions.   
7.6.2 Progress with actions is reported to the Strategic Management Team and the A&S
Committee on a quarterly basis. Follow-up results are also taken into account and
referred to in the annual report. 
7.6.3 Argyll & Bute Council’s Internal Audit service fully conforms with Standard 2500 on
Monitoring Progress. 
7.7 2600 - Communicating the Acceptance of Risks 
When the chief audit executive concludes that management has accepted a level of risk
that may be unacceptable to the organisation, they must discuss the matter with senior
management. If the chief audit executive determines that the matter has not been
resolved, they must communicate the matter to the board. It is not the responsibility of
the chief audit executive to resolve the risk. 
7.7.1 The CIA has unrestricted access to the Chief Executive and Chair of the A&S Committee
and can provide assurance that, should it be required, he can escalate issues directly to
them.  The CIA also attends SMT meetings giving him access to the SMT should he
have any concerns that need to be raised. 
7.7.2 All audit reports are taken to the A&S Committee and are presented to the SMT. 
7.7.3 The CIA contributes to the annual governance statement and the annual audit opinion
is reported to the A&S Committee. 
7.7.4 Argyll & Bute Council’s Internal Audit service fully conforms to the Standard on
Communicating the Acceptance of Risk. 
Gillian McConnachie CA
Audit & Risk Manager and Chief Internal Auditor
East Dunbartonshire Council
January 2023

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APPENDIX A – SUMMARY OF ASSESSMENT 
REF PAGE
No. ASSESSMENT AREA
Fully
Conforms 
Generally
Conforms 
Partially
Conforms 
Does Not
Conform 
Section A 5 Mission of Internal Audit and Core Principles    
Section B 5 Definition of Internal Auditing    
Section C 5 Code of Ethics    
Section D 6 ATTRIBUTE STANDARDS 
1000 6 Purpose, Authority and Responsibility    
1100 6 Independence and Objectivity    
1200 7 Proficiency and Due Professional Care    
1300 8 Quality Assurance and Improvement Programme    
Section E 8 PERFORMANCE STANDARDS 
2000 8 Managing the internal Audit Activity    
2100 9 Nature of Work    
2200 10 Engagement Planning    
2300 10 Performing the Engagement    
2400 11 Communicating Results

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2500 12 Monitoring Progress    
2600 12 Communicating the Acceptance of Risks    
TOTALS 14 0 0 0

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APPENDIX B – EVIDENCE PACK
The following represent the main sources of evidence that were
considered in the course of the review:
 Minutes and papers from A&S Committee
 Audit Manual
 Stakeholder Questionnaires
 Interviews with the CIA, members of the audit team and an Executive Director
 Job Descriptions
 Code of Conduct
 Performance and Career Conversation Template
 Evidence of qualification
 Organisational chart
 Audit Survey Template
 CPD records
 Audit Survey Monitoring and Actions
 Prior EQA report
 Audit Plan Consultation
 HSCP Audit Plan Consultation
 Assurance Mapping
 Audit Universe
 Audit Plan
 Anti-Fraud Strategy 
 LiveArgyll Service Level Agreement
 A sample of audit files 
APPENDIX C – STAKEHOLDER QUESTIONNAIRES
Stakeholder questionnaires were completed by the following key members of staff and Elected
Members:
 Martin Caldwell, Chair of the A&S Committee
 Pippa Milne, Chief Executive
 Kirsty Flanagan, Executive Director
 Douglas Hendry, Executive Director

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APPENDIX D – ACTION PLAN
No.  Para  Recommendation  Management Response  Responsible Officer
/ Agreed
Completion Date 
1 6.2.4
The register of interest which is used to identify potential
conflicts of interest on internal audit work appears to
have been last updated in Feb 2021.  The risk is deemed
to be low as staff demonstrate awareness of when they
would flag any potential conflicts of interest to the Chief
Internal Auditor.  Nonetheless the register should be
updated as soon as practical and annually thereafter in
order to fully demonstrate compliance with PSIAS in this
regard.
Whilst there was a register of interest in place for staff, this
should have been reviewed annually as outlined in the
recommendation. This has since been fully reviewed and
updated and an updated copy has been provided to the
Assessor as evidence of completion.
Completed 21st
December 2022.
2 7.5.4
The annual governance statement for 2021/22 referred to
the Contract Management Roads and Amenity Services
audit conclusion of limited assurance.  Whilst this was
noted in a table in the annual audit report, it was not
mentioned in the opinion or report wording.  Instead,
reference was made to ‘Subject to matters listed in the
annual governance statement’ in the conclusion of the
covering report.  It may help the Audit and Scrutiny
Committee and provide clarity if such matters are
specifically referred to in the Annual Audit Report.
This will be addressed as part of the review of the Annual
Governance Statement and also the production of the Internal
Audit Annual Report for 2022/23.
August 2023 
Critical 
Significant 
Routine