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Agenda Document Pack - Audit Committee - 24/02/2025

Midlothian Council · 24 February 2025
Back to Audit Committee — 24 February 2025 and its agenda

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Page 1

Notice of Meeting and Agenda 
Audit Committee 
Venue:  Council Chambers/Hybrid, 
Midlothian House, Dalkeith, EH22 1DN 
Date:  Monday, 24 February 2025 
Time:  11:00 
Executive Director : Place 
Contact:
Clerk Name: Democratic Services
Clerk Telephone: 
Clerk Email: democratic.services@midlothian.gov.uk 
Further Information: 
This is a meeting which is open to members of the public.  
Privacy notice: Please note that this meeting may be recorded. The
recording may be publicly available following the meeting. If you would
like to know how Midlothian Council collects, uses and shares your
personal information, please visit our website: www.midlothian.gov.uk 
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1          Welcome, Introductions and Apologies   
2          Order of Business 
Including notice of new business submitted as urgent for consideration at the
end of the meeting. 
3          Declaration of Interest 
Members should declare any financial and non-financial interests they have in
the items of business for consideration, identifying the relevant agenda item
and the nature of their interest. 
4          Minute of Previous Meeting 
Minute of Audit Committee 25 November 2024 submitted for
approval
5 - 16
4.2 Action Log 17 - 18 
5          Public Reports
5.1 Midlothian Council Annual Audit Plan 2024/25 - Draft, report by
Audit Director, Audit Scotland
19 - 38
5.2 Local Government in Scotland: Financial Bulletin 2023/24, report
for information, Audit Scotland
39 - 74
5.3 Treasury Management and Investment Strategy 2025/26 &
Prudential Indicators, report by Chief Financial Officer & Section
95 Officer
75 - 152
5.4 Internal Audit Work to January 2025, report by Chief Internal
Auditor
153 - 164
5.5 Internal Audit Mid-Term Performance Report 2024/25, report by
Chief Internal Auditor
165 - 176
5.6 Internal Audit Charter, report by Chief Internal Auditor 177 - 190
5.7 Internal Audit Strategy and Annual Plan 2025/26, report by Chief
Internal Auditor
191 - 206
5.8 Counter Fraud Annual Plan 2025/26, report by Chief Internal
Auditor
207 - 212
5.9 Audit Committee Recruitment of an Independent Member, report
by Chief Internal Auditor
213 - 224
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5.10 Strategic Risk Profile Quarter 2&3, 2024-25, report by Chief
Officer Place
225 - 306 
6          Private Reports 
No items for discussion 
7          Date of Next Meeting 
The next meeting will be held on Monday 16 June 2025 at 11am. 
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Minute of Meeting 
Audit Committee        
Monday 24 February 2025
Item No 4.1 
Audit Committee 
Date Time Venue
Monday 25 November 2024 11am Council Chambers/Hybrid 
Present:
Councillor McEwan (Chair)
Councillor McCall
Councillor Bowen 
In Attendance:
Councillor Pottinger (virtual)  
Councillor Scott (virtual)  
Councillor Winchester (virtual)  
Dr Grace Vickers  Chief Executive 
Kevin Anderson Executive Director Place
Morag Barrow  Director of Health & Social Care: Midlothian
HSCP Chief Officer to Midlothian IJB
David Gladwin Chief Financial Officer and Section 95 Officer
Saty Kaur Chief Officer Corporate Solutions
Derek Oliver Chief Officer Place
Duncan Stainbank Chief Internal Auditor
Michelle Strong Education Chief Operating Officer 
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Gary Thomson Senior Finance Business Partner
Alan Turpie Legal and Governance Manager and Monitoring
Officer
Patricia Fraser Audit Scotland
Claire Gardiner Audit Director, Audit Scotland
Lisa Young Acting Senior Business Partner
Iina Jaara Democratic Services Team Leader
Maria Perez Democratic Services Officer 
1. Welcome and Apologies for Absence 
The Chair welcomed everyone to the meeting of the Audit Committee. 
Apologies were received from Councillor Milligan.
2. Order of Business 
The order of business was as detailed in the agenda.
3. Declarations of interest 
No declarations of interest were intimated at this stage of the proceedings. 
4. Minute of Previous Meeting
4.1 Minutes of the previous meeting held 30 September 2024 were submitted and
approved as the correct record. Minutes were moved by Councillor McCall and
seconded by Councillor Bowen.
4.2 The Action Log was submitted and noted. 
5.      Public Reports 
Report No. Report Title Submitted by:
5.1
Annual Audit Report to Members and
the Controller of Audit –
year ended 31 March 2024
Audit Scotland
Outline of report and summary of discussion
The Audit Director presented the report for noting. 
Audit Scotland completed two reports on the 2023-2024 accounts, including the
Independent Auditor’s report and the Annual Audit Report.   
The Audit Director referred to the International Standards in Auditing (ISA) 580
letter which is required by audit standards and discussed the financial statements’
audit work. The Audit Director stated that the report provides an unmodified opinion
on the annual accounts and in that regard everything is satisfactory. 
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The purpose of the Annual Audit Report’s role is to highlight significant audit matters
and unadjusted errors. The Audit Director stated that there are no errors for the
financial year audited. 
Appendix B in the report contains the Chief Financial Officer and Section 95’s letter
of representation which offers assurance on the matters of fraud, liability and any
non-compliance with rules and regulations. The Audit Director asked the Elected
Members to confirm if this letter aligns with their understanding of fraud or non-
compliance. 
Elected Members thanked the Audit Director for the reports and praised the good
financial management shown by the Chief Financial Officer and Section 95’s team. 
The Audit Director explained that the Annual Audit Report concludes Audit
Scotland’s involvement for the financial year 2023-2024. Audit Scotland confirmed
they had complied with ethical standards and remained independent. The Audit
Director highlighted the following parts in the report: 
Section 1- The Audit Director confirmed Audit Scotland is issuing an unmodified
opinion. 
Exhibit 1 highlights a materiality increase from planning which is linked to increased
gross expenditure rather than an increase in the percentages applied or the
benchmark used. 
Exhibit 2 points out seven significant audit matters for the Elected Members’
attention. These issues or errors have been discussed with management. The first
three issues relate to non-current assets, and these have been highlighted to the
Finance Team and Valuer:
• Condition ratings (received post year-end) led to the Valuer making
adjustment on the value of Council buildings and resulted in an adjustment
of £19 million in the accounts. 
• Valuation process used for Council dwellings. While Audit Scotland found no
material error, they recommend the Valuer considers rent yield factor for next
valuation 
• Two mixed use properties in which the majority use had not been reflected
in the choice of the Building Cost Information Service code. This resulted in
an adjustment of £1 million. 
The Audit Director also highlighted holiday pay accrual and explained that the
absence rates applied had an error which was corrected resulting in a £3 million
adjustment. 
Exhibits 3 and 4 in the report highlight risks identified during the audit process but
in all instances Audit Scotland is satisfied these risks will not result in material
misstatement in the annual accounts. 
Sections 2 to 5 in the report flag that appropriate and effective financial
arrangements are in place, and that the Council ended the financial year with a
small budget underspend of £0.1 million. The report also identified some areas in
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Page 8

which controls could be strengthened. These are not seen by Audit Scotland as
weaknesses but as areas for improvement. 
The report also highlighted reserves diminished in year, and that the Council made
use of the financial flexibilities around service concessions in year which has
impacted the opening balance of reserves by moving it upwards by £20 million. 
In terms of financial sustainability, the Council’s Medium Term Financial Strategy
has identified a budget gap of £20 million. The Audit Director stated that Midlothian
Council is not underestimating the risk and is taking appropriate action to address
sustainability. 
The Audit Director stated that there is an effective governance and performance
framework in place, summarised by the Best Value Report brought to this
Committee in September 2024. The Workforce Strategy recommendations made
in the Best Value Report are in the process of being implemented. The Audit
Director thanked the Finance Team for their hard work and cooperation during the
audit process.
Elected Members expressed their satisfaction with the findings of the Audit
Scotland report and thanked all those involved.
The report was moved by Councillor McCall and seconded by Councillor Bowen.
Decision
The Audit Committee approved the recommendations in the report. 
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Report No. Report Title Submitted by:
5.2 Annual Accounts for the year ended
31 March 2024
Chief Financial
Officer and Section
95 Officer 
Outline of report and summary of discussion
he Chief Financial Officer and Section 95 Officer presented the report for decision.
The Chief Financial Officer and Section 95 Officer noted that the draft annual
accounts had been submitted to the Audit Committee on 24 June 2024 and passed
to Audit Scotland. The Committee is asked to approve the audited annual accounts.
It is a governance requirement for the annual accounts to be approved prior to the
Chief Financial Officer and Section 95 Officer, Chief Executive and Council Leader
signing them so that Audit Scotland can issue the audit certificate.  
During the last 5 months Audit Scotland carried out an extensive audit and issued
an unmodified opinion.
The Audit Director already addressed some areas of accounts that required
adjustment which are also listed in section 3.2 of the Chief Financial Officer and
Section 95’s report:
• The error in the unused annual leave calculation has been amended,
resulting in changes to the comprehensive income and expenditure account,
increased creditor balance and increased statutory reserve for employee
benefits. This is a non-cash adjustment.
• In terms of accounting for non-current assets, the draft annual accounts were
prepared with information available at the time. There was an asset condition
survey carried out simultaneously, and after the findings of this survey were
released, the decreased value of some assets resulted on a reduction of
£19.5 million pounds.
• Other adjustments have been made in the valuation methodology of mixed-
use properties and housing stock discount factor but in either case these are
non-cash adjustments and Council reserves were not affected.
The Chief Financial Officer and Section 95 Officer noted the challenging financial
landscape and the difficulty to justify investing in additional resources. This
mismatch between demand, focus, expectations of auditors and the need to
provide resource allocations by Councils has been observed at a national level. 
The third adjustment impacts the value of Midlothian Energy Limited, in which the
Council holds a 50% share consolidated in group accounts. Again, this has not
resulted in a change to reserves.
Finally, the Scottish Government changes to non-domestic rates have resulted in
some adjustments to the creditor accounts. This has not impacted cash reserves.
In response to feedback received from Audit Scotland and Elected Members, there
have been other minor adjustments to the annual accounts.
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The Chief Financial Officer and Section 95 Officer noted that Audit Scotland found
the papers provided to be of good standard and that colleagues in the Council had
worked well with auditors during the audit process.
The Chief Financial Officer and Section 95 Officer highlighted reserve sustainability
which along with the budget gap are the main challenges noted in the report.  
Members were reminded that the usable reserves in March 2023 had £33 million
in the Housing Revenue Account to support the Council’s housebuilding program.
The Capital Fund had £17 million earmarked to support capital investment.
Midlothian’s growth is putting pressure on this fund as new infrastructure is
required. Another £4 million was earmarked for repairs and renewals as part of the
Public Private Partnership (PPP) accounting regime. The General Fund had £46
million, most of which was either cross-year flexibility or to be released in the
coming years to support recurring expenditure whilst longer-term sustainable
change is made. 
Planned utilisation of reserves leaves the Council with £9 million of non-earmarked
reserves, which have decreased to £6.8 million reflecting the pressures of the
current financial year. The Chief Financial Officer and Section 95 Officer warned
that Council reserves are getting close to the minimum 2% figure of £4.8 million.
Elected Members asked whether retrofitting a property affects the value of the
asset, and in that case whether re-evaluation is needed. The Chief Financial Officer
and Section 95 Officer confirmed that investment in assets is reflected in the value
of those assets.   
Councillor McCall moved to approve the 2023-2024 audited annual accounts,
Councillor Bowen seconded the motion. 
Decision
The Audit Committee approved the audited annual accounts for the financial year
ending 31 March 2024 for signature in light of the appointed auditor’s report. 
Report No. Report Title Submitted by:
5.3 Treasury Management Mid-Year review
2024/2025
Chief Financial
Officer and Section
95 Officer
Outline of report and summary of discussion
The Chief Financial Officer and Section 95 Officer presented the report for noting.
The report informs Elected Members of treasury management activity undertaken
during the first half of 2024/2025 and the forecast activity for the second half of
2024/2025 in accordance with the Treasury Management and Annual Investment
Strategy approved by Council on 27 February 2024. Elected Members are invited
to comment on this report which is to be presented to Council on 17 December
2024. 
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Section 3 of the report provides background information on the role of the Audit
Committee in treasury management. 
Section 4 provides a summary of the economic environment of the first half of this
financial year.
Section 5 describes the main areas of treasury activity. 
The position on 31 March 2024 showed an under borrowed position of £60.9 million
which had increased to £67.8 million by 30 September 2024. The Council took
advantage of low interest rates in August to secure two £10 million loans for a 4-5
year period. A further £10 million was borrowed last week under the same rationale,
with the additional risk mitigation that it would allow the Council not to rely on
internal borrowing. Table 2 on page 184 shows information on the Council’s funds
on deposits showing little variation between the deposit values on 31 March and 30
September 2024. 
Section 6.6.1 provides an update on economic conditions post-UK budget showing
an increase in inflationary pressures and section 6.6.2 shows expected treasury
activity for the second half of the financial year 2024/2025. Through effective
treasury decisions the Council avoided the need to borrow during the period of high
interest rates. The Chief Financial Officer and Section 95 Officer stressed the need
to not overly rely on internal borrowing and added that the Finance Team will
continue to explore favourable borrowing opportunities. 
Section 8 shows Midlothian’s performance indicators compared to other Local
Authorities. Data on other Local Authorities’ loan fund rate is provided for
comparison and illustrates the financial benefits of the current treasury
management strategy for Midlothian Council. 
Elected Members congratulated the Chief Financial Officer and Section 95 Officer
for their probity and efficient bookkeeping. 
Councillor McCall moved to adopt the recommendations in the report, seconded by
Councillor Bowen. 
Decision
The Audit Committee noted the recommendations set out in the report. 
Report No. Report Title Submitted by:
5.4 Internal Audit Work to October 2024 Chief Internal
Auditor 
Outline of report and summary of discussion
The Chief Internal Auditor presented the report for decision. The report informs
Members of the recent work carried out by the Internal Audit Team and the findings
and actions agreed by management to improve internal controls and governance
arrangements. 
The Chief Internal Auditor highlighted that final assurance reports have been
completed for Attainment Scotland Funding and Midlothian Energy Limited which
show that risk management, governance and controls are reasonable. Midlothian
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Energy Limited is a 50/50 joint venture established in 2020 between Vattenfall and
Midlothian Council to provide low carbon heating and eventually other energy
solutions. Key agreements including a shareholders’ agreement and concession
agreement are in place between both organisations. 
The internal audit work on Midlothian Energy Limited has identified the following
areas for improvement: 
• Although financial extracts are provided to Midlothian Energy Limited, full
management accounts as required by the shareholders agreement are not
being provided.
• There is no separate risk register for approved projects approved or an overall
risk register for Midlothian Energy Limited and no separate risk management
policy. 
The Chief Internal Auditor advised that page 215 in the report contains the
Attainment Scotland Funding summary. The Attainment Scotland Funding is
distributed from the Scottish Government to Local Authorities and is composed of
funds from Pupil Equity, Strategic Equity and Care Experienced Young People
Funding. Midlothian Council fully allocates Pupil Equity Funds to schools. The
report highlights that there are processes and governance in line with Council
procedures and national guidance.  However, some issues were identified, and the
report recommends that they are addressed, and management have agreed to
complete by March 2025: 
• Schools have not provided an annual audit report of the use of their school fund
since the pandemic.
• Transfers from Pupil Equity Funds to schools increased significantly over the
past two years and processes have not yet been established for schools to
formally report on their use of the Pupil Equity Funding.
• There is no service level agreement for the use of Pupil Equity Funds for play
therapy in primary school settings.
• The Care Experienced Young People Fund does not have a service level
agreement for their provider of art therapy supplies 
Elected Members thanked the Chief Internal Auditor for the report. Councillor
McCall recommended the adoption of this report and Councillor Bowen seconded
this motion. 
Decision
The Audit Committee approved the recommendations set out in the report. 
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Report No. Report Title Submitted by:
5.5 Follow-Up Review of Completed
Internal Audit Recommendations
and Progress Update
Chief Internal
Auditor  
Outline of report and summary of discussion 
The Chief Internal Auditor presented the report for decision. The report updates
Elected Members on the results of the internal audit follow-up review including a
sample check on the adequacy of new internal controls for internal audit
recommendations which were marked as completed by management in the period
April 2023 to March 2024. The report also updates Elected Members on the status
of the implementation by management of recommendations from Internal Audit
Reports. 
From a sample of 33 recommendations, 22 have been completed in a satisfactory
manner, 7 have been partially completed and 4 are yet to be completed. Of the 7
partially completed recommendations 5 are low rated and the remaining 2 are
medium rated, and all are to be taken to finalisation by management. 
Of the 4 not yet completed recommendations, 2 are medium rated and 2 are low
rated. One of the partially completed recommendations has been confirmed as
closed since the completion of this report brings the number of partially completed
recommendations down to 6 which will be monitored until completion by
management and internal audit within the Council. 
Appendix 1 on page 221 provides a list of recommendations which are past their
target dates. 
The Chief Internal Auditor summarised that the report shows management are
taking appropriate steps to implement recommendations made by the Internal Audit
Report however competing priorities sometimes delays this process. 
Elected Members pointed out that Appendix 1 in the report needs to be updated as
some of the action owners have left Midlothian Council.  The Chief Internal Auditor
advised this would be updated. 
Councillor McCall recommended the adoption of this report with the above
amendment and Councillor Bowen seconded this recommendation. 
Decision
The Audit Committee accepted the recommendations set out in the report.
Action
Chief Internal Auditor to update Appendix 1 in report with the correct overdue
action owners. 
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Report No. Report Title Submitted by:
5.6 Audit Scotland Report: The National
Fraud Initiative in Scotland
2024
Chief Internal
Auditor  
Outline of report and summary of discussion
The Chief Internal Auditor presented the report for noting. The report informs
Elected Members of Audit Scotland’s National Fraud Initiative 2024. Midlothian
Council continues to be involved in the National Fraud initiative which involved 110
public sector bodies and takes place every two years. 
The report highlights the following key findings:
• £21.5 million in fraud and payment errors across the Scottish public sector,
increasing from £14.9 million in 2021. Although savings have increased from
£4.5 million to £5.7 million similar to the 2018/19 savings, some of the other
increases in savings and notional outcome estimates are due in part to
methodology changes.
• £4.5 million was saved through Council tax discounts by removing ineligible
claims, £1.2 million through housing benefit overpayments and £1.5 million
from preserved occupational pensions where the claimant has passed away. 
Th Chief Internal Auditor explained that these findings were included in the Annual
Fraud Report presented to the Audit Committee in June 2024. The findings showed
£444,000 in fraud and payment errors from Midlothian Council which are included
within National Fraud Initiative results. The Council’s Counter Fraud Team is
working together with the National Fraud Initiative and further matches for the new
exercise will be available in December 2024. 
Elected Members asked if it is possible to carry out recovery actions on discovering
overpayment of a deceased person’s pension. The Chief Officer Corporate
Solutions advised that there is a process to recover monies from a deceased
person’s estate and the decision whether to carry out recovery is made on a case-
by-case basis.  This recovery process would not apply for pensions because these
are not administered by the Council. 
Elected Members asked if artificial intelligence is used to identify fraud. The Chief
Internal Auditor stated that there is continuous improvement in the data and joint
working with the Department of Work and Pensions, but that there is no artificial
intelligence involved in the process. 
Elected Members noted that the number of applicants taken off the housing list has
increased and asked whether the Council has the correct information. The Chief
Internal Auditor stated that individuals were removed after a data matching
exercise. The Executive Director Place advised that the last data review process
took place during the pandemic and a new review is due. They advised that
matching is done based on applicants’ declarations and if any individuals are
removed from the housing list this is due to their circumstances being inconsistent
with this declaration. 
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Councillor McCall moved to adopt the recommendations in the report, and
Councillor Bowen seconded this recommendation. 
Decision
The Audit Committee noted the recommendations set out in the report. 
6. Private Reports 
No items for discussion. 
7. Date of Next Meeting 
The next meeting will be held on Monday 24 February 2025 at 11:00am. 
The meeting ended at 11.54am.
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Audit Committee               
Monday 24 February 2025
Item 4.2
Audit Committee Action Log 
No Date of Meeting Item No and Title Action Action Owner Expected
completion
date
Comments
1 5.1 Treasury
management 
06/12/2022 Session with members to be
organised with regards to
responsible treasury
management/ethical issues.
Chief Financial
Officer
February 2025 An update will be provided
in the Treasury
Management and
Investment Strategy for
2025/26. 
2 5.5 Risk
Management
Update – Strategic
Risk Profile
Quarter 1 2024/25 
30/09/2024 Review report to determine if
risk scores linked to cost of
living and Care at Home need
to be upgraded.
Chief Officer
Place
Dec 2024 in line
with Q2 risk
reporting.
A combined Q2 and Q3
Strategic Risk Report
submitted to Audit
Committee on 24 February.
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No Date of Meeting Item No and Title Action Action Owner Expected
completion
date
Comments
3 5.5 Follow-Up
Review of
Completed Internal
Audit
Recommendations
and Progress
Update
25/11/2024 Data in Appendix 1 - Overdue
Actions to be reviewed and
updated so the name of action
owners is correct.
Chief Internal
Auditor 
December 2024 Completed - report updated
to show the correct action
owners. 
Recommended for closure. 
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Midlothian Council
Annual Audit Plan 2024/25 - DRAFT
Prepared for Midlothian Council
February 2025
Audit Committee
Monday 24 February 2025
Item No 5.1
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Midlothian Council Annual Audit Plan | 2
Contents
Introduction 3
Audit scope and responsibilities 4
Audit of the annual accounts 6
Wider scope and Best Value 12
Reporting arrangements, timetable and audit fee 14
Other matters 17
Accessibility
You can find out more and read this report using assistive technology on
our website www.audit.scot/accessibility.
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Introduction | 3
Introduction
Purpose of the Annual Audit Plan
1. The purpose of this Annual Audit Plan is to provide an overview of the
planned scope and timing of the 2024/25 audit of the Midlothian Council
annual accounts. It outlines the audit work planned to meet the audit
requirements set out in auditing standards and the Code of Audit Practice,
including supplementary guidance.
Appointed auditor and independence
2. Claire Gardiner of Audit Scotland has been appointed by the Accounts
Commission as external auditor of Midlothian Council (the council) for the
period from 2022/23 until 2026/27. The 2024/25 financial year is therefore
the third of the five-year audit appointment.
3. The appointed auditor and the audit team are independent of the
council in accordance with relevant ethical requirements, including the
Financial Reporting Council’s Ethical Standard. This standard imposes
stringent rules to ensure the independence and objectivity of auditors.
Audit Scotland has robust arrangements in place to ensure compliance
with ethical standards. The arrangements are overseen by the Executive
Director of Innovation and Quality, who serves as Audit Scotland’s
Ethics Partner.
4. The Ethical Standard requires auditors to communicate any
relationships that may affect the independence and objectivity of the audit
team. There are no such relationships pertaining to the audit of the council
to communicate.
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Audit scope and responsibilities | 4
Audit scope and responsibilities
Scope of the audit
5. The audit is performed in accordance with the Code of Audit Practice,
including supplementary guidance, International Standards on Auditing
(UK), and relevant legislation. These set out the requirements for the
scope of the audit which includes:
• An audit of the financial statements and an opinion on whether they
give a true and fair view and are free from material misstatement.
• An opinion on statutory other information published with the
financial statements in the annual accounts, the Management
Commentary, and the Annual Governance Statement, and an
opinion on the audited part of the Remuneration Report.
• Conclusions on the arrangements in relation to the wider scope
areas: Financial Management, Financial Sustainability, Vision,
Leadership, and Governance, and Use of Resources to Improve
Outcomes.
• Reporting on the council’s arrangements for securing Best Value.
• Providing assurance on the Housing Benefit Subsidy Claim,
Non-Domestic Rates Return, and the Whole of Government
Accounts return.
• A review of the council’s arrangements for preparing and publishing
statutory performance information.
• Provision of an Annual Audit Report setting out significant matters
identified from the audit of the annual accounts and the wider scope
areas specified in the Code of Audit Practice.
Responsibilities
6. The Code of Audit Practice sets out the respective responsibilities of the
council and the auditor. A summary of the key responsibilities is outlined
below.
Auditor’s responsibilities
7. The responsibilities of auditors in the public sector are established in
the Local Government (Scotland) Act 1973. These include providing an
independent opinion on the financial statements and other information
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Audit scope and responsibilities | 5
reported within the annual accounts and concluding on arrangements in
place for the wider scope areas.  
8. Midlothian Council’s responsibilities
9. The council has primary responsibility for ensuring proper financial
stewardship of public funds, compliance with relevant legislation and
establishing effective arrangements for governance, propriety and
regularity that enables it to successfully deliver its objectives. The features
of proper financial stewardship include:
• Establishing arrangements to ensure the proper conduct of its
affairs.
• Preparation of annual accounts comprising financial statements and
other information that gives a true and fair view.
• Establishing arrangements for the prevention and detection of
fraud, error and irregularities, and bribery and corruption.
• Implementing arrangements to ensure its financial position is
soundly based.
• Making arrangements to secure Best Value.
• Establishing an internal audit function.
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Audit of the annual accounts | 6
Audit of the annual accounts
Introduction
10. The audit of the annual accounts is driven by materiality and the risks
of material misstatement in the financial statements, with greater attention
being given to the significant risks of material misstatement. This chapter
outlines materiality, the significant risks of material misstatement that have
been identified, and the impact these have on the planned audit
procedures.
Materiality
11. The concept of materiality is applied by auditors in planning and
performing an audit, and in evaluating the effect of any uncorrected
misstatements on the financial statements or other information reported in
the annual accounts.
12. Materiality determines whether matters identified during the audit
could reasonably be expected to influence the decisions of users of the
financial statements. Auditors set a monetary threshold when determining
materiality, although some issues may be considered material by their
nature. Materiality is ultimately a matter of the auditor’s professional
judgement.
13. The materiality levels determined for the audit of the council and its
group are outlined in Exhibit 1.
Exhibit 1
2024/25 Materiality levels for Midlothian Council and its group
Materiality
Midlothian Council and its
group
Materiality – Based on an assessment of the needs of
users of the financial statements and the nature of the
council’s operations. The benchmark used to determine
materiality is gross expenditure based on the audited
2023/24 financial statements. Materiality has been set at
2% of the benchmark.
£11 million
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Audit of the annual accounts | 7
Materiality
Midlothian Council and its
group
Performance materiality – this acts as a trigger point. If
the aggregate of misstatements identified during the audit
exceeds performance materiality, this could indicate that
further audit procedures are required. Using professional
judgement, performance materiality has been set at 70% of
planning materiality.
£7 million
Reporting threshold – all misstatements greater than the
reporting threshold will be reported. 
£0.5 million
Source: Audit Scotland
Significant risks of material misstatement to the financial
statements
14. The risk assessment process draws on the audit team’s cumulative
knowledge of the council including:
• the nature of its operations and its significant transaction streams
• the system of internal control
• governance arrangements and processes; and
• developments that could impact on its financial reporting.
15. Based on the risk assessment process, significant risks of material
misstatement to the financial statements have been identified and these
are summarised in Exhibit 2. These are the risks which have the greatest
impact on the planned audit approach, and the planned audit procedures
in response to the risks.
16. The risk assessment process is an iterative and dynamic process. The
assessment of risks set out in this Annual Audit Plan may change as more
information and evidence is obtained over the course of the audit. Where
such changes occur, these will be reported to the council and those
charged with governance, where relevant.
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Audit of the annual accounts | 8
Exhibit 2
Significant risks of material misstatement to the financial statements
Risk of material misstatement Planned audit response
Fraud caused by management
override of controls 
Management is in a unique position to
perpetrate fraud because of
management’s ability to override
controls that otherwise appear to be
operating effectively.
The audit team will:
• Evaluate the design and implementation of
controls over journal entry processing.
• Make inquiries of individuals involved in the
financial reporting process about inappropriate
or unusual activity relating to the processing of
journal entries.
• Test journals entries, focusing on those that are
assessed as higher risk, such as those affecting
revenue and expenditure recognition around the
year-end.
• Evaluate significant transactions outside the
normal course of business.
• Assess the adequacy of controls in place for
identifying and disclosing related party
relationships and transactions in the financial
statements.
• Assess changes to the methods and underlying
assumptions used to prepare accounting
estimates and assess these for evidence of
management bias.
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Audit of the annual accounts | 9
Risk of material misstatement Planned audit response
Valuation of property, plant and
equipment 
The council held £1 billion of land and
building assets at 31 March 2024. 
The council is required to value land
and building assets at existing use value
where an active market exists for these
assets. Where there is no active market,
these assets are valued on a
depreciated cost replacement (DRC)
basis. As a result, there is a significant
degree of subjectivity in these
valuations which are based on specialist
assumptions, and changes in the
assumptions can result in material
changes to valuations.
All non-current assets are revalued on a
five-year rolling basis. Values may also
change year on year, and it is important
that the council ensures the financial
statements accurately reflect the value
of the land and buildings.
Due to the inherent complexity and
subjectivity involved, a significant risk of
material misstatement for valuations has
been identified. 
The audit team will:
• Evaluate the design and implementation of
controls over the valuation process.
• Review the information provided to the valuer
and assess this for completeness and accuracy.
• Evaluate the competence, capabilities, and
objectivity of the valuer.
• Obtain an understanding of management’s
involvement in the valuation process to assess if
appropriate oversight has occurred.
• Review the appropriateness of the key data and
assumptions used in the 2024/25 valuation
process, and challenge these where required.
• Review management’s assessment that the
value in the balance sheet of assets not subject
to a valuation process in 2024/25 is not
materially different to current value at the year-
end, and challenge this where required.
Source: Audit Scotland
Key audit matters
17. The Code of Audit Practice requires public sector auditors to
communicate key audit matters. Key audit matters are those matters, that
in the auditor’s professional judgement, are of most significance to the
audit of the financial statements and require most attention when
performing the audit.
18. In determining key audit matters, auditors consider:
• Areas of higher or significant risk of material misstatement.
• Areas where significant judgement is required, including accounting
estimates that are subject to a high degree of estimation
uncertainty.
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Audit of the annual accounts | 10
• Significant events or transactions that occurred during the year.
19. In addition to the significant risks of material misstatement in Exhibit 2
the following key audit matters have been identified as part of our planning
process and will be reported on in our Annual Audit Report.
20. Pension Valuation: The valuation requires the use of an actuarial
methodology based on a range of assumptions including financial and
demographic assumptions. Small movements in the assumptions can
result in material changes to valuations. We will assess the scope,
independence and competence of the professionals engaged in providing
estimates for pensions and review appropriateness of actuarial
assumptions and results including comparison with other councils. We will
establish officer’s arrangements for ensuring the reasonableness of
professional estimations and the accuracy of information provided to the
actuary by Midlothian Council.
21. IFRS 16 takes effect for local government bodies from 1 April
2024.This will change the way in which Midlothian Council accounts for
service concession arrangements and operating leases, including
recognising assets and liabilities for the rights and obligations arising from
leases previously classified as operating leases. We will review the
accounting treatment and disclosures made in relation to the new standard
in line with guidance.
Group audit
22. The council is part of a group and prepares group financial
statements. Midlothian Council is the parent of the group which includes
five other components.
23. Risk assessment procedures have been performed on the group audit
to identify if there are any risks of material misstatement to the group
financial statements, or any components where audit procedures are
required for the purposes of the group audit. The outcome of the risk
assessment procedures on the group audit are outlined in Exhibit 3.
Exhibit 3
Outcome of risk assessment procedures on the group audit
Group
component
Accounting
treatment
Risk of material
misstatement
Audit
procedures
required
Auditor
Midlothian
Council
Parent body Yes – Exhibit 2 Yes – full scope
audit
Audit Scotland
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Audit of the annual accounts | 11
Group
component
Accounting
treatment
Risk of material
misstatement
Audit
procedures
required
Auditor
Trusts,
bequests,
common good
community
funds
Consolidated on
a line-by-line
basis
No – not material
to the group
financial
statements
Group level
analytical
procedures only
Audit Scotland
Pacific Shelf 826
Ltd (Subsidiary)
Consolidated on
a line-by-line
basis
No – not material
to the group
financial
statements
Group level
analytical
procedures only
Henderson
Loggie
Lothian
Valuation Joint
Board
(Associate)
Accounted for
on equity basis
No – not material
to the group
financial
statements
Group level
analytical
procedures only
Audit Scotland
Midlothian
Integration Joint
Board (Joint
Venture)
Accounted for
on equity basis
No – not material
to group financial
statements
Group level
analytical
procedures only
Audit Scotland
Midlothian
Energy Ltd
(Joint Venture)
Accounted for
on equity basis
No – not material
to the group
financial
statements
Group level
analytical
procedures only
PWC
Source: Audit Scotland
24. Where audit procedures are required on a component’s financial
statements, and the component auditor is different to the council’s
appointed auditor, group audit instructions will be issued to the component
auditor outlining expectations and requirements in performing these
audit procedures.
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Wider scope and Best Value | 12
Wider scope and Best Value
Introduction
25. Reflecting the fact that public money is involved, the Code of Audit
Practice requires that public audit is planned and undertaken from a wider
perspective than in the private sector. The wider scope audit set out by the
Code of Audit Practice broadens the audit of the annual accounts to
include consideration of additional aspects or risks in four wider scope
areas, which are summarised below:
• Financial Management – this means having sound budgetary
processes. Factors that can impact on the council being able to
secure sound financial management include the strength of the
financial management culture, accountability, and arrangements to
prevent and detect fraud, error and other irregularities, bribery and
corruption.
• Financial Sustainability – this means looking forward over the
medium and longer term in planning the services to be delivered
and how they will be delivered effectively. This is assessed by
considering the council’s medium- to longer-term planning for
service delivery.
This area remains a significant risk across the local government
sector for all councils including Midlothian, especially in the longer
term. This area is being actively managed by the council with
appropriate financial plans in place which are subject to regular
review.  We will continue to review and assess the arrangements in
place at the council to ensure operations are financially sustainable.
• Vision, Leadership and Governance – – this means having a
clear vision and strategy, with set priorities within the vision and
strategy. This is assessed by considering the clarity of plans in
place to deliver the vision and strategy and the effectiveness of the
governance arrangements to support delivery.
• Use of Resources to Improve Outcomes – this means using
resources to meet stated outcomes and improvement objectives
through effective planning and working with partners and
communities. This is assessed by considering the council’s
arrangements for ensuing resources are deployed to improve
strategic outcomes, meet the needs of service users, and deliver
continuous improvement.
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Wider scope and Best Value | 13
26. A conclusion on the effectiveness and appropriateness of
arrangements the council has in place for each of the wider scope areas
will be reported in the Annual Audit Report
Best Value
27. Under the Code of Audit Practice, the audit of Best Value in councils is
fully integrated within the annual audit. As part of the annual audit, auditors
are required to take a risk-based approach to assessing and reporting on
whether the council has made proper arrangements for securing Best
Value, including follow up of findings previously reported in relation to Best
Value.
Best Value thematic review 3: Transformation
28. The Accounts Commission also reports nationally on thematic aspects
of councils’ approaches to, and performance in, meeting their Best Value
duties. As part of the annual audit, thematic reviews, as directed by the
Accounts Commission, are conducted on the council.
29. The thematic review for 2024/25 is about service transformation and
involves considering how the council is redesigning services to maintain
outcomes and deliver services more efficiently. Conclusions and
judgements on the thematic review will be reported in a separate
Management Report and summarised in the Annual Audit Report, where
required.
30. At least once over the five-year appointment, the Controller of Audit
will report to the Accounts Commission on the council’s performance in
meeting its Best Value duties. Midlothian Council is included in the fifth
year of the programme.
Significant wider scope and Best Value risks
31. No significant risks in the wider scope areas or Best Value were
identified from the risk assessment process.
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Reporting arrangements, timetable and audit fee | 14
Reporting arrangements,
timetable and audit fee
Audit outputs
32. The outputs from the 2024/25 audit include:
• This Annual Audit Plan.
• An Independent Auditor’s Report to the council and the Accounts
Commission setting out opinions on the annual accounts.
• An Annual Audit Report to the council and the Accounts
Commission setting out significant matters identified from the audit
of the annual accounts, conclusions from the wider scope and Best
Value audit, and recommendations.
33. The matters to be reported will be discussed with the relevant senior
officers of the council for factual accuracy before they are issued. All
outputs from the audit will be published on Audit Scotland’s website, apart
from the Independent Auditor’s Report, which is included in the audited
annual accounts.
34. Target dates for the audit outputs are set by the Accounts
Commission. In setting the target dates for the audit outputs, consideration
is given to the statutory date for approving the annual accounts, which is
30 September 2025 for local government bodies.
35. The Independent Auditor’s Report and Annual Audit Report are
planned to be issued by the target date 30 September 2025.
Audit timetable
36. Achieving the timetable for production of the annual accounts,
supported by complete and accurate working papers, is critical to delivery
of the audit to agreed target dates. Exhibit 4 includes a timetable for the
audit, which has been agreed with management. Agreed target dates will
be kept under review as the audit progresses, and any changes required,
and their potential impact, will be discussed with the council and reported
to those charged with governance, where required.
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Reporting arrangements, timetable and audit fee | 15
Exhibit 4
2024/25 audit timetable
Audit activity
Midlothian
Council target
date
Audit team
target date
Relevant
committee date
Issue of Annual Audit Plan N/A 31 March 2025 24 February 2025
Annual Accounts
Consideration of unaudited
annual accounts by those
charged with governance
30 June 2025 N/A 16 June 2025
Latest submission date for the
receipt of the unaudited annual
accounts with complete working
papers package.
1 July 2025 N/A N/A
Latest date for final clearance
meeting with the Director of
Finance
29 August 2025 29 August 2025 N/A
Agreement of audited and
unsigned annual accounts and
issue of draft Letter of
Representation, proposed
Independent Auditor’s Report,
and draft Annual Audit Report
Autumn 2025
Date TBC
Autumn 2025
Date TBC
Autumn 2025
Date TBC
Signed Independent Auditor’s
Report 
Date TBC 30 September
2025
Date TBC
Housing Benefit grant claim,
NDRI return
30 September
2025 
31 December
2025
N/A
Best Value 3 Transformation
Issue of Best Value
Management Report
2 June 2025 2 June 2025 16 June 2025
Source: Audit Scotland
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Reporting arrangements, timetable and audit fee | 16
Audit fee
37. Midlothian Council’s audit fee is determined in line with Audit
Scotland’s fee setting arrangements. The planned audit fee for 2024/25 is
£295,490 (2023/24: £289,950).
38. In setting the audit fee, it is assumed that the council has effective
governance arrangements in place and the complete annual accounts will
be provided for audit in line with the agreed timetable. The audit fee
assumes there will be no significant changes to the planned scope of the
audit. Where the audit cannot proceed as planned, for example, due to
incomplete or inadequate working papers, the audit fee may need to be
increased.
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Other matters | 17
Other matters
Internal audit
39. The council is responsible for establishing an internal audit function as
part of an effective system of internal control. As part of the audit, the audit
team will obtain an understanding of internal audit, including its nature,
responsibilities, and activities.
40. While internal audit and external audit have differing roles and
responsibilities, external auditors may seek to rely on the work of internal
audit where it is considered appropriate. A review of internal audit’s
2024/25 audit plan was carried out to identify if there were any areas
where the audit team could rely on its work. The audit team concluded it
will not rely on internal audit’s work. However, the audit team will review
internal audit's reports and assess if there is any impact on the audit.
Audit quality
41. Audit Scotland is committed to the consistent delivery of high-quality
audit. Audit quality requires ongoing attention and improvement to keep
pace with external and internal changes. Details of the arrangements in
place for the delivery of high-quality audits is available from the Audit
Scotland website.
42. The International Standards on Quality Management (ISQM)
applicable to Audit Scotland for 2024/25 audits are:
• ISQM (UK) 1, which deals with an audit organisation’s
responsibilities to design, implement, and operate a system of
quality management (SoQM) for audits. Audit Scotland’s SoQM
consists of a variety of components, such as: governance
arrangements and culture to support audit quality, compliance with
ethical requirements, ensuring Audit Scotland is dedicated to high-
quality audit through engagement performance and resourcing
arrangements, and ensuring there are robust quality monitoring
arrangements in place. Audit Scotland carries out an annual
evaluation of its SoQM and has concluded it complies with this
standard.
• ISQM (UK) 2, which sets out arrangements for conducting
engagement quality reviews, which are performed by senior
management not involved in an audit, to review significant
judgements and conclusions reached by the audit team, and the
appropriateness of proposed audit opinions on high-risk audits.
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Other matters | 18
43. To monitor quality at an individual audit level, Audit Scotland carries
out internal quality reviews on a sample of audits. Additionally, the Institute
of Chartered Accountants of England and Wales (ICAEW) carries out
independent quality reviews on a sample of audits.
44. Actions to address deficiencies identified by internal and external
quality reviews are included in a rolling Quality Improvement Action Plan,
which is used to support continuous improvement. Progress with
implementing planned actions is monitored on a regular basis by Audit
Scotland’s Quality and Ethics Committee.
45. Audit Scotland may periodically seek the views of the council on the
quality of audit services provided. The audit team would also welcome
feedback at any time.
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Midlothian Council
Annual Audit Plan 2024/25 - DRAFT - Draft
Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN
Phone: 0131 625 1500 Email: info@audit.scot
www.audit.scot
AS.5.0
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Page 39

Local government in Scotland
Financial bulletin
2023/24
Prepared by Audit Scotland
January 2025
Audit Committee
Monday 24 February 2025
Item No 5.2
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2Financial bulletin 2023/24
Contents
Key facts 3
Key messages 4
Recommendations 6
Introduction 7
1. Council funding and budgets 9
2. Financial performance 15
3. Financial position and outlook 24
Appendix 1 34
Accessibility
You can find out more and read this report using assistive
technology on our website www.audit.scot/accessibility.
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3
Key facts
Some of these are based on a sample – see paragraph 4 for further information 
on our methodology
Funding and budgets
• 1.8 per cent: the real-terms reduction in revenue funding from the
Scottish Government in 2023/24 compared to 2022/23
• 21 per cent: the proportion of Scottish Government revenue funding
that was ring-fenced or directed towards national policy commitments in
2023/24
• £759 million: the budget gap identified by our sample of 29 councils at
the start of 2023/24. The 2024/25 budget gap identified by all 32 councils
was £585 million
• 1.2 per cent: the real-terms reduction in capital funding from the Scottish
Government in 2023/24 compared to 2022/23.
Financial performance
• 3.3 per cent: the real-terms reduction in councils’ total revenue funding
and income in 2023/24 compared to 2022/23
• 9 out of 29: the number of councils that reported overspends against
their agreed revenue budgets
• 11 out of 30: the number of councils that achieved all their planned
savings
• 25 out of 30: the number of councils that reported lower expenditure
than planned across their capital programmes in 2023/24
• £19.8 billion: councils’ net debt in 2023/24, a 15.8 per cent increase on
2022/23, as councils become more reliant on borrowing to finance their
capital programmes.
Financial position and outlook
• 5 per cent: the decrease in councils’ total usable reserves
• 84 per cent: the proportion of the General Fund that is committed
• 12 out of 29: the number of councils that made unplanned use of their
reserves in 2023/24 to manage budget pressures
• 15 out of 30: the number of councils that have long-term financial plans
in place, with councils reporting difficulty planning for the longer term due
to future uncertainty.
Key facts 3Key factsKey facts
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4Key messages
Key messages
Key messages
Key messages
Despite an increase in overall revenue and capital funding
for councils in 2024/25, and the Scottish Government’s
budget proposals in December 2024 indicating a further real
terms uplift in funding for 2025/26, the financial outlook for
Scotland’s councils remains challenging.
1 In 2023/24, councils’ total revenue and income fell, including
another real terms decrease in revenue funding from the
Scottish Government. Councils are increasingly reliant on
identifying savings, which becomes progressively more difficult
year-on-year, and again used reserves to remain within their
agreed budgets.
2 In 2023/24, capital funding remained constrained, with councils
borrowing more and managing a range of complex funding
models. Capital funding from the Scottish Government reduced
slightly in real terms, continuing a longer-term trend. Capital
expenditure was lower than planned. Councils continue to
borrow more to enable investment in their estates and council
debt, and annual interest costs, continue to increase.
3 In 2023/24, usable reserves, which are those that can be
used to support service delivery, reduced and most are already
committed for specific purposes. This presents an ongoing
challenge for councils reliant on reserves to balance their
budgets, as well as to longer-term financial sustainability. 
Using reserves to routinely balance budgets is not sustainable.
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Key messages 5
4 Councils need to intensify transformation activity, progressing
at scale and pace to ensure their financial sustainability. How
councils plan to use their reserves, make savings and transform
their services needs to become more transparent. The need
to consult local communities and clearly communicate the
implications for local services of the budget decisions taken 
has never been more important.
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6RecommendationsRecommendations
Recommendations
In 2025, councils should:
• Report on the savings made within their management commentaries more
comprehensively, including provision of comparisons to savings targets agreed
during budget-setting, and whether they were recurring or non-recurring
(paragraphs 29 - 30).
• Ensure that the impact of capital underspends, future borrowing projections and of
using financial flexibilities on their indebtedness are reported clearly alongside the
impact of these on future revenue budgets (paragraphs 34 - 41).
• Ensure reserves policies indicate explicitly and clearly the impact of financial
flexibilities on reserves held; the nature, level of and intended timing of the
deployment of committed usable reserves held; and the level of uncommitted and
contingency funding held within General Funds (paragraph 54 and Case study).
• Prioritise service transformation, considering the impact of current service delivery
models on longer-term financial sustainability, including the medium-term impact
on reserve levels (paragraphs 61 - 62).
• Ensure that financial sustainability becomes a central focus of financial monitoring
and reporting, making greater use of financial sustainability indicators within
reports to elected members and within their regular public reporting and financial
strategies and plans (paragraphs 63 - 67).
We note progress against the recommendations from our Financial bulletin 2022/23
in Appendix 1.
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Introduction
About this report
1. This report is part of a series of overview outputs produced by
the Accounts Commission which together provide an independent
overview of the financial and operational performance of Scotland’s local
government sector.
2. This report examines councils’ financial performance in 2023/24.
This follows the unprecedented challenges of the Covid-19 pandemic
and cost-of-living crisis and sits against a backdrop of the whole of the
Scottish public sector facing challenges to its financial sustainability.
The bulletin sets out:
• councils’ funding and budget-setting
• councils’ financial performance
• councils’ position at the end of 2023/24 and the financial outlook.
3. In spring 2025, we will publish a budget briefing examining the 2025/26
budgets set by councils, including analysis of anticipated budget gaps and
the decisions made by councils when setting their budgets. This will be
followed by a report focused on service performance later in 2025.
Methodology
4. The primary sources of information for this report are councils’
2023/24 accounts and annual audit reports, a data request issued to
councils in October 2024 and Scottish Budget documents.
5. Our findings are based primarily on:
• The 2023/24 annual accounts for 29 councils (20 audited and
nine unaudited). At our 2 December 2024 deadline, accounts
were unavailable for Clackmannanshire, Eilean Siar and East
Dunbartonshire and these councils are not included in our 2023/24
analysis (or comparisons to previous years).
• Supplementary information from 30 councils collected via a data
return issued to council directors of finance and was also reviewed
by appointed auditors. At our 25 November 2024 deadline, data
returns were unavailable for Clackmannanshire and Eilean Siar and
these councils are not included in our analysis. We also utilised
7Introduction
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Introduction 8
elements of data returns previously submitted to us in support of
our Financial bulletin 2022/23 report.
• Scottish Government Budget documents. Our analysis of Scottish
Government funding reports on the funding position for all 32 of
Scotland’s councils.
6. When looking at trends, we convert some figures to real terms.
This adjusts financial information from past and future years to prices for
the year under review (ie, 2023/24). This is to take account of inflation
so that trend information is comparable. To adjust for inflation, we use
gross domestic product (GDP) deflators, which are published quarterly by
HM Treasury. GDP deflators are the standard approach adopted by both
the UK Government and Scottish Government when analysing public
expenditure.
7. Financial trend data (both capital and revenue) relating to funding,
income or expenditure will generally be shown in real terms. Financial
information from the councils’ accounts’ balance sheets remains
unadjusted. This includes trend analysis on reserves, sources of capital
finance, borrowing and debt. These are not adjusted to real terms as they
are already subject to revaluations within the councils’ accounts to reflect
current prices.
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1. Council funding
and budgets
Both revenue and capital funding from the Scottish
Government to councils were reduced in real terms in
2023/24, with councils once again setting budgets that
required significant gaps to be addressed.
Councils are reliant on Scottish Government funding
which makes up over 60 per cent of income
8. As the largest source of funding or income for councils, at over 60 per
cent, Scottish Government funding shapes the fiscal environment that
councils operate in. Currently councils receive a single year settlement,
with a draft allocation published in the Scottish Budget in December. This
is revised throughout the year and in recent years a low initial settlement
has been followed by large additional transfers during the financial year.
9. In 2023/24, the Scottish Government allocated councils total revenue
and capital funding of £13.7 billion. This settlement was higher than
before the pandemic but in real terms funding was reduced year-on-year
since 2020/21. The 2024/25 settlement has reversed this trend and the
2025/26 draft settlement published in December 2024 indicates another
real-terms uplift in funding for councils (Exhibit 1, page 10).
10. This initial 2025/26 draft settlement allocates £15 billion of revenue
and capital funding to councils, a 5.8 per cent real terms increase on
the 2024/25 draft settlement. Increases to revenue funding include an
uplift to the general revenue grant, funding for pay awards and teachers’
pensions. Increases to capital include additional funds to support inter-
islands connectivity and climate change. There is still uncertainty as
to how increased employers’ National Insurance (NI) contributions,
announced by the UK Government, will be funded. The Convention of
Scottish Local Authorities (COSLA) estimates these will be an additional
£265 million cost pressure for councils in 2025/26.
11. The funding increase for councils recently announced as part of the
Scottish Government’s 2025/26 draft budget in December 2024 does
not change the fact that the financial outlook remains challenging
(Part 3). We will examine the implications of the Scottish Budget for
councils’ own budget-setting in our next Local government in Scotland
publication, Local government budgets 2025/26.
91. Council funding and budgets
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1. Council funding and budgets 10
Exhibit 1.
Scottish Government revenue and capital funding to councils since
2018/19 in real terms
Funding in 2023/24 was higher than before the pandemic but in real terms has reduced
year-on-year since 2020/21. This trend reversed in 2024/25 and 2025/26 sees a further
funding uplift.
2019/20 2020/21 2021/22 2022/23 2023/24 2024/25 2025/26 2018/19
Outurn Autumn budget revision Draft budget
13
14.313.6 14.7 14.6 14.2 13.7 13.7
Funding was higher than before the
pandemic but in real terms has reduced
year-on-year since 2020/21
Funding increased in
2024/25 and 2025/26
sees another uplift
Draft Budget Allocation
Note: Draft budget allocations include transfers from other portfolios. 2020/21 and 2021/22 totals
include Covid-19 funding allocations. Barnett consequentials (and other funding) will be allocated to
2024/25 in the Spring Budget Revision. The draft 2025/26 settlement will be subject to additional
in-year allocations that are already included in earlier year totals.
Source: Scottish Government Budget documents
Revenue funding from the Scottish Government
fell by 1.8 per cent in real terms in 2023/24, despite
significant in-year allocations
12. In 2023/24, revenue funding from the Scottish Government (at the
spring revision) was £12.7 billion, a 4.2 per cent cash increase on the
previous year but 1.8 per cent lower in real terms. General revenue grant
funding and non-domestic rates combined decreased by 1.5 per cent.
Specific revenue grants saw no cash increase which meant a reduction
of 6.9 per cent in real terms.
£ billion
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1. Council funding and budgets 11
13. Some further Scottish Government funding received by councils,
although not formally ring-fenced, is provided with the expectation that
it is directed to specific purposes. This is announced and distributed to
councils in-year. In 2023/24, councils received an additional £1.6 billion
at the autumn revision including additional funding to support teachers’
salaries as well as the expected transfers from other portfolios including
health and education. A further £0.3 billion was transferred from other
portfolios at the spring revision.
14. In 2023/24, we calculated that ring-fenced and directed funding
amounted to almost £2.7 billion, which is 21 per cent of Scottish
Government revenue funding to councils. This is lower than in 2022/23.
In the 2024/25 Scottish Budget, following a commitment in the Verity
House Agreement to reduce the level of ring-fenced funding, a number
of ring-fenced or directed items were ‘baselined’ into the general revenue
grant. This includes all £522 million of the early learning and childcare
specific revenue grant and £429 million of in-year transfers including adult
social care Living Wage funding, Free Personal and Nursing Care and
Free School Meals Intervention. While no longer ring-fenced, spending
will still need to be directed towards these policies. In the 2025/26
Scottish Budget, initial indications do not show any significant alterations.
Councils identified £759 million of budget gaps at
the start of 2023/24, and planned to use savings and
reserves to address these
15. Councils set their own budgets in February and March for the
financial year ahead using the initial allocation from the Scottish
Government. At the time of setting their 2023/24 budgets, councils in our
sample of 29 identified a cumulative budget gap of at least £759 million
for the year. This represented a budget gap of 4.8 per cent of the total
net cost of services.
16. To close the budget gap and set a balanced budget, councils took a
range of actions. Over 90 per cent was covered by agreeing:
• to make £260 million of recurring savings (34 per cent of the total
share)
• to make a further £30 million of non-recurring, one-off savings
(four per cent)
• to use £202 million of reserves (26 per cent)
• to raise £144 million through increases to council tax (19 per cent)
• to use £73 million of funding released via application of financial
flexibilities (nine per cent)1 (Exhibit 2, page 13).
1 The budget gap and values that make up the bridging actions vary from those published in last
year’s Financial bulletin as the sample is different and additional data returns were received post
publication that are now included.
During the budget-
setting process,
councils may
identify a budget
gap, which is the
difference between
their anticipated
expenditure for the
year and the funding
and income they
expect to receive.
Councils will identify
and agree bridging
actions to allow them
to set a balanced
budget. This may
include an agreement
on savings to be made
during the year.
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1. Council funding and budgets 12
17. The use of reserves and other non-recurring measures is
unsustainable and is only a temporary plug for a budget gap in that one
year. The gap will remain in future years until recurring measures such
as recurring savings or increases to income are found or the service cost
base is reduced.
18. The setting of council tax levels is an important mechanism available
to councils in delivering a balanced budget. In 2023/24, councils
increased their tax by an average of 5.4 per cent. This was used to
bridge 19 per cent of the overall budget gap. The Scottish Government
imposed a council tax freeze for 2024/25, instead providing £144 million
to ‘fully fund’ the freeze to the equivalent of a five per cent increase. The
Cabinet Secretary for Finance and Local Government confirmed during
her budget statement in December 2024 that there will be no council tax
freeze or cap for 2025/26.
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1. Council funding and budgets 13
Exhibit 2.
The bridging actions councils identified within their 2023/24 budgets
as a proportion of net cost of services
Recurring savings and using reserves made up the majority of how councils intended
to meet their identified budget gaps.
Fife
Glasgow
Dundee
East Ayrshire
Renfrewshire
North Lanarkshire
Dumfries and Galloway
Inverclyde
Midlothian
East Lothian
West Lothian
Aberdeenshire
City of Edinburgh
Argyll and Bute
Scottish Borders
South Ayrshire
North Ayrshire
Stirling
East Renfrewshire
Falkirk
Perth and Kinross
Aberdeen
Angus
Highland
West Dunbartonshire
South Lanarkshire
Moray
Scotland
0% 1% 2% 3% 4% 5% 6% 7% 8% 9%
Increase to council tax
Use of reserves Financial flexibilities Other
Agreed savings recurring Agreed savings non-recurring
Note: In addition to the three councils whose 2023/24 annual accounts were not available, Shetland
and Orkney are excluded from this chart as both are outliers due to their high use of reserves to set
their budget, reflecting the councils’ regular utilisation of the returns from significant investments and
harbour income. Shetland’s bridging actions made up 35 per cent of their net cost of services (over 80 per
cent of which related to reserves use). Orkney’s bridging actions made up 13 per cent of their net cost of
services (of which over 90 per cent was use of reserves).
Source: Council data returns (2023) and Councils’ annual accounts 2023/24 (audited and unaudited)
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1. Council funding and budgets 14
With Scottish Government capital funding remaining
constrained, councils are increasingly reliant upon
borrowing to fund planned investment decisions
19. Capital funding from the Scottish Government (at the spring revision)
fell by 1.2 per cent in real terms between 2022/23 and 2023/24 and
was 21 per cent lower than 2018/19. Both the general capital grant and
specific capital grant have decreased in real terms. The specific capital
grant, the proportion of funding that is ring-fenced for specific uses,
was much lower than five years ago and has been relatively static for
the past three years. This is due to the completion of the capital element
of the Early Learning and Childcare Expansion Programme. Councils
received £70 million of capital funding for use in 2023/24, by allowing
an equivalent amount of revenue reserves to be released, and a further
£22 million of funding to support the cost of local government pay
awards (for example by allowing councils to use this instead of planned
transfers from revenue budgets).
20. Capital funding was reduced further in 2024/25. The initial draft
allocation for 2025/26 saw an increase compared to 2024/25 but capital
funding remains lower than 2023/24 and earlier years. The longer-term
reduction in capital grants means councils are having to finance their
chosen investment in new facilities by other means. Councils are now
more reliant on other sources of finance, such as borrowing, transfers
from their revenue budgets and making use of financial flexibilities, than
has previously been the case (paragraphs 33 - 41).
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15
2. Financial performance
Councils increasingly relied on savings and reserves to
ensure they remained within agreed revenue budgets;
capital expenditure was lower than planned and borrowing
increased. Improvements in how councils report their
savings are still needed.
Councils’ total revenue funding and income fell by 3.3 per
cent in real terms in 2023/24, with income from service fees
still below pre-pandemic levels.
21. In addition to Scottish Government funding and council tax, councils receive
funding and income from several other sources, including fees and charges for
using services and council house rents (Exhibit 3).
22. In 2023/24, from our review of 29 councils’ annual accounts, councils received
£21.2 billion in revenue funding and income. This is £540 million more than 2022/23
but represents a real terms decrease of 3.3 per cent (£725 million) as increases in
income have not kept pace with inflation. In 2023/24, total funding and income fell
back to 2019/20 levels.
2. Financial performance
Exhibit 3.
Sources of council funding and income in 2023/24
The proportion of funding from each source is similar to 2022/23.
GRG
NDR
Council Tax
Grants (including Scottish
Government & others)
Customer and
client receipts
HRA rents
Interest receivable
& similar charges 1% (£0.2 billion)
7% (£1.4 billion)
9% (£1.8 billion)
16% (£3.4 billion)
13% (£2.8 billion)
14% (£3 billion)
40%
(£8.5 billion)
Note: Interest receivable refers to the interest that has been earned by investments, loans, or income
to be received from overdue invoices.
Source: Councils’ annual accounts 2023/24 (audited and unaudited) (based on 29 annual accounts)Page 53 of 306

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2. Financial performance 16
23. Council tax is an important source of income for councils, providing
£2.8 billion in 2023/24. The proportion has remained static for the last
five years at around 13 per cent of total funding and income. In 2023/24,
councils received £11 million more income from council tax than in
2022/23, which is a 0.4 per cent real terms increase.
24. Income from customer and client receipts dropped significantly during
the pandemic and has not yet returned to previous levels. Customer and
client receipts are 12 per cent (£253 million) lower in real terms than in
2019/20. Councils reported receiving lower income than budgeted for
as a reason for service overspends in 2023/24 across a broad range
of services, with parking and waste the most common. However, the
picture is mixed and for some councils and service areas increased
income offset expenditure and led to services underspending against
their budgets. Income generation, and the limited capacity to increase
this, was cited by a number of councils as a risk to financial sustainability.
Overall, councils remained within their agreed
revenue budgets, but some services spent more
than planned
25. In 2023/24, councils managed net budgets of around £15 billion,
compared to £13.4 billion in 2022/23. Overall, councils reported a
revenue budget underspend of £111 million or 0.7 per cent. This is around
half the variance seen in 2022/23. Since 2019/20 there has been a small
overall underspend each year and, except for 2020/21, this variance has
decreased year-on-year. Despite the overall underspend, nine reported
overspends against their agreed revenue budgets.
26. Councils reported both underspends and overspends at a service
level, with workforce issues and income a common theme for both
(Exhibit 4, page 17).
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2. Financial performance 17
Exhibit 4.
Council overspends and underspends at a service level and reasons
for them
Workforce issues and income generation are a common theme for both.
Service area Reasons for
Overspends
• Reported in a wide range of
service areas with culture and
leisure, children and families,
education and adult social care
being noted most often.
• Service area overspends were
mostly attributed to a lack of
funding, workforce pressures
and general cost increases.
• Underperformance of a range of
income streams also contributed
to overspends in some councils.
Underspends
• Education and early years were
referred to most often.
• Communities, culture and
leisure, and planning and
economic development were
also identified by some councils
as areas of underspend.
• Underspends in education and
early years were often attributed
to lower than anticipated
demand and unfilled staff
positions.
• Underspends were sometimes
attributed to more favourable
income position, such as
generating greater income than
budgeted for and receiving
additional VAT reimbursements.
• Workforce issues, such as
challenges with recruitment,
and high vacancy levels, were
also identified as a cause of
underspends.
Note: Culture and leisure services were reported in both but twice as often as an area of overspend
than an underspend.
Source: Council data returns
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2. Financial performance 18
Councils delivered significant savings, but some
remain reliant on one-off measures and reporting
against savings targets should be more transparent
27. From our sample of 30, 28 councils set a savings target in 2023/24,
totalling £362 million, with £332 million (92 per cent) being achieved.
This is significantly higher than the savings target reported by the same
councils last year (£214 million).
28. Of the 30 councils:
• eleven achieved their full savings target or more
• thirteen missed their target but achieved 80 per cent or more
• four achieved less than 80 per cent of their target
• two councils (Fife and Orkney) did not have savings targets
in place.
29. Not all councils could split savings targets or achieved savings
information into recurring or non-recurring categories. Where we have a
breakdown of how savings were achieved (27), 85 per cent (£244 million)
were achieved on a recurring basis, compared to 82 per cent in 2022/23.
Non-recurring savings accounted for 15 per cent of total savings
achieved, at £42 million (Exhibit 5, page 19).
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2. Financial performance 19
Exhibit 5.
Proportion of savings targets achieved in 2023/24, split by recurring and
non-recurring savings (based on 27 councils that can split their savings in
this way)
Some councils continue to rely upon one-off measures to deliver in-year savings.
0 20 40 60 80 100 120
Shetland
East Dunbartonshire
Scottish Borders
Aberdeenshire
Highland
Falkirk
Argyll & Bute
South Ayrshire
Midlothian
East Lothian
Stirling
City of Edinburgh
Glasgow
Dumfries & Galloway
Perth & Kinross
North Ayrshire
Angus
East Renfrewshire
West Dunbartonshire
Renfrewshire
South Lanarkshire
East Ayrshire
North Lanarkshire
Inverclyde
West Lothian
Dundee City
Moray
Scotland
Percentage
% of total target  - recurring
% of total target  - non-recurring
Note: In addition to the two councils that did not submit a data return, a further three councils are
excluded from this exhibit. Aberdeen City sets a savings target to be achieved in the year but does
not differentiate between recurring and non-recurring savings for monitoring purposes. The savings
target was achieved for 2023/24. Fife and Orkney did not have a savings target in place in 2023/24.
Source: Council data returns
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2. Financial performance 20
30. In our Financial bulletin 2022/23 we recommended that councils
prioritise the achievement of recurring savings and avoid reliance
on non-recurring measures. The overall extent of progress against
our recommendation is difficult to assess due to a lack of detail and
transparency in reporting on savings performance. Non-recurring savings
are not always included in savings targets or performance information so
it remains difficult to assess the overall reliance on these or, indeed, the
overall savings achieved.
31. Additionally, a review of management commentaries within annual
accounts found that not all councils are reporting progress against
savings plans and, for the majority that are, these largely focus on their
previous or future plans. The majority lacked detail on areas such as
performance trends and, again, often did not report if savings were
recurring or non-recurring.
32. Councils have identified the need to generate future savings as
they undertake wider-scale transformation, redesign how services
are delivered and consider their future policies on fees and charges
for accessing services. This will need to be done in consultation with
their partners and citizens. Councils should report more transparently
the nature of their savings and how these could impact services on an
ongoing basis.
Capital expenditure was 20 per cent lower than
planned and funded by increased borrowing
33. The value of council estates, mainly council owned property
(including buildings and schools) and equipment, increased by £5 billion
in 2023/24 to £51 billion. This reflects continuing investment by councils
and, in 2023/24, capital expenditure was £3.5 billion. This is comparable
in cash terms to 2022/23. Borrowing increased again in 2023/24 to
£1.7 billion, a significant increase of £406 million (31 per cent) since
2022/23, and up £1.2 billion (196 per cent) since 2018/19. Borrowing
was used to finance 49 per cent of total capital expenditure (Exhibit 6,
page 21).
34. From our sample of 30 councils providing information through the
data return, 25 reported a capital underspend in 2023/24 of £755 million.
This equates to 20 per cent of councils’ total capital budget. This is less
than the underspend of 24 per cent in 2022/23; however, it is still higher
than the 17 per cent reported in 2018/19. Significant underspends were
reported for both General Fund (23 per cent of budget) and HRA
capital programmes (15 per cent of budget). Councils reported a range
of project types and reasons for why capital underspends had occurred
(Exhibit 7, page 21).
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2. Financial performance 21
Exhibit 6.
Capital expenditure split by sources of finance, in cash terms
Borrowing and government grants remain the most significant means of financing
capital investment.
2022/23 2023/24
-0.5 0 0.5 1 1.5 2
Other contributions and
Public Private Partnership (PPP)
Internal loans fund
repayments available to reinvest
Government grants
Capital receipts
Capital Funded from
Current Revenue (CFCR)
An increase in borrowing
billion
Note: Internal loans fund repayments are an annual charge that recognise capital costs in the revenue
budget. Once repaid, they allow borrowed funds to be used elsewhere. Capital receipts are income
councils generate from selling existing assets. Revenue transfers is capital expenditure funded from
service revenue budgets.
Source: Councils’ annual accounts 2022/23 and 2023/24 (audited and unaudited)
Exhibit 7.
Type and reasons for underspends on councils’ capital programmes
Project type Reasons for
Underspends
• School and early learning building
projects.
• Housing projects.
• Large-scale infrastructure projects
(with a small number of councils
underspending in relation to
projects being delivered as part of
their City Deals).
• Project and programme slippage,
caused by a range of supply chain
and capacity issues.
• Project delays caused by cost,
contract and legal negotiations and
unexpected issues arising during
the course of works.
• Project deferment.
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2. Financial performance 22
35. Managing their capital programmes is an important tool for councils
to control their annual expenditure. All but two councils reported having
a multi-year capital plan in place. These covered a range of periods from
five to 30 years, with most covering five to ten years. South Lanarkshire
and Stirling councils both reported only having an annual capital plan in
place. A multi-year plan allows councils to manage their capital spending
over this period.
36. However, consistently failing to invest in estates and infrastructure
increases the risk that asset failures may impact services, projects will
become more expensive to deliver, and that maintenance spending will
need to increase due to assets becoming older. It also impacts the ability
of councils to manage their overall estates, identify surplus assets and
consider the efficiency of partnership working, including co-location with
other services.
Borrowing means debt has again increased, 
and further borrowing will be needed to invest
in new schools
37. Due to the increased reliance on borrowing to fund investment,
councils’ net debt has now risen to £19.8 billion. This is an increase of
15.8 per cent from 2022/23 and a 29.7 per cent increase since 2018/19.
All but one council increased their debt in 2023/24. The cost of servicing
debt has risen, with a 16 per cent rise in interest payable and similar
charges since 2022/23. Interest payable as a proportion of net cost of
services, was six per cent compared to five per cent in 2022/23.
38. Under LEIP, councils borrow to meet the cost of building new
schools, with the Scottish Government providing revenue grant funding
over a 25-year period linked to specific outcomes (maintenance, energy
efficiency, digital infrastructure and job creation) to meet maintenance
and life-cycle costs. Councils, however, need to fund the £1 billion cost
of building schools, including any interest on the money borrowed to
fund this. The programme has faced significant delays and cost increases
and, to complete the programme by the planned date of 2027, significant
further borrowing by councils will be needed.
39. Alongside investing and maintaining their own estates, councils
have made use of a range of different Public Private Partnership (PPP)
contracts to invest in their estates. A number of earlier Private Finance
Initiative (PFI) contracts are now nearing the end of their terms. Councils
are having to prepare for, and manage, complex closing arrangements.
Councils have already entered into negotiations relating to contracts that
are ending, with 10 PFI contracts due to expire by the end of 2030.
In September
2019, the Scottish
Government
announced it would
support £1 billion of
capital investment
in the school estate
on a match-funding
basis. In consultation
with councils, this
created a joint £2
billion Learning
Estate Improvement
Programme (LEIP),
enabling additional
investment without
the use of private
finance contracts.
Councils provide
upfront capital
funding and Scottish
Government revenue
follows over 25 years
for achievement of
outcomes.
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2. Financial performance 23
40. By making use of financial flexibilities across 2022/23 and
2023/24, councils have been able to reprofile the debt associated
with PPP contracts. This has allowed councils to recognise significant
gains from annual contractual payments they have previously made,
recognising these within their usable reserves. Future capital expenditure
will be able to be offset against these, but they are not cash backed.
This means the need for councils to borrow to finance their future capital
investment has not changed, nor have their current external debts.
Alongside LEIP projects, councils have already committed to significant
future borrowing.
41. Councils set and agree their borrowing and treasury management
strategies individually, deciding on what is a prudent and affordable level
of debt under the Prudential Code. As part of this, a range of indicators
are considered, including the cost of servicing their debts, to show that
capital plans are affordable and sustainable. Increased borrowing means
increased costs that will need to be met annually from revenue budgets.
While auditors have not expressed specific concerns about the level of
borrowing (in the 15 annual audit reports that were available at the time
of our review), it is a factor in the assessment of financial sustainability
and auditors are expressing greater concerns about the overall financial
sustainability of councils (paragraph 58).
Between 2020 and
2024, the Scottish
Government
permitted councils
to make use of a
range of financial
flexibilities to
manage financial
pressures. One of
these related to
service concessions
(including PPP) and
allowed councils
to reprofile debt
repayments. This
offered an immediate
benefit of significant
one-off increases to
reserves but these
are not cash backed,
and debt payments
will need to be made
for longer, deferring
costs to later years
which has implications
for future revenue
budgets.
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24
3. Financial position
and outlook
Using reserves to manage financial pressures and stay
within agreed budgets is not sustainable. Usable reserves
fell in 2023/24, and most are committed for specific
purposes. Progress on transformation and reform must 
be prioritised to ensure longer-term financial sustainability.
Councils’ usable reserves remain higher than before
the pandemic, mainly due to the use of financial
flexibilities, but decreased in 2023/24 
42. Holding and using reserves is a normal, and helpful, way of
managing council finances but reserves are a one-off resource meaning
councils need to carefully plan and monitor how these are being used.
Using reserves to support services in the short term is not sustainable
unless they are used to support service transformation and generate
future savings.
43. In 2023/24, councils’ total usable reserves decreased by five per
cent to £4.1 billion which equates to around 25 per cent of net cost of
services. The overall decrease is attributed to a fall in capital reserves
along with a very modest increase in revenue reserves (Exhibit 8,
page 25).
44. Usable reserves remain £1.66 billion higher than before the
pandemic. Revenue reserves were boosted in recent years by:
• Covid-19 funding, but these are largely exhausted with only around
£67 million remaining earmarked (2.8 per cent of the committed
General Fund balance)
• making use of financial flexibilities related to service concessions,
resulting in reprofiled debt and significant one-off increases to
reserves. Although an accounting adjustment, and not cash backed,
these can be used to support services.
3. Financial position and outlook
Usable reserves can
be used to support
service delivery,
and to meet in-year
expenditure (and are
sometimes referred
to as cash backed
reserves).
Unusable reserves
represent accounting
adjustments to reflect
things such as an
increase in the value
of council-owned
buildings. They
generally cannot be
routinely accessed
or used to support
services. 
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3. Financial position and outlook 25
Exhibit 8. 
Councils’ usable reserves, 2023/24 compared to 2022/23 and 2018/19
Revenue reserves are higher than pre-pandemic but have remained relatively static 
in the last year.
0
.5
1
1.5
2
2.5
3
3.5
4
£ billion
Revenue Capital
2018/19 2022/23 2023/24
Note: Total usable reserves were £4.1 billion in 2023/24. Between 2022/23 and 2023/24 revenue
reserves increased by 0.8 per cent, capital reserves fell by 33 per cent. Total usable reserves are 
68 per cent higher than in 2018/19, up from £2.4 billion (90 per cent increase in revenue reserves,
four per cent decrease in capital reserves)
Source: Councils’ annual accounts 2023/24 (audited and unaudited)
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3. Financial position and outlook 26
45. The overall decrease in usable reserves in 2023/24 is notable as they
have been increasing significantly in recent years. Two-thirds of councils
still increased their total usable reserves, but this is largely attributable
to councils making use of financial flexibilities (a number of councils
accounted for this in 2022/23, while others introduced it in 2023/24).
46. Around a third of councils saw their total usable reserve fall in
2023/24, including some large decreases related to the drawing down
of committed reserves. These reserves were used for Equal Pay
settlements, pay awards, budget support and the further deployment
of Covid-19 reserves.
General Fund reserves increased slightly but over
80 per cent are committed for specific purposes
47. General Fund reserves (excluding the HRA element which not
all councils have) continued the upward trend of the past five years,
increasing by three per cent in 2023/24 to £2.8 billion. This equates to
17 per cent of net cost of services and is driven by growth in committed
reserves. Uncommitted reserves have remained constant at between
two and three per cent of net cost of services (Exhibit 9, page 27).
48. In 2023/24, over 80 per cent of the General Fund was committed.
This means that it has been allocated for specific purposes and is not
readily available for other uses.
The General Fund
is the principal usable
revenue reserve held
by councils. It can be
used for a wide range
of purposes, including
bridging budgets gaps
as it can be used to
finance spending on
services or some
elements of capital
spending.
The Housing Revenue
Account (HRA)
reserve can only be
used to fund spending
on council-owned
housing.
Committed reserves
have been allocated (or
earmarked) for specific
purposes and are not
readily available for
other uses.
Uncommitted
reserves can be
deployed more easily
and, because of the
nature and scale of
it, the uncommitted
element of the
General Fund can
be considered to
represent a degree of
contingency funding.
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3. Financial position and outlook 27
Exhibit 9. 
Councils’ General Fund balance between 2018/19 and 2023/24, 
split by committed and uncommitted
General Fund reserves are increasing but over 80 per cent is committed.
2019/20 2020/21 2021/22 2022/23 2023/24 2018/19
General Fund committed General Fund uncommitted
£730m
£360m
£848m
£467m
£0.9bn
£0.3bn
£0.9bn
£0.3bn
£1.9bn
£0.4bn £2.2bn
£0.4bn
£2.3bn
£0.4bn
£2.4bn
£0.5bn
Source: Councils’ annual accounts 2023/24 (audited and unaudited)
Some councils’ levels of uncommitted reserves are
low, but they have specific reserves earmarked for
contingency
49. Councils have reserve policies in place, which set out the rationale for
the minimum level of uncommitted reserves held by the council. Most
have an agreed minimum level, usually two per cent of their net budgeted
revenue expenditure, although four councils have set this higher.
50. In 2023/24, nine councils had an uncommitted reserves level of less
than two per cent of net budgeted revenue expenditure. However, a
review found that in many cases these low reserve levels were planned
decisions and the levels were deemed to be sufficient and/or supported
by additional committed funds for contingencies. Aberdeenshire, South
Ayrshire and West Dunbartonshire all had uncommitted reserves below
their minimum level and intend to review this during 2024/25.
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3. Financial position and outlook 28
51. While councils hold uncommitted reserves for contingencies,
around a third reported also earmarking some reserves specifically for
contingencies to either manage budget risks or specific risks, such as
adverse weather. The nine councils providing information on the value of
the reserves earmarked for contingencies reported a total of £50 million.
Councils continue to use their reserves to manage
budget pressures, but this is not sustainable
52. While overall usable reserves levels remain high, there is evidence
that councils are continuing to use reserves to support service spend and
this is not sustainable. In 2023/24:
• Councils bridged over a quarter of their budget gap using reserves
(£202 million).
• Twelve councils reported making unplanned use of reserves in
2023/24, to support in-year spending and to balance the outturn
position. This was most often to cover the cost of the 2023/24
pay award; to address specific service or project pressures, or to
provide financial support to IJBs.
53. Usable reserves held as a proportion of spending has reduced.
In 2023/24, 15 councils held usable reserves that were over 20 per cent
of their net cost of services, which is less than 2022/23 (20 councils) but
still higher than before the pandemic (nine councils). This indicates that
reserves are increasing at a slower rate than expenditure, even with use
of financial flexibilities. One council had total usable reserves of less than
ten per cent of their net cost of services.
Councils could improve how clearly they report on
how they intend to use their reserves
54. With the use of reserves to support services and the low level of
uncommitted reserves across the sector it is increasingly important that
councils report how and when the intend to make use of their reserves
(Case study 1, page 29).
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3. Financial position and outlook 29
Case study 1.
Councils could be more transparent within their published plans about
how they intend to make use of reserves
A review of councils’ management commentaries found that all councils
clearly identify key areas of reserves and explain their purpose, with most
identifying their minimum reserve level.
All but two councils reported, through their data return, that they formally
document or publish at least some information about their committed
reserves. Committed reserves information is usually documented in
councils’ accounts or financial outturn reports, and sometimes in other
formats, such as reserves reports. Few councils reported documenting
information in performance monitoring reports.
Nearly all councils publish and document a full costed breakdown of
committed reserves categories and details of what has been drawn
down within the year. Although most formally document what is
committed for major initiatives, this information is not always published.
Only two thirds of councils document or publish information on planned
spend for future years.
Source: Council data returns and Council annual accounts 2023/24
(audited and unaudited)
Recent changes to pension contribution rates offer
councils a short-term window to reduce costs
55. The result of the 2023 triennial revaluation showed a significantly
improved funding position across Scotland’s 11 local government pension
funds. Councils are using this as an opportunity to lower their employer
contributions and reduce their costs in the short-term. The 12 councils
who are members of Strathclyde Pension Fund are reducing their
contribution rates from 19.3 per cent to 6.5 per cent for 2024/25 and
2025/26 (increasing to 17.5 per cent in 2026/27), significantly reducing
their annual contribution costs for two years. Other councils are making
more modest reductions to their contribution rates of between two and
three percentage points.
Ensuring medium- and long-term financial
sustainability is a significant challenge
56. The risks to financial sustainability are well known. These include
external factors such as increased demand, demographic changes and
the need to invest significantly to address certain policy areas such as
climate change and its impact. There are also specific pressures that
councils identified as presenting risks to achieving future financial balance/
sustainability including:
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3. Financial position and outlook 30
• Uncertainty about future funding: single-year settlements,
ring-fencing of funding and directed funding for specific Scottish
Government policies limiting local flexibility (for example, teacher
numbers, social care provision and IJB allocations).
• Council tax freezes: while there is no freeze in 2025/26, the
Scottish Government froze council tax between 2008/09 and
2016/17, and in 2021/22, and capped increases at three per cent in
2017/18 and 2018/19. The risk of future freezes is seen as a main
challenge to ensuring medium- to long-term financial sustainability.
Even when ‘fully funded’ a council tax freeze suppresses the
growth of the council tax base over that period and the income
generated when the freeze is lifted is lower than if councils were
able to make tax-raising decisions at a local level.
• Pay awards and employers’ NI costs: overspends have been
caused by pay awards, with some councils reporting that the
budgets provided are not enough to cover the costs or these costs
are unfunded. In 2023/24, three councils made unplanned use of
reserves to meet pay awards and there is ongoing uncertainty about
the scale of future annual offers. There is now also uncertainty over
how increased employers’ NI contributions will be funded.
• Inflationary pressures: general pressures and some specific
issues that impact the delivery of capital programmes (costs of
goods and services, service demand, public perception, borrowing,
funding, increasing standards and difficulty with asset sales).
• Savings: some councils cited the challenge of identifying and
achieving recurring savings.
57. Most councils reported that financial sustainability was a significant
challenge. Some specific challenges reported by councils include:
• Angus Council reported the need for change if they are to be
financially sustainable over the medium to long term. The scale of
reductions required could leave some services unable to function.
• East Lothian Council identified critical risks to its fiscal sustainability
and reported managing their financial environment as the highest
ever scoring risk on their Corporate Risk Register.
• Inverclyde Council reported that ongoing depopulation may mean
significant future funding reductions.
• Orkney Islands Council highlighted the growing contribution from
reserves to meet in-year service costs as being unsustainable.
• Shetland Islands Council reported they were financially
unsustainable on the basis of current plans.
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3. Financial position and outlook 31
58. Alongside councils’ own assessment of their financial sustainability,
many auditors highlighted in their 2023/24 annual audit reports (15
available for review) the challenges councils face in achieving financial
balance in future years and securing long-term financial sustainability. 
These centred on the scale of budget gaps; the need to keep on top of
savings plans; low levels of uncommitted reserves; unsustainable cost
bases and the difficult choices to be made.
Councils have medium-term financial plans in place
but must now make progress on transformation 
and reform
59. While several councils reported confidence that they had robust
processes and actions in place to ensure they were financially
sustainable, councils largely reported that it is difficult to plan into the
future without clarity on medium- or long-term government funding and
priorities, stating there is general economic uncertainty and volatility.
This difficulty, however, underlines the importance of councils ensuring
that they have a clear understanding of risks to their financial positions,
effective risk management processes to monitor these, and indicative
forecasts informed by scenario planning.
60. All councils that provided data returns to us reported having medium-
term financial plans in place, with most of these spanning 3-5 years 
(25 out of 30 councils). Most councils (25) reported that they reviewed
their financial plans in 2024. Half of councils (15 out of 30) have a long-
term financial plan in place and, for those that do, most cover a 10-year
period.
61. As we set out in our recent Transformation in councils report,
councils must prioritise and progress the delivery of their plans for
transformation. And a step change is needed in terms of scale and
pace. That could look like new innovative approaches to service delivery,
reconsidering which services could be more effectively delivered by other
partners, exploring opportunities for new income generation (including
those that are being legislated for) or identifying how economies of scale
could be achieved by sharing services.
62. Delivering transformation successfully requires resources to be
committed towards it and it is positive to see that most councils 
(27 from our data return sample of 30) reported holding reserves
earmarked for transformation. Glasgow, Orkney and Shetland did not. 
Of the 26 providing information on the value held, a total of £270 million
was reported which is about 13 per cent of committed General Fund
balance and equates to two per cent of the net cost of services. Most
councils’ transformation reserves were equivalent to two per cent or
lower of net cost of services, but some earmarked a significantly higher
proportion. Argyll and Bute earmarked the equivalent of ten per cent of
net cost of services, Scottish Borders six per cent, and Aberdeenshire,
East Lothian and Highland all earmarked five per cent.
Transformation is
our next Best Value
thematic focus and
we will be auditing
councils’ plans for
transformation as 
part of the 2024/25
annual audit.
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3. Financial position and outlook 32
Councils could make more use of financial
sustainability indicators, including to inform their
longer-term planning
63. Assessing and monitoring financial sustainability is essential. Councils
use a range of indicators to do so, but the type used, and extent of their
use, varies. The Local Government Benchmarking Framework includes
sustainability indicators, currently being reviewed by Directors of Finance,
to ensure that they remain appropriate, and CIPFA also recommends
indicators. Councils are not required to use specific indicators and have
discretion as to how they assess their own financial sustainability.
64. We asked councils how they assess and monitor financial
sustainability, including how this is reported to elected members:
• Around three-quarters of councils use the Local Government
Benchmarking Framework Indicators and the CIPFA level of
reserves indicator.
• Around a third of councils use the CIPFA change in reserves and
reserves sustainability measures.
• Some councils reported that they use their own equivalent
calculations or different indicators including outturn against
expenditure, ratio of council tax to overall funding, ratio of financing
costs to net revenue stream, external debt and borrowing levels,
and recurrent versus non-current budget mitigation.
65. Most councils reported that they assess and monitor financial
sustainability more generally, such as via the regular monitoring of
budgets, reserves and the capital financing requirement; and carrying out
periodic risk assessments. For example, East Ayrshire Council’s ‘East
Ayrshire Performs’ reports financial and service performance information
about the council publicly, including a suite of financial resilience
indicators, focusing on council reserves and liquidity but also capital
financing, investment and borrowing.
66. Most councils include and consider financial indicators within
their financial plans, with 17 councils including an analysis of financial
sustainability and/or resilience indicators within their medium-term
financial plans and nine within their longer-term plans.
67. All councils reported to us that elected members had been provided
with a summary of the council’s medium- to long-term financial
sustainability but more needs to be done to regularly and formally report
upon the consideration of financial sustainability. This should be reported
publicly, as a minimum, as part of annual budget-setting papers and
within annual refreshes of financial plans.
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3. Financial position and outlook 33
Financial outlook
68. Within this report we outline the financial challenges Scotland’s
councils are now facing. While indications are that the 2025/26 budget
will result in increased funding, and councils are now free to vary council
tax rates, it is unlikely that increased funding and income will be able
to keep pace with increasing costs. In recent years councils have been
able to increase the reserves they hold, but much of this has been due
to additional Covid-19 funding, use of financial flexibilities and other one-
off actions. The initial benefits of these measures, and the reserves
that councils were able to build, do not negate the need for significant
reform and transformation. 2023/24 saw a reduction in usable reserves
and while this represented only five per cent of these reserves, this was
equivalent to over eight per cent of the usable reserves held as recently
as 2019/20.
69. How councils plan to use their reserves, make savings and
transform their services needs to become more transparent as financial
sustainability issues are to be addressed. The need to consult local
communities and clearly communicate the implications of budget
decisions has never been more important.
70. Our next Local government in Scotland publication, Local
government budgets 2025/26, will examine the steps that Scotland’s
councils take as they set their budgets for 2025/26, setting out the
finalised funding settlement from the Scottish Government, decisions
taken in setting council tax and the steps they intend to take to fund and
transform services.
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Appendix 1
Progress against the recommendations in Local
Government in Scotland Financial Bulletin 2022/23
Councils should: Progress/ status
Prioritise the achievement of recurring
savings and avoid reliance on non-recurring
savings to enhance longer-term financial
sustainability
In progress/Limited progress
The overall extent of progress against this
recommendation is difficult to assess due to a
lack of detail and transparency in reporting on
recurring and non-recurring savings performance
(paragraph 30).
An updated recommendation on savings
performance and transparency is included in this
report.
Ensure that management commentaries are
open and transparent, include a clear link
between budget outturn and the financial
performance in the accounts and report on 
the achievement of planned savings targets
In progress
Our review of 2023/24 management
commentaries found that that most councils
reported outturn against budget with significant
variations explained. However not all councils
provided sufficient information on savings target
achievement.  
An updated recommendation on savings
performance and transparency is included in
this report.
Provide clear statements about reserves
policy and explicitly set out the purpose
of committed reserves within their
annual accounts. This will enhance the
level of assurance that councils can
provide regarding their ongoing financial
sustainability
Complete / In progress
A review of available councils’ management
commentaries found that key areas of reserves
were clearly identified, with the purpose
explained and the majority identifying a
minimum reserve level. However publication 
of committed reserve information was less 
well evidenced (Case study 1).  
An updated recommendation on greater
transparency of reserves is included in this
report.
Cont.
34Appendix 1
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Appendix 1 35
Councils should: Progress/ status
Ensure effective and timely consultation
and engagement with communities on the
options that must be considered to achieve
a balanced budget
In progress
Less than half of councils stated, via our data
return, that public consultation was undertaken
when preparing budgets for 2023/24. In our
Local government budgets 2024/25 publication,
24 out of 32 councils stated they undertook
community engagement on financial pressures.
We will follow this up in our budget briefing in
Spring 2025 when we look at councils’ 2025/26
budget setting.
Strengthen their monitoring and reporting
of financial resilience including clearer and
more public-facing use of performance
against financial resilience indicators and
measures. Financial resilience indicators
should be a component of councils’ medium
and longer-term financial plans to provide
assurance that they are balancing short-term
pressures with robust planning for long-
term financial sustainability
In progress
Most councils reported that they assess and
monitor financial sustainability, with financial
indicators used in financial plans, with 17
explicitly using these within their medium- and
long-term financial plans (paragraphs 63 - 67).
An updated recommendation on the use of
financial indicators in monitoring and reporting is
included in this report.
Work with the Scottish Government to 
build momentum and accelerate progress 
in the development of a fiscal framework 
for local government to enhance the clarity
and certainty of budgets for councils in
future years
In progress
We understand that COSLA and the Scottish
Government have been progressing the
development of a fiscal framework
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Local government in Scotland
Financial bulletin
2023/24
Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN
Phone: 0131 625 1500 Email: info@audit.scot
www.audit.scot
ISBN 978 1 915839 60 2
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Audit Committee
Monday 24 February 2025
Item No  5.3 
Treasury Management and Investment Strategy 2025/26 & Prudential
Indicators 
Report by David Gladwin, Chief Financial Officer & Section 95 Officer 
Report for Decision 
1 Recommendations 
The Audit Committee is invited to comment on this report before it is
presented to Council.  In particular, Audit Committee should note the
following recommendations which are proposed to be put to Council on
25 February 2025:- 
a) Approve the restriction of the Authorised Limit to the value of
the Capital Financing Requirement at 31 March 2026
(£604.957 million), pending finalisation of the General
Services Capital Plan Prioritisation; 
b) Note that there are no other material changes proposed to the
Treasury Management and Investment Strategy (TMIS) for
2025/26 from the strategy currently in place, other than:- 
i. to no longer fully cash back the Council’s useable
reserves – instead, to run down cash balances to support
the deferral of borrowing as outlined in Section 4, to allow
the Council to navigate past the current interest rate
hump; and
ii. to update the Prudential Indicators (Section 5 and
Appendix 2), to reflect the revised capital plans; 
c) Note the use of the Asset Life method for the repayment of all
loans fund advances as outlined in Section 6; and 
d) Accordingly approve the Treasury Management and
Investment Strategy for 2025/26. 
2 Purpose of Report/Executive Summary 
In accordance with the Treasury Management Code of Practice, the
annual Treasury Management & Investment Strategy (TMIS) &
Prudential Indicators report is required to be adequately scrutinised
before being recommended to the Council.  For Midlothian, this role is
undertaken by the Audit Committee, with this report being presented to
Audit Committee on 24 February 2025 prior to consideration by Council
on 25 February 2025. 
The purpose of the report to Council will be to provide an update on the
implementation of the Council’s TMIS 2024/25, and to make
recommendations to facilitate consideration of the 2025/26 Strategy,
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2
specifically the TMIS for 2025/26, the Prudential and Treasury
indicators contained therein, and the approach to the statutory
repayment of loans fund advances. 
Any revisions arising from Audit Committee consideration of the report
on 24 February 2025 will be verbally updated to Council before
discussing the report on 25 February 2025. 
Date: 07 February 2025
Report Contact:
Gary Thomson, Senior Finance Business Partner
gary.thomson@midlothian.gov.uk 
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3
3. Update on implementation of TMIS for 2024/25 
3.1 Borrowing 
The Council’s borrowing position as set out in the 2024/25 Treasury
Management Mid-Year Review Report was £340.871 million at 31
March 2024, and six months later was £359.812 million on 30
September 2024. 
The principal source of borrowing is the UK Debt Management
Office’s Public Works Loans Board (PWLB) and fixed rate loans are
taken at a time and tenure which takes cognisance of the PWLB rates
(derived from the UK Gilts market) and the management of maturity
risk in the long term across the Council’s loan portfolio. 
The Council’s loan portfolio, as at 24 January 2025, is shown in table
1 below:- 
Table 1: Current Loan Portfolio as at 24 January 2025 
Loan Type
Principal
Outstanding
£000’s
Weighted
Average
Rate
PWLB Annuity 395 8.91%
PWLB Maturity 343,502 3.15%
LOBO 20,000 4.51%
Market Loans 15,548 2.68%
Total Loans 379,445 3.21% 
The repayment profile of this debt is shown in graphical and tabular
form below:- 
Figure 1: Loan Maturity Structure 
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4
Table 2: Loan Maturity Profile 
Financial Year 2024/25
Remaining
£000’s
2025/26-
2026/27
£000’s
2026/27-
2028/29
£000’s
2029/30-
2032/33
£000’s
2033/34-
2037/38
£000’s
2038/39+ 
£000’s
Debt Maturing 0 2,263 46,323 60,106 32,365 238,389
% of total portfolio 0.00% 0.60% 12.21% 15.84% 8.53% 62.83% 
Proactive Treasury Management by the Council in the last decade
has placed the Council in a strong refinancing position for its existing
external debt portfolio, with just 12.80% (£48.585 million) of the
Council’s total Loan Portfolio of £379.445 million requiring refinancing
over the remainder of the current, and forthcoming four, financial
years, as shown in the table above. 
The majority of this (£43m) matures in the final few years of this
decade (March 2027+) where borrowing in the last 12 months to fund
the Council’s in-year Capital Financing Requirements has been
sourced in line with the approved TMIS – specifically, to borrow from
PWLB for a relatively shorter term (3-5 years Maturity loan; 10 year
Equal Instalment of Principle (EIP) loan), to navigate past the current
interest rate hump, with gilt yields expected to ease throughout the
course of the next 12-36 months. 
This relatively low short-term exposure to refinancing risk puts the
Council in a strong position to plan its borrowings in advance, take
advantage of any dips in longer-term borrowing rates from PWLB and
other sources, and maintain a low weighted average coupon rate on
external debt. 
3.2 Deposits 
The Council’s position for funds on deposit fluctuates on a daily basis,
with the 2024/25 Treasury Management Mid-Year Review Report
setting out the position at 31 March 2024 of £56.619 million and six
months later on 30 September 2024, at £49.550 million. 
The position at 31 January 2025, as set out in Table 3 below, totals
£45.408 million. 
Table 3: Current Deposits as at 31 January 2025 
Deposit Type
Principal
Outstanding
£000’s
Weighted
Average
Rate
Bank Call Accounts 1,655 4.71%
Money Market Funds 23,753 4.72%
Bank Fixed Term Deposits 20,000 5.06%
Total Deposits 45,408 4.87% 
The Council’s current deposit portfolio is broadly reflective of the wider
UK Local Authority position, as noted in the Treasury Management &
Annual Investment Strategy Statement – 2025/26 Detailed in
Appendix 3, Section 4.4. 
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5
4. Treasury Management & Investment Strategy 2025/26 
4.1 Main Objectives of TMIS 2025/26 
The objectives of the proposed TMIS are:- 
• To secure long-term borrowing to fund capital investment,
through locking in to long-term interest rates and de-risking
the Council’s Capital Financing Requirement (CFR); 
• To ensure short-term liquidity to manage the Council’s day-to-
day cashflow.  This is achieved through the utilisation of
instant access Money Market Fund and Bank Accounts, with
the amount held in these reflecting the Council’s level of
working capital and fluctuating throughout the year due to a
number of factors; 
The only material changes to the 2025/26 TMIS, from the 2024/25
TMIS approved by Council, are as follows:- 
1. Approve the restriction of the Authorised Limit to the value of
the Capital Financing Requirement at 31 March 2026
(£604.957 million) (see Section 5 – Prudential Indicators),
pending finalisation of the General Services Capital Plan
Prioritisation;
2. To approve a change in policy to no longer fully cash-back the
Council’s usable reserves (see Section 4.4 – Investment
Strategy). 
There are no changes recommended to the Permitted Investments. 
More detail on the borrowing and investment strategy for 2025/26 is
provided in Sections 4.2, 4.3 and 4.4 below. 
4.2 Borrowing Requirement 2024/25 to 2028/29 
The Council’s capital plans contain projections of capital expenditure
and income over the forthcoming financial years.  Any expenditure not
financed directly by income, requires funding through borrowing. 
The projected borrowing requirement arising from the Council’s
Capital Plans, the Midlothian Energy Limited (MEL) Shareholder
Injection, and the maturing long-term loans that require to be
refinanced, over the period 2024/25 to 2028/29 is shown in table 4:- 
Table 4: Total Borrowing Requirement over the period 2024/25 to 2028/29 
2024/25
£000’s
2025/26
£000’s
2026/27
£000’s
2027/28
£000’s
2028/29
£000’s
Total
£000’s
Capital Expenditure      
General Services 53,913 91,680 129,171 86,134 12,185 373,083
HRA 47,429 80,242 72,003 44,139 28,826 272,639
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6
Total Capital Expenditure 101,342 171,922 201,174 130,273 41,011 645,722
Total Available Financing -32,039 -36,073 -40,007 -23,478 -17,805 -149,403
Principal Debt Repayments -10,394 -10,679 -12,111 -13,711 -15,111 -62,006
Capital Expenditure less
available Financing 
58,909 125,170 149,054 93,084 8,095 434,313
MEL Shareholder Injection 4,590 0 0 0 0 4,590
Maturing Long-term Loans 0 2,263 12,391 12,409 22,427 49,490
Total Borrowing
Requirement
63,499 127,433 161,445 105,493 30,522 488,393
Borrowing secured -40,000 0 0 0 0 -40,000
Anticipated borrowing
over remainder of
2024/25
-15,000 0 0 0 0 -15,000
Total Remaining
Borrowing Requirement
8,499 127,433 161,445 105,493 30,522 433,393 
4.3 Borrowing Strategy for remainder of 2024/25 and 2025/26 
Borrowing is undertaken to finance the Council’s approved Capital
plans and to do so in the most cost-effective way.  As can been noted
from Table 4 above the Council has a significant borrowing
requirement across the current and forthcoming four financial years
(2024/25 to 2028/29). 
This TMIS provides for this capital investment to be underpinned by
long-term borrowing, recognising the current interest rate
environment, the significant borrowing requirement arising from the
Council’s capital plans, and the long term benefits of de risking the
delivery and affordability of these capital plans by locking into the
certainty brought by PWLB fixed rate loans. 
The Council’s external loan debt at 31 March 2025 is projected to be
£394.445 million.  Based on the Council’s historic and current
approved Capital Plans, the Underlying Borrowing Requirement
(UBR) – which is the Council’s underlying need to borrow for capital
purposes (excluding the long-term liability arising from PFI/DBFM
projects) – at 31 March 2025 is expected to equate to £479.787
million (see Appendix 2, Table 2.3). 
This means that the Council is expected to be £85.342 million (18%)
under-borrowed at the end of the 2024/25 financial year i.e. the
Council has funded the majority (82%) of its underlying borrowing
requirement as at 31 March 2025.  In the current economic climate,
this is a prudent approach which balances (a) de-risking the longer
term borrowing requirement at current longer term borrowing rates;
against (b) the current year and forthcoming financial year budget
projections; and is in line with the majority of other Scottish Local
Authorities.  As noted in Section 3.1 above, the Council has a
relatively low short-medium term exposure to refinancing risk and is
therefore in a strong position to plan its new borrowing requirements
in advance, taking advantage of any dips in longer-term borrowing
rates from PWLB and other sources, and maintain a low weighted
average coupon rate on external debt.
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The Underlying Borrowing Requirement is projected to rise to
£855.191 million by 31 March 2029 (see Appendix 2, Section 2.3) –
more than double the current external debt portfolio value.  The profile
of this, and the projected external loan portfolio to fund the Underlying
Borrowing Requirement over the period 2024/25 to 2028/29, is shown
in graphical format below. 
Figure 3: Projected Loan Portfolio & Underlying Borrowing
Requirement 
Interest Rates
The current PWLB yield curve is bell shaped with the low point in the
curve at the 3 year mark (4.90%; certainty rate) with rates trending
upwards towards the 20-30 year tenor (high point of 5.86%) before
easing back slightly to sit at c. 5.55% in the 50 year duration. 
Current PWLB rates have generally increased by c. 50bps across the
entire curve from levels reported at the time of the 2024/25 TMIS to
Council in February 2024, and have shifted upwards by 25-35bps
across the medium to long part of the curve since the TM Mid Year
Review Report to Council in December 2024 whilst holding fairly
steady at the very short (up to 7 year) range. 
The yield curve is expected to remain bell shaped over the short-
medium term, with a gradual shift downwards of the entire curve by c.
40bps over the next 12 months, a further 40bps over the subsequent
12 months and a further 20bps over the following 12 months of the
forecast period (so 100bps total). 
This is forecast to bring longer-term borrowing rates down from
between 5.30%-5.50%, to between:- 
• 4.90%-5.10% by March 2026;
• 4.50%-4.70% by March 2027; and
• 4.30%-4.50% by March 2028. 
The Interest Rate Forecast from the Council’s Treasury Advisers,
MUFG Corporate Markets (formerly Link Treasury Services Limited),
is shown in Table 5 below, with Further commentary on this is
provided in Appendix 3 Section 3.3.
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8 
Table 5: MUFG Interest Rate Forecasts 
The funding of the Council’s in-year and forward CFR is typically for
infrastructure with long asset lives (50-60 years), and the tenor of
PWLB and market loans are typically drawn with this in mind. 
Borrowing Strategy
Consideration for any new borrowing in the remainder of the 2024/25
financial year and during the 2025/26 financial year, to fund the
Council’s in-year CFR, will seek to balance:- 
a) the security/certainty of current relatively high longer-term
borrowing rates of upwards of 5.30% in the 30-50 year duration
(which are forecast to drop by 40bps within one year and a total
of 80bps within 24 months) and the potential additional
budgetary pressure that this brings in both the short/medium
and longer term; with 
b) the option to borrow initially for a shorter-term duration from
PWLB or other markets, for 3 to 5 years (at say c. 4.50% at the
HRA rate), to allow the Council to fund the immediate in-year
borrowing requirement.  Based on current interest rate
forecasts (see Appendix 3 Section 3.3), this would then allow
the Council the option to refinance this borrowing at initial 3-5
year maturity with less expensive, longer term borrowing, e.g. a
45 to 47 year tenor in, say, 36 months at a forecast rate of c.
4.30%. 
As noted in Section 3.1, the Council’s proactive Treasury
Management over the last decade has put the Council in a strong
refinancing position for its external debt portfolio which allows the
Council to slot in shorter dated external borrowing into the current
debt maturity profile to fund the current & forthcoming in-year
borrowing requirements, to allow the Council to navigate past the
current expected hump in longer-term borrowing rates. 
It is expected that any further long-term borrowing that is undertaken
during 2024/25 and 2025/26 to finance the current & future year
capital plans will be sourced by drawing new PWLB loans at the
Certainty Rate (which has been available to the Council since 2012
and is priced at Gilts+80bps), and/or the HRA rate.  The HRA rate is
available to all Councils to fund HRA capital expenditure, at a rate that
is priced at Gilts+40bps.  In the UK Budget in October 2024, the
availability over which Councils can draw HRA rate borrowing from
PWLB was extended to 31 March 2026.
MUFG Corporate Markets Interest Rate View
Mar-25 Jun-25 Sep-25 Dec-25 Mar-26 Jun-26 Sep-26 Dec-26 Mar-27 Jun-27 Sep-27 Dec-27
BANK RATE 4.50 4.25 4.00 4.00 3.75 3.75 3.75 3.50 3.50 3.50 3.50 3.50
3 month average earnings 4.50 4.30 4.00 4.00 4.00 3.80 3.80 3.80 3.50 3.50 3.50 3.50
6 month average earnings 4.40 4.20 3.90 3.90 3.90 3.80 3.80 3.80 3.50 3.50 3.50 3.50
12 month average earnings 4.40 4.20 3.90 3.90 3.80 3.80 3.80 3.80 3.50 3.50 3.50 3.50
5 year PWLB 4.90 4.80 4.60 4.50 4.50 4.40 4.30 4.20 4.10 4.00 4.00 3.90
10 year PWLB 5.10 5.00 4.80 4.80 4.70 4.50 4.50 4.40 4.30 4.20 4.20 4.10
25 year PWLB 5.50 5.40 5.30 5.20 5.10 5.00 4.90 4.80 4.70 4.60 4.50 4.50
50 year PWLB 5.30 5.20 5.10 5.00 4.90 4.80 4.70 4.60 4.50 4.40 4.30 4.30
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Both the General Services and HRA capital programmes are being
kept under regular review due to the effects of inflationary pressures,
shortages of materials and labour, and the ratios of financing costs to
the net revenue streams.  The Council’s borrowing strategy will,
therefore, also be regularly reviewed and then revised, if necessary,
to achieve optimum value and risk exposure in the medium-long-term. 
Appendix 3 Section 3.3 provides forecasts for interest rates from the
Council’s Treasury Management advisor, MUFG Corporate Markets. 
Council officers, in conjunction with MUFG, will continue to monitor
daily long-term borrowing rates in order to take advantage of any dips
in the market or to de-risk any change in the medium-longer term
forecast for gilt yields. 
Forward Borrowing
The opportunity also continues to exist to consider further loans on a
‘forward dealing’ basis, and officers will continue to explore the
viability of these loans as part of securing the long term borrowing
required to meet the Council’s Underlying Borrowing Requirement. 
Debt Rescheduling 
As noted in the Mid-Year Review Report, now that the whole of the
yield curve has shifted higher there may be opportunities for debt
rescheduling in the remainder of the financial year. 
This would involve the Council repaying loans prematurely (both
market and PWLB) whilst high discount rates on premature
repayment prevail. 
Any debt rescheduling will be considered when the difference
between the refinancing rate and the redemption rate is most
advantageous and the situation will be continually monitored in order
to take advantage of any perceived anomalies in the yield curve.  The
reasons for any rescheduling taking place would include: 
- the generation of cash savings at minimum risk;
- to reduce the average interest rate;
- to amend the maturity profile and/or the balance of volatility of
the debt portfolio. 
Council officers will explore debt rescheduling opportunities with
MUFG Treasury Solutions; with only prudent and affordable debt
rescheduling that considers both the short and medium-longer term
impact being considered. 
4.4 Investment Strategy for remainder of 2024/25 and 2025/26 
As noted in Section 4.1, the only change to the proposed Investment
Strategy for the remainder of 2024/25 and 2025/26 is to no longer fully
cash back the Council’s useable reserves, instead using these
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10
balances to allow the deferral of borrowing at the current high interest
rates payable, to allow the Council to most effectively navigate past
the current interest rate hump of the next 36 months, when rates on
longer term borrowing are expected to drop by 100bps. 
No other changes are proposed to the Investment Strategy from that
approved by Council in the 2024/25 TMIS. 
All deposits will be placed with high creditworthy counterparties in
accordance with the approved creditworthiness policy as outlined in
Appendix 1, with a tenor reflective of the expected drawdown of
useable reserve forecasts, and at a yield commensurate with this. 
The list of Permitted Investments in Appendix 1 remains unchanged
from that approved by Council in the 2024/25 TMIS. 
As required by the CIPFA Treasury Management Code, Local
authorities “must not borrow to invest for the primary purpose of
financial return.”  Midlothian Council does not and has not borrowed to
invest for the primary purpose of financial return. 
Environmental, Social and Governance (ESG) in credit and
counterparty policies (Treasury Management Practice 1) 
As noted in the 2024/25 TMIS, the inclusion of ESG criteria continues
to be an emerging area in the Local Authority environment which will
require ongoing monitoring. 
For the 2025/26 financial year, the Council’s priorities of security,
liquidity and then yield remain paramount and unchanged (and in that
order), with ESG criteria an added 4th element to consider in the
decision making process. 
For short term investments with counterparties, this Council utilises
the MUFG creditworthiness service which uses the ratings provided
by Fitch, Moody’s and Standard & Poor’s to assess creditworthiness,
which in themselves include analysis of ESG factors, and specifically
the “G” element, when assigning ratings.  Of the 3 elements of ESG,
the most important element when considering treasury deposits is the
Governance aspect – given the majority of treasury deposits
undertaken by Midlothian Council are naturally short dated in duration,
poor governance can have a more immediate impact on the financial
circumstances of an entity and potential for a default event that could
impact the amount of principal returned on the deposit. 
Those financial institutions viewed as having poor/weak corporate
governance are generally less well credit rated in the first instance or
have a higher propensity for being subject to negative rating action,
and the Council’s existing creditworthiness policy will therefore take
this into account. 
Environment and Social factors are also important, but relate more to
the long-term impact.  Council should note that in relation to the
security aspect of Treasury deposits, placing an undue weight on the
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11
Environmental and Social factors in the decision making process
could have an adverse effect of limiting the list of potential
counterparty options, thus decreasing diversification.  This could then
in turn lead to a widening of credit (security) criteria, or those with a
stronger “ESG” performance, in order to restore a balance of
diversification across the deposit portfolio, potentially increasing credit
risk – and placing the cornerstone of prudent investing at risk. 
The inclusion of ESG criteria therefore remains an area which
requires ongoing review.  Council officers, in conjunction with the
Council’s treasury advisers MUFG, will therefore continue to monitor
and assess ongoing developments and emerging standards in this
area, and methods in which the Council can incorporate ESG factors
into our creditworthiness assessment process, and report back to
Council accordingly. 
5 Prudential Indicators – Midlothian Council 
The Prudential Code for Capital Finance in Local Authorities requires
that Councils can demonstrate that their Capital Plans are affordable,
prudent and sustainable, taking into account the financial provisions
made in current and future revenue budgets; and that Treasury
Management decisions are taken in accordance with good practice. 
The Prudential Indicators that Councils need to consider relate to both
actual, historic outcomes, and future estimated outcomes (covering
the same period as the Council’s Capital Plans), as follows:- 
• Actual outcomes for 2023/24;
• Revised estimates of the 2024/25 indicators; and
• Estimates of indicators for 2025/26 to 2028/29. 
The Prudential Indicators required by the Code are listed individually
in Appendix 2. 
The key Prudential Indicators relating to the Underlying Borrowing
Requirement, the expected Gross External Debt, and the proposed
Authorised Limit, are shown in graphical format below. 
Figure 4: Prudential Indicators for Borrowing 
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12 
The Capital Financing Requirement (CFR) denotes the Council’s
underlying need to borrow for capital purposes.  The CFR includes
borrowing arising as a result of the Council’s Capital Plans, plus the
long-term liability arising from the Council’s PPP/DBFM contracts. 
The Underlying Borrowing Requirement as shown in Figure 4
above strips out the latter of these (long-term liability arising from the
Council’s PPP/DBFM contracts) from the CFR. 
The Authorised Limit for Borrowing represents the limit beyond
which borrowing is prohibited, and needs to be set and revised by
Members.  It is the expected maximum borrowing need with some
headroom for unexpected movements. 
The Authorised Limit for Borrowing for the 2025/26 financial year has
been calculated to equate to the maximum value of the Underlying
Borrowing Requirement in 2025/26.  This equates to £604.957 million
as outlined in Table 6 below. 
Table 6: Authorised Limit for Borrowing: Calculation 
Authorised Limit for Borrowing Amount
£000’s
CFR – General Services (31 March 2026) 261,535
CFR – HRA (31 March 2026) 343,422
Proposed Authorised Limit for Borrowing 604,957
Council is therefore asked to approve an authorised limit for borrowing
of £604.957 million (see Appendix 2, Section 4.2). 
IFRS16
The Council will adopt IFRS16 for its statutory accounts for financial
year 2024/25.  This will bring on balance sheet all operating leases
where there is a right of use asset addition.  Work is being finalised to
quantify the effect of this on the Balance Sheet and the Prudential
Indicators, and adjustments to the limits will be included in the Treasury
Management Outturn Report to Council in June 2025, and the Treasury
Management Mid Year Review Report to Council in late 2025.  Council
should note that the on balance sheet treatment of IFRS16 will have no
394,445
528,600
684,328
777,161 785,216
£-
£100,000
£200,000
£300,000
£400,000
£500,000
£600,000
£700,000
£800,000
£900,000
2024/25 2025/26 2026/27 2027/28 2028/29
£000's
Financial Year
Prudential Indicators for Borrowing
External Debt Authorised Limit Underlying Borrowing Requirement / Operational Boundary
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13
impact on the Council’s underlying need to borrow for Treasury
Management purposes, and therefore no limit on the Authorised Limit
for Borrowing of £604.957 million as proposed in this report. 
6 Statutory repayment of loans fund advances 
Under the Local Government Finance Circular 7/2016, Council is
required to set out its policy for the statutory repayment of loans fund
advances prior to the start of each 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. 
6.1 New Assets 
In accordance with Finance Circular 7/2016, for all advances made in
relation to the provision of a new asset, the policy will be to defer the
commencement of the first principal repayment of the loans fund
advance until the financial year following the one in which the asset is
first available for use. 
6.2 Prudent Repayment of Loans Fund Advances 
Finance Circular 7/2016 provides a variety of options to Councils for
the profiling of the repayment of each loans fund advance, so long as
the principle of prudence is maintained.  For the 2025/26 financial year,
there are 3 options available: (a) Asset Life method; (b) Depreciation
method; and (c) Funding/income profile method. 
In line with the policy adopted in 2024/25, the Asset Life method shall
be used for those assets in Table 7. 
Table 7: Asset Classes adopting the “Asset Life” method
Infrastructure
Current
Loans
Fund
Advance
Period
New Primary Schools/Extensions 60
New Leisure Centres 60
New Offices 60
Road Upgrades 50
Street Lighting Columns 50
Structures/Bridges 50
Footway/Cyclepaths 50
Town Centre Environmental Improvements 50
New Care Homes 45
Children’s Play Equipment 20 
The annual repayments under the “Asset Life” method for those asset
classes as noted above will be calculated using the asset lives and will
use the annuity method, in line with previous years.  The annuity
interest rate that will be used to calculate loans fund principal
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14
repayments under the “Asset Life” method will be the in-year loans fund
rate, which for 2024/25 is currently estimated to be 2.54%. 
For all other asset classes, the policy will also be to profile the annual
repayments under the “Asset Life” method, with the profile also
calculated using the annuity method.  The annuity interest rate that will
be used to calculate loans fund principal repayments under the “Asset
Life” method will be the in-year loans fund rate, which for 2024/25 is
currently estimated to be 2.54%. 
Whilst neither the Depreciation nor the Funding/income profile methods
are currently proposed, Council officers will continue to monitor whether
it is appropriate to use this for future capital projects. 
7. Report Implications 
7.1 Resource 
There are no direct resource implications arising from this report. 
7.2 Digital 
None 
7.3 Risk 
The strategies outlined in this report are designed to maintain the
effectiveness of the overall risk management arrangements for
Treasury activity.  Providing the limits outlined in the strategies are
observed they will support the controls already in place in the
Treasury Management Practices within which the treasury function
operates. 
The Prudential Indicators contained in Appendix 2 maintain the
effectiveness of the overall risk management of Capital Investment
and Treasury Management. 
7.4 Ensuring Equalities 
There are no equality issues arising from this report. 
7.5 Additional Report Implications 
See Appendix A. 
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Appendix A: Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Not applicable. 
A.2 Key Drivers for Change 
A.3 Key Delivery Streams 
Themes addressed in this report: 
One Council Working with you, for you 
Preventative and Sustainable 
Efficient and Modern 
Innovative and Ambitious 
None of the above 
A.4 Delivering Best Value 
The report does not directly impact on Delivering Best Value. 
A.5 Involving Communities and Other Stakeholders 
Although no external consultation has taken place, cognisance has
been taken of professional advice obtained from MUFG Asset
Services, the Council’s appointed Treasury Consultants. 
A.6 Impact on Performance and Outcomes 
The strategies to be adopted are an integral part of the corporate aim
to achieve Best Value as they seek to minimise the cost of borrowing
by exercising prudent debt management and investment. This in turn
helps to ensure that the Council’s capital expenditure is sustainable in
revenue terms. 
A.7 Adopting a Preventative Approach 
Not applicable. 
A.8 Supporting Sustainable Development 
Not applicable. 
Background Papers:-
Appendix 1:- Permitted Investments
Appendix 2:- Prudential Indicators
Appendix 3:- Treasury Management & Annual Investment Strategy
Statement – 2025/26 Detailed
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Permitted Investments Appendix 1 
The Council uses the Link creditworthiness service for specific categories of permitted
investments.  This utilises credit ratings from the three main credit rating agencies – Fitch,
Moody’s and Standard & Poors, along with credit watches, outlooks, CDS spreads and country
sovereign ratings in a weighted scoring system with an end product of a series of colour coded
bands which indicate the relative creditworthiness of specific categories of counterparties for
investment. 
These colour codes are used by the Council to determine the maximum suggested duration for
investment with that counterparty.  These are as follows:- 
Link Asset Services
Colour Code
Maximum Suggested
Duration for Investment
Yellow 6 years*
Dark Pink 6 years**
Light Pink 6 years**
Purple 2.5 years
Blue 1.25 years***
Orange 1.25 years
Red 7 months
Green 120 days
No colour Not to be used
* Note the yellow colour category is for:- UK Government Debt, or its equivalent, Money
Market Funds (MMF's), and collateralised deposits where the collateral is UK Government
Debt
** Dark Pink for Ultra Short Dated Bond Funds with a credit score of 1.25; Light Pink for Ultra
Short Dated Bond Funds with a credit score of 1.5
*** Only applies to nationalised or semi-nationalised UK banks 
Note that the maximum suggested durations listed above have been extended by 1 year (when
compared to the suggested maximum durations provided by Link) for the Yellow, Dark Pink, Light
Pink categories (and so to 6 years); the Purple category by 6 months to 2.5 years; the Blue and
Orange categories by 3 months to 1.25 years; the Red category by a month to 7 months, and the
Green category by 20 days to 120 days.  This is to allow flexibility around these durations on the
margins e.g. the placement of a 13 month fixed term deposit for a counterparty rated Orange or
Blue.  A thorough appraisal of the additional risk involved in extending the duration of any deposit
(marginally) beyond the maximum suggested by Link, against any enhanced value to the portfolio,
will be undertaken prior to the placement of any deposit. 
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1.1  Deposits 
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m
of total
investments
Max. maturity
period
Debt Management Agency
Deposit Facility -- Term No 100% 6 months
Term deposits – local authorities -- Term No 100% 5 years
Call accounts – banks and
building societies Green Instant No 100% 1 day
Term deposits / Notice Accounts
– banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use 
1.2 Deposits with counterparties currently in receipt of government support / ownership 
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
UK nationalised banks – Call
accounts Blue Instant No 100% 1 day
UK nationalised banks – Term
Deposits / Notice Accounts Blue Term No 100% 1.25 years
UK nationalised banks – Fixed
term deposits with variable rate
and variable maturities: -
Structured deposits
Blue Term No 100% 1.25 years
Non-UK(high sovereign rated
country) nationalised banks –
Call accounts
Green Instant No 100% 1 day
Non-UK (high sovereign rated
country) nationalised banks:-
Term Deposits / Notice Accounts
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Non-UK (high sovereign rated
country) nationalised banks:- 
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits  
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
If forward deposits are made, the forward period plus the deal period equate to the maximum maturity
period. 
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1.3  Collective investment schemes structured as Open Ended Investment Companies (OEICs) 
Investment Category
Minimum
Credit
Criteria 
Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
Government Liquidity Funds AAA Instant No 100% 1 day
Money Market Funds CNAV AAA Instant No 100% 1 day
Money Market Funds LVNAV AAA Instant No 100% 1 day
Money Market Funds VNAV AAA Instant No 100% 1 day
Ultra Short Dated Bond Funds
with a credit score of 1.25 AAA T+1 to
T+5 Yes 100% 1 week
Ultra Short Dated Bond Funds
with a credit score of 1.5 AAA T+1 to
T+5 Yes 100% 1 week
Bond Funds AAA T+2 or
longer Yes 50% 2 days
Gilt Funds AAA T+2 or
longer Yes 50% 2 days 
1.4 Securities issued or guaranteed by governments 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max %?£m 
of total
investments
Max. maturity
period
Treasury Bills
UK
sovereign
rating
Sale T+1 Yes 100% 50 years
UK Government Gilts
UK
sovereign
rating 
Sale T+1 Yes 100% 50 years
Bond issuance issued by a
financial institution which is
explicitly guaranteed by  the
UK Government  e.g. National
Rail
UK
sovereign
rating 
Sale T+3 Yes 100% 50 years
Sovereign bond issues (other
than the UK govt)
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years
Bonds issued by multilateral
development banks 
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years 
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1.5 Securities issued by corporate organisations 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max % 
of total
investments
Max. maturity
period
Certificates of deposit issued
by banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+0 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Commercial paper other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+0 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Floating rate notes
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Corporate Bonds other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use 
1.6 Other 
Investment Category Minimum Credit
Criteria  Liquidity
risk
Market
risk 
Max %/£m 
of total
investments
Max.
maturity
period
Local authority mortgage guarantee
scheme. Blue Term No 50% 5 years
Loans to Third Parties n/a Term No £25m 25 years
Subordinated Debt Subscription to
Newbattle Centre SPV n/a Term No £0.326m 22 years
Midlothian Energy Limited n/a Term No £10.2m n/a 
Treasury Risks and Mitigating Controls for each type of investment are as outlined in the Treasury
Management & Annual Investment Strategy Statement – 2023/24 Detailed – Appendix 5.3.  The Council’s
Treasury Management Practices have also been updated in line with the new CIPFA Prudential and
Treasury Management Codes which were approved by Audit Committee on 6 December 2022.  
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Prudential Indicators Appendix 2 
1. Prudential Indicators for Affordability 
These indicators provide an indication of the impact of the capital investment plans on the
Council’s overall finances. 
1.1 Estimates of Ratio of Financing Costs to Net Revenue Stream 
This indicator identifies the trend in the cost of capital (borrowing and other long term obligation
costs net of investment income) against the net revenue stream. 
The figures above are based on the current General Services and HRA Capital Plans. 
1.2 HRA Ratios 
The following indicator identifies the ratio of overall debt on the HRA account compared to annual
house rent revenue. 
The following indicator identifies the ratio of overall debt on the HRA account per HRA dwelling. 
1.3 Net Income from Service & Commercial Investments as a proportion of Net Revenue Stream 
A indicator, which is a requirement of the new Prudential Code, identifies the ratio of net income
from service and commercial investments as a proportion of the net General Services revenue
stream. 
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
General Services 0.62% 1.30% 2.85% 3.87% 4.90% 4.98%
HRA 40.24% 42.80% 44.42% 48.49% 51.95% 53.19%
Ratio of Financing Costs to Net Revenue Stream
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
HRA debt £000's 246,524£  277,473£  343,422£  399,595£  426,052£  440,130£ 
HRA Revenues £000's 33,162      37,730      41,060      44,266      46,352      48,642     
Ratio of HRA Debt to Revenues
% 743% 735% 836% 903% 919% 905%
HRA Debt as a % of Gross Revenue
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
HRA debt £000's 246,524£  277,473£  343,422£  399,595£  426,052£  440,130£ 
Number of HRA dwellings 7,448        7,592        7,747        8,068        8,228        8,253       
Debt per dwelling £ 33,099£    36,548£    44,330£    49,528£    51,781£    53,330£   
HRA Debt per Dwelling
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Income from Service Investments          34           34           34           34           34           34
Net Revenue Stream 257,849  293,755  313,460  318,960  320,210  321,460
% 0.01% 0.01% 0.01% 0.01% 0.01% 0.01%
Net Income from Service Investments as a proportion of Net Revenue Stream
%
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2. Prudential Indicators for Capital Expenditure 
The Council’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. 
2.1 Estimated Capital Expenditure 
This indicator shows the gross capital spend included in the relevant capital plans. 
2.2 Financing of Capital Expenditure 
This indicator shows how the Capital Expenditure forecasts are being financed by capital or
revenue resources.  Any shortfall of resources results in a funding borrowing need. 
2.3 Estimated Capital Financing Requirement 
This indicator measures the Council’s maximum underlying need to borrow for capital purposes
and other long term liabilities over the next three years. 
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
General Services
Children, Young People & Estates 26,241£  21,547£    52,177£    101,332£  63,822£    4,572£   
Asset Management 10,897£  15,736£    18,639£    12,063£    12,160£    8,800£   
Transport, Energy & Infrastructure 2,340£    3,841£      3,370£      5,308£      2,233£      428£      
Regeneration & Development 6,263£    13,706£    17,648£    12,097£    10,509£    -£           
Other 1,915£    1,623£      1,257£      697£         698£         621£      
Provision for return of contingencies -£            (2,539)£    (1,411)£    (2,327)£    (3,287)£    (2,236)£  
Total General Services 47,656£  53,913£    91,680£    129,170£  86,134£    12,185£ 
Total HRA 50,412£  47,429£    80,242£    72,003£    44,139£    28,826£ 
Combined Total 98,068£  101,342£  171,922£  201,173£  130,273£  41,011£ 
Capital Expenditure
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Expenditure
General Services 47,656£  53,913£    91,680£    129,170£  86,134£    12,185£ 
HRA 50,412£  47,429£    80,242£    72,003£    44,139£    28,826£ 
Total 98,068£  101,342£  171,922£  201,173£  130,273£  41,011£ 
Financed by:
Capital receipts -£           -£             -£             -£             -£             -£           
Capital grants 33,539£  25,462£    22,467£    22,602£    18,712£    13,774£ 
Capital reserves -£           -£             -£             -£             -£             -£           
Developer/Other Contributions 88£         6,578£      13,606£    17,405£    4,767£      4,031£   
Net financing need for the year 64,441£  69,303£    135,849£  161,165£  106,795£  23,206£ 
Capital Expenditure and Available Financing
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3. Prudential Indicators for Prudence 
3.1 Net Borrowing Requirement 
This indicator shows the amount of external borrowing required to finance the current debt
outstanding on capital projects. 
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Financing Requirement
CFR – General Services 169,764£  202,314£   261,535£  354,416£   421,043£  415,061£ 
CFR – HRA 246,524£  277,473£   343,422£  399,595£   426,052£  440,130£ 
CFR – PFI Schemes 88,739£    84,815£     80,661£    76,277£     71,663£    66,819£   
Total CFR 505,027£  564,602£   685,618£  830,288£   918,758£  922,010£ 
Movement in CFR 102,163£  59,575£     121,016£  144,670£   88,470£    3,251£     
Movement in CFR represented by
Net financing need for the year (previous table) 64,441£    69,303£     135,849£  161,165£   106,795£  23,206£   
MEL Shareholder Injection -£             4,590£       -£             -£               -£             -£            
Less Scheduled Debt Amortisation (9,494)£    (10,394)£    (10,679)£  (12,111)£    (13,711)£  (15,111)£ 
Less net PFI Finance Lease Principal Payments (3,694)£    (3,924)£      (4,154)£    (4,384)£      (4,614)£    (4,844)£   
Movement in CFR 51,253£    59,575£     121,016£  144,670£   88,470£    3,251£     
Capital Financing Requirement (CFR)
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
External Debt
Debt at 1 April 321,753£  340,871£  394,445£  528,600£  684,328£     777,161£    
Actual/Expected change in Debt 19,118£    53,574£    134,155£  155,728£  92,833£       8,054£        
Other long-term liabilities (OLTL) at 1 April 92,433£    88,739£    84,815£    80,661£    76,277£       71,663£      
Actual/Expected change in OLTL (3,694)£    (3,924)£    (4,154)£    (4,384)£    (4,614)£       (4,844)£      
Actual/Expected Gross Debt at 31 March 429,610£  479,260£  609,261£  760,605£  848,824£     852,035£    
The Capital Financing Requirement 505,027£  564,602£  685,618£  830,288£  918,758£     922,010£    
Under / (over) borrowing 75,417£    85,342£    76,357£    69,683£    69,934£       69,975£      
Deposits
Cash & Cash Equivalents 26,619£    20,000£    20,000£    20,000£    20,000£       20,000£      
Short-Term Investments 30,000£    -£             -£             -£             -£                -£               
Total Deposits 56,619£    20,000£    20,000£    20,000£    20,000£       20,000£      
Net Borrowing Requirement
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4. Prudential Indicators for External Debt 
4.1 Operational Boundary 
This is the limit beyond which external debt is not normally expected to exceed and will be the
focus of day to day treasury management.  Typically, this would be a similar figure to the CFR,
but may be lower or higher depending on the levels of actual debt.
For this Council:-
• the Operational Boundary for Borrowing has been calculated to equate directly to the
value of the CFR for General Services and HRA combined, over the current financial
year and the following 4 financial years (2024/25 to 2028/29); and
• the Operational Boundary for Other Long-Term Liabilities has been calculated to
equate directly to the in-year CFR for Other Long-Term Liabilities, given the known
contractual provisions for the repayment of debt within the Council’s two PPP
agreements. 
Should the Operational Boundary be breached, for example as a result of a decision taken to
borrow in advance (should market conditions indicate that it is prudent to do so), this will be
reported to Council at the next available opportunity. 
4.2 Authorised Limit of Total External Debt 
This indicator sets the limit for total external debt. 
The Authorised Limit for Borrowing for the 2025/26 financial year has been calculated to equate
to the maximum value of the Underlying Borrowing Requirement in 2025/26.  This equates to
£604.957 million as outlined below. 
2024/25 2025/26 2026/27 2027/28 2028/29
Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's
Operational Boundary - Borrowing 479,787£ 604,957£ 754,011£  847,095£  855,191£ 
Operational Boundary - Other long term liabilities 84,815£   80,661£   76,277£    71,663£    66,819£   
Total 564,602£ 685,618£ 830,288£  918,758£  922,010£ 
Operational Boundary
£000's
CFR - General Services at 31 March 2026 261,535£ 
CFR - HRA at 31 March 2026 343,422£ 
Authorised Limit for Borrowing 604,957£ 
Authorised Limit for Borrowing
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5. Prudential Indicators for Treasury Management 
5.1 Upper limits on Fixed and Variable Interest Rates 
This indicator limits the amount of external debt that may be held at fixed or variable rates.  These
limits are proposed to be as follows:- 
5.2 Maturity Structure of Borrowing 
This indicator sets the upper and lower limits of the time scales within which external debt may be
held. 
The Treasury Management Code of Practice requires that LOBO’s with a call date in the next 12
months are classified as short-term borrowing rather than longer-term (10 year+) borrowing. 
In addition, the Code also recommends that where an authority’s debt is typically very long term
(i.e. for a period of greater than 10 years), that authorities should break down the period in excess
of 10 years into several ranges, for example 10 to 20 years, 20 to 30 years, etc. 
With the above in mind, the proposed upper and lower limits for each maturity band are shown
below, with the overall aim to ensure a spreading approach to avoid a cluster of high value loans
maturing/requiring refinancing within a short period of time. 
Limits on fixed interest rates based on gross debt 100.00%
Limits on variable interest rates based on gross debt 30.00%
Limits on fixed interest rates based on investments 100.00%
Limits on variable interest rates based on investments 100.00%
Upper Limits on Exposure to Fixed and Variable Interest Rates 2025/26
Interest rate exposures Upper
Limit
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5.4 Total Principal Sums Invested for Periods Longer than 365 Days 
This indicator relates to the total level of investments held for periods longer than 365 days. 
The current strategy as outlined in the body of these reports is to continue to cash-back the
Council’s balance sheet reserves.  It is expected that the majority of this will be in the form of fixed
term deposits and/or certificates of deposit.  Given expected reserve forecasts and the current
interest rate environment, in particular the short-medium term forecast for the Council’s Capital
Fund and HRA Reserve, the limit for prinicipal sums invested for > 365 days has been retained at
£70m. 
For its cash flow generated balances, the Council will seek to utilise its business reserve instant
access accounts and money market funds. 
5.5 Liability Benchmark 
The “Liability Benchmark” identifies future borrowing needs across the short, medium and longer
terms, against the maturity profile of the Council’s existing loan portfolio. 
The Council’s Liability Benchmark in graphical format is as shown below. 
Maturity structure of fixed interest rate borrowing 2025/26 Lower Upper
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
Maturity structure of variable interest rate borrowing 2025/26 Lower Upper
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
30 years to 40 years
Under 12 months
12 months to 2 years
50 years and above
40 years to 50 years
Maturity Structure of Borrowing 2025/26
5 years to 10 years
10 years to 20 years
20 years to 30 years
30 years to 40 years
40 years to 50 years
50 years and above
Under 12 months
12 months to 2 years
2 years to 5 years
2 years to 5 years
5 years to 10 years
10 years to 20 years
20 years to 30 years
Limit £70m
Principal Sums Invested for > 365 Days
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There are four components to the Liability Benchmark: - 
1 Existing loan debt outstanding: the Council’s existing loans that are still
outstanding in future years – shown as the stacked bar elements of the figure
above.
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 shows the Council’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 (drawdowns/enhancement of
reserves) forecast.
4 Liability benchmark (or gross loans requirement): this equals net loans
requirement plus short-term liquidity/working capital allowance. 
The Liability Benchmark Indicator identifies the Council’s expected future capital financing
requirement, as driven by the Council’s approved Capital Plans – and therefore the Council’s
future borrowing needs; along with how this matches to the existing debt maturity profile.  It is
therefore a key tool to support the financing risk management of the capital financing
requirement. 
As can be noted from the figure above, the Council has a significant borrowing requirement
(which equates to £448.393 million) in the short-medium term, arising as a direct result of the
Council’s approved Capital Plans.  The proposed approach to securing this borrowing need for
the 2025/26 financial year is outlined in the main body of this report, Section 4.3. 
The Liability Benchmark also outlines the profile of the Council’s CFR over the medium-long term,
against the Council’s existing debt portfolio maturity profile.  As can be seen from the figure
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above, the profile of the CFR movements in the medium-long term broadly matches the
movements in the Councils external debt portfolio over this period. 
The Debt Liability Benchmark will assist the Council with plotting the tenor of borrowing to finance
the Council’s approved capital plans that is undertaken in the remainder of 2024/25 and the
forthcoming 2025/26 period, to ensure that this aligns with the Council’s future expected CFR
profile and Liability Benchmark projections, taking into account the profile of existing loan
maturities as identified in the figure above. 
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Appendix 3 
Treasury Management Strategy Statement
and Annual Investment Strategy 
Midlothian Council
2025/26 
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INDEX 
1 INTRODUCTION ............................................................................................................................ 3
1.1 Background ............................................................................................................................................... 3
1.2 Reporting requirements ............................................................................................................................ 3
1.3 Treasury Management Strategy for 2025/26 ........................................................................................... 5
1.4 Training ...................................................................................................................................................... 5
1.5 Treasury management consultants .......................................................................................................... 6
2 THE CAPITAL PRUDENTIAL INDICATORS 2025/26 – 2028/29 ............................................. 7
2.1 Capital expenditure ................................................................................................................................... 7
2.2 The Council’s borrowing need (the Capital Financing Requirement) ...................................................... 8
3 Borrowing .................................................................................................................................... 11
3.1 Current portfolio position ......................................................................................................................... 11
3.2 Treasury Indicators: limits to borrowing activity ...................................................................................... 13
3.3 Prospects for interest rates ..................................................................................................................... 14
3.4 Borrowing strategy .................................................................................................................................. 16
3.5 Policy on borrowing in advance of need ................................................................................................. 20
3.6 Debt rescheduling ................................................................................................................................... 20
4 ANNUAL INVESTMENT STRATEGY ........................................................................................ 21
4.1 Investment policy ..................................................................................................................................... 21
4.2 Creditworthiness policy ........................................................................................................................... 23
4.3 Country and sector limits ......................................................................................................................... 24
4.4 Investment strategy ................................................................................................................................. 25
4.5 Investment risk benchmarking ................................................................................................................ 26
4.6 End of year investment report ................................................................................................................. 26
5 Appendices .................................................................................................................................. 27
5.1 APPENDIX: Economic Background ....................................................................................................... 28
5.2 APPENDIX: Treasury Management Practice (TMP1): Permitted Investments .................................... 28
5.3 APPENDIX: Treasury Management Practice (TMP1) – Credit and Counterparty Risk Management 41
5.4 APPENDIX: Approved countries for investments .................................................................................. 47
5.5 APPENDIX: Treasury management scheme of delegation .................................................................. 48
5.6 APPENDIX: The treasury management role of the section 95 officer .................................................. 49 
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1 INTRODUCTION
1.1 Background
The main function of the treasury management service is the funding of the Council’s
capital plans.  These capital plans provide a guide to the borrowing need of the Council,
essentially the longer term cash flow planning to ensure that the Council can meet its
capital spending obligations.  This management of longer term cash may involve
arranging long or short term loans, or using longer term cash flow surpluses.   On
occasion any debt previously drawn may be restructured to meet Council risk or cost
objectives. 
The Council is required to operate a balanced budget, which broadly means that cash
raised during the year will meet cash expenditure.  As such, the second part of the treasury
management operation is to ensure that this cash flow is adequately planned, with cash
being available when it is needed.  Surplus monies are deposited with low risk
counterparties or instruments commensurate with the Council’s low risk appetite, providing
adequate liquidity initially before considering investment return. 
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 affecting the available budget.  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. 
Whilst any loans to third parties, commercial investment initiatives or other non-financial
investments will impact on the treasury function, these activities are generally classed as
non-treasury activities, (arising usually from capital expenditure),and are separate from the
day to day treasury management activities. 
CIPFA defines treasury management as: 
“The management of the local authority’s borrowing, investments and cash flows, 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.” 
Whilst any commercial initiatives or loans to third parties will impact on the treasury
function, these activities are generally classed as non-treasury activities, (arising
usually from capital expenditure), and are separate from the day-to-day treasury
management activities 
1.2 Reporting requirements
1.2.1 Capital Strategy 
The CIPFA Prudential and Treasury Management Codes require all local authorities
to prepare an additional report, a capital strategy report, which provides the following: 
• a high-level long term overview of how capital expenditure, capital financing
and treasury management activity contribute to the provision of services
• an overview of how the associated risk is managed
• the implications for future financial sustainability 
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4
The aim of the capital strategy is to ensure that all elected members on the full council
fully understand the overall long-term policy objectives and resulting capital strategy
requirements, governance procedures and risk appetite. 
1.2.2 Treasury Management Reporting 
The Council is required to receive and approve, as a minimum, three main reports each
year, which incorporate a variety of polices, estimates and actuals.   
a) Prudential and treasury indicators and treasury strategy (this report) - The
first, and most important report covers:
• the capital plans (including prudential indicators) for 2024/25 to 2028/29;
• a policy for the statutory repayment of debt, (how residual capital expenditure
is charged to revenue over time);
• the treasury management strategy (how the investments and borrowings are
to be organised) for 2025/26, including treasury indicators; and 
• a permitted investment strategy for 2025/26 (the parameters on how
investments are to be managed). 
b) A mid year treasury management report – This will update members with
the progress of the capital position, amending prudential indicators as
necessary, and whether the actual treasury strategy is meeting the strategy
outlined in advance of the year, or whether any policies require revision. 
c) An annual treasury outturn report – This provides details of a selection of
actual prudential and treasury indicators for the previous financial year and
actual treasury operations compared to the estimates within the strategy. 
Scrutiny
The above reports are required to be adequately scrutinised before being
recommended to the Council.  This role is undertaken by the Audit Committee with this
report being presented to Audit Committee prior to consideration by Council.  Any
revisions arising from Audit Committee consideration of the report on 24 February 2025
will be verbally updated to Council before discussing the report on 25 February 2025. 
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1.3 Treasury Management Strategy for 2025/26
The strategy for 2025/26 covers two main areas: 
Capital issues
• the capital expenditure plans and the prudential indicators (Section 2 of this report);
• The policy for the statutory repayment of loans fund advance (Section 2.4 of this
report). 
Treasury management issues
• policy on use of external service providers (Section 1.5);
• the current treasury position (Section 3.1);
• treasury indicators which limit the treasury risk and activities of the Council (Section
3.2);
• prospects for interest rates (Section 3.3);
• the borrowing strategy (Section 3.4);
• policy on borrowing in advance of need (Section 3.5);
• debt rescheduling (Section 3.6);
• the investment strategy (Section 4.1); and
• creditworthiness policy (Section 4.2). 
These elements cover the requirements of the Local Government in Scotland Act 2003, the
CIPFA Prudential Code, the CIPFA Treasury Management Code and The Scottish
Government Local Authority (Capital Finance & Accounting) (Scotland) Regulations 2016.
1.4 Training
The CIPFA Code requires the responsible officer to ensure that members with responsibility
for treasury management receive adequate training in treasury management.  This
especially applies to members responsibe for scrutiny.   
Furthermore, pages 47 and 48 of the Code state that they expect “all organisations to have
a formal and comprehensive knowledge and skills or training policy for the effective
acquisition and retention of treasury management knowledge and skills for those
responsible for management, delivery, governance and decision making. 
Organisations need to consider how to assess whether treasury management staff and
board/ council members have the required knowledge and skills to undertake their roles
and whether they have been able to maintain those skills and keep them up to date. 
As a minimum, authorities should carry out the following to monitor and review knowledge
and skills: 
• Record attendance at training.
• Prepare tailored learning plans for treasury management officers and
board/council members.
• Require treasury management officers and board/council members to
undertake self-assessment against the required competencies. 
• Have regular communication with officers and board/council members,
encouraging them to highlight training needs on an ongoing basis.” 
In further support of the revised training requirements, CIPFA’s Better Governance Forum
and Treasury Management Network have produced a ‘self-assessment by members
responsible for the scrutiny of treasury management’, which is available from the CIPFA
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website to download.  This was presented to members of the Audit Committee and Council
as part of the Council’s Treasury Management 2021-22 Mid-Year Review Report. 
A formal record of Knowledge & Skills Schedule has been developed as part of the
Council’s Treasury Management Practices.  This will be periodically reviewed to assess
suitability, and updated to reflect ongoing training, knowledge and skills gained.  Similarly,
a formal record of the treasury management/capital finance training received by members
will also be periodically reviewed and updated. 
1.5 Treasury management consultants
The Council uses MUFG Corporate Markets (former Link, Treasury Solutions Limited) as
its external treasury management advisors. 
The Council recognises that responsibility for treasury management decisions remains with
the organisation at all times and will ensure that undue reliance is not placed upon our
external service providers.  All decisions will be undertaken with regards to all available
information, including, but not solely, our treasury advisers. 
It also recognises that there is value in employing external providers of treasury
management services in order to acquire access to specialist skills and resources. The
Council will ensure that the terms of their appointment and the methods by which their value
will be assessed are properly agreed and documented, and subjected to regular review. 
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2 THE CAPITAL PRUDENTIAL INDICATORS 2024/25 –
2028/29
The Council’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.
2.1 Capital expenditure
This prudential indicator is a summary of the Council’s capital expenditure plans,
both those agreed previously, and those forming part of this budget cycle.
The table below summarises the Capital Expenditure forecasts:- 
The table below shows how the Capital Expenditure forecasts are being financed
by capital or revenue resources.  Any shortfall of resources results in a funding
borrowing need.
Members are asked to approve the capital expenditure forecasts and the financing
of these forecasts:- 
Note: The above financing need excludes other long term liabilities, such as PFI
and leasing arrangements which already include borrowing instruments.  
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
General Services
Children, Young People & Estates 26,241£  21,547£    52,177£    101,332£  63,822£    4,572£   
Asset Management 10,897£  15,736£    18,639£    12,063£    12,160£    8,800£   
Transport, Energy & Infrastructure 2,340£    3,841£      3,370£      5,308£      2,233£      428£      
Regeneration & Development 6,263£    13,706£    17,648£    12,097£    10,509£    -£           
Other 1,915£    1,623£      1,257£      697£         698£         621£      
Provision for return of contingencies -£            (2,539)£    (1,411)£    (2,327)£    (3,287)£    (2,236)£  
Total General Services 47,656£  53,913£    91,680£    129,170£  86,134£    12,185£ 
Total HRA 50,412£  47,429£    80,242£    72,003£    44,139£    28,826£ 
Combined Total 98,068£  101,342£  171,922£  201,173£  130,273£  41,011£ 
Table 1: Capital Expenditure
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Expenditure
General Services 47,656£  53,913£    91,680£    129,170£  86,134£    12,185£ 
HRA 50,412£  47,429£    80,242£    72,003£    44,139£    28,826£ 
Total 98,068£  101,342£  171,922£  201,173£  130,273£  41,011£ 
Financed by:
Capital receipts -£           -£             -£             -£             -£             -£           
Capital grants 33,539£  25,462£    22,467£    22,602£    18,712£    13,774£ 
Capital reserves -£           -£             -£             -£             -£             -£           
Developer/Other Contributions 88£         6,578£      13,606£    17,405£    4,767£      4,031£   
Net financing need for the year 64,441£  69,303£    135,849£  161,165£  106,795£  23,206£ 
Table 2: Capital Expenditure and Available Financing
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2.2 The Council’s borrowing need (the Capital Financing Requirement)
The second prudential indicator is the Council’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 Council’s underlying borrowing need.  Any capital expenditure
above, which has not immediately been paid for (financed), will increase the CFR.
The CFR does not increase indefinitely, as annual repayments from revenue need
to be made which reflect the useful life of capital assets financed from borrowing. 
From 1st April 2016, Local Authorities may choose whether to use scheduled debt
amortisation (loans pool charges) or another suitable method of calculation in order
to repay borrowing.
The CFR includes any other long term liabilities (e.g. PFI schemes, finance leases). 
Whilst these increase the CFR, and therefore the Council’s borrowing requirement,
these types of scheme already include a borrowing facility and so the Council is
not required to separately borrow for these schemes.  The Council currently has
£88.739m of such schemes within the CFR.  The Council is asked to approve the
CFR projections below: 
A key aspect of the regulatory and professional guidance is that elected members
are aware of the size and scope of any commercial activity in relation to the
authority’s overall financial position.  The capital expenditure figures shown in 2.1
and the details above demonstrate the scope of this activity and, by approving
these figures, consider the scale proportionate to the Authority’s remaining activity.
2.3 Liability Benchmark
A third prudential indicator is the Debt Liability Benchmark (LB).  The Authority is
required to estimate and measure the LB for the forthcoming financial year and
the following two financial years, as a minimum. 
There are four components to the Liability Benchmark: - 
1 Existing loan debt outstanding: the Council’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 shows the Council’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
(drawdowns/enhancement of reserves) forecast.
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Financing Requirement
CFR – General Services 169,764£  202,314£   261,535£  354,416£   421,043£  415,061£ 
CFR – HRA 246,524£  277,473£   343,422£  399,595£   426,052£  440,130£ 
CFR – PFI Schemes 88,739£    84,815£     80,661£    76,277£     71,663£    66,819£   
Total CFR 505,027£  564,602£   685,618£  830,288£   918,758£  922,010£ 
Movement in CFR 102,163£  59,575£     121,016£  144,670£   88,470£    3,251£     
Movement in CFR represented by
Net financing need for the year (previous table) 64,441£    69,303£     135,849£  161,165£   106,795£  23,206£   
MEL Shareholder Injection -£             4,590£       -£             -£               -£             -£            
Less Scheduled Debt Amortisation (9,494)£    (10,394)£    (10,679)£  (12,111)£    (13,711)£  (15,111)£ 
Less net PFI Finance Lease Principal Payments (3,694)£    (3,924)£      (4,154)£    (4,384)£      (4,614)£    (4,844)£   
Movement in CFR 51,253£    59,575£     121,016£  144,670£   88,470£    3,251£     
Table 3: Capital Financing Requirement (CFR)
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4 Liability benchmark (or gross loans requirement): this equals net
loans requirement plus short-term liquidity/working capital allowance. 
2.4 Core funds and expected investment balances
The application of resources (capital receipts, reserves etc.) to either finance
capital expenditure or other budget decisions to support the revenue budget will
have an ongoing impact on investments unless resources are supplemented each
year from new sources (asset sales etc.).  Detailed below are estimates of the year-
end balances for each resource and anticipated day-to-day cash flow balances. 
*Working capital balances shown are estimated year-end; these may be higher
mid-year 
2.5 Statutory repayment of loans fund advances
Under the Local Government Finance Circular 7/2016, Council is now required to set
out its policy for the statutory repayment of loans fund advances prior to the start of
each 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.
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
HRA Balances 32,143£    35,352£    35,351£      35,660£      36,011£    36,152£ 
General Fund Balances 9,877£      7,000£      5,000£        5,000£        5,000£      5,000£   
Earmarked reserves 24,317£    13,767£  6,883£        -£               -£             -£           
Provisions 4,138£      3,900£      3,800£        3,700£        3,600£      3,500£   
Capital Fund 20,107£    18,137£    18,137£      18,137£      18,137£    18,137£ 
Total Reserves / Core Funds 90,582£    78,156£    69,171£      62,497£      62,748£    62,789£ 
Reserve
Table 4: Balance Sheet Resources
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It is proposed to retain the methodology adopted in 2024/25 – that is as follows:-
New Assets
In accordance with Finance Circular 7/2016, for all advances made in relation to the
provision of a new asset, the policy will be to defer the commencement of the first
principal repayment of the loans fund advance until the financial year following the one
in which the asset is first available for use.
Prudent Repayment of Loans Fund Advances
Finance Circular 7/2016 provides a variety of options to Councils for the profiling of the
repayment of each loans fund advance, so long as the principle of prudence is
maintained.  There are 4 options available: (a) Asset Life method; (b) Statutory method;
(c) Depreciation method; and (d) Funding/income profile method.
In line with the policy adopted in 2024/25, the Asset Life method shall be used for those
assets in Table 5.
Table 5: Asset Classes adopting the “Asset Life” method
Infrastructure
Curren
Loans Fund
Advance
Period
New Primary Schools/Extensions 60
New Leisure Centres 60
New Offices 60
Road Upgrades 50
Street Lighting Columns 50
Structures/Bridges 50
Footway/Cyclepaths 50
Town Centre Environmental Improvements 50
New Care Homes 45
Children’s Play Equipment 20 
The annual repayments under the “Asset Life” method for those asset classes as noted
above will be calculated using the asset lives and will use the annuity method, to
ensure consistency of approach with the Statutory method for all other asset classes
(see below).  The annuity interest rate that will be used to calculate loans fund principal
repayments under the “Asset Life” method will be the in-year loans fund rate, which for
2024/25 is currently estimated to be 2.54%.
For all other asset classes, the policy will also be to profile the annual repayments
under the “Asset Life” method, with the profile also calculated using the annuity
method.  The annuity interest rate that will be used to calculate loans fund principal
repayments under the “Asset Life” method will be the in-year loans fund rate, which for
2024/25 is currently estimated to be 2.54%.
Whilst neither the Depreciation nor the Funding/income profile methods are currently
proposed, Council officers will continue to monitor whether it is appropriate to use this
for future capital projects.
IFRS16
The Council will adopt IFRS16 for its statutory accounts for financial year 2024/25. 
This will bring on balance sheet all operating leases where there is a right of use asset
addition.  Work is being finalised to quantify the effect of this on the Balance Sheet and
the Prudential Indicators, and adjustments to the limits will be included in the Treasury
Management Outturn Report to Council in June 2025, and the Treasury Management
Mid-Year Review Report to Council in late 2025.  Council should note that the on-
balance sheet treatment of IFRS16 will have no impact on the Council’s underlying
need to borrow for Treasury Management purposes, and therefore no limit on the
Authorised Limit for Borrowing of £605.707 million as proposed in this report. 
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3 Borrowing
The capital expenditure plans set out in Section 2 provide details of the service activity of
the Council.  The treasury management function ensures that the Council’s cash is
organised in accordance with the the relevant professional codes, so that sufficient cash is
available to meet this service activity.  This will involve both the organisation of the cash
flow and, where capital plans require, the organisation of approporiate borrowing facilities. 
The strategy covers the relevant treasury / prudential indicators, the current and projected
debt positions and the annual investment strategy.
3.1 Treasury management portfolio position
The overall treasury management portfolio as at 31 March 2024 and for the position as at
31 January 2025 are shown below for both borrowing and investments.
Table 6: Portfolio Position 31 March 2024 and 31 January 2025 
The Council’s forward projections for borrowing and investments are summarised below.
The table shows the actual external debt (the treasury management operations), against
the underlying capital borrowing need (the Capital Financing Requirement - CFR),
highlighting any over or under borrowing. 
Within the range of prudential indicators there are a number of key indicators to ensure
that the Council operates its activities within well-defined limits.  One of these is that
the Council needs to ensure that its gross debt does not, except in the short term, exceed
Principal Weighted Principal Weighted
Outstanding Average Outstanding Average
£000’s Rate £000’s Rate
PWLB Annuity               452 8.91%               395 8.91%
PWLB Maturity        304,128 3.01%        343,502 3.15%
LOBO          20,000 4.51%          20,000 4.51%
Market Loans          16,221 2.68%          15,548 2.68%
Salix Loans                 70 0.00%                  -   0.00%
Total Loans        340,871 3.09%        379,445 3.21%
Principal Weighted Principal Weighted
Outstanding Average Outstanding Average
£000’s Rate £000’s Rate
Bank Call Accounts            1,519 5.14%            1,655 4.71%
Money Market Funds          25,100 5.29%          23,753 4.72%
Bank Fixed Term Deposits          30,000 5.12%          20,000 5.06%
Total Deposits          56,619 5.20%          45,408 4.87%
31 January 202531 March 2024
31 March 2024 31 January 2025
Loan Type
Deposit Type
2023/24 2024/25 2025/26 2026/27 2027/28 2028/29
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
External Debt
Debt at 1 April 321,753£  340,871£  394,445£  528,600£  684,328£     777,161£    
Actual/Expected change in Debt 19,118£    53,574£    134,155£  155,728£  92,833£       8,054£        
Other long-term liabilities (OLTL) at 1 April 92,433£    88,739£    84,815£    80,661£    76,277£       71,663£      
Actual/Expected change in OLTL (3,694)£    (3,924)£    (4,154)£    (4,384)£    (4,614)£       (4,844)£      
Actual/Expected Gross Debt at 31 March 429,610£  479,260£  609,261£  760,605£  848,824£     852,035£    
The Capital Financing Requirement 505,027£  564,602£  685,618£  830,288£  918,758£     922,010£    
Under / (over) borrowing 75,417£    85,342£    76,357£    69,683£    69,934£       69,975£      
Deposits
Cash & Cash Equivalents 26,619£    20,000£    20,000£    20,000£    20,000£       20,000£      
Short-Term Investments 30,000£    -£             -£             -£             -£                -£               
Total Deposits 56,619£    20,000£    20,000£    20,000£    20,000£       20,000£      
Table 7: Net Borrowing Requirement
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the total of the CFR in the preceding year plus the estimates of any additional CFR for
2025/26.
The Chief Financial Officer & Section 95 Officer reports that the Council complied with
this prudential indicator in the current year and does not envisage difficulties for the
future.  This view takes into account current commitments, existing plans, and the
proposals in this budget report.  
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3.2 Treasury Indicators: limits to borrowing activity
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.
For this Council:-
• the Operational Boundary for Borrowing has been calculated to equate directly
to the in-year value of the CFR over the current and following 4 financial years
(2024/25 to 2028/29); and
• the Operational Boundary for Other Long-Term Liabilities has been calculated
to equate directly to the in-year CFR for Other Long-Term Liabilities, given the
known contractual provisions for the repayment of debt within the Council’s two
PPP agreements. 
The authorised limit for external debt
This indicator sets the limit for total external debt. 
The Authorised Limit for Borrowing for the 2025/26 financial year has been calculated to
equate to the maximum value of the Underlying Borrowing Requirement in 2025/26.  This
equates to £604.957 million as outlined below. 
2024/25 2025/26 2026/27 2027/28 2028/29
Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's
Operational Boundary - Borrowing 479,787£ 604,957£ 754,011£  847,095£  855,191£ 
Operational Boundary - Other long term liabilities 84,815£   80,661£   76,277£    71,663£    66,819£   
Total 564,602£ 685,618£ 830,288£  918,758£  922,010£ 
Table 8: Operational Boundary
£000's
CFR - General Services at 31 March 2026 261,535£ 
CFR - HRA at 31 March 2026 343,422£ 
Authorised Limit for Borrowing 604,957£ 
Table 9: Authorised Limit for Borrowing
394,445
528,600
684,328
777,161 785,216
£-
£100,000
£200,000
£300,000
£400,000
£500,000
£600,000
£700,000
£800,000
£900,000
2024/25 2025/26 2026/27 2027/28 2028/29
£000's
Financial Year
Prudential Indicators for Borrowing
External Debt Authorised Limit Underlying Borrowing Requirement / Operational Boundary
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3.3 Prospects for interest rates
The Council has appointed MUFG Corporate Markets as its treasury advisor and part
of their service is to assist the Council to formulate a view on interest rates. Link
provided the following forecasts for certainty rates (gilt yields plus 80 bps) on 11
November with the next update scheduled for the week commencing 10th February
following the Bank of England’s Monetary Policy Committee Meeting on 6th February
2025. 
MUFG’s revised PWLB rate forecasts below are based on the Certainty Rate (the
standard rate minus 20 bps). 
Following the 30 October Budget, the outcome of the US Presidential election on 6
November, and the 25bps Bank Rate cut undertaken by the Monetary Policy
Committee (MPC) on 7 November, MUFG have significantly revised their central
forecasts for the first time since May 2024.  In summary, the Bank Rate forecast is now
50bps – 75bps higher than was previously the case, whilst the PWLB forecasts have
been materially lifted to not only reflect our increased concerns around the future path
of inflation, but also the increased level of Government borrowing over the term of the
current Parliament. 
Reflecting on the 30 October Budget, MUFG’s central case is that those policy
announcements will 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 2.7% y/y (Q4 2025) and 2.2% (Q4 2026) before
dropping back in 2027 to 1.8% y/y. 
The anticipated major investment in the public sector, according to the Bank, is
expected to 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, and a tepid GDP performance. 
MUFG’s central view is that monetary policy is sufficiently tight at present to cater for
some further moderate loosening, the extent of which, however, will continue to be
data dependent.  MUFG forecast the next reduction in Bank Rate to be made in
February (MPC meeting on 06/02/2025) and for a pattern to evolve whereby rate cuts
are made quarterly and in keeping with the release of the Bank’s Quarterly Monetary
Policy Reports (February, May, August and November). 
Any movement below a 4% Bank Rate will, nonetheless, be very much dependent on
inflation data in the second half of 2025. The fact that the November MPC rate cut
MUFG Corporate Markets Interest Rate View
Mar-25 Jun-25 Sep-25 Dec-25 Mar-26 Jun-26 Sep-26 Dec-26 Mar-27 Jun-27 Sep-27 Dec-27
BANK RATE 4.50 4.25 4.00 4.00 3.75 3.75 3.75 3.50 3.50 3.50 3.50 3.50
3 month average earnings 4.50 4.30 4.00 4.00 4.00 3.80 3.80 3.80 3.50 3.50 3.50 3.50
6 month average earnings 4.40 4.20 3.90 3.90 3.90 3.80 3.80 3.80 3.50 3.50 3.50 3.50
12 month average earnings 4.40 4.20 3.90 3.90 3.80 3.80 3.80 3.80 3.50 3.50 3.50 3.50
5 year PWLB 4.90 4.80 4.60 4.50 4.50 4.40 4.30 4.20 4.10 4.00 4.00 3.90
10 year PWLB 5.10 5.00 4.80 4.80 4.70 4.50 4.50 4.40 4.30 4.20 4.20 4.10
25 year PWLB 5.50 5.40 5.30 5.20 5.10 5.00 4.90 4.80 4.70 4.60 4.50 4.50
50 year PWLB 5.30 5.20 5.10 5.00 4.90 4.80 4.70 4.60 4.50 4.40 4.30 4.30
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decision saw a split vote of 8-1 confirms that there are already some concerns around
inflation’s stickiness, and with recent public sector wage increases beginning to funnel
their way into headline average earnings data, the market will be looking very closely
at those releases. 
Regarding the PWLB forecast, the short to medium part of the curve is forecast to
remain elevated over the course of the next year, and the degree to which rates
moderate will be tied to the arguments for further Bank Rate loosening or otherwise. 
The longer part of the curve will also be impacted by inflation factors, but there is also
the additional concern that with other major developed economies such as the US and
France looking to run large budget deficits there could be a glut of government debt
issuance that investors will only agree to digest if the interest rates paid provide
sufficient reward for that scenario. 
Donald Trump’s victory in the US Election paves the way for the introduction/extension
of tariffs that could prove inflationary whilst the same could be said of further tax cuts
and an expansion of the current US budget deficit.  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 abound in Europe, the Middle East
and Asia. 
The MPC voted by 7-2 on 6 February 2025 to cut the Bank of England’s base rate by
0.25% to 4.50%.  However, the other two votes were for base rate to be cut by 0.50%
which is a very dovish outlook – with the prospect that yields will now fall. 
A more detailed interest rate view and economic commentary is provided at
appendix 5.1. 
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3.4 Borrowing strategy 
Borrowing is undertaken to finance the Council’s approved Capital plans and to do so
in the most cost-effective way.  As can been noted from Table 4 above the Council has
a significant borrowing requirement across the current and forthcoming four financial
years (2024/25 to 2028/29). 
This TMIS provides for this capital investment to be underpinned by long-term
borrowing, recognising the current interest rate environment, the significant borrowing
requirement arising from the Council’s capital plans, and the long term benefits of de
risking the delivery and affordability of these capital plans by locking into the certainty
brought by PWLB fixed rate loans. 
The Council’s external loan debt at 31 March 2025 is projected to be £394.445
million.  Based on the Council’s historic and current approved Capital Plans, the
Underlying Borrowing Requirement (UBR) – which is the Council’s underlying need
to borrow for capital purposes (excluding the long-term liability arising from PFI/DBFM
projects) – at 31 March 2025 is expected to equate to £479.787 million. 
This means that the Council is expected to be £85.342 million (18%) under-
borrowed at the end of the 2024/25 financial year i.e. the Council has funded the
majority (82%) of its underlying borrowing requirement as at 31 March 2025.  In the
current economic climate, this is a prudent approach which balances (a) de-risking the
longer term borrowing requirement at current longer term borrowing rates; against (b)
the current year and forthcoming financial year budget projections.  The Council has a
relatively low short-medium term exposure to refinancing risk and is therefore in a
strong position to plan its new borrowing requirements in advance, taking advantage of
any dips in longer-term borrowing rates from PWLB and other sources, and maintain a
low weighted average coupon rate on external debt.   
The Underlying Borrowing Requirement is projected to rise to £855.191 million by
31 March 2029 – more than double the current external debt portfolio value.  The
profile of this, and the projected external loan portfolio to fund the Underlying
Borrowing Requirement over the period 2024/25 to 2028/29, is shown in graphical
format below. 
Figure 3: Loan Portfolio & Underlying Borrowing Requirement 
Interest Rates
The current PWLB yield curve is bell shaped with the low point in the curve at the 3
year mark (4.90%; certainty rate) with rates trending upwards towards the 20-30 year
tenor (high point of 5.86%) before easing back slightly to sit at c. 5.55% in the 50 year
duration. 
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Current PWLB rates have generally increased by c. 50bps across the entire curve
from levels reported at the time of the 2024/25 TMIS to Council in February 2024, and
have shifted upwards by 25-35bps across the medium to long part of the curve since
the TM Mid Year Review Report to Council in December 2024 whilst holding fairly
steady at the very short (up to 7 year) range. 
The yield curve is expected to remain bell shaped over the short-medium term, with a
gradual shift downwards of the entire curve by c. 40bps over the next 12 months, a
further 40bps over the subsequent 12 months and a further 20bps over the following
12 months of the forecast period (so 100bps total). 
This is forecast to bring longer-term borrowing rates down from between 5.30%-
5.50%, to between:- 
• 4.90%-5.10% by March 2026;
• 4.50%-4.70% by March 2027; and
• 4.30%-4.50% by March 2028. 
The Interest Rate Forecast from the Council’s Treasury Advisers, MUFG Corporate
Markets, is shown in Table 5 below, with Further commentary on this is provided in
Appendix 3 Section 3.3. 
Table 5: MUFG Interest Rate Forecasts 
The funding of the Council’s in-year and forward CFR is typically for infrastructure with
long asset lives (50-60 years), and the tenor of PWLB and market loans are typically
drawn with this in mind. 
Borrowing Strategy
Consideration for any new borrowing in the remainder of the 2024/25 financial year
and during the 2025/26 financial year, to fund the Council’s in-year CFR, will seek to
balance:- 
a) the security/certainty of current relatively high longer-term borrowing rates
of upwards of 5.30% in the 30-50 year duration (which are forecast to
drop by 40bps within one year and a total of 80bps within 24 months) and
the potential additional budgetary pressure that this brings in both the
short/medium and longer term; with 
b) the option to borrow initially for a shorter-term duration from PWLB or
other markets, for 3 to 5 years (at say c. 4.50% at the HRA rate), to allow
the Council to fund the immediate in-year borrowing requirement.  Based
on current interest rate forecasts (see Appendix 3 Section 3.3), this would
then allow the Council the option to refinance this borrowing at initial 3-5
year maturity with less expensive, longer term borrowing, e.g. a 45 to 47
year tenor in, say, 36 months at a forecast rate of c. 4.30%. 
As noted in Section 3.1 of the main body of this report, the Council’s proactive
Treasury Management over the last decade has put the Council in a strong refinancing
MUFG Corporate Markets Interest Rate View
Mar-25 Jun-25 Sep-25 Dec-25 Mar-26 Jun-26 Sep-26 Dec-26 Mar-27 Jun-27 Sep-27 Dec-27
BANK RATE 4.50 4.25 4.00 4.00 3.75 3.75 3.75 3.50 3.50 3.50 3.50 3.50
3 month average earnings 4.50 4.30 4.00 4.00 4.00 3.80 3.80 3.80 3.50 3.50 3.50 3.50
6 month average earnings 4.40 4.20 3.90 3.90 3.90 3.80 3.80 3.80 3.50 3.50 3.50 3.50
12 month average earnings 4.40 4.20 3.90 3.90 3.80 3.80 3.80 3.80 3.50 3.50 3.50 3.50
5 year PWLB 4.90 4.80 4.60 4.50 4.50 4.40 4.30 4.20 4.10 4.00 4.00 3.90
10 year PWLB 5.10 5.00 4.80 4.80 4.70 4.50 4.50 4.40 4.30 4.20 4.20 4.10
25 year PWLB 5.50 5.40 5.30 5.20 5.10 5.00 4.90 4.80 4.70 4.60 4.50 4.50
50 year PWLB 5.30 5.20 5.10 5.00 4.90 4.80 4.70 4.60 4.50 4.40 4.30 4.30
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position for its external debt portfolio which allows the Council to slot in shorter dated
external borrowing into the current debt maturity profile to fund the current &
forthcoming in-year borrowing requirements, to allow the Council to navigate past the
current expected hump in longer-term borrowing rates. 
It is expected that any further long-term borrowing that is undertaken during 2024/25
and 2025/26 to finance the current & future year capital plans will be sourced by
drawing new PWLB loans at the Certainty Rate (which has been available to the
Council since 2012 and is priced at Gilts+80bps), and/or the HRA rate.  The HRA rate
is available to all Councils to fund HRA capital expenditure, at a rate that is priced at
Gilts+40bps.  In the UK Budget in October 2024, the availability over which Councils
can draw HRA rate borrowing from PWLB was extended to 31 March 2026. 
Both the General Services and HRA capital programmes are being kept under regular
review due to the effects of inflationary pressures, shortages of materials and labour,
and the ratios of financing costs to the net revenue streams.  The Council’s borrowing
strategy will, therefore, also be regularly reviewed and then revised, if necessary, to
achieve optimum value and risk exposure in the medium-long-term.  The impact
particularly of the General Services Capital Plan Prioritisation – which is also reported
to Council on today’s agenda – will have a bearing on this. 
Appendix 3 Section 3.3 provides forecasts for interest rates from the Council’s
Treasury Management advisor, MUFG Corporate Markets.  Council officers, in
conjunction with MUFG, will continue to monitor daily long-term borrowing rates in
order to take advantage of any dips in the market or to de-risk any change in the
medium-longer term forecast for gilt yields. 
Forward Borrowing
The opportunity also continues to exist to consider further loans on a ‘forward dealing’
basis, and officers will continue to explore the viability of these loans as part of
securing the long term borrowing required to meet the Council’s Underlying Borrowing
Requirement. 
Treasury management limits on activity
There are three debt related treasury activity limits.  The purpose of these are to
restrain the activity of the treasury function within certain limits, thereby managing
risk and reducing the impact of any adverse movement in interest rates.  However,
if these are set to be too restrictive they will impair the opportunities to reduce costs
/ improve performance.  The indicators are:
• Upper limits on variable interest rate exposure. This identifies a
maximum limit for variable interest rates for borrowing based upon the
gross debt position, and variable interest rates for investments based
upon the total investment position;
• Upper limits on fixed interest rate exposure.  This is similar to the
previous indicator and covers a maximum limit on fixed interest rates
for both borrowing and investments;
• Maturity structure of borrowing. These gross limits are set to reduce the
Council’s exposure to large fixed rate sums falling due for refinancing,
and are required for upper and lower limits.  
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The Council is asked to approve the following treasury indicators and limits: 
Limits on fixed interest rates based on gross debt 100.00%
Limits on variable interest rates based on gross debt 30.00%
Limits on fixed interest rates based on investments 100.00%
Limits on variable interest rates based on investments 100.00%
Upper Limits on Exposure to Fixed and Variable Interest Rates 2025/26
Interest rate exposures Upper
Limit
Maturity structure of fixed interest rate borrowing 2025/26 Lower Upper
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
Maturity structure of variable interest rate borrowing 2025/26 Lower Upper
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
30 years to 40 years
Under 12 months
12 months to 2 years
50 years and above
40 years to 50 years
Maturity Structure of Borrowing 2025/26
5 years to 10 years
10 years to 20 years
20 years to 30 years
30 years to 40 years
40 years to 50 years
50 years and above
Under 12 months
12 months to 2 years
2 years to 5 years
2 years to 5 years
5 years to 10 years
10 years to 20 years
20 years to 30 years
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3.5 Policy on borrowing in advance of need
The Council will not borrow more than or in advance of its needs purely in order to profit
from the investment of the extra sum borrowed.  Any decision to borrow in advance will be
within forward approved Capital Financing Requirement estimates (as detailed in Section
3.2) and will be considered carefully to ensure that value for money can be demonstrated
and that the Council can ensure the security of such funds. 
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. 
3.6 Debt rescheduling
As noted in the Mid-Year Review Report, now that the whole of the yield curve has shifted
higher there may be opportunities for debt rescheduling in the remainder of the financial
year. 
This would involve the Council repaying loans prematurely (both market and PWLB) whilst
high discount rates on premature repayment prevail. 
Any debt rescheduling will be considered when the difference between the refinancing rate
and the redemption rate is most advantageous and the situation will be continually
monitored in order to take advantage of any perceived anomalies in the yield curve.  The
reasons for any rescheduling taking place would include: 
- the generation of cash savings at minimum risk;
- to reduce the average interest rate;
- to amend the maturity profile and/or the balance of volatility of the debt
portfolio. 
Council officers will explore debt rescheduling opportunities with MUFG Corporate Markets;
with only prudent and affordable debt rescheduling that considers both the short and
medium-longer term impact being considered. 
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4 ANNUAL INVESTMENT STRATEGY
4.1 Investment policy
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 the Public Services: Code of Practice and
Cross Sectoral Guidance Notes 2021 (“the Code”);
• CIPFA Treasury Management Guidance Notes 2021 
The Council’s investment priorities will be security first, portfolio liquidity second and then
yield, (return).  The Council will aim to achieve the optimum return (yield) on its investments
commensurate with proper levels of security and liquidity and with the Council’s risk
appetite. 
In the current economic climate, it is considered appropriate to maintain a degree of liquidity
to cover cash flow needs but to also consider “laddering” investments for periods up to 12
months with high credit rated financial institutions as we move down the interest rate yield
curve. 
The above regulations and guidance place 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. The Council applies minimum acceptable credit criteria in order to generate
a list of highly creditworthy counterparties which 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. 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 this end the Council will engage with
its advisors to maintain a monitor on market pricing such as “credit default
swaps” and overlay that information on top of the credit ratings. 
3. Other information sources used will include the financial press, share price
and other such information pertaining to the banking sector in order to establish
the most robust scrutiny process on the suitability of potential investment
counterparties. 
4. This authority has defined the list of types of investment instruments that are
permitted investments authorised for use in appendix 5.2.  Appendix 5.3
expands on the risks involved in each type of investment and the mitigating
controls. 
5. Lending limits, (maturity tenors), for each counterparty will be set through
applying the matrix table in Section 4.2 (maturity durations). 
6. Investments will only placed with counterparties from countries with a specified
minimum sovereign rating, (see paragraph 4.3). 
7. Lending per Country and Institution will be set through the application of the
criteria in Section 4.3 (amounts). 
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8. Transaction limits are set for each type of investment in appendix 5.2. 
9. This authority will set a limit for the amount of its investments which are invested
for longer than 365 days, (see paragraph 4.4). 
10. This authority has engaged external consultants, (see paragraph 1.5), to
provide expert advice on how to optimise an appropriate balance of security,
liquidity and yield, given the risk appetite of this authority in the context of the
expected level of cash balances and need for liquidity throughout the year. 
11. All investments will be denominated in sterling. 
However, this authority will also pursue value for money in treasury management and will
monitor the yield from investment income against appropriate benchmarks for investment
performance, (see paragraph 4.5). Regular monitoring of investment performance will be
carried out during the year.  
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4.2 Creditworthiness policy
This Council applies the creditworthiness service provided by MUFG Corporate Markets. 
This service employs a sophisticated modelling approach utilising credit ratings from the
three main credit rating agencies - Fitch, Moody’s and Standard and Poor’s.  The credit
ratings of counterparties are supplemented with the following overlays:- 
• credit watches and credit outlooks from credit rating agencies;
• CDS spreads to give early warning of likely changes in credit ratings;
• sovereign ratings to select counterparties from only the most creditworthy countries. 
This modelling approach combines credit ratings, credit watches and credit outlooks in a
weighted scoring system which is then combined with an overlay of CDS spreads for which
the end product is a series of colour coded bands which indicate the relative
creditworthiness of counterparties.  These colour codes are used by the Council to
determine the suggested duration for investments.   The Council will therefore use
counterparties within the following durational bands:- 
Note that the maximum suggested durations listed above have been extended by 1 year
(when compared to the suggested maximum durations provided by Link) for the Yellow,
Dark Pink, Light Pink, Purple, Blue and Orange categories, to allow flexibility around these
durations on the margins e.g. the placement of a 13 month fixed term deposit for a
counterparty rated Orange or Blue.  Equally, the maximum suggested duration for the Red
category has been extended by a month to 8 months, on the same basis.  A thorough
appraisal of the additional risk involved in extending the duration of any deposit (marginally)
beyond the maximum suggested by Capita, against any enhanced value to the portfolio,
will be undertaken prior to the placement of any deposit. 
The MUFG Corporate Markets creditworthiness service uses a wider array of information
than just primary ratings.  Furthermore, by using a risk weighted scoring system, it does not
give undue preponderance to just one agency’s ratings. 
Link Asset
Services
Colour Code
Maximum
Suggested
Duration for
Investment
Yellow 6 years*
Dark Pink 6 years**
Light Pink 6 years**
Purple 2.5 years
Blue 1.25 years***
Orange 1.25 years
Red 7 months
Green 120 days
No colour Not to be used
* Note the yellow colour category is for:- UK Government Debt, or its equivalent,  
Money Market Funds (MMF's), and collateralised deposits where
the collateral is UK Government Debt
** Dark Pink for Ultra Short Dated Bond Funds with a credit score of 1.25
Light Pink for Ultra Short Dated Bond Funds with a credit score of 1.5
*** Applies only to nationalised or semi-nationalised UK Banks
Table 14: Recommended Maximum
Durations for Investments
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Typically the minimum credit ratings criteria the Council use will be (Fitch or equivalents):- 
• Short term rating F1;
• Long term rating A-. 
There may be occasions when the counterparty ratings from one rating agency are
marginally lower than these ratings but may still be used.  In these instances consideration
will be given to the whole range of ratings available, or other topical market information, to
support their use. 
All credit ratings will be monitored weekly.  The Council is alerted to changes to ratings of
all three agencies through its use of the MUFG Corporate Markets creditworthiness service. 
• if a downgrade results in the counterparty / investment scheme no longer meeting
the Council’s minimum criteria, its further use as a new investment will be withdrawn
immediately;
• in addition to the use of credit ratings the Council will be advised of information in
movements in credit default swap spreads against the iTraxx benchmark and other
market data on a daily basis via its Passport website, provided exclusively to the
Council by MUFG Corporate Markets. Extreme market movements may result in
downgrade of an institution or removal from the Council’s lending list. 
Sole reliance will not be placed on the use of this external service.  In addition this Council
will also use market data and market information, information on sovereign support for
banks and the credit ratings of that supporting government.
UK banks – ring fencing
The largest UK banks, (those with more than £25bn of retail / Small and Medium-sized
Enterprise (SME) deposits), are required, by UK law, to separate core retail banking
services from their investment and international banking activities by 1st January 2019. This
is known as “ring-fencing”. Whilst smaller banks with less than £25bn in deposits are
exempt, they can choose to opt up. Several banks are very close to the threshold already
and so may come into scope in the future regardless.
Ring-fencing is a regulatory initiative created in response to the global financial crisis. It
mandates the separation of retail and SME deposits from investment banking, in order to
improve the resilience and resolvability of banks by changing their structure. In general,
simpler, activities offered from within a ring-fenced bank, (RFB), will be focused on lower
risk, day-to-day core transactions, whilst more complex and “riskier” activities are required
to be housed in a separate entity, a non-ring-fenced bank, (NRFB). This is intended to
ensure that an entity’s core activities are not adversely affected by the acts or omissions of
other members of its group.
While the structure of the banks included within this process may have changed, the
fundamentals of credit assessment have not. The Council will continue to assess the new-
formed entities in the same way that it does others and those with sufficiently high ratings,
(and any other metrics considered), will be considered for investment purposes.
4.3 Country and sector limits
The Council has determined that it will only use approved counterparties from the UK, or
approved counterparties from other countries with a minimum sovereign credit rating of AA-
from Fitch.
The list of countries that qualify using the above criteria as at the date of this report are
shown in Appendix 5.4.  This list will be added to, or deducted from, by officers should
ratings change in accordance with this policy.
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The Council will avoid a concentration of investments in too few counterparties or countries
by adopting a spreading approach to investing whereby no more than £30 million will be
invested in Lloyds Banking Group and the NatWest (Royal Bank of Scotland) Group, £15
million in any other UK counterparty, and £15 million in any one counterparty, group or
country outwith the UK.
4.4 Investment strategy
Current Deposits 
As at 31 January 2025, the Council’s deposits were as follows:- 
Counterparty Amount
£000’s
Security
Long/Short
Term Rating*
(Colour)**
Liquidity Yield UK Local
Authority
Investment***
£000’s
MMF
Aberdeen 11,913 AAAmmf
(Yellow) Instant Access 4.69% 1,425,558
MMF
Federated 485 AAAmmf
(Yellow) Instant Access 4.72% 978,210
MMF
LGIM 11,356 AAAmmf
(Yellow) Instant Access 4.73% 502,695
Bank of Scotland
Call Account 1,635 A+/F1+
(Orange) Instant Access 4.62% 162,411
Handelsbanken AB
Call Account 19 AA-/F1+
(Orange) Instant Access 4.59% 145,084
National Westminster
Bank plc 20,000 A+/F1
(Red)
Start: 27 Mar 2024
End: 27 Mar 2025 5.06% 418,175
Total 45,408    3,632,133 
* Credit Rating from Fitch
** Colour represents maximum recommended duration for investment per MUFG Corporate Markets
Credit Scoring methodology – see Appendix 2.
*** As at 31 December 2024 
In-house funds. 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, with the yield curve reducing the further out deposits are placed). 
While an element of 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. 
• If it is thought that Bank Rate is likely to fall within that time period,
consideration will be given to locking in higher rates currently obtainable, for
longer periods, where this is possible within the Council’s day-to-day and
monthly cashflow projections;
• Conversely, if it is thought that Bank Rate is likely to rise significantly within
the time horizon being considered (unlikely in the current climate), then
consideration will be given to keeping most investments as being short term
or variable. 
Investment returns expectations
The current forecast shown in paragraph 3.3, includes a forecast for Bank Rate to reduce
from the current level of 4.50% at the time of writing (3 February 2025) to 3.50% by the end
of the forecast time horizon (December 2027). 
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: - 
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Average earnings in
each year 
2024/25 (residual) 4.60%
2025/26 4.10%
2026/27 3.70%
2027/28 3.50%
2028/29 3.50%
Long term later years 3.50% 
As there are so many variables at this time, caution must be exercised in respect of all
interest rate forecasts.
Investment treasury indicator and limit - total principal funds invested for greater than
365 days. These limits are set with regard to the Council’s liquidity requirements and
expected usable reserve forecasts, and are based on the availability of funds after each
year-end. 
The Council is asked to retain the following treasury indicator and limit: - 
For its cash flow generated balances, the Council will seek to utilise its business reserve
instant access accounts and money market funds.
4.5 Investment risk benchmarking
The Council will use an investment benchmark to assess the investment performance of its
investment portfolio of 6 month SONIA compounded.  The Council also participates in
Investment Benchmarking groups with MUFG Corporate Markets whereby performance
with other Benchmarking club members and the wider Scottish and UK Local Authority
Investment benchmarking is compared. 
4.6 End of year investment report
At the end of the financial year, the Council will report on its investment activity as part of
its Annual Treasury Report.
Limit £70m
Principal Sums Invested for > 365 Days
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5 Appendices 
1. Economic background
2. Treasury Management Practice 1 – Permitted Investments
3. Treasury Management Practice 1 – Credit and Counterparty Risk Management
4. Approved countries for investments
5. Treasury management scheme of delegation
6. The treasury management role of the section 95 officer 
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5.1 APPENDIX: Economic Background
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. 
Reflecting on the 30 October Budget, MUFG’s 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 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 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
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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. 
Focussing on borrowing, a term that is likely to be prevalent 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 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. 
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, further rate reductions and their timing will very much be determined by
Trump’s policy announcements and their implications for both inflation and Treasury
issuance. 
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 2024, 20 June 2024, 1 August 2024, 19 September 2024, 7
November 2024, 6 February 2025 
• On 9 May 2024, 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
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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 2024, 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.  
• On 6 February 2025, the MPC voted by 7-2 to cut base rate by 0.25% to
4.50%.  However, the other two votes were for base rate to be cut by
0.50% which is a very dovish outlook – with the prospect that yields will
now fall. 
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5.2 APPENDIX: Treasury Management Practice (TMP1): Permitted Investments 
This Council is asked to approve the following forms of investment instrument for use as
permitted investments as set out in tables 1.1-1.4. 
Treasury risks
All the investment instruments in tables 1.1-1.4 are subject to the following risks:- 
1. Credit and counter-party 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 capital or current (revenue) resources.
There are no counterparties where this risk is zero although AAA rated
organisations have the highest, relative, level of creditworthiness. 
2. Liquidity risk: this is the risk that cash will not be available when it is needed.  
While it could be said that all counterparties are subject to at least a very small level
of liquidity risk as credit risk can never be zero, in this document, liquidity risk has
been treated as whether or not instant access to cash can be obtained from each
form of investment instrument.  However, it has to be pointed out that while some
forms of investment e.g. gilts, CDs, corporate bonds can usually be sold
immediately if the need arises, there are two caveats: - a.  cash may not be available
until a settlement date up to three days after the sale  b.  there is an implied
assumption that markets will not freeze up and so the instrument in question will
find a ready buyer.  The column in tables 1.1-1.4 headed as ‘market risk’ will show
each investment instrument as being instant access, sale T+3 = transaction date
plus 3 business days before you get cash, or term i.e. money is locked in until an
agreed maturity date. 
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, some cash rich local authorities may
positively want exposure to market risk e.g. those investing in investment
instruments 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 its Treasury Indicators in this report (see
Section 3.4). 
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.   
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Controls on treasury risks
1. Credit and counter-party risk: this authority has set minimum credit criteria to
determine which counterparties and countries are of sufficiently high
creditworthiness to be considered for investment purposes.  See Sections 4.2 and
4.3. 
2. Liquidity risk: this authority 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: this authority does not purchase investment instruments which are
subject to market risk in terms of fluctuation in their value. 
4. Interest rate risk: this authority manages this risk by having a view of the future
course of interest rates and then formulating a treasury management strategy
accordingly which aims to maximise investment earnings consistent with control of
risk or alternatively, seeks to minimise expenditure on interest costs on borrowing. 
See Section 4.4. 
5. Legal and regulatory risk: this authority will not undertake any form of investing
until it has ensured that it has all 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 investment 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 credit worthiness banks and building societies.  See paragraph 4.2
for an explanation of this authority’s definition of high credit worthiness.  While
an unlimited amount of the investment portfolio may be put into banks and
building societies with high credit worthiness, the authority will ensure
diversification of its portfolio ensuring that no more than £15 million can be
placed with any one institution or group at any one time, other than the Bank
of Scotland or Royal Bank of Scotland where the limit is £30 million. 
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Objectives of each type of investment instrument
Regulation 25 requires an explanation of the objectives of every type of investment
instrument which an authority approves as being ‘permitted’.
1. DEPOSITS
The following forms of ‘investments’ are actually more accurately called deposits as cash
is deposited in an account until an agreed maturity date or is held at call. 
a) Debt Management Agency Deposit Facility.  This offers the lowest risk form of
investment available to local authorities as it is effectively an investment placed with the
Government.  It is also easy to use as it is a deposit account and avoids the
complications of buying and holding Government issued treasury bills or gilts.  As it is
low risk it also earns low rates of interest.  However, it is very useful for authorities
whose overriding priority is the avoidance of risk.  The longest period for a term deposit
with the DMADF is 6 months. 
b) Term Deposits – Local Authorities.  They are quasi-Government bodies with low
counterparty and value risk.  Typical deposit terms vary from 1 month to 2 years, with
longer term deposits offering an opportunity to increase investment returns by locking
in high rates ahead of an expected fall in the level of interest rates.  At other times,
longer term rates can offer good value when the markets incorrectly assess the speed
and timing of interest rate increases.  This form of investing therefore, offers a lot of
flexibility and typically higher earnings than the DMADF.  Where it is restricted is that
once a longer term investment is made, that cash is locked in until the maturity date
other than with agreement of the counterparty, at which point penalties would typically
apply.
c) Call accounts with high credit worthiness banks and building societies.  See
Section 4.2 for an explanation of this authority’s definition of high credit worthiness. 
These typically offer a much higher rate of return than the DMADF and now that
measures have been put in place to avoid over reliance on credit ratings, the authority
feels much more confident that the residual risks around using such banks and building
societies are at a low, reasonable and acceptable level. There is instant access to
recalling cash deposited (or short-dated notice e.g. 15-30 days).  This generally means
accepting a lower rate of interest than that which could be earned from the same
institution by making a term deposit (see 1d below).  However, there are a number of
call accounts which at the time of writing, offer rates 2 – 3 times more than term deposits
with the DMADF.  Some use of call accounts is highly desirable to ensure that the
authority has ready access to cash when needed to pay bills. 
d) Term deposits with high credit worthiness banks and building societies.  The
objectives are as for 1c.  These offer a much higher rate of return than the DMADF and
deposits made with other Local Authorities (dependent upon term) and, similar to 1c,
now that measures have been put in place to avoid over reliance on credit ratings, the
authority feels much more confident that the residual risks around using such banks
and building societies are at a low, reasonable and acceptable level.  This is the most
widely used form of investing used by local authorities.  The authority will ensure
diversification of its portfolio of deposits ensuring that no more than £15 million is
invested with any (non-nationalised) UK counterparty, and no more than £15 million is
invested with any other non-UK counterparty, group or country.  In addition, longer term
deposits offer an opportunity to increase investment returns by locking in high rates
ahead of an expected fall in the level of interest rates.  At other times, longer term rates
can offer good value when the markets incorrectly assess the speed and timing of
interest rate increases.  This form of investing therefore, offers a lot of flexibility and
higher earnings than the DMADF.  Where it is restricted is that once a longer term
investment is made, that cash is locked in until the maturity date. 
e) Fixed term deposits with variable rate and variable maturities (structured
deposits).  This encompasses ALL types of structured deposits.  There has been
considerable change in the types of structured deposits brought to the market over the
last few years, some of which are already no longer available.  In view of the fluidity of
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this area, this is a generic title for all structured deposits so as to provide councils with
greater flexibility to adopt new instruments as and when they are brought to the market. 
This line encompasses ALL types of structured deposits.  There has been considerable
change in the types of structured deposits brought to the market over the last few years,
some of which are already no longer available.  In view of the fluidity of this area, this is
a generic title for all structured deposits so as to provide greater flexibility to adopt new
instruments as and when they are brought to the market.
2. DEPOSITS WITH COUNTERPARTIES CURRENTLY IN RECEIPT OF UK
GOVERNMENT SUPPORT / OWNERSHIP
These banks offer another dimension of creditworthiness in terms of UK Government
backing through either direct (partial or full) ownership.  The view of this authority is that
such backing makes these banks attractive institutions with whom to place deposits, and
that will remain our view if the UK sovereign rating were to be downgraded in the coming
year. 
a. Call accounts.  As for 1c. but UK Government stated support implies that the UK
Government stands behind these banks and building societies and will be deeply
committed to providing whatever support that may be required to ensure the
continuity of such institutions.  This authority feels this indicates a low and
acceptable level of residual risk. 
b. Term deposits with high credit worthiness banks which are fully or semi
nationalised. As for 1d. but Government ownership partial or full implies that the UK
Government stands behind this bank and will be deeply committed to providing
whatever support that may be required to ensure the continuity of that bank.  This
authority considers   this indicates a low and acceptable level of residual risk. 
c. Fixed term deposits with variable rate and variable maturities (structured
deposits).  As for 1e but UK Government stated support implies that the UK
Government stands behind eligible banks and building societies and will be deeply
committed to providing whatever support that may be required to ensure the continuity
of such institutions.  This authority feels this indicates a low and acceptable level of
residual risk.  This line encompasses ALL types of structured deposits.  There has been
considerable change in the types of structured deposits brought to the market over the
last few years, some of which are already no longer available.  In view of the fluidity of
this area, this is a generic title for all structured deposits so as to provide greater
flexibility to adopt new instruments as and when they are brought to the market.  
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3. COLLECTIVE INVESTMENT SCHEMES STRUCTURED AS OPEN ENDED
INVESTMENT COMPANIES (OEICS)
a. Government liquidity funds.  These are the same as money market funds (see
below) but only invest in government debt issuance with highly rated governments.  Due
to the higher quality of underlying investments, they offer a lower rate of return than
MMFs.  However, their net return is typically on a par with the DMADF, but with instant
access. 
b. Money Market Funds (MMFs).  By definition, MMFs are AAA rated and are widely
diversified, using many forms of money market securities including types which this
authority does not currently have the expertise or capabilities to hold directly.  However,
due to the high level of expertise of the fund managers and the huge amounts of money
invested in MMFs, and the fact that the weighted average maturity (WAM) cannot
exceed 60 days, MMFs offer a combination of high security, instant access to funds,
high diversification and good rates of return compared to equivalent instant access
facilities. They are particularly advantageous in falling interest rate environments as
their 60 day WAM means they have locked in investments earning higher rates of
interest than are currently available in the market.  MMFs also help an authority to
diversify its own portfolio as e.g. a £2m investment placed directly with HSBC is a 100%
risk exposure to HSBC whereas £2m invested in a MMF may end up with say £10,000
being invested with HSBC through the MMF.  For authorities particularly concerned
with risk exposure to banks, MMFs offer an effective way of minimising risk exposure
while still getting much better rates of return than available through the DMADF. 
c. Ultra Short Dated Bond Funds .  These funds are similar to MMFs, can still be AAA
rated but have Variable Net Asset Values (VNAV) as opposed to a traditional MMF
which has a Constant Net Asset Value (CNAV). They aim to achieve a higher yield and
to do this either take more credit risk or invest out for longer periods of time, which
means they are more volatile. These funds can have WAM’s and Weighted Average
Life (WAL’s) of 90 – 365 days or even longer. Their primary objective is yield and capital
preservation is second.  They therefore are a higher risk than MMFs and
correspondingly have the potential to earn higher returns than MMFs. 
d. Gilt funds.  These are funds which invest only in U.K. Government gilts.  They offer a
lower rate of return than bond funds but are highly rated both as a fund and through
investing only in highly rated government securities.  They offer a higher rate of return
than investing in the DMADF but they do have an exposure to movements in market
prices of assets held. 
e. Bond funds.  These can invest in both government and corporate bonds.  This
therefore entails a higher level of risk exposure than gilt funds and the aim is to achieve
a higher rate of return than normally available from gilt funds by trading in non-
government bonds.    
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4.  SECURITIES ISSUED OR GUARANTEED BY GOVERNMENTS 
The following types of investments are where an authority directly purchases a particular
investment instrument, a security, i.e. it has a market price when purchased and that value
can change during the period the instrument is held until it matures or is sold.  The annual
earnings on a security is called a yield i.e. it is normally the interest paid by the issuer divided
by the price you paid to purchase the security unless a security is initially issued at a
discount e.g. treasury bills..   
a. Treasury bills.  These are short term bills (up to 12 months, although none have
ever been issued for this maturity) issued by the Government and so are backed
by the sovereign rating of the UK.  The yield is higher than the rate of interest paid
by the DMADF and another advantage compared to a time deposit in the DMADF
is that they can be sold if there is a need for access to cash at any point in time. 
However, there is a spread between purchase and sale prices so early sales could
incur a net cost during the period of ownership. 
b. Gilts.  These are longer term debt issuance by the UK Government and are backed by
the sovereign rating of the UK. The yield is higher than the rate of interest paid by the
DMADF and another advantage compared to a time deposit in the DMADF is that they
can be sold if there is a need for access to cash at any point in time.  However, there is
a spread between purchase and sale prices so early sales may incur a net cost. Market
movements that occur between purchase and sale may also have an adverse impact
on proceeds. The advantage over Treasury bills is that they generally offer higher yields
the longer it is to maturity (for most periods) if the yield curve is positive. 
c. Bond issuance issued by a financial institution which is explicitly guaranteed by
the UK Government e.g. National Rail.  This is similar to a gilt due to the explicit
Government guarantee. 
d. Sovereign bond issues (other than the UK govt) denominated in Sterling.  As for
gilts but issued by other nations.  Use limited to issues of nations with at least the same
sovereign rating as for the UK. 
e. Bonds issued by Multi Lateral Development Banks (MLDBs).  These are similar to
c. and e. above but are issued by MLDBs which are typically guaranteed by a group of
sovereign states e.g. European Bank for Reconstruction and Development.
5.  SECURITIES ISSUED BY CORPORATE ORGANISATIONS 
The following types of investments are where an authority directly purchases a particular
investment instrument, a security, i.e. it has a market price when purchased and that value
can change during the period the instrument is held until it is sold.  The annual earnings on
a security is called a yield i.e. is the interest paid by the issuer divided by the price you paid
to purchase the security.  These are similar to the previous category but corporate
organisations can have a wide variety of credit worthiness so it is essential for local
authorities to only select the organisations with the highest levels of credit worthiness. 
Corporate securities are generally a higher risk than government debt issuance and so earn
higher yields. 
a. Certificates of deposit (CDs).  These are shorter term securities issued by deposit
taking institutions (mainly financial institutions). They are negotiable instruments, so can
be sold ahead of maturity and also purchased after they have been issued.  However,
that liquidity can come at a price, where the yield could be marginally less than placing
a deposit with the same bank as the issuing bank. 
b. Commercial paper.  This is similar to CDs but is issued by commercial
organisations or other entities.  Maturity periods are up to 365 days but commonly
90 days.  
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c. Corporate bonds.  These are (long term) bonds (usually bearing a fixed rate of
interest) issued by a financial institution, company or other non-government issuer
in order to raise capital for the institution as an alternative to issuing shares or
borrowing from banks.  They are generally seen to be of a lower creditworthiness
than government issued debt and so usually offer higher rates of yield. 
d. Floating rate notes.  These are bonds on which the rate of interest is established
periodically with reference to short-term interest rates.  
6.  OTHER
a. Local Authority Mortgage Scheme.  Authorities who are participating in the Local
Authority Mortgage Guarantee Scheme (LAMS) may be required to place a deposit
with the mortgage provider(s) up to the full value of the guarantee.  The deposit will
be in place for the term of the guarantee i.e. 5 years (with the possibility of a further
2 year extension if the account is 90+ days in arrears at the end of the initial 5
years) - and may have conditions / structures attached.  The mortgage provider will
not hold a legal charge over the deposit.
b. Loans to third parties – This would involve the Council borrowing from the
PWLB/markets and onward lending to Registered Social Landlords to enable them
to access lower cost loans and kickstart developments of affordable mid-market
homes.  The risk associated with such an investment would be mitigated by an
assessment of the counterparty in advance of any loan being granted and through
the application of a premium on the loan rate.  Interest would be paid by the RSL
over the term of the loan, with repayment of principal upon the earlier of 10/20
years or at the point of house sales.  The Council will also request that a standard
security is taken over the property which would allow the Council to require the sale
of the homes to another landlord, providing greater risk mitigation.
c. Subordinated Debt Subscription to the SPV set up to deliver the Newbattle
Centre project – this involved the Council subscribing £332,806 of subordinated
debt to the SPV that was set up to deliver the Newbattle Centre project (2 year
construction and 25 year operational contract length). The length of the investment
is 25 years with the subscription made at operation commencement of the contract. 
The repayment profile will comprise 81% of the principal remaining invested until
the final two years of the contract. The risk associated with this type of investment
will be mitigated through an annual assessment as a minimum to review the holding
of such debt, and whether the exposure to risk arising from the investment has
changed over the period.
d. ESCO: Midlothian Energy Limited (MEL) Joint Venture between Midlothian Council
and Vattenfall to deliver energy supply to Shawfair using heat supplied from the
Millerhill Energy from Waste plant and related projects.
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Table 1: Permitted Investments 
1.1  Deposits
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m
of total
investments
Max. maturity
period
Max
Transaction
Value
Debt Management Agency
Deposit Facility
UK
Government Term No 100% 6 months n/a
Term deposits – local authorities Quasi-UK
Government Term No 100% 5 years £15m
Call accounts – banks and
building societies
Green  Instant No 100% 1 day £15m
Term deposits / Notice Accounts
– banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m 
1.2 Deposits with counterparties currently in receipt of government support / ownership
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
Max
Transaction
Value
UK nationalised banks – Call
accounts Blue Instant No 100% 1 day £30m
UK  nationalised banks – Term
Deposits / Notice Accounts Blue Term No 100% 2 years £30m
UK  nationalised banks – Fixed
term deposits with variable rate
and variable maturities: -
Structured deposits
Blue Term No 100% 2 years £30m
Non-UK (high sovereign rated
country) nationalised banks –
Call accounts
Green Instant No 100% 1 day £15m
Non-UK (high sovereign rated
country) nationalised banks:-
Term Deposits / Notice Accounts
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Non-UK (high sovereign rated
country) nationalised banks:- 
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits  
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
If forward deposits are made, the forward period plus the deal period equate to the maximum
maturity period. 
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1.3  Collective investment schemes structured as Open Ended Investment Companies
(OEICs) 
Investment Category Minimum
Credit Criteria  Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
Max
Transaction
Value
Government Liquidity Funds AAA Instant No 100% 1 day £15m
Money Market Funds CNAV AAA Instant No 100% 1 day £15m
Money Market Funds LVNAV AAA Instant No 100% 1 day £15m
Money Market Funds VNAV AAA Instant No 100% 1 day £15m
Ultra Short Dated Bond Funds
with a credit score of 1.25 AAA T+1 to
T+5 Yes 100% 1 week £15m
Ultra Short Dated Bond Funds
with a credit score of 1.5 AAA T+1 to
T+5 Yes 100% 1 week £15m
Bond Funds AAA T+2 or
longer Yes 50% 2 days £15m
Gilt Funds AAA T+2 or
longer Yes 50% 2 days £15m 
1.4 Securities issued or guaranteed by governments 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max %?£m 
of total
investments
Max. maturity
period
Treasury Bills
UK
sovereign
rating
Sale T+1 Yes 100% 6 months
UK Government Gilts
UK
sovereign
rating 
Sale T+1 Yes 100% 50 years
Bond issuance issued by a
financial institution which is
explicitly guaranteed by  the
UK Government  e.g. National
Rail
UK
sovereign
rating 
Sale T+3 Yes 100% 50 years
Sovereign bond issues (other
than the UK govt)
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years
Bonds issued by multilateral
development banks 
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years 
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1.5 Securities issued by corporate organisations 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max % 
of total
investments
Max. maturity
period
Max
Transaction
Value
Certificates of deposit issued
by banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+1 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Commercial paper other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+0 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Floating rate notes
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Corporate Bonds other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m 
1.6 Other 
Investment Category Minimum Credit
Criteria  Liquidity
risk
Market
risk 
Max %/£m 
of total
investments
Max.
maturity
period
Local authority mortgage guarantee
scheme. Blue Term No 50% 5 years
Loans to Third Parties n/a Term No £25m 20 years
Subordinated Debt Subscription to
Newbattle Centre SPV n/a Term No £0.326m 22 years
ESCO n/a Term No £10.2m n/a 
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5.3 APPENDIX: Treasury Management Practice (TMP1) – Credit and Counterparty Risk Management 
Midlothian Council Permitted Investments, Associated Controls and Limits
Type of Investment Treasury Risks Mitigating Controls Council
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.
As shown in
Appendix 5.2.
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.  Deposits can only be broken with
the agreement of the counterparty, and penalties can
apply.
Deposits with other non-local authority bodies will be
restricted to the overall credit rating criteria.
Little mitigating controls required for
local authority deposits, as this is a
quasi UK Government investment.
Non- local authority deposits will follow
the approved credit rating criteria.
As shown in
Appendix 5.2.
c. CNAV, LVNAV and
VNAV Money Market
Funds (MMFs) (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 MMF
has a “AAA” rated status from either
Fitch, Moody’s or Standard & Poors.
As shown in
Appendix 5.2.
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 Ultra
Short Dated Bond Fund has a “AAA”
rated status from either Fitch, Moody’s
or Standard and Poor’s.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
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
approved above restricts lending only to
high quality counterparties, measured
primarily by credit ratings from Fitch,
Moody’s and Standard and Poor’s, with
the credit scoring methodology by
MUFG Corporate Markets overlaid.
On day to day investment dealing with
this criteria will be further strengthened
by the use of additional market
intelligence.
As shown in
Appendix 5.2.
f. Term deposits with
financial institutions
(banks and building
societies) (Low to
medium risk
depending on period
& credit rating)
These tend to be low risk investments, but will
exhibit higher risks than categories (a), (b), (c) and
(d) above.  Whilst there is no risk to value with these
types of investments, liquidity is low and term
deposits can only be broken with the agreement of
the counterparty, and penalties may apply.  
The counterparty selection criteria
approved above restricts lending only to
high quality counterparties, measured
primarily by credit ratings from Fitch,
Moody’s and Standard and Poor’s, with
the credit scoring methodology by
MUFG Corporate Markets overlaid.
On day to day investment dealing, this
criteria will be further strengthened by
the use of additional market
intelligence.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
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
As shown in
Appendix 5.2.
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 maturity).  Liquidity
risk will normally be low.
The counterparty selection criteria approved
above restricts lending only to high quality
counterparties, measured primarily by credit
ratings from Fitch, Moody’s and Standard and
Poor’s.  The selection defaults to the lowest
available colour band / credit rating to provide
additional risk control measures.
Day to day investment dealing with this
criteria will be further strengthened by the use
of additional market intelligence.
As shown in
Appendix 5.2.
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), (c) and (d) above.  Whilst
there is no risk to value with these types of
investments, liquidity is very low and
investments can only be broken with the
agreement of the counterparty (penalties may
apply).  
The counterparty selection criteria approved
above restricts lending only to high quality
counterparties, measured primarily by credit
ratings from Fitch, Moody’s and Standard and
Poor’s, with the credit scoring methodology
by MUFG Corporate Markets overlaid.
On day to day investment dealing, this criteria
will be further strengthened by the use of
additional market intelligence.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
j. Corporate bonds (Medium to
high risk depending on
period & credit rating)
These are marketable securities issued by
financial and corporate institutions.
Counterparty risk will vary and there is risk to
value of capital loss arising from selling ahead
of maturity if combined with an adverse
movement in interest rates.  Liquidity risk will
be low.
The counterparty selection criteria
approved above restricts lending only to
high quality counterparties, measured
primarily by credit ratings from Fitch,
Moody’s and Standard and Poor’s.  The
selection defaults to the lowest
available colour band / credit rating to
provide additional risk control
measures.  Corporate bonds will be
restricted to those meeting the base
criteria.
Day to day investment dealing with this
criteria will be further strengthened by
the use of additional market
intelligence.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
Other types of investments
k. Loans to third parties Using the example of a loan to a RSL, these
would be medium risk investments, exhibiting
higher risks than categories (a)-(f) above. 
They are also highly illiquid and are only repaid
at the end of a defined period of time (up to 20
years) or on the sale of a property, whichever is
the earlier.
The risk associated with such an
investment would be mitigated through
the application of a premium on the
loan rate.  The Council will also request
that a standard security is taken over
the property which would allow the
Council to require the sale of the homes
to another landlord, providing greater
risk mitigation.
£25m
l. 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.
Per Existing
m. Local Authority Mortgage
Scheme (LAMS)
These are service investments at market rates
of interest plus a premium. 
As shown in
Appendix 5.2.
n. Subordinated Debt Subscription
to Newbattle Centre SPV
These are investments that are exposed to the
success or failure of individual projects and are
highly illiquid.
The Council and Scottish Government
(via the SFT) are participants in and
party to the governance and controls
within the project structure. As such
they are well placed to influence and
ensure the successful completion of the
project’s term.
As shown in
Appendix 5.2.
o. ESCO These are investments that are exposed to the
success or failure of individual projects and are
highly illiquid.
The Council is in a joint venture
partnership and therefore party to the
governance and controls within the
project structure. As such the Council is
As shown in
Appendix 5.2.
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46
well placed to influence and ensure the
successful completion of the project’s
term 
The Monitoring of Deposit Counterparties - The status of counterparties will be monitored regularly.  The Council receives credit rating and
market information from MUFG Corporate Markets, including when ratings change, and counterparties are checked promptly.  On occasion
ratings may be downgraded when an investment has already been made.  The criteria used are such that a minor downgrading should not
affect the full receipt of the principal and interest.  Any counterparty failing to meet the criteria will be removed from the list immediately by the
Chief Financial Officer & Section 95 Officer, and if required new counterparties which meet the criteria will be added to the list. 
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5.4 APPENDIX: Approved countries for investments 
Based on the lowest available rating as at 30.01.2025 
AAA
• Australia
• Denmark
• Germany
• Netherlands
• Norway
• Singapore
• Sweden
• Switzerland 
AA+
• Canada
• Finland
• U.S.A. 
AA
• Abu Dhabi (UAE) 
AA-
• Belgium
• France
• U.K. 
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5.5 APPENDIX: Treasury management scheme of delegation
(i) Full Council
• receiving and reviewing reports on treasury management policies, practices and
activities;
• approval of annual strategy.
• approval of/amendments to the organisation’s adopted clauses, treasury
management policy statement and treasury management practices;
• budget consideration and approval;
• approval of the division of responsibilities;
• receiving and reviewing regular monitoring reports and acting on
recommendations;
• approving the selection of external service providers and agreeing terms of
appointment. 
(iii) Audit Committee
• reviewing treasury management reports, the treasury management policy and
procedures, and making recommendations to the responsible body. 
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5.6 APPENDIX: The treasury management role of the section 95 officer
The S95 (responsible) officer
• recommending clauses, treasury management policy/practices for approval,
reviewing the same regularly, and monitoring compliance;
• submitting regular treasury management policy reports;
• submitting 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;
• 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;
o Reporting and management information (TMP6 and schedules), including
where and how often monitoring reports are taken;
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50
o Training and qualifications (TMP10 and schedules), including how the
relevant knowledge and skills in relation to non-treasury investments will
be arranged.
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Audit Committee
Monday 24 February 2025
Item No 5.4 
Internal Audit Work to January 2025 
Report by Duncan Stainbank, Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is asked to:
a) Consider the Executive Summary of the final Internal Audit assurance report issued
associated with the delivery of the approved Internal Audit Annual Plan 2024/25;
b) Note the Internal Audit Consultancy and Other Work carried out in accordance with the
approved Internal audit Charter; and
c) Acknowledge the assurance provided on internal controls and governance arrangements
in place for the areas covered by this Internal Audit work. 
2 Purpose of Report/Executive Summary 
The purpose of this report is to provide members of the Audit Committee with details of the
recent work carried out by Internal Audit and the findings and recommended audit actions
agreed by Management to improve internal controls and governance arrangements. 
The Internal Audit Annual Plan 2024/25 was approved by the Audit Committee on 18 March
2024. Internal Audit has carried out work associated with the delivery of the plan to meet its
objective of providing an opinion on the efficacy of the Council’s risk management, internal
control and governance. 
An Executive Summary of the final Internal Audit assurance report issued, including audit
objective, findings, good practice and recommendations (where appropriate), and the Chief
Internal Auditor’s independent and objective opinion on the adequacy of the control
environment and governance arrangements within each audit area, is shown in Appendix 1. 
The Internal Audit function conforms to the professional standards as set out in Public Sector
Internal Audit Standards (PSIAS) (2017) including the production of this report to
communicate the results of the reviews. 
Date 11 February 2025 
Report Contact:
Duncan Stainbank
duncan.stainbank@midlothian.gov.uk
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3 Progress Report 
3.1 The Internal Audit Annual Plan 2024/25 was approved by the Audit Committee on 18 March
2024. Internal Audit has completed the following work in the period from 1 November 2024 to
31 January 2025 associated with the delivery of the plan to meet its objective of providing an
opinion on the efficacy of the Council’s risk management, internal control and governance. 
3.2 The Internal Audit function conforms to the professional standards as set out in Public Sector
Internal Audit Standards (PSIAS) (2017), including the production of this report to
communicate the results. 
3.3 Internal Audit issued final assurance reports on the following subject:
• Business Continuity 
3.4 An Executive Summary of the final Internal Audit assurance report issued in respect of
Business Continuity including audit objective conclusions, key findings and recommendations
and areas of good practice, including the Chief Internal Auditor’s independent and objective
opinion on the adequacy of the control environment and governance arrangements within
each audit area, is shown in Appendix 1.
The definitions for Internal Audit assurance categories are as follows:
Level Definition
Substantial
Assurance
A sound system of governance, risk management and control exists, with internal controls operating
effectively and being consistently applied to support the achievement of objectives in the area audited. 
Reasonable
Assurance
There is a generally sound system of governance, risk management and control in place. Some issues,
non-compliance or scope for improvement were identified which may put at risk the achievement of
objectives in the area audited. 
Limited
Assurance
Significant gaps, weaknesses or non-compliance were identified. Improvement is required to the system
of governance, risk management and control to effectively manage risks to the achievement of objectives
in the area audited. 
No Assurance Immediate action is required to address fundamental gaps, weaknesses or non-compliance identified.
The system of governance, risk management and control is inadequate to effectively manage risks to the
achievement of objectives in the area audited. 
Internal Audit Consultancy and Other Work
3.6 Internal Audit staff have been involved in the following for the Council to meet its aims and
objectives, and its roles and responsibilities in accordance with the approved Internal Audit
Charter and Strategy:
a) In its critical friend role provided an independent view and challenge at various forums
including: Capital Plan and Asset Management Board, Chief Officers Risk & Resilience
Group, and the Integrity Group.
b) Learning and development during the research stage of new audit areas for all Internal
Audit team members and through joining virtual audit forums (Computer Audit Sub-group)
and meetings; and
c) Monitored publication of Audit Scotland reports. 
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Recommendations
3.7 Recommendations in reports are suggested changes to existing procedures or processes to
improve the controls or to introduce controls where none exist. The grading of each
recommendation reflects the risk assessment of non-implementation, being the product of the
likelihood of the risk materialising and its impact: 
High Recommendations relating to factors fundamental to the success of the control objectives of the
system. The weaknesses may give rise to significant financial loss/misstatement or failure of
business processes. 
Medium Recommendations which will improve the efficiency and effectiveness of the existing controls. 
Low Recommendations concerning minor issues that are not critical, but which may prevent attainment
of best practice and/or operational efficiency. 
Outwith the report, Internal Audit informs operational managers about other matters as part of continuous
improvement. 
3.8 The table below summarises the number of Internal Audit recommendations made during
2023/24:
Recs Rating 2024/25 Number of Recs
High 2
Medium 5
Low 0
Not Graded 0
Sub-total reported this period 7
Previously reported 15
Total 22 
Recommendations agreed with action plan 22
Not agreed; risk accepted 0
Total 22 
4 Report Implications (Resource, Digital, Risk and Equalities) 
4.1 Resource 
Resource implications of implementing Internal Audit recommendations are considered as
part of the audit process to ensure these are reasonable and proportionate to the risks. 
4.2 Digital 
There are no digital implications arising from this report. 
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4.3 Risk 
The PSIAS require Internal Audit to evaluate the effectiveness of the Council’s Risk
Management arrangements and contribute to improvements in the process. At the start of
each audit engagement, to capture potential areas of risk and uncertainty more fully, key
stakeholders have been consulted and risk registers have been considered. During each
audit engagement the management of risk has been tested. 
It is anticipated that improvements in the management and mitigation of risks will arise as a
direct result of Management implementing the Internal Audit recommendations made. If audit
recommendations are not implemented, there is a greater risk of financial loss and/or
reduced operational efficiency and effectiveness, and Management may not be able to
demonstrate improvement in internal control and governance arrangements, and effective
management of risks. 
4.4 Ensuring Equalities 
This report does not relate to a new or revised policy, service or budget change, which
affects people (the public or staff), so an Integrated Impact Assessment (IIA) is not an
applicable consideration. 
The Internal Audit work is carried out in accordance with the appropriate legislation and
professional standards. The latter includes compliance by those within the Internal Audit
function with the Code of Ethics set out in the PSIAS which is appropriate for the profession
of Internal Audit founded as it is on trust placed in its independent and objective assurance
about risk management, internal control and governance. 
4.5 Additional Report Implications (See Appendix A) 
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within the Single Midlothian
Plan to which Midlothian Council and its Community Planning Partners have made a
commitment (Reducing the gap in economic circumstances; Reducing the gap in learning
outcomes; Reducing the gap in health outcomes; and Reducing the impact of climate
change), good governance is important to enable Midlothian Council to deliver its key
priorities in support of achieving the Council’s objectives. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow supported by the 9 drivers
for change. Implementing the 9 drivers for change in practice is applicable to the Council’s
Internal Audit service provision to assist the Council in achieving its objectives. 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
The definition of Internal Auditing within the Public Sector Internal Audit Standards (PSIAS) is
“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.” 
Implementation by Management of the actions associated with Internal Audit
recommendations, that are designed to improve internal control and governance
arrangements and management of risks, underpins the Council’s own continuous
improvement arrangements to enhance its effectiveness, thus supporting the delivery of the
Council’s best value duties.
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A.5 Involving Communities and Other Stakeholders 
The Chief Internal Auditor is accountable to the Audit Committee which, in fulfilling its
governance role, acts as a bridge between the Council and other stakeholders. 
This report has been presented to Senior Management relevant to the areas audited have
agreed the final Internal Audit assurance reports as set out in the relevant Executive
Summary within Appendix 1. 
A.6 Impact on Performance and Outcomes 
The Findings and Recommendations from Internal Audit work during the year are designed to
assist the Council in improving its performance and outcomes. 
A.7 Adopting a Preventative Approach 
Internal Audit assurance work includes assessments on when a preventative approach can
be adopted. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable development. Good governance
is important to enable Midlothian Council to achieve its objectives. 
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Appendix 1.  Executive Summary: Business Continuity
Conclusion: Limited Assurance
A Business Continuity system was purchased in 2020 but is only used in a very limited capacity within the Place Directorate to document and
monitor business continuity plans making it difficult to track the Council’s overall progress in improving its resilience, there is insufficient resource
within Protective Services or Business Applications to rollout the Business Continuity system to more users, Protective Services do not have an
adequate process for recording and monitoring Directorate/Service compliance with the corporate policy, there are critical services within the
Council that do not have adequate or up-to-date business continuity plans, plans are not tested consistently, the Business Continuity Policy
requires update, the available training improved, and the written procedures available for services on business continuity require review and
expansion.
Background
The Civil Contingencies Act 2004 sets out specific duties for local authorities in relation to Business Continuity (for example to maintain business
continuity plans and provide generic advice and assistance in connection with business continuity, including signposting to specialist services). 
An approved Business Continuity Policy is in place which was last updated in 2017.  A Contingency Planning Officer (CPO), which is
multidisciplinary in role, is in post within Protective Services and is responsible for facilitating the provision of business continuity advice and
training to services.  In addition, the role supports the response to business continuity incidents and has responsibility to establish a process for
recording compliance with the corporate Business Continuity Policy.  The Contingency Planning Group (referenced in the 2017 Business
Continuity policy) which became the Risk & Resilience Group (as distinct from the current Strategic Risk and Resilience Group responsible for
monitoring the Council’s strategic risks) was responsible for monitoring compliance with the corporate policy and was chaired by the previous
Waste Risk and Resilience Manager.  The Risk & Resilience Group has not met since 2020.  As noted in the Business Continuity Policy, Senior
Management are responsible for ensuring business continuity plans are prepared for their Directorate / Service, tested, reviewed, critical
activities at a service level have been agreed, and employees in their Directorate have received an appropriate level of awareness and training
on the business continuity management process.
Summary of findings and recommendations
The following key findings and recommendations are highlighted, which have all been agreed by Management:
• Although a business continuity system was procured in 2020, its implementation was impacted by the Covid Pandemic and the Council
restructuring which occurred around that time, and its roll out is limited to a small number of pilot users within the Place Directorate.  The
business case and implementation plan were insufficiently developed post-procurement.  The Health Safety and Resilience Team service
review has identified there is insufficient resource within their service.  Management will review resource required to support an implementation
of a business continuity system and ongoing support by September 2025.
• A number of critical areas do not have adequate or up-to-date business continuity plans, or in some cases have no plans.  Services with no
plans or recently created plans have not undergone testing of their plans.  Chief Officers will ensure the creation of appropriate business
continuity plans by December 2025 and ensure that these are thereafter periodically reviewed, updated and tested.
• The Health Safety and Resilience Team do not have an adequate process for recording and monitoring Directorate/Service compliance with
the corporate policy, including the monitoring and review of Business Continuity Plans and the reporting of compliance to management. 
Management will ensure that appropriate monitoring with the corporate policy is in place, and this will include reviewing the level of resource
assigned to support this by September 2025.
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• There is no formal Digital Services Annual Business Continuity Testing Programme in place.  Management will implement an Annual Testing
Programme by September 2025.
• There is no appropriate forum/group in place for Business Continuity Leads to meet, at least annually, to discuss business continuity with other
service leads and Protective Services officers.  Management will host a forum with Business Continuity Leads from each service at least
annually to update knowledge on business continuity and support Contingency Planning in recording and monitoring Directorate/Service
compliance with the corporate policy by October 2025.
• The Business Continuity Policy is overdue for review; however a review is currently underway.   This means the Council’s approach has not
recently been endorsed at a senior level.   Management will ensure that the policy is reviewed and updated by June 2025.
• The guidance provided to services requires review and standardisation, guidance further developed for Business Continuity Leads, and the
training available enhanced (e.g. through development of an e-Learning module).  Management will update the business continuity guidance
and implement a business continuity e-learning module by October 2025. 
Recommendations
Grade 
High Medium Low Total
Current Report 2 5 - -
Prior Report (2022) 2 - - -
Materiality - The recent cyber-attack on Western Isles Council is anticipated
to cost the Council £1m and the cyber-attack on SEPA is reported to have
cost the organisation £5.5m.  The Council would be liable, at minimum, to
pay the policy excess following the loss or significant damage to any Council
building (e.g. following a fire or flood) and likely further recovery costs. 
Shortages of resources, such as fuel or power, would result in the Council
not being able to deliver services as expected, likely resulting in increased
costs for the Council. 
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3  
Headlines
Objectives Conclusion Comments
1.   Business critical services
across the Council have
been identified and
processes are in place to
ensure that business
continuity plans for those
areas remain up-to-date,
aligned with service delivery
requirements and continue to
be fit for purpose.
Limited
Assurance
Critical services identified include the Contact Centre, Child Protection and Vulnerable Children’s
Services, Education, and the Health and Social Care Partnership.  The Council’s Business
Continuity Policy was approved in 2017 and requires update to take into account the increased
cyber security risk, the systems to be prioritised in the event of a severe cyber-attack, the learning
from the Covid response and the Council’s current organisational structure (update in progress).
The Health Safety and Resilience Team do not have an adequate process for recording and
monitoring Directorate/Service compliance with the corporate policy.  Additionally, the guidance
and training provided to services requires review and improvement.  Delivering this may require
additional resource within the team as identified by the service review.  A system was purchased
in 2020 to enable services to record their business continuity plans electronically, but it has not
been implemented across the Council - current users are limited to a small number of pilot users
within the Place Directorate.  Therefore, it is not possible to get an accurate picture of what plans
are in place or if they are up-to-date without contacting each service manager individually.  The
implementation of the business continuity system was not adequately resourced and the rollout of
the application to other services has stalled.  
It was identified during the audit from the sample of services reviewed in the Place Directorate,
Children, Young People and Partnerships, and Social Care that a number of critical areas do not
have adequate or up-to-date Council business continuity plans, or in some cases have no plans.  
2.   A programme of testing
has been developed to
validate, over time, the
effectiveness of business
continuity plans and
solutions.
Limited
Assurance
As noted above, many services do not have up-to-date business continuity plans.  Some services
within Place Directorate have been updating their business continuity plans this year, but as these
plans have only recently been updated, they have not yet been tested.
Digital Services have an up-to-date Cyber Response Plan, Playbooks for different types of
potential cyber-attack, and undertake business continuity exercises.  There is no Annual Business
Continuity Testing Programme for formally testing specific aspects of systems and ensuring that
all relevant system specific documentation is up-to-date.  
3.   Following testing,
changes and improvements
have been implemented,
where required.
Limited
Assurance
As noted above, business continuity plans have not been appropriately developed or tested
across the Council.  However, Digital Services were able to provide evidence of business
continuity exercises carried out and lessons learned from their exercises.  The lessons learned
have contributed to their Cyber Security Action Plan and updated business continuity policies.
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4
Areas where expected controls are met/good practice
No. Areas of Positive Assurance
1. Digital Services created a Cyber Security Action Plan in 2022 following a number of high-profile cyber-attacks on public sector
organisations and have improved the Council’s resilience following the completion of the majority of the identified actions.  This included
the implementation of a password manager, vulnerability management software, improving the Council’s backup arrangements to
include cloud backup, and procuring a cyber incident response retainer to support the Council in the event of a cyber-attack.
2 The Council is moving more of its applications to cloud based ‘software as a service’ solution each year, which improves the Council’s
digital resilience.  
3. The importance of business continuity planning, particularly in relation to the impact of a cyber-attack, was reinforced in detail to senior
management at Leadership Forum events in June and September this year and relevant guidance was issued following this event.
4. The procurement of a business continuity system has been undertaken and there is an option to extend the contract until December
2030, meaning this could be rolled out across the Council provided the project was suitably resourced.  
5 Following NHS Lothian processes and procedures, Council delivered Health and Social Care Partnership Services have prepared plans
for their services outlining management arrangements, key suppliers, buildings, resources, and how actions should be documented if a
significant event requiring invocation of the plan were to occur.  It was advised that the Plans have been made available in a section of
the NHS Lothian network that will still be accessible if the main network is offline due to, for example, a cyber-attack. 
Business continuity within Council Services delivered by the Health and Social Care Partnership is monitored and reviewed by local
NHS resilience arrangements, including:
- Daily STAT PREP meetings to record system, service and staffing pressures.
- Critical Services list to reallocate staffing to areas under increased demand.
- Virtual control room and processes in place and routinely tested.
- Twice annual assurance reporting on resilience and continuity.
- NHS led annual exercises both tabletop and internal.
- Executive level resilience support provided by Executive Business Manager.
6 The Development of Business Continuity plans are the function and responsibility of each Directorate / Service.  Business Continuity is
a standing item on the Children, Young People and Partnerships and HSCP DMT.  Children, Young People and Partnerships have
sought support from a neighbouring authority to assist in developing their business continuity processes.  Whilst internal support has
been sought to develop service specific business continuity plans, the Executive Director was informed there was no capacity within the
Place Directorate to provide support in drafting their business continuity plans.  An external consultant has been appointed to undertake
this work which the Executive Director has been advised is due to be complete by end of March 2025.
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5 
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Audit Committee
Monday 24 February 2025
Item No 5.5 
Internal Audit Mid-Term Performance Report 2024/25 
Report by Duncan Stainbank, Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is asked to:
a) Note the progress Internal Audit has made with activity in the Internal
Audit Annual Plan 2024/25 to the end of January 2025; and 
b) Confirm that it is satisfied with the performance of the Internal Audit
service provision. 
2 Purpose of Report/Executive Summary 
The purpose of this report is to inform the Audit Committee of the
progress Internal Audit has made in the first 10 months of the year to 31
January 2025, towards completing the Internal Audit Annual Plan
2024/25. It also summarises the statutory obligations for Internal Audit
and requirements of the Public Sector Internal Audit Standards. 
Internal Audit provides assurance to Management and the Audit
Committee on the effectiveness of internal controls and governance
within the Council. 
The Internal Audit Annual Plan 2024/25 that was approved by the Audit
Committee on 18 March 2024 sets out the audit coverage for the year
utilising the expected available Internal Audit staff resources to enable
the Chief Internal Auditor, as the Council’s Chief Audit Executive
(CAE), to provide the statutory annual internal audit opinion regarding
the adequacy and effectiveness of internal control within the Council. 
The report provides details of the progress to date by Internal Audit
with its programme of work and highlights changes that require
approval to reflect the changes in resourcing available throughout the
year. 
Date 11 February 2025 
Report Contact:
Duncan Stainbank  Tel No 01620 827353
duncan.stainbank@midlothian.gov.uk
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3 Background 
3.1 As part of Midlothian Council’s system of corporate governance,
Internal Audit’s purpose is to support the Council in its activities
designed to achieve its declared objectives and to do so:
➢ In support of the Council’s vision, values and priorities.
➢ As a contribution to the Council’s corporate management of risk,
including assisting Management to improve the risk identification
and management process where there is exposure to significant
financial, strategic, reputational and operational risk to the
achievement of the Council’s objectives.
➢ As an aid to ensuring that the Council and its elected members,
employees and contracted third parties are operating within the law
and relevant regulations, and that public money is safeguarded and
properly accounted for, and used economically, efficiently and
effectively.
➢ As a contribution towards establishing and maintaining a culture of
honesty, integrity, openness, accountability and transparency
throughout the Council in all its activities and transactions.
➢ As a contribution towards ensuring that financial statements and
other published performance information are accurate and reliable. 
3.2 Internal Audit provides assurance to Management and the Audit
Committee on the effectiveness of internal controls, risk management
and governance within the Council. 
3.3 The Internal Audit Annual Plan 2024/25 that was approved by the Audit
Committee on 18 March 2024 set out the audit coverage for the year
utilising anticipated available Internal Audit staff resources to enable
the Chief Internal Auditor, as the Council’s Chief Audit Executive
(CAE), to provide the statutory annual internal audit opinion regarding
the adequacy and effectiveness of internal control within the Council. 
3.4 Internal Audit assurance services are also provided during the year to
the Midlothian Health and Social Care Integration Joint Board, and a
statutory annual Internal Audit opinion is provided to its respective
Management and Board/Audit and Risk Committee to meet its
obligations. 
4 Mid-Year Results Against Internal Audit Plan 2024/25 
4.1 The Internal Audit programme of work led by the Principal Internal
Auditor takes account of the availability of auditor resources and
consultation with Management to consider operational service delivery
demands and timing of the Council’s transformation programmes. 
4.2 The Appendix 1 to this report provides details of the progress by
Internal Audit with its programme of work. Those audits which are
complete are highlighted in dark shading, those underway to reflect
their continuous audit approach are highlighted in light shading. 
4.3 In addition, 2 audits: Purchase to Pay and Social Work Children’s
Services to Adult Services Transition (shaded in grey) have now been
removed from the audit plan as this is not the appropriate time to
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4.4 The Internal Audit plan had, in addition to regularly required review
processes, 9 audits scheduled for completion in 2024/25.  1
assignment has been substituted for another review being Property
Assets and Property Strategy for a review of Education Construction
Governance identified as a key risk in year. The team has completed 4
assignments (44%), 6 further assignments (46%) are scheduled with
current team capacity to be substantially complete prior to the annual
governance reports in June 2025. Substantial completion of the plan
will allow for an appropriate assessment of the Councils governance,
risk and control environment. 
4.5 The continuous audit approach, in accordance with the Internal Audit
Strategy approved by Audit Committee on 18 March 2024, enables
Internal Audit to provide added value advice on internal controls and
governance and ‘critical friend’ consultancy services. For example,
Capital Planning and Asset Management Board, and Information
Management Group. 
5 Continued Reporting on the Internal Audit Plan for 2024/25 
5.1 The Internal Audit work will continue to be reported to the Corporate
Management Team and to the Audit Committee. The Internal Audit
reports will include: an Executive Summary of the audit objective,
findings, good practice, recommendations (where appropriate) and
audit opinion of assurance for each Final Internal Audit Report issued
to relevant Management; a summary of Internal Audit Assurance Work
in Progress; and an outline of Internal Audit Consultancy and Other
Work carried out in accordance with the approved Internal Audit
Charter. 
5.2 Internal Audit’s compliance with its Strategy and delivery of its risk-
based Annual Plan will be communicated within the Internal Audit
Annual Assurance Report which will also provide the statutory annual
Internal Audit opinion based on audit findings over the year. 
6 The Local Authority Accounts (Scotland) Regulations 2014 
6.1 The Local Authority Accounts (Scotland) Regulations 2014 which came
into force on 10 October 2014 require a local authority to operate a
professional and objective internal auditing service. This service must
be provided in accordance with recognised standards and practices in
relation to internal auditing. Recognised standards and practices are
those set out in the Public Sector Internal Audit Standards: Applying the
IIA International Standards to the UK Public Sector (PSIAS). The
standards require internal audit to have suitable operational
independence from the authority. 
6.2 The regulations require a local authority to assess the efficiency and
effectiveness of internal auditing activity from time to time in
accordance with recognised internal auditing standards and practices. 
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7  Public Sector Internal Audit Standards (PSIAS) and Quality
Assurance & Improvement Plan (QAIP) 
7.1 The Internal Audit function follows the professional standards as set out
in Public Sector Internal Audit Standards (PSIAS) effective April 2013
(updated April 2017) which includes:
➢ Definition of Internal Auditing;
➢ Code of Ethics;
➢ Attribute Standards (responsibility, independence, proficiency,
quality);
➢ Professional Standards (managing activity, nature of work,
engagement planning, performing the engagement, communicating
results, monitoring progress, risk management). 
7.2 The PSIAS requires the Chief Audit Executive (CAE), the Council’s
Chief Internal Auditor, to carry out an annual internal self-assessment
against the PSIAS, develop a quality assurance and improvement plan
(QAIP) based on the outcome, and report the results of the QAIP to
senior management and elected members. 
7.3 An annual internal self-assessment against the PSIAS of the Internal
Audit function was completed in 2023/24. The results and associated
improvement actions was reported to the Corporate Management Team
and the Audit Committee within the Internal Audit Annual Assurance
Report in June 2024. This enabled the Council to meet the
requirements of the Local Authority Accounts (Scotland) Regulations
2014 to consider the findings of assessments as part of the
consideration of the system of internal control required by regulation 5. 
7.4 The PSIAS also requires the self-assessment to be subject to an
External Quality Assessment (EQA) each five years, by appropriately
qualified and independent reviewers. This EQA was carried out by
Highland Council in March 2018 and the results were outlined in the
Internal Audit Annual Assurance Report 2017/18 reported to the Audit
Committee in June 2018. The schedule for the second cycle of EQAs,
with other participating Scottish Councils as peer reviewers, indicates
that Midlothian will be reviewed by East Renfrewshire Council in 2024
This review has commenced and a further internal assessment with
documentation provided to the East Renfrewshire Council team it is
scheduled that a report will be provided to the Audit Committee in June
2025. 
8 Report Implications (Resource, Digital, Risk and Equalities) 
8.1 Resource 
The Internal Audit function reports directly to the Chief Executive
(operationally) and the Audit Committee (functionally). There is
currently a staff resource of 3.22 FTE, comprising Chief Internal Auditor
(0.5 FTE – shared with East Lothian Council), Principal Internal Auditor
(0.72 FTE), and Internal Auditor (2.0 FTE).  Each member of the
Internal Audit team has a professional internal audit or accountancy
qualification, and has suitable experience, knowledge, skills and
competencies (such as the Code of Ethics set out in PSIAS and the
Seven Principles of Public Life) needed to perform the plan. 
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Budget monitoring of the Service is discussed by the Chief Internal
Auditor and the Principal Internal Auditor with the Financial Services
Manager on a quarterly basis to address any budgetary pressures. 
There is a commitment to provide resource to the Midlothian Health
and Social Care Integration Joint Board (MIJB) as part of the Council’s
commitment to partnership working. Separate plans and reports are
presented to MIJB Audit and Risk Committee to fulfil this role. 
8.2 Digital 
There are no digital implications arising from this report. 
8.3 Risk 
The PSIAS require Internal Audit to evaluate the effectiveness of the
Council’s Risk Management arrangements and contribute to
improvements in the process. 
Key components of the audit planning process include a clear
understanding of the Council’s functions, associated risks, and
potential range and breadth of audit areas for inclusion. During the
development of the Internal Audit Annual Plan 2024/25, at the start of
each audit engagement, and during the re-assessment of the plan, to
capture potential areas of risk and uncertainty more fully, key
stakeholders have been consulted and risk registers have been
considered, to ensure the plan is formulated on a risk-based approach. 
If Internal Audit staffing levels fall below that assumed for the remaining
three-month period or if there is an unexpected and unplanned level of
contingency audit work, there is a high level of risk that the remaining
elements of the Annual Plan 2024/25 will not be delivered in full. This
could only be mitigated by use of external resource. Regular monitoring
will be undertaken to ensure that a sufficient range and breadth of
assurance audit work will be carried out during 2024/25 to underpin, a
‘not limited’ statutory Internal Audit opinion to Management and the
Audit Committee on the effectiveness of internal controls and
governance within the Council. 
8.4 Ensuring Equalities 
This report does not relate to a new or revised policy, service or budget
change, which affects people (the public or staff), so an Integrated
Impact Assessment (IIA) is not an applicable consideration. 
The Internal Audit work is carried out in accordance with the
appropriate legislation and professional standards. The latter includes
compliance by those within the Internal Audit function with the Code of
Ethics set out in the PSIAS which is appropriate for the profession of
Internal Audit founded as it is on trust placed in its independent and
objective assurance about risk management, internal control and
governance. 
8.5 Additional Report Implications (See Appendix A) 
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan to which Midlothian Council and its
Community Planning Partners have made a commitment (Reducing the
gap in economic circumstances; Reducing the gap in learning
outcomes; Reducing the gap in health outcomes; and Reducing the
impact of climate change), by providing an independent and objective
annual assessment of the adequacy of the entire control environment,
Internal Audit supports the Council to achieve its objectives. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow
supported by the 9 drivers for change. Implementing the 9 drivers for
change in practice is applicable to the Council’s Internal Audit service
provision to assist the Council in achieving its objectives. 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
The definition of Internal Auditing within the Public Sector Internal Audit
Standards (PSIAS) is “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.” 
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Implementation by Management of the actions associated with Internal
Audit recommendations, that are designed to improve internal control
and governance arrangements and management of risks, underpins
the Council’s own continuous improvement arrangements to enhance
its effectiveness, thus supporting the delivery of the Council’s best
value duties. 
A.5 Involving Communities and Other Stakeholders 
Internal Audit’s purpose is to support the Council in its activities
designed to achieve its declared objectives for the benefit of
Midlothian’s communities and other stakeholders. 
The Chief Internal Auditor is accountable to the Audit Committee which,
in fulfilling its governance role, acts as a bridge between the Council
and other stakeholders. 
This report has been presented to the Corporate Management Team to
outline the key messages of assurance plans. 
A.6 Impact on Performance and Outcomes 
The Findings and Recommendations from Internal Audit work during
the year, which are designed to maintain and / or enhance internal
controls, governance arrangements and risk management, assists the
Council in improving its performance and outcomes. 
A.7 Adopting a Preventative Approach 
Having robust internal controls, governance arrangements and risk
management in place contributes to safeguarding the Council’s
resources for delivery of services, as part of protecting the public purse.
Internal Audit assurance and consultancy activity is designed to
improve operations and assist the Council in accomplishing its
objectives. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable
development. Good governance, including the provision of an Internal
Audit service, is important to enable Midlothian Council to achieve its
objectives.
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Appendix 1
AUDIT DAYS COMMENTARY STATUS 
Assurance – Risk Based and Cyclical 
MLC Annual
Assessment of
Internal
Control and
Governance
20 Prepare an annual assurance report for
Management and the Audit Committee
summarising the work undertaken by
Internal Audit during the year and forming
an opinion on adequacy of the Council’s
arrangements for risk management,
governance and internal control.
Continuous audit approach on progress
with areas of improvement. Annual
evaluation of compliance with the Local
Code of Corporate Governance covering
the corporate whole and individual
Directorates / Services.
Continuous audit
approach to follow-up
on implementation of
actions on Areas of
Improvement set out in
the Annual Governance
Statement 2023/24.
Annual evaluation of
compliance with the
Local Code of
Corporate Governance
scheduled 4th Qtr.
Internal Audit opinion,
work undertaken and
compliance with PSIAS
will be outlined in
Internal Audit Annual
Assurance Report
2024/25.
Midlothian
Energy  30
Review the governance structures,
ensure monitoring regimes are in place
and operating to ensure long term
delivery of outcomes for the Council and
control over financial and operational risk.   
Complete: Final Report
issued November 2024.
Executive Summary to
Audit Committee
December 2024. 
Fostering,
Kinship Care
and Adoption
30
Review the processes in place to operate
the Fostering, Kinship Care and Adoption
processes and ensure that the correct
funding is being allocated appropriately
for each young person.  
Audit Terms of
Reference Agreed with
Service and initial work
underway report due to
be submitted to June
2025 Audit Committee.   
Education
Additional
Support Needs 
30
Review of the processes in place to plan
for and provide services for pupils with
additional support needs across
Education services, meeting the needs of
young people in accordance with
regulatory requirements.  
Key elements of this
audit were covered in
the assurance review of
the Bowles report to
Audit Committee in
September 2024. 
Purchase to
Pay 30
Review the control process in place
around the Council’s Purchase to Pay
system to ensure that they are operating
effectively and providing assurance that
all expenditure is appropriately processed
through systems and is being correctly
authorised in accordance with the
financial control processes of the Council.  
This review has been
delayed until 2025/26
plan due to systems
upgrades being
implemented in
December 2024. 
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AUDIT DAYS COMMENTARY STATUS 
Social Work
Children’s
Services to
Adult Services
Transition 
25 Review the processes in place for
transitions from Childrens Social Work
Services to Adult Social Work Services
for clients with ongoing needs, to ensure
efficient and effective transitions are
planned and implemented. 
This review was
dependent upon
progress being made
with funding provided
for this area. As
recruitment was not
successful this has
been suspended until
changes are
implemented to audit. 
Business
Continuity 
20 Review the Business Continuity
processes in place within the Council
ensuring that they cover all key risks,
including cybersecurity incidents,
power/energy losses etc.  
Complete: Final Report
issued February 2025.
Executive Summary to
Audit Committee
February 2025.
Budget
Monitoring
25 Review the processes in place to ensure
that services and service management
are effectively monitoring and managing
budgets throughout the financial year and
identifying and escalating significant
issues through finance and governance
structures on a timely basis. 
This audit has
commenced the
Executive Summary is
scheduled to be
submitted to the Audit
Committee in June
2025. 
School Funds 25 Review the processes in place to ensure
appropriate management and controls
processes are in place for school funds. 
The Attainment
Scotland Funding report
to Audit Committee in
November 2024
highlighted issues that
have resulted in a
working group being
implemented for School
Funds a full audit will be
rescheduled for 2025/26
SEEMIS
(School
Information
Management
System). 
20 Review the control process in place to
ensure accurate recording and use of
management information within the
SEEMIS System.  
The draft report has
been issued to
management in January
2024. The Executive
Summary will be
reported to the Audit
Committee in June 2025
IT Asset
Management 
20 Review the processes in place to ensure
that IT assets are recorded, managed
and maintained in an effective and
efficient manner.  
This review is underway
with reporting of the
Executive Summary to
the Audit Committee in
June 2025.
Property
assets and
property
strategy
20
Review the processes of developing a
property asset management strategy and
the governance of the implementation. 
This review has been
superseded by a review
of Education
Construction
Governance with the
reporting of the
Executive Summary to
Audit Committee in
June 2025.
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AUDIT DAYS COMMENTARY STATUS 
Consultancy 
Consultancy 20 In its ‘critical friend’ role provide: an
independent view and challenge of a
sample of programmes and projects
(including Learning Estate Strategy,
Business Transformation Board,
Information Management Group); and an
objective assessment of self-evaluation
arrangements.
In its critical friend role
provided an
independent view and
challenge at various
forums including Capital
Plan and Asset
Management Board,
and Information
Management Group. 
AUDIT DAYS COMMENTARY STATUS 
Other 
PSIAS External
Review 
10 Time to support the East Renfrewshire
External Quality Assurance review of
Internal Audit through the SLACIAG
framework. 
East Renfrewshire
review is underway, and
review documentation
collected and provided
for review hope to
report to the June Audit
Committee. 
MLC Audit
Committee Self-
Assessment
5 Provide assistance to Chair in
undertaking a self-assessment of the
Audit Committee against the CIPFA
best practice guidance.
The Chair presented
the Audit Committee
Annual Report 2022/23
to Council in October
2023. 2023/24 self-
assessment is
scheduled 4th Qtr.
MLC
Recommendation
Follow Up
Reviews
30 Undertake 2 reviews: the first includes
a sample check on the adequacy of
new internal controls for audit actions
flagged as closed, and the second
assesses performance against closing
audit actions by the agreed due date.
Follow-up Review of
Completed and In
Progress Internal Audit
Recommendations
reported to Audit
Committee November
2024.  
Contingency 30 Support / undertake any investigations
and other reactive work to ensure high
risk issues and concerns identified by
management or Audit Committee
during the year are appropriately
addressed.
Contingency days are
being used to support
completion of Internal
Audit plan due to
resource constraints
and
investigation/reactive
work. 
Help Desk
Enquiry system
22 Provide guidance and advice to
management on internal controls.
Ongoing
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MLC
Administration of
Audit Scotland
Reports
5 Monitor publication of Audit Scotland
reports and co-ordinate submission by
management of Audit Scotland reports
to the relevant Committee.
Ongoing
Management
Groups
15 Attend and provide support to Risk
Management and Integrity Groups.
Ongoing
MLC Attendance
at Boards /
Committees
20 Prepare for and attend Audit
Committee meetings and other
Boards/Committees.
Ongoing
MLC Audit
Planning for
2025/26
10 Update the Audit Universe, check risk
registers and other sources of
assurance, and develop and consult on
proposed coverage within the Internal
Audit Annual Plan 2025/26 in
accordance with GIAS. 
Internal Audit Annual
Plan 2025/26 is being
presented to Audit
Committee for approval
in February 2025. 
AUDIT DAYS COMMENTARY STATUS 
Non MLC 
Midlothian
Health and
Social Care
Integration
Joint Board
40 Audit reviews and support to be
determined and agreed by the MIJB Audit
and Risk Committee for review of the
adequacy of the MIJB’s arrangements for
risk management, governance and
internal control for delegated resources.
MIJB Internal Audit
Annual Plan 2024/25
approved by MIJB Audit
and Risk Committee in
March 2024. Audit work
ongoing. Reports will be
presented to MIJB Audit
and Risk Committee. 
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Audit Committee
Monday 24 February 2025
Item No 5.6 
Internal Audit Charter 
Report by Duncan Stainbank, Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is invited to:
a) Note that the Internal Audit Charter has been fully updated in
accordance with the Chartered Institute of Internal Auditors model
charter and in compliance with Global Internal Audit Standards in
application in the UK Public sector from 1 April 2025; 
b) Approve the revised Internal Audit Charter shown at Appendix 1 for
use from 1 April 2025; and  
c) Note that the Internal Audit Charter will be reviewed annually. 
2 Purpose of Report/Executive Summary 
This report provides the Audit Committee with the updated Internal
Audit Charter, in accordance with GIAS, for approval that defines the
purpose of Internal Audit and the mandate for Internal Audit within
Midlothian Council. The Charter clarifies the independence,
organizational Position and reporting relationships of Internal Audit and
outlines the roles and responsibilities of the Audit Committee and the
chief audit executive, who is the Chief Internal Auditor for Midlothian
Council and Midlothian IJB.     
The definition of Internal Auditing within Global Internal Audit Standards
(GIAS) is to strengthen Midlothian Council’s & Midlothian Integration
Joint Board’s ability to create, protect, and sustain value by providing
the Audit Committee and management with independent, risk-based,
and objective assurance, advice, insight, and foresight. 
Date 10 February 2025 
Report Contacts
Duncan Stainbank, Chief Internal Auditor 
duncan.stainbank@midlothian.gov.uk     
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3 Background 
3.1 The definition of Internal Auditing within Global Internal Audit Standards
(GIAS) is to strengthen Midlothian Council’s & Midlothian Integration
Joint Board’s ability to create, protect, and sustain value by providing
the Audit Committee and management with independent, risk-based,
and objective assurance, advice, insight, and foresight. 
3.2 The Midlothian Council Internal Audit function will follow the
professional standards as set out in the Global Internal Audit Standards
(GIAS) as adjusted by the UK Public Sector Application note as they
come into effect on 1st April 2025. A processes of evaluation against
these standards is currently being undertaken within the Internal Audit
team and further reporting to the Audit Committee on compliance will
be completed during the year.   
3.3 In accordance with GIAS, the chief audit executive must develop and
maintain an internal audit charter that specifies, at a minimum, the
internal audit function’s: 
• Purpose of Internal Auditing.
• Commitment to adhering to the Global Internal Audit Standards.
• Mandate, including scope and types of services to be provided, and
the board’s responsibilities and expectations regarding
management’s support of the internal audit function. 
• Organizational position and reporting relationships. 
3.4 The Board is defined in relation to GIAS as the Midlothian Audit
Committee acting on behalf of Midlothian Council. 
3.5 Internal Audit assurance resources and services are also provided by
Midlothian Council’s Internal Audit team to the Midlothian Integration
Joint Board (MIJB), including the appointed MIJB Chief Internal Auditor.
The Internal Audit Charter and Strategy are applicable to each
organisation. 
4 Internal Audit Charter   
4.1 The authority for Internal Audit to operate in Midlothian Council is
contained in the Council’s Local Code of Corporate Governance,
Standing Orders, and Financial Regulations. This Internal Audit Charter
expands upon that framework. 
4.2 The Internal Audit Charter as shown in Appendix 1 to this report:
establishes the Internal Audit activity’s position within the organisation,
including the nature of the Chief Audit Executive’s functional reporting
relationship with the board; authorises access to records, personnel
and physical properties relevant to the performance of engagements;
and defines the scope of Internal Audit activities. 
4.3 The Internal Audit Charter has been annually reviewed in relation to
Public Sector Internal Audit Standards and the Charter which was
previously approved by the Audit Committee on 18 March 2024 will
remain in place until the 1 April 2025. 
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4.4 The Internal Audit Charter should be considered alongside the Internal
Audit Strategy and Plan 2025/26. The Internal Audit Strategy sets out
the Council’s assurance framework within which Internal Audit
operates, and the Chief Audit Executive’s strategy for discharging its
role and providing the necessary annual assurance opinions to
Midlothian Council and Midlothian Integration Joint Board (MIJB). The
Internal Audit Charter and Strategy are applicable to these
organisations. There are separate Internal Audit Annual Plans for each
organisation, which set out the range and breadth of audit activity. 
5 Report Implications (Resource, Digital, Risk and Equalities) 
5.1 Resource 
The Local Authority Accounts (Scotland) Regulations 2014 that came
into force on 10 October 2014 require a local authority to operate a
professional and objective internal auditing service. 
Internal Audit must have sufficient staff and other resources to enable it
to carry out the objectives of the Charter and to deliver a programme of
independent and objective audit assurance work alongside other
available sources of assurance to enable the Chief Audit Executive to
prepare annual opinions on the adequacy of the overall control
environment for Midlothian Council and the MIJB. Internal Audit
resources are set out in the Internal Audit Strategy and Plan 2025/26,
for the approval of the Audit Committee. 
5.2 Digital 
There are no digital implications arising from this report. 
5.3 Risk 
Approval of the Internal Audit Charter (Appendix 1), as recommended
in this report, will ensure that Internal Audit is tasked to carry out its role
in accordance with Global Internal Audit Standards and best Corporate
Governance practice. 
5.4 Ensuring Equalities 
This report does not relate to a new or revised policy, service or budget
change, which affects people (the public or staff), so an Integrated
Impact Assessment (IIA) is not an applicable consideration. 
The Internal Audit work is carried out in accordance with the
appropriate legislation and professional standards. The latter includes
compliance by those within the Internal Audit function and Global
Internal Audit Standards. 
5.5 Additional Report Implications (See Appendix A) 
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan to which Midlothian Council and its
Community Planning Partners have made a commitment (Reducing the
gap in economic circumstances; Reducing the gap in learning
outcomes; Reducing the gap in health outcomes; and Reducing the
impact of climate change), good governance is important to enable
Midlothian Council to deliver its key priorities in support of achieving the
Council’s objectives. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow
supported by the 9 drivers for change. Implementing the 9 drivers for
change in practice is applicable to the Council’s Internal Audit service
provision to assist the Council in achieving its objectives. 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
The purpose of the internal audit function is to strengthen Midlothian
Council’s & Midlothian Integration Joint Board’s ability to create,
protect, and sustain best value by providing the Audit Committee and
management with independent, risk-based, and objective assurance,
advice, insight, and foresight. 
A.5 Involving Communities and Other Stakeholders 
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The Chief Audit Executive is accountable to the Audit Committee
which, in fulfilling its governance role, acts as a bridge between the
Council and other stakeholders. 
A.6 Impact on Performance and Outcomes 
Applying the framework of the GIAS will give the Audit Committee
assurance that the Internal Audit function is compliant with legislative
requirements and current best practice. 
A.7 Adopting a Preventative Approach 
A full review of the Internal Audit Service compliance with GIAS is
currently underway to ensure that the service is compliant with
legislative and regulatory requirements as well as best governance
practice in the public sector. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable
development. Internal Audit is a key element of good governance which
is important to enable Midlothian Council to achieve its objectives
including sustainable outcomes.
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Internal Audit Charter for Midlothian Council 
Purpose
The purpose of the internal audit function is to strengthen Midlothian Council’s & Midlothian
Integration Joint Board’s ability to create, protect, and sustain best value by providing the Audit
Committee and management with independent, risk-based, and objective assurance, advice,
insight, and foresight.
The internal audit function enhances Midlothian Council’s & Midlothian Integration Joint Board’s
ability:
• Successful achievement of its objectives.
• Governance, risk management, and control processes.
• Decision-making and oversight.
• Reputation and credibility with its stakeholders.
• Ability to serve the public interest.
Midlothian Council’s internal audit function is most effective when:
• Internal auditing is performed by competent professionals in conformance with The IIA’s
Global Internal Audit Standards, which are set in the public interest.
• The internal audit function is independently positioned with direct accountability to the
Audit Committee.
• Internal auditors are free from undue influence and committed to making objective
assessments.
Commitment to Adhering to the Global Internal Audit Standards
The Midlothian Council’s internal audit function will adhere to the mandatory elements of The
Institute of Internal Auditors' International Professional Practices Framework, which are the
Global Internal Audit Standards and Topical Requirements, and the adjustments made through
the Application Note Global Internal Audit Standards in the UK Public Sector. The chief audit
executive, Chief Internal Auditor in Midlothian Council, will report annually to the Audit
Committee and senior management regarding the internal audit function’s conformance with the
Standards, which will be assessed through a quality assurance and improvement program.
Mandate
Authority
Midlothian Council’s internal audit function mandate is within The Local Authority Accounts
(Scotland) Regulations 2014, which states in section 7, that:  
(1) A local authority must operate a professional and objective internal auditing service in
accordance with recognized standards and practices in relation to internal auditing.
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(2) Any officer or member of a local authority must, as required by those undertaking internal
auditing—
(a)make available such documents of that authority which relate to its accounting and other
records for the purpose of internal auditing; and
(b)supply such information and explanation as those undertaking internal auditing consider
necessary for that purpose.
(3) A local authority must from time to time assess the efficiency and effectiveness of its internal
auditing, in accordance with the standards and practices referred to in paragraph (1).
(4) The findings of the assessments referred to in paragraph (3) must be considered, as part of
the consideration of the system of internal control referred to in regulation 5(2), at the meeting
referred to in regulation 5(3).
The internal audit function’s authority is created by its direct reporting relationship to Midlothian
Council’s Audit Committee. Such authority allows for unrestricted access to the Audit Committee
Chair and Members. 
The Audit Committee authorizes the internal audit function to:
• Have full and unrestricted access to all functions, data, records, information, physical
property, and personnel pertinent to carrying out internal audit responsibilities. Internal
auditors are accountable for confidentiality and safeguarding records and information.
• Allocate resources, set frequencies, select subjects, determine scopes of work, apply
techniques, and issue communications to accomplish the function’s objectives. 
• Obtain assistance from the necessary personnel of Midlothian Council and other
specialized services from within or outside Midlothian Council to complete internal audit
services.
Independence, Organizational Position, and Reporting Relationships 
The chief audit executive, will be positioned at a level in the organization that enables internal
audit services and responsibilities to be performed without interference from management,
thereby establishing the independence of the internal audit function.  The chief audit executive
will report functionally to the Chief Executive and the Chair of the Audit Committee and
administratively to the Chief Executive. This positioning provides the organizational authority
and status to bring matters directly to senior management and escalate matters to the Chair of
the Audit Committee or the Chief Executive as appropriate, when necessary, without
interference and supports the internal auditors’ ability to maintain objectivity. 
The chief audit executive will confirm to the Audit Committee, at least annually, the
organizational independence of the internal audit function. If the governance structure does not
support organizational independence, the chief audit executive will document the characteristics
of the governance structure limiting independence and any safeguards employed to achieve the
principle of independence. The chief audit executive will disclose to the Audit Committee any
interference internal auditors encounter related to the scope, performance, or communication of
internal audit work and results. The disclosure will include communicating the implications of
such interference on the internal audit function’s effectiveness and ability to fulfill its mandate.
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Changes to the Mandate and Charter 
Circumstances may justify a follow-up discussion between the chief audit executive, Audit
Committee, and senior management on the internal audit mandate or other aspects of the
internal audit charter. Such circumstances may include but are not limited to:
• A significant change in the Global Internal Audit Standards.
• A significant reorganization within the organization.
• Significant changes in the chief audit executive, Council, Audit Committee and/or senior
management.
• Significant changes to the organization’s strategies, objectives, risk profile, or the
environment in which the organization operates.
• New laws or regulations that may affect the nature and/or scope of internal audit
services.
Audit Committee Oversight
To establish, maintain, and ensure that Midlothian Council’s internal audit function has sufficient
authority to fulfill its duties, the Audit Committee will:
• Discuss with the chief audit executive and senior management the appropriate authority,
role, responsibilities, scope, and services (assurance and/or advisory) of the internal
audit function.
• Ensure the chief audit executive has unrestricted access to and communicates and
interacts directly with the Audit Committee, including in private meetings without senior
management present at least once a year.
• Discuss with the chief audit executive and senior management other topics that should
be included in the internal audit charter.
• Participate in discussions with the chief audit executive and senior management about
the “essential conditions,” described in the Global Internal Audit Standards, which
establish the foundation that enables an effective internal audit function.
• Approve the internal audit function’s charter, which includes the internal audit mandate
and the scope and types of internal audit services.
• Review the internal audit charter annually with the chief audit executive to consider
changes affecting the organization, such as the employment of a new chief audit
executive or changes in the type, severity, and interdependencies of risks to the
organization; and approve the internal audit charter on an annual basis.
• Approve the risk-based internal audit plan.
• Provide input to the internal audit function’s human resources administration and
budgets.
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• Review the internal audit function’s expenses.
• Provide input to senior management on the appointment and removal of the chief audit
executive, ensuring adequate competencies and qualifications and conformance with the
Global Internal Audit Standards.
• Review and provide input to senior management on the chief audit executive’s
performance.
• Receive communications from the chief audit executive about the internal audit function
including its performance relative to its plan.
• Ensure a quality assurance and improvement program has been established and review
the results annually.
• Make appropriate inquiries of senior management and the chief audit executive to
determine whether scope or resource limitations are inappropriate. 
Chief Audit Executive Roles and Responsibilities
Ethics and Professionalism
The chief audit executive will ensure that internal auditors:
• Conform with the Global Internal Audit Standards, including the principles of Ethics and
Professionalism: integrity, objectivity, competency, due professional care, and
confidentiality.
• Understand, respect, meet, and contribute to the legitimate and ethical expectations of
the organization and be able to recognize conduct that is contrary to those expectations.
• Encourage and promote an ethics-based culture in the organization. 
• Report organizational behavior that is inconsistent with the organization’s ethical
expectations, as described in applicable policies and procedures.
Objectivity 
The chief audit executive will ensure that the internal audit function remains free from all
conditions that threaten the ability of internal auditors to carry out their responsibilities in an
unbiased manner, including matters of engagement selection, scope, procedures, frequency,
timing, and communication. If the chief audit executive determines that objectivity may be
impaired in fact or appearance, the details of the impairment will be disclosed to appropriate
parties. 
Internal auditors will maintain an unbiased mental attitude that allows them to perform
engagements objectively such that they believe in their work product, do not compromise
quality, and do not subordinate their judgment on audit matters to others, either in fact or
appearance.
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Internal auditors will have no direct operational responsibility or authority over any of the
activities they review. Accordingly, internal auditors will not implement internal controls, develop
procedures, install systems, or engage in other activities that may impair their judgment,
including:
• Assessing specific operations for which they had responsibility within the previous year. 
• Performing operational duties for Midlothian Council or its subsidiaries or associates.
• Initiating or approving transactions external to the internal audit function.
• Directing the activities of any Midlothian Council employee that is not employed by the
internal audit or counter fraud function, except to the extent that such employees have
been appropriately assigned to internal audit teams or to assist internal auditors.
Internal auditors will:
• Disclose impairments of independence or objectivity, in fact or appearance, to
appropriate parties and at least annually, such as the chief audit executive, Audit
Committee, management, or others.
• Exhibit professional objectivity in gathering, evaluating, and communicating information. 
• Make balanced assessments of all available and relevant facts and circumstances.
• Take necessary precautions to avoid conflicts of interest, bias, and undue influence.
Managing the Internal Audit Function
The chief audit executive has the responsibility to:
• At least annually, develop a risk-based internal audit plan that considers the input of the
Audit Committee and senior management. Discuss the plan with the Audit Committee
and senior management and submit the plan to the Audit Committee for review and
approval. 
• Communicate the impact of resource limitations on the internal audit plan to the Audit 
Committee and senior management.
• Review and adjust the internal audit plan, as necessary, in response to changes in
Midlothian Council’s business, risks, operations, programs, systems, and controls.
• Communicate with the Audit Committee and senior management if there are significant
interim changes to the internal audit plan.
• Ensure internal audit engagements are performed, documented, and communicated in
accordance with the Global Internal Audit Standards.
• Follow up on engagement findings and confirm the implementation of recommendations
or action plans and communicate the results of internal audit services to the Audit
Committee and senior management regularly and for each engagement as appropriate. 
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• Ensure the internal audit function collectively possesses or obtains the knowledge, skills,
and other competencies and qualifications needed to meet the requirements of the
Global Internal Audit Standards and fulfill the internal audit mandate.
• Identify and consider trends and emerging issues that could impact Midlothian Council
and communicate to the Audit Committee and senior management as appropriate.
• Consider emerging trends and successful practices in internal auditing.
• Establish and ensure adherence to methodologies designed to guide the internal audit
function.
• Ensure adherence to Midlothian Council’s relevant policies and procedures unless such
policies and procedures conflict with the internal audit charter or the Global Internal Audit
Standards. Any such conflicts will be resolved or documented and communicated to the
Audit Committee and senior management.
• Coordinate activities and consider relying upon the work of other internal and external
providers of assurance and advisory services. If the chief audit executive cannot achieve
an appropriate level of coordination, the issue must be communicated to senior
management and if necessary escalated to the Audit Committee.
Communication with the Audit Committee and Senior Management 
The chief audit executive will report annually to the Audit Committee and senior management
regarding:
• The internal audit function’s mandate.
• The internal audit plan and performance relative to its plan.
• Internal audit resources/budget.
• Significant revisions to the internal audit plan and resources/budget. 
• Potential impairments to independence, including relevant disclosures as applicable. 
• Results from the quality assurance and improvement program, which include the internal
audit function’s conformance with The IIA’s Global Internal Audit Standards and action
plans to address the internal audit function’s deficiencies and opportunities for
improvement.
• Significant risk exposures and control issues, including fraud risks, governance issues,
and other areas of focus for the Audit Committee that could interfere with the
achievement of Midlothian Council’s strategic objectives.
• Results of assurance and advisory services.
• Resource requirements.
• Management’s responses to risk that the internal audit function determines may be
unacceptable or acceptance of a risk that is beyond Midlothian Council’s risk appetite. 
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Quality Assurance and Improvement Program
The chief audit executive will develop, implement, and maintain a quality assurance and
improvement program that covers all aspects of the internal audit function. The program will
include external and internal assessments of the internal audit function’s conformance with the
Global Internal Audit Standards, as well as performance measurement to assess the internal
audit function’s progress toward the achievement of its objectives and promotion of continuous
improvement. The program also will assess, if applicable, compliance with laws and/or
regulations relevant to internal auditing. Also, if applicable, the assessment will include plans to
address the internal audit function’s deficiencies and opportunities for improvement. 
Annually, the chief audit executive will communicate with the Audit Committee and senior
management about the internal audit function’s quality assurance and improvement program,
including the results of internal assessments (ongoing monitoring and periodic self-
assessments) and external assessments. External assessments will be conducted at least once
every five years by a qualified, independent assessor or assessment team from outside
Midlothian Council; qualifications will be in accordance with the GIAS Global Internal Audit
Standards in the UK Public Sector Application note.  
Scope and Types of Internal Audit Services 
The scope of internal audit services covers the entire breadth of the organization, including all of
Midlothian Council’s activities, assets, and personnel. The scope of internal audit activities also
encompasses but is not limited to objective examinations of evidence to provide independent
assurance and advisory services to the Audit Committee and management on the adequacy
and effectiveness of governance, risk management, and control processes for Midlothian
Council. 
The nature and scope of advisory services may be agreed with the party requesting the service,
provided the internal audit function does not assume management responsibility, and subject to
the availability of internal audit resource. Opportunities for improving the efficiency of
governance, risk management, and control processes may be identified during advisory
engagements. These opportunities will be communicated to the appropriate level of
management.
Internal audit engagements may include evaluating whether: 
• Risks relating to the achievement of Midlothian Council’s & Midlothian Integration Joint
Board’s strategic objectives are appropriately identified and managed.
• The actions of Midlothian Council’s & Midlothian Integration Joint Board’s officers,
directors, management, employees, and contractors or other relevant parties comply
with Midlothian Council’s & Midlothian Integration Joint Board’s policies, procedures, and
applicable laws, regulations, and governance standards.
• The results of operations and programs are consistent with established goals and
objectives.
• Operations and programs are being carried out effectively, efficiently, ethically, and
equitably.
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• Established processes and systems enable compliance with the policies, procedures,
laws, and regulations that could significantly impact Midlothian Council & Midlothian
Integration Joint Board.
• The integrity of information and the means used to identify, measure, analyze, classify,
and report such information is reliable.
• Resources and assets are acquired economically, used efficiently and sustainably, and
protected adequately. 
Approved by the Audit Committee at its meeting on 24 February 2025.   
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Audit Committee
Monday 24 February 2025
Item No 5.7 
Internal Audit Strategy and Annual Plan 2025/26 
Report by Duncan Stainbank, Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is invited to:
a) Note the changes to the Internal Audit Strategy outlined in section 4
of this report; 
b) Note the outline of the Internal Audit planning process outlined in
section 5 of this report;
c) Approve the Internal Audit Strategy (Appendix 1); and  
d) Approve the Internal Audit Annual Plan 2025/26 (Appendix 2). 
2 Purpose of Report/Executive Summary 
The purpose of this report is to gain approval from the Audit Committee
to the proposed Internal Audit Strategy and Annual Plan 2025/26 to
enable the Chief Internal Auditor to prepare annual opinions on the
adequacy of the overall control environment for Midlothian Council, and
Midlothian Integration Joint Board (MIJB). 
The Internal Audit Strategy at Appendix 1 outlines the strategic
direction for how Internal Audit will achieve its objectives, which are set
out in the Internal Audit Charter, in conformance with Global Internal
Audit Standards. It guides the Internal Audit function in delivering high
quality internal audit services to Midlothian Council and the MIJB. 
The Internal Audit Annual Plan 2025/26 at Appendix 2 has been
developed by the shared Chief Internal Auditor and the Principal
Internal Auditor. It sets out the proposed range and breadth of audit
activity within the audit programme of work to enable the Chief Internal
Auditor to prepare the independent and objective audit opinions for
Midlothian Council and the MIJB. A separate Internal Audit Annual Plan
2025/26 for the MIJB will be presented to its Audit and Risk Committee.
Key components of the audit planning process include a clear
understanding of each organisation’s functions, associated risks, and
assurance framework. 
Date 10 February 2025 
Report Contacts
Duncan Stainbank, Chief Internal Auditor 
duncan.stainbank@midlothian.gov.uk     
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3 Background 
3.1 The Local Authority Accounts (Scotland) Regulations 2014 that came
into force on 10 October 2014 require a local authority to operate a
professional and objective internal auditing service. This service must
be provided in accordance with recognised standards and practices in
relation to internal auditing. Recognised standards and practices are
those set out in the Global Internal Audit Standards (GIAS) as adjusted
by the UK Public Sector Application note. 
3.2 The Midlothian Council Internal Audit function is planning to follow the
professional standards as set out in the Global Internal Audit Standards
(GIAS) as adjusted by the UK Public Sector Application note, from the
1 April 2025, where resources allow. In accordance with GIAS to
develop an effective internal audit strategy and plan, the chief audit
executive must understand the organization’s governance, risk
management, and control processes. 
3.3 GIAS also requires that the chief audit executive must develop and
implement a strategy for the internal audit function that supports the
strategic objectives and success of the organization and aligns with the
expectations of the board (the Audit Committee acting on behalf of the
Council), senior management, and other key stakeholders, including
Audit Scotland and the Midlothian Public. 
3.4 Internal Audit resources and services are also provided by Midlothian
Council’s Internal Audit team to the Midlothian Health and Social Care
Integration Joint Board (MIJB), including the appointed MIJB Chief
Internal Auditor. The Internal Audit Charter and Strategy are applicable
to each organisation. 
4        Internal Audit Strategy 
4.1 GIAS Standard 9.2 Internal Audit Strategy states, that; “the chief audit
executive must develop and implement a strategy for the internal audit
function that supports the strategic objectives and success of the
organization and aligns with the expectations of the board, senior
management, and other key stakeholders.” 
4.2 The Chief Internal Auditor (CAE) and the Principal Internal Auditor have
developed the Internal Audit Strategy at Appendix 1. It outlines the
strategic direction for how Internal Audit will achieve its objectives,
which are set out in the Internal Audit Charter, in conformance with
GIAS. It guides the Internal Audit function in delivering high quality
internal audit services to Midlothian Council and the Midlothian Health
and Social Care Integration Joint Board (MIJB). 
4.4 The Internal Audit Strategy:
• Outlines the assurance framework, providing clarity of the
respective responsibilities of Management for designing and
monitoring governance and control systems and of the role of
Internal Audit in providing independent assurance thereon;
• States how the key themes which are integral to the assurance
gathering process across the organisation’s activities will be
covered to inform the annual Internal Audit opinion statement;
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• Describes the approach to the development of the risk based
Internal Audit annual plan;
• Sets out the relative allocation of Internal Audit resources;
• Outlines how the Internal Audit programme of work will be
delivered to add value; and
• Describes the monitoring and reporting of Internal Audit findings
from its work and progress with its plans to the relevant
organisation’s audit committee/board. 
5        Internal Audit Annual Plan 2025/26 
5.1 The key standards within the GIAS relating to the Internal Audit Plan is
Standard 9.4 Internal Audit Plan, which states the following:  The chief
audit executive must create an internal audit plan that supports the
achievement of the organization’s objectives. The chief audit executive
must base the internal audit plan on a documented assessment of the
organization’s strategies, objectives, and risks. This assessment must
be informed by input from the board and senior management as well as
the chief audit executive’s understanding of the organization’s
governance, risk management, and control processes. The
assessment must be performed at least annually.  
5.2 GIAS Standard 9.4 also states that; The internal audit plan must: 
• Consider the internal audit mandate and the full range of agreed-
to internal audit services. 
• Specify internal audit services that support the evaluation and
improvement of the organization’s governance, risk management,
and control processes. 
• Consider coverage of information technology governance, fraud
risk, the effectiveness of the organization’s compliance and ethics
programs, and other high-risk areas. 
• Identify the necessary human, financial, and technological
resources necessary to complete the plan. 
• Be dynamic and updated timely in response to changes in the
organization’s business, risks operations, programs, systems,
controls, and organizational culture. 
5.3 GIAS Standard 9.5 Coordination and Reliance states that, “The chief
audit executive must coordinate with internal and external providers of
assurance services and consider relying upon their work. Coordination
of services minimizes duplication of efforts, highlights gaps in coverage
of key risks, and enhances the overall value added by providers. If
unable to achieve an appropriate level of coordination, the chief audit
executive must raise any concerns with senior management and, if
necessary, the board.”  The audit plan has been developed with
coordination and reliance on the work of Audit Scotland as the
appointed external auditor, specifically in relation to work on
transformation covering many of the key identified Council risks.
However, Coordination and reliance on other assurance providers
including Education Scotland, Care Commission, health and safety
inspectorate, has not been possible for the 2025/26 plan. Full
compliance with this element of the standards has not been completed
as Midlothian Council does not have a full assurance map.   
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5.4 The Chief Internal Auditor (CAE) and the Principal Internal Auditor have
developed the Internal Audit Annual Plan 2025/26 at Appendix 2,
based on the Internal Audit staff resources set out in 6.1. It sets out the
proposed range and breadth of audit activity to be undertaken to
provide the independent and objective audit opinions to Midlothian
Council and the MIJB. 
5.5 As part of the Internal Audit planning process, it was necessary to
consider each organisation’s priorities, plans, strategies, objectives,
risks and mitigating controls, and the internal and external assurances
provided to determine the priorities of the Internal Audit activity
consistent with the organisation’s goals, as follows:
• Analysis was undertaken of Internal Audit work during the past 5
years against the Audit Universe which has been significantly
revised and realigned by the Principal Internal Auditor to reflect
the current strategic and operational management arrangements
and approach to service delivery to ensure appropriate coverage;
• The Strategic Risk Profile was checked to confirm coverage on
key strategic risks, as reliance is placed on the risk assessments
carried out by the Risk Owners taking account of the risk ratings
and mitigations; and 
• The chief internal Auditor completed their own service specific risk
assessments where service risk registers were not mature
enough to place reliance on. 
• Account was taken of known external audit and inspection
activities to avoid duplication of assurance work. 
5.6 It is envisaged that 2025/26 will continue to be a year of change for the
Council and other partner organisations. Therefore, the Internal Audit
Annual Plan 2025/26 should be considered to be flexible and will be
periodically reviewed, and amended as required, to reflect any new
arrangement or changing risks and priorities or available resources.
Any amendments relating to the Council will be brought to the
Corporate Management Team and the Audit Committee for approval. 
5.7 The Non-MLC days reflect the Council’s partnership working
commitment to provide Internal Audit resource and services to the
Midlothian Health and Social Care Integration Joint Board (MIJB). A
separate Internal Audit Annual Plan 2025/26 will be presented to the
MIJB Audit and Risk Committee for approval. 
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6 Report Implications (Resource, Digital, Risk and Equalities) 
6.1 Resource 
The Local Authority Accounts (Scotland) Regulations 2014 that came
into force on 10 October 2014 require a local authority to operate a
professional and objective internal auditing service. 
Internal Audit must have sufficient staff and other resources to enable it
to carry out the objectives of the Charter and to deliver a programme of
independent and objective audit assurance work alongside other
available sources of assurance to enable the Chief Audit Executive to
prepare annual opinions on the adequacy of the overall control
environment for Midlothian Council, and the MIJB. 
The Internal Audit staff resource totalling 3.22 FTE comprises Chief
Internal Auditor (0.5 FTE), Principal Internal Auditor (0.72 FTE) and
Internal Auditor (2.0 FTE). Each member of the current Internal Audit
team has a professional internal audit or accountancy qualification, and
has suitable experience, knowledge, skills and competencies (Including
knowledge of GIAS and the Seven Principles of Public Life) needed to
deliver the Plan. After deduction for estimated annual leave, public
holidays, absence including staff turnover, learning and development,
and management and supervision, this equates to a total of 511 days
available for Internal Audit activity (2024/25 plan 522 days). 
6.2 Digital 
There are no digital implications arising from this report. 
6.3 Risk 
Key components of the audit planning process include a clear
understanding of the Council’s functions, associated risks, and
potential range and breadth of audit activity for inclusion within the
plan. As in previous years, to capture potential areas of risk and
uncertainty more fully, reference has been made to the Strategic Risk
Profile and key stakeholders have been consulted to make an
appropriate assessment of service level risks. 
At all times, Management’s responsibilities (led by the Corporate
Management Team) include:
o Designing and maintaining proper risk management, governance
and internal control processes and systems for which they have
responsibility to ensure probity in systems and operations,
including the prevention, detection and resolution of fraud and
irregularities. These are not fixed but evolve as the Council
changes.
o Checking that these governance arrangements and internal
controls are operating effectively and obtaining assurances from
internal compliance, risk, inspection, quality, and control functions.
(The above are known as the first and second lines.)
o Engaging with Internal Audit (the third line) in a positive way to
achieve shared goals for robust internal control and governance,
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best value and improvement, and ensuring that Internal Audit can
properly fulfil its role.
o Considering and acting upon Internal Audit findings and
recommendations, including implementation of audit
recommendations within agreed timescales and updating Pentana
performance system, or accepting responsibility for any resultant
risk from not doing so.
o Seeking advice and consultancy support from Internal Audit on
existing controls and on changes to and transformation of
governance, processes and procedures. 
6.4 Ensuring Equalities 
This report does not relate to a new or revised policy, service or budget
change, which affects people (the public or staff), so an Integrated
Impact Assessment (IIA) is not an applicable consideration. 
The Internal Audit work is carried out in accordance with the
appropriate legislation and professional standards. The latter includes
compliance with Global Internal Audit Standards. 
6.5 Additional Report Implications (See Appendix A)
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan to which Midlothian Council and its
Community Planning Partners have made a commitment (Reducing the
gap in economic circumstances; Reducing the gap in learning
outcomes; Reducing the gap in health outcomes; and Reducing the
impact of climate change), good governance is important to enable
Midlothian Council to deliver its key priorities in support of achieving the
Council’s objectives. These objectives have been considered and
reviewed against each internal audit assignment within the plan. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow
supported by the 9 drivers for change. Implementing the 9 drivers for
change in practice is applicable to the Council’s Internal Audit service
provision to assist the Council in achieving its objectives. 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
The purpose of the internal audit function is to strengthen Midlothian
Council’s & Midlothian Integration Joint Board’s ability to create,
protect, and sustain best value by providing the Audit Committee and
management with independent, risk-based, and objective assurance,
advice, insight, and foresight. 
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A.5 Involving Communities and Other Stakeholders 
The Chief Audit Executive is accountable to the Audit Committee
which, in fulfilling its governance role, acts as a bridge between
the Council and other stakeholders. The Audit Committee remit
includes “To approve the risk-based internal audit plan, including
internal audit’s resources requirements, the approach to using
other sources of assurance and any work required to place
reliance upon those other sources”. 
The Council Management Team has been consulted on the Internal
Audit resources, risk-based audit approach and the resultant planned
Internal Audit coverage to ensure it will provide assurance on controls
and governance relating to the key risks facing the Council and to
assist them in discharging their roles and responsibilities. External
Audit plans have been taken into account in completing the planning
process. 
A.6 Impact on Performance and Outcomes 
Applying the framework of the GIAS will give the Audit Committee
assurance that the Internal Audit function is compliant with legislative
requirements and current best practice. 
The delivery of the Internal Audit strategy and annual plan assists the
Council in improving its performance and outcomes. 
A.7 Adopting a Preventative Approach 
A full review of the Internal Audit Service compliance with GIAS is
currently underway to ensure that the service is compliant with
legislative and regulatory requirements as well as best governance
practice in the public sector. 
Specific audits within the 2025/26 plan will include assessments on
when a preventative approach can be adopted by the Council. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable
development. Internal Audit is a key element of good governance which
is important to enable Midlothian Council to achieve its objectives
including sustainable outcomes.
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INTERNAL AUDIT STRATEGY         APPENDIX 1 
1. STRATEGIC VISION 
1.1. The vision of this strategy is to guide MLC Internal Audit function in delivering a high-quality internal audit
service to Midlothian Council (MLC) and Midlothian Health & Social Care Integration Joint Board (MIJB), which is
capable of: 
• providing the statutory annual assurance and audit opinion on the adequacy of each organisation’s risk
management, internal control and governance arrangements to the relevant organisation’s senior
management and board/audit committee; 
• carrying out all other objectives contained in Internal Audit’s Charter; and 
• adding value to each organisation by influencing and offering ways to enhance the governance and internal
control environment in alignment to their strategic priorities. 
2. STRATEGY OBJECTIVES 
2.1. The objectives of this strategy are to: 
• Outline the assurance framework which comprises assurances from within the organisation and from
external providers of assurance to improve the organisational understanding of the expectations of Internal
Audit; 
• State how the key themes which are integral to the assurance gathering process across the organisation’s
activities will be covered to inform the annual audit opinion statement; 
• Describe the approach to the development of the risk based Internal Audit annual plan; 
• Set out the relative allocation of Internal Audit resources; 
• Outline how the Internal Audit programme of work will be delivered to add value and will be prioritised to
ensure those areas of greatest risk are covered during the audit year; and 
• Describe the monitoring and reporting of the Internal Audit findings from its work and progress with its
plans to the relevant organisation’s audit committee/board. 
3. ASSURANCE FRAMEWORK 
3.1. It is Management’s responsibility to design and maintain proper risk management, governance and internal
control processes and systems to ensure probity in systems and operations, and mitigation of risks, including the
prevention, detection and resolution of fraud and irregularities. Management is also responsible for checking that
the arrangements and controls are operating effectively and obtaining assurances from internal compliance, risk,
inspection, quality, and control functions. These are known as the first and second lines of assurance. Internal Audit,
as the third line of assurance, is the review function which will provide independent assurance on the effectiveness
of the first and second lines of assurance, challenge current practices, recommend best practice and improvements
to lead to a strengthening of the control environment and management of risks, thus assisting the organisation in
achieving its objectives. 
3.2. The organisation’s assurance framework is the means by which the relevant organisation’s Senior Management
and Audit Committee/Board ensures that they are properly informed on the risks of not meeting objectives or
delivering appropriate outcomes and that it has adequate assurances on the design and operation of systems in
place to mitigate those risks. 
3.3. The assurance framework comprises assurances from within the organisation (from Management and
compliance functions, and independent and objective assurance from Internal Audit) and from external providers of
assurance. Examples of the latter include the Accounts Commission, External Audit (Audit Scotland for MLC and
MIJB), Education Scotland, Care Inspectorate, Scottish Housing Regulator, and other regulators. 
3.4. The assurances are considered during the annual review of the effectiveness of each organisation’s overall
governance framework carried out by officers of each organisation and supported by Internal Audit. The output is
the Annual Governance Statement which is included within the relevant organisation’s Annual Report and Accounts. 
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3.5. Where audit assurance is required on services that are delivered jointly by public sector joint working
arrangements which include the organisation as a partner, these assurances will be sought as appropriate from
partners’ Internal Audit service providers and Management. 
4. KEY THEMES INTEGRAL TO INTERNAL AUDIT ASSURANCE 
4.1. Each organisation is responsible for ensuring that its business is conducted in accordance with the law and
proper standards, and that public money is safeguarded and properly accounted for, and used economically,
efficiently and effectively. Fundamentally corporate governance is about the systems and processes, and cultures
and values that are used by the organisation to discharge those responsibilities in a timely, inclusive, open, honest
and accountable manner. This includes: setting the strategic direction, vision, culture and values of the organisation;
effective operation of corporate systems; processes and internal controls; engaging with and, where appropriate,
lead communities; monitoring whether strategic objectives have been achieved and services delivered cost
effectively; and ensuring that appropriate arrangements are in place for the managing risks. 
4.2. The organisation’s statutory financial officer, Section 95 Officer or equivalent, i.e. Chief Financial Officer (MLC)
and Chief Finance Officer (MIJB), is responsible for the proper administration of the organisation’s financial affairs.
Under their direction, the organisation’s system of internal financial control is based on a framework of Financial
Regulations (rules and regulations for financial management or administration arrangements linked to other key
financial documents that set out the policy framework, associated strategy, and the more detailed procedures and
guidelines), regular Management Information, administrative procedures (including segregation of duties),
Management Supervision, and a system of Delegation and Accountability. 
4.3. The continued use of and investment in technology to support service delivery, and digital change and
transformation to improve operations is a key part of the vision for each organisation. Arrangements in place are
underpinned by the overarching framework of the ICT security policy designed to ensure that computer systems are
secure, reliable and conform to nationally agreed standards, and by the ICT Strategy linked to Corporate Priorities
designed to support effective and modern service delivery and to meet service objectives. 
5. APPROACH TO PERIODIC PLANNING 
5.1. The Internal Audit Strategy and the Internal Audit Annual Plan 2025/26 has been prepared in conformance with
the Global Internal Audit Standards to fulfil the requirement to produce the statutory annual assurance and audit
opinion for each organisation. 
5.2. As part of the Internal Audit planning process, it was necessary to consider each organisation’s priorities, plans,
strategies, objectives, risks and mitigating controls, and the internal and external assurances provided to determine
the priorities of the Internal Audit activity consistent with the organisation’s goals, as follows: 
• Analysis was undertaken of Internal Audit work during the past 5 years against the Audit Universe, which
has been significantly revised and realigned to reflect the current strategic and operational management
arrangements and approach to service delivery, to ensure appropriate coverage; 
• The Strategic Risk Profile was checked to confirm coverage on key strategic risks, as reliance is placed on the
risk assessments carried out by the Risk Owners taking account of the risk ratings and mitigations;
• Where service level risk management processes were not sufficiently up to date or mature to provide timely
reporting on risks Internal Audit undertake there won risk assessment processes to establish levels of risk;
and 
• Account was taken of known external audit and inspection activities to avoid duplication of assurance work;
however this may fall short of the level of co-ordination required under GIAS standard 9.5 Coordination and
Reliance. 
5.3. The audit planning process involves consultation with key stakeholders including discussions with Senior
Management of each organisation to capture potential areas of risk and uncertainty more fully. This is of particular
importance during a period of change and transformation as each organisation responds to new legislation or
service delivery arrangements that might affect plans, priorities and resources. 
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6. ALLOCATION OF INTERNAL AUDIT RESOURCES 
6.1. The Internal Audit staff resource totalling 3.22 FTE comprises Chief Internal Auditor (0.5 FTE), Principal Internal
Auditor (0.72 FTE) and Internal Auditor (2.0 FTE). Each member of the Internal Audit team has a professional internal
audit or accountancy qualification, and has suitable experience, knowledge, skills and competencies (such as the
training on the requirements of GIAS and the Seven Principles of Public Life) needed to deliver the plan. The
Available Days has been amended to reflect the Internal Audit resources after consideration of estimated annual
leave, public holidays, absence, learning and development (including required professional CPD), and management
and supervision. 
6.2. It is estimated that around 80% of Available Days will be spent on assurance, and legislative and other
compliance activities combined. The Assurance work includes sufficient work across a range and breadth of audit
areas which assure those processes that are currently in place and which Management rely on to deliver services,
and to enable preparation of the required annual audit opinion on the adequacy of the organisation’s control
environment. 
6.3. An estimate of 10% of Available Days will be spent on other activities in support of the Internal Audit function
meeting its wider objectives as set out in the Internal Audit Charter. 
6.4. An estimate of around 4% of Available Days will be utilised on Consultancy activities which support
Management in delivering innovation, change and transformation. Management seek this value added activity
during this unprecedented period of change for Local Government though this allocation reflects a reasonable
estimate of what is actually deliverable within the boundaries of the role of Internal Audit and the resources
available. 
6.5. It is estimated that around 6% of Available Days will be spent on the provision of Internal Audit services to
Midlothian Integration Joint Board (MIJB). This reflects MLC’s contribution of support resources as governance
arrangements have changed in response to statutory partnership working for the provision of health and social care
integration. 
7. APPROACH TO DELIVERY OF PROGRAMME OF WORK 
7.1. To facilitate operational delivery, an Internal Audit Programme of Work will be developed which provides an
indication of when work will be scheduled during the year, taking account of discussions with Senior Management
and the availability of Internal Audit resources. 
7.2. For each Internal Audit, in line with recognised good practice, an Audit Assignment detailing the scope,
objectives and timing will be prepared and agreed with the relevant Chief Officer/Head of Service and Manager
prior to commencement of Internal Audit fieldwork. Within assurance work: 
• The organisation’s Local Code of Corporate Governance (MLC/MIJB) will be used by Internal Audit as an
integrated toolkit to test the extent of compliance. 
• End to end reviews of financial management and administration processes will be undertaken by Internal
Audit to test the extent of compliance (as integral part of protecting public finances, safeguarding assets,
and delivering services effectively and sustainably), and substantive testing of transactions including data
analytics will be carried out where this is possible to ensure completeness and accuracy. 
• The Plans (Financial and Asset Management) to deliver the organisation’s strategies, plans and priorities will
be reviewed against best practice standards. 
• Internal Audit will consider fraud risk and prevention and detection controls, and other appropriate cross-
cutting risks and controls (such as risk management, performance management, community engagement,
equalities, business continuity, and health and safety), highlight examples of effective internal controls, and
share good practice across service areas. 
• The ICT arrangements in place to protect each organisation from attack in relation to data security, integrity
and availability will be tested and ICT Plans will be reviewed to confirm they support delivery of the
organisation’s strategies and priorities. 
• National reports that give rise to introducing best practice arrangements or lessons learned from other local
authorities or other public sector bodies will be considered and applied by Internal Audit to influence and
offer ways to enhance governance and internal controls. 
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7.3. The Legislative and Other Compliance work will include testing in accordance with the terms of the funders’
service level agreements or legislative requirements, as part of the wider assurance framework. 
7.4. Within Advisory activities, Internal Audit will add value to the Council as it transforms its service delivery
models, re-designs its business processes, and utilises technology to automate processes by influencing and offering
ways to ensure adequate governance, risk management and internal controls. Internal Audit in its ‘critical friend’
role will provide an independent view and challenge of a sample of programmes and projects, and an objective
assessment of self-evaluation arrangements and improvement that underpin the provision of Best Value, when
resources allow. 
7.5. Other work will include: 
• Carrying out Follow-Up to monitor Management’s progress with implementation of Audit recommendations
to: ensure that improvement actions have been timeously and effectively implemented; check that these
have had the desired effect to manage identified risks; and demonstrate continuous improvement in
internal control and governance. To facilitate the Internal Audit follow-up activity, Audit recommendations
will continue to be input to the Ideagen system, the corporate performance management system, to assist
relevant Management in tracking and recording their implementation in a consistent way; 
• Performing Contingency advisory reviews on specific instruction from Members or Senior Management,
investigations and review of sufficiently important issues highlighted during the year were resources allow;
and 
• Delivering the Help Desk Facility where Internal Audit guidance and advice is given to Management on
internal controls. 
8. MONITORING THE WORK OF INTERNAL AUDIT 
8.1. The Global Internal Audit Standards (GIAS) requires periodic reporting on the Internal Audit activity to the
relevant organisation’s Senior Management and Audit Committee/Board. 
8.2. Internal Audit assurance work completed and work in progress, and consultancy and other work for the Council
associated with the delivery of the Plan will be outlined within regular reports to its Audit Committee. Specifically
relating to Internal Audit assurance work, this report will include an Executive Summary of the audit objective, good
practice, findings, recommendations, and audit opinion of assurance for each Final Internal Audit Report issued to
relevant Senior Management in the period. 
8.3. Regular progress updates on implementation by Management of relevant Audit recommendations will be
reported periodically during the year to the relevant organisation’s Senior Management and Audit
Committee/Board. 
8.4. Internal Audit’s compliance with its Strategy, delivery of its risk-based Annual Plan, and outcomes of
assessment(s) against GIAS will be considered by the Chief Internal Auditor on a regular basis and formally reported
every six months to the Council’s Corporate Management Team and the Audit Committee, through a Mid-Term
Performance Report and within the Annual Assurance Report. 
8.5. The Internal Audit Annual Assurance Report for each organisation (Midlothian Council and MIJB) to their
respective Senior Management and Audit Committee/Board will provide the statutory annual audit opinion on the
levels of assurance based on Internal Audit findings over the year to inform each organisation’s Annual Governance
Statement. 
8.6. The GIAS requires an annual Internal Self-Assessment and an External Quality Assessment (EQA) each five years
by appropriately qualified and independent reviewers to assess conformance with the Global Internal Audit
Standards, as well as performance measurement to assess the internal audit function’s progress toward the
achievement of its objectives and promotion of continuous improvement. The program also will assess, if applicable,
compliance with laws and/or regulations relevant to internal auditingThe Scottish Local Authorities Chief Internal
Auditors Group (SLACIAG) have implemented a “peer review” framework, in which MLC participates, as a cost-
effective means of complying with the EQA requirement. Reporting on outcomes includes a statement on
conformance with GIAS and the quality assurance and improvement plan (QAIP) to enable an evaluation of the
Internal Audit quality management framework and to identify opportunities for improvement. 
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Internal Audit Annual Plan 2025/26       Appendix 2
Category Activity Days Commentary
Assurance -
Cyclical
MLC Annual
Assessment of
Internal Control
and Governance
30
Prepare an annual assurance report for
Management and the Audit Committee
summarising the work undertaken by
Internal Audit during the year and forming
an opinion on adequacy of the Council’s
arrangements for risk management,
governance and internal control.
Continuous audit approach on progress
with areas of improvement. Annual
evaluation of compliance with the Local
Code of Corporate Governance covering
the corporate whole and individual
Directorates/Services.
Assurance -
Risk
School Funds /
School Budgets
(DSM)
30
Review the processes in place to ensure
appropriate management and controls
processes are in place for school budgets
(DSM) and school funds. 
Assurance -
Risk
Recruitment &
Use of Agencies  30
Review the processes in place to ensure
that staff recruitment is completed
effectively and protects Midlothian Council
from the risk of employment of
inappropriate or unqualified staff members
or agency workers, whilst meeting
legislative requirements. 
Assurance -
Risk
Property assets
and property
strategy -
Midlothian House
refurbishment
30
Review the processes of developing a
property asset management strategy
across the Council specifically including
the refurbishment of Midlothian House. 
Assurance -
Risk
Purchase to Pay
(Accounts
Payable) &
Electronic
Payments
30
Review the control process in place
around the Council’s Purchase to Pay
system to ensure that they are operating
effectively and providing assurance that all
expenditure is appropriately processed
through systems and is being correctly
authorised in accordance with the financial
control processes of the Council.  
Assurance -
Risk School Transport 30
Review the controls in place to ensure that
the Council is meeting legislative
requirements for School Transport whilst
providing Best Value and that Governance
processes ensure that this is appropriately
monitored and adjusted as required. 
Assurance -
Risk
Fleet
Management 30
Review of the controls, governance and
compliance processes in place to ensure
that Council vehicles are being adequately
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Category Activity Days Commentary
and professionally managed in line with
legislative and regulatory requirements.  
Assurance -
Risk Mosaic 30
Review the case management, payment
processes and social care systems
resilience within and associated with the
core social work Mosaic application.  
Assurance -
Risk
Council Tax
Billing 30
Review the control processes in place to
ensure accurate, timely, complete and
appropriate Council Tax billing
arrangements, in line with appropriate
regulatory and legislative requirements. 
Assurance -
Cyclical
Direct Payments -
Self Directed
Support
30
Review that the controls in place for Direct
Payment for Social Care self-directed
support provide appropriate governance
risk management and control to ensure
best value and meet legislative and best
practice requirements. 
Assurance -
Cyclical House Rents 30
Review that controls in place for housing
rents ensure that complete, accurate and
timely charging and collection processes
for housing rents in line with legislative
and best practice requirements. 
Assurance -
Cyclical Project Support  30
To review the Governance and internal
controls in place to ensure best value in
the use of resource to manage constant
change to achieve council objectives.    
Consultancy Consultancy 
10
In its ‘critical friend’ role provide: an
independent view and challenge of a
sample of programmes and projects
(including Capital Plan and Asset
Management Boards, Business
Transformation Board, Information
Management Group); and an objective
assessment of self-evaluation
arrangements. 
Other MLC Audit
Committee Self-
Assessment 5
Provide assistance to the Chair in
undertaking a self-assessment of the
Audit Committee against the CIPFA best
practice guidance.
Assurance -
Cyclical
MLC
Recommendation
Follow Up
Reviews 25
Undertake 2 reviews: the first includes a
sample check on the adequacy of new
internal controls for Audit Actions flagged
as closed, and the second assesses
performance against closing Audit Actions
by the agreed due date. 
Other Contingency 
16
Support / undertake any investigations
and other reactive work to ensure high risk
issues and concerns identified by
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Category Activity Days Commentary
Management or Audit Committee during
the year are appropriately addressed.
Other Help Desk
Enquiry system  15
Provide guidance and advice to
Management and Staff on internal
controls. 
Other MLC
Administration of
Audit Scotland
Reports
5
Monitor publication of Audit Scotland
reports and co-ordinate submission by
Management of Audit Scotland Reports to
the relevant Committee. 
Other Risk Management
& Integrity Group 15
Attend and provide support to the Risk
Management Group, and the Integrity
Group.
Other MLC Attendance
at Boards /
Committees
20
Prepare for and attend Audit Committee
meetings and other Boards/Committees
as relevant.
Other MLC Audit
Planning for
2026/27 10
Update the Audit Universe, check risk
registers and other sources of assurance,
and develop and consult on proposed
coverage within the Internal Audit Annual
Plan 2024/25.
MIJB
Assurance
Midlothian Health
and Social Care
Integration Joint
Board
30
Audit reviews and support to be
determined and agreed by the Midlothian
Health and Social Care Integration Joint
Board Audit and Risk Committee for
review of the adequacy of the MIJB’s
arrangements for risk management,
governance and internal control for
delegated resources.    
Total Days 2025/26 511 
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Audit Committee
Monday 24 March 2025
Item No 5.8 
Counter Fraud Annual Plan 2025/26 
Report by Duncan Stainbank, Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is invited to:
a) Approve the Counter Fraud Annual Plan 2025/26 (Appendix 1). 
2 Purpose of Report/Executive Summary 
The purpose of this report is to gain approval from the Audit Committee
for the proposed Counter Fraud Annual Plan 2025/26 to support the
delivery of the Council’s Counter Fraud Strategy and to demonstrate
compliance with the Council’s Counter Fraud Policy Statement. 
Having robust fraud risk management prevention and investigation
arrangements in place contributes to safeguarding the Council’s
financial resources, for delivery of services, as part of protecting the
public purse. A focus on enhancing fraud prevention and detection to
improve Midlothian Council’s resilience to the risk of fraud, theft,
corruption and crime, and ensure these are embedded preventative
practices as specific changes associated with the Counter Fraud
Strategy approved by Council in August 2020. 
The Counter Fraud Annual Plan 2025/26 (Appendix 1) sets out the
planned counter fraud activity to support the approach and culture of
the Council in tackling fraud and corruption to deliver the Counter
Fraud Strategy. This will enable the Council to demonstrate compliance
with its Counter Fraud Policy Statement as its commitment to tackling
fraud and reflects the Integrity Group’s assessment of counter fraud
controls. 
Date 10 February 2025 
Report Contact:
Duncan Stainbank  
duncan.stainbank@midlothian.gov.uk
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3 Background 
3.1 A review was carried out in 2019/20 of counter fraud management
arrangements in place and to make improvements in light of the
significant fraud investigations that have occurred within Midlothian
Council in recent years, noting that some are ongoing. 
3.2 The conclusion of the review included a refresh to the corporate policy
and strategy for tackling fraud. A revised Counter Fraud Policy
Statement and Counter Fraud Strategy and proposal to have 2 FTE
Corporate Fraud Officers to deliver the revised Counter Fraud Policy
and Strategy were approved by Midlothian Council in August 2020. 
4        Counter Fraud Annual Plan 2024/25 
4.1 Having robust fraud prevention and investigation arrangements in place
contributes to safeguarding the Council’s financial resources, for
delivery of services, as part of protecting the public purse. A focus on
enhancing fraud prevention and detection to improve Midlothian
Council’s resilience to the risk of fraud, theft, corruption and crime
(including cybercrime and money laundering) and ensure these are
embedded preventative practices as specific changes associated with
the Counter Fraud Strategy approved by Council in August 2020. 
4.2 The Counter Fraud Annual Plan 2025/26 (Appendix 1) sets out the
planned Counter Fraud activity to support the change in approach and
culture for the Council for tackling fraud and corruption to deliver the
approved Counter Fraud Strategy. This will enable the Council to
demonstrate compliance with its Counter Fraud Policy Statement as its
commitment to tackling fraud and reflects the Integrity Group’s
assessment of counter fraud controls (update submitted to the Audit
Committee in January 2022). 
5 Report Implications (Resource, Digital, Risk and Equalities) 
5.1 Resource 
The primary responsibility for the prevention, detection and
investigation of fraud rests with Management, supported by the
Integrity Group and the Corporate Fraud Team. 
The purpose of the Integrity Group is to improve the Council’s
resilience to fraud, corruption, theft and crime (including cybercrime
and money laundering). The formal establishment of the Integrity
Group with a Terms of Reference (approved by the Audit Committee on
22 June 2020) enables the shift to more holistic working in multi-
disciplinary forums to tackle fraud in a consistent and collaborative way
across the Council.   
The revised Counter Fraud Policy Statement and Counter Fraud
Strategy and proposal to have 2 FTE Corporate Fraud Officers to
deliver the revised Counter Fraud Policy and Strategy were approved
by Midlothian Council in August 2020. The 2 Corporate Fraud Officers
are line managed by the Principal Internal Auditor who reports to the
Chief Internal Auditor.
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Savings will continue to be identified arising from Corporate Fraud
Team activity, which will be stated within the Counter Fraud Annual
Reports presented to the Audit Committee. 
5.2 Digital 
None. 
5.3 Risk 
The Council is committed to minimising the risk of loss due to fraud,
theft, corruption or crime and to taking appropriate action against those
who attempt to defraud the Council, whether from within the authority
or from outside. 
The Counter Fraud Policy Statement sets out the roles and
responsibilities for the prevention, detection and investigation of fraud.
The Counter Fraud Strategy provides a shift in approach to focus on
enhancing fraud prevention and detection to improve Midlothian
Council’s resilience to the risk of fraud. The work undertaken by the
Corporate Fraud Team in collaboration with other Services is designed
to reduce the fraud risks within the Council. 
5.4 Ensuring Equalities 
An Integrated Impact Assessment (IIA) Form was completed as part of
the development of the revised Counter Fraud Policy and Strategy. The
conclusion was that undertaking a Combined Impact Assessment was
not necessary as the policy / proposal has little relevance to equality,
negligible impact on the economy, and no impact on the environment.
The revised Counter Fraud Policy and Strategy set out enhancements
to internal Management arrangements though it is anticipated that
there will be minimal impact on internal staff only; there is no change to
the Whistleblowing external-facing arrangements. 
5.5 Additional Report Implications (See Appendix A)
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan (Reducing the gap in economic
circumstances; Reducing the gap in learning outcomes; Reducing the
gap in health outcomes; and Reducing the impact of climate change)
by preventing and detecting fraud, additional resources might be
available to support the Council’s objectives. Any loss of funds due to
fraud, theft, corruption or crime might impact on the ability of Midlothian
Council to achieve its key priorities. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow
supported by the 9 drivers for change. Implementing the 9 drivers for
change in practice is applicable to the Council’s arrangements for
tackling fraud as set out in the Counter Fraud Policy Statement and
Counter Fraud Strategy that were approved by Council in August 2020.
The shift to the key drivers for change is an intrinsic part of the change
in approach and culture for the Council for tackling fraud and
corruption. For example:
(a) The formal establishment of an Integrity Group with a Terms of
Reference (approved by the Audit Committee in June 2020) shifting
to more holistic working in multi-disciplinary forums to tackle fraud
in a consistent and collaborative way across the Council;
(b) A focus on enhancing fraud prevention and detection to improve
Midlothian Council’s resilience to the risk of fraud, theft, corruption,
and crime and ensure these are embedded preventative practices; 
(c) Applying the minimum standard within the CIPFA Code of Practice
on ‘Managing the Risk of Fraud and Corruption (2014)’ for counter
fraud policy, strategy and other practices, and adopting the CIPFA
Counter Fraud Maturity Model as a means of self-assessment
moving forward will enable continuous improvement to be
evaluated, managed and evidenced; and
(d) Use of a blend of toolkits such as fraud risk assessments and e-
learning packages that can be tailored to specific Services. 
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A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
Having robust fraud prevention and investigation arrangements in place
contributes to safeguarding the Council’s financial resources, for
delivery of services, as part of protecting the public purse. The
approved Counter Fraud Strategy states the Council will measure
progress against the CIPFA Counter Fraud Maturity Model as a self-
assessment approach to continuous improvement in order to
continuous improvement to be evaluated, managed and evidenced
demonstrate best value in the use of resources. 
A.5 Involving Communities and Other Stakeholders 
Ensuring awareness of the Whistleblowing facility to report areas of
concern is important in the approach to tackling fraud. The facility has
been promoted in recent years and is being utilised, as stated in the
Counter Fraud Annual Report 2023/24 that reported outcomes of
corporate fraud activity, some of which arose from whistleblowing
received from staff, those within communities or other stakeholders. 
A.6 Impact on Performance and Outcomes 
The primary responsibility for the prevention, detection and
investigation of fraud rests with Management, supported by the
Integrity Group and the Corporate Fraud team. Internal Audit provides
advice and independent assurance on the effectiveness of processes
put in place by Management. The Findings and Recommendations
from Internal Audit and Corporate Fraud work which are presented to
the Audit Committee during the year assists the Council in maintaining
and / or enhancing fraud prevention and detection controls. 
A.7 Adopting a Preventative Approach 
Having robust fraud prevention and investigation arrangements in place
contributes to safeguarding the Council’s financial resources, for
delivery of services, as part of protecting the public purse. A focus on
enhancing fraud prevention and detection to improve Midlothian
Council’s resilience to the risk of fraud, theft, corruption and crime, and
ensure these are embedded preventative practices are specific
changes associated with the approved Counter Fraud Strategy. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable
development. Good governance is important to enable Midlothian
Council to achieve its objectives including sustainable outcomes.
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Midlothian Council Counter Fraud Annual Plan 2025/26          Appendix 1
Ref Category Activity Number
of Days
Commentary
1. Compliance Contract
Management
30 Data analytics to test governance and internal controls in place over Contract
Management arrangements with third parties to assess compliance with
procurement rules.
2. Compliance Corporate Fraud
Enquiries
100 Respond to whistleblowing notifications. 
3. Data Match National Fraud
Initiative
100 Co-ordinate the NFI exercise across Council services, investigate data
matches from 2024/25 exercise, coordinate and provide update of data
matches reviewed for 2024/25 exercise.  
4. Compliance Social Housing 30 Social Housing enquiries and investigations.
5. Compliance Council Tax  15 Council Tax enquiries and investigations.
6.  Other Corporate Fraud
Policy Framework
15  Support the Integrity Group with monitoring of policies and procedures review,
update and communication.
7. Other Fraud Risk
Assessments
100 Develop a risk assessment process and support operational Service Managers
to assess fraud risks and develop improved mitigating controls in preparation
for the implementation of government guidance on the implementation of UK
government guidance on the Crime of Failure to Prevent Fraud. 
8. Other Fraud Awareness
Training
10 Develop and deliver fraud awareness training modules (face-to-face, virtual or
via e-learning) to Management and Staff as required. 
9. Other Integrity Groups 6 Attend and provide support to the Council’s Integrity Group.  
Corporate Fraud Total 406 
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Audit Committee 
Monday 24 February 2025
Item No 5.9 
Audit Committee Recruitment of an Independent Member 
Report by Duncan Stainbank, Chief Internal Auditor 
Report for Decision 
1 Recommendations 
Audit Committee is recommended to: 
• Note the contents of the report, informed by the Audit Committee
Annual/End of Term Report 2023/24; and
• Provide comments on the proposal to remunerate Independent
Members to inform Council’s decision on Tuesday 25 February
2025. 
2 Purpose of Report/Executive Summary 
2.1 The Audit Committee Annual/End of Term Report 2023/24, by the
Chair of the Audit Committee as approved by the Audit Committee on
the 30 September 2024 had recommended improvements for the Audit
Committee. Section 4.2 of that approved report contained the following
2 recommendations: 
• Schedule a recruitment, selection and appointment process for
independent members of the Audit Committee within the next year. 
• Move to 4 scheduled meetings of the Audit Committee each year
from the 7 meetings currently scheduled, whilst retaining the
capability to call further meetings when required. 
2.2 The CIPFA Position Statement 2022: Audit committees in local
authorities and police states, the following: “CIPFA recommends that
each authority audit committee should include at least two co-opted
independent members to provide appropriate technical expertise.” This
is the standard that the Audit Committee annually assesses against
and currently there are no independent members of the Midlothian
Council Audit Committee. 
2.3 A recruitment advert for an Independent Audit Committee Chair and
Member was issued in May 2022, however no candidates applied for
these positions, as a result agreement to rotate the Chair across the
three political parties was agreed. Since May 2022 the Audit
Committee has been Chaired by three separate Councillors.  The
CIPFA Position Statement 2022: Audit committees in local authorities
and police, states under characteristics of audit committee
membership: 
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2
“A strong, independently minded chair, displaying a depth of
knowledge, skills, and interest. There are many personal skills needed
to be an effective chair, but key to these are:
• promoting apolitical open discussion
• managing meetings to cover all business and encouraging a
candid approach from
• all participants maintaining the focus of the committee on
matters of greatest priority.” 
2.4 The CIPFA Position Statement 2022: Audit committees in local
authorities and police provides no statement that the Chair of the Audit
Committee should be an independent member. The CIPFA Publication
Practical Guidance for Local Authorities and Police Guiding the Audit
Committee, states the following on appointing the Chair of the Audit
Committee. 
“Unless there is specific legislation or guidance in place on the
selection of the committee chair, authorities can determine their own
approach. To try and emphasise the independence and apolitical
nature of the committee, some authorities specify that the position
should be occupied by an ‘opposition’ member. This approach may be
appropriate for some but will not be possible for all authorities – for
example, where there are few opposition members.” 
2.5  It is therefore being recommended that a permanent chair is appointed
following on from a recruitment exercise as early as possible in 2025.
The Audit Committee should then be empowered to appoint a chair
meeting the required skills from within the membership of the
committee rather than appointing a chair directly from any recruitment
exercise. 
2.6 Given the lack of candidates applying for Independent Member
positions at the last attempt in 2022 a review of other authorities and
public sector bodies has been undertaken. Scottish Local Authorities
have not normally provided renumeration for Independent Audit
Committee Members although limited Councils have independent
members in place. However, other UK Local Authorities are beginning
to offer renumerated roles, for example currently the London Borough
of Hounslow are offering an annual allowance of £2,000 for
Independent Members of the Audit & Governance Committee, Wealden
District Council offering an annual allowance of £909, Mole Valley
District Council offering £530 per annum, and Oldham Council offering
£446 per annum. Consideration should be given to a small allowance
being offered for an appropriate independent member candidate, with a
mechanism to be agreed via the Chief Officer Council Resources.       
Date: 14 January 2025 
Report Contact: 
Duncan Stainbank  Tel No 01620 827353
duncan.stainbank@midlothian.gov.uk 
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3 
3 Background/Main Body of Report 
3.1 It is important that the Council’s Audit Committee fully complies with
best practice guidance on Audit Committees to ensure it can
demonstrate its effectiveness as a scrutiny body as a foundation for
sound corporate governance for the Council. 
3.2 The Chartered Institute of Public Finance and Accountancy (CIPFA)
issued an updated guidance note Audit Committees Practical Guidance
for Local Authorities and Police 2022 Edition (hereinafter referred to as
CIPFA Audit Committees Guidance). It incorporates CIPFA’s Position
Statement: Audit Committees in Local Authorities and Police which sets
out CIPFA’s view of the role and functions of an Audit Committee. 
3.3 The CIPFA Audit Committees Guidance includes the production of an
annual report on the performance of the Audit Committee against its
remit for submission to the Council. 
3.4 The Audit Committee Self-Assessment as approved by the Audit
Committee on the 30 September 2024 identified 2 improvements that
require changes to the Scheme of Administration as laid out in the
recommendations in 1. Above. These are: 
• Schedule a recruitment, selection and appointment process for
independent members of the Audit Committee within the next year. 
• Move to 4 scheduled meetings of the Audit Committee each year
from the 7 meetings currently scheduled, whilst retaining the
capability to call further meetings when required. 
4 Report Implications (Resource, Digital and Risk) 
4.1 Resource 
The report recommends following benchmarking that the two
Independent Members are provided an allowance of £200 per Audit
Committee, prepared for and attended. Total cost is estimated as
between £1,600 and £2,000 per annum.   
4.2 Digital 
There are no digital implications arising from this report. 
4.3 Risk 
There is a risk that the Audit Committee does not fully comply with best
practice guidance thus limiting its effectiveness as a scrutiny body as a
foundation for sound corporate governance. The implementation of the
recommendations ensure that the best practice is being adhered to. 
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4
4.4 Ensuring Equalities (if required a separate IIA must be completed) 
This report does not relate to a new or revised policy, service or budget
change, which affects people (the public or staff), so an Integrated
Impact Assessment (IIA) is not an applicable consideration. 
4.5 Additional Report Implications (See Appendix A) 
Appendices 
Appendix A – Report Implications
Appendix B - Revised Audit Committee Extract from the Scheme of
Administration. 
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5
APPENDIX A – Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan to which Midlothian Council and its
Community Planning Partners have made a commitment (Reducing the
gap in economic circumstances; Reducing the gap in learning
outcomes; Reducing the gap in health outcomes; and Reducing the
impact of climate change), good governance is important to enable
Midlothian Council to deliver its key priorities in support of achieving the
Council’s objectives. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working 
Hub and Spoke  
Modern  
Sustainable 
Transformational 
Preventative 
Asset-based  
Continuous Improvement 
One size fits one 
None of the above 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
None of the above 
A.4 Delivering Best Value 
Self-assessment of the Audit Committee utilising best practice toolkits
underpins its own continuous improvement to enhance its effectiveness
as a scrutiny body as a foundation for sound corporate governance of
the Council, thus supporting the delivery of the Council’s best value
duties. 
A.5 Involving Communities and Other Stakeholders 
The Audit Committee in fulfilling its governance role acts as a bridge
between the Council and other stakeholders. Including Independent
members on the Committee should enhance this role further. 
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6
A.6 Impact on Performance and Outcomes 
The members of the Audit Committee have reflected on the
performance and outcomes against the remit of the Committee through
the completion of annual self-assessments. The identification of
improvement actions as evidenced through the Audit Committee
Annual / End of Term Report are designed to enhance its effectiveness
as a scrutiny body as a foundation for sound corporate governance of
the Council. 
A.7 Adopting a Preventative Approach 
Assurances received by the Audit Committee from Management,
Internal Audit and External Audit set out the assessment of prevention
and detection internal controls and governance arrangements. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable
development. Good governance is important to enable Midlothian
Council to achieve its objectives. 
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Appendix B: Audit Committee Scheme of Administration Extract
Proposed Changes 
Composition:
The Audit Committee will comprise 5 Elected Members, currently on the
following basis: 
• 2 Labour Members
• 2 SNP Members
• 1 Conservative Member 
The Audit Committee will have an Independent Chair whose appointment will
be made by the Council on the submission of a report from the Chief Executive. 
Pending the appointment, or in the absence, of the Independent Chair, the
Committee will be chaired by an elected Member of the Audit Committee, who
can be an Elected Member or a non-voting independent member or a non-
Cabinet Elected Member agreed by the voting members of the Committee
meeting who is a non-Cabinet member. 
The Committee will also include twoone independent non-voting members to be
appointed by the Council on a report by the Chief Executive. At the invitation of
the Chair, Tthe Independent members is person can comment on all aspects of
the Committee’s business in order to assist it in its deliberations. 
Business:
Statement of purpose
1. The audit committee is a key component of Midlothian Council’s
corporate governance. It provides an independent and high-level focus
on the audit, assurance and reporting arrangements that underpin
good governance and financial standards.
2. The purpose of the audit committee is to provide independent
assurance to elected members of the adequacy of the risk
management framework and the internal control environment. It
provides independent review of Midlothian Council’s governance, risk
management and control frameworks and overseas the financial
reporting and annual governance processes. It oversees internal and
external audit, helping to ensure efficient and effective assurance
arrangements are in place.
Governance, risk and control
3. To review the council’s corporate governance arrangements against
the good governance framework and consider annual governance
reports and assurances, relating to the council’s service delivery
models including partnership and collaboration, to ensure that the
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highest standards of probity, public accountability and ethical
standards are demonstrated. 
4. To review the Annual Governance Statement prior to approval and
consider whether it properly reflects the risk environment and
supporting assurances, taking into account internal audit’s opinion on
the overall adequacy and effectiveness of the council’s framework of
governance, risk management and control. 
5. To consider the council’s arrangements to secure value for money and
review assurances and assessments on the effectiveness of these
arrangements.
6. To consider the council’s framework of assurance, relating to the
council’s service delivery models including partnership and
collaboration, and ensure that it adequately addresses the risk and
priorities of the council.
7. To monitor the effective development and operation of risk
management in the council relating to the council’s service delivery
models including partnership and collaboration.
8. To monitor progress in addressing risk-related issues reported to the
committee.
9. To consider reports on the effectiveness of internal controls and monitor
the implementation of agreed actions.
10. To review the assessment of fraud risks and potential harm to the
council from fraud corruption.
11. To monitor the counter-fraud strategy, actions and resources. 
12. To monitor controls operating over Treasury Management, through the
scrutiny of the treasury management strategy, mid-term and annual
performance reports prior to their presentation to Council for approval,
and the Council’s approach to establishing ethical standards.
Internal audit
13. To approve the internal audit charter. 
14. To review proposals made in relation to the appointment of external
providers of internal audit services and to make recommendations.
15. To approve the risk-based internal audit plan, including internal audit’s
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resources requirements, the approach to using other sources of
assurance and any work required to place reliance upon those other
sources.
16. To approve significant interim changes to the risk-based internal audit
plan and resource requirements.
17. To make appropriate enquiries of both management and the Chief
Internal Auditor to determine if there are any inappropriate scope or
resource limitation.
18. To consider reports from the Chief Internal Auditor on internal audit’s
performance during the year, including the performance of external
providers of internal audit services. These will include: 
a) Updates on the work of internal audit including key findings, issues
of concern and action in hand as a result of internal audit work.
b) Regular reports on the results of the Quality Assurance and
Improvement Programme.
c) Reports on instances where the internal audit function does not
conform to the Public Sector Internal Audit Standards and Local
Government Application Note, considering whether the non-
conformance is significant enough that it must be included in the
Annual Governance Statement.
19. To consider the Chief Internal Auditor’s annual report:
a) The statement of the level of conformance with the Public Sector
Internal Audit Standards and Local Government Application Note
(including code of ethics) and the results of Assurance and
Improvement Programme that supports the statement – these will
indicate the reliability of the conclusions of internal audit.
b) The opinion on the overall adequacy and effectiveness of the
council’s framework of governance, risk management and control
together with the summary of the work supporting the opinion -
these will assist the committee in reviewing the Annual Governance
Statement.
20. To consider summaries of specific internal audit reports as requested.
21. To receive reports outlining the action taken where the Chief Internal
Auditor has concluded that management has accepted a level of risk
that may be unacceptable to the authority or there are concerns about
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progress with the implementation of agreed actions.
22. To contribute to the Quality Assurance and Improvement Programme
and in particular, to the external quality assessment of internal audit
that takes place at least once every five years.
23. To consider a report on the effectiveness of internal audit to support the
Annual Governance Statement.
24. To support the development of effective communication with the Chief
Internal Auditor.
External audit
25. To consider the external auditor’s annual letter, relevant reports, and
the report to those charged with governance.
26. To consider specific reports as agreed with the external auditor. 
27. To comment on the scope and depth of external audit work and
to ensure it gives value for money.
28. To commission work from internal and external audit. 
29. To advise and recommend on the effectiveness of relationships
between external and internal audit and other inspection
agencies or relevant bodies.
Financial Reporting
30. To review the annual statement of accounts. Specifically, to
consider whether appropriate accounting policies have been
followed and whether there are concerns arising from the
financial statements or from the audit that need to be brought to
the attention of the Council.
31. To consider the external auditor’s report to those charged with
governance on issues arising from the audit of the accounts.
Accountability arrangements
32. To report to those charged with governance on the committee’s
findings, conclusions and recommendations concerning the
adequacy and effectiveness of their governance, risk
management and internal control frameworks; financial
reporting arrangements, and internal and external audit
functions.
33. To report to full council on a regular basis on the committee’s
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performance in relation to the terms of reference and the
effectiveness of the committee in meeting its purpose. 
Frequency of meetings:
The Council will decide on the schedule of meetings for the Audit Committee,
usually on a rolling annual basis which will be published.A minimum of 4
meetings will be held on an annual basis. 
Quorum:
The quorum for meetings of the Audit Committee will be 3  Members, including
at least 2 Voting Members.which may include the Independent Chair (when
appointed). 
Minutes:
The Minutes of the Audit Committee will be recorded by the Officer clerking the
meeting and submitted to the next ordinary meeting of the Committee for
approval. They will also be submitted to the Council both for information and to
allow the Council to consider any recommendations contained in them. Meetings
of the Audit Committee will also be audiocast subject to the exemptions
contained within the Local Government (Scotland) Act 1973. 
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Audit Committee 
Monday 24 February 2025
Item No 5.10 
Risk Management Update – Strategic Risk Profile Quarter 2&3, 2024-25 
Report by Derek Oliver, Chief Officer Place 
Report for Information 
1 Recommendations 
Audit Committee is recommended to: 
• Note the current risk landscape and organisational response to
the most significant risks in Quarter 2 (Q2) 2024-25 (1st Jul to
30th Sep 2024) and in Quarter 3 (Q3) 2024-25 (1st Oct to 31st
Dec 2024). 
2 Purpose of Report/Executive Summary 
The purpose of this report is to provide Audit Committee with: 
• An update on the risk responses Midlothian Council has
implemented during Q2 and Q3 2024/25 to respond to the
current risk climate
• Assurance that Midlothian Council took a proportionate and
planned approach to prepare and respond to the current risk
climate
• The risk evaluation of current strategic risks and opportunities
for the Council 
7 February 2025 
Report Contact:
Derek Oliver, Chief Officer Place
Derek.Oliver@midlothian.gov.uk 
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2 
3 Q2 & Q3 Risk Management Overview 
3.1 Midlothian Council has delivered a wide range of services to the people
of Midlothian throughout Quarter 2 & 3, 2024-25. 
3.2 The Council continues to manage and review risks recorded within the
Strategic Risk Profile. The work required to maintain the necessary
corporate oversight over the broader strategic landscape continues
through the Risk and Resilience Chief Officer Group and Corporate
Management Team (CMT). 
3.3 Audit Committee should note that there were no new risks added from
the previous Quarter however, as per the request from Audit
Committee, the Strategic Opportunities section was revised to include
Strategic Projects.  The Projects included have a Red category across
their respective Risk Evaluation. Updates on actions taken are included
in the full strategic risk profile (Appendix B). 
3.4 Strategic Risk Profile (SRP) 
The SRP is split into three sections:
• Strategic issues
• Strategic risks
• Opportunities 
3.5 STRATEGIC ISSUES - SUMMARY 
Strategic issues Likelihood Impact Score Evaluation 
Q2 Q3
The Change Programme 5 5 25 Critical Critical
Financial Sustainability 5 5 25 Critical Critical
National Care Service N/A N/A N/A   
3.6 The Change Programme 
The Change Programme remains evaluated at Critical. The financial
challenges of the forecasted budget gap pose a significant challenge
for benefits realisation. Council agreed to a Transformation Blueprint in
June 2023 which is a 5-year transformation plan. 
3.7 Financial Sustainability 
The scale of the financial challenge continues to be reported to the
Business Transformation Steering Group and Council. 
3.8 National Care Service 
The Scottish Government announced in January 2025 that the National
Care Service proposal is now not proceeding. 
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3 
3.9 STRATEGIC RISKS – SUMMARY 
Strategic Risks Likelihood Impact Score Evaluation
Q3 24-25  Q2 24-25
Climate Change 5 5 25 Critical  Critical
Financial Sustainability in
future years 5 5 25 Critical  Critical
The Long-Term Change
Programme 5 5 25 Critical  Critical
Legal and Regulatory
compliance 5 5 25 Critical  Critical
UK decision to leave the EU 4 5 20 High  High
Scottish Child Abuse Inquiry 4 4 16 High  High
Growing Council 4 4 16 High  High
Cost of Living Crisis 3 5 15 Medium  Medium
Asset Management 3 5 15 Medium  Medium
Cyber Security 3 5 15 Medium  Medium
Health and Safety 3 5 15 Medium  Medium
Care at Home 3 4 12 Medium  Medium
Employee performance 3 4 12 Medium  Medium
Emergency planning and
business continuity 3 4 12 Medium  Medium
Governance and Standards 2 4 8 Low  Low
Internal control environment 2 3 6 Low  Low
Corporate policies and
strategies 2 3 6 Low  Low 
3.10STRATEGIC RISKS – RATED CRITICAL/HIGH 
3.11 Climate Change 
Councillors were presented with a briefing on the Climate Action Plan
in Q2 24-25 as committed to through the Transformation Blueprint. 
With a report presented to October Council, Councillors approved,
given the challenges (particularly financial), the realignment of the
target deadline of 2030 for net zero emissions from the Midlothian
Council estate to 2045.   
.
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4 
In light of this, a refresh of the Council’s Climate Change Strategy,
approved by Council in August 2020, is progressing. 
3.12 Financial Sustainability in future years 
The scale of the financial challenge continues to be reported to
Business Transformation Steering Group and Council. 
3.13 The Long-Term Change Programme
The Change Programme has remained at Critical for the last 2 years.
The financial challenges of the underlying budget gap pose a
significant challenge. Council agreed to a Transformation Blueprint in
June 2023 which is a 5-year transformation plan. 
3.14 Legal and Regulatory compliance
Significant resourcing pressures have impacted on risk evaluation. 
Work is ongoing with the Scottish Information Commissioner and
National Records of Scotland to develop and deliver improvement
plans. 
3.15 UK decision to leave the EU 
The rate of inflation is impacting on the cost-of-living crisis for
Midlothian residents and posing significant risk to a number of Council
Capital Programme work streams. This was reported to the Business
Transformation Steering Group (BTSG) and also through progress
reports on programmes to Council.  A new Economic Strategy was
approved by Council in October.  This risk evaluation remains High. 
3.16 Scottish Child Abuse Inquiry (SCAI)
The SCAI risk evaluation remains High as the Inquiry continues. 
3.17 Growing Council
The risk evaluation remains High in Q3 20240-25. This is in response
to the current financial challenge as described above and the increased
pressure the Council faces with growth. Some current examples of this
include:
• Inflationary impact on the delivery of the capital programme
• Cost of living crisis 
• Pressure on the care sector as people are living longer and
require more care provision
• General population growth places additional demand on
infrastructure such as GPs, schools, waste services etc.
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5 
3.18 Work is ongoing to review the Learning Estate Strategy and a
reprioritisation of the Capital Programme.  
3.19 STRATEGIC OPPORTUNITIES 
3.20 Capital Projects - Housing
Projects impacted with 26% reduction in Affordable Housing Supply
Programme grant to Midlothian and continued high build costs.  Phase
5 housing programme has been reviewed to ensure affordability within
the Housing Revenue Account, allowing for reduced levels of grant. 
Projects highlighted with specific Red Risk Evaluation(s) and detailed
within the SRP are Newbyres, Gorebridge; Edmonstone Road,
Shawfair and Newton Church Road, Danderhall. 
3.21 Capital Projects – Transport, Net Zero & Infrastructure
Cost of delivering enabling infrastructure projects has risen, resulting in
significant funding gap emerging and impacting on progress of A701
Relief Road, Sustainable Transport Corridor and Straiton Junction
Improvements, which are detailed within the SRP. 
3.22 Capital Projects – Children, Young People & Partnerships Estates
Programme: Primary
Five specific projects identified within the SRP:
1. Mayfield/St Lukes PS New Build: Tender return from Stage 1
exceeds available budget. Programme delayed for project revision. 
2. Kings Park PS Extension & Refurbishment: No available budget to
undertake extension. Condition and suitability of school to be
addressed.
3. Rosewell PS Extension: No available budget to undertake
extension. Condition and suitability of school to be addressed.
4. Mauricewood PS Extension & Refurbishment: Rising roll and
catchment review requires investment in school to address capacity
and suitability. Limited budget available.  Design team appointed to
develop investment in school that aligns with budget available from
Developer Contributions.
5. Bilston PS Extension: Rising roll and catchment review requires
investment in school to address capacity and suitability. Limited
budget available.  Design team appointed to develop investment in
school that aligns with budget available from Developer
Contributions. 
3.23 Capital Projects – Children, Young People & Partnerships Estates
Programme: Secondary 
Three specific projects identified within the SRP:
1. Beeslack HS Replacement:  Contractor appointment delayed.
Programme behind due to changes in scope / design.  
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6 
2. Shawfair All Through: Site acquisition complete. School location
fixed with design team. Remediation programme being revised.
Seeking to make efficiencies in remediation programme.
3. Penicuik HS New Build: LEIP target for delivery is Dec 2026,
however programme for occupation is July 2027. Cost reports
tracking higher and risks identified in refurbishment works.   SFT
advising if additional LEIP funding available. 
3.24 Capital Projects – Regeneration 
Three specific projects identified within the SRP:
1. Vogrie Changing Places: contractor issues.
2. Destination Hillend: Alpine Coaster delivered with access and
parking infrastructure. Project absorbed risk and contingency. 
Delays to delivery resulting from issues with access / water mains.
Main Building tender return exceeded budget. Next Phase to be
recast. Interim works on water supply and drainage required.
3. Hopefield Industrial Estate: Updated financial model required. 
3.25 City Region Deal 
Edinburgh and South East Scotland City Region Deal - bid for funding
to Scottish and UK Governments to accelerate economic growth
through investment in infrastructure/ housing/ skills and innovation was
agreed by Council in June 2018.  Projects continue to be progressed
with realisation of regional enhancements and connectivity. 
4 Report Implications (Resource, Digital and Risk) 
4.1 Resource 
There are no direct resource implications indicated in this report,
although individual risks have associated resource implications. 
4.2 Digital 
None 
4.3 Risk 
The risks reported in this report are understood with the Council able to
demonstrate the current risk controls and actions being taken in
response to these.
The report provides an overview of the significant risks faced by the
Council during Quarter 2 & 3 2024-25 and should act to provide
assurance that Midlothian Council took a proportionate and planned
approach to prepare and respond to each of these risks. 
4.4 Ensuring Equalities (if required a separate IIA must be completed) 
There are no direct equalities issues arising from this report. 
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7 
4.5 Additional Report Implications (See Appendix A) 
See Appendix A 
Appendices 
Appendix A – Additional Report Implications
Appendix B – Strategic Risk Profile (Quarter 2 & 3, 2024-25) 
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8 
APPENDIX A – Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
This report provides an overview of the Strategic Risk Profile of
Midlothian Council at a defined point in time. The issues, risks and
opportunities affecting or supporting delivery of the council priorities are
set out within the Strategic Risk Profile. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working 
Hub and Spoke 
Modern 
Sustainable 
Transformational 
Preventative 
Asset-based 
Continuous Improvement 
One size fits one 
None of the above 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you 
Preventative and Sustainable 
Efficient and Modern 
Innovative and Ambitious 
None of the above 
A.4 Delivering Best Value 
The Council’s commitment to best value and securing continuous
improvement can best be delivered when decisions are made against a
backdrop of understanding the risks and opportunities before an
organisation. This report seeks to provide assurance that the current
risk environment is understood and that Midlothian Council is taking
appropriate action in response to those identified risks. 
A.5 Involving Communities and Other Stakeholders 
This Strategic Risk Profile report has been compiled with input from a
range of internal key stakeholders. 
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9 
A.6 Impact on Performance and Outcomes 
This report seeks to provide an overview of the challenging risk
environment within which the Council is operating at this time. Being in
a risk aware position helps to inform current and future decision
making, with the intention of enhancing decision making and the
associated performance and outcomes which flow from well informed
decision making. 
A.7 Adopting a Preventative Approach 
The Risk Management approach being taken by the Council is founded
on a preventative approach to managing risks, where appropriate and
more generally to decision making with far greater risk awareness. 
A.8 Supporting Sustainable Development 
Senior Managers must ensure the sustainability of the Council, which
entails identifying, understanding and managing Strategic and Service
level risks and opportunities.
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
STRATEGIC RISK PROFILE, Q2 July - September 2024 
SRP STRATEGIC RISK PROFILE 
SRP This risk register captures the main strategic issues, risks and opportunities that are corporate in nature. It identifies the nature of the risks, measures required to control the risks and their evaluation. It also
details what further actions are required to reduce the likelihood and impacts of those risks to more acceptable and manageable levels with timescales.   
Strategic Issues 
SRP.IR.02 The Change Programme 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.IR.
02
Risk cause
The pace of transformation strands of
activity, reporting to the Business
Transformation Board, does not secure
service transformation, delivery of
outcomes or benefit realisation. 
Risk event
Delayed progress or non-achievement of
outcomes and benefits. 
Risk effect 
Slow or delayed financial benefits arising
from service redesign, requiring the
adoption of recovery plans or requiring
short term service reductions which impact
on the Council’s ability to deliver against its
priorities. 
.  
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Transformation Blueprint agreed at Council June 2023 which is a 5-
year transformation plan. Revised governance for transformation agreed
and revised Terms of Reference in place for the Business Transformation
Board to oversee progress on change programme. 
2. Regular reporting to Council setting out scale of financial challenge
ahead with recurring expenditure for current service delivery projected to
exceed recurring income. 
3. Cross Party Business Transformation Steering Group are given
updates on the progress of the Transformation programme. 4. Financial
monitoring reports and work of the Financial Management Corporate
Management Team evidence continued financial sustainability, in so far
as services are delivered within the overall budget in year.  
5 5 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SPR.RA
-02.08 Transformation Blueprint 2023-28 delivery
Q2 24/25: Progress with sprints is reported to BTB at every meeting via the
dashboard and also in detailed reports at some points. BTSG are provided with
an updated dashboard every cycle and receive focused reports on individual
sprints and also funding requests to release BT funds to support project work. 
Q1 24/25: As Q4 23/24. 
Q4 23/24: Work on sprints continues with some reporting to BTSG in the run
up to June Council with the majority of others scheduled for August. BTB is now
meeting fortnightly to encourage and closely monitor progress. To support
monitoring of progress a dashboard has been developed and this is shared with
CMT and BTSG as a standing item. 
Q3 23/24: Regular review and updates to the Business Transformation Board
which meets monthly. Transformation Manager in post and sprints initiated.  
Chief *Executive;
Chief Officer
*Place; Chief
Officer Corporate
Solutions; Chief
Finance Officer; 
30-Jun-2028  20%
SRP.RA
.02.03
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability.
Q2 24/25: Further update on the MTFS was presented to Council in October
and a public consultation was launched on 9th October running to 20th November. 
Q1 24/25: An update on the MTFS was presented to Council in June 2024. This
identifies immediate actions required, in addition to those in the Transformation
Blueprint, to bridge the gap between recurring expenditure and recurring income
and to allow the setting of a balanced budget for 2025/26.   
Q4 23/24: An update on the MTFS with refreshed projections and a clear plan
to address financial sustainability will be presented to Council in June 2024. 
Q3 23/24: As Q1. Preparations for MTFS at February Council.  
Chief *Executive;
Chief Finance
Officer;
30-June-2024  100%   
SRP.IR.07 Financial Sustainability 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.IR.
07
Risk cause
Scottish Government Grant settlements fall
short of the resources needed to sustain
core services. Core funding falling short of
inflation pressures, pay awards and
demographic pressures arising from an
Increasing ageing population of over 75’s. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
1. There is an approved Capital Strategy and Reserves Strategy in place.
The Capital Strategy is being updated in the context of ongoing and
significant infrastructure pressures. 
2. There is an approved budget for 2024/25. Services are delivered within
the totality of that budget. 
3. Enhanced monitoring arrangements have been agreed for service
areas that are regularly showing overspends. 
5 5 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Increasing population of 0-15 age group
and at a time when there are rising
customer expectations. 
Risk event
Transformation activity and the flexibility
available to Councils as part of the grant
settlement does not address future years
projected budget gaps. 
Risk effect Inadequate government
funding makes securing balanced budgets
challenging. This in turn erodes the
Council’s ability to deliver services to the
community and potentially means that
resources available fall short of those the
Council assess as required to meet its
statutory obligations. Whilst transformation
activity can help reshape services and
ensure best value in the delivery of
services it is not a solution to continued
erosion of core funding. 
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
4. Directorates have budget boards in place to monitor and agree actions
for those items which are identified as needing specific attention or
present a risk to the financial position of services. 
5. Strategic Boards in place and BTB focus and attention on driving
transformation to support future year’s financial sustainability. 
6. Working through COSLA to influence government spending decisions
to influence Scottish Government’s budget allocation to Councils. 
7. Capital Plan and Asset Management Board will scrutinise and
challenge slippage on capital programmes recognising that slippage can
have an adverse impact on financial sustainability and also the delivery
on assets required to support capital growth. 
8. Chief Executive continues to emphasise the need for effective financial
control and underlined the benefit to the organisation of such an
approach.  
9. Scottish Governments May 2022 Resource Spending Review provided
planning parameters for term of parliament, albeit these are challenging
and present a real terms reduction in grant funding of circa 7% over the
period. 
10. Report to Council February 2024 sets out scale of financial challenge
ahead with recurring expenditure for current service delivery projected to
exceed recurring income. Updated MTFS projections presented in June
2024.
11. Cross Party Business Transformation Steering Group engaged in
consideration of measures to secure balanced budgets alongside the
development of a Strategic Plan to support decisions about what
services, beyond those which are statutory can be provided.                  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SPR.RA
-02.09 Transformation Blueprint 2023 to 2028
Q2 24/25: Refer to SRP.RA-02.08 
Q1 24/25: As Q4 23/24. 
Q4 23/24: Work on sprints continues with some reporting to BTSG in the run
up to June Council with the majority of others scheduled for August. BTB is now
meeting fortnightly to encourage and closely monitor progress. To support
monitoring of progress a dashboard has been developed and this is shared with
CMT and BTSG as a standing item. 
Q3 23/24: Regular review and updates to the Business Transformation Board
which meets monthly. Transformation Manager in post and sprints initiated.  
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2024  20%
SRP.RA
.02.03
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability.
Q2 24/25: Refer to SPR.RA-02.03 
Q1 24/25: An update on the MTFS was presented to Council in June 2024. This
Chief *Executive;
Chief Finance
Officer; 
30-June-2024  100%
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
identifies immediate actions required, in addition to those in the Transformation
Blueprint, to bridge the gap between recurring expenditure and recurring income
and to allow the setting of a balanced budget for 2025/26. 
Q4 23/24: An update on the MTFS with refreshed projections and a clear plan
to address financial sustainability will be presented to Council in June 2024. 
Q3 23/24: As Q1. Preparations for MTFS at February Council.  
SRP.RA
-02.10 Capital Plan Prioritisation
Q2 24/25: Work continues on Capital Plan prioritisation 
Q1 24/25: Work continues on Capital Plan prioritisation 
Q4 23/24: Work continues on Capital Plan prioritisation 
Q3 23/24: Work continues on Capital Plan prioritisation  
Chief Finance
Officer; Executive
Director – Place;
Executive Director
- Education
31-Oct-2024  0%   
SRP.IR.11 National Care Service 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.IR.
11
Risk cause
In August 2022 the Scottish Government
launched a 12-week consultation on the
way in which social care is delivered in
Scotland. The consultation followed
recommendations made in the
Independent Review of Adult Social care.
The independent analysis of responses
was published in February 2022. On 20
June 2022 the Scottish Parliament
published the National Care Service (NCS)
Bill which will provide the foundation for
the NCS. 
Risk event
A Bill passes through various
Parliamentary stages. The Bill is currently
in Stage 1 of the process. The most
significant part of the legislation which
poses the most risk is the intention to
transfer social care responsibility from
local authorities to a new, national service. 
Head of *Adult
and Social Care;
Chief *Executive;
Director *Health
and Social Care;
Executive
Director *Place;
Chief Officer
Young People
and Partnerships
As of 14 November 2024, a pause has been placed on the delivery of
NCS legislation by the Scottish Government.  3 5 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Risk effect 
The details of the logistics of any transfer
are not yet provided within the Bill. It is not
clear the extent to which powers will be
removed from local authorities or what the
provision or delivery of services will or will
not be. 
At this stage, the risk effect is anticipated
to be significant financial impact to local
authorities and IJBs, as well as the
potential for impacts on staffing, transfer of
property and facilities and the reshaping of
the delivery of care. 
It should be noted that the initial impact on
the Council is staff time to contribute to the
ongoing discussions and understanding of
the impact of the Bill.                  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.11.1 Officer Working Group
Q2 24/25: As of 14 November 2024, the Scottish Government has paused
legislation on the creation of a NCS. 
Q1 24/25: The Bill is at Stage 2 
Q4 23/24: The Bill is at Stage 2. 
Q3 23/24: Further information now expected late March 2024.  
Chief *Executive;  31-Dec-2024  100%   
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Strategic Risks 
SRP.RR.01 Financial Sustainability in future years 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.01
Risk cause:
Scottish Government Grant settlements fall
short of the resources needed to sustain
core services. Core funding falling short of
inflation pressures, pay awards and
demographic pressures arising from an
Increasing ageing population of over 75’s. 
Increasing population of 0-15 age group
and at a time when there are rising
customer expectations. 
Policy decisions by UK & Scottish
Governments which are not fully funded. 
Changes to the responsibilities of Local
Government and the funding implication
that arise from that, particularly in respect
of the creation of a National Care Service. 
Future year pay award settlements. 
Risk event: 
Real terms reduction in core grant
settlements. 
Policies decisions at Government level not
fully funded to Council's. 
Implementation of a National Care Service
and impact on grant settlements. 
Securing the extent of change required in
order to deliver financial sustainability and
a change program that recognises the size
of the challenge. 
Cost pressures exceeding budget
estimates. 
Risk to not achieving financial
sustainability is a failure to deliver cost
reductions / service change embedded in
the blueprint and also supplementing the
blueprint.   
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Development of Strategic Plan, Transformation Blueprint and MTFS
projections which come together to provide a framework to effect change
and to move the Council to a position of financial sustainability. 
2. Maintaining a level of reserves to deal with unforeseen or one-off cost
pressures. 
3. Capital and Reserves Strategies in place. The Capital Strategy is being
updated in the context of ongoing and significant infrastructure pressures. 
4. Working through COSLA to influence government spending decisions
to influence Scottish Government’s budget allocation to Councils. 
5. Implement a lobbying strategy with government to recognise the
unique position Midlothian Council is in. 
6. Best Value Audit report actions. 
7. Strategic Boards in place to drive transformation in line with the
Transformation Blueprint. 
8. Dedicating capacity to understand impact of NCS Bill, but limited
details mean this is challenging and many unanswered questions (refer to
specific risk on NCS for further detail)  
5 5 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.03
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability.
Q2 24/25: Refer to SRP.RA-02.03 
Q1 24/25: An update on the MTFS was presented to Council in June 2024. This
identifies immediate actions required, in addition to those in the Transformation
Blueprint, to bridge the gap between recurring expenditure and recurring income
and to allow the setting of a balanced budget for 2025/26. 
Q4 23/24: An update on the MTFS with refreshed projections and a clear plan
to address financial sustainability will be presented to Council in June 2024. 
Q3 23/24: As Q1. Preparations for MTFS at February Council.  
Chief *Executive;
Chief Finance
Officer; 
30-June-2024  100%
SRP.RA
.02.04 Transformation Blueprint 2023 to 2028
Q2 24/25: Refer to SRP.RA-02.08 
Q1 24/25: As Q4 23/24. 
Q4 23/24: Work on sprints continues with some reporting to BTSG in the run
up to June Council with the majority of others scheduled for August. BTB is now
meeting fortnightly to encourage and closely monitor progress. To support
monitoring of progress a dashboard has been developed and this is shared with
CMT and BTSG as a standing item. 
Q3 23/24: Regular review and updates to the Business Transformation Board
which meets monthly. Transformation Manager in post and sprints initiated.  
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2028  20%
SRP.RA
.02.06 Capital Plan prioritisation
Q2 24/25: Work continues on Capital Plan prioritisation 
Q1 24/25: Work continues on Capital Plan prioritisation 
Q4 23/24: Work continues on Capital Plan prioritisation.   
Q3 23/24: Work continues on Capital Plan prioritisation.  
Head of
*Development;
Executive Director
*Place; Chief
Finance Officer; 
31-Oct-2024  0%              
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
SRP.RR.02 The Long-Term Change Programme 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.02
Risk cause:
A MTFS that does not address the
projected budget shortfall or contextual
factors relating to the Midlothian area. 
Reduced resources 
Leadership fit for the future. 
Lack of clarity or clear compelling vision for
the future 
Delay or shortfall in securing savings 
Lack of or not securing transformational
change in service provision 
Risk event:
Delayed progress in applying various
strands of the Change Programme
including Delivering Excellence Framework 
Slow benefits realisation and budget
savings. Cuts in service provision rather
than service transformation 
Risk effect:
Objectives of change not actually met or
progress too slow. Adverse impact on
services Slow or delayed
proposals/savings arising from service
redesign. Potentially further eroding
reserves or requiring short term service
reductions which impact on Council's
ability to deliver against its priorities. Staff
morale negatively affected, Government
step-in short term savings instead of
transformation  
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Development of Strategic Plan, Transformation Blueprint and MTFS
projections which come together to provide a framework to effect change
and to move the Council to a position of financial sustainability. 
2. Leadership from all Elected Members, Executive Team and Senior
Leadership Group. 
3. Appropriate governance in place across the BTB Strategic Boards 
4. Resilience planning. 
5. Capacity to deliver change. 
6. Dedicating capacity to understand impact of NCS Bill, but limited
details mean this is challenging and many unanswered questions (refer to 
specific risk for NCS Billl).
7. High level priority is given to blueprint work.    
5 5 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.03
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability.
Q2 24/25: Refer to SPR.RA-02.03 
Q1 24/25: An update on the MTFS was presented to Council in June 2024. This
identifies immediate actions required, in addition to those in the Transformation
Blueprint, to bridge the gap between recurring expenditure and recurring income
Chief *Executive;
Chief Finance
Officer;
30-June-2024  100%
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
and to allow the setting of a balanced budget for 2025/26. 
Q4 23/24: An update on the MTFS with refreshed projections and a clear plan
to address financial sustainability will be presented to Council in June 2024. 
Q3 23/24: As Q1. Preparations for MTFS at February Council.  
SRP.RA
.02.04 Transformation Blueprint 2023 to 2028
Q2 24/25: Refer to SRP.RA-02.08 
Q1 24/25: As Q4 23/24 
Q4 23/24: Work on sprints continues with some reporting to BTSG in the run
up to June Council with the majority of others scheduled for August. BTB is now
meeting fortnightly to encourage and closely monitor progress. To support
monitoring of progress a dashboard has been developed and this is shared with
CMT and BTSG as a standing item. 
Q3 23/24: Regular review and updates to the Business Transformation Board
which meets monthly. Transformation Manager in post and sprints initiated.  
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2028  20%   
SRP.RR.03 Legal and Regulatory Compliance 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.03
Risk cause
Current or new legislation applying to
Midlothian Council.
Lack of capacity to resource statutory
obligations around GDPR, data protection,
records management, information requests
and statutory regulatory functions. 
Risk event
Council and or Services not identifying all
applicable legislation impacting Council
activities and Service requirements. 
Risk effect
Council failing to meet its statutory
obligations resulting in a potential negative
impact for service users or employees.
Reputational impact of not meeting
statutory obligations.  
Head of *Adult
and Social Care;
Legal *and
Governance
Manager; Chief
Operating Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Executive Directors, Chief Officer(s) and Head(s) of Service
responsible for identifying applicable legislation and propose Council or
Service responses to CMT and Cabinet/Council as required. 
2. Annual Assurance Statement. 
3. Internal Audit testing of internal controls as part of risk-based audit
plan. 
4. External Audit. 
5. Range of external inspection. 
6. BTSG oversight of new legislation 
7. Central repository of applicable legislation.  
5 5 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.03.02 Rights of the Child Bill
Q4 23/24: Q4 Council wide group established and developing a plan that
ensures we are all aware and adhering to UNCRC. 
Q3 23/24: Bill now adopted. Policy to be presented to Council May/June 2024.  
Chief *Social Work
Officer; 31-Dec-2024  0%
SRP.RA
.03.03 National Care Service
Q2 24/25: As of 14 November 2024, the Scottish Government has paused
legislation on the creation of a NCS. 
Q1 24/25: The Bill is at Stage 2.
Q4 23/24: Q4 National Care Service is at stage 2 and we await decisions
around what next.
Q3 23/24: National Care Service Bill has been delayed for any further decision
until the 1st March 2024.  
Chief *Executive;  31-Dec-2024  0%
SRP.RA
.03.05
Review of Standing Orders, Scheme of
Administration and Scheme of Delegation
Q4 23/24: Workplan presented and agreed by SOWG in April 2024. Some
changes to SOs and Scheme of Administration presented and approved by
Council in May 2024 (this is technically Q1 2024/25 update). 
Legal &
Governance
Manager;
Executive Director
*Place; Chief
Officer Corporate
Solutions;
31-Dec-2024  40%
SRP.RA
.03.07
Review of policy and creation of a policy
register
Q4 23/24: work to develop policy register ongoing. 
Q3 23/24: Corporate Solutions has initiated a review of policies in the Council,
aligned to legislation changes and statutory requirements for the Local Authority.
Work is ongoing to gather information across the Council to inform an action
plan and a refreshed policy register. It is estimated that this work will take until
end 2024 to be completed. 
Chief Officer
Corporate
Solutions
31-Dec-2024  10%
NEW Compliance with statutory duties
Q1 24/25: Records Management Officer in post and reviewing the Records
Management Plan, Corporate Retention Policy and Schedule and supporting the
development of retention framework for M365 rollout.  
Q4 23/24: Work is ongoing with the Scottish Information Commissioner and
National Records of Scotland to develop and deliver improvement plans. Ongoing
recruitment for Records Manager. Rationale report for resourcing in
development. Significant resourcing pressures contribute to the increase in
Chief Officer
Corporate
Solutions, Legal
and Governance
Manager 
31-Dec-2024  10%
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
scoring for Q4.  
SRP.RR.04 Employee performance 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.04
Risk cause
Employees not suitably trained/developed
for the roles required of them. 
Limited availability of qualified practitioners
in certain sectors. 
Change program not informed by all key
stakeholders. 
Ageing work force. 
Employees unclear on expected
behaviours. 
Employees constrained to innovate as a
result of management practice. 
Employee productivity rate below the
required level because of ineffective use of
the People Policies particularly Maximising
Attendance. 
Salaries in some functional areas lower
compared to other LA’s resulting in
recruitment issues particularly with trying
to recruit experienced staff. 
Risk event
Employees not engaged/consulted as part
of organisational transformation. 
Experienced employees leaving the
organisation. 
Inability to recruit suitably qualified /
trained staff to fill vacancies negatively
impacting on remaining workforce. 
Unacceptable behaviours demonstrated by
employees. 
Stated organisational culture not
consistently reinforced by managers. 
Poor employee performance will stifle
transformational change. 
Risk effect
Difficulties recruiting the right staff. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
HR Strategic
Lead; Chief
Officer Young
People and
Partnerships
Over-riding risk control measure = Focus on having the right people, here,
healthy, performing, behaving and well led via effective utilisation of the
workforce strategy and accompanying action plan. 
Attendance / Wellbeing
1. Continuing implementation of the Wellness@Midlothian agenda. 
2. Creation of an Employee Health and Wellbeing Strategy and
supporting policy. 
3. Maintaining the Healthy Working Lives Gold Award. 
4. Proactive use of Occupational Health, Midlothian Physiotherapy,
Employee Assistance Programme and the Workplace Chaplaincy
Service. 
5. Change of EAP supplier to ensure provision of best possible service. 
6. Development of progressive People Policies. 
7. Roll-out of mental health training for staff and managers. 
Performance
1. Service-level workforce plans. 
2. Structured, robust, well established ‘Making Performance Matter’
Framework where expected standards of behaviour and Council values
are re-enforced. 
3. Continued re-enforcement of all People Policies involving various
communication methods. 
4. Development of a suite of management information to ensure Service
Managers are informed e.g., turnover, absence levels/reasons etc. 
Organisational Change
1. Policy for Organisational Change includes strong emphasis on early
engagement of employees. 
2. Redeployment Procedure to ensure maximum chance of successful
redeployment. 
Conduct
1. Resolution Policy encourages early intervention of workplace issues. 
2. Professional standards and values build into the induction process and
management development programme. 
Communication
1. A range of initiatives to keep staff informed of change (Chief
3 4 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Challenges retaining quality staff. 
Low skill levels. 
Low morale, especially during change. 
High absence rates, loss of experience in
service areas. 
‘A Great Place to Grow’ our values
including respect, collaboration, pride and
ownership not realised, potentially
resulting in missing the opportunity to
capitalise on the abilities, experience and
ideas of team members. Poor employee
performance will Exacerbate the financial
challenge. 
Executive’s weekly email, Connect, All staff emails, tailored team
briefings etc.                  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.04
Development and Delivery of the Council’s
Workforce Strategy 2024-29 including
analysis of future workforce requirements,
gap analysis and gap closing strategies,
and performance measures and target
setting.
Q1 24/25: Workforce Strategy in development and expected to be presented to
December Council with Action Plan for approval. Audit Scotland external audit on
workforce and digital to be presented to Audit Committee September 2024. 
Q4 23/24: Ongoing work nationally to review workforce planning which
Midlothian is contributing to. Best Value focus this year is on workforce planning
– awaiting outcome of external audit to identify improvement plan for 24/25. 
Q3 23/24: Service plans were presented to June 2023 council. Supporting
workforce plans are due to be fully in place for June 2024. The workforce
planning process, guidance and documentation has been developed and
approved for use by managers across the council. The HR team is available to
support managers who wish help and guidance in the development of these
workforce plans. 
Chief Officer
Corporate
Solutions 
31 Dec 2024   25%   
SRP.RR.07 Care at Home 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.07
Risk cause
Internal and External providers of Care at
Home services unable to meet service and
quality requirements as a result of a lack of
capacity. 
Head of *Adult
and Social Care;
Director *Health
and Social Care
1. Care at Home winter assurance plan and business continuity plan
complete 
2. Development of Care at Home Service Improvement action plan near
completion 
3. External commissioning complete and ongoing contract monitoring in
place 
3 4 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Risk event
Capacity of Community Support
outstripped by demand. 
Risk effect
There is a risk that patients will have their
discharge delayed because there is
insufficient community supports to enable
timely discharge leading to deterioration in
their health, beds being blocked and
elective operations potentially being
cancelled.  
4. External provider audits complete 
5. Re-established Multi-Agency Quality in Care at Home quarterly review
meetings jointly with East Lothian 
6. Weekly provider meetings in place 
7. Additional locum team members and contracts with agency staff in
place 
8. Daily discharge meeting with Multidisciplinary and Multi-agency team
planning to plan and coordinate discharge to ensure care at hone support
in place                  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.07.01
Independent review of adult and social
care
Q2 24/25: The Scottish Government has initiated a pause on the development
of the NCS. 
Q1 23/24: Pause remains in place.
Head of *Adult
and Social Care;
Chief *Executive; 
31-Jan-2024  100%   
SRP.RR.08 Asset Management – buildings, vehicles,  roads and Digital assets/networks 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.08 
Risk cause
Many of the assets the Council own by
their nature are in a position of ongoing
deterioration through their normal use,
e.g., roads - normal wear and tear,
streetlights and vehicles & buildings used
to deliver services. 
Risk event
Many assets will deteriorate under normal
conditions although buildings, roads and
streetlights as an example can be
damaged during more extreme weather
events or as a result of a lack of
maintenance. 
Risk effect
Head of *Adult
and Social Care;
Head of
*Development;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
1. There is provision in place within the capital plan for investment in the
asset base. 
2. Asset register 
3. Condition Survey 
4. Understanding of future asset needs 
5. Asset Strategy: 
. Roads 
. Land 
. Fleet 
. Digital Service Network 
. Digital Service hardware 
6. Capital programme - investment in estate. 
7. Ongoing monitoring of properties by: Maintenance Surveyors, Facilities
Management and Property Users. 
8. Established Capital Plan and Asset Management Board and dedicated
Asset Management Board 
9. Establishment of 7 thematic Estate Safety and Management Groups
chaired by Chief Officer Place 10. Building Accessibility Strategy  
3 5 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
In the case of Roads Services there is a
real risk of increased potholes and
insurance claims, reduced skid resistance
leading to higher accident potential and
building up of higher costs in the future. In
respect of vehicles, increased
breakdowns, service failures, greater
maintenance inevitable, higher short-term
hire costs. In terms of property, health and
safety issues arise, failure to meet current
standards and higher running costs. There
is also the risk of two-tier accommodation,
some high quality, some low. 
Young People
and Partnerships                
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.08.02
Plan for appropriate investment in capital
works and remedial maintenance over the
lifespan of each property asset.
Q1 24/25: Condition Surveys continue, with Learning Estate (excl PPP)
expected to be concluded by end December 2024 to inform capital investment
proposal. 
Q4 23/24: Backlog maintenance repairs being undertaken across the estate on
a prioritised basis. 
Q3 23/24: Surveyors have now completed the first phase of surveys that were
due to have been completed by March 2024. A further phase will begin in April
and run though until April 2025.  
Chief Officer
*Place;  30-Apr-2025  33%
SRP.RA
.08.05 Learning Estate Strategy
Q4 23/24: All Priority 1 and 2 projects are progressing. In terms of all of the
capacity breaches that were detailed in Priority 2 of the LES, investment was
made to provide a solution. 
Q3 23/24: All Priority 1 projects as detailed in the Learning Estate Strategy
have been approved by Council in June 2023, this includes Beeslack HS
replacement and Penicuik HS refurbishment & extension. A number of Projects in
the priority 2 tranche have been progressed to ensure schools do not experience
capacity breaches.  
Head of
*Development;  30-Apr-2025  50%
SRP.RA
.08.06 Asset Management systems
Q4 23/24: As Q3. 
Q3 23/24: Identified for implementation through Transformation Blueprint and
The Change Programme.  
Chief Officer
*Place;  31-Mar-2025  0%   
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
SRP.RR.09 Emergency Planning and Business Continuity Management 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.09
Risk cause
The Council not preparing or timeously
reviewing Emergency Plans and testing
arrangements to respond to Civil
Contingencies Incidents 
Risk event
There are a wide range of potential events
the Council may be expected to respond to
e.g., Severe weather incident, Pandemic,
Utility disruption etc. 
Risk effect
Censure through non-compliance with the
Civil Contingencies Act Not adequately
recovering from the loss of major
accommodation (e.g., secondary school,
main offices), computer systems and staff
Not able to respond to a major emergency
in the community Fatal Accident Inquiries  
Head of *Adult
and Social Care;
Head of
*Development;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
David Robertson;
Chief Officer
Young People
and Partnerships
1. Civil Contingencies Risk Register used to highlight key risks and record
response, 
- Council’s plans developed and maintained in response to identified
risks, 
- Risk and Resilience Group support development, peer review and roll
out of plans. 
2. Establishment based incident response plans in place and maintained
locally. 
3. Emergency response plan setting out general approach to respond to a
major emergency in-line with key partner organisations. 
4. As part of the Council’s Emergency response the importance of
recording decisions made and information available at the time is
highlighted as this would be scrutinised in the event of an FAI. 
05 – Care for People Group: Afghan, Ukrainian and UASC support
programmes  
3 4 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.09.02 Development of Emergency Plans 
Q2 24/25: Service review for the Health, Safety and Resilience Team Service,
which includes Contingency Planning, is still in progress. 
Plans/plan updates include: 
• Midlothian Pipelines Emergency Plan (required under the Pipelines
Safety Regulations 1996).   
• Emergency Contacts Directory (reflecting staff changes) 
• Provision of Business Continuity guidance notes to service managers. 
Plan updates/procedures in progress:  
• Midlothian Council Emergency Plan (generic). This document outlines
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31-Dec-2024  75%
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
internal emergency management arrangements and multi-agency
partnership relationships. 
• Operation UNICORN (and associated arrangements). Scottish
Government have advised that national planning arrangements are
underway, and we will tie in with those. Meantime, we have the basics
in place, based on previous experience. 
• Corporate Business Continuity (BC) Plan. An update to the Corporate
Business Continuity Policy was provided to Corporate Management
Team members in Q4 23/24. However, learning from a Cyber Security
event facilitated by Scottish Government in June 2024 and September
2024 and the experiences of other organisations will be incorporated
into an expanded document, which will also link in with the work being
done by Digital Services on the technical response to a cyber-attack.   
• Draft action plan in relation to the revised Prevent Duty Guidance to
measure our compliance.  (In support of the Prevent SPOC.)
• Support to the Executive PA Place with the Festive Period Service
Arrangements document. 
Multi-agency Exercises, Training, Presentations, Work streams:
• Debrief for the multi-agency Exercise Puma (Torness related exercise)
held in June 2024. 
• Supporting School Business Managers in the development of their
School Incident Plans, in collaboration with Police Scotland colleagues. 
• Familiarisation training exercise using Airwave handsets (held by Police
Scotland for partner use in emergencies).  These short sessions are
organised by the Scottish resilience community on a regular basis
throughout the year. 
• A number of national presentations relating to Prevent (extremism) 
Q1 24/25: Exercise (simulated cyber attack) took place at the Leadership
Forum June 2024 with the session facilitated by Scottish Government and LRP
Colleagues. The session was designed to remind services managers of the
importance of having , maintaining and exercising their Business Continuity
Planning arrangements.   
Plans/plan updates include: 
• Midlothian Council generic Emergency Plan. This document outlines
internal emergency management arrangements and multi-agency
partnership relationships. 
• Operation UNICORN (and associated arrangements).  Scottish
Government have advised that national planning arrangements are
underway.  Meantime, we have the basics in place, based on previous
experience. 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
• Corporate Business Continuity (BC) Plan. An update to the Corporate
Business Continuity Policy was provided to Corporate Management
Team members in Q4 23/24.  However, learning from a Cyber Security
event facilitated by Scottish Government in June 2024 and the
experiences of other organisations will now be incorporated into an
expanded document, which will also link in with the work being done by
Digital Services on the technical response to a cyber attack.   
Multi-agency Exercises, Training, Presentations, Work streams:
Team Members also participated in the following where appropriate to their
areas of work, invitations were extended to colleagues in other services and
partners: 
• Planning for and participation in a Torness related exercise in June
2024. 
• Lothian and Borders Local Resilience Partnership non-routine inputs
including Met Office Extreme Heat Awareness 
Q4 23/24: Work on flooding across the county and its risks has commenced,
with a report to Council scheduled for post-recess.  CMT desktop exercise
undertaken. 
Q3 23/24: A service review of the Health, Safety & Resilience team has
commenced.  
SRP.RA
.09.03 Business Continuity Software System 
Q1 24/25: The Health, Safety & Resilience Service review is progressing and
has identified staffing shortages to meet obligations. 
Q4 23/24: Report in early draft, to be completed once Health, Safety &
Resilience service review completed (SRPO.RA.09.02).  BCPs in the event of
power outage to be incorporated. 
Q3 23/24: System review/upgrade has been considered and it is planned to
present a report to CMT in Q4.  
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31-Dec-2024  25%    
SRP.RR.10 Governance and Standards in Public Life 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.10
Risk cause
Code of conduct for Members and
employees’ actions falling short of
Legal *and
Governance
Manager; Chief
01 Annual Assurance Statement. 
02 Standing Orders 
03 Scheme of Administration 
2 4 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
International Standards. 
Risk event
Failure in openness, accountability, clarity. 
Risk effect Service, partnerships and
project outcomes not achieved. Non-
compliance with conduct standards and
reduction in standards in public life.  
*Executive; Chief
Officer *Place;
Executive
Director *Place;
Chief Officer
Corporate
Solutions
04 Scheme of Delegation 
05 Elected Member Code of Conduct 
06 Induction programme for new members and ongoing learning and
development programme 
07 Employee Code of Conduct                 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.03.05
Review of Standing Orders, Scheme of
Administration and Scheme of Delegation 
Q1 24/25: Workplan presented and agreed by SOWG in April 2024. Some
changes to SOs and Scheme of Administration presented and approved by
Council in May 2024. 
Q3 23/24: Workplan being developed by officer working group and will be
presented to SOWG in March 2024 for approval.  
Legal *and
Governance
Manager; Chief
Officer Corporate
Solutions; 
31-Dec-2024  20%
SRP.RA
.10.03
Review of the employee onboarding and
induction programme
Q3 2023/24: CMT agreed to a refresh of the staff induction programme which
include a compliance section. It is anticipated that the new programme will be
fully completed by end Dec 2024, with a phasing of improvement actions being
delivered throughout 2024.  
HR Strategic Lead 31-Dec-2024  5%   
SRP.RR.11 Corporate Policies and Strategies 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.11
Risk cause
Policies may not match the aspirations of
the Council's Strategic priorities or cultural
perspective. 
Risk event
Policies not monitored may become out of
date. 
Policies not reviewed to ensure alignment
with strategic priorities. 
Risk effect Policies not monitored could
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
1. Single Midlothian Plan providing overarching direction 
2. Service plans aligned to Single Midlothian Plan. 
3. Leadership team to ensure correct approaches are adopted to get the
right results. 
4. Strategic housing investment plan, submitted to Scottish Government. 
5. Capital Strategy 
6. Integrated Joint Board (IJB) Plan 
7. IJB Strategic needs assessment 8. Midlothian Local Development Plan
2017 – the Council’s corporate spatial strategy.  
2 3 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
result in non-compliance with legislation
Policies not aligned to strategic priorities
will inhibit rather than support
implementation of strategic priorities.  
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships                
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.04 Transformation Blueprint 2023 to 2028 
Q2 24/25: Refer to SRP.RA-02.08 
Q1 24/25: As Q4 23/24. 
Q4 23/24: Work on sprints continues with some reporting to BTSG in the run
up to June Council with the majority of others scheduled for August. BTB is now
meeting fortnightly to encourage and closely monitor progress. To support
monitoring of progress a dashboard has been developed and this is shared with
CMT and BTSG as a standing item. 
Q3 23/24: Regular review and updates to the Business Transformation Board
which meets monthly. Transformation Manager in post and sprints initiated.  
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2028  20%
SRP.RA
.03.07
Review of policy and creation of a policy
register
Q4 23/24: work to develop policy register ongoing. 
Q3 23/24: Corporate Solutions has initiated a review of policies in the Council,
aligned to legislation changes and statutory requirements for the Local Authority.
Work is ongoing to gather information across the Council to inform an action
plan and a refreshed policy register. It is estimated that this work will take until
end 2024 to be completed. 
Chief Officer
Corporate
Solutions
31-Dec-2024  10%
SRP.RA
.11.05 Antisocial Behaviour Policy
Q1 24/25: Member Briefing on Housing and Antisocial Behaviour to be prepared
and presented during Q2, with report to Council to follow. 
Q4 23/24: Midlothian Community Action Team SLA 2024-25 contains tackling
ASB as a strategic objective. 
Chief Officer
*Place;  31-Dec-2024  0%    
SRP.RR.12 Internal Control Environment 
Risk Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Code
SRP.R
R.12
Risk cause
Work procedures/process inadvertently
create the capacity for fraud and waste to
occur. 
Internal Controls requiring more time, effort
or cost than the risk being managed. 
Mangers failing to follow procedures and
keep systems updated with accurate
information. 
Risk event
Persons exploiting opportunities to commit
fraud. 
Waste and errors 
Changing risk landscape associated with
remote working solutions. 
Risk effect
Waste and loss 
Risks over managed with risk controls
costing more than the potential loss being
managed. Increased opportunity for fraud
or financial loss has direct impact on
management information. Has adverse
effect on service performance.  
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Services have been prompted to consider fraud and waste within
Service Risk Registers. 
2. Risk Management Guide provides direction on the need to balance
time, effort and cost against benefit of risk controls. 
3. Internal Audit examine internal control arrangements based largely on
the risk registers. 
4. Corporate Fraud team in place who assist managers to undertake
fraud risk assessments in their areas (focused on priority areas) and
provide advice and guidance on fraud related matters. Active participation
in the National Fraud Initiative to investigate matches. 5. Whistleblowing
Policy and Counter Fraud Policy in place (subject to review) with
whistleblowing channels available to report concerns (anonymously if
required). 
6. Internal and external assurance. Annual Governance Statement which
involves obtaining assurance from Management over controls in their
Service. 
7. E-learning for staff to complete mandatory training for fraud awareness. 
8. Regular updates to Audit committee on progress with
recommendations made by Internal Audit. 
9. Remind staff to declare secondary employment/outside interests and
gifts & hospitality 
10. Induction for all new employees (with service exceptions), including
legal, HR, procurement, health and safety. Control at entry to
organisation. 
11. The Integrity Group continues to meet to improve the Council’s
resilience to fraud, corruption, theft and crime (including cybercrime),
maintaining proper risk management, governance and internal control
processes and systems to ensure probity in systems and operations, and
mitigation of risks, including the prevention, detection and resolution of
fraud and irregularities. Management is also responsible for checking that
the arrangements and controls are operating effectively and obtaining
assurances from internal compliance, risk, inspection, quality, and control
functions.  
2 3 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.12.04
Review of Serious Organised Crime (SOC)
group 
Q1 24/25: Initial meeting with Police is planned to discuss strategy. 
Q4 23/24: Chief Officer Place on national SOC working groups and utilising
forums to inform strategy. 
Q3 23/24: Work underway to refresh SOC Strategy, working with Police
Chief Officer
*Place; Health,
Safety &
Resilience
Manager
31-Mar-2025  50%
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Scotland and neighbouring authorities. Draft report expected Q4.      
SRP.RR.13 Climate Change 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.13
Risk cause
Council Services not adequately engaged,
resourced or directed to fulfil the
requirements of the Climate Change Act. 
Risk event
Council Services not responding to the
Climate Change Act with sufficient pace. 
Risk effect Council failing to meet its
obligation under the Climate Change
(Scotland) Act 2009 and incurring the
associated reputational damage.  
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Planning,
Sustainable
Growth and
Investment
*Manager; Chief
Officer *Place;
Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Statutory requirement to report on compliance with climate change
duties. 
2. Council Carbon Management Plan 
3. Approval of a Corporate Climate Change Strategy and action plan 
4. CPP Board for Climate Change to bring strategic focus and oversight
of plans and progress. 
5. Resilience Seminars  
5 5 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.13.04
Delivery of the BTB Board Carbon Neutral
by 2030
Q1 24/25: Member Briefing on Climate Action Plan being prepared for
presentation in Q2/3. 
Q4 23/24: Climate Action Plan finalised and will be presented to Council in
2024/25. 
Planning,
Sustainable
Growth and
Investment
*Manager; Chief
Officer *Place; 
31-Mar-2030  0%
SRP.RA
.13.05
Development of the Strategic Plan 2023-
27
Q4 23/24: Climate Action Plan finalised and will be presented to Council in
2024/25.
Planning,
Sustainable 31-Mar-2025  50%
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Q4 22/23: Carbon Neutral by 2030 is a strategic priority.  
Growth and
Investment
*Manager; Chief
Officer *Place; 
SRP.RR.14.1 Scottish Child Abuse Inquiry 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.14.1
Risk Cause: Midlothian Council and its
legacy organisations, predating the
creation of Midlothian Council in 1996,
have been involved in the provision of care
of children going back to living memory.
During this time there is the likelihood that
the care children received fell below
standards of care now in place. There is
the further potential that some people in
the care of Midlothian Council and its
legacy organisations were subject to
abuse by those who were employed to
care for them. 
Risk Event: The Scottish Government
began an Inquiry into cases of Child Abuse
occurring prior to 17 December 2014, the
intention of this enquiry is to identify
historic case of abuse which have to date
gone unreported. 
The most recent Section 21 notice around
the Foster Care Case Study is a significant
piece of work. The request for information
from 1930 to date is very challenging given
the volume of files that require to be read
and analysed. 
Risk Effect: If the inquiry finds historic
cases of abuse in Midlothian this could
damage the reputation of the Council and
could place doubt in the eyes of the public
as to the safety of these currently in care.
There is significant scope for a substantial
financial impact arising from claims of
historic abuse. Some existing employees
may be affected by the inquiry and
Chief *Executive;
Chief *Social
Work Officer 
The Council initially set up an Inquiry Project Team, however this is no
longer required as we have an experienced worker overseeing all
requests for the Scottish Child Abuse Inquiry Team. 
Work is ongoing and we have the additional tasks of supporting and
responding to enquiries from the redress team. 
The Inquiry Team have established a Project Plan covering: 
1. Residential establishments, List D Schools and Foster Carers:
identifying Children’s homes, Foster Carers and any List D Schools in
Midlothian over the last 100 years and researching historic records. 
2. Record Audit: reviewing the Council’s existing paper and electronic
recordkeeping systems to identify relevant records and map them to
residential establishments. This also includes, where possible, noting the
Council’s historic recordkeeping policies, such as retention schedules. 
3. Cataloguing/Indexing: checking and updating existing recordkeeping
systems for accuracy and consistency, enabling effective information
retrieval when requested by the Inquiry. 
The Project Team have established a Project Plan covering: 
4. Ascertaining the succession and insurance position in relation to
potential historic child abuse claims. 
5. Ascertaining and agreeing Midlothian Council’s legal position/
approach in dealing with the potential historic child abuse claims. 
6. Identifying the need for guidance, protocol, templates etc. should/if any
claims be made against the council. 
7. Consideration to identifying if additional staffing will be required as
expected deluge of FOI’s SARs in 2018 from solicitors of potential
claimants. 
8. Project team is in place with project plan with a range of identified
actions which are being progressed. Monthly meetings to progress project
plan. 9. The SCAI Social Worker is very competent and experienced in
this area of work and provides quarterly updates on their findings from the
file read. This is a real strength within this area of work. The CSWO and
Principal Solicitor meet regularly with the social worker to discuss findings
4 4 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
subsequent claims of abuse. 
We have requested an extension for Parts
B, C & D of the last Section 21 to April
2020, which has been granted. To date
there has been no evidence from the
extensive file read to suggest there has
been systemic abuse within our foster care
system. 
from the file read. 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.14.03
Foster Care and Residential Care File
Review
Q4 23/24: Foster care enquiry completed. 
Q3 23/24: Inquiry has heard all the evidence for the Sect 21.  
Childrens Services
Management
Team; Chief
*Social Work
Officer;  Chief
Officer Young
People and
Partnerships
31-Mar-2024  100%   
SRP.RR.16 Growing Council 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.16
Risk cause
Population growth in Midlothian over the
next 10 to 15 years will see Midlothian
become the fastest growing Council in
Scotland. 
Between 2014 and 2039, ages 0-15yrs,
population is projected to increase by 20%
and for ages 75+ population projected to
increase by 100%. 
Risk event 
Failure to resource and plan for these rises
will significantly impact the Councils ability
to fulfil its statutory obligations in relation to
these groups. 
Risk effect Inadequate capacity within the
Head of *Adult
and Social Care;
Chief *Executive;
Executive
Director *Place;
Fiona
*Robertson;
Chief Officer
Young People
and Partnerships
1. Local development plan and supplementary guidance on developer
contributions. 
2. Services planning future service provision on the basis of anticipated
service demands 
3. The change programme 
4. Learning Estate Strategy 
5. Capital Plan Prioritisation 
6. Strategic Housing Investment Strategy 
7. Rent Review Strategy 
8. Joint needs assessment used to develop - IJB Strategic Plan 
9. Capital Plan and Asset Management Board will scrutinise and
challenge slippage on capital programmes recognising that slippage can
have an adverse impact on financial sustainability and also the delivery
on assets required to support capital growth. 10. City Deal provides the
opportunity to support inclusive growth.  
4 4 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
school estate to cope with the projected
increase in pupil numbers. In sufficient
provision to support an aging population
placing costly inefficiencies on other parts
of the care sector. General population
increase placing additional demand on
infrastructure including GP services.
Increased pressure on infrastructure,
services e.g., waste collection and growth
of road network as new development
roads are adopted. 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.06 Capital Plan prioritisation 
Q2 24/25: Work continues on Capital Plan prioritisation. 
Q1 24/25: Work continues on Capital Plan prioritisation. 
Q4 23/24: Work continues on Capital Plan prioritisation.   
Q3 23/24: Work continues on Capital Plan prioritisation.  
Head of
*Development;
Executive Director
*Place; Chief
Finance Officer; 
31-Oct-2024  75%    
SRP.RR.17 UK Decision to leave the EU 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.17
Risk cause
UK vote to leave the European Union 
Risk event
UK leaving the European Union 
Risk effect The impacts associated with
the UK's decision to leave the UK have yet
to be realised and will only become clear
once the final terms of the UK's departure
are finalised. There are some direct
potential impacts such as an end to EU
funding of Council co-ordinated projects
and indirect impacts on industries
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
1. Risk and Resilience Group 
2. Taking a risk management approach to identifying and assessing
anticipated impacts 
3. Working with a range of national and local bodies to inform preparatory
arrangements. 
4. EU Settlement scheme promoted on Council Internet to support those
living and working in Midlothian to access the Home Office scheme.  
4 5 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
undertaken within the geographical area
which have relied on EU funding, such as
agriculture. There are wider potential
implications arising from uncertainty
regarding the resident status of EU
nationals, post any exit agreement, and
the availability of workers from outside the
UK accessing the job market here in the
future. These factors have the potential to
impact on the availability of the right
people with the right skills being available
to help grow the economy here in
Midlothian. One area this could affect the
Council could be in the delivery of future
building projects within Midlothian which
could curtail further economic growth.  
Finance Officer;
Chief Officer
Young People
and Partnerships                
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.17.01 Refresh of Economic Strategy
Q2 24/25: Member Briefing delivered on Midlothian Strategy for Inclusive
Economic Growth, with report prepared for Council in November. 
Q1 24/25: Member Briefing scheduled for 3rd October 2024. 
Q3 23/24: Draft Economic Strategy prepared; to be presented to Council in Q1
24/25.  
Chief Officer
*Place; 30-Jun-2024  60%    
SRP.RR.19 Health & Safety 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.19
Risk cause
Failing to identify and rectify non-
compliance with Health and Safety
regulations. 
Risk event
Employees required to undertake tasks
they are not competent to. 
Statutorily driven health and safety
protective arrangements for service users
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
1. Health Safety and Wellbeing Strategy & Service Plan 
2. Suite of Health and Safety Management Arrangements developed
setting out council response to statutory obligations 
3. Comprehensive range of Health & Safety Management & Assessment
based development opportunities for line managers 
4. Use of Health & Safety Management Information System (SPHERA) to
enhance information transfer and organisational efficiency 
5. Comprehensive training programme in place to support those with
responsibility for managing health and safety. 
6. Use of comprehensive audit programme to confirm the application of
3 5 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
and employees not implemented correctly. 
Non-compliance with policy and procedure 
Not undertaking audits and inspections to
confirm adherence to policy and legislative
requirements. 
Risk effect 
Serious injury of ill health impact on
employees and or service users. 
Negative impact on outcomes for
customers/service users. 
Service users and employees exposed to
hazards where statutory requirements
exist. 
Statutory health and safety - duty of care
over services users and employees not
met. Criminal prosecution of the Corporate
body and or individuals through Corporate
Homicide (Corporate Manslaughter)
Significant financial penalties from Criminal
Prosecution.  
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
David Robertson;
Chief Officer
Young People
and Partnerships
agreed management Arrangements and Council Policy. 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
NEW 
Health, Safety & Resilience Service
Review 
Q2 24/25: Service Review progressing and developing. 
Q1 24/25: The Health, Safety & Resilience Service review is progressing and
has identified staffing shortages to meet obligations. The report will be
submitted in Q2 for consideration. 
Q4 23/24: Service review in progress.
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31/07/2024  100%
SRP.RA
.19.01
Delivery of Health, Safety and Wellbeing
Service Plan 
Q2 24/25: Awaiting outcome of service review before reviewing service plan. 
Q1 24/25: Implementation of the Protective Services Health, Safety &
Resilience Service Plan continues. The plan will be reviewed at conclusion of the
service review. 
Q3 23/23: Implementation of the Protective Services Health, Safety &
Resilience Service Plan continues. 
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31-Mar-2025  50%
SRP.RA
.19.07 H&S audit across all Council estate  Q2 25/25: As Q1 24/25.
Chief Officer
*Place; Senior 31-Mar-2025  33%
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Q1 24/25: Fire Risk Assessments/Audits progressing. A number of Zurich
Insurance audits have also taken place. 
Q4 23/24: Fire Risk Assessments/Audits are currently priority. 
Q3 23/24: Work on audit report continues. Change to SFRS response
incorporated into Fire Action Plans and Management Arrangements.  
Manager
Protective
Services; David
Robertson 
SRP.RR.21 Cyber Security 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.21
Risk Cause
Malicious attempts to damage, disrupt or
gain unauthorised access to Council
computer systems, networks or devices. 
Risk Event
The Council is at significant risk of cyber-
attack from Ransomware Phishing Emails,
Advanced Persistent Threats (APT) and
Distributed Denial of Service Attacks
(DDOS) attacks. Hacking and Social
Engineering. 
Risk Effect
Access to Council systems by cyber
criminals and foreign intelligence agencies
for financial, commercial or information
gathering reasons. This could lead to
significant financial losses, data
compromise and subsequent regulatory
sanction if our technical and organisational
measures are deemed insufficient. Severe
business disruption including the almost
total loss of critical IT systems and
networks leading to significant service
delivery challenges.  
Head of *Adult
and Social Care;
Cyber Security
Information
Governance and
*Compliance
Manager; Head
of *Development;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
David Robertson;
Chief Officer
Young People
and Partnerships
1. Implementation of and compliance with the Scottish Government Cyber
Resiliency Public Sector Action Plan 
2. Cyber Essentials Plus Certification 
3. Public Sector Network Certification 
4. Appropriate technical and organisational measures deployed to reduce
the likelihood and impact of an attack 
5. Having adequate skills and knowledge in the organisation 
6. Implementing Scottish Government Cyber Security Action Plan 
7. Creating a Midlothian Cyber Defence Action Plan. 
8. Adoption of the NCSC (National Cyber Security Centre) Active Cyber
Defence programme  
3 5 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA Appropriate Technical and Organisational Q1 24/25 - Action/mitigation includes: - Cyber Security 31-Mar-2025  75%
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
.21.1 Measures 
1. Achieved Cyber Essentials Plus Certification
2. Achieved PSN Certification from the Cabinet Office
3. Organised and facilitated a leadership forum exercise on cyber
resilience
4. Successfully responded to 15 significant cyber security events
5. Provided significant Information Governance and Security advice for the
continued deployment of M365 and Google Workspace 
Q4 23/24: Ongoing review of cyber incident response plans. Information
Governance and Security processes for M365 deployment ongoing and a number
of milestones achieved to progress further rollout of applications within M365
environment. Leadership Forum tabletop session scheduled June 2024. 
Q3 23/24: Action/mitigation includes: - 
1. Updated cyber incident response plans. 
2. Cyber security presentations to Elected Members and Place directorate. 
3. Conducted phishing exercises. 
4. Successfully responded to 13 cyber security events. 
Provided significant Information Governance and Security advice for the
deployment of M365 and Google Workspace 
Q1 23/24: Action/mitigation includes:- 
1. Achieved Cyber Essentials Plus Certification 
2. Preparations completed for Q2 2023/2024 PSN Certification, including
submission to Cabinet Office. 
3. Provided significant Information Governance and Security advice for the
deployment of M365 and Google Workspace 
4. Responded to numerous threat alerts to ensure the security of the Council’s
network 
5. Engaged with Cyber Incident Response company to review the Councils Cyber
Incident response capability in Q2 
Information
Governance and
*Compliance
Manager; Chief
*Digital Officer;    
SRP.RR.22 Cost of Living Crisis 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.22
Risk cause
The UK is currently facing an
unprecedented storm of increasing prices,
bills and tax. The 40-year high inflation
Chief *Executive;
Director *Health
and Social Care;
Executive
1. Council Cost of Living Task Force to oversee the Council’s response to
the crisis 
2. Allocation of LACER funding to support those most affected 
3. Strategic Evaluation Partner appointed to create poverty profile 
3 5 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
rate of 9% is the main driver of the cost of
living crisis which has outstripped wage
and benefit increases. 
Risk event
Rapid ongoing rise of energy prices as well
as food and drink prices. 
Risk effect The impact on households is
already being noted with 87% of adults in
the UK reported an increase in their cost of
living in April 2022 (Office for National
Statistics; Francis-Devine et al, 2022). The
price rises will impact low-income
households the hardest as a larger
proportion of their bills are on energy and
food. The Resolution Foundation estimates
an extra 1.3 million people will fall into
absolute poverty in 2023, including
500,000 children. 
Director *Place 4. Community Planning Partnership has established a Midlothian
Strategic Poverty Prevention Group co-chaired by Council Leader and
Director of Public Health 
5. New Child Poverty chair and lead appointed (Executive Director
Children, Young People and Partnerships) 
6. Child Poverty self-evaluation underway with Improvement Service                  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.22.1 Cost of Living Task Force Q1 23/24: Meetings continuing.   Chief *Executive;  31-Mar-2024  100%
SRP.RA
.22.2 LACER funding
Q2 22/23: Identification of 15 trusted partners to distribute funding in
communities for food and fuel, wash and dry provision and support to establish
reheatable food initiatives.  
Lifelong Learning
and Employability;  31-Mar-2023  100% 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
Strategic Opportunities 
SRP.OP.08 Capital Projects - Housing 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.08
26% reduction in Affordable Housing
Supply Programme grant to Midlothian and
continued high build costs will affect ability
to deliver housing programme. 
Projects progressing, with Timeline,
Budget, Risk and Resource categorised as
parameters on a RAG status, with any Red
classifications identified and reported.   
Executive
Director *Place;
Head of
Development  
1. Newbyres, Gorebridge: Timeline impacted with potential ground
conditions and delay with peer review process. This has since been
addressed and now on site.
2. Edmonstone Road, Shawfair – Timeline, Budget and Risk impacted
with Stewart Milne entering administration.  Developer now in process of
being appointed to take this forward.
3. Newton Church Road, Danderhall – Timeline impacted with delays to
tender process as contractors requested extensions and in delivering
tender report.  Tender report now approved and works to start before end
of 2024. 
Phase 5 housing programme has been reviewed to ensure affordability
within the Housing Revenue Account, allowing for reduced levels of grant. 
Timeline Budget Risk Resource
R G G G
R A A G
R A A G           
SRP.OP.09 Capital Projects – Transport, Net Zero & Infrastructure 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.09
Cost of delivering enabling infrastructure
projects has risen, resulting in significant
funding gap emerging. 
Projects progressing, with Timeline,
Budget, Risk and Resource categorised as
parameters on a RAG status, with any Red
classifications identified and reported.  
Executive
Director *Place;
Head of
Development  
1. A701 Relief Road
2. A701 Sustainable Trasport Corridor
3. A701 Straiton Junction Improvements 
For all highlighted projects, estimated cost significantly exceeds budget
available to deliver project. 
For all highlighted projects, addressing requirement for investment in
A701 corridor in phases with prioritisation applied. Bush Loan Junction
progressing ahead of remaining programme fully funded by ESESCRD
funding. 
Timeline Budget Risk Resource
A R R G
A R R G
A R R G 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
SRP.OP.10 Capital Projects – Children, Young People & Partnerships Estates Programme: Primary 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.10
Projects progressing, with Timeline,
Budget, Risk and Resource categorised as
parameters on a RAG status, with any Red
classifications identified and reported.  
Executive
Director *Place;
Executive
Director CYPP;
Head of
Development  
1. Mayfield/St Lukes PS New Build: Tender return from Stage 1
exceeds available budget. Programme delayed for project
revision. Existing school remains safe while operational. 
2. Mauricewood PS Extension & Refurbishment: Rising roll and
catchment review requires investment in school to address
capacity and suitability. Limited budget available.  Design team
appointed to develop investment in school that aligns with
budget available from Developer Contributions.
3. Bilston PS Extension: Rising roll and catchment review requires
investment in school to address capacity and suitability. Limited
budget available.  Design team appointed to develop
investment in school that aligns with budget available from
Developer Contributions.
4. Relocation of Mount Esk Nursery / Hawthorden Extension:
Rising roll and catchment review requires investment in school
to address capacity and suitability. Limited budget available. 
Design team appointed to develop investment in school that
aligns with budget available from Developer Contributions. 
Timeline Budget Risk Resource
R R R A
R A A A
R A A A
A A A A 
SRP.OP.09 Capital Projects – Children, Young People & Partnerships Estates Programme: Secondary 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.09
Projects progressing, with Timeline,
Budget, Risk and Resource categorised as
parameters on a RAG status, with any Red
classifications identified and reported.  
Executive
Director *Place;
Executive
Director CYPP;
Head of
Development  
1. Beeslack HS Replacement: Site acquisition being progressed,
however dependent on planning being achieved (expected 
Dec 24). Contractor appointment delayed. Programme behind
due to changes in scope / design.  
2. Shawfair All Through: Site acquisition complete. School
location fixed with design team. Remediation programme being
revised. School target date of 2027 likely to be missed.
Outcome of design process to determine cost of project and
budget position.  Design outcome to be to adhere to available
budget. Smaller school will reduce build programme. Seeking
to make efficiencies in remediation programme.
3. Penicuik HS New Build: LEIP target for delivery is Dec 2026, 
Timeline Budget Risk Resource
A A A G
R A A A
A A A G
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
however programme for occupation is July 2027. Cost reports
tracking higher and risks identified in refurbishment works. 
Removing requirement for modular units and minimising
enabling works will assist minimising impact on GSCP. Design
review can bring project into budget. SFT advising if additional
LEIP funding available to address abnormal costs. 
SRP.OP.09 Capital Projects – Regeneration 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.10
Projects progressing, with Timeline,
Budget, Risk and Resource categorised as
parameters on a RAG status, with any Red
classifications identified and reported.  
Executive
Director *Place;
Head of
Development  
1. Vogrie Changing Places: issues with contractor.
2. Destination Hillend: Alpine Coaster delivered with access and
parking infrastructure. Project absorbed risk and contingency. 
Delays to delivery resulting from issues with access / water
mains. Main Building tender return exceeded budget. Next
Phase to be recast. Interim works on water supply and
drainage required.
3. Hopefield Industrial Estate: Updated financial model required.
4. Extension to Waste Transfer Shed – Stobhill Depot
5. Dalkeith Asset Rationalisation Programme: Budget now
approved by Council. Appointments/procurement strategy
being updated and stakeholder consultation to commence. 
Timeline Budget Risk Resource
R A R A
R R R A
R A A G
G A A G
A G A G   
SRP.OP.04 City Deal 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.O
P.04
South East Scotland Region City Deal - a
bid for funding to Scottish and UK
Governments to accelerate economic
growth through investment in
infrastructure/ housing/ skills and
innovation. 200 Council Houses linked to
the City Deal. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
1. City Deal signed in August 2018. 
2. Maintain strong Midlothian involvement through the City Deal
governance structure. 
3. Midlothian City Deal Key Officer (Internal) Group. 
4. Securing best arrangements for Midlothian through close liaison with
partners and conclusion of business cases.  
4 5 
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STRATEGIC RISK PROFILE, Q2 July - September 2024 v3.1 
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships                
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.O
P.04.02
Realisation of outcomes of respective
workstreams Q1 24/25: Work continues on the relevant programmes.   Executive Director
*Place 31-Mar-2025  10%           
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
STRATEGIC RISK PROFILE, Q3 October-December 2024 
SRP STRATEGIC RISK PROFILE 
SRP This risk register captures the main strategic issues, risks and opportunities that are corporate in nature. It identifies the nature of the risks, measures required to control the risks and their evaluation. It also
details what further actions are required to reduce the likelihood and impacts of those risks to more acceptable and manageable levels with timescales.   
Strategic Issues 
SRP.IR.02 The Change Programme 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.IR.
02
Risk cause
The pace of transformation strands of
activity, reporting to the Business
Transformation Board, does not secure
service transformation, delivery of
outcomes or benefit realisation. 
Risk event
Delayed progress or non-achievement of
outcomes and benefits. 
Risk effect 
Slow or delayed financial benefits arising
from service redesign, requiring the
adoption of recovery plans or requiring
short term service reductions which impact
on the Council’s ability to deliver against
its priorities. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Transformation Blueprint agreed at Council June 2023 which is a 5-
year transformation plan. Revised governance for transformation agreed
and revised Terms of Reference in place for the Business Transformation
Board to oversee progress on change programme. 
2. Regular reporting to Council setting out scale of financial challenge
ahead with recurring expenditure for current service delivery projected to
exceed recurring income. 
3. Cross Party Business Transformation Steering Group are given
updates on the progress of the Transformation programme. 4. Financial
monitoring reports and work of the Financial Management Corporate
Management Team evidence continued financial sustainability, in so far
as services are delivered within the overall budget in year.  
5 5 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
.  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SPR.R
A-02.08 Transformation Blueprint 2023-28 delivery
Q3 24/25: As Q2 24/25. 
Q2 24/25: Progress with sprints is reported to BTB at every meeting via the
dashboard and also in detailed reports at some points. BTSG are provided with
an updated dashboard every cycle and receive focused reports on individual
sprints and also funding requests to release BT funds to support project work. 
Q1 24/25: As Q4 23/24. 
Q4 23/24: Work on sprints continues with some reporting to BTSG in the run
up to June Council with the majority of others scheduled for August. BTB is now
meeting fortnightly to encourage and closely monitor progress. To support
monitoring of progress a dashboard has been developed and this is shared with
CMT and BTSG as a standing item. 
Q3 23/24: Regular review and updates to the Business Transformation Board
which meets monthly. Transformation Manager in post and sprints initiated.  
Chief *Executive;
Chief Officer
*Place; Chief
Officer Corporate
Solutions; Chief
Finance Officer; 
30-Jun-2028  20%
SRP.R
A.02.03
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability.
Q3 24/25: An update on the MTFS was presented to Council in December along
with outcomes from the public consultation. Detailed analysis of emerging
national budget positions for 2025/26 was presented and discussed at the
Business Transformation Group. 
Q2 24/25: Further update on the MTFS was presented to Council in October
and a public consultation was launched on 9th October running to 20th
November. 
Q1 24/25: An update on the MTFS was presented to Council in June 2024. This
identifies immediate actions required, in addition to those in the Transformation
Blueprint, to bridge the gap between recurring expenditure and recurring
income and to allow the setting of a balanced budget for 2025/26.   
Q4 23/24: An update on the MTFS with refreshed projections and a clear plan
to address financial sustainability will be presented to Council in June 2024. 
Q3 23/24: As Q1. Preparations for MTFS at February Council.  
Chief *Executive;
Chief Finance
Officer;
30-June-2024  100%
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
SRP.IR.07 Financial Sustainability 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.IR.
07
Risk cause
Scottish Government Grant settlements
fall short of the resources needed to
sustain core services. Core funding falling
short of inflation pressures, pay awards
and demographic pressures arising from
an Increasing ageing population of over
75’s. 
Increasing population of 0-15 age group
and at a time when there are rising
customer expectations. 
Risk event
Transformation activity and the flexibility
available to Councils as part of the grant
settlement does not address future years
projected budget gaps. 
Risk effect Inadequate government
funding makes securing balanced budgets
challenging. This in turn erodes the
Council’s ability to deliver services to the
community and potentially means that
resources available fall short of those the
Council assess as required to meet its
statutory obligations. Whilst transformation
activity can help reshape services and
ensure best value in the delivery of
services it is not a solution to continued
erosion of core funding. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. There is an approved Capital Strategy and Reserves Strategy in place.
The Capital Strategy is being updated in the context of ongoing and
significant infrastructure pressures. 
2. There is an approved budget for 2024/25. Services are delivered
within the totality of that budget. 
3. Enhanced monitoring arrangements have been agreed for service
areas that are regularly showing overspends. 
4. Directorates have budget boards in place to monitor and agree actions
for those items which are identified as needing specific attention or
present a risk to the financial position of services. 
5. Strategic Boards in place and BTB focus and attention on driving
transformation to support future year’s financial sustainability. 
6. Working through COSLA to influence government spending decisions
to influence Scottish Government’s budget allocation to Councils. 
7. Capital Plan and Asset Management Board will scrutinise and
challenge slippage on capital programmes recognising that slippage can
have an adverse impact on financial sustainability and also the delivery
on assets required to support capital growth. 
8. Chief Executive continues to emphasise the need for effective financial
control and underlined the benefit to the organisation of such an
approach.  
9. Scottish Governments May 2022 Resource Spending Review provided
planning parameters for term of parliament, albeit these are challenging
and present a real terms reduction in grant funding of circa 7% over the
period. 
10. Report to Council February 2024 sets out scale of financial challenge
ahead with recurring expenditure for current service delivery projected to
exceed recurring income. Updated MTFS projections presented in June
2024 with a further update due in February 2025.
11. Cross Party Business Transformation Steering Group engaged in
consideration of measures to secure balanced budgets alongside the
development of a Strategic Plan to support decisions about what
services, beyond those which are statutory can be provided.  
5 5 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SPR.R
A-02.09 Transformation Blueprint 2023 to 2028
Q3 24/25: Refer to SRP.RA-02.08 
Q2 24/25: Refer to SRP.RA-02.08 
Q1 24/25: As Q4 23/24. 
Q4 23/24: Work on sprints continues with some reporting to BTSG in the run
up to June Council with the majority of others scheduled for August. BTB is now
meeting fortnightly to encourage and closely monitor progress. To support
monitoring of progress a dashboard has been developed and this is shared with
CMT and BTSG as a standing item. 
Q3 23/24: Regular review and updates to the Business Transformation Board
which meets monthly. Transformation Manager in post and sprints initiated.  
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2024  20%
SRP.R
A.02.03
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability.
Q3 24/25: Refer to SPR.RA-02.03 
Q2 24/25: Refer to SPR.RA-02.03 
Q1 24/25: An update on the MTFS was presented to Council in June 2024. This
identifies immediate actions required, in addition to those in the Transformation
Blueprint, to bridge the gap between recurring expenditure and recurring
income and to allow the setting of a balanced budget for 2025/26. 
Q4 23/24: An update on the MTFS with refreshed projections and a clear plan
to address financial sustainability will be presented to Council in June 2024. 
Q3 23/24: As Q1. Preparations for MTFS at February Council.  
Chief *Executive;
Chief Finance
Officer; 
30-June-2024  100%
SRP.R
A-02.10 Capital Plan Prioritisation
Q3 24/25: Work continues on Capital Plan Prioritisation 
Q2 24/25: Work continues on Capital Plan prioritisation 
Q1 24/25: Work continues on Capital Plan prioritisation 
Q4 23/24: Work continues on Capital Plan prioritisation 
Q3 23/24: Work continues on Capital Plan prioritisation  
Chief Finance
Officer; Executive
Director – Place;
Executive Director
- Education
31-Oct-2024  0%   
SRP.IR.11 National Care Service
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.IR.
11
Risk cause
In August 2022 the Scottish Government
launched a 12-week consultation on the
way in which social care is delivered in
Scotland. The consultation followed
recommendations made in the
Independent Review of Adult Social care.
The independent analysis of responses
was published in February 2022. On 20
June 2022 the Scottish Parliament
published the National Care Service
(NCS) Bill which will provide the
foundation for the NCS. 
Risk event
A Bill passes through various
Parliamentary stages. The Bill is currently
in Stage 1 of the process. The most
significant part of the legislation which
poses the most risk is the intention to
transfer social care responsibility from
local authorities to a new, national service. 
Risk effect 
The details of the logistics of any transfer
are not yet provided within the Bill. It is not
clear the extent to which powers will be
removed from local authorities or what the
provision or delivery of services will or will
not be. 
At this stage, the risk effect is anticipated
to be significant financial impact to local
authorities and IJBs, as well as the
potential for impacts on staffing, transfer of
property and facilities and the reshaping of
the delivery of care. 
It should be noted that the initial impact on
the Council is staff time to contribute to the
ongoing discussions and understanding of
the impact of the Bill.  
Head of *Adult
and Social Care;
Chief *Executive;
Director *Health
and Social Care;
Executive
Director *Place;
Chief Officer
Young People
and Partnerships
As of 14 November 2024, a pause has been placed on the delivery of
NCS legislation by the Scottish Government. 
NOTE: As of Jan 2025, the National Care Service proposal is now
not proceeding.
N/A N/A N/A                
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.11.1 Officer Working Group 
Q3 24/25: Scottish Government announced in January 2025 that they will not
be proceeding with the National Care Service. 
Q2 24/25: As of 14 November 2024, the Scottish Government has paused
legislation on the creation of a NCS. 
Q1 24/25: The Bill is at Stage 2 
Q4 23/24: The Bill is at Stage 2. 
Q3 23/24: Further information now expected late March 2024.  
Chief *Executive;  31-Dec-2024  100%   
Strategic Risks 
SRP.RR.01 Financial Sustainability in Future Years 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.01
Risk cause:
Scottish Government Grant settlements
fall short of the resources needed to
sustain core services. Core funding falling
short of inflation pressures, pay awards
and demographic pressures arising from
an Increasing ageing population of over
75’s. 
Increasing population of 0-15 age group
and at a time when there are rising
customer expectations. 
Policy decisions by UK & Scottish
Governments which are not fully funded. 
Changes to the responsibilities of Local
Government and the funding implication
that arise from that, particularly in respect
of the creation of a National Care Service. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
1. Development of Strategic Plan, Transformation Blueprint and MTFS
projections which come together to provide a framework to effect change
and to move the Council to a position of financial sustainability. 
2. Maintaining a level of reserves to deal with unforeseen or one-off cost
pressures. 
3. Capital and Reserves Strategies in place. The Capital Strategy is
being updated in the context of ongoing and significant infrastructure
pressures. 
4. Working through COSLA to influence government spending decisions
to influence Scottish Government’s budget allocation to Councils. 
5. Implement a lobbying strategy with government to recognise the
unique position Midlothian Council is in. 
6. Best Value Audit report actions. 
7. Strategic Boards in place to drive transformation in line with the
Transformation Blueprint. 
5 5 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Future year pay award settlements. 
Risk event: 
Real terms reduction in core grant
settlements. 
Policies decisions at Government level not
fully funded to Council's. 
Implementation of a National Care Service
and impact on grant settlements. 
Securing the extent of change required in
order to deliver financial sustainability and
a change program that recognises the size
of the challenge. 
Cost pressures exceeding budget
estimates. 
Risk to not achieving financial
sustainability is a failure to deliver cost
reductions / service change embedded in
the blueprint and also supplementing the
blueprint.   
Young People
and Partnerships
8. Dedicating capacity to understand impact of NCS Bill, but limited
details mean this is challenging and many unanswered questions (refer
to specific risk on NCS for further detail).                  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.03
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability.
Q3 24/25: Refer to SRP.RA-02.03 
Q2 24/25: Refer to SRP.RA-02.03 
Q1 24/25: An update on the MTFS was presented to Council in June 2024. This
identifies immediate actions required, in addition to those in the Transformation
Blueprint, to bridge the gap between recurring expenditure and recurring
income and to allow the setting of a balanced budget for 2025/26. 
Q4 23/24: An update on the MTFS with refreshed projections and a clear plan
to address financial sustainability will be presented to Council in June 2024. 
Q3 23/24: As Q1. Preparations for MTFS at February Council.  
Chief *Executive;
Chief Finance
Officer; 
30-June-2024  100%
SRP.RA
.02.04 Transformation Blueprint 2023 to 2028
Q3 24/25: Refer to SRP.RA-02.08 
Q2 24/25: Refer to SRP.RA-02.08 
Q1 24/25: As Q4 23/24. 
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2028  20%
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Q4 23/24: Work on sprints continues with some reporting to BTSG in the run
up to June Council with the majority of others scheduled for August. BTB is now
meeting fortnightly to encourage and closely monitor progress. To support
monitoring of progress a dashboard has been developed and this is shared with
CMT and BTSG as a standing item. 
Q3 23/24: Regular review and updates to the Business Transformation Board
which meets monthly. Transformation Manager in post and sprints initiated.  
SRP.RA
.02.06 Capital Plan prioritisation
Q3 24/25: Work continues on Capital Plan Prioritisation 
Q2 24/25: Work continues on Capital Plan prioritisation 
Q1 24/25: Work continues on Capital Plan prioritisation 
Q4 23/24: Work continues on Capital Plan prioritisation.   
Q3 23/24: Work continues on Capital Plan prioritisation.  
Head of
*Development;
Executive Director
*Place; Chief
Finance Officer; 
31-Oct-2024  0%    
SRP.RR.02 The Long-Term Change Programme 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.02
Risk cause:
A MTFS that does not address the
projected budget shortfall or contextual
factors relating to the Midlothian area. 
Reduced resources 
Leadership fit for the future. 
Lack of clarity or clear compelling vision
for the future 
Delay or shortfall in securing savings 
Lack of or not securing transformational
change in service provision 
Risk event:
Delayed progress in applying various
strands of the Change Programme
including Delivering Excellence
Framework 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Development of Strategic Plan, Transformation Blueprint and MTFS
projections which come together to provide a framework to effect change
and to move the Council to a position of financial sustainability. 
2. Leadership from all Elected Members, Executive Team and Senior
Leadership Group. 
3. Appropriate governance in place across the BTB Strategic Boards 
4. Resilience planning. 
5. Capacity to deliver change. 
6. Dedicating capacity to understand impact of NCS Bill, but limited
details mean this is challenging and many unanswered questions (refer
to  specific risk for NCS Billl).
7. High level priority is given to blueprint work.    
5 5 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Slow benefits realisation and budget
savings. Cuts in service provision rather
than service transformation 
Risk effect:
Objectives of change not actually met or
progress too slow. Adverse impact on
services Slow or delayed
proposals/savings arising from service
redesign. Potentially further eroding
reserves or requiring short term service
reductions which impact on Council's
ability to deliver against its priorities. Staff
morale negatively affected, Government
step-in short term savings instead of
transformation                  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.02.03
Develop Medium Term Financial Strategy
with greater oversight, clearer
responsibility and accountability.
Q3 24/25: Refer to SPR.RA-02.03 
Q2 24/25: Refer to SPR.RA-02.03 
Q1 24/25: An update on the MTFS was presented to Council in June 2024. This
identifies immediate actions required, in addition to those in the Transformation
Blueprint, to bridge the gap between recurring expenditure and recurring
income and to allow the setting of a balanced budget for 2025/26. 
Q4 23/24: An update on the MTFS with refreshed projections and a clear plan
to address financial sustainability will be presented to Council in June 2024. 
Q3 23/24: As Q1. Preparations for MTFS at February Council.  
Chief *Executive;
Chief Finance
Officer;
30-June-2024  100%
SRP.R
A.02.04 Transformation Blueprint 2023 to 2028
Q3 24/25: Refer to SRP.RA-02.08 
Q2 24/25: Refer to SRP.RA-02.08 
Q1 24/25: As Q4 23/24 
Q4 23/24: Work on sprints continues with some reporting to BTSG in the run
up to June Council with the majority of others scheduled for August. BTB is now
meeting fortnightly to encourage and closely monitor progress. To support
monitoring of progress a dashboard has been developed and this is shared with
CMT and BTSG as a standing item.
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2028  20%
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Q3 23/24: Regular review and updates to the Business Transformation Board
which meets monthly. Transformation Manager in post and sprints initiated.     
SRP.RR.03 Legal and Regulatory Compliance 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.03
Risk cause
Current or new legislation applying to
Midlothian Council.
Lack of capacity to resource statutory
obligations around GDPR, data protection,
records management, information
requests and statutory regulatory
functions. 
Risk event
Council and or Services not identifying all
applicable legislation impacting Council
activities and Service requirements. 
Risk effect
Council failing to meet its statutory
obligations resulting in a potential negative
impact for service users or employees.
Reputational impact of not meeting
statutory obligations.  
Head of *Adult
and Social Care;
Legal *and
Governance
Manager; Chief
Operating Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Executive Directors, Chief Officer(s) and Head(s) of Service
responsible for identifying applicable legislation and propose Council or
Service responses to CMT and Cabinet/Council as required. 
2. Annual Assurance Statement. 
3. Internal Audit testing of internal controls as part of risk-based audit
plan. 
4. External Audit. 
5. Range of external inspection. 
6. BTSG oversight of new legislation 
7. Central repository of applicable legislation.  
5 5 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.03.02 Rights of the Child Bill
Q4 23/24: Q4 Council wide group established and developing a plan that
ensures we are all aware and adhering to UNCRC. 
Q3 23/24: Bill now adopted. Policy to be presented to Council May/June 2024.  
Executive Director
– People  31-Dec-2024  0%
SRP.R
A.03.03 National Care Service  Q3 24/25: Scottish Government announced in January 2025 that they will not
be proceeding with the National Care Service.  Chief *Executive;  31-Dec-2024  0%
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Q2 24/25: As of 14 November 2024, the Scottish Government has paused
legislation on the creation of a NCS. 
Q1 24/25: The Bill is at Stage 2.
Q4 23/24: Q4 National Care Service is at stage 2 and we await decisions
around what next.
Q3 23/24: National Care Service Bill has been delayed for any further decision
until the 1st March 2024.  
SRP.R
A.03.05
Review of Standing Orders, Scheme of
Administration and Scheme of Delegation
Q4 23/24: Workplan presented and agreed by SOWG in April 2024. Some
changes to SOs and Scheme of Administration presented and approved by
Council in May 2024 (this is technically Q1 2024/25 update). 
Legal &
Governance
Manager;
Executive Director
*Place; Chief
Officer Corporate
Solutions;
31-Dec-2024  40%
SRP.R
A.03.07
Review of policy and creation of a policy
register
Q4 23/24: work to develop policy register ongoing. 
Q3 23/24: Corporate Solutions has initiated a review of policies in the Council,
aligned to legislation changes and statutory requirements for the Local
Authority. Work is ongoing to gather information across the Council to inform an
action plan and a refreshed policy register. It is estimated that this work will
take until end 2024 to be completed. 
Chief Officer
Corporate
Solutions
31-Dec-2024  10%
NEW Compliance with statutory duties
Q1 24/25: Records Management Officer in post and reviewing the Records
Management Plan, Corporate Retention Policy and Schedule and supporting the
development of retention framework for M365 rollout.  
Q4 23/24: Work is ongoing with the Scottish Information Commissioner and
National Records of Scotland to develop and deliver improvement plans.
Ongoing recruitment for Records Manager. Rationale report for resourcing in
development. Significant resourcing pressures contribute to the increase in
scoring for Q4.
Chief Officer
Corporate
Solutions, Legal
and Governance
Manager 
31-Dec-2024  10%   
SRP.RR.04 Employee performance 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.04
Risk cause
Employees not suitably trained/developed
for the roles required of them. 
Limited availability of qualified
practitioners in certain sectors. 
Change program not informed by all key
stakeholders. 
Ageing work force. 
Employees unclear on expected
behaviours. 
Employees constrained to innovate as a
result of management practice. 
Employee productivity rate below the
required level because of ineffective use
of the People Policies particularly
Maximising Attendance. 
Salaries in some functional areas lower
compared to other LA’s resulting in
recruitment issues particularly with trying
to recruit experienced staff. 
Risk event
Employees not engaged/consulted as part
of organisational transformation. 
Experienced employees leaving the
organisation. 
Inability to recruit suitably qualified /
trained staff to fill vacancies negatively
impacting on remaining workforce. 
Unacceptable behaviours demonstrated
by employees. 
Stated organisational culture not
consistently reinforced by managers. 
Poor employee performance will stifle
transformational change. 
Risk effect
Difficulties recruiting the right staff. 
Challenges retaining quality staff. 
Low skill levels. 
Low morale, especially during change. 
High absence rates, loss of experience in
service areas. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
HR Strategic
Lead; Chief
Officer Young
People and
Partnerships
Over-riding risk control measure = Focus on having the right people,
here, healthy, performing, behaving and well led via effective utilisation of
the workforce strategy and accompanying action plan. 
Attendance / Wellbeing
1. Continuing implementation of the Wellness@Midlothian agenda. 
2. Creation of an Employee Health and Wellbeing Strategy and
supporting policy. 
3. Maintaining the Healthy Working Lives Gold Award. 
4. Proactive use of Occupational Health, Midlothian Physiotherapy,
Employee Assistance Programme and the Workplace Chaplaincy
Service. 
5. Change of EAP supplier to ensure provision of best possible service. 
6. Development of progressive People Policies. 
7. Roll-out of mental health training for staff and managers. 
Performance
1. Service-level workforce plans. 
2. Structured, robust, well established ‘Making Performance Matter’
Framework where expected standards of behaviour and Council values
are re-enforced. 
3. Continued re-enforcement of all People Policies involving various
communication methods. 
4. Development of a suite of management information to ensure Service
Managers are informed e.g., turnover, absence levels/reasons etc. 
Organisational Change
1. Policy for Organisational Change includes strong emphasis on early
engagement of employees. 
2. Redeployment Procedure to ensure maximum chance of successful
redeployment. 
Conduct
1. Resolution Policy encourages early intervention of workplace issues. 
2. Professional standards and values build into the induction process and
management development programme. 
Communication
1. A range of initiatives to keep staff informed of change (Chief
Executive’s weekly email, Connect, All staff emails, tailored team
briefings etc.  
3 4 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
‘A Great Place to Grow’ our values
including respect, collaboration, pride and
ownership not realised, potentially
resulting in missing the opportunity to
capitalise on the abilities, experience and
ideas of team members. Poor employee
performance will Exacerbate the financial
challenge. 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.04
Development and Delivery of the Council’s
Workforce Strategy 2024-29 including
analysis of future workforce requirements,
gap analysis and gap closing strategies,
and performance measures and target
setting.
Q1 24/25: Workforce Strategy in development and expected to be presented
to December Council with Action Plan for approval. Audit Scotland external audit
on workforce and digital to be presented to Audit Committee September 2024. 
Q4 23/24: Ongoing work nationally to review workforce planning which
Midlothian is contributing to. Best Value focus this year is on workforce planning
– awaiting outcome of external audit to identify improvement plan for 24/25. 
Q3 23/24: Service plans were presented to June 2023 council. Supporting
workforce plans are due to be fully in place for June 2024. The workforce
planning process, guidance and documentation has been developed and
approved for use by managers across the council. The HR team is available to
support managers who wish help and guidance in the development of these
workforce plans. 
Chief Officer
Corporate
Solutions 
31 Dec 2024   25%   
SRP.RR.07 Care at Home 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.07
Risk cause
Internal and External providers of Care at
Home services unable to meet service and
quality requirements as a result of a lack
of capacity. 
Risk event
Head of *Adult
and Social Care;
Director *Health
and Social Care
1. Care at Home winter assurance plan and business continuity plan
complete 
2. Development of Care at Home Service Improvement action plan near
completion 
3. External commissioning complete and ongoing contract monitoring in
place 
4. External provider audits complete 
3 4 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Capacity of Community Support
outstripped by demand. 
Risk effect
There is a risk that patients will have their
discharge delayed because there is
insufficient community supports to enable
timely discharge leading to deterioration in
their health, beds being blocked and
elective operations potentially being
cancelled.  
5. Re-established Multi-Agency Quality in Care at Home quarterly review
meetings jointly with East Lothian 
6. Weekly provider meetings in place 
7. Additional locum team members and contracts with agency staff in
place 
8. Daily discharge meeting with Multidisciplinary and Multi-agency team
planning to plan and coordinate discharge to ensure care at hone support
in place                  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.07.01
Independent review of adult and social
care 
Q3 24/25: Scottish Government announced in January 2025 that they will not
be proceeding with the National Care Service. 
Q2 24/25: The Scottish Government has initiated a pause on the development
of the NCS. 
Q1 23/24: Pause remains in place.
Head of *Adult
and Social Care;
Chief *Executive; 
31-Jan-2024  100%     
SRP.RR.08 Asset Management – buildings, vehicles,  roads and Digital assets/networks 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.08 
Risk cause
Many of the assets the Council own by
their nature are in a position of ongoing
deterioration through their normal use,
e.g., roads - normal wear and tear,
streetlights and vehicles & buildings used
to deliver services. 
Risk event
Head of *Adult
and Social Care;
Head of
*Development;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
1. There is provision in place within the capital plan for investment in the
asset base. 
2. Asset register 
3. Condition Survey 
4. Understanding of future asset needs 
5. Asset Strategy: 
. Roads 
. Land 
. Fleet 
. Digital Service Network 
3 5 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Many assets will deteriorate under normal
conditions although buildings, roads and
streetlights as an example can be
damaged during more extreme weather
events or as a result of a lack of
maintenance. 
Risk effect
In the case of Roads Services there is a
real risk of increased potholes and
insurance claims, reduced skid resistance
leading to higher accident potential and
building up of higher costs in the future. In
respect of vehicles, increased
breakdowns, service failures, greater
maintenance inevitable, higher short-term
hire costs. In terms of property, health and
safety issues arise, failure to meet current
standards and higher running costs. There
is also the risk of two-tier accommodation,
some high quality, some low. 
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
. Digital Service hardware 
6. Capital programme - investment in estate. 
7. Ongoing monitoring of properties by: Maintenance Surveyors,
Facilities Management and Property Users. 
8. Established Capital Plan and Asset Management Board and dedicated
Asset Management Board 
9. Establishment of 7 thematic Estate Safety and Management Groups
chaired by Chief Officer Place 10. Building Accessibility Strategy                  
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.08.02
Plan for appropriate investment in capital
works and remedial maintenance over the
lifespan of each property asset.
Q3 24/25:  Condition Surveys of Learning Estate (excl PPP) has concluded.  Q4
presentation to Elected Members.  Backlog repairs continue. 
Q1 24/25: Condition Surveys continue, with Learning Estate (excl PPP)
expected to be concluded by end December 2024 to inform capital investment
proposal. 
Q4 23/24: Backlog maintenance repairs being undertaken across the estate on
a prioritised basis. 
Q3 23/24: Surveyors have now completed the first phase of surveys that were
due to have been completed by March 2024. A further phase will begin in April
and run though until April 2025.  
Chief Officer
*Place;  30-Apr-2025  33%
SRP.R
A.08.05 Learning Estate Strategy
Q4 23/24: All Priority 1 and 2 projects are progressing. In terms of all of the
capacity breaches that were detailed in Priority 2 of the LES, investment was
made to provide a solution. 
Head of
*Development;  30-Apr-2025  50%
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Q3 23/24: All Priority 1 projects as detailed in the Learning Estate Strategy
have been approved by Council in June 2023, this includes Beeslack HS
replacement and Penicuik HS refurbishment & extension. A number of Projects
in the priority 2 tranche have been progressed to ensure schools do not
experience capacity breaches.   
Q3 24/25 Learning Estate Strategy Update paper due to go February Council, this includes
a progress report on status of all approved and ‘approved in principle’ projects. Edge
analytics have also completed their validation of the School Roll Projections.
SRP.R
A.08.06 Asset Management systems
Q4 23/24: As Q3. 
Q3 23/24: Identified for implementation through Transformation Blueprint and
The Change Programme.  
Chief Officer
*Place;  31-Mar-2025  0%   
SRP.RR.09 Emergency Planning and Business Continuity Management 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.09
Risk cause
The Council not preparing or timeously
reviewing Emergency Plans and testing
arrangements to respond to Civil
Contingencies Incidents 
Risk event
There are a wide range of potential events
the Council may be expected to respond
to e.g., Severe weather incident,
Pandemic, Utility disruption etc. 
Risk effect
Censure through non-compliance with the
Civil Contingencies Act Not adequately
recovering from the loss of major
accommodation (e.g., secondary school,
main offices), computer systems and staff
Not able to respond to a major emergency
in the community Fatal Accident Inquiries  
Head of *Adult
and Social Care;
Head of
*Development;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
David Robertson;
Chief Officer
Young People
and Partnerships
1. Civil Contingencies Risk Register used to highlight key risks and
record response, 
- Council’s plans developed and maintained in response to identified
risks, 
- Risk and Resilience Group support development, peer review and roll
out of plans. 
2. Establishment based incident response plans in place and maintained
locally. 
3. Emergency response plan setting out general approach to respond to
a major emergency in-line with key partner organisations. 
4. As part of the Council’s Emergency response the importance of
recording decisions made and information available at the time is
highlighted as this would be scrutinised in the event of an FAI. 
05 – Care for People Group: Afghan, Ukrainian and UASC support
programmes  
3 4 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.09.02 Development of Emergency Plans 
Q3 24/25: The service review for the Health, Safety and Resilience Team
Service, which includes Contingency Planning, has not yet concluded.  This
means ongoing challenges continue, preventing notable progress. 
Plans and Procedures updated this quarter:  
• Midlothian Council Severe Weather Plan 
• Emergency Contacts Directory (reflecting staff changes) 
• Support to the Executive PA Place with the Festive Period Service
Arrangements document. 
Plan updates/procedures in progress:  
• Midlothian Council Emergency Plan (generic). This document outlines
internal emergency management arrangements and multi-agency
partnership relationships.  
• Operation UNICORN (and associated arrangements). Scottish
Government have advised that national planning arrangements are
underway and where relevant to Midlothian, will be incorporated in the
Midlothian Council guidance document.    
• Corporate Business Continuity (BC) Plan has been drafted.  
Multi-agency Exercises, Training, Presentations, Work streams:  
• Participated in a Cyber Security training exercise organised by Digital
Services in liaison with an external partner. This is a further example of
collaborative working with Digital Services in order to improve Business
Continuity Planning across the organisation.
• Supporting School Business Managers in the development of their
School Incident Plans, in collaboration with Police Scotland colleagues.   
Q2 24/25: Service review for the Health, Safety and Resilience Team Service,
which includes Contingency Planning, is still in progress. 
Plans/plan updates include: 
• Midlothian Pipelines Emergency Plan (required under the Pipelines
Safety Regulations 1996).   
• Emergency Contacts Directory (reflecting staff changes) 
• Provision of Business Continuity guidance notes to service managers. 
Plan updates/procedures in progress:  
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31-Mar-2025  75%
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
• Midlothian Council Emergency Plan (generic). This document outlines
internal emergency management arrangements and multi-agency
partnership relationships. 
• Operation UNICORN (and associated arrangements). Scottish
Government have advised that national planning arrangements are
underway, and we will tie in with those. Meantime, we have the basics
in place, based on previous experience. 
• Corporate Business Continuity (BC) Plan. An update to the Corporate
Business Continuity Policy was provided to Corporate Management
Team members in Q4 23/24. However, learning from a Cyber Security
event facilitated by Scottish Government in June 2024 and September
2024 and the experiences of other organisations will be incorporated
into an expanded document, which will also link in with the work being
done by Digital Services on the technical response to a cyber-attack.   
• Draft action plan in relation to the revised Prevent Duty Guidance to
measure our compliance.  (In support of the Prevent SPOC.)
• Support to the Executive PA Place with the Festive Period Service
Arrangements document. 
Multi-agency Exercises, Training, Presentations, Work streams:
• Debrief for the multi-agency Exercise Puma (Torness related exercise)
held in June 2024. 
• Supporting School Business Managers in the development of their
School Incident Plans, in collaboration with Police Scotland colleagues. 
• Familiarisation training exercise using Airwave handsets (held by Police
Scotland for partner use in emergencies).  These short sessions are
organised by the Scottish resilience community on a regular basis
throughout the year. 
• A number of national presentations relating to Prevent (extremism) 
Q1 24/25: Exercise (simulated cyber attack) took place at the Leadership
Forum June 2024 with the session facilitated by Scottish Government and LRP
Colleagues. The session was designed to remind services managers of the
importance of having , maintaining and exercising their Business Continuity
Planning arrangements.   
Plans/plan updates include: 
• Midlothian Council generic Emergency Plan. This document outlines
internal emergency management arrangements and multi-agency
partnership relationships. 
• Operation UNICORN (and associated arrangements).  Scottish
Government have advised that national planning arrangements are
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
underway.  Meantime, we have the basics in place, based on previous
experience. 
• Corporate Business Continuity (BC) Plan. An update to the Corporate
Business Continuity Policy was provided to Corporate Management
Team members in Q4 23/24.  However, learning from a Cyber Security
event facilitated by Scottish Government in June 2024 and the
experiences of other organisations will now be incorporated into an
expanded document, which will also link in with the work being done by
Digital Services on the technical response to a cyber attack.   
Multi-agency Exercises, Training, Presentations, Work streams:
Team Members also participated in the following where appropriate to their
areas of work, invitations were extended to colleagues in other services and
partners: 
• Planning for and participation in a Torness related exercise in June
2024. 
• Lothian and Borders Local Resilience Partnership non-routine inputs
including Met Office Extreme Heat Awareness 
Q4 23/24: Work on flooding across the county and its risks has commenced,
with a report to Council scheduled for post-recess.  CMT desktop exercise
undertaken. 
Q3 23/24: A service review of the Health, Safety & Resilience team has
commenced.  
SRP.R
A.09.03 Business Continuity Software System 
Q3 24/25: System requires resource to roll out across the organisation. 
Resource identified, with progress expected through Q1/Q2 25/26.  Practical
demonstration of Business Continuity tested in recent storm event (Jan 25). 
Q1 24/25: The Health, Safety & Resilience Service review is progressing and
has identified staffing shortages to meet obligations. 
Q4 23/24: Report in early draft, to be completed once Health, Safety &
Resilience service review completed (SRPO.RA.09.02).  BCPs in the event of
power outage to be incorporated. 
Q3 23/24: System review/upgrade has been considered and it is planned to
present a report to CMT in Q4.  
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31-Dec-2024  25%    
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
SRP.RR.10 Governance and Standards in Public Life 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.10
Risk cause
Code of conduct for Members and
employees’ actions falling short of
International Standards. 
Risk event
Failure in openness, accountability, clarity. 
Risk effect Service, partnerships and
project outcomes not achieved. Non-
compliance with conduct standards and
reduction in standards in public life.  
Legal *and
Governance
Manager; Chief
*Executive; Chief
Officer *Place;
Executive
Director *Place;
Chief Officer
Corporate
Solutions
01 Annual Assurance Statement. 
02 Standing Orders 
03 Scheme of Administration 
04 Scheme of Delegation 
05 Elected Member Code of Conduct 
06 Induction programme for new members and ongoing learning and
development programme 
07 Employee Code of Conduct  
2 4 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.03.05
Review of Standing Orders, Scheme of
Administration and Scheme of Delegation 
Q1 24/25: Workplan presented and agreed by SOWG in April 2024. Some
changes to SOs and Scheme of Administration presented and approved by
Council in May 2024. 
Q3 23/24: Workplan being developed by officer working group and will be
presented to SOWG in March 2024 for approval.  
Legal *and
Governance
Manager; Chief
Officer Corporate
Solutions; 
31-Dec-2024  20%
SRP.RA
.10.03
Review of the employee onboarding and
induction programme
Q3 2023/24: CMT agreed to a refresh of the staff induction programme which
include a compliance section. It is anticipated that the new programme will be
fully completed by end Dec 2024, with a phasing of improvement actions being
delivered throughout 2024.  
HR Strategic Lead 31-Dec-2024  5%     
SRP.RR.11 Corporate Policies and Strategies 
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.11
Risk cause
Policies may not match the aspirations of
the Council's Strategic priorities or cultural
perspective. 
Risk event
Policies not monitored may become out of
date. 
Policies not reviewed to ensure alignment
with strategic priorities. 
Risk effect Policies not monitored could
result in non-compliance with legislation
Policies not aligned to strategic priorities
will inhibit rather than support
implementation of strategic priorities.  
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Single Midlothian Plan providing overarching direction 
2. Service plans aligned to Single Midlothian Plan. 
3. Leadership team to ensure correct approaches are adopted to get the
right results. 
4. Strategic housing investment plan, submitted to Scottish Government. 
5. Capital Strategy 
6. Integrated Joint Board (IJB) Plan 
7. IJB Strategic needs assessment 8. Midlothian Local Development Plan
2017 – the Council’s corporate spatial strategy.  
2 3 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.04 Transformation Blueprint 2023 to 2028 
Q3 24/25: Refer to SRP.RA-02.08 
Q2 24/25: Refer to SRP.RA-02.08 
Q1 24/25: As Q4 23/24. 
Q4 23/24: Work on sprints continues with some reporting to BTSG in the run
up to June Council with the majority of others scheduled for August. BTB is now
meeting fortnightly to encourage and closely monitor progress. To support
monitoring of progress a dashboard has been developed and this is shared with
CMT and BTSG as a standing item. 
Q3 23/24: Regular review and updates to the Business Transformation Board
which meets monthly. Transformation Manager in post and sprints initiated.  
Chief *Executive;
Chief Finance
Officer; 
30-Jun-2028  20%
SRP.RA
.03.07
Review of policy and creation of a policy
register
Q4 23/24: work to develop policy register ongoing. 
Q3 23/24: Corporate Solutions has initiated a review of policies in the Council,
aligned to legislation changes and statutory requirements for the Local
Authority. Work is ongoing to gather information across the Council to inform an
Chief Officer
Corporate
Solutions
31-Dec-2024  10%
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
action plan and a refreshed policy register. It is estimated that this work will
take until end 2024 to be completed. 
SRP.RA
.11.05 Antisocial Behaviour Policy
Q1 24/25: Member Briefing on Housing and Antisocial Behaviour to be
prepared and presented during Q2, with report to Council to follow. 
Q4 23/24: Midlothian Community Action Team SLA 2024-25 contains tackling
ASB as a strategic objective. 
Chief Officer
*Place;  31-Dec-2024  0%    
SRP.RR.12 Internal Control Environment 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.12
Risk cause
Work procedures/process inadvertently
create the capacity for fraud and waste to
occur. 
Internal Controls requiring more time,
effort or cost than the risk being managed. 
Mangers failing to follow procedures and
keep systems updated with accurate
information. 
Risk event
Persons exploiting opportunities to commit
fraud. 
Waste and errors 
Changing risk landscape associated with
remote working solutions. 
Risk effect
Waste and loss 
Risks over managed with risk controls
costing more than the potential loss being
managed. Increased opportunity for fraud
or financial loss has direct impact on
management information. Has adverse
effect on service performance.  
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. Services have been prompted to consider fraud and waste within
Service Risk Registers. 
2. Risk Management Guide provides direction on the need to balance
time, effort and cost against benefit of risk controls. 
3. Internal Audit examine internal control arrangements based largely on
the risk registers. 
4. Corporate Fraud team in place who assist managers to undertake
fraud risk assessments in their areas (focused on priority areas) and
provide advice and guidance on fraud related matters. Active
participation in the National Fraud Initiative to investigate matches. 5.
Whistleblowing Policy and Counter Fraud Policy in place (subject to
review) with whistleblowing channels available to report concerns
(anonymously if required). 
6. Internal and external assurance. Annual Governance Statement which
involves obtaining assurance from Management over controls in their
Service. 
7. E-learning for staff to complete mandatory training for fraud
awareness. 
8. Regular updates to Audit committee on progress with
recommendations made by Internal Audit. 
9. Remind staff to declare secondary employment/outside interests and
gifts & hospitality 
10. Induction for all new employees (with service exceptions), including
legal, HR, procurement, health and safety. Control at entry to
organisation. 
11. The Integrity Group continues to meet to improve the Council’s
resilience to fraud, corruption, theft and crime (including cybercrime),
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maintaining proper risk management, governance and internal control
processes and systems to ensure probity in systems and operations, and
mitigation of risks, including the prevention, detection and resolution of
fraud and irregularities. Management is also responsible for checking that
the arrangements and controls are operating effectively and obtaining
assurances from internal compliance, risk, inspection, quality, and control
functions.                 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.12.04
Review of Serious Organised Crime
(SOC) group
Q3 24/25: Draft Strategy devised.  Regulatory safeguards/actions progressing
through Licensing. 
Q1 24/25: Initial meeting with Police is planned to discuss strategy. 
Q4 23/24: Chief Officer Place on national SOC working groups and utilising
forums to inform strategy. 
Q3 23/24: Work underway to refresh SOC Strategy, working with Police
Scotland and neighbouring authorities. Draft report expected Q4.  
Chief Officer
*Place; Health,
Safety &
Resilience
Manager
31-Mar-2025  50%   
SRP.RR.13 Climate Change 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.13
Risk cause
Council Services not adequately engaged,
resourced or directed to fulfil the
requirements of the Climate Change Act. 
Risk event
Council Services not responding to the
Climate Change Act with sufficient pace. 
Risk effect Council failing to meet its
obligation under the Climate Change
(Scotland) Act 2009 and incurring the
associated reputational damage.  
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Planning,
Sustainable
Growth and
Investment
*Manager; Chief
1. Statutory requirement to report on compliance with climate change
duties. 
2. Council Carbon Management Plan 
3. Approval of a Corporate Climate Change Strategy and action plan 
4. CPP Board for Climate Change to bring strategic focus and oversight
of plans and progress. 
5. Resilience Seminars  
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Officer *Place;
Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships     
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.13.04
Delivery of the BTB Board Carbon Neutral
by 2030
Q3 24/25:  Council approved realignment of Net Zero target from 2030 to
2045. 
Q2 24/25: Member Briefing delivered. 
Q1 24/25: Member Briefing on Climate Action Plan being prepared for
presentation in Q2/3. 
Q4 23/24: Climate Action Plan finalised and will be presented to Council in
2024/25. 
Planning,
Sustainable
Growth and
Investment
*Manager; Chief
Officer *Place; 
31-Mar-2030  0%
SRP.RA
.13.05
Development of the Strategic Plan 2023-
27
Q3 24/25:  Council approved realignment of Net Zero target from 2030 to
2045.  Climate Action Strategy refresh to follow. 
Q4 23/24: Climate Action Plan finalised and will be presented to Council in
2024/25. 
Q4 22/23: Carbon Neutral by 2030 is a strategic priority.  
Planning,
Sustainable
Growth and
Investment
*Manager; Chief
Officer *Place; 
31-Mar-2025  90%   
SRP.RR.14.1 Scottish Child Abuse Inquiry 
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Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.14.1
Risk Cause: Midlothian Council and its
legacy organisations, predating the
creation of Midlothian Council in 1996,
have been involved in the provision of
care of children going back to living
memory. During this time there is the
likelihood that the care children received
fell below standards of care now in place.
There is the further potential that some
people in the care of Midlothian Council
and its legacy organisations were subject
to abuse by those who were employed to
care for them. 
Risk Event: The Scottish Government
began an Inquiry into cases of Child
Abuse occurring prior to 17 December
2014, the intention of this enquiry is to
identify historic case of abuse which have
to date gone unreported. 
The most recent Section 21 notice around
the Foster Care Case Study is a
significant piece of work. The request for
information from 1930 to date is very
challenging given the volume of files that
require to be read and analysed. 
Risk Effect: If the inquiry finds historic
cases of abuse in Midlothian this could
damage the reputation of the Council and
could place doubt in the eyes of the public
as to the safety of these currently in care.
There is significant scope for a substantial
financial impact arising from claims of
historic abuse. Some existing employees
may be affected by the inquiry and
subsequent claims of abuse. 
We have requested an extension for Parts
B, C & D of the last Section 21 to April
2020, which has been granted. To date
there has been no evidence from the
extensive file read to suggest there has
been systemic abuse within our foster
care system. 
Chief *Executive;
Chief *Social
Work Officer 
The Council initially set up an Inquiry Project Team, however this is no
longer required as we have an experienced worker overseeing all
requests for the Scottish Child Abuse Inquiry Team. 
Work is ongoing and we have the additional tasks of supporting and
responding to enquiries from the redress team. 
The Inquiry Team have established a Project Plan covering: 
1. Residential establishments, List D Schools and Foster Carers:
identifying Children’s homes, Foster Carers and any List D Schools in
Midlothian over the last 100 years and researching historic records. 
2. Record Audit: reviewing the Council’s existing paper and electronic
recordkeeping systems to identify relevant records and map them to
residential establishments. This also includes, where possible, noting the
Council’s historic recordkeeping policies, such as retention schedules. 
3. Cataloguing/Indexing: checking and updating existing recordkeeping
systems for accuracy and consistency, enabling effective information
retrieval when requested by the Inquiry. 
The Project Team have established a Project Plan covering: 
4. Ascertaining the succession and insurance position in relation to
potential historic child abuse claims. 
5. Ascertaining and agreeing Midlothian Council’s legal position/
approach in dealing with the potential historic child abuse claims. 
6. Identifying the need for guidance, protocol, templates etc. should/if any
claims be made against the council. 
7. Consideration to identifying if additional staffing will be required as
expected deluge of FOI’s SARs in 2018 from solicitors of potential
claimants. 
8. Project team is in place with project plan with a range of identified
actions which are being progressed. Monthly meetings to progress
project plan. 9. The SCAI Social Worker is very competent and
experienced in this area of work and provides quarterly updates on their
findings from the file read. This is a real strength within this area of work.
The CSWO and Principal Solicitor meet regularly with the social worker
to discuss findings from the file read. 
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Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.14.03
Foster Care and Residential Care File
Review
Q3 24/25: Phase 10 is now in progress with investigation of residential care
homes run by local authorities. We will comply with all s21 requests. 
Q4 23/24: Foster care enquiry completed. 
Q3 23/24: Inquiry has heard all the evidence for the Sect 21.  
Childrens Services
Management
Team; Chief
*Social Work
Officer;  Chief
Officer Young
People and
Partnerships
31-Mar-2024  100%   
SRP.RR.16 Growing Council 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.16
Risk cause
Population growth in Midlothian over the
next 10 to 15 years will see Midlothian
become the fastest growing Council in
Scotland. 
Between 2014 and 2039, ages 0-15yrs,
population is projected to increase by 20%
and for ages 75+ population projected to
increase by 100%. 
Risk event 
Failure to resource and plan for these
rises will significantly impact the Councils
ability to fulfil its statutory obligations in
relation to these groups. 
Risk effect Inadequate capacity within the
school estate to cope with the projected
increase in pupil numbers. In sufficient
provision to support an aging population
placing costly inefficiencies on other parts
of the care sector. General population
increase placing additional demand on
Head of *Adult
and Social Care;
Chief *Executive;
Executive
Director *Place;
Fiona
*Robertson;
Chief Officer
Young People
and Partnerships
1. Local development plan and supplementary guidance on developer
contributions. 
2. Services planning future service provision on the basis of anticipated
service demands 
3. The change programme 
4. Learning Estate Strategy 
5. Capital Plan Prioritisation 
6. Strategic Housing Investment Strategy 
7. Rent Review Strategy 
8. Joint needs assessment used to develop - IJB Strategic Plan 
9. Capital Plan and Asset Management Board will scrutinise and
challenge slippage on capital programmes recognising that slippage can
have an adverse impact on financial sustainability and also the delivery
on assets required to support capital growth. 10. City Deal provides the
opportunity to support inclusive growth.  
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infrastructure including GP services.
Increased pressure on infrastructure,
services e.g., waste collection and growth
of road network as new development
roads are adopted. 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.RA
.02.06 Capital Plan prioritisation 
Q3 24/25: Work continues on Capital Plan prioritisation. 
Q2 24/25: Work continues on Capital Plan prioritisation. 
Q1 24/25: Work continues on Capital Plan prioritisation. 
Q4 23/24: Work continues on Capital Plan prioritisation.   
Q3 23/24: Work continues on Capital Plan prioritisation.  
Head of
*Development;
Executive Director
*Place; Chief
Finance Officer; 
31-Oct-2024  75%         
SRP.RR.17 UK Decision to leave the EU 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.17
Risk cause
UK vote to leave the European Union 
Risk event
UK leaving the European Union 
Risk effect The impacts associated with
the UK's decision to leave the UK have yet
to be realised and will only become clear
once the final terms of the UK's departure
are finalised. There are some direct
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
1. Risk and Resilience Group 
2. Taking a risk management approach to identifying and assessing
anticipated impacts 
3. Working with a range of national and local bodies to inform preparatory
arrangements. 
4. EU Settlement scheme promoted on Council Internet to support those
living and working in Midlothian to access the Home Office scheme.  
4 5 
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potential impacts such as an end to EU
funding of Council co-ordinated projects
and indirect impacts on industries
undertaken within the geographical area
which have relied on EU funding, such as
agriculture. There are wider potential
implications arising from uncertainty
regarding the resident status of EU
nationals, post any exit agreement, and
the availability of workers from outside the
UK accessing the job market here in the
future. These factors have the potential to
impact on the availability of the right
people with the right skills being available
to help grow the economy here in
Midlothian. One area this could affect the
Council could be in the delivery of future
building projects within Midlothian which
could curtail further economic growth.  
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships                
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.17.01 Refresh of Economic Strategy
Q3 24/25: Council approved new Midlothian Strategy for Inclusive Economic
Growth 2025-2030. 
Q2 24/25: Member Briefing delivered on Midlothian Strategy for Inclusive
Economic Growth, with report prepared for Council in November. 
Q1 24/25: Member Briefing scheduled for 3rd October 2024. 
Q3 23/24: Draft Economic Strategy prepared; to be presented to Council in Q1
24/25.  
Chief Officer
*Place; 30-Jun-2024  100% 
SRP.RR.19 Health & Safety 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.19 Risk cause
Head of *Adult
and Social Care;
Chief Operating
1. Health Safety and Wellbeing Strategy & Service Plan 
2. Suite of Health and Safety Management Arrangements developed
setting out council response to statutory obligations 
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Failing to identify and rectify non-
compliance with Health and Safety
regulations. 
Risk event
Employees required to undertake tasks
they are not competent to. 
Statutorily driven health and safety
protective arrangements for service users
and employees not implemented correctly. 
Non-compliance with policy and procedure 
Not undertaking audits and inspections to
confirm adherence to policy and legislative
requirements. 
Risk effect 
Serious injury of ill health impact on
employees and or service users. 
Negative impact on outcomes for
customers/service users. 
Service users and employees exposed to
hazards where statutory requirements
exist. 
Statutory health and safety - duty of care
over services users and employees not
met. Criminal prosecution of the Corporate
body and or individuals through Corporate
Homicide (Corporate Manslaughter)
Significant financial penalties from
Criminal Prosecution.  
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
David Robertson;
Chief Officer
Young People
and Partnerships
3. Comprehensive range of Health & Safety Management & Assessment
based development opportunities for line managers 
4. Use of Health & Safety Management Information System (SPHERA) to
enhance information transfer and organisational efficiency 
5. Comprehensive training programme in place to support those with
responsibility for managing health and safety. 
6. Use of comprehensive audit programme to confirm the application of
agreed management Arrangements and Council Policy. 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
NEW 
Health, Safety & Resilience Service
Review 
Q3 24/25: Position unchanged from Q2. 
Q2 24/25: Service Review progressing and developing. 
Q1 24/25: The Health, Safety & Resilience Service review is progressing and
has identified staffing shortages to meet obligations. The report will be
submitted in Q2 for consideration. 
Q4 23/24: Service review in progress.
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31/10/2024  100%
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SRP.R
A.19.01
Delivery of Health, Safety and Wellbeing
Service Plan 
Q3 24/25: Position unchanged from Q2. 
Q2 24/25: Awaiting outcome of service review before reviewing service plan. 
Q1 24/25: Implementation of the Protective Services Health, Safety &
Resilience Service Plan continues. The plan will be reviewed at conclusion of the
service review. 
Q3 23/23: Implementation of the Protective Services Health, Safety &
Resilience Service Plan continues. 
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31-Mar-2025  50%
SRP.R
A.19.07
H&S fire safety audit across all Council
estate 
Q3 24/25: Departure of Fire Safety Adviser in Nov 2024 has adversely affected
implementation of audit programme and reactive responses. Another member of
staff is temporarily dealing with priority work until a replacement is recruited.   
Q2 25/25: As Q1 24/25. 
Q1 24/25: Fire Risk Assessments/Audits progressing. A number of Zurich
Insurance audits have also taken place. 
Q4 23/24: Fire Risk Assessments/Audits are currently priority. 
Q3 23/24: Work on audit report continues. Change to SFRS response
incorporated into Fire Action Plans and Management Arrangements.  
Chief Officer
*Place; Senior
Manager
Protective
Services; David
Robertson
31-Mar-2025  33%   
SRP.RR.21 Cyber Security 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.21
Risk Cause
Malicious attempts to damage, disrupt or
gain unauthorised access to Council
computer systems, networks or devices. 
Risk Event
The cyber threat is severe and advancing
quickly.The Council is at significant risk of
cyber-attack from Ransomware Phishing
Emails, Advanced Persistent Threats
Head of *Adult
and Social Care;
Cyber Security
Information
Governance and
*Compliance
Manager; Head
of *Development;
Chief Operating
Officer
1. Implementation of and compliance with the Scottish Government
Cyber Resiliency Public Sector Action Plan 
2. Cyber Essentials Plus Certification 
3. Public Sector Network Certification 
4. Regular Audits and Inspections
5. Appropriate technical and organisational measures deployed to reduce
the likelihood and impact of an attack 
6. Having adequate skills and knowledge in the organisation 
7. Implementing Scottish Government Cyber Security Action Plan
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(APT) and Distributed Denial of Service
Attacks (DDOS) attacks. Hacking and
Social Engineering. 
Risk Effect
Access to Council systems by cyber
criminals and foreign intelligence agencies
for financial, commercial or information
gathering reasons. This could lead to
significant financial losses, data
compromise and subsequent regulatory
sanction if our technical and organisational
measures are deemed insufficient. Severe
business disruption including the almost
total loss of critical IT systems and
networks leading to significant service
delivery challenges.  
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
David Robertson;
Chief Officer
Young People
and Partnerships
8. Adoption of the NCSC (National Cyber Security Centre) Active Cyber
Defence programme  
9. Technology upgrades
10. Incident Response plans and exercises                
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.21.1
Appropriate Technical and Organisational
Measures 
Q3 24/25 - Action/mitigation includes: - 
1. Quorum cyber security table top exercise completed 
2. Successfully defended the organisation from several cyber incidents
3. Provided significant Information Governance and Security advice for
the continued deployment of M365 and Google Workspace
4. Audit on business continuity
5. Ran successful phishing exercises 
Q1 24/25 - Action/mitigation includes: - 
1. Achieved Cyber Essentials Plus Certification
2. Achieved PSN Certification from the Cabinet Office
3. Organised and facilitated a leadership forum exercise on cyber
resilience
4. Successfully responded to 15 significant cyber security events
5. Provided significant Information Governance and Security advice for
the continued deployment of M365 and Google Workspace 
Q4 23/24: Ongoing review of cyber incident response plans. Information
Governance and Security processes for M365 deployment ongoing and a number
Cyber Security
Information
Governance and
*Compliance
Manager; Chief
*Digital Officer;
31-Mar-2025  75%
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of milestones achieved to progress further rollout of applications within M365
environment. Leadership Forum tabletop session scheduled June 2024. 
Q3 23/24: Action/mitigation includes: - 
1. Updated cyber incident response plans. 
2. Cyber security presentations to Elected Members and Place directorate. 
3. Conducted phishing exercises. 
4. Successfully responded to 13 cyber security events. 
Provided significant Information Governance and Security advice for the
deployment of M365 and Google Workspace 
Q1 23/24: Action/mitigation includes:- 
1. Achieved Cyber Essentials Plus Certification 
2. Preparations completed for Q2 2023/2024 PSN Certification, including
submission to Cabinet Office. 
3. Provided significant Information Governance and Security advice for the
deployment of M365 and Google Workspace 
4. Responded to numerous threat alerts to ensure the security of the Council’s
network 
5. Engaged with Cyber Incident Response company to review the Councils Cyber
Incident response capability in Q2 
SRP.RR.22 Cost of Living Crisis 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.R
R.22
Risk cause
The UK is currently facing an
unprecedented storm of increasing prices,
bills and tax. The 40-year high inflation
rate of 9% is the main driver of the cost of
living crisis which has outstripped wage
and benefit increases. 
Risk event
Rapid ongoing rise of energy prices as
well as food and drink prices. 
Chief *Executive;
Director *Health
and Social Care;
Executive
Director *Place
1. Council Cost of Living Task Force to oversee the Council’s response
to the crisis 
2. Allocation of LACER funding to support those most affected 
3. Strategic Evaluation Partner appointed to create poverty profile 
4. Community Planning Partnership has established a Midlothian
Strategic Poverty Prevention Group co-chaired by Council Leader and
Director of Public Health 
5. New Child Poverty chair and lead appointed (Executive Director
Children, Young People and Partnerships) 
6. Child Poverty self-evaluation underway with Improvement Service  
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Risk effect The impact on households is
already being noted with 87% of adults in
the UK reported an increase in their cost
of living in April 2022 (Office for National
Statistics; Francis-Devine et al, 2022). The
price rises will impact low-income
households the hardest as a larger
proportion of their bills are on energy and
food. The Resolution Foundation
estimates an extra 1.3 million people will
fall into absolute poverty in 2023, including
500,000 children. 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.R
A.22.1 Cost of Living Task Force Q1 23/24: Meetings continuing.   Chief *Executive;  31-Mar-2024  100%
SRP.R
A.22.2 LACER funding
Q2 22/23: Identification of 15 trusted partners to distribute funding in
communities for food and fuel, wash and dry provision and support to establish
reheatable food initiatives.  
Lifelong Learning
and Employability;  31-Mar-2023  100% 
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Strategic Opportunities 
SRP.OP.08 Capital Projects - Housing 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.08
26% reduction in Affordable Housing
Supply Programme grant to Midlothian
and continued high build costs will affect
ability to deliver housing programme. 
Projects progressing, with Timeline,
Budget, Risk and Resource categorised
as parameters on a RAG status, with any
Red classifications identified and reported.   
Executive
Director *Place;
Head of
Development  
1. Newbyres, Gorebridge: Timeline impacted with potential ground
conditions and delay with peer review process. This has since been
addressed and now on site.
2. Edmonstone Road, Shawfair – Timeline, Budget and Risk impacted
with Stewart Milne entering administration.  Developer now in process of
being appointed to take this forward.
3. Newton Church Road, Danderhall – Timeline impacted with delays to
tender process as contractors requested extensions and in delivering
tender report.  Tender report now approved and works to start before end
of 2024. 
Phase 5 housing programme has been reviewed to ensure affordability
within the Housing Revenue Account, allowing for reduced levels of
grant. 
Timeline Budget Risk Resource
R G G G
R A A G
R A A G            
SRP.OP.09 Capital Projects – Transport, Net Zero & Infrastructure 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.09
Cost of delivering enabling infrastructure
projects has risen, resulting in significant
funding gap emerging. 
Projects progressing, with Timeline,
Budget, Risk and Resource categorised
as parameters on a RAG status, with any
Red classifications identified and reported.  
Executive
Director *Place;
Head of
Development  
1. A701 Relief Road
2. A701 Sustainable Trasport Corridor
3. A701 Straiton Junction Improvements 
For all highlighted projects, estimated cost significantly exceeds budget
available to deliver project. 
For all highlighted projects, addressing requirement for investment in
A701 corridor in phases with prioritisation applied. Bush Loan Junction
progressing ahead of remaining programme fully funded by ESESCRD
funding. 
Timeline Budget Risk Resource
A R R G
A R R G
A R R G
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SRP.OP.10 Capital Projects – Children, Young People & Partnerships Estates Programme: Primary 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.10
Projects progressing, with Timeline,
Budget, Risk and Resource categorised
as parameters on a RAG status, with any
Red classifications identified and reported.  
Executive
Director *Place;
Executive
Director CYPP;
Head of
Development  
1. Mayfield/St Lukes PS New Build: Tender return from Stage 1
exceeds available budget. Programme delayed for project revision.
Existing school remains safe while operational. Mayfiield School
pupils were decanted to the new Easthouses PS in December.
Budget gap has lowered due to intensive cost reduction exercise,
budget gap whilst lower still remains.
2. Mauricewood PS Extension & Refurbishment: Rising roll and
catchment review requires investment in school to address capacity
and suitability. Limited budget available.  Design team appointed to
develop investment in school that aligns with budget available from
Developer Contributions. Funding insufficient as some contributions
were withdrawn for pay for costs of previous extension
3. Bilston PS Extension: Rising roll and catchment review requires
investment in school to address capacity and suitability. Limited
budget available.  Design team appointed to develop investment in
school that aligns with budget available from Developer
Contributions. Approval to proceed with Stage to go to February
council.
4. Relocation of Mount Esk Nursery / Hawthorden Extension: Rising
roll and catchment review requires investment in school to address
capacity and suitability. Limited budget available.  Design team
appointed to develop investment in school that aligns with budget
available from Developer Contributions. Stage 2 design and costs
complete. 
Timeline Budget Risk Resource
R R R A
R A A A
R A A A
A A A A   
SRP.OP.09 Capital Projects – Children, Young People & Partnerships Estates Programme: Secondary 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.09
Projects progressing, with Timeline,
Budget, Risk and Resource categorised
Executive
Director *Place;
Executive  
1. Beeslack HS Replacement: Site acquisition being progressed,
however dependent on planning being achieved (expected 
Timeline Budget Risk Resource
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
as parameters on a RAG status, with any
Red classifications identified and reported.  
Director CYPP;
Head of
Development
Dec 24). Preferred contractor to be brought to Council for approval 
2. Shawfair All Through: Site acquisition complete. School location
fixed with design team. Remediation programme being revised.
School target date of 2027 likely to be missed. Outcome of design
process to determine cost of project and budget position.  Design
outcome to be to adhere to available budget. Smaller school will
reduce build programme. Seeking to make efficiencies in
remediation programme. Stage 2 Design complete, awaiting
completion of cost analysis exercise.
3. Penicuik HS New Build: LEIP target for delivery is Dec 2026,
however programme for occupation is July 2027. Cost reports
tracking higher and risks identified in refurbishment works. 
Removing requirement for modular units and minimising enabling
works will assist minimising impact on GSCP. Design review can
bring project into budget. SFT advising if additional LEIP funding
available to address abnormal costs. Contractor, Morrison
Construction appointed Jan’25. 
A A A G
R A A A
A A A G   
SRP.OP.09 Capital Projects – Regeneration 
Risk
Code Risk Identification Managed by Risk Commentary Risk Evaluation
SRP.O
P.10
Projects progressing, with Timeline,
Budget, Risk and Resource categorised
as parameters on a RAG status, with any
Red classifications identified and reported.  
Executive
Director *Place;
Head of
Development  
1. Vogrie Changing Places: issues with contractor.
2. Destination Hillend: Alpine Coaster delivered with access and
parking infrastructure. Project absorbed risk and contingency. 
Delays to delivery resulting from issues with access / water mains.
Main Building tender return exceeded budget. Next Phase to be
recast. Interim works on water supply and drainage required.
3. Hopefield Industrial Estate: Updated financial model required.
4. Extension to Waste Transfer Shed – Stobhill Depot
5. Dalkeith Asset Rationalisation Programme: Budget now approved
by Council. Appointments/procurement strategy being updated and
stakeholder consultation to commence. 
Timeline Budget Risk Resource
R A R A
R R R A
R A A G
G A A G
A G A G   
SRP.OP.04 City Deal
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STRATEGIC RISK PROFILE, Q3 Oct-Dec 2024 v1.0 
Risk
Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk Evaluation
SRP.O
P.04
South East Scotland Region City Deal - a
bid for funding to Scottish and UK
Governments to accelerate economic
growth through investment in
infrastructure/ housing/ skills and
innovation. 200 Council Houses linked to
the City Deal. 
Head of *Adult
and Social Care;
Chief Operating
Officer
*Education; Chief
*Executive;
Director *Health
and Social Care;
Chief Officer
*Place; Executive
Director *Place;
Chief Officer
Corporate
Solutions; Chief
Finance Officer;
Chief Officer
Young People
and Partnerships
1. City Deal signed in August 2018. 
2. Maintain strong Midlothian involvement through the City Deal
governance structure. 
3. Midlothian City Deal Key Officer (Internal) Group. 
4. Securing best arrangements for Midlothian through close liaison with
partners and conclusion of business cases.  
4 5 
Related
Action
Code
Related Action Related action latest note Managed By Due Date Status
SRP.O
P.04.02
Realisation of outcomes of respective
workstreams Q1 24/25: Work continues on the relevant programmes.   Executive Director
*Place 31-Mar-2025  10%           
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