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Agenda Document Pack - Audit Committee - 07/02/2023

Midlothian Council · 7 February 2023
Back to Audit Committee — 7 February 2023 and its agenda

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Notice of Meeting and Agenda 
Audit Committee 
Venue:  Council Chambers, 
Midlothian House, Dalkeith, EH22 1DN 
Date:  Tuesday, 07 February 2023 
Time:  13:00 
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
4.1 Minute Meeting 06 December 2022 Submitted for Approval 3 - 8
4.2 Action log 9 - 10 
5          Public Reports
5.1 Treasury Management and Investment Strategy 2023/24 &
Prudential Indicators, Report by Acting Chief Financial Officer
11 - 92
5.2 Internal Audit Work to December 2022, Report by Chief Internal
Auditor
93 - 104
5.3 Internal Audit Mid-Term Performance Report 2022/23, Report by
Chief Internal Auditor
105 - 118
5.4 Risk Management Update – Strategic Risk Profile Quarter 3
2022/23, Report by Chief Officer Place
119 - 158
5.5 Scotland’s Public Finances: Challenges and Risks, Report by
Acting Chief Financial Officer
159 - 190
5.6 Internal Audit Service – Update on Shared Internal Audit Service
between Midlothian and East Lothian Councils, Report by
Executive Director Place
191 - 196 
6          Private Reports 
No items for discussion 
7          Date of Next Meeting 
The next meeting will be held on Tuesday 7 March 2023 at 11am. 
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Minute of Meeting 
Audit Committee 
Date Time Venue
Tuesday 6 December 2022 11.00am Council Chamber 
Present:
Councillor Smaill (Chair)
Councillor McEwan
Councillor McKenzie
Councillor Milligan 
Councillor Scott 
In Attendance:
Grace Vickers Chief Executive
Kevin Anderson Executive Director Place
Alan Turpie Legal and Governance Manager / Monitoring Officer
Derek Oliver Chief Officer Place
David Gladwin Acting Chief Financial Officer 
Saty Kaur Chief Officer Corporate Solutions Acting
Elaine Greaves Principal Internal Auditor 
Gary Thomson Senior Finance Business Partner
Andrew Henderson Democratic Services Officer 
Audit Committee
Tuesday 07 February 2023
Item 4.1
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1. Welcome and Apologies for Absence 
The Clerk took the opportunity to welcome members to the meeting of Audit.
The Clerk advised that an independent Chair had still not been appointed and
invited members to nominate a chair for the meeting. It was noted that, in terms
of the Scheme of Administration, this would require to be a non-cabinet
member. Councillor Milligan, seconded by Councillor McEwan submitted a
block proposal that Councillor Smaill sit as chair until the start of the summer
recess of 2023, thereafter Councillor Milligan would sit as chair until the start of
the summer recess of 2024 and thereafter Councillor McEwan would sit as
chair until the start of the summer recess of 2025. The proposal was approved
unanimously and Councillor Smaill presided as chair for the remainder of the
meeting. 
Apologies were submitted on behalf of Morag Barrow. 
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. Minutes of Previous Meetings 
4.1 The minute of the meeting of 27 September 2022 was submitted and approved
as correct record. 
4.2 The Action log was submitted, Kevin Anderson provided a brief update in
relation to each of the action points. The action log was subsequently noted. 
5. Public Reports 
Report No. Report Title Submitted by:
5.1 Treasury Management Mid-Year Review
Report 2022/23
Acting Chief
Financial Officer
Outline of report and summary of discussion
David Gladwin provided a brief overview of the report and appendices making
reference to the Treasury management activity undertaken during the first half of
22/23, forecast activity for the second half of 22/23 and prudential indicators for
22/23. Following comments from members, David Gladwin agreed to look into the
possibility of setting up a session for members on responsible treasury
management. David Gladwin then took the opportunity to respond to members
questions. 
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A discussion ensued in relation to over borrowing with reference being made to
the councils over borrowed position and whether members should have had
involvement prior to this occurring in addition to what measures could be used to
ensure councillor involvement should this happen again in the future. David
Gladwin highlighted that borrowing commitments are made on a long term
perspective in line with the annual borrowing requirement and the capital
financing requirement. David Gladwin outlined that council has been sighted on
this, but that this could be brought back to members if they wished to discuss the
matter further. 
In responding to comments regarding transient borrowing and the resultant ethical
issues, Gary Thomson confirmed that environmental and social impacts were
considered as part of the treasury management process and that councils are
required to formulate a policy on this. 
With regard to the approach of borrowing when rates are more attractive, David
Gladwin confirmed that the council had an overall borrowing requirement as
opposed to individual projects and that the charge to the council’s revenue
account was a consequence of the overall position. 
Decision
a) Session with members to be considered in relation to responsible treasury
management/ethical issues and;
b)    Noted the report and the treasury activity undertaken in the period to 30
September 2022, as outlined in Section 5 and;
b) Noted the actual and forecast activity during the second-half of the year as
outlined in Section 6 and;
c) Noted the technical revisions to the Prudential Indicators in Section 7 of this
report and;
d) Noted the updated Treasury Management Practices and the self-
assessment tool on the scrutiny of Treasury Management as published by
CIPFA and undertake a self-assessment in line with the tool. 
Report No. Report Title Submitted by:
5.2 Internal Audit Work to October 2022 Principal Internal
Auditor
Outline of report and summary of discussion
In speaking to the report, Elaine Greaves provided a brief overview of the Internal
Audit Work conducted up until October 2022, making reference to the ongoing
audit on street lighting. Officers then took the opportunity to respond to members
questions. 
Responding to comments in relation to street lights, the public use of the ‘tell your
council’ system and the Council’s ability to fund night time inspections, Derek
Oliver confirmed that this came under the asset management system and that
some street lights have technology which indicates if the light is defective so that
this could be quickly picked up by partners on a prioritised basis. 
In response to comments regarding FOI delays, Grace Vickers confirmed that the
Executive Director Children Young People and Partnerships would be looking into
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this internally and acknowledged that the outstanding FOI’s had been received
during bottleneck periods and that further information would be included on the
Council’s website. 
Decision
a) Noted the Executive Summaries of the final Internal Audit assurance reports
issued and;
b) Noted the Internal Audit Assurance Work in Progress and Internal Audit and
Other Work carried out and;
c) Acknowledged the assurance provided on internal controls and governance
arrangements in place for the areas covered by this Internal Audit work. 
Report No. Report Title Submitted by:
5.3 Follow-Up Reviews of Completed Internal
Audit Recommendations & Progress Update
Principal Internal
Auditor
Outline of report and summary of discussion
Elaine Greaves provided a brief overview of the Follow-Up Reviews of Completed
Internal Audit Recommendations & Progress Update and highlighted that out of 40
sampled audit recommendations 36 had been satisfactory, 3 had been partially
satisfactory and 1 was deemed unsatisfactory and that 4 recommendations had
been reopened on Pentana. Elaine Greaves then took the opportunity to respond
to points of clarity.
In response to comments regarding how councillors could request internal audit
work, Elaine Greaves acknowledged that the Internal Audit plan was fluid and that
a plan for 2023/24 would be submitted in March outlining intended work.  It was
also advised that councillors could email herself or the corporate fraud/internal
audit mail boxes with any areas of concern. 
Decision
a) Noted the results from the sample check of Internal Audit recommendations
that have been marked as completed by Management in the period April 2021
to March 2022 to improve internal controls and governance, and mitigate risks
and;
b) Acknowledged the progress made by Management in implementing Internal
Audit recommendations to improve internal controls and governance, to
mitigate risks, and consider whether it is satisfied with the progress made by
Management and;
c) Approved the report outcomes and; 
d) Noted that Internal Audit will continue to monitor for completion the outstanding
recommendations and will provide update reports to the Audit Committee. 
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Report No. Report Title Submitted by:
5.4 Risk Management Update – Strategic Risk
Profile Quarter 2 2022/23
Chief Officer Place
Outline of report and summary of discussion
Derek Oliver provided a brief overview of the Risk Management Update – Strategic
Risk Profile Quarter 2 2022/23, making reference to the various risks highlighted
and that these would continue to be monitored. Derek Oliver then made further
reference to high risks and continued to open to members questions. 
Derek Oliver clarified that review of the service risk register was a regular process
and is signed off by the corporate management team, and that the risk and
resilience group has been proposed to help evaluate the risks. 
Decision
Noted the current risk landscape and organisational response to the most significant
risks in Quarter 2 (Q1) 2022/23 (1 July to 30 September 2022) 
Report No. Report Title Submitted by:
5.5 Audit Scotland Counter Fraud Reports,   Principal Internal
Auditor
Outline of report and summary of discussion
In speaking to the Audit Scotland Fraud and irregularity 2021/22 and The National
Fraud Initiative in Scotland 2022 reports, Elaine Greaves made reference to
staffing pressures resulting from the covid 19 pandemic and the strengthening of
controls where previous fraud error has been identified. Elaine Greaves then took
the opportunity to respond to members questions. 
A brief discussion ensued in relation to blue badge fraud and Elaine Greaves
acknowledged a previous issue with the ‘tell us once service’ in which the
appropriate service had not been notified and highlighted that this has since been
rectified.
Decision
a) Acknowledged the Audit Scotland counter fraud reports published in recent
months and;
b) Acknowledged that the Integrity Group of officers considered both reports as
part of their counter fraud role and responsibilities. 
6. Private Reports 
None 
7. Date of Next Meeting 
Date of Next Meeting: Tuesday 24 January 2023 at 11am. 
(Post meeting comment –rescheduled to Tuesday 7 February 2023 at 1pm.) 
The meeting terminated at 11:54 am 
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Audit Committee 
Action Log 
No Subject Date Action Action Owner Expected
completion
date
Comments
1 Responsible treasury
management 
06/12/2022 Session with members to be
organised with regard to
Responsible treasury
management/ethical issues.
Acting Chief
Financial
Officer
Ongoing   
Audit Committee
Tuesday 07 February 2022
Item No: 4.2  
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Audit Committee
Tuesday 7 February 2023 
Item No  5.1 
Treasury Management and Investment Strategy 2023/24 & Prudential
Indicators 
Report by David Gladwin, Acting Chief Financial 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
21 February 2023:- 
a) Approve the restriction of the Authorised Limit to the value of
the Capital Financing Requirement at 31 March 2024
(£472.662 million), pending finalisation of the General
Services Capital Plan Prioritisation; 
b) To note the ongoing review in respect of incorporating ESG
criteria into the decision making process for making deposits,
and that officers will continue to monitor and evaluate
emerging approaches as the marketplace develops; 
c) Note that there are no other material changes proposed to the
Treasury Management and Investment Strategy (TMIS) for
2023/24 from the strategy currently in place, other than to
update the Prudential Indicators (Section 5 and Appendix 2),
to reflect the revised capital plans; 
d) Note the retention of the current approach for the repayment
of loans fund advances as outlined in Section 7; and 
e) Accordingly approve the Treasury Management and
Investment Strategy for 2023/24. 
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 7 February 2023 prior to consideration by Council
on 21 February 2023. 
The purpose of the report to Council will be to provide an update on the
implementation of the Council’s TMIS 2022/23, and to make
recommendations to facilitate consideration of the 2023/24 Strategy,
specifically the TMIS for 2023/24, the 2021 update to the Prudential
and Treasury Management Codes, the Prudential and Treasury
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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 7 February 2023 will be incorporated into the final version of the
report to Council on 21 February 2023. 
Date: 27 January 2023
Report Contact:
Gary Thomson, Senior Finance Business Partner
gary.thomson@midlothian.gov.uk  0131 271 3110 
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3. Update on implementation of TMIS for 2022/23 
3.1 Borrowing 
The Council’s borrowing position as set out in the 2022/23 Treasury
Management Mid-Year Review Report was £323.271 million at 31
March 2022, and six months later was £322.838 million on 30
September 2022. 
The principle 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 20 January 2023, is shown in table
1 below:- 
Table 1: Current Loan Portfolio as at 20 January 2023 
Loan Type
Principal
Outstanding
£000’s
Weighted
Average
Rate
PWLB Annuity 505 8.91%
PWLB Maturity 284,776 2.92%
LOBO 20,000 4.51%
Market Loans 16,886 2.68%
Salix Loans 235 0.00%
Total Loans 322,402 3.01% 
The repayment profile of this debt is shown in graphical and tabular
form below:- 
Figure 1: Loan Maturity Structure 
£-
£5,000
£10,000
£15,000
£20,000
£25,000
£30,000
21/22
24/25
27/28
30/31
33/34
36/37
39/40
42/43
45/46
48/49
51/52
54/55
57/58
60/61
63/64
66/67
69/70
72/73
75/76
£000's
Financial Year
Loan Maturity Structure
PWLB New
Existing LOBO
Existing Market
Existing PWLB
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Table 2: Loan Maturity Profile 
Financial Year 2022/23
Remaining
£000’s
2023/24-
2026/27
£000’s
2027/28-
2031/32
£000’s
2032/33-
2036/37
£000’s
2037/38+ 
£000’s
Debt Maturing 648 4,330 33,857 29,258 254,309
% of total portfolio 0.20% 1.34% 10.50% 9.08% 78.88% 
As can be noted in the graph and table above, proactive Treasury
Management by the Council in the last decade has placed the Council
in an extremely strong refinancing position for its existing external
debt portfolio, with only £4.978 million, or just 1.54%, of the Council’s
total Loan Portfolio of £322.402 million requiring refinancing over the
current and forthcoming four financial years.  This extremely low
short-term exposure to refinancing risk has put the Council in a strong
position to plan its new borrowings in advance, take advantage of any
dips in longer-term borrowing rates from PWLB (as demonstrated
above) 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 2022/23 Treasury Management Mid-Year Review Report
setting out the position at 31 March 2022 of £156.367 million and six
months later on 30 September 2022, at £167.399 million. 
The position at 20 January 2023, as set out in Table 3 below, totals
£146.055 million. 
Table 3: Current Deposits as at 20 January 2023 
Investment Type
Principal
Outstanding
£000’s
Weighted
Average
Rate
Bank Call Accounts 14,940 3.30%
Money Market Funds 44,115 3.32%
Bank Fixed Term Deposits 70,000 3.17%
Other Local Authorities 17,000 2.30%
Total Investments 146,055 3.23% 
The cash balances above represent the following: 
• Funds held in Bank Fixed Term Deposits and on Deposit with
other Local Authorities which are cash backing the Council’s
projected useable reserves (at 31 March 2023) of £70.273
million;
• A balance held in instant access accounts and money market
funds which are used for day to day liquidity to meet cashflow
requirements;
• The remainder reflects accumulated balances reflective of (a)
the Scottish Government providing upfront funding to local
authorities to support a range of grant schemes, (b) advanced
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Revenue Support Grant payments and Early Years Capital
Grant payments, (c) the receipt of developer contributions from
sites across Midlothian, towards new school, community, road
and other infrastructure, and (d) the impact of rephasing of the
Council’s capital plans as reported in the General Services and
HRA Quarter 3 Financial Monitoring reports. 
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 – 2023/24 Detailed in
Appendix 4, Section 4.4.  .  
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4. Treasury Management & Investment Strategy 2023/24 
4.1 Main Objectives of TMIS 2023/24 
The objectives of the current and 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; 
• To cash back the Council’s usable reserves. 
No material changes are proposed to the current TMIS which was
scrutinised by Audit Committee in January 2022 and approved by
Council in February 2022, other than for the following:- 
a) Approve the restriction of the Authorised Limit to the value of the
Capital Financing Requirement at 31 March 2024 (£472.662
million), pending finalisation of the General Services Capital
Plan Prioritisation; 
b) To note the ongoing review in respect of incorporating ESG
criteria into the decision making process for making deposits,
and that officers will continue to monitor and evaluate emerging
approaches as the marketplace develops; 
Similarly no changes are recommended to the Permitted Investments,
other than the removal of Qatar as an approved country for
Investment. 
More detail on the borrowing and investment strategy for 2023/24 is
provided in Sections 4.2, 4.3 and 4.4 below. 
4.2 Borrowing Requirement 2022/23 to 2026/27 
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 2022/23 to 2026/27 is shown in table 4:- 
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Table 4: Total Borrowing Requirement over the period 2022/23 to 2026/27 
2022/23
£000’s
2023/24
£000’s
2024/25
£000’s
2025/26
£000’s
2026/27
£000’s
Total
£000’s
Capital Expenditure      
General Services 28,505 86,289 96,822 51,791 12,787 276,194
HRA 41,400 94,897 60,711 21,822 8,943 227,773
Total Capital Expenditure 69,905 181,186 157,533 73,613 21,730 503,967
Total Available Financing -28,729 -43,082 -44,357 -21,697 -13,607 -151,473
Principal Debt Repayments -5,986 -9,389 -11,238 -11,830 -12,185 -50,628
Capital Expenditure less
available Financing 
35,189 128,715 101,938 40,086 -4,062 301,867
MEL Shareholder Injection 4,420 710 3,560 0 0 8,690
Maturing Long-term Loans 1,465 830 1,448 1,355 851 5,949
Total Borrowing
Requirement
41,074 130,255 106,946 41,441 -3,211 316,506
Borrowing secured from
previous years
-16,024 0 0 0 0 -16,024
Total Remaining
Borrowing Requirement
25,050 130,255 106,946 41,441 -3,211 300,482 
4.3 Borrowing Strategy for remainder of 2022/23 and 2023/24 
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
(2022/23 to 2026/27). 
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 2023 is projected to be
£322.402 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 2023 is expected to equate to £343.625
million. 
This means that the Council is expected to be £21.223 million (6%)
under-borrowed at the end of the 2022/23 financial year i.e. the
Council has funded the majority (94%) of its underlying borrowing
requirement as at 31 March 2023. 
The long-term borrowing the Council took in late 2021/22 to pre-fund
part of its 2022/23 borrowing requirement has allowed the Council to
defer taking long-term borrowing during 2022/23 when long-term
borrowing rates rose significantly, and instead use part of its cash
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balances to support the in-year borrowing requirement during
2022/23. 
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 an
extremely 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
£619.304 million by 31 March 2027 – almost double the current
Underlying Borrowing Requirement.  The profile of this, and the
projected external loan portfolio to fund the Underlying Borrowing
Requirement over the period 2022/23 to 2026/27, is shown in
graphical format below. 
Figure 3: Loan Portfolio & Underlying Borrowing Requirement 
PWLB Borrowing
It is expected that the majority of the Council’s remaining 2022/23 and
2023/24 borrowing requirement of £155.306 million (table 4) will be
funded through new PWLB maturity loans. 
Long-term PWLB borrowing rates for both HRA and non-HRA
purposes, which were on a gradual upward trend during the early part
of the 2022/23 financial year, saw a significant spike in interest rates
due to the tumultuous market volatility experienced in autumn 2022 as
a result of the government’s economic policy, with longer term PWLB
borrowing rates topping out at just under 6.00%.  During late 2022, as
a degree of market confidence in the UK Economy and
Fiscal/Monetary policy returned, rates shifted downwards to around
3.60%-3.90%, before shifting gradually back north during early 2023
to sit at c. 4.24%-4.57% at the time of writing. 
The short-medium-term forecast is for PWLB long-term rates to sit flat
at around the 4.30% mark during the remainder of 2022/23 and into
the early part of 2023/24, before starting to ease off gradually during
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the mid-latter part of the 2023/24 year, and forecast to sit at c 3.90%
by March 2024. 
Council officers will therefore continue to monitor PWLB and market
rates throughout 2023/24 in order to take advantage of any dips in the
market in order to resource the Council’s remaining 2022/23, and
2023/24, borrowing requirement of £155.306 million (see table 4). 
Temporary Borrowing
The Bank of England’s Monetary Policy Committee raised base rate
throughout the 2022/23 financial year, to a level of 3.50% at the time
of writing and with further rises expected in the 2 remaining meetings
in February and March.  This is forecast to take base rate to a peak of
4.50% by the start of the 2023/24 financial year, before gradually
dropping back to c. 4.00% towards the end of 2023/24. 
As such, utilisation of an element of temporary borrowing – which
typically tracks close to base rate levels – within the Council’s overall
loan portfolio may prove attractive whilst the market waits for inflation,
and therein gilt yields and PWLB rates, to drop back later in 2023. 
However, given the market volatility in 2023/24, this position can shift
quickly and Council officers will continue to monitor the temporary
borrowing and long-term borrowing markets to assess whether
temporary borrowing would add value to the Council’s overall
portfolio. 
The quantum of any temporary borrowing will also be assessed
against the backdrop of potential long term costs if the opportunity is
missed to take PWLB or other market loans to de-risk the Council’s
long-term Capital Financing Requirement. 
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. 
4.4 Investment Strategy for remainder of 2022/23 and 2023/24 
No changes are proposed to the Investment Strategy from that
approved by Council in the 2022/23 TMIS. 
Council should note that in parallel to securing its external borrowing
to finance the capital financing requirement, the strategy means that
Council should continue to cash back the Council’s useable reserves. 
In doing so, the Council are able to continue to minimise the extent of
under-borrowing and at the same time de-risk the Council’s forward
borrowing requirement; whilst also ensuring that all deposits are
securely placed with high creditworthy counterparties, complying with
the CIPFA Treasury Management Code principles of security, liquidity
and then yield – in that order.
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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 also remains
unchanged from that approved by Council in the 2022/23 TMIS, other
than the removal of Qatar as an approved country for Investment. 
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) 
The inclusion of ESG criteria is still very much an emerging area in
the Local Authority environment which will require ongoing monitoring. 
For the 2023/24 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. 
Page 50 of CIPFA’s Treasury Management Code states:- 
“ESG issues are increasingly significant for investors and
investment managers. This is better developed in equity
and bond markets than for short-term cash deposits, and
there is a diversity of market approaches to ESG
classification and analysis.  This means that a consistent
and developed approach to ESG for public service
organisations is currently difficult. 
Organisations are therefore recommended to consider their
credit and counterparty policies in light of ESG information
and develop their own ESG investment policies and
treasury management practices consistent with their
organisation’s own relevant policies, such as environmental
and climate change policies.” 
For short term investments with counterparties, this Council utilises
the Link 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. 
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11
Those financial institutions viewed as having poor/weak corporate
governance are generally less well 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
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
Link, will therefore 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 2021/22;
• Revised estimates of the 2022/23 indicators; and
• Estimates of indicators for 2023/24 to 2026/27. 
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 2023/24 financial year has
been calculated to equate to the maximum value of the Underlying
Borrowing Requirement in 2023/24.  This equates to £472.662 million
as outlined in Table 5 below. 
Table 5: Authorised Limit for Borrowing: Calculation 
Authorised Limit for Borrowing Amount
£000’s
CFR – General Services (31 March 2024) 192,891
CFR – HRA (31 March 2024) 279,771
Proposed Authorised Limit for Borrowing 472,662 
Council is therefore asked to approve an authorised limit for borrowing
of £472.662 million.  
322,402
472,662
579,409 623,366 619,304
£-
£100,000
£200,000
£300,000
£400,000
£500,000
£600,000
£700,000
2022/23 2023/24 2024/25 2025/26 2026/27
£000's
Financial Year
Prudential Indicators for Borrowing
External Debt Authorised Limit Underlying Borrowing Requirement / Operational Boundary
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13
6 CIPFA Codes & CIPFA Toolkit 
6.1 CIPFA Codes 
CIPFA, on 20 December 2021, released the new editions of the
Treasury Management Code and Prudential Code. 
The main areas that have been updated were as noted to Council in
the TMIS in February 2022. 
CIPFA expect Local Authorities to integrate the requirements of the
new Treasury Management and Prudential Codes, and the Treasury
Management Guidance Note, into their decision-making, monitoring
and management. 
CIPFA make it clear that the reporting requirements of the new 2021
Prudential Code must be implemented for the 2023/24 financial year. 
For Midlothian Council, this will be as follows:- 
• A fully updated set of Treasury Management Practices (TMPs)
were presented to, and approved by, Audit Committee on 6
December 2022; 
• The new Prudential Indicators in respect of (a) the Debt
Liability Benchmark (Appendix 2, Section 5.5) and (b) Net
Income from Service & Commercial Investments as a
proportion of Net Revenue Stream (Appendix 2, Section 1.3)
are included within this report; 
• The reporting requirements of the Prudential Code requires
that the Section 95 officer establish procedures to monitor and
report Prudential Management Indicators on a quarterly basis. 
These are already currently reported to Council as part of the
Treasury Mid-Year Review (Q2), Treasury Strategy (Q3), and
Annual Treasury Outturn (Q4) reports. 
For the 2023/24 financial year, in addition to the existing
reporting arrangements, the monitoring and reporting of
Prudential Indicators, along with forecast debt and investments
indicators, will be reported as part of the existing Quarter 1
integrated revenue and capital financial monitoring reports. 
• Officers will incorporate the new Environmental & Sustainability
provisions of the Prudential Code in the next update of the
Capital Strategy. 
6.2 CIPFA Scottish Treasury Management Forum Toolkit 
The Council is a member, and represented at officer level on the
Executive Committee, of the CIPFA Scottish Treasury Management
Forum (Scottish TMF), who have recently undertaken work in
partnership with CIPFA to develop a new Scottish Treasury Toolkit.
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14 
This Toolkit delivers on the Scottish TMF’s vision to create a free (to
all members of the Scottish TMF) online learning programme aimed at
Elected Members and Treasury Practitioners within Scottish Local
Authorities.  The toolkit focuses on Scottish regulations with
commentary on differences to England and Wales, and includes a
series of online learning modules developed to assist Officers and
Members in their knowledge and understanding of Treasury practices
and procedures. 
2022 saw the completion of the first 4 e-learning modules and these
will be made available to member organisations from early February
2023, with a further 8 modules in the pipeline of development and
which are expected to be made available as the year progresses. 
The new Treasury Management Code of Practice (TMP10 Training &
Qualifications: Knowledge and Skills) requires organisations to retain
a knowledge and skills register of elected members and employees
that includes a training schedule outlining the aims and objectives of
training and the expected level of knowledge, skills and expertise
required of those involved in Treasury Management.  This is covered
in more detail in the Council’s TMPs as approved by Audit Committee
on 6 December 2022, a copy of which is in the Members Library. 
It is therefore proposed that to assist Elected Members to have the
necessary expertise, knowledge and skills to undertake their role in
the scrutiny of Treasury Management that officers will assemble a list
of Elected Members to undertake the Scottish Treasury Toolkit online
e-learning programme. 
In parallel with this, officers will also assemble a list of employees
charged with the execution of the Treasury Management Strategy to
undertake the Scottish Treasury Toolkit online learning programme. 
As Elected Members and employees progress through the series of
online learning modules, the Council’s TMP10: Training &
Qualifications: Knowledge and Skills schedule will be updated
accordingly. 
7 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.
The TMIS retains the methodology adopted in 2022/23 – that is as
follows:- 
7.1 New Assets 
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15
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. 
7.2 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.  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 2022/23, the Asset Life method shall
be used for those assets in Table 6. 
Table 6: Asset Classes to adopt 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
* Average loans fund advance length 
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 2022/23 is currently estimated to be 2.21%. 
For all other asset classes, the policy will be to maintain the practice of
previous years and apply what is termed “the Statutory Method” –
following the principles of Schedule 3 of the Local Government
(Scotland) Act 1975 – with all loans fund advances being repaid by the
annuity method.  The annuity rate that is proposed to be applied to the
loans fund repayments varies and will be the in-year loans fund rate,
reflecting the Council’s current loan and investment portfolio.  The loans
fund rate for 2022/23 is forecast to be 2.21% 
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16
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. 
8 Performance Indicators 2021/22 – comparison with other
Scottish Local Authorities 
The Treasury Management Forum collates performance indicators for
all Scottish Local Authorities.  The indicators relating to financial year
2021/22 have been published and once again demonstrate the
continuing effectiveness of the Council’s Treasury function in
maximising efficiency in Treasury Management activity, with the
Council having the 5th lowest weighted average borrowing &
investment (loans fund) rate across all Scottish mainland authorities in
2021/22 (2.98%).  The Council has consistently maintained the loans
fund rate as one of the lowest across all Scottish mainland authorities
for the last decade and more.  Appendix 3 outlines the loans fund rate
for each Scottish Local Authority in 2021/22. 
The forecast loans fund rate of 2.21% for 2022/23 is expected to once
again be one of the lowest for all Scottish Local Authorities.   
Were the internal loans fund rate to have equated to the Scottish
weighted average of 3.33%, this would have generated loan charges
in 2021/22 of £15.2m.  The Council’s actual 2021/22 loan charges for
General Services and HRA were £14.1m, representing a cash saving
(compared to the Scotland average) of £1.1m in 2021/22. 
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17
9. Report Implications 
9.1 Resource 
There are no direct resource implications arising from this report. 
9.2 Digital 
None 
9.3 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. 
9.4 Ensuring Equalities 
There are no equality issues arising from this report. 
9.5 Additional Report Implications 
See Appendix A.  
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18
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 Link 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: Performance Indicators 2021/22
Appendix 4:- Treasury Management & Annual Investment Strategy
Statement – 2023/24 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 new 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. 
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
General Services 1.08% 1.25% 1.57% 3.43% 4.47% 4.67%
HRA 38.27% 40.78% 43.67% 55.12% 54.22% 56.26%
Ratio of Financing Costs to Net Revenue Stream
%
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
HRA debt £000's 173,114£  199,340£  279,771£  327,765£  341,407£  342,046£ 
HRA revenues £000's 31,833£    31,143£    31,577£    32,928£    35,361£    35,094£   
Ratio of debt to revenues % 544% 640% 886% 995% 965% 975%
HRA Debt as a % of Gross Revenue
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
HRA debt £000's 173,114£  199,340£  279,771£  327,765£  341,407£  342,046£ 
Number of HRA dwellings 7,002        7,170        7,451        7,841        8,212        8,224       
Debt per dwelling £ 24,724£    27,802£    37,548£    41,801£    41,574£    41,591£   
HRA Debt per Dwelling
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Income from Service Investments          51           34           34           34           34           34
Net Revenue Stream 241,017  247,161  250,161  253,602  257,190  262,632
% 0.02% 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. 
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
General Services
Children, Young People & Estates 5,688£    6,954£      39,388£    51,710£    38,524£    5,511£   
Asset Management 12,542£  12,622£    15,486£    11,656£    8,686£      7,686£   
Transport, Energy & Infrastructure 1,440£    1,393£      3,302£      16,454£    2,862£      408£      
Regeneration & Development 726£       2,731£      20,373£    13,776£    1,136£      11£        
Other 3,232£    5,790£      8,476£      5,402£      3,058£      528£      
Provision for return of contingencies (241)£      (985)£        (737)£        (2,176)£     (2,475)£     (1,357)£  
Total General Services 23,386£  28,505£    86,289£    96,822£    51,791£    12,787£ 
Total HRA 39,477£  41,400£    94,897£    60,711£    21,822£    8,943£   
Combined Total 62,863£  69,905£    181,186£  157,533£  73,613£    21,730£ 
Capital Expenditure
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Expenditure
General Services 23,386£  28,505£   86,289£    96,822£    51,791£   12,787£  
HRA 39,477£  41,400£   94,897£    60,711£    21,822£   8,943£    
Total 62,863£  69,905£   181,186£  157,533£  73,613£   21,730£  
Financed by:
Capital receipts 30£         -£            -£              -£              -£            -£           
Capital grants 17,492£  21,431£   27,244£    23,400£    9,185£     8,251£    
Capital reserves 27,000£  3,000£     2,533£      7,694£      -£            -£           
Developer/Other Contributions 5,825£    4,298£     13,305£    13,263£    12,513£   5,356£    
Net financing need for the year 12,516£  41,175£   138,104£  113,176£  51,916£   8,123£    
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. 
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Financing Requirement
CFR – General Services 134,133£  144,286£   192,891£  251,645£   281,958£  277,258£ 
CFR – HRA 173,114£  199,340£   279,771£  327,765£   341,407£  342,046£ 
CFR – PFI Schemes 95,914£    92,433£     88,739£    84,815£     80,661£    76,277£   
Total CFR 403,161£  436,059£   561,401£  664,225£   704,026£  695,581£ 
Movement in CFR 9,259£      32,898£     125,341£  102,824£   39,802£    (8,446)£    
Movement in CFR represented by
Net financing need for the year (previous table) 12,516£    41,175£     138,104£  113,176£   51,916£    8,123£     
Less Scheduled Debt Amortisation (5,670)£     (5,986)£      (9,389)£     (11,238)£    (11,830)£   (12,185)£  
Less net PFI Finance Lease Principal Payments (13,832)£   (3,481)£      (3,694)£     (3,924)£      (4,154)£     (4,384)£    
Movement in CFR (6,986)£     31,708£     125,021£  98,014£     35,932£    (8,446)£    
Capital Financing Requirement (CFR)
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
External Debt
Debt at 1 April 274,795£  323,271£  322,402£  472,662£  579,409£  623,366£ 
Actual/Expected change in Debt 48,476£    (869)£        150,260£  106,747£  43,956£    (4,062)£    
Other long-term liabilities (OLTL) at 1 April 99,203£    95,914£    92,433£    88,739£    84,815£    80,661£   
Actual/Expected change in OLTL (3,289)£     (3,481)£     (3,694)£     (3,924)£     (4,154)£     (4,384)£    
Actual/Expected Gross Debt at 31 March 419,185£  414,835£  561,401£  664,224£  704,027£  695,581£ 
The Capital Financing Requirement 403,161£  436,059£  561,401£  664,225£  704,026£  695,581£ 
Under / (over) borrowing (16,024)£   21,224£    -£              -£              -£              -£             
Deposits
Cash & Cash Equivalents 56,287£    65,000£    25,000£    25,000£    25,000£    25,000£   
Short-Term Investments 74,985£    70,000£    55,000£    48,000£    48,000£    46,000£   
Total Deposits 131,272£  135,000£  80,000£    73,000£    73,000£    71,000£   
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 (2022/23 to 2026/27); 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 2023/24 financial year has been calculated to equate
to the maximum value of the Underlying Borrowing Requirement in 2023/24.  This equates to
£472.662 million as outlined below. 
2022/23 2023/24 2024/25 2025/26 2026/27
Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's
Operational Boundary - Borrowing 343,626£  472,662£  579,410£  623,365£  619,304£ 
Operational Boundary - Other long term liabilities 92,433£    88,739£    84,815£    80,661£    76,277£   
Total 436,059£  561,401£  664,225£  704,026£  695,581£ 
Operational Boundary
£000's
CFR - General Services at 31 March 2024 192,891£ 
CFR - HRA at 31 March 2024 279,771£ 
Authorised Limit for Borrowing 472,662£ 
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 2023/24
Interest rate exposures Upper
Limit
Maturity structure of fixed interest rate borrowing 2023/24 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 2023/24 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
Maturity Structure of Borrowing 2023/24
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
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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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 
In the new 2021 CIPFA Treasury Management Code of Practice, a new Treasury Management
Indicator – the “Liability Benchmark” is required which 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. 
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. 
Limit £70m
Principal Sums Invested for > 365 Days
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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 Debt 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 £300.482 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 2023/24 financial year is outlined in the main body of this report, Section 4.3. 
The Debt 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
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 2022/23 and the
forthcoming 2023/24 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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Authority
Loans
Fund
Rate
West Dunbartonshire 1.94%
Aberdeenshire 2.32%
North Lanarkshire 2.55%
East Lothian 2.81%
Midlothian 2.97%
East Dunbartonshire 3.00%
Aberdeen City 3.01%
Perth & Kinross 3.15%
Dumfries  & Galloway 3.19%
Falkirk 3.23%
South Ayrshire 3.25%
East Ayrshire 3.27%
Stirling 3.32%
Orkney 3.33%
Fife 3.34%
Dundee City 3.36%
Argyll & Bute 3.41%
Inverclyde 3.43%
North Ayrshire 3.46%
Highland 3.50%
East Renfrewshire 3.52%
South Lanarkshire 3.61%
Scottish Borders 3.66%
West Lothian 3.70%
Glasgow City 3.71%
Moray 3.76%
Edinburgh City 3.84%
Renfrewshire 3.99%
Angus 4.44%
Clackmannanshire 5.07%
Comhairle Nan Eilean Siar 7.15%
Appendix 3
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Appendix 4 
Treasury Management Strategy Statement
and Annual Investment Strategy 
Midlothian Council
2023/24 
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INDEX 
1 INTRODUCTION ............................................................................................................................ 3
1.1 Background ............................................................................................................................................... 3
1.2 Reporting requirements ............................................................................................................................ 3
1.3 Treasury Management Strategy for 2023/24 ........................................................................................... 5
1.4 Training ...................................................................................................................................................... 5
1.5 Treasury management consultants .......................................................................................................... 6
2 THE CAPITAL PRUDENTIAL INDICATORS 2023/24 – 2026/27 ............................................. 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 ................................................................................................. 19
3.6 Debt rescheduling ................................................................................................................................... 19
4 ANNUAL INVESTMENT STRATEGY ........................................................................................ 20
4.1 Investment policy ..................................................................................................................................... 20
4.2 Creditworthiness policy ........................................................................................................................... 22
4.3 Country and sector limits ......................................................................................................................... 23
4.4 Investment strategy ................................................................................................................................. 24
4.5 Investment risk benchmarking ................................................................................................................ 25
4.6 End of year investment report ................................................................................................................. 25
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 2022/23 to 2026/27;
• 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 2023/24, including treasury indicators; and 
• a permitted investment strategy for 2023/24 (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.  Revisions
arising from Audit Committee consideration of the report on 25 January 2022 have
been incorporated into the final version of this report. 
Quarterly reports
From 2023/24 quarterly reporting is also required.  In addition to the three major reports
detailed above, Prudential and Treasury Management Indicators will be reported at
Quarter 1 as part of the Council’s integrated Revenue and Capital Monitoring reports.  
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1.3 Treasury Management Strategy for 2023/24
The strategy for 2023/24 covers two main areas: 
Capital issues
• the capital expenditure plans and the prudential indicators (Section 2 of this report);
• The loans fund repayment policy (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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6
website to download.  This was presented to members of the Audit Committee and Council
as part of the Council’s Treasury Management 2022-23 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 Link Group, Treasury Solutions 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 2022/23 –
2026/27
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.  
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
General Services
Children, Young People & Estates 5,688£    6,954£      39,388£    51,710£    38,524£    5,511£   
Asset Management 12,542£  12,622£    15,486£    11,656£    8,686£      7,686£   
Transport, Energy & Infrastructure 1,440£    1,393£      3,302£      16,454£    2,862£      408£      
Regeneration & Development 726£       2,731£      20,373£    13,776£    1,136£      11£        
Other 3,232£    5,790£      8,476£      5,402£      3,058£      528£      
Provision for return of contingencies (241)£      (985)£        (737)£        (2,176)£     (2,475)£     (1,357)£  
Total General Services 23,386£  28,505£    86,289£    96,822£    51,791£    12,787£ 
Total HRA 39,477£  41,400£    94,897£    60,711£    21,822£    8,943£   
Combined Total 62,863£  69,905£    181,186£  157,533£  73,613£    21,730£ 
Table 1: Capital Expenditure
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Expenditure
General Services 23,386£  28,505£   86,289£    96,822£    51,791£   12,787£  
HRA 39,477£  41,400£   94,897£    60,711£    21,822£   8,943£    
Total 62,863£  69,905£   181,186£  157,533£  73,613£   21,730£  
Financed by:
Capital receipts 30£         -£            -£              -£              -£            -£           
Capital grants 17,492£  21,431£   27,244£    23,400£    9,185£     8,251£    
Capital reserves 27,000£  3,000£     2,533£      7,694£      -£            -£           
Developer/Other Contributions 5,825£    4,298£     13,305£    13,263£    12,513£   5,356£    
Net financing need for the year 12,516£  41,175£   138,104£  113,176£  51,916£   8,123£    
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
£95.914m 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 and new prudential indicator for 2023/24 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.
4 Liability benchmark (or gross loans requirement): this equals net
loans requirement plus short-term liquidity/working capital allowance. 
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Financing Requirement
CFR – General Services 134,133£  144,286£   192,891£  251,645£   281,958£  277,258£ 
CFR – HRA 173,114£  199,340£   279,771£  327,765£   341,407£  342,046£ 
CFR – PFI Schemes 95,914£    92,433£     88,739£    84,815£     80,661£    76,277£   
Total CFR 403,161£  436,059£   561,401£  664,225£   704,026£  695,581£ 
Movement in CFR (6,986)£     32,898£     125,341£  102,824£   39,802£    (8,446)£    
Movement in CFR represented by
Net financing need for the year (previous table) 12,516£    41,175£     138,104£  113,176£   51,916£    8,123£     
Less Scheduled Debt Amortisation (5,670)£     (5,986)£      (9,389)£     (11,238)£    (11,830)£   (12,185)£  
Less net PFI Finance Lease Principal Payments (13,832)£   (3,481)£      (3,694)£     (3,924)£      (4,154)£     (4,384)£    
Movement in CFR (6,986)£     31,708£     125,021£  98,014£     35,932£    (8,446)£    
Table 3: Capital Financing Requirement (CFR)
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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.
It is proposed to retain the methodology adopted in 2022/23 – that is as follows:-
New Assets
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
HRA Balances 28,084£    31,988£    33,669£      33,217£      33,076£    31,588£ 
General Fund Balances 3,812£      3,812£      3,650£        3,650£        3,650£      3,650£   
Earmarked reserves 28,620£    12,404£   -£                -£                -£              -£           
Provisions 3,718£      3,214£      2,787£        2,600£        2,500£      2,400£   
Capital Fund 22,178£    19,178£    16,646£      8,952£        8,952£      8,952£   
Total Reserves / Core Funds 86,412£    70,596£    56,752£      48,419£      48,178£    46,590£ 
Working capital* 28,836£    85,628£    23,248£      24,581£      24,822£    24,410£ 
Under/over borrowing (16,024)£   21,224£    -£                -£                -£              -£           
Expected investments 131,272£  135,000£  80,000£      73,000£      73,000£    71,000£ 
Reserve
Table 4: Balance Sheet Resources
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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 2022/23, the Asset Life method shall be used for those
assets in Table 6.
Table 5: Asset Classes to adopt 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
* Average loans fund advance length
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
2022/23 is currently estimated to be 2.21%.
For all other asset classes, the policy will be to maintain the practice of previous years
and apply what is termed “the Statutory Method” – following the principles of Schedule
3 of the Local Government (Scotland) Act 1975 – with all loans fund advances being
repaid by the annuity method.  The annuity rate that is proposed to be applied to the
loans fund repayments varies will be the in-year loans fund rate, reflecting the Council’s
current loan and investment portfolio.  The loans fund rate for 2022/23 is forecast to be
2.21%
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.  
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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 2022 and for the position as at
20 January 2023 are shown below for both borrowing and investments.
Table 6: Portfolio Position 31 March 2022 and 20 January 2023 
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. 
Principal Weighted Principal Weighted
Outstanding Average Outstanding Average
£000’s Rate £000’s Rate
PWLB Annuity                553 8.91%                505 8.91%
PWLB Maturity         284,776 2.92%         284,776 2.92%
LOBO           20,000 4.51%           20,000 4.51%
Market Loans           17,542 2.68%           17,064 2.68%
Salix Loans                400 0.00%                235 0.00%
Total Loans         323,271 3.02%         322,580 3.01%
Principal Weighted Principal Weighted
Outstanding Average Outstanding Average
£000’s Rate £000’s Rate
Bank Call Accounts           31,059 0.64%           14,940 3.30%
Money Market Funds           30,324 0.52%           44,115 3.32%
Bank Fixed Term Deposits           35,000 0.41%           70,000 3.56%
Other Local Authorities           45,000 1.56%           17,000 1.60%
Total Deposits         141,383 0.85%         146,055 3.23%
20 January 202331 March 2022
31 March 2022 20 January 2023
Loan Type
Deposit Type
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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
the total of the CFR in the preceding year plus the estimates of any additional CFR for
2023/24.
The Acting Chief Financial 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.  
2021/22 2022/23 2023/24 2024/25 2025/26 2026/27
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
External Debt
Debt at 1 April 274,795£  323,271£  322,402£  472,662£  579,409£  623,366£ 
Actual/Expected change in Debt 48,476£    (869)£        150,260£  106,747£  43,956£    (4,062)£    
Other long-term liabilities (OLTL) at 1 April 99,203£    95,914£    92,433£    88,739£    84,815£    80,661£   
Actual/Expected change in OLTL (3,289)£     (3,481)£     (3,694)£     (3,924)£     (4,154)£     (4,384)£    
Actual/Expected Gross Debt at 31 March 419,185£  414,835£  561,401£  664,224£  704,027£  695,581£ 
The Capital Financing Requirement 403,161£  436,059£  561,401£  664,225£  704,026£  695,581£ 
Under / (over) borrowing (16,024)£   21,224£    -£              -£              -£              -£             
Deposits
Cash & Cash Equivalents 56,287£    65,000£    25,000£    25,000£    25,000£    25,000£   
Short-Term Investments 74,985£    70,000£    55,000£    48,000£    48,000£    46,000£   
Total Deposits 131,272£  135,000£  80,000£    73,000£    73,000£    71,000£   
Table 7: Net Borrowing Requirement
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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
(2022/23 to 2026/27); 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 2023/24 financial year has been calculated to
equate to the maximum value of the Underlying Borrowing Requirement in 2023/24.  This
equates to £472.662 million as outlined below. 
2022/23 2023/24 2024/25 2025/26 2026/27
Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's
Operational Boundary - Borrowing 343,626£  472,662£  579,410£  623,365£  619,304£ 
Operational Boundary - Other long term liabilities 92,433£    88,739£    84,815£    80,661£    76,277£   
Total 436,059£  561,401£  664,225£  704,026£  695,581£ 
Operational Boundary
£000's
CFR - General Services at 31 March 2024 192,891£ 
CFR - HRA at 31 March 2024 279,771£ 
Authorised Limit for Borrowing 472,662£ 
Authorised Limit for Borrowing
322,402
472,662
579,409 623,366 619,304
£-
£100,000
£200,000
£300,000
£400,000
£500,000
£600,000
£700,000
2022/23 2023/24 2024/25 2025/26 2026/27
£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 Link Group, Treasury Solutions 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. 
Link’s central forecast for interest rates reflects a view that the MPC would be keen to
further demonstrate its anti-inflation credentials by delivering a succession of rate
increases.  Bank Rate stands at 3.50% currently, but is expected to reach a peak of
4.50% in H1 2023. 
Further down the road, Link anticipate the Bank of England will be keen to loosen
monetary policy when the worst of the inflationary pressures are behind us – but that
timing will be one of fine judgment: cut too soon, and inflationary pressures may well
build up further; cut too late and any downturn or recession may be prolonged. 
The CPI measure of inflation looks to have peaked at 11.1% in Q4 2022 (currently
10.7%).  Despite the cost-of-living squeeze that is still taking shape, the Bank will want
to see evidence that wages are not spiralling upwards in what is evidently a very tight
labour market. 
Regarding the plan to sell £10bn of gilts back into the market each quarter (Quantitative
Tightening), this has started and will focus on the short, medium and longer end of the
curve in equal measure, now that the short-lived effects of the Truss/Kwarteng
unfunded dash for growth policy are firmly in the rear-view mirror. 
In the upcoming months, Link’s forecasts will be guided not only by economic data
releases and clarifications from the MPC over its monetary policies and the
Government over its fiscal policies, but the on-going conflict between Russia and
Ukraine.  (More recently, the heightened tensions between China/Taiwan/US also
have the potential to have a wider and negative economic impact.) 
On the positive side, consumers are still estimated to be sitting on over £160bn of
excess savings left over from the pandemic so that will cushion some of the impact of
the above challenges.   However, most of those are held by more affluent people
whereas lower income families already spend nearly all their income on essentials
such as food, energy and rent/mortgage payments. 
PWLB RATES
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• The yield curve movements have become less volatile of late and PWLB 5
to 50 years Certainty Rates are, generally, in the range of 4.10% to 4.80%.  
• We view the markets as having built in, already, nearly all the effects on gilt
yields of the likely increases in Bank Rate and the elevated inflation outlook. 
The balance of risks to the UK economy: - 
• The overall balance of risks to economic growth in the UK is to the
downside. 
Downside risks to current forecasts for UK gilt yields and PWLB rates include: - 
• Labour and supply shortages prove more enduring and disruptive and
depress economic activity (accepting that in the near-term this is also an
upside risk to inflation and, thus, rising gilt yields). 
• The Bank of England acts too quickly, or too far, over the next year to raise
Bank Rate and causes UK economic growth, and increases in inflation, to
be weaker than we currently anticipate. 
• UK / EU trade arrangements – if there was a major impact on trade flows
and financial services due to complications or lack of co-operation in sorting
out significant remaining issues. 
• Geopolitical risks, for example in Ukraine/Russia, China/Taiwan/US, Iran,
North Korea and Middle Eastern countries, which could lead to increasing
safe-haven flows. 
Upside risks to current forecasts for UK gilt yields and PWLB rates: - 
• The Bank of England is too slow in its pace and strength of increases in
Bank Rate and, therefore, allows inflationary pressures to build up too
strongly and for a longer period within the UK economy, which then
necessitates Bank Rate staying higher for longer than we currently project
or even necessitates a further series of increases in Bank Rate. 
• The Government acts too quickly to cut taxes and/or increases expenditure
in light of the cost-of-living squeeze. 
• The pound weakens because of a lack of confidence in the UK
Government’s fiscal policies, resulting in investors pricing in a risk premium
for holding UK sovereign debt. 
• Longer term US treasury yields rise strongly and pull gilt yields up higher
than currently forecast. 
• Projected gilt issuance, inclusive of natural maturities and QT, could be too
much for the markets to comfortably digest without higher yields
consequently. 
The long-term (beyond 10 years) forecast for Bank Rate stands at 2.5%. As all PWLB
certainty rates are currently above this level, borrowing strategies need to be reviewed
in that context.  Better value can generally be obtained at the shorter end of the curve
and short-dated fixed LA to LA monies should be considered. Temporary borrowing
rates are likely, however, to remain near Bank Rate and may also prove attractive
whilst the market waits for inflation, and therein gilt yields, to drop back later in 2023. 
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 in the main report,
above the Council has a significant borrowing requirement across the current and
forthcoming four financial years (2022/23 to 2026/27). 
The Council’s external loan debt at 31 March 2023 is projected to be £322.402 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 2023 is expected to equate to £343.625 million. 
This means that the Council is expected to be £21.223 million (6%) under-borrowed at
the end of the 2022/23 financial year i.e. the Council has funded the majority (94%) of
its underlying borrowing requirement as at 31 March 2023. 
The long-term borrowing the Council took in late 2021/22 to pre-fund part of its
2022/23 borrowing requirement has allowed the Council to defer taking long-term
borrowing during 2022/23 when long-term borrowing rates rose significantly, and
instead use part of its cash balances to support the in-year borrowing requirement
during 2022/23. 
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 an extremely 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 £619.304 million by 31
March 2027 – almost double the current Underlying Borrowing Requirement.  The
profile of this, and the projected external loan portfolio to fund the Underlying
Borrowing Requirement over the period 2022/23 to 2026/27, is shown in graphical
format below. 
The Council’s projected loan portfolio over the period 2022/23 to 2026/27 is shown in
graphical format below. 
PWLB Borrowing
It is expected that the majority of the Council’s remaining 2022/23 and 2023/24 borrowing
requirement of £155.306 million (table 4 in main report) will be funded through new PWLB
maturity loans. 
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Long-term PWLB borrowing rates for both HRA and non-HRA purposes, which were on a
gradual upward trend during the early part of the 2022/23 financial year, saw a significant
spike in interest rates due to the tumultuous market volatility experienced in autumn 2022
as a result of the government’s economic policy, with longer term PWLB borrowing rates
topping out at just under 6.00%.  During late 2022, as a degree of market confidence in
the UK Economy and Fiscal/Monetary policy returned, rates shifted downwards to around
3.60%-3.90%, before shifting gradually back north during early 2023 to sit at c. 4.24%-
4.57% at the time of writing. 
The short-medium-term forecast is for PWLB long-term rates to sit flat at around the
4.30% mark during the remainder of 2022/23 and into the early part of 2023/24, before
starting to ease off gradually during the mid-latter part of the 2023/24 year, and forecast to
sit at c 3.90% by March 2024. 
Council officers will therefore continue to monitor PWLB and market rates throughout
2023/24 in order to take advantage of any dips in the market in order to resource the
Council’s remaining 2022/23, and 2023/24, borrowing requirement of £155.306 million
(see table 4). 
Temporary Borrowing
The Bank of England’s Monetary Policy Committee raised base rate throughout the
2022/23 financial year, to a level of 3.50% at the time of writing and with further rises
expected in the 2 remaining meetings in February and March.  This is forecast to take
base rate to a peak of 4.50% by the start of the 2023/24 financial year, before gradually
dropping back to c. 4.00% towards the end of 2023/24. 
As such, utilisation of an element of temporary borrowing – which typically tracks close to
base rate levels – within the Council’s overall loan portfolio may prove attractive whilst the
market waits for inflation, and therein gilt yields and PWLB rates, to drop back later in
2023. 
However, given the market volatility in 2023/24, this position can shift quickly and Council
officers will continue to monitor the temporary borrowing and long-term borrowing markets
to assess whether temporary borrowing would add value to the Council’s overall portfolio. 
The quantum of any temporary borrowing will also be assessed against the backdrop of
potential long term costs if the opportunity is missed to take PWLB or other market loans
to de-risk the Council’s long-term Capital Financing Requirement. 
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  
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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.
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 2023/24
Interest rate exposures Upper
Limit
Maturity structure of fixed interest rate borrowing 2023/24 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 2023/24 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
Maturity Structure of Borrowing 2023/24
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
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
Rescheduling of current borrowing in our debt portfolio is unlikely to occur as there is still a
large difference between premature redemption rates and new borrowing rates. 
All rescheduling will be reported to the Council, at the earliest meeting following its action. 
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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, whilst investment rates remain elevated,
as well as wider range fund options. 
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 Link Group, Treasury
Solutions.  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 Capita) 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 Link Group, Treasury Solutions 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 Link Group, Treasury Solutions 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 Link Group, Treasury Solutions. 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 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 20 January 2023, 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 14,903 AAAmmf
(Yellow) Instant Access 3.40% 1,931,129
MMF
Federated 14,503 AAAmmf
(Yellow) Instant Access 3.39% 1,008,282
MMF
LGIM 14,709 AAAmmf
(Yellow) Instant Access 3.18% 306,784
Lloyds Bank Corporate
Markets plc 30,000 A+/F1
(Red)
Start: 30 Nov 2022
End: 30 May 2023 4.25% 272,800
National Westminster
Bank plc 15,000 A+/F1
(Blue)
Start: 31 May 2022
End: 31 May 2023 2.00% 1,052,317
Handelsbanken AB
Call Account 14,940 AA/F1+
(Orange) Instant Access 3.30% 721,491
Toronto Dominion Bank 10,000 AA-F1+
(Orange)
Start: 16 Jun 2022
End: 15 Jun 2023 2.85% 436,311
Landesbank Hessen-
Thueringen Girozen 5,000 A+/F1+
(Orange)
Start: 30 Nov 2022
End: 29 Nov 2023 4.47% 306,000
Standard Chartered
Bank 10,000 A+/F1
(Red)
Start: 30 Nov 2022
End: 30 May 2023 4.06% 944,807
Wokingham Borough
Council 15,000
Quasi-UK
Government
(AA- / Yellow)
Start: 25 Mar 2020
End: 24 Mar 2023 1.60%
3,029,079
Stoke on Trent City
Council 2,000
Quasi-UK
Government
(AA- / Yellow)
Start: 06 Apr 2020
End: 06 Apr 2023 1.60%
Total 146,055    10,009,000 
* Credit Rating from Fitch
** Colour represents maximum recommended duration for investment per Link Group, Treasury
Solutions, Treasury Solutions Credit Scoring methodology – see Appendix 2.
*** As at 30 November 2022 
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.  Greater returns are usually
obtainable by investing for longer periods. 
The current shape of the yield curve suggests that is the case at present, but there is the
prospect of Bank Rate peaking in the first half of 2023 and possibly reducing as early as
the latter part of 2023 so an agile investment strategy would be appropriate to optimise
returns. 
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. 
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• If it is thought that Bank Rate is likely to rise significantly within the time
horizon being considered, then consideration will be given to keeping most
investments as being short term or variable;
• Conversely, 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. 
Investment returns expectations
The suggested budgeted investment earnings rates for returns on investments placed for
periods up to about three months during each financial year, (based on a forecast for bank
Rate to reach 4.50% in Q2 2023), are as follows.: 
Average earnings in
each year 
2022/23 4.00%
2023/24 4.40%
2024/25 3.30%
2025/26 2.60%
2026/27 2.50%
Long term later years 2.80% 
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: - 
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.
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 Link Group, Treasury Solutions 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
2019/20 2020/21 2021/22
Limit £70m £70m £70m
Principal Sums
Invested for > 365 Days
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At the end of the financial year, the Council will report on its investment activity as part of
its Annual Treasury Report.
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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
Against a backdrop of stubborn inflationary pressures, the easing of Covid restrictions in
most developed economies, the Russian invasion of Ukraine, and a range of different UK
Government policies, it is no surprise that UK interest rates have been volatile right across
the curve, from Bank Rate through to 50-year gilt yields, for all of 2022. 
Market commentators’ misplaced optimism around inflation has been the root cause of
the rout in the bond markets with, for example, UK, EZ and US 10-year yields all rising by
over 200bps since the turn of the year.  The table below provides a snapshot of the
conundrum facing central banks: inflation is elevated but labour markets are extra-
ordinarily tight, making it an issue of fine judgment as to how far monetary policy needs to
tighten. 
UK Eurozone US
Bank Rate 3.5% 2.0% 4.25%-4.50%
GDP -0.2%q/q Q3
(2.4%y/y)
+0.2%q/q Q3
(2.1%y/y)
2.6% Q3
Annualised
Inflation 10.7%y/y (Nov) 10.1%y/y (Nov) 7.1%y/y (Nov)
Unemployment
Rate
3.7% (Oct) 6.5% (Oct) 3.7% (Nov) 
Q2 of 2022 saw UK GDP revised upwards to +0.2% q/q, but this was quickly reversed in
the third quarter, albeit some of the fall in GDP can be placed at the foot of the extra Bank
Holiday in the wake of the Queen’s passing.  Nevertheless, CPI inflation has picked up to
what should be a peak reading of 11.1% in October, although with further increases in the
gas and electricity price caps pencilled in for April 2023, and the cap potentially rising from
an average of £2,500 to £3,000 per household, there is still a possibility that inflation will
spike higher again before dropping back slowly through 2023. 
The UK unemployment rate fell to a 48-year low of 3.6%, and this despite a net migration
increase of c500k.  The fact is that with many economic participants registered as long-
term sick, the UK labour force actually shrunk by c500k in the year to June.  Without an
increase in the labour force participation rate, it is hard to see how the UK economy will
be able to grow its way to prosperity, and with average wage increases running at over
6% the MPC will be concerned that wage inflation will prove just as sticky as major
supply-side shocks to food and energy that have endured since Russia’s invasion of
Ukraine on 22nd February 2022. 
Throughout Q3 Bank Rate increased, finishing the quarter at 2.25% (an increase of 1%). 
Q4 has seen rates rise to 3.5% in December and the market expects Bank Rate to hit
4.5% by May 2023. 
Following a Conservative Party leadership contest, Liz Truss became Prime Minister for a
tumultuous seven weeks that ran through September and October.   Put simply, the
markets did not like the unfunded tax-cutting and heavy spending policies put forward by
her Chancellor, Kwasi Kwarteng, and their reign lasted barely seven weeks before being
replaced by Prime Minister Rishi Sunak and Chancellor Jeremy Hunt.  Their Autumn
Statement of 17th November gave rise to a net £55bn fiscal tightening, although much of
the “heavy lifting” has been left for the next Parliament to deliver.  However, the markets
liked what they heard, and UK gilt yields have almost completely reversed the increases
seen under the previous tenants of No10/11 Downing Street. 
Globally, though, all the major economies are expected to struggle in the near term.  The
fall below 50 in the composite Purchasing Manager Indices for the UK, US, EZ and China
all point to at least one, if not more, quarters of GDP contraction.  In November, the MPC
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projected eight quarters of negative growth for the UK lasting throughout 2023 and 2024,
but with Bank Rate set to peak at lower levels than previously priced in by the markets
and the fiscal tightening deferred to some extent, it is not clear that things will be as bad
as first anticipated by the Bank. 
The £ has strengthened of late, recovering from a record low of $1.035, on the Monday
following the Truss government’s “fiscal event”, to $1.22. Notwithstanding the £’s better
run of late, 2023 is likely to see a housing correction of some magnitude as fixed-rate
mortgages have moved above 5% and affordability has been squeezed despite proposed
Stamp Duty cuts remaining in place. 
In the table below, the rise in gilt yields, and therein PWLB rates, through the first half of
2022/23 is clear to see. 
However, the peak in rates on 28th September as illustrated in the table covering April to
September 2022 below, has been followed by the whole curve shifting lower.   PWLB
rates at the front end of the curve are generally over 1% lower now whilst the 50 years is
over 1.75% lower. 
After a shaky start to the year, the S&P 500 and FTSE 100 have climbed in recent weeks,
albeit the former is still 17% down and the FTSE 2% up.  The German DAX is 9% down
for the year. 
CENTRAL BANK CONCERNS – DECEMBER 2022 
In December, the Fed decided to push up US rates by 0.5% to a range of 4.25% to 4.5%,
whilst the MPC followed by raising Bank Rate from 3% to 3.5%, in line with market
expectations.  EZ rates have also increased to 2% with further tightening in the pipeline. 
Having said that, the sentiment expressed in the press conferences in the US and the UK
were very different.  In the US, Fed Chair, Jerome Powell, stated that rates will be
elevated and stay higher for longer than markets had expected.  Governor Bailey, here in
1.40%
1.80%
2.20%
2.60%
3.00%
3.40%
3.80%
4.20%
4.60%
5.00%
5.40%
5.80%
PWLB Rates 1.4.22 - 30.9.22
1 Year 5 Year 10 Year 25 Year 50 Year 50 year target %
1 Year 5 Year 10 Year 25 Year 50 Year
Low 1.95% 2.18% 2.36% 2.52% 2.25%
Date 01/04/2022 13/05/2022 04/04/2022 04/04/2022 04/04/2022
High 5.11% 5.44% 5.35% 5.80% 5.51%
Date 28/09/2022 28/09/2022 28/09/2022 28/09/2022 28/09/2022
Average 2.81% 2.92% 3.13% 3.44% 3.17%
Spread 3.16% 3.26% 2.99% 3.28% 3.26%
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the UK, said the opposite and explained that the two economies are positioned very
differently so you should not, therefore, expect the same policy or messaging. 
Regarding UK market expectations, although they now expect Bank Rate to peak within a
lower range of 4.5% - 4.75%, caution is advised as the Bank of England Quarterly
Monetary Policy Reports have carried a dovish message over the course of the last year,
only for the Bank to have to play catch-up as the inflationary data has proven stronger
than expected.   
In addition, the Bank’s central message that GDP will fall for eight quarters starting with
Q3 2022 may prove to be a little pessimistic.  Will the £160bn excess savings
accumulated by households through the Covid lockdowns provide a spending buffer for
the economy – at least to a degree?  Ultimately, however, it will not only be inflation data
but also employment data that will mostly impact the decision-making process, although
any softening in the interest rate outlook in the US may also have an effect (just as,
conversely, greater tightening may also). 
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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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41
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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42
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 Link
Group, Treasury Solutions 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 Link
Group, Treasury Solutions 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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43
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 Link Group, Treasury Solutions 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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44
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 Link Group, Treasury Solutions, 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 Acting Chief Financial 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 20.01.2022 
AAA
• Australia
• Denmark
• Germany
• Netherlands
• Norway
• Singapore
• Sweden
• Switzerland 
AA+
• Canada
• Finland
• U.S.A. 
AA
• Abu Dhabi (UAE)
• France 
AA-
• Belgium
• 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
Tuesday 7 February 2023
Item 5.2
Internal Audit Work to December 2022
Report by Chief Internal Auditor
Report for Decision
1 Recommendations
The Audit Committee is asked to:
a) Consider the Executive Summaries of the final Internal Audit
assurance reports issued;
b) Note the Internal Audit Assurance Work in Progress and Internal
Audit and Other Work carried out; 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 2022/23 was approved by the Audit
Committee on 14 March 2022. 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 reports
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 MLC Internal Audit function conforms with 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 25 January 2023
Report Contact:
Duncan Stainbank
duncan.stainbank@midlothian.gov.uk
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3 Progress Report
3.1 The Internal Audit Annual Plan 2022/23 was approved by the Audit
Committee on 14 March 2022. Internal Audit has carried out the
following work in the period from 1 November to 31 December 2022
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 MLC Internal Audit function conforms with 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.
3.3 Internal Audit issued final assurance reports on the following subjects:
• Accounts Receivable – Sundry Debt; and
• Utilities: Energy and Water Consumption
3.4 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 definitions for Internal Audit assurance categories are as follows:
Level Definition
Comprehensive
assurance
Sound risk, control, and governance systems are in place. These should be effective in mitigating
risks to the achievement of objectives. Some improvements in a few, relatively minor, areas may
be required.
Substantial
assurance
Largely satisfactory risk, control, and governance systems are in place. There is, however, some
scope for improvement as current arrangements could undermine the achievement of objectives
or leave them vulnerable to error or misuse.
Limited assurance Risk, control, and governance systems have some satisfactory aspects. There are, however, some
significant weaknesses likely to undermine the achievement of objectives and leave them
vulnerable to an unacceptable risk of error or misuse.
No assurance The systems for risk, control, and governance are ineffectively designed and operated. Objectives
are not being achieved and the risk of serious error or misuse is unacceptable. Significant
improvements are required.
Current Internal Audit Assurance Work in Progress 
3.5 Internal Audit assurance work in progress to deliver the Internal Audit
Annual Plan 2022/23 consists of the following:
Audit Area Audit Stage
Employability Funded Programmes Drafting the report
Care at Home Drafting the report
Performance Management and Performance Indicators Drafting the report
Mental Health Services Planning underway
Construction projects / social housing programme Planning underway
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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, Capital Plan Management Group, Capital Plan
Prioritisation Review Group, Chief Officers Risk & Resilience
Group, Integrity Group, UKSPF Oversight Board and Information
Management 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 and co-ordinated
submission by management of Audit Scotland Reports to the Audit
Committee or other Committee as relevant.
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: Significant weaknesses in existing controls, leaving the Council or Service open to error, fraud,
financial loss or reputational damage, where the risk is sufficiently high to require immediate action
within one month of formally raising the issue. Added to the relevant Risk Register and included in the
relevant Assurance Statement.
Medium: Substantial weaknesses in existing controls, leaving the Council or Service open to medium
risk of error, fraud, financial loss or reputational damage requiring reasonably urgent action within
three months of formally raising the issue.
Low: Moderate weaknesses in existing controls, leaving the Council or Service open to low risk of
error, fraud, financial loss or reputational damage requiring action within six months of formally raising
the issue to improve efficiency, effectiveness and economy of operations or which otherwise require to
be brought to attention of senior management.
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 2022/23:
Recs Rating 2022/23 Number of Recs
High 0
Medium 6
Low 13
Sub-total reported this period 19
Previously reported 15
Total 34
Recommendations agreed with action plan 34
Not agreed; risk accepted 0
Total 34
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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.
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 the
Council to deliver its key priorities in support of achieving the 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
The 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 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 
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 and areas of improvement.
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
Report Summary of key findings and recommendations Recommendations Status
H M L
Subject: Accounts Receivable -
Sundry Debt
Category: Assurance – Cyclical
Date issued:
17 November 2022 Draft
7 December 2022 Final
Level of Assurance:
Substantial
The purpose of the audit was to review the controls in place to set fees and
charges for services, raise invoices promptly, and collect debts efficiently
resulting in debtors' balances that are complete, accurate and recoverable with
appropriate VAT treatment.
The Council uses Capita’s Integra 2 finance system for sales ledger and arrears
management processes.  Invoices are raised via the sales ledger for a wide
range of chargeable services.  For 2021/22 14,641 invoices were raised
(£24,876,891), 1,135 credit notes were raised (£1,673,554), and 28,453
payments were received (£25,810,735).  The Council’s sundry debt over 30
days old as at 31 March 2019 was £1,489,433 and this increased to £1,959,244
by 31 March 2022.
The Council had weaker collection performance during 2020 at the height of the
Coronavirus pandemic, but from 2021 the collection performance improved and
was similar to normal levels prior to the outbreak of the virus.  The Council’s
aged debt position has deteriorated when compared to pre-pandemic levels, but
collection performance on invoices raised from the latter part of 2021 onwards is
more in line with pre-pandemic performance. 
Most invoices are raised on behalf of services by either the Sundry Debt Team
or Business Support Services.  Schools raise their own invoices for room and
facility hires.  Payments in respect of invoices raised are receipted onto the
Civica ICON system.  A daily upload from this system updates all of the
customer accounts with the payments received.  Responsibility for collection of
sundry debt rests with the Sundry Debt Team.  The Council contracts an
external debt collector (Walker Love) who provide debt collection services for
debts that need a specialist service.
Internal Audit considers that the level of assurance is substantial for the
accounts receivable system.  Accounts receivable processes have improved in
terms of consistency, audit trail, and internal control over the years, and a
significant part of the improvement is due to the Sundry Debt Team and the
internal procedures developed by them.
Internal Audit made the following recommendations:
• Management should review if the timescale for raising rechargeable repairs
invoices could be reduced. (Low)
0 1 5 Management have
accepted the factual
accuracy of the
report and its
findings, and agreed
to implement the
recommendations.
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2
• The Fees and Charges Schedule should be published on the Council
website annually to allow the public to view it and it should include all
relevant fees and charges. (Low)
• The service should finalise the implementation of a credit note E-form which
would require all credit notes to undergo appropriate authorisation. (Medium)
• Record retention requirements for invoice request slips should be clarified
and the procedure should be applied consistently by all officers raising
invoices. (Low)
• Income Collection guidance on VAT should be more detailed. (Low)
• For executory debt, comprehensive diary notes which reflect the complexity
of the case, relevant action taken, evidence reviewed and the basis for the
decision to no longer pursue the debt should be documented. (Low) 
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3
Report Summary of key findings and recommendations Recommendations Status
H M L
Subject:  Utilities: Energy
and Water Consumption
Category: Assurance –
Cyclical
Date issued:
15 December 2022 Draft
18 January 2023 Final
Level of Assurance:
Substantial for the
procurement
arrangements, invoicing
and third party usage.
Limited for usage
monitoring and the
medium to long-term plans
to reduce usage. 
The purpose of the audit was to review the controls over the consumption of utilities
(energy and water) ensuring utilisation is adequately controlled and represents value
for money.
Utilities are procured through the national framework managed by Scottish
Procurement - rates are agreed annually and it is predicted that prices will increase
next year.  The management of utilities is primarily the responsibility of the Energy
Team within the Place Directorate.  There is 1 FTE Energy Assistant Development
Officer with responsibility for payment of utilities invoices, arranging for the
installation or removal of meters, monitoring utilities usage, liaising with the supplier
to address issues or errors in the Council’s utilities billing, assisting in the
preparation of utilities budgets, monitoring and identifying utilities anomalies,
managing Salix funding, providing information relevant for Carbon Management
reporting, and undertaking projects / campaigns to reduce energy usage. The
2022/23 budget for utilities (gas, water and electricity) is £4.686m and was increased
by £1.058m at August Council due to the significant increase in gas prices since the
budget was approved at the start of the year.
Electronic invoices are uploaded to the SystemsLink application for monitoring
purposes and are paid following authorisation within the Council’s Finance system,
Integra 2.  Utility costs are charged to the relevant Council sites by Financial
Services using a report produced by the SystemsLink application.  Baseline
consumption levels have been set for all Council buildings and the budget forecast is
based on these and utility price guidance received from Scottish Procurement and
these are monitored throughout the year.  Baseline consumption is based on
average consumption for the property over a set number of years and is updated
following changes to properties such as extensions or energy improvements. 
The Council approved a Heating Policy in May 2019 which set target building
temperatures for the different types of building (e.g. office space, school offices and
classrooms, gymnasiums, sports centres, care homes, sports centre changing
rooms, pool halls, gym halls, stores, etc.) and the Engineering Technician has
advised that building temperatures have been set in line with the target temperatures
in the policy. 
Internal Audit considers that the level of assurance is Substantial for the
procurement arrangements, invoicing and third party usage.  Assurance is Limited
for usage monitoring and the medium to long-term plans to reduce usage.
0 5 8 Management have
accepted the factual
accuracy of the
report and its
findings, and agreed
to implement the
recommendations.
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Internal Audit made the following recommendations:
• Written procedures outlining the invoicing process for utilities should be updated
and complete PDF version of utilities invoices should be appropriately filed and
retained in line with the Council’s Records Management Policy. Procedures for
the usage monitoring process should be developed and a formalised process
with an appropriate audit trail should be developed for requesting or removing an
energy meter. (Low)
• The energy team should review if more of the smaller sites, such as the door
entry and stair lighting sites and smaller buildings could have AMRs installed and
whether AMRs for water consumption could be installed for additional sites.
(Low)
• The contract rates for the utilities providers should be uploaded to SystemsLink
each year to provide assurance for each invoice and every site that the utility
providers are adhering to the agreed contract rates.  In the interim, conformation
of all relevant rates should be obtained from providers at the start of the year and
evidence retained of sample checking of rates. (Low)
• Invoice verification services should be undertaken with increased frequency to
ensure the Council is receiving best value for its utilities usage. (Low)
• The rates applicable for electricity generated by the Council’s solar panels should
be obtained annually from the provider.  Additionally, the low electricity
generation noted from a sample of panels should be reviewed to understand
what caused this and if action is required to fix the issue. (Low)
• The property sharing arrangement with the NHS for the Recovery Hub including
any rental contribution should be reviewed to ensure it reflects current usage and
this should be documented in a written agreement between the Council and NHS
Lothian. (Medium)
• As stipulated in the Heating Policy, a Buildings Register detailing the heating
arrangements for each building should be developed and this should document
any variations from the heating policy.  The target temperatures for each building
should be reviewed taking into account the rising costs of energy along with the
ability to monitor non-compliance with the Heating Policy. (Medium)
• Management should review the scope for expanding the number of Council
properties included on the Cylon Building Management System.  Additionally, the
system’s reporting functionality should be reviewed. (Low)
• The service should review the resource allocated to the Energy Team to improve
the Council’s ability to monitor energy usage, reduce the key person dependency
risk, and provide more segregation of duties / review controls over information
input into the SystemsLink application. (Medium)
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5
• The Energy Team should work more closely with the Council’s Engineering team
and usage monitoring should consider information from the Building
Management System.  An inventory detailing boilers in all Council buildings
should be collated and this should include the age of each boiler. (Low)
• Management should review the scope for upgrading to the cloud based version
of SystemsLink.  This should be done in consultation with Digital Services and
Business Applications  (Low)
• A review of future plans and management of the Bonnyrigg District Heating
Scheme is required. (Medium)
• Following the pilot exercise being undertaken for Fairfield House and Midlothian
House, a longer term plan for improving building efficiency and reducing utilities
usage across the Council estate should be developed. (Medium)
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Audit Committee
Tuesday 7 February 2023
Item 5.3
Internal Audit Mid-Term Performance Report 2022/23
Report by 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 2022/23 to the end December 2022;
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 9 months of the year to 31
December 2022, towards completing the Internal Audit Annual Plan
2022/23. 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 2022/23 that was approved by the Audit
Committee on 14 March 2022 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 25 January 2022
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 in particular 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 2022/23 that was approved by the Audit
Committee on 14 March 2022 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 2022/23
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.
4.3 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, and
those scheduled for the final quarter of the year, or that will not now be
completed in the year are not shaded. 
4.4 In addition 2 audits Workforce Planning and Health and Safety, shaded
in grey, have now been removed from the audit plan as this is not the
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appropriate time to complete these audits, given current risk and other
external assurance. 
4.5 The Internal Audit plan had, in addition to regularly required review
processes 22 audits scheduled for completion in 2022/23, removing 2
audits results in a requirement to complete 20 audit assignments. The
team has completed 6 assignments (30%), 3 further assignments will
be complete for the March Audit Committee (15%). 4 further
assignments (20%) are scheduled with current team capacity to
substantially complete prior to the annual governance reports in May
2023. Work is underway to identify further resource to complete a
further 3 assignments (15%) by May 2023. The 80% substantial
completion of the plan would allow for an appopriate assessment of the
Councils, governance, risk and control environment that is not limited.
4.6 Going forward further consideration will be given to creating a more risk
based audit plan identifying potential efficiencies when possible, to
ensure that appropriate assurance can be provided for the Council
within the resources made available.   
4.7 The continuous audit approach, in accordance with the Internal Audit
Strategy approved by Audit Committee on 14 March 2022, enables
Internal Audit to provide added value advice on internal controls and
governance and ‘critical friend’ consultancy services. For example,
Business Transformation Board, Capital Planning and Asset
Management Board, and Information Management Group. 
5 Continued Reporting on the Internal Audit Plan for 2022/23
5.1 The Internal Audit work will continue to be reported to the Corporate
Management Team and to the Audit Committee. The Internal Audit
Work 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 & 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.
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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. 
7  Public Sector Internal Audit Standards (PSIAS) and Quality
Assurance & Improvement Plan (QAIP) 
7.1 The MLC 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 will be completed prior to the end of 2022/23. The results
and any associated improvement actions will continue to be reported to
the Corporate Management Team and the Audit Committee within the
Internal Audit Annual Assurance Report. This will enable 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 Council will be reviewed by East Renfrewshire Council
in 2023. 
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
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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 2022/23, 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 2022/23 will not be delivered in full. This
could only be mitigated by use of external resource Regular monitoring
will be undertaken progress to ensure that a sufficient range and
breadth of assurance audit work will be carried out during 2022/23 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.”
Implementation by Management of the actions associated with Internal
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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 - 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
2021/22. 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 2022/23. 
PPP Schools
Contract
Management and
payment
mechanism
30 Review of the contract management
arrangements over the PPP1&2 school
contracts including review of the monthly
payment mechanism.
Complete: Final Report
issued 27 September 2022.
Executive Summary to
Audit Committee 06
December 2022. 
Accounts
Receivable -
Sundry Debt
20 Review of controls in place to set fees and
charges for services, raise invoices promptly
and collect debts efficiently resulting in
debtors' balances that are complete, accurate
and recoverable including review of VAT
treatment.
Complete: Final Report
issued 07 December 2022.
Executive Summary to
Audit Committee 07
February 2023. 
Complaints 20 Review of the controls in place to ensure
complaints are dealt with adequately and in a
timely manner.
Resource is being assessed
to complete in Qtr 4 
Construction
projects / social
housing
programme
30 Review of the adequacy of the control
framework established by management to
allow successful delivery of construction
projects including the Social Housing
Programme.
Brought forward from
2020/21. Defer to 2022/23
- Low risk due to Covid-19
pandemic restrictions in
2020/21 and 2021/22.
Scheduled for 4th Qtr with
planning underway. 
Children’s
Residential and
Day Services
20 Review of the controls in place to ensure sound
budgetary control and the demand on service
delivery for children’s residential and day
services.
Due to Resource
Constraints in 2022/23 this
audit is not scheduled for
completion. Consideration
will be given to inclusion in
the 2023/24 Internal Audit
work plan.  
Schools 20 Review of internal financial controls and
business administrative procedures in place
and data analytics of expenditure (DSM, PEF
Due to Resource
Constraints in 2022/23 this
audit is not scheduled for
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and other Funds including Schools Funds) to
ensure the efficient and effective use of
resources in the school establishments.
completion. Consideration
will be given to inclusion in
the 2023/24 Internal Audit
work plan.  
Counter Fraud
and
Whistleblowing
arrangements
20 Review of the Council's Counter Fraud controls
including policies and whistleblowing
arrangements.
This review has been
completed and will be
reported as part of the
Annual Assurance
Reporting in June 2023. 
Freedom of
Information
20 Review of the controls in place to ensure
Freedom of Information enquiries and dealt
with adequately and in a timely manner. This
will include a review of the implementation of
the new system.
Complete: Final Report
issued 27 September 2022.
Executive Summary to
Audit Committee 06
December 2022. 
Purchasing Cards 20 Review of the controls over the use of
purchasing cards ensuring expenditure incurred
is valid, appropriate and represents value for
money.
Resource is being assessed
to complete in Qtr 4
Lighting 30 Review of the controls over the installation of
new lighting and the maintenance of existing
lighting.
Complete: Final Report
issued 29 September 2022.
Executive Summary to
Audit Committee 06
December 2022. 
Utilities, Energy
and Water
Consumption
30 Review of the controls over the consumption of
utilities ensuring utilisation is adequately
controlled and represents value for money
Complete: Final Report to
be issued 20 January 2022.
Executive Summary to
Audit Committee 07
February 2023. 
AUDIT DAYS COMMENTARY STATUS 
Assurance – Risk Based 
External funded
programmes - CLL
30 Review external funded programmes under the
terms of the associated agreements to assess
compliance with the requirements and delivery
of outcomes.
Audit testing is now
complete and final report is
due in February 2023 with
the Executive Summery
being submitted to the
March Audit Committee.
Criminal Justice 20 Review of the controls in place to ensure
professionals work jointly and effectively and
provide support in a timely manner to ensure
the protection and welfare of children and
young people.
Due to Resource
Constraints in 2022/23 this
audit is not scheduled for
completion. Consideration
will be given to inclusion in
the 2023/24 Internal Audit
work plan.  
Mental Health
Services
30 Assess the governance arrangements in place
to commission specialist mental health services
to promote closer integration and partnership
working to meet the needs of people with
This audit is scheduled for
completion in Qtr4 Initial
Planning is underway. 
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mental health needs. Ensure there is sound
budgetary control in place.
Schools Budgets
(DSM)
30 Review the Council's implementation of the
new DSM scheme.
Due to Resource
Constraints in 2022/23 this
audit is not scheduled for
completion. Consideration
will be given to inclusion in
the 2023/24 Internal Audit
work plan.  
Systems
Development,
maintenance and
support
30 Review of the controls in place to ensure new
systems are adequately installed, tested and
implemented in a timely manner.
This audit is scheduled to
commence in Qtr4
Information
Governance
20 Continual audit approach to review the
information governance framework including
roles and responsibilities, policy development
and implementation.
Resource is being assessed
to commence in Qtr 4
Financial
Sustainability in
Future Years
20 Continual audit approach to review the
medium term financial strategy and plans to
ensure they are based on realistic assumptions.
Ensure that appropriate scrutiny and challenge
is undertaken to deliver the plans.
This audit is scheduled to
commence in Qtr4.
Workforce
Planning
30 Review of the recruitment, training and
performance management of employees.
Delayed awaiting service
staff appointments.
Consideration will be given
to inclusion in the 2023/24
Internal Audit work plan.  
Care at Home 30 Review of the contract management
arrangements over the care at home contract
to ensure that the Council is receiving value for
money.
Audit testing is now
underway and final report
is due in February 2023
with the Executive
Summery being submitted
to the March Audit
Committee. 
Performance
Management &
Performance
Indicators
20 Testing of a sample of performance indicators
to ensure that they are complete, accurate,
based on current data and conform to the
stipulated criteria.
Audit testing is now
underway and final report
is due in February 2023
with the Executive
Summery being submitted
to the March Audit
Committee.
Health & Safety 20 The Council is complying with relevant Health
and Safety legislation, has a structured
approach to Health and Safety awareness,
including review of the Health and Safety
Management system to ensure there are
adequate and effective controls in place for
health and safety.
Delayed as it is understood
that external assessment of
Health and Safety is being
completed shortly.
Consideration will be given
to inclusion in future
Internal Audit work plans.   
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AUDIT DAYS COMMENTARY STATUS 
Consultancy 
Consultancy 30 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
Business Transformation
Board, Capital Plan and
Asset Management Board,
and Information
Management Group. 
AUDIT DAYS COMMENTARY STATUS 
Other 
PSIAS Self-
Assessment
10 Undertake annual self-assessment of the
Internal Audit function against the Public Sector
Internal Audit Standards (PSIAS) and report
findings to the Audit Committee.
Scheduled 4th Qtr. Findings
will be outlined in Internal
Audit Annual Assurance
Report 2022/23.
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 2021/22 to Council
on 4 October 2022.
2022/23 self-assessment
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 Internal Audit
Recommendations to Audit
Committee 6 December
2022. Follow-Up Review of
In Progress Internal Audit
Recommendations
scheduled 4th Qtr.
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
20 Provide guidance and advice to Management
on internal controls.
Ongoing
MLC
Administration of
Audit Scotland
Reports
2 Monitor publication of Audit Scotland reports
and co-ordinate submission by Management of
Audit Scotland Reports to the relevant
Committee.
Ongoing
Management
Groups
4 Attend and provide support to Risk
Management and Integrity Groups.
Ongoing
MLC Attendance
at Boards /
Committees
10 Prepare for and attend Audit Committee
meetings and other Boards/Committees.
Ongoing
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MLC Audit
Planning for
2023/24
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 2023/24
Scheduled 4 Qtr. Internal
Audit Annual Plan 2023/24
will be presented to Audit
Committee for approval in
March 2023. 
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 2022/23 approved by
MIJB Audit and Risk
Committee on 3 March
2022. Audit work ongoing.
Reports will be presented
to MIJB Audit and Risk
Committee 
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Audit Committee
Tuesday 7 February 2023
Item 5.4 
Risk Management Update – Strategic Risk Profile Quarter 3 2022/23 
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 3 (Q3) 2022/23 (1 October
to 31 December 2022). 
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 Q3 2022/23 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 
14 January 2023 
Report Contact:
Derek Oliver, Chief Officer Place
Derek.Oliver@midlothian.gov.uk 
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2 
3 Q3 risk management overview 
3.1 Midlothian Council has delivered a wide range of services to the people
of Midlothian throughout Quarter 3 2022/23 (1 October to 31 December
2022) whilst operating within seasonal challenges including initiation of
the Council’s winter weather response. 
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’s group and Corporate
Management Team (CMT). 
3.3 Audit Committee should note that there are no changes this quarter to
the evaluation of current risks and no new risks. Updates on actions
taken are included in the full strategic risk profile (Appendix B). 
Strategic Risk Profile Summary
3.4 The SRP is split into three sections:
• Strategic issues
• Strategic risks
• Opportunities 
STRATEGIC ISSUES - SUMMARY 
Strategic issues Likelihood Impact Score Evaluation Q3 Q2 22/23
COVID 19 4 4 16 High  High
The Change Programme 5 5 25 Critical  Critical
Financial Stability 5 5 25 Critical  Critical 
COVID-19
3.5 The risk evaluation was reduced from Critical to High in Q1 22/23 and
remains as high through Q2 22/23 and Q3 22/23. Whilst the rate of
infection and case numbers was decreasing in Q2 and early Q3; data
shows that towards the end of Q3 and into early Q4 that infection rates
of COVID-19 and other respiratory and flu-related illnesses are
increasing. This has not impacted on the risk evaluation yet however
services continue to see the impact through absences, which impacts
on service delivery. The Council continues to monitor and risk assess
as appropriate.
The Change Programme 
3.6 The Change Programme remains at Critical throughout 22/23. The
financial challenges of the underlying budget gap pose a significant
challenge for benefits realisation. Council agreed to a solution to
balance the 2022/23 budget, however the increased costs associated
with delivering change and transformation require longer term financial
solutions. Work is ongoing to develop the next Medium Term Financial
Strategy and associated Strategic Plan which will inform the future
direction of the programme.
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3 
Financial Sustainability
3.7 Scottish Government grant settlements fall short of the resources
needed to sustain core services. This core funding shortfall, combined
with inflation pressures, pay awards and demographic pressures
arising from a continued increasing ageing population of over 75’s,
increasing population of 0-15 age group and at a time when there are
rising customer expectations poses a significant challenge for the
Council. 
3.8 The Scottish Budget was announced on 15 December 2022. The first
version of the Local Government Finance circular was published on 20
December 2022 with subsequent revisions received late December
2022 and further revisions published in Q4 January 2023. Work is
ongoing to determine the impact of the Scottish Budget and convert the
cash figures contained within to real term figures and align to
Midlothian’s position. 
3.9 Included knowns within the Scottish Budget are changes to the way
that Non Domestic Rate Revaluation Appeals are handled, as well as a
range of non-recurring commitments such as Scottish Child Bridging
Payment and interim Care Funding; and a range of new commitments
for 2023/24. 
3.10 There are still unknowns within the Scottish Budget with a number of
areas that remain to be confirmed following discussions between
CoSLA and Scottish Government including Free School Meals, Early
Learning and Childcare, Teachers Pay and other items that all play a
significant part in informing the Council’s short and medium term
financial strategy. 
3.11 It is clear however that the Local Government Funding is reducing
significantly in real terms. 
3.12 The scale of the financial challenge continues to be reported to
Business Transformation Steering Group and Council (with the most
recent financial position to be reported to a Special Council meeting on
31 January 2023). Discussions on proposals to inform the Medium
Term Financial Strategy are ongoing. Balancing the budget for future
years will require cross party support and agreement to identify
sustainable solutions. Due to the current uncertainty and lack of a
revised Medium Term Financial Strategy this issue remains Critical
through Q3. 
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4
STRATEGIC RISKS – SUMMARY 
Strategic Risks Likelihood Impact Score Evaluation Q2 Q1 22/21
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
Early Years Expansion
(1140 Hours)
4 5 20 High . High
Scottish Child Abuse
Inquiry
4 4 16 High  High
UK decision to leave the
EU
4 5 20 High  High
Growing Council 4 4 16 High  High
Cost of Living Crisis 3 5 15 Medium  Medium
National Care Service  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
Governance and standards 3 4 12 Medium  Medium
Employee performance 3 4 12 Medium  Medium
Emergency planning and
business continuity
3 4 12 Medium  Medium
Legal and Regulatory
compliance
3 3 9 Medium  Medium
Internal control
environment
3 3 9 Medium  Medium
Corporate policies and
strategies
2 3 6 Low  Low 
STRATEGIC RISKS – RATED CRITICAL/HIGH 
Climate Change 
3.13 The Council developed a Climate Change Action Plan as part of its
Climate Change Strategy approved by Council in August 2020, as well
as making the commitment to achieve Carbon Neutral by 2030. 
3.14 The Carbon Neutral by 2030 strategic board is developing the overall
cross Council response to the Council’s statutory requirements. There
are a range of projects underway which will contribute to the overall
ambition but development of the programme and these projects is
identifying that there is a significant financial investment that is required
to be made to retrofit buildings, fleet replacement and change working
practices. 
3.15 The current financial resource and staffing capacity across the Council
is insufficient and poses a critical risk to delivery. This is also impacted
by the financial sustainability challenge that is articulated in this report. 
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5
3.16 A review of the current Climate Change Strategy and Action Plan is
being undertaken and an update will be provided to Council in Q4
2022/23. The risk evaluation continues to remain Critical in Q3. 
Early Years Expansion (1140 hours)
3.17 Following the Scottish Government’s decision to increase the number
of free early learning and childcare hours to 1140, the Council has
continued to plan with its partners. The two key strands to the
successful implementation are the recruitment and training of staff and
the physical increase in estate capacity. These challenges are being
considered in the wider context of the plan, in which the capacity and
expansion of all funded providers (council, private and voluntary
settings as well as childminders) combine to deliver the requirements. 
3.18 This risk evaluation continues to remain High whilst the Council awaits
an update on the funding provision. 
Scottish Child Abuse Inquiry (SCAI)
3.19 The SCAI risk remains High. The Inquiry has heard all the evidence for
the Sct 21 submissions around foster care. Many Chief Social Work
Officers (CSWO’s) were called to give evidence around abuse within
their local authority. Midlothian CSWO was not called to give evidence.
This part of the inquiry is now concluded with learning from this due to
be written up by around March 2023. The learning will result in an
action plan being developed which we shall consider and ensure that
our policies and practice are updated accordingly. 
UK decision to leave the EU
3.20 The last three quarters have demonstrated that 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) in Q1 and Q2 and also through progress reports on
programmes to Council i.e. the delivery of the A701 and increased
school build costs. The current Capital Programme is subject to a
reprioritisation review and will be reported to Council in Q4 22/23
alongside the Medium Term Financial Strategy. This risk evaluation
remains High. 
Growing Council
3.21 In Q2 22/23 the risk evaluation increased from Medium to High. 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 and rent freeze response that could risk the
delivery of the house building programme
• 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.
3.25 Work is ongoing to review the Learning Estate Strategy and a
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6  
STRATEGIC OPPORTUNITIES 
Shawfair
3.26 The Shawfair development, with its new Rail link provides a major
incentive for house builders, employers, retail and commercial interests
including opportunities to secure a low carbon community through
district heating from Zero Waste. The Energy Services Agreement with
Shawfair LLP has now been signed and work progresses to deliver the
Energy Centre. 
Easter Bush
3.27 Fast growing opportunities in Science, Technology, Engineering and
Mathematics (STEM) with opportunities to link with education.
Partnership links to schools and university sector at the 'Bush' to
promote STEM. The rate of inflation is impacting on the costs of the
A701 improvements which will was reported to Council at the end of
June 2022. A funding application has been submitted to the UK
Government’s Levelling Up fund to close the funding gap, with the
results to be announced in Q4 2022/23. 
City Deal
3.28 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. In 2022,
Midlothian Council took over the chairing of the City Deal programme.
In Q3 2022/23 this annual chairing arrangement came to an end and
the Council carried out the handover to Scottish Borders Council. 
Creating a world class education system
3.29 The Centres of Excellence model is a core part of the Council's
strategy to create a world-class education system in Midlothian. 
Funding has been approved by Scottish government to create a STEM
centre of excellence as a replacement for Beeslack High school.
Research is being carried with the University of Edinburgh to establish
the impact of new school buildings on educational attainment. 
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7
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 3 2022/23 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. 
4.4 Additional Report Implications (See Appendix A) 
See Appendix A 
Appendices 
Appendix A – Additional Report Implications
Appendix B – Strategic Risk Profile (Quarter 3 2022/23) 
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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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1
Strategic Risk Profile 
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.  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships
1. Strategic Boards established reporting to the Business
Transformation Board covering the full range of transformation strands:
Capital Strategy; Carbon Neutral by 2030; Digital First; Economic
Renewal; Education Recovery; HSCP Transformation; Hub & Spoke
Place Based Solutions; Remote Working. 
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 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. 
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 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SPR.RA-
02.08 Strategic Plan 2023 to 2027
Q3 22/23: Development of Strategic Plan and MTFS for next term of Council being
progressed to support decisions about what services, beyond those which are statutory
can be provided. This facilitates setting of the 2023/24 budget in February 2023.  
Chief Executive,
Chief Finance
Officer
28-Feb-2023 
SRP.RA.02.0
3
Develop Medium Term Financial Strategy with greater
oversight, clearer responsibility and accountability.
Q3 22/23: An ongoing assessment of the projected gap for 2023/24 through to 2027/28
has been presented to BTSG alongside a series of officer savings proposals to bring
recurring expenditure back in line with recurring income.  
Chief Executive,
Chief Finance
Officer
28-Feb-2023 
Appendix B
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2      
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. It 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.  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships
1. There is an approved Capital Strategy and Reserve Strategy in
place. 
2. There is an approved budget for 2022/23. Services are being
delivered within the totality of that budget and the 2022/23 budget has
been approved albeit with heavy reliance on one off funding. 
3. There are effective arrangements in place to monitor financial
performance including quarterly reporting to Council with draft reports
considered at a dedicated CMT session each quarter to bring greater
focus. 
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. Enhanced monitoring arrangements have been put in
place for the Place Directorate. 
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 23 August 2022 sets out scale of financial
challenge ahead with recurring expenditure for current service delivery
projected to exceed recurring income. 
11. “Mini Budgets” progressed in 2020/21 and in 2021/22 that removed
non-deliverable legacy savings targets given focus on response to and
recovery from pandemic. 
12. 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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3              
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SPR.RA-
02.09 Strategic Plan 2023 to 2027
Q3 22/23: Development of Strategic Plan and MTFS for next term of Council being
progressed to support decisions about what services, beyond those which are statutory
can be provided. This facilitates setting of the 2023/24 budget in February 2023.  
Chief Executive,
Chief Finance
Officer
28-Feb-2023 
SRP.RA.02.0
3
Develop Medium Term Financial Strategy with greater
oversight, clearer responsibility and accountability.
Q3 22/23: An ongoing assessment of the projected gap for 2023/24 through to2027/28
has been presented to BTSG alongside a series of officer savings proposals to bring
recurring expenditure back in line with recurring income.  
Chief Executive,
Chief Finance
Officer
28-Feb-2023 
SRP.IR.10 COVID 19 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.IR.10
Risk cause: COVID 19 Virus 
Risk event: Virus evident in all communities with rates of
positive infection increasing. In a Sottish setting the focus
on increase is within the central belt. 
Risk effect: Potential for widespread impacts with the risk
of significant levels of community transmission leading to
increased government restrictions aimed at reducing
community transmission. 
Delivery of services making use of remote working
solutions as far as possible. National lockdown measures
to limit and control spread, impact on income generating
services. 
Rapid pace of guidance change following government
announcements and expectation of quick changes to
service delivery in line with new controls.  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships,
HR Strategic
Lead
1. CIMT established to take the strategic approach to managing the
response to COVID 19 and stands ready to be re-initiated at any time. 
2. Hybrid working has been adopted by the Council as well as a
dedicated Hybrid Working Board as part of the Transformation
Programme 
3. COVID-19 guidance monitored and continually revised, with
particular focus on Adult Services, Children’s Services, Education and
Communities and Lifelong Learning around how they would continue to
maintain contact with children and young people who were deemed to
be at risk. 
4. Keeping employees briefed and supported through the Chief
Executive’s weekly staff briefings; Communications weekly email and
routine HR updates. (e-mailed to all employees through combination of
work and personal e-mail addresses). Includes Wellbeing advice,
guidance and support and signposting to PAM and EAP providers. 
5. Promotion of digital tools to support employees and prevent
employees becoming isolated. 
6. Council website kept up-to date, providing details of which services
were operating and any changes on how to access services. 
7. A range of interventions, including digital equipment and tools such
as MS Teams put in place to support remote and hybrid working 
8. Following safe working guidance issued by Scottish Government
relevant to sectors. 
9. Economic Recovery Strategy 
10. School and workplace based COVID risk assessments continually
reviewed to support the identification and control of risk (and personal
risk assessments where required)  
4 4 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
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4
SRP.RA.10.1 Hybrid Working
Q3 22/23: Hybrid Working project is a key project contributing to the Council’s
transformation programme. Project Board regularly reports to Business Transformation
Board and Business Transformation Steering Group. 
Executive Director
Place, Chief
Digital Officer
31-Mar-2023 
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. 
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.  
Chief Executive,
Executive
Director Health &
Social Care,
Head of Adult and
Social Care;
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place;
Chief Officer
Children, Young
People and
Partnerships
1. The Bill is under consultation and it is anticipated that additional
information will be released by April 2023. 
2. Officer Working Group established to engage with the NCS Design
School and to continue the existing work with COSLA, SOLACE,
SOLAR and other relevant bodies 
3. Ongoing briefings with elected members 
4. Continued dialogue and engagement with Scottish Government and
IJB/H&SCP/Children’s Services  
3 5 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
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5
SRP.RA.11.1 Officer Working Group 
Q3 22/23: COSLA and Social Work Scotland have formally requested a pause on the
NCS Bill.
Q1 22/23: Officer Working Group agreed to be established by CMT  
Chief Executive 31 March
2023 
Strategic Risks   
SRP.RR.01 Financial Sustainability in future years 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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. 
Uncertainty around service delivery models and income
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships
1. Development of Strategic Plan and MTFS for term of new Council. 
2. Maintaining a level of reserves to deal with unforeseen or one off
cost pressures. 
3. Capital and Reserves Strategies in place. 
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
Route Map through and out of the Pandemic 
budget approved for 22/23 albeit with reliance on one off funding
sources 
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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6
streams and prospects for public finances associated with
COVID impact and recovery. 
Risk effect: 
Gap in Council budget between budget commitments /
pressures and funding level and inadequate options
presented to address this, resulting in a structural deficit.
The pace of growth coupled with the shortfall in grant
settlements adds pressure to Council budgets which will be
unable to deliver capital and revenue work programmes.                
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.02.0
3
Develop Medium Term Financial Strategy with greater
oversight, clearer responsibility and accountability.
Q3 22/23: An ongoing assessment of the projected gap for 2023/24 through to 2027/28
has been presented to BTSG alongside a series of officer savings proposals to bring
recurring expenditure back in line with recurring income.  
Chief Executive,
Chief Finance
Officer
28-Feb-2023 
SRP.RA.02.0
4 Strategic Plan 2023 to 2027
Q3 22/23: Development of Strategic Plan and MTFS for next term of Council being
progressed to support decisions about what services, beyond those which are statutory
can be provided. This facilitates setting of the 2023/24 budget in February 2023  
Chief Executive,
Chief Finance
Officer
28-Feb-2023 
SRP.RA.02.0
5 Understanding impact of NCS Bill
Q2 22/23: COSLA and Social Work Scotland have formally requested a pause on the NCS
Bill.
Q1 22/23: 
Officer Working Group agreed to be established by CMT. Note details on the NCS Bill are
currently limited – see new risk within Strategic Risk profile for further information and
actions  
Chief Executive 31 March
2023 
NEW Capital Plan prioritisation
Q3 22/23: Work is ongoing to review the overall Capital Plan and committed expenditure,
with a reprioritisation of the programme reflective of the escalating inflationary pressures.
Reprioritisation plan to be presented to Council in Q4 for approval, aligned to the Medium
Term Financial Strategy.
Executive Director
Place, Executive
Director Children,
Young People and
Partnerships,
Chief Finance
Officer, Head of
Development
31 March
2023 
SRP.RR.02 The Long Term Change Programme 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
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7
Evaluation
SRP.RR.02
Risk cause
A MTFS that doesn't 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 
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  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships
1. Development of Strategic Plan and MTFS for term of new Council
and service options which identify what can /cannot be delivered within
the resources available. 
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 new risk on NCS for further detail)  
5 5 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SPR.IA.02.06 Strategic Plan 2023 - 2027
Q3 22/23: Development of Strategic Plan and MTFS for next term of Council being
progressed to support decisions about what services, beyond those which are statutory
can be provided. This facilitates setting of the 2023/24 budget in February 2023  
Chief Executive,
Chief Finance
Officer
28-Feb-2023 
SRP.RA.02.0
3
Develop Medium Term Financial Strategy with greater
oversight, clearer responsibility and accountability.
Q3 22/23: An ongoing assessment of the projected gap for 2023/24 through to 2027/28
has been presented to BTSG alongside a series of officer savings proposals to bring
recurring expenditure back in line with recurring income.  
Chief Executive,
Chief Finance
Officer
28-Feb-2023 
SRP.RR.03 Legal and Regulatory Compliance 
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8
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.03
Risk cause
Current or new legislation applying to Midlothian Council 
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.  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships,
Legal and
Governance
Manager
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. Local Scrutiny Plan 
7. BTSG oversight of new legislation  
3 3 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.03.0
2 Rights of the Child Bill 
Q3 22/23: Scotland is set to become the first country in the UK to directly incorporate the
UN Convention on the Rights of the Child into domestic law. The Scottish Government’s
new bill on the rights of the child is expected to have far reaching implications for public
bodies. Midlothian Council is beginning to roll out training with regards to the implication
this new piece of legislation shall have on all services. 
Q2 22/23: Scotland is set to become the first country in the UK to directly incorporate the
UN Convention on the Rights of the Child into domestic law. The Scottish Government’s
new bill on the rights of the child is expected to have far reaching implications for public
bodies. With guidance beginning to be disseminated from the Scottish Government, the
Council is continuing to monitor and plan.   
Executive Director
Children, Young
People and
Partnerships,
Chief Social Work
Officer
31-Mar-2023 
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9
SRP.RA.03.0
3 National Care Service
Q3 22/23: COSLA and Social Work Scotland have formally requested a pause on the
NCS Bill. 
Q1 22/23: 
Officer Working Group agreed to be established by CMT. Note details on the NCS Bill are
currently limited – see new risk within Strategic Risk profile for further information and
actions.  
Chief Executive 31-Mar-2023 
SRP.RA.03.0
5 Standing Orders
Q3 22/23: The Standing Orders Working Group was approved and appointed at the
Council meeting on 13.12.2022 and will meet in Q3 to ensure that these issues are
included within this work programme and that all staffing changes are incorporated into
the Scheme of Delegation. In the interim, mitigations will be put in place to ensure
authorisations are valid.  
Q2 22/23: Structural reviews within the Midlothian Council resulting in the Standing Orders
being outdated. Authorised Officers within Regulatory Services may be open to challenge
in relation to statutory enforcement work on grounds of delegated authority. Statutory
enforcement work including the service of Statutory Notices, Fixed Penalties and Court
proceedings may require to be withdrawn resulting in reputational damage and or financial
penalty (e.g. case costs awarded against the LA). Structural reviews approved by Council
have been incorporated into Standing Orders. 
Executive Director
Place; Legal and
Governance
Manager
31- Mar 2023 
SRP.RR.04 Employee performance 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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 significantly lower in social work area in
comparison to other LA’s resulting in recruitment issues
particularly with trying to recruit experienced staff 
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
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
3 4 
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10
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. 
‘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  
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships,
HR Strategic
Lead
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.                
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.02.0
4
Revisions to Service Workforce Plans - including analysis
of future workforce requirements, gap analysis and gap
closing strategies, and performance measures and target
setting.
Q3 22/23: Workforce plan guidance issued to all Directorates. Refreshed workforce plans
to be developed in line with the new service plans for the next financial year 23/24   HR Strategic Lead 31-Mar-2023 
SRP.RA.02.0
6 Workforce wellbeing Q3 22/23: Continuing to embed the new Employee Health and Wellbeing Strategy.   HR Strategic Lead 31-Mar-2023 
SRP.RR.07 Care at Home 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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
Director Health
and Social Care,
Head of Adult
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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11
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.07.0
1 Independent review of adult and social care
Q3 22/23: COSLA and Social Work Scotland have formally requested a pause on the
NCS Bill. 
Q1 22/23: 
NCS Bill published June 2022. Consultation at Stage 1, concludes in Sept. See separate
risk on NCS for further information.  
Head of Adult and
Social Care; Chief
Executive
30-Jun-2022 
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.RR.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, street lights and vehicles
& buildings used to deliver services. 
Risk event
Many assets will deteriorate under normal conditions
although buildings, roads and street lights 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
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
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 program - 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
3 5 
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12
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. 
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships,
Head of
Development
dedicated Asset Management Board 
9. Establishment of 7 thematic Estate Safety and Management Groups
chaired by Chief Officer Place                
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.08.0
2
Plan for appropriate investment in capital works and
remedial maintenance over the lifespan of each property
asset.
Q2 22/23: Programme of work agreed to progress for building condition surveys on a
phased approach, over a three year period. Move to implementation into 22/23.   
Check w/Gareth
Chief Officer Place 31-Mar-2023 
SRP.RA.08.0
5 Learning Estate Strategy
Q2 22/23: Potential risk to delivery of Learning Estate projects due to .inflated costs from a
number of factors. Factoring the commitment to net zero into our projects has added
another cost pressure and may affect the affordability and viability of some projects.
Oversight of Learning Estate programme through the Capital plan & Asset Management
Board   
MB
Executive Director
Children, Young
People and
Partnerships,
Head of
Development
31-Mar-2023 
SRP.RA.08.0
6 Asset Management systems Q2 22/23: Work is ongoing through Place services to identify appropriate asset
management systems   Chief Officer Place 31-Mar-2023 
SRP.RR.09 Emergency Planning and Business Continuity Management 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Potential sub risks include:- 
01 – 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. 
02 – Establishment based incident response plans in place and
maintained locally. 
03 – Emergency response plan setting out general approach to
respond to a major emergency in-line with key partner organisations. 
04 – 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. 
3 4 
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13
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  
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships,
Head of
Development,
Senior Manager
Protective
Services, Health,
Safety &
Resilience
Manager
05 – Care for People Group meeting 6 weekly to continue support for
Communities in response to COVID – 19 to establish and co-ordinate
support for people on a multi-agency basis. 
06 – Care for People Group: Afghan, Ukrainian and UASC support
programmes                
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.09.0
2 Development of Emergency Planning Improvement Plan
Q3 22/23: New Health, Safety and Resilience Team Manager in pos
Q2 22/23: New Contingency Planning Officer in post and work progressing on
improvement plan   
Chief Officer
Place; Senior
Manager
Protective
Services, Health,
Safety &
Resilience
Manager
31-Mar-2023 
SRP.RA.09.0
3 Business Continuity System
Q3 22/23: Pilot areas identified and champions across Directorates for the roll out
Q2 22/23: System currently being populated ahead of roll out to all services. A small
number of Council services engaged to test and validate operational functionality. Project
governance now overseen through the Customer Service Platform Board   
Chief Officer
Place; Senior
Manager
Protective
Services, Health,
Safety &
Resilience
Manager
31-Mar-2023 
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14
SRP.RR.10 Governance and Standards in Public Life 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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  
Chief Officer
Corporate
Solutions; Chief
Executive; Chief
Officer Place;
Executive
Director Place;
Alan Turpie
Potential sub risks include:- 
01 Macro governance at the top – failure in openness, accountability,
clarity; 
02 Micro governance in services, partnerships and projects and
outcomes not achieved 
03 Non-compliance with codes of conduct and reduction in standards
in public life 
04 Annual Assurance Statement. 
05 Standing Orders 
06 Scheme of Administration 
07 Scheme of Delegation  
3 4 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RR.10.0
1 Corporate Governance
Q3 22/23: Annual Assurance Statement submitted annually, People Policies and Standing
Orders subject to review process (see separate risks contained within the strategic risk
profile for further information)  
Executive Director
Place; Chief
Officer Corporate
Solutions; Legal
and Governance
Manager
31-Mar-2023 
SRP.RR.11 Corporate Policies and Strategies 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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 align to strategic priorities will inhibit the rather
than support implementation of strategic priorities.  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
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 in October 2022 
5. Procurement Strategy 2018 
6. Capital Strategy 
7. Integrated Joint Board (IJB) Plan 
8. IJB Strategic needs assessment 
9. Midlothian Local Development Plan 2017 – the Council’s corporate
spatial strategy.  
2 3 
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15
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships              
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.11.0
2 Accessibility Strategy
Q3 22/23: Work progresses through the building audit programme 
Q2 22/23: Education working with Property colleagues to refresh building
data including information on building accessibility. Once work is complete, a
work stream will be progressed to ensure Council compliance.  
Chief Officer
Place; Chief
Operating
Officer
Education;
Senior Manager
Property and
Facilities
Management
31-Mar-2023 
SRP.RA.11.0
5 Antisocial Behaviour Policy Q3 22/23: Work continues  Chief Officer
Place 31-Mar-2023 
SRP.RA.11.0
6 Strategic Plan 2023 - 2027
Q3 22/23: Development of Strategic Plan and MTFS for next term of Council
being progressed to support decisions about what services, beyond those
which are statutory can be provided. This facilitates setting of the 2023/24
budget in February 2023  
Chief Executive;
Chief Finance
Officer
31-Mar-2023 
SRP.RR.11.0
1 Parental Engagement Strategy
Q3 22/23: A Parental Engagement strategy and a Parent Council Toolkit have
been developed and implemented in October 2022. The Parental Learner
Liaison Officer continues to engage with parents and learners through Parent
Council Chairs, Parent/ learner Conferences as well as hearing their voice
through National Discussions and consultations.
Q2 22/23: Parental Learner Liaison Officer has produced a draft Parental
Engagement Strategy looking at examples throughout Scotland and a
consultation with all stakeholders is underway. Following a review with Parent
Council Chairs, a Parental Engagement calendar has been created for next
session to support PC Chairs with the information and structure they need. The
National Parental Involvement & Engagement survey has been rolled out to all
Primary, Secondary & Special School parents with data to be evaluated in July.
Parent Working Groups have been created to support specific interests and
priorities – Consultation, Equity, Digital Learning, ASN & DWY/Positive
Destinations. A Parent Council ‘Toolkit’ has been created to inform Parents of
the functions of a Parent Council, provide support, signposting and remits. This
will provide a more consistent structure within Midlothian of all Parent Councils
and potentially boost numbers. Social Media has been created for Parental
Chief Operating
Officer
Education
31-Oct-2022 
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16
Engagement and the design of a webpage to add to the Council Website is
underway. Draft plans for our first Parent Conference in Q1 of next session is
underway. The same is to be said for a Pupil Conference. The PLLO is now an
active member in the SEIC Young Persons Involvement Group and regularly
meets the Education Scotland’s Attainment Advisor.   
SRP.RR.12 Internal Control Environment 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
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. Whistleblowing Policy (subject to review) 
5. Internal and external assurance. 
6. E-learning for staff to complete mandatory training for fraud
awareness. 
7. Implemented changes to business processes and procedures to
maintain and enhance internal control. 
8. Bi-annual updates to Audit committee on progress with
recommendations noted in the annual governance statement. 
9. Continue remind staff of secondary employment/outside interests
and gifts & hospitality 
10. Digital induction for all new employees (with service exceptions),
including legal, HR, procurement, health and safety. Control at entry to
organisation. 
11. Management Development Programme, delivered in partnership
with Edinburgh College, provides reinforcement of organisational
regulatory obligations. 
12. 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.  
3 3 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
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17
SRP.RA.12.0
4 Review of Serious Organised Crime (SOC) group Q3 22/23: Review continues
Q2 22/23: Review of SOC has begun with stakeholder engagement underway   Chief Officer Place 31-Mar-2023 
SRP.RR.13 Climate Change 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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.  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships;
Senior Manager
Planning,
Sustainable
Growth and
Investment
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.13.0
3 Recruitment of Climate Change Officer Q3 22/23: Service Review continues.  
Chief Officer
Place; Senior
Manager
Planning,
Sustainable
Growth and
Investment
31 March
2023 
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18
SRP.RA.13.0
4 Delivery of the BTB Board Carbon Neutral by 2030
Q3 22/23: Work underway to develop a fully costed Climate Change action plan to be
presented to members in Q4 2022/23
Q2 22/23: Carbon Management Plan requires to be reviewed and resourced adequately.
There is a requirement for a cross Council approach to achieve carbon neutral by 2030.
Work is underway in discrete areas to contribute to achievement of the ambition, but
financial resource and staffing is required to develop an overarching engagement and
action plan.  
Chief Officer
Place; Senior
Manager
Planning,
Sustainable
Growth and
Investment
31-Mar-2030 
SRP.RA.13.0
5 Development of the Strategic Plan 2023-27 Q3 22/23: Carbon Neutral by 2030 is a strategic priority within the draft strategic plan  
Chief Officer
Place; Senior
Manager
Planning,
Sustainable
Growth and
Investment
31-Mar-2023 
SRP.RR.14.1 Scottish Child Abuse Inquiry 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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 the 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
Chief Executive;
Executive
Director Children,
Young People
and Partnerships;
Chief Social
Worker
The Council have set up an Abuse Inquiry Project Team to support the
Council to prepare for information requests to support the Inquiry. 
In addition we have a Claims Project Team who have mapped out how
we shall manage any future claims reported against the Local
Authority. 
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. 
4 4 
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19
by the inquiry and subsequent claims of abuse. 
We have request 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.  
7. Consideration to identifying if additional staffing will be required as
expected deluge of FOI’s SAR’s 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.                
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.14.0
3 Foster Care and Residential Care File Review
Q3 22/23: Inquiry has heard all the evidence for the Sct 21 submissions around foster
care. Many CSWO’s were called to give evidence around abuse within their local
authority. Midlothian CSWO was not called to give evidence. This part of the inquiry is
now concluded with learning from this due to be written up by around March 2023. The
learning will result in an action plan being developed which we shall consider and ensure
that our policies and practice are updated accordingly.
Q1 22/23: Inquiry is taking evidence in relation to Sct 21 submissions around foster care
findings. Many CSWO’s have been called to give evidence around abuse within their local
authority. To date Midlothian have not been called to give evidence. We have a QC
offering advice on our submission, which do not suggest that there is evidence to suggest
there has been systemic abuse, based on our file read to date.   
Children’s
Services
Management
Team; Chief
Social Worker
31-Mar-2023 
SRP.RR.16 Growing Council 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.16
Risk cause
Population growth in Midlothian over the next 10 - 15 years
will see Midlothian become the fastest growing Council in
Scotland. . 0-15 population increase, projected at 20% and
75+ population increase projected to increased by 100%
between 2014 and 2039. 
Risk event 
Failure to resource and plan for these rises will significantly
impact the Councils ability to fulfil its statutory obligations in
Head of Adult and
Social Care;
Director of
Education; Chief
Executive;
Executive
Director Place;
Joan Tranent
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 
4 4 
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20
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
infrastructure including GP services. Increased pressure on
infrastructure, services e.g. waste collection and growth of
road network as new development roads are adopted.  
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.                
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.16.0
1 Capital Programme
Q3 22/23: Capital Plan prioritisation also includes Learning Estate Strategy expanded to
meet statutory requirements.
Q2 22/23: Latest roll projections indicate that that we will breach capacity in some schools
in Aug 2023. Capital programme updated based on outcome of review of Learning Estate
Strategy underway  
Director of
Education;
Executive Director
Place
31-Aug-2023 
SRP.RA.16.0
2 Capital Plan reprioritisation
Q3 22/23: In light of rising costs through inflationary impacts, EU Exit and post pandemic
economic shifts, work is ongoing to review the current capital plan and reprioritise the
programme. This will be reported to Council in Q4 22/23 for review and approval.  
Executive Director
Place, Executive
Director Children,
Young People and
Partnerships,
Chief Finance
Officer, Head of
Development
31-Mar-2023 
SRP.RR.17 UK Decision to leave the EU 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
01 – Risk and Resilience Group 
02 – Taking a risk management approach to identifying and assessing
anticipated impacts 
03 – Working with a range of national and local bodies to inform
preparatory arrangements. 
04 – 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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21
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 Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships              
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.17.0
1 Refresh of Economic Strategy Q2 22/23: Report recommendations agreed by Council in Oct 2022. Work is now
underway to refresh the Economic Strategy by March 2023   Chief Officer Place 31-Mar-2023 
SRP.RR.19 Health & Safety 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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 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
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships;
Protective
1 - Health Safety and Wellbeing Strategy 
2 - Suite of Health and Safety Management Arrangements developed
setting out council response to statutory obligations (Revised 2021) 
3 - Comprehensive range of Health & Safety Management &
Assessment based development opportunities for line managers 
4 - Use of Health & Safety Management Information System to
enhance information transfer and organisational efficiency 
5 - Comprehensive training programme in place to support those with
responsibility for managing health and safety. 
6 - Guidance and Risk assessment templates to support COVID 19
response. 
7 - Use of comprehensive audit programme to confirm the application
of agreed management Arrangements and Council Policy. 
8 - New risk assessment guidance and support for managers rapidly
deployed in response to COVID 19 in line with associated Scottish
Government guidance.  
3 5 
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22
individuals through Corporate Homicide (Corporate
Manslaughter) Significant financial penalties from Criminal
Prosecution.  
Services Senior
Manager; Health,
Safety and
Resilience
Manager              
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.19.0
1 Delivery of Health, Safety and Wellbeing Strategy
Q3 22/23: Health, Safety and Resilience Manager started 9 January 2023.
Q2 22/23: Appointment made for Team Manager Health, Safety & Resilience. Due to take
up post in Jan 2023.  
Chief Officer
Place; Edel Ryan 31-Mar-2023 
SRP.RA.19.0
7 H&S audit across all Council estate
Q3 22/23: Zurich rolling out training across the Council 
Q2 22/23: Protective Services and Property Service are progressing a Health and Safety
building audit across the full Council estate, which will inform the development of
associated action plans taking a risk based assessment of the findings. Asbestos
inspection programme commenced with first round of inspections focussed on the learning
estate over the summer holiday period. Review of arrangements for first aid and fire
warden provision commenced.   
Chief Officer Place 31-March-
2023 
SRP.RR.20 Early Years Expansion (1140 Hours) 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.20
Risk cause
Population growth in Midlothian over the next 10 - 15 years
will see Midlothian become the fastest growing Council in
Scotland. . 0-15 population increase, projected at 20% in
addition the Scottish Government has made a commitment
to increase the current provision of free early years care
from 600 to 1140 hours. 
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. 
The sustainable rate review may lead to significant
increase in funding to providers; maintaining current rate is
not an option if not deemed sustainable. The result could
lead to a funding gap in future years. 
Risk effect 
Inadequate capacity within the school estate and/or Early
Chief Executive;
Executive
Director Place;
Executive
Director Children,
Young People
and Partnerships;
Chief Finance
Officer
1. Learning Estate Strategy 
2. Early Years Expansion to 1140 hours updates 
3. Capital Strategy 
4. School Roll Projections will be reviewed and updated 
5. Business Support and Finance Business Partners reviewing external
funding landscape closely for future funding options  
4 5 
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23
Years to cope with the projected increase in numbers. Lack
of staffing and/or financial support to build new schools
Potential for additional unfunded request to place 4 year
olds with August to December birthdays requesting
additional year of 1140 hours, not currently funded by
Scottish Government.                
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RR.20.0
1 1140 future years funding
Q3 22/23: No change – awaiting outcome of funding position
Q2 22/23: Potential increased costs associated with paying a sustainable rate to partner
providers may place further pressure on containing service delivery costs within available
funding. Scottish Government funding for 2023/24 will be known during Q3.   
Executive Director
Children, Young
People and
Partnerships,
Chief Officer
Corporate
Solutions; Chief
Finance Officer
31-Mar-2023 
SRP.RR.21 Cyber Security 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.RR.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.  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
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. Employing an Information Governance and Security Lead 
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 
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24
and Partnerships,
Head of
Development,
Senior Manager
Protective
Services, Health,
Safety &
Resilience
Manager
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.21.1 Appropriate Technical and Organisational Measures
Q3 22/23: Action/mitigation includes:- 
1. Appointment of Cyber Security Analyst to support the Cyber Lead 
2. On-going phishing exercise on staff and the purchasing of new cyber security training
software 
3. The implementation of new software to scan for security vulnerabilities. Establishing
new password security protection software  
Chief Digital
Officer; Cyber
Security,
Information
Governance and
Compliance
Manager
31-Mar-2023
SRP.IR.12 Cost of Living Crisis
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.IR.12
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 (gas, electricity and
fuel) 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
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care
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  
3 5
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25
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.RA.12.1 Cost of Living Task Force
Q3 22/23: Establishment of Warm and Welcoming Hubs in Lasswade and Newbattle
libraries for the winter
Q2 22/23: The Council agreed to establish a Cost of Living Crisis Task Force at its
meeting on 28 June 2022 and is now meeting fortnightly. Membership is drawn across
CMT, cross party member representation and NHS.  
Chief Executive 31 March
2023 
SRP.RA.12.2 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 March
2023 
Strategic Opportunities 
SRP.OP.01 Shawfair 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.OP.01 The delivery of a new sustainable low carbon community at
Shawfair.  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Senior Manager
Planning,
Sustainable
Growth and
Investment
1. Shawfair Landowners Group meets quarterly. 
2. Legal agreement with developers to secure developer contributions
(Section 75) towards infrastructure. 
3. Approved masterplan and design guide for the entire community 
4. Business and industrial provision, including small business incubator
space. 
5. Circa 4000 new homes 
6. A school campus comprising Early Years, Nursery, Primary,
Secondary & Life Long Learning provision 
7. New Primary schools 
8. Public Transport infrastructure including railway station. 
9. Midlothian Energy Ltd (Joint Venture between MLC and Vattenfall)  
5 4 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
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26 
SRP.OP.02 Borders Rail 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.OP.02
Passenger numbers after three years of operation are
above projections. The railway has been, and continues to
be a catalyst for economic development, access to training
and labour markets, tourism growth, environmental
improvements must notably in town centres, and access to
the countryside.  
Chief Executive,
Executive
Director Place,
Chief Officer
Place
1. Monitored by Economic Development. 
2. Maximising the Impact: A blueprint for the Future - published by the
blueprint group involving Scottish Government, Scottish Borders,
Midlothian and City of Edinburgh Council, Transport Scotland, Scottish
Enterprise and Visit Scotland. The document sets out the ambitions of
the partners to realise the full potential of the new Railway. 
3. Timely submission of bids for approval by the Blueprint Group 
4. Close monitoring of approved funded projects. 
5. Borders rail subgroup chaired by Midlothian Council Chief
Executive.  
5 4 
Related
Action Code Related Action Related action latest note Managed By Due Date Status         
SRP.OP.03 Easter Bush - Penicuik 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.OP.03
One of Midlothian’s largest and most significant
employment areas. Fast Growing opportunities in Science
Technology Engineering and Mathematics (STEM) with
opportunities to link with education. Partnership links to
schools and university sector at the 'Bush' to promote
STEM. 
Need to secure long-term strategic road access to ensure
continued growth.  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of
Development
1. Planning in place around creating Secondary Schools as centres for
excellence linked to specialisms including Science Technology
Engineering and Mathematics (STEM). 
2. Land allocated for expansion. 
3. Midlothian Science Zone. 
4. City Deal funding to provide for growth and strategic road access.  
5 4 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.OP.03.A
2 A701/A702 Trunk Road Improvements Q3 22/23: Escalating costs of this project has resulted in a significant funding gap which
requires to be addressed in order for the project to proceed. MLC has submitted an 
31- March -
2023 
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27
application to the Levelling Up Fund to address this gap. Progress report to Council on 28
June – STAG Appraisal (stage 2) complete. Report highlighted that cost inflation and
increased project costs as outstanding areas of concern. Feedback from Government is
that outcome of the Levelling Up application should be known in Q4 2022/23- awaiting
update.
SRP.OP.04 City Deal 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.OP.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.  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
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.OP.04.0
2 Realisation of outcomes of respective work streams 
Q3 22/23: Midlothian has now completed its year as chair. Work continues on the relevant
programmes.
Q2 22/23: For the 2022 calendar year Midlothian is the chair of the CRD programme
(annual rotation across the six Local Authorities).  
Executive Director
Place 31-Mar-2023 
SRP.OP.05 Growing Council 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
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28
Evaluation
SRP.OP.05
Midlothian Council has been identified as the fastest
growing Council’s in Scotland. This brings the opportunity
to support the Council vision of being ‘A Great Place to
Grow’. As a growing Council this brings the opportunity to
redevelop parts of Midlothian, improve infrastructure with a
focus on area targeting, improving economic opportunities,
improving education and health outcome. 
This growth creates the opportunity to meet the housing
need with 25% of new homes being built in the affordable
housing bracket, in addition to the expansion in Council
House building. This construction will directly support
employment in construction and will see a steady increase
in the volume of Council tax received over time.  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships, 
1. Community Planning Partnership 
2. The Single Midlothian Plan 
3. Strategic Housing Investment Plan (SHIP)  
5 5 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.RA.16.0
1 Capital Programme
Q3 22/23: Capital Plan prioritisation also includes Learning Estate Strategy expanded to
meet statutory requirements.
Q2 22/23: Latest roll projections indicate that that we will breach capacity in some schools
in Aug 2023. Capital programme updated based on outcome of review of Learning Estate
Strategy underway  
Director of
Education;
Executive Director
Place
31-Aug-2023 
SRP.RA.16.0
2 Capital Plan reprioritisation
Q3 22/23: In light of rising costs through inflationary impacts, EU Exit and post pandemic
economic shifts, work is ongoing to review the current capital plan and reprioritise the
programme. This will be reported to Council in Q4 22/23 for review and approval.  
Executive Director
Place, Executive
Director Children,
Young People and
Partnerships,
Chief Finance
Officer, Head of
Development
31-Mar-2023 
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29
SRP.OP.07 Creating a world Class Education System 
Risk Code Risk Identification Managed by Risk Control Measures Likelihood Impact Risk
Evaluation
SRP.OP.07
The Centres of Excellence model is a core part of the
Council's strategy to create a world-class education system
in Midlothian. This is an ambitious project designed to
deliver excellence and equity with a particular emphasis on
interrupting the cycle of poverty. 
Risk event:
The Phase 2 Equipped for Learning plan has a strong
focus on transforming classroom practice and learner
outcomes. This can only be achieved if effective technical
support for EfL is in place to support this change. 
Programme is at risk of succeeding due to escalating
inflation costs and resultant pressure on the overall capital
plan budget, as well as resourcing to deliver Learning
Estate programme.  
Risk Effect: 
Without the technical support and appropriate infrastructure
we will not achieve the change resulting in a negative
impact on learners experiences and outcomes  
Chief Executive,
Executive
Director Children,
Young People
and Partnerships,
Executive
Director Place,
Director Health
and Social Care,
Head of Adult and
Social Care;
Chief Officer
Corporate
Solutions; 
Chief Finance
Officer, Chief
Officer Place,
Chief Operating
Officer Education,
Chief Officer
Young People
and Partnerships,
Head of
Development 
1. Digital Centre of Excellence at Newbattle Community High School 
2. Partnership agreement with the University of Edinburgh 
3. Beeslack Replacement High School, pilot project for next round of
SFT funding – funding model building in energy efficiency targets 
4. Accelerating our ambition – Digital Strategy 
5. Review of Digital team to support Digital Centre for Excellence  
4 5 
Related
Action Code Related Action Related action latest note Managed By Due Date Status
SRP.OP.A.07
.01 Research and development
Q2 22/23: CIVTECH research project progressing well in partnership with University of
Edinburgh and SFT. Ongoing dialogue with the University of Edinburgh and Edinburgh
College in relation to the new centre of excellence.  
Executive Director
Children, Young
People and
Partnerships
31-Aug-2023 
SRP.OP.A.07
.03 Equipped for Learning
Q3 22/23: Appointment made for Google Administrator and commenced 4 Jan 2023.
Q2 22/23: Recruitment has commenced for the Google Administrator post which will
provide additional capability and enhance the programme delivery  
Executive Director
Children, Young
People and
Partnerships
31-Dec-2022 
Page 157 of 196

Page 158

Page 158 of 196

Page 159

Audit Committee
Tuesday 7 February 2023
Item 5.5 
Scotland’s Public Finances: Challenges and Risks 
Report by David Gladwin, Acting Chief Financial Officer 
Report for Information 
1 Recommendations 
Audit Committee is recommended to:
• Consider the Audit Scotland report; and
• Note that the key messages have been considered by Council
Officers and are embedded in the Medium Term Financial
Strategy Report considered by Council on Tuesday 31st January
and also the quarter 3 suite of financial governance reports to be
presented to Council on Tuesday 21st February. 
2 Purpose of Report / Executive Summary 
The purpose of this report is to provide Audit Committee with a
summary of the Scotland’s Public Finance: challenges and risks report
published by Audit Scotland in November 2022 and is appended to this
report. 
Three main messages come from the report covering rising costs and
increasing demand, limitations on Scottish Government’s ability to
manoeuver in balancing their 22/23 and 23/24 budgets and
commentary on the pace and scale of reform required across the public
sector. 
Date Thursday 26 January 2023 
Report Contact:
David Gladwin, Acting Chief Financial Officer
David.Gladwin@midlothian.gov.uk 
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Page 160

2 
3 Background 
3.1 Audit Scotland is a statutory body established in April 2020, under the
Public Finance and Accountability (Scotland) Act 2000. It provides
services to the Auditor General for Scotland and the Accounts
Commission for Scotland. 
3.2 Audit Scotland has prepared the attached report ‘Scotland’s public
finances – challenges and risks’ (Appendix B) for the Auditor General
for Scotland. The Auditor General appoints auditors to Scotland’s
central government and NHS bodies; examines how public bodies
spend money; helps them to manage their finances to the highest
standards; and checks whether they achieve value for money. 
3.3  The report sets out the challenges and risks that affect the current
financial position (up to the point of issue), the significant financial
pressure that public finances are under and information on how the
Scottish Government aim to tackle these in its resource spending
review. 
Key Messages 
3.4 Rising costs and increasing demands mean that the Scottish
Government has to closely and carefully manage its position, to avoid
the real risk that it will overspend on the 2022/23 budget. Whilst cost
and inflation pressures are well documented for all areas of the public
sector and beyond the main concern highlighted is the risk that an in-
year 2022/23 overspend on the Scottish Government budget would
have on 2023/24. 
3.5 Recognition of the restrictive position that the Scottish Government find
themselves in to balance their 2022/23 budget due to limited areas of
flexibilities that remain available. 
3.6 The pace and scale of reform across the public sector needs to
increase. A gap exists between ambition and delivery which must
narrow but also which must be resourced and delivered in a
sustainable way. 
4 Report Implications (Resource, Digital and Risk) 
4.1 Resource 
None 
4.2 Digital 
None 
4.3 Risk 
None 
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3
4.4 Ensuring Equalities (if required a separate IIA must be completed) 
None 
4.4 Additional Report Implications (See Appendix A) 
See Appendix A 
Appendices 
Appendix A – Additional Report Implications
Appendix B – Scotland’s public finances – challenges and risks 
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4
APPENDIX A – Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Not applicable 
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 
Not applicable 
A.5 Involving Communities and Other Stakeholders 
Not applicable 
A.6 Impact on Performance and Outcomes 
Not applicable 
A.7 Adopting a Preventative Approach 
Not applicable 
A.8 Supporting Sustainable Development 
Not applicable 
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Page 163

5 
APPENDIX B 
Scotland’s public finances – challenges and risks 
Page 163 of 196

Page 164

Page 164 of 196

Page 165

Briefing
Scotland’s public
finances
Challenges and risks
Prepared by Audit Scotland
November 2022
Appendix B
Page 165 of 196

Page 166

Scotland’s public finances: Challenges and risks | 2 
Contents 
Introduction 3
Key messages 4
The cost of living crisis adds to the pressures on the 
Scottish budget 5
The Scottish Government faces tough choices for the 
2022/23 and 2023/24 budgets 9
Reforms to public services are now required 17
Conclusion 25
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Page 167

Introduction | 3
Introduction
1. The pressures placed on Scottish public finances have been significant and
varied for several years. The level of funding available to the Scottish
Government has fluctuated, falling in real terms between 2010/11 and 2017/18
but steadily increasing since.1 The response to the Covid-19 pandemic saw
further, significant increases to the Scottish budget but this funding was
temporary and has now come to an end.
2. The Scottish public sector has had to adapt to these changes in funding
levels alongside managing increasing demand for services and external events
such as the Covid-19 and cost of living crises. These challenges continue to
grow, with real-life implications for people in Scotland.
3. The re-opening of economies following Covid-19 led to inflation across the
world because of growing demand, labour shortages and increased transport
costs. The war in Ukraine has increased energy prices.2 Inflation is outstripping
any increases that people are seeing to wages or benefits, and real earnings fell
at the fastest rate since records began between April and June.3
The rising cost of living is described as a ‘cost of living crisis’
4. According to the Office for National Statistics, 87 per cent of adults in the UK
reported an increase in their cost of living in August-September 2022.4
Businesses, the third sector and the public sector also face higher operating
costs, including higher labour costs as wages rise in response to inflation.
In this paper, when we talk about the cost of living crisis, or the cost crisis, we
mean all these pressures across the economy that are caused by rising prices.
5. The Scottish Government has said that it faces ‘significant financial
challenges’ because of the cost crisis,5 as it supports individuals and
businesses affected by rising prices, at the same time as inflation means its
funding buys less than was expected when the budget was set in December.
6. This paper focuses on the pressures facing the Scottish budget this financial
year and in the medium term, and the implications this has for public services.
It intends to inform and support scrutiny of proposed spending and tax plans in
the current context, and emphasise the need for reform to public services.
1 Institute for Fiscal Studies, How and why has the Scottish Government’s funding changed in
recent years?, March 2021
2 Institute for Fiscal Studies, The Cost of Living Crisis, accessed August 2022
3 BBC, Inflation drives fastest fall in real pay on record, August 2022
4 ONS, Public opinions and social trends, Great Britain, 30 September 2022
5 Deputy First Minister, Letter to the Finance and Public Administration Committee,
September 2022
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Page 168

Key messages | 4 
Key messages
Scotland’s public finances: challenges and risks
• Rising costs and increasing demands mean that the Scottish
Government has to closely and carefully manage its position, to avoid
the real risk that it will overspend on the 2022/23 budget. There have
been significant financial pressures on public services for some time before
the cost of living crisis. The current high level of inflation means that the
Scottish Government faces higher public-sector pay and other costs, at the
same time as it faces increasing demand for support from people impacted
by the crisis. The budget was set when inflation was lower, and the
Scottish Government is unlikely to receive additional funding to address
this issue in the near future. 
If the Scottish Government were to overspend against its budget, this
money could be clawed back from the following year’s budget. This would
be the first such occasion since the creation of the Scottish Parliament.
• The Scottish Government has limited room for manoeuvre to make
changes to balance the 2022/23 budget, and will face difficult choices
setting the 2023/24 budget. Within the year, much of the Scottish budget
is committed, which means that there is limited flexibility available to the
Scottish Government in the short term. Setting the 2023/24 budget will be
challenging, and the UK Government’s spending and tax decisions will
impact on this. A balance must be struck between short-term necessities
and longer-term priorities, and the Scottish Government will need to revisit
its priorities if the economic and fiscal conditions worsen.
• The pace and scale of reform required across the public sector needs
to increase. While the Scottish Government must continue to react to
immediate events and financial pressures, this must not distract from the
immediate need for broader reform. The Scottish Government’s Resource
Spending Review sets out its planned reforms and next steps. In the past,
the Auditor General has highlighted an implementation gap between the
Scottish Government’s ambitions for reform and delivery on the ground.
It is vital that these reforms are delivered effectively, and with public
engagement, to deliver sustainable services that improve
people’s outcomes.
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Page 169

The cost of living crisis adds to the pressures on the Scottish budget | 5 
The cost of living crisis adds to
the pressures on the Scottish
budget 
Sustainability pressures on Scotland’s public finances pre-date
the current cost crisis and the Covid-19 pandemic, and have
worsened because of them 
7. Significant risks to the financial sustainability of public services in Scotland
are not new:
• In 2018, the Auditor General first stated that the NHS was not in a
financially sustainable position.6 NHS boards were increasingly reliant
on additional financial support from the Scottish Government or
non-recurring savings to break even.
• The Accounts Commission has also highlighted for some years that
councils in Scotland are also facing financial sustainability pressures.
In the Local Government Overview published in June 2020, the
Accounts Commission highlighted that councils making continued use
of reserves to manage the funding gap was unsustainable.7
8. The long-term financial and operational effects of Covid-19 are still being felt.
The pandemic has had a range of indirect and direct health and societal
impacts, such as backlogs in NHS treatments and court cases. 
9. No additional separate funding was provided by the UK Government for
Covid-19 in 2022/23, although the overall Scottish budget has grown in
comparison to pre-pandemic levels. The extra pressures caused by the
pandemic are being funded through the core Scottish budget, placing more
pressure on Scottish public finances. 
The Scottish Government must meet any additional spending
above UK measures from its existing budget
10. The current high levels of inflation bring further uncertainty and volatility to
UK and Scottish government budgets. During the Covid-19 pandemic, the
UK Government response included both direct support for individuals and
businesses (for example, the furlough scheme) and also increased
departmental spending, which led to increased funding for the Scottish 
6 Audit Scotland, NHS in Scotland 2018, October 2018
7 Accounts Commission, Local government in Scotland: Overview 2020, June 2020
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Page 170

The cost of living crisis adds to the pressures on the Scottish budget | 6 
Government. As set out in Scotland’s financial response to Covid-19, the
UK Government provided the majority of funding for the Scottish Government’s
£15.5 billion spending response to the pandemic in 2020/21 and 2021/22. 
11. To date, the main financial responses to the cost crisis have been in
reserved rather than devolved areas, which do not directly impact the Scottish
budget. To help manage energy costs, the UK Government has announced the
Energy Price Guarantee (for households) and the Energy Bill Relief Scheme
(for non-domestic customers). Both these schemes were expected to cost
£60 billion in 2022/23 across the UK when they were announced.8 
12. Funding from the UK Government provided through the block grant is the
main source of funding for the Scottish budget. This gives Scotland a proportion
of the amount that the UK Government allocates to its departments for spending
on devolved issues (such as health and education). The block grant only
changes in response to UK Government decisions, and is not automatically
uprated for inflation. 
13. The UK Government has not changed its departmental spending this year
to account for the higher costs facing the public sector, meaning that if the
Scottish Government wishes to spend more money to support individuals and
business through the cost of living crisis, this must be funded from the existing
Scottish budget, rather than through additional Barnett consequentials.
14. Increased inflation means the public pound buys less than was expected
when the budget was set. As part of the Programme for Government, the First
Minister highlighted that because of inflation, the Scottish 2022/23 budget is
worth £1.7 billion less than it was when it was set in December.9 
15. The Comprehensive Spending Review (CSR) sets out the UK
Government’s intended spending over the medium term and was announced
when forecasts for inflation were much lower. The CSR projected 3.3 per cent
real-terms growth in its departmental resource budgets between 2021/22 and
2024/25. In August 2022, the Institute for Fiscal Studies estimated that the real
terms growth in spending over that period has now dropped to 1.9 per cent.10
Any increased costs must be met through the original spending envelope given
to UK Government departments – and consequently, that given to the Scottish
Government. 
16. The UK Government as announced that it will deliver an Autumn Statement
on 17 November. This will contain important information for the Scottish
Government to consider as it sets its 2023/24 budget. 
8 UK Government, The Growth Plan, September 2022
9 Scottish Government, Programme for Government 2022-2023: First Minister’s speech,
6 September 2022
10 Institute for Fiscal Studies, The inflation squeeze on public services, 10 August 2022. This is
based on levels of inflation for the GDP deflator as opposed to the Consumer Price Index.
Please see the article for more information.
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The cost of living crisis adds to the pressures on the Scottish budget | 7 
The Scottish Government must manage the increased costs of
running the public sector on an ongoing basis
17. Although inflation is not forecast to stay high over the long term,11 the like-
for-like increased costs are locked in for future budgets, and will not fall back to
their previous levels. As a result, the Scottish Government must manage these
higher unit costs permanently, or change the way it operates. Examples of the
rising costs the Scottish Government faces are set out in Exhibit 1. 
Exhibit 1
Examples of cost pressures on the public sector 
The enhanced pay offers that have been made to date total over £700 million.12
Agreement has yet to be reached with unions in some key areas of the public sector. 
Electricity costs through the National Framework Agreement have increased by
27.5 per cent over the last year. 
Gas prices through the National Framework Agreement have increased by 197 per cent
over the last year.13 
Food costs are estimated to increase by five per cent over the next year. Councils
currently spend around £86 million on food each year.14 
The costs of capital projects are also increasing, with councils reporting increases of
around 30 per cent on anticipated costs.15 This is likely to be reflected more widely
across the public sector. 
Source: Audit Scotland
18. Wages are the most significant of these costs, accounting for over
£22 billion across the devolved public sector (including local government).16
The Scottish Government pay policy set in December 2021 reflected inflation of
3.1 per cent,17 but by the time of the next Medium-term Financial Strategy in
May, this had increased to nine per cent.18 
11 Bank of England, Monetary Policy Report, August 2022
12 Deputy First Minister, Letter to the Finance and Public Administration Committee,
September 2022
13 Scottish Parliament Written Answer, S6W-07596, March 2022 
14 COSLA/SOLACE/CIPFA Directors of Finance Section, Finance and Public Administration
Committee consultation response, August 2022
15 COSLA/SOLACE/CIPFA Directors of Finance Section, Finance and Public Administration
Committee consultation response, August 2022
16 Scottish Government, Scotland’s Fiscal Outlook, May 2022
17 Scottish Government, Scotland’s Fiscal Outlook, December 2021. This is CPI inflation.
18 Scottish Government, Scotland’s Fiscal Outlook, May 2022
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The cost of living crisis adds to the pressures on the Scottish budget | 8 
19. Public-sector trade unions have called for pay rises that match inflation.19
The Scottish Government, local government, and trade unions agreed a deal
over the summer. Funding for any future pay deals will need to be found from
the 2022/23 budget. 
The costs of supporting people through the crisis have
increased
20. Social security spending is a key channel through which the Scottish
Government provides support to individuals, and in 2022/23 accounts for
approximately ten per cent of the Scottish Government budget.20 The Scottish
Fiscal Commission (SFC) forecast that higher inflation will increase social
security spending by £156 million in 2023/24 and by £213 million in 2026/27,
compared to their forecast in December 2021.21 Social security spending is
forecast to rise from £5,072 million in 2023/24 to £6,490 million in 2026/27. 
21. The Scottish Child Payment (SCP) will also be increased from £20
per week to £25 when it is rolled out to households with children aged 6–15
in November 2022. From 2024/25 onwards the benefit is forecast to cost around
£25 million more than forecast in May 2022, because of higher inflation.22
22. It is not clear if the current environment will lead to more people being
eligible and applying for benefits. In their latest SCP costing from September,
the SFC has not changed its assumption of the number of families receiving
qualifying benefits or the underlying forecasts of unemployment. These will be
updated in the SFC’s next forecasts which will be published to accompany the
Scottish Government’s 2023/24 budget announcement. This could mean further
cost pressures if the economic position were to worsen as social security
spending is demand-led and needs-based.
23. The Scottish Government has also announced other new support in
response to the cost of living crisis, including an extra £21.75 million to provide
free school meals to eligible children over the school holidays23 and the
expansion of home energy schemes, including £161 million for the Warmer
Homes Scotland scheme, Area Based schemes, and Home Energy Scotland.24
The Scottish Government has also committed to doubling the quarterly bridging
that will be paid in December to children and young people in receipt of free
school meals.25 
19 STUC, Scotland Demands a Pay Rise, 2022
20 The Scottish Fiscal Commission, Scotland’s Economic and Fiscal Forecasts, May 2022
21 The Scottish Fiscal Commission, Scotland’s Economic and Fiscal Forecasts, Figure 5.11,
May 2022
22 The Scottish Fiscal Commission, Supplementary Costing – Scottish Child Payment,
September 2022
23 Scottish Government, Summer support for children, July 2022
24 Scottish Government, Cost of living support, July 2022
25 Scottish Government, Extra winter cash for children and young people in receipt of free
school meals, October 2022
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The Scottish Government faces
tough choices for the 2022/23
and 2023/24 budgets 
Without very close management of the budget, there is a real
risk the Scottish Government overspends against its 2022/23
budget
24. The Scottish Government has reported balanced budgets since devolution
was introduced in 1999. Early in 2022/23, the Scottish Government was
forecasting a significant budget gap for the financial year, which was larger than
could be managed through its usual budget processes. The Scottish
Government identified the need for more substantial changes to spending,
which were announced through the Emergency Budget Review process.
The fiscal environment continues to be uncertain, and the Scottish Government
must closely manage its budget for the rest of the financial year. 
25. The Scottish Government has recognised that the financial situation it faces
is by far the most challenging since devolution. An overspend on the budget
would be a new development for Scottish public finances. The potential
consequences and how this would take shape are unclear at this stage. Our
understanding is that HM Treasury rules mean that any overspend against the
2022/23 budget would be deducted from the following year’s block grant.26
This would mean that there is less funding available for spending on next year’s
budget, exacerbating existing pressures on future public spending. 
26. As set out in the fiscal framework, the Scottish Government can borrow to
cover a temporary cash shortfall in year. Borrowing powers available to the
Scottish Government are limited, and those available for resource borrowing
must be paid back over three to five years. Ultimately, the Scottish
Government’s finances will not be sustainable if its spending commitments
cannot be met by its funding and its tax raising powers. 
26 HM Treasury, Statement of Funding Policy, October 2021
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Savings have already been found from the 2022/23 budget
27. In September, the Scottish Government has announced £560 million of
additional income and savings to the 2022/23 budget to fund the increased cost
of public sector pay deals.27 In November, a further £615 million of savings were
identified through the Emergency Budget Review process, the majority
(£400 million) of which were changes within the health portfolio to support the
proposed pay offer.28 
28. At just under £1.2 billion, these changes include nearly £200 million of
income and funding not expected at the time the budget was set and of the
remainder, £300 million relates to capital changes, and £700 million relates to
day to day spending. 
29. The details of these changes are set out below, and in Exhibit 2 (page 11):
• Changes to capital: This includes deferral and reprofiling of capital
spending, as well as some changes as result of reduced demand. An
example includes £120 million of capital reprioritisation identified from
multiple portfolios and transferred to local government to increase their
overall resources available to support the local government pay offer. 
• Deferral of funding: spending can be delayed into future years’
budgets. For example, ring-fenced UK funding has been deferred for
the Rural Affairs and Islands portfolios, and £70 million of Social Care
and National Care Service (NCS) spending has been re-profiled.
• Increased income and additional consequential funding: additional
funding has been applied to cover increased costs. For example, in
September the Scottish Government applied £56 million of funding
generated by the ScotWind clearance process to the 2022/23 budget,
and has received an additional £82 million in Barnett consequentials.
• Demand changes: Where demand is less than expected, underspends
are redeployed. Examples include a cut of £37 million in funding for
concessionary fares, a £20 million reduction in further education student
support, based on a forecast reduction in demand, and a reduction in
justice spending based on a lower than anticipated requirement for
services within the justice system as it recovers from backlogs.
The Scottish Government notes that this does not impact on
service delivery.
• Reduced spending: this includes a reduction of £53 million in funding
for employability schemes, and £38 million of mental health spending
that has been reprioritised to support the NHS pay offer. 
27 Deputy First Minister, Letter to the Finance and Public Administration Committee,
7 September 2022
28 Scottish Government, Emergency Budget Review 2022/23, 2 November 2022
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• Recruitment controls: restrictions in hiring across a range of public
bodies.
• Resource to capital switches: resource spending is being replaced by
capital spending, for example, within the Education and Skills portfolio
for Gaelic support. 
30. The EBR notes that as a result of the ongoing uncertainty, there remains a
risk to balancing the 2022/23 budget.29 
Exhibit 2
Breakdown of types of savings and reductions included in 2022/23 savings
announced to date
Source: Scottish Government, Audit Scotland analysis. September changes come from the
Deputy First Minister’s letter to the Finance and Public Administration Committee, dated
7 September, and the November changes come from the Emergency Budget Review. 
The Scottish Government has tools available to manage its
budget, but its options are limited
31. The Scottish Government’s options – its ability to flex its budget in response
to events – comes from multiple sources, as set out in the following paragraphs. 
29 Scottish Government, Emergency Budget Review 2022/23, 2 November 2022 
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Fiscal framework tools and powers
32. The Fiscal Framework agreed between the Scottish and UK governments in
2015 includes levers that the Scottish Government can use to manage volatility
in its budget. However, these were largely designed to address volatility that
arises from forecasting error and were not designed to help balance the budget. 
33. The Scotland Reserve is used to manage spending across years. In his
letter to the Finance and Public Administration Committee, the Deputy First
Minister confirmed that all the available funds from the reserve have been
allocated to support spending in the 2022/23 budget.30 As highlighted in
Scotland’s new financial powers: Operation of the Fiscal Framework 2018/19,
when the Government plans to use the Scotland Reserve to carry forward
significant amounts of budget and spending power from one financial year to
the next, this will limit the extent to which the reserve is able to operate as a
buffer against budget pressures, and this money can only be spent once. 
34. The fiscal framework also included borrowing powers. As set out in
paragraph 25, the in-year cash management borrowing powers can only be
used to fund a temporary shortfall in cash flow or working capital, and do not
enable the Scottish Government to spend beyond the funding as set in the
budget.31
35. The Scottish Government also has capital borrowing powers. While capital
borrowing cannot be used to support revenue spending, in the wider public
sector (for example, local government) certain types of capital spending could
be moved to resource spending. For example, during the Covid-19 pandemic,
the Scottish Government identified a package of financial flexibilities for
councils, including permitting the use of capital receipts received to fund 
day-to-day costs.32 In such a scenario, the Scottish Government could use its
capital borrowing powers to offset this, and to restore capital funding available.
This would need to be done in line with HM Treasury’s Consolidated
Budgeting Guidance. 
36. Taxes are another source of funding for the Scottish Government budget,
and higher inflation can lead to higher tax takes as prices or wages grow faster
than tax thresholds. However, Scotland’s tax revenues will not change
significantly for the rest of 2022/23, because the contribution that Scottish
Income Tax, (which accounts for 94 per cent of Scotland’s tax revenues)33
makes to the 2022/23 budget was fixed in cash terms when the budget was
agreed. The income tax policy for 2023/24 will be announced alongside the
budget in December. 
30 Deputy First Minister, Letter to the Finance and Public Administration Committee,
7 September 2022
31 For more information, see Audit Scotland, Operation of the Fiscal Framework, October 2018
32 Scottish Government, Local Government Finance Circular No 2/2021, February 2021
33 This is the share of Scottish Income Tax, Land and Building Transaction Tax and Scottish
Landfill Tax. It does not include Non-domestic Rates revenues.
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Controllable and non-controllable costs
37. Reducing budgets in an unmanaged way can have significant impacts on
the quality of services provided, how accessible services are, and on people’s
long-term outcomes. The Scottish Government and other public bodies will
need to understand well in advance what constraints there are to their
flexibilities to cut spending. Examples include statutory services and duties that
must be provided by law (for example, statutory targets for net zero
commitments), the Scottish Government’s human rights duties, and
commitments such as no compulsory redundancies. 
38. In addition, in the short term, much of the budget is fixed and committed,
and there are limits to what can be changed without significant disruption. Much
of the public spending incorporated in the Scottish budget is for areas such as
staff costs that are difficult to change quickly. 
39. The Scottish Government will need to understand where it is most able to
quickly alter spending, and understand what options are available to it in
responding to budget fluctuations. Public bodies are also likely to be required to
budget more flexibly as a result. For example, to fund the local government pay
deal agreed in August, the Scottish Government allowed councils to take some
funding that had previously been ringfenced for another use and use this to
cover the cost of the pay agreement. 
40. In the medium to long term, fewer costs are fixed and more can be
changed. This means there is more opportunity for reforming public services,
as discussed in more detail in section 3. 
Wider public sector flexibilities 
41. Some public bodies, such as councils and integration health and social care
authorities, also have reserves that can be used to carry funding over from one
financial year to the next. However, funding held in reserves can only be spent
once and cannot be reliably used to cover recurring costs. As highlighted in
Scotland’s financial response to Covid-19, some of the money held in council
and integration authority reserves has been earmarked for specific purposes,
such as the ongoing response to Covid-19. The Scottish Government has
requested that some funding which is currently allocated for Covid-19 in
integration authority reserves is now used for wider Covid-19 purposes. 
42. As the Auditor General has highlighted in previous section 22 reports on the
audit of the Scottish Government Consolidated Accounts,34 there remains a
need for a public consolidated account to provide a comprehensive and
transparent assessment of the state of Scotland’s public finances. This is
important for decision-making over the longer term as it will provide information
about the impact of past decisions on future budgets, the potential risks to
financial sustainability and the scale of assets and liabilities, including those
held by publicly owned companies. The report on the 2021/22 audit of the
Scottish Government Consolidated Accounts will update on this matter when it
is published later in 2022. 
34 Auditor General for Scotland, The 2020/21 audit of the Scottish Government Consolidated
Accounts, December 2021
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The Scottish Government will have to consider UK Government
policies when setting the 2023/24 budget
43. The level of funding that will be available to the 2023/24 Scottish Budget is
not yet known. There is ongoing uncertainty around UK Government policy on
spending, tax, and social security, with the Chancellor of the Exchequer stating
that ‘nothing is off the table’ in terms of changes to tax and cuts to public
spending. Changes to UK Government spending in devolved areas impacts the
size of the Scottish budget, and reductions to the budgets of public services
such as the NHS in England will reduce the funding available to the Scottish
Government. The Scottish Government will need to manage this uncertainty
when setting the 2023/24 Scottish Budget. 
44. While most of the changes to UK tax policy announced in the September
mini-budget have been reversed, the changes that had been announced to
Stamp Duty have been retained and will impact on the Scottish budget. While
the Scottish Government is responsible for setting its own equivalent to Stamp
Duty in the form of the Land and Buildings Transaction Tax (LBTT), changes to
UK Government tax policy impact the net benefit to the Scottish budget as a
result of this devolved tax. If the Scottish Government chooses to retain the
existing rates and thresholds for LBTT, then UK Government changes to Stamp
Duty would result in additional funding of approximately £65 million for the
Scottish Budget in 2023/24.35 
45. In March 2022, the UK Government announced that working age benefits
would rise in line with inflation for 2023/24. It is unclear if this is still the UK
Government’s intention.36 If the UK Government chooses not to increase
benefits to fully cover inflation this has implications for Scottish social security
spending. 
46. If the UK Government decides to uprate the reserved benefits by less than
inflation in April 2023, the devolved Scottish benefits that are administered by
the Department for Work and Pensions (DWP) may need to be updated by the
same rate. This is because of an agreement between the Scottish Government
and DWP to ensure payments are consistent while clients are transferred to
Scotland.37 
47. In addition, this means that there would be less funding available for the
benefits that are now administered by Social Security Scotland (such as Adult
Disability Payment and Child Disability Payment) because the Block Grant
Adjustment that the Scottish Government receives from the UK Government
would increase at the lower rate. There is a statutory requirement in the Social
Security Scotland Act (2018) to consider the effect of inflation and respond if 
35 Deputy First Minister, Letter to the Convener of the Finance and Public Administration
Committee, 3 October 2022
36 House of Commons Work and Pensions Committee, Letter to Chancellor of the Exchequer,
October 2022 
37 For example, please see: the Secretary of State for Work and Pensions and the Scottish
Ministers, Agency Agreement in respect of Personal Independence Payment for people
resident in Scotland, 2020
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that effect is, in the opinion of the Scottish Government, material. The Scottish
Government has not yet published its report on the effect of inflation on benefits
for 2023/24 so it is not clear what rates it will apply in 2023/24. 
The Scottish Government has been developing its approach to
managing financial sustainability risk
48. The Scottish Government recognises the issues and risks relating to the
sustainability of the public finances over the medium term, and is changing how
it manages its financial sustainability risks.
49. The Director-General Scottish Exchequer is responsible for managing the
financial sustainability risks to the Scottish Government, and the core purpose
of the Scottish Exchequer Directorate is ‘a fiscally sustainable Scotland’. The
directorate is developing its strategy for fiscal sustainability, with the goal of
balancing the 2023/24 Budget. The Scottish Government has informed us that
the work being undertaken aims to ensure there is an understanding of fiscal
risks across the whole of the Scottish Government, and an early priority of this
work is to strengthen the spending data available. 
50. In Scotland’s financial response to Covid‑19, the Auditor General and the
Accounts Commission highlighted that when the Scottish Government is
understanding spending and performance information across several portfolios,
it should consider the lessons learned from Covid-19, when the Scottish
Government had difficulties in tracking actual spending because its budget
processes were not designed to separate specific spending in areas across
portfolios.
51. It will be important that the results of the Scottish Government’s fiscal
sustainability work are transparently shown to improve scrutiny of the financial
position, and to highlight risks early.
The financial pressures faced may have implications for the
scale, range and types of public services that can be provided 
52. Worsening economic conditions will increase demand for public services.
The Scottish Government may be in the difficult position of deciding what
spending programmes and areas of government it will deliver differently, deliver
less of, and which programmes it may need to stop delivering completely. 
53. The Scottish Government set out four priority spending areas in the
Resource Spending Review (RSR) published in May:
• tackling child poverty 
• addressing the climate crisis 
• securing a stronger, fairer, greener economy 
• delivering excellent public services.38 
38 Scottish Government, Resource Spending Review, May 2022
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54. If spending in these areas is protected, then reductions and changes to
services will have to be applied to non-priority areas. In the RSR, the Scottish
Government planned real-terms decreases in spending to areas such as local
government, the police, prisons, justice, universities and rural affairs over the
spending review period. 
55. The current new financial realities mean that if the economic or fiscal
environment continues to worsen, the Scottish Government may need to revisit
all current priorities and policy commitments. Even if spending in priority areas
is protected, services may be under significant pressure due to higher
demands, especially on top of backlogs and challenges caused by Covid-19. 
The Scottish Government needs to understand how its
decisions will affect different groups
56. Recent research by the Glasgow Centre for Population Health has indicated
that there is an increasing body of UK and international evidence attributing falls
in life expectancy in the UK between 2011 and 2019 to reductions in UK
Government spending, particularly in relation to social security, during that
period.39 To minimise the negative impacts from the any future changes to
public spending on people’s outcomes, the near-term pressures on the budget
must be managed while maintaining a focus on long-term priorities.
57. This will be difficult in the current context, when it may be unavoidable that
some of the choices that need to be made will negatively impact on wider work
to improving outcomes. The more challenging the financial situation, the larger
the impact this is likely to have on people and outcomes. 
58. The Scottish Government and public bodies must understand how the
decisions they make will impact on different groups in society. In advance of the
Emergency Budget Review, several gender equality organisations wrote to the
Deputy First Minister to highlight the importance of analysing the impact that the
budget will have on women, children, and other marginalised groups.40
Alongside the Emergency Budget Review, the Scottish Government published a
summary of the evidence on equality and fairness of the Emergency Budget
Review. This considers the evidence at a high level and focuses on the most
substantial changes, but is more limited than a full Equality Impact
Assessment.41 
39 Walsh D, Wyper GMA, McCartney G, Trends in healthy life expectancy in the age of austerity,
Journal of Epidemiology and Community Health 2022
40 Engender, Gender Budget Analysis in Budgetary Reviews, letter to DFM, October 2022
41 Scottish Government, Emergency Budget Review: equality and fairness – evidence summary,
November 2022
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Reforms to public services are now required | 17 
Reforms to public services are
now required 
Failure to make the necessary changes to how public services
are delivered will likely mean further budget pressures in the
future
59. In the long term, the economic and fiscal outlook means that continuing to
make small-scale budget cuts is unfeasible. The Auditor General and the
Accounts Commission have continued to underline the importance of reforming
public services to manage the sustainability of public finances. 
60. Reforming public services means changing how services are delivered to
people in a way that more effectively meets both their needs and the
Government’s policy aspirations. Reform is most successful when it is planned
and targeted – in contrast with flat budget reductions across the board which
reduce spending across the public sector, without considering the impact on
wider ambitions.
61. The significant pressures which require immediate reform are even greater
than when medium-term plans were last set out by the Scottish Government.
The Medium-term Financial Strategy (MTFS) published in December 2021,
projected that by 2026/27 there would be a £3.5 billion gap between its central
funding and spending scenarios.42 The MTFS was then updated in May 2022
and published alongside the RSR.43 This reflected a balanced medium-term
position, where the central funding scenario and central spending scenario
align, closing the previously identified funding gap. A key part of how the
Scottish Government planned to close the funding gap was by making
necessary budgetary savings through public service reform.
62. The RSR includes reference to four main types of reform, summarised in 
Exhibit 3 (page 18). 
42 Scottish Government, Medium Term Financial Strategy, December 2021
43 Scottish Government, Medium Term Financial Strategy, May 2022
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Reforms to public services are now required | 18 
Exhibit 3
Public service reforms included in the RSR 
Type of reform Summary from RSR
New approaches to
public services
Key reforms over the course of this Parliament include:
• the establishment of the National Care Service  
• keeping the Promise (as set out following the Care Review),
including by investing £500 million in preventative spend through
the Whole Family Wellbeing Funding  
• the Vision for Justice in Scotland – the future justice system  
• Education Reform – replacing existing education bodies 
• National Strategy for Economic Transformation. 
Public sector
capacity and pay 
The RSR includes plans to: 
• from 2023/24, a broad aim to keep the total cost of the overall
annual pay bill the same as 2022/23   
• a broad aim to return the total size of the devolved public sector
workforce to around pre-Covid-19 levels by 2026/27, through
effective vacancy and recruitment management   
• continued development of the use of technology within the public
sector to support hybrid and flexible working. 
Efficiencies for the
public sector 
Recurring annual efficiencies of at least three per cent will be required
from public bodies. Planned efficiencies include:
• further use of shared services 
• management of the public sector estate (around 30,000 properties) 
• effective procurement (current levels of procurement spending stood
at £13.3 billion in 2020/21, or around a quarter of the Scottish
budget)   
• management of public sector grants.  
Reform to public
bodies
The RSR notes that there are currently 129 public bodies in Scotland,
and notes ‘reform is inevitable’. 
Source: Audit Scotland, Scottish Government
63. The cost of living crisis, and the pressures on public spending and public
services, mean that these reforms are more necessary than they were even
when the RSR was announced earlier this year. 
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In the past, delivery of the reform of public services has not
matched the original ambition 
64. Both the Auditor General and the Accounts Commission have highlighted
previously how difficult it is to reform public services, for example in their papers
on health and social care integration, Scotland’s colleges, drug and alcohol
policy, and police and fire reform. 
65. Reflecting on the progress made ten years on since the Christie
Commission, the Auditor General commented that, “concerted action has been
taken to try and implement progressive policies... But audit work consistently
shows a major implementation gap between policy ambitions and delivery on
the ground.” 44
66. For example, social care reforms aimed to offer people more choice and
control about the services they received. A 2017 progress audit on self-directed
support found that, after seven years, there was no evidence that authorities
had made a transformation in services.45
67. The recent Social care briefing sets out key learning points from past public
service reforms, including:
• realistic costs in financial memorandums accompanying parliamentary
bills for legislative change
• a comprehensive business case, clearly setting out the purpose and
objectives of reform
• evidence to support major changes and being clear about how they will
improve outcomes, options, appraisals and economic modelling
• governance, accountability, roles and responsibilities in the
new structure. 
68. These points will be more important during a period of tight budgets to
ensure reform achieves maximum value for money. Investing in good processes
and data for reform may be challenging in the current context when money and
capacity is restricted, but learning from previous reforms will help ensure
reforms deliver the expected outcomes.
69. Audit Scotland has raised concerns about the approach being taken to
some of the reforms currently planned. For example, in the recent Social care
briefing paper, the Auditor General and the Accounts Commission noted that the
proposals were not fully costed and there is much to do to establish the true
costs of reform.46 This briefing paper also noted the importance of strong,
stable, and collaborative leadership. In recent years, the Auditor General and 
44 Auditor General for Scotland, Christie’s clarion call can’t wait another decade,
September 2021
45 Auditor General for Scotland, Christie’s clarion call can’t wait another decade,
September 2021
46 Auditor General and the Accounts Commission, Social care briefing, January 2022
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Reforms to public services are now required | 20 
the Accounts Commission have reported on the leadership capacity across the
public sector, emphasising the critical need for effective leadership at a time of
increasing pressures and change. Public bodies, including councils, integration
authorities and the NHS are experiencing a high turnover in senior staff and are
competing not only with each other for the best quality leaders but also with the
private and third sectors.
70. In the face of the financial challenges, the pace and scale of reform needs
to increase, and this will require a sense of urgency from the Scottish
Government, at a time when it is also pressing to resolve short-term issues
facing the budget.
71. If this does not happen, it will become increasingly difficult for the Scottish
Government to manage the pressures on the budget, meaning that the cuts to
spending necessary to balance the budget will become larger, and the quality of
public services delivered will worsen. 
72. Following the publication of the RSR, the Scottish Government has set up a
new Public Spending Portfolio Board, to ensure the delivery of the RSR across
directorates, identify links across workstreams, and provide advice across
Scottish Government as needed. This aims to link the RSR both to the
Emergency Budget Review and to the 2023/24 budget.
73. The board has met three times since June, and is at the early stages of its
role of overseeing the implementation of the required reforms, and has focused
so far on the workstreams (such as public sector pay and the reform of public
bodies) which will feature in the 2023/24 budget. A Public Spending Analytical
Unit has also been set up to monitor public spending and support the reform
agenda.
74. To be effective, the Scottish Government’s new approaches will need to
clearly set out what reform intends to deliver, how it intends to track and monitor
both savings and other financial impacts and the impacts on outcomes, and
how these link across the public sector.  
A shift to preventative spend is essential alongside meeting
immediate challenges
75. The recent Social care briefing reflected that the Christie Commission
stated that one of the major barriers to increasing preventative spending – that
is, public spending that aims to prevent negative social outcomes from
occurring in the first place – was the extent to which resources are currently tied
up in dealing with short-term problems. The report warned that without a shift to
preventative action, increasing demand would swamp public services’ capacity
to achieve outcomes. 
76. This still holds true, over a decade later. Although it will be difficult, investing
in preventative spending will be necessary to meet some of the Scottish
Government’s core outcomes. Recently the Auditor General and the Accounts
Commission have reported on two areas where preventative spend in priority
areas may be under pressure because of the cost of living crisis:
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• The Scottish Government had significantly increased in investment in
employability support for parents to reduce child poverty. In September
2022, this spending was reduced from £81 million to £29 million as part
of the Emergency Budget Review statement.47 
• The Accounts Commission’s recent briefing on Scotland’s councils’
approach to addressing climate change reported that the cost of living
crisis could lead to climate change activity being deprioritised or
delayed by councils.48
77. In the recent Drug and alcohol services update, we highlighted that public
health prevention programmes are cost-effective in drug and alcohol services,
but it was not clear what percentage of spending in this area was targeted on
early intervention and prevention. The Auditor General noted that over the last
ten years since the Christie Commission report the focus has still been on short-
term metrics for public services.49 Preventative spend, like the reform agenda,
will stop the problems Scotland is facing now from growing over time. 
Covid-19 has shown that public bodies can change how
services are provided – and at speed
78. The Covid-19 pandemic and the lockdowns that were implemented to
reduce the spread of the virus completely changed what was possible in terms
of providing public services, at the same time as individuals and communities
needed entirely new forms of support.
79. In our work on public services’ response to the pandemic, we have
highlighted that public bodies worked well together to deliver new funding and
work in different ways. As reported in the Covid-19: Vaccination programme
briefing paper, excellent progress was made in rolling out the Covid-19
vaccination programme, and new digital tools were developed at pace to
support this. In the Local government in Scotland: Overview 2021, the Accounts
Commission noted that councils’ working practices changed at a pace and scale
‘that would have been considered impossible in the past’.
80. Since the pandemic, the number of challenges has multiplied, and
uncertainty can make it harder to focus on the longer term and reform.
However, the pandemic response has shown that change can be achieved
quickly, and decisions can be taken in different ways with wider public
participation (paragraph 85). 
47 Auditor General for Scotland and the Accounts Commission, Tackling child poverty,
September 2022
48 Audit Scotland, Scotland’s councils’ approach to addressing climate change, September 2022
49 Auditor General for Scotland, Christie’s clarion call can’t wait another decade,
September 2021
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The public should be fully involved in the key decisions about
how public services will need to change
81. The changes required to public services are significant, will be long
standing, and will impact on people’s lives. As such, it is important that citizens
and communities are informed about the scale of the challenge and have a say
in how services change.
82. The Accounts Commission’s community empowerment and Best Value
audit work has noted limited progress in citizen participation in budget
processes, particularly for marginalised groups, for example in relation to
participatory budgeting. The recent Tackling child poverty briefing paper
reported that not enough involvement of children and families with lived
experience of poverty are hindering the development of sufficiently targeted
policies for tackling child poverty. 
83.  We have however found good examples of public engagement from our
work on social security.50 The programme continues to learn from existing
benefit recipients through user experience panels and engagement with
targeted client groups to inform its design decisions. 
84. Empowering communities to participate in democratic processes can help
to reduce disadvantage and inequality and improve outcomes for communities
and individuals. There are many benefits of getting community empowerment
and public participation right, as set out in our Principles of community
empowerment work with scrutiny bodies in 2019. However, good public
participation needs a lot of investment and capacity building to include a cross-
section of the community, not just the most vocal, articulate, or resourced.
85. The Community empowerment: Covid-19 update found communities played
a crucial role in the response to the pandemic. Public bodies can learn from this
by encouraging public participation and adopting new ways of working. Issues
to consider include: 
• designing flexible governance and decision-making processes best
suited to the communities they serve
• implementing more local decision-making structures with active local
participation 
• reducing the digital divide and continue to learn from and improve digital
engagement with communities. 
50 Auditor General for Scotland, Social Security: Implementing the devolved powers, May 2019
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Reforms to public services are now required | 23 
It must be clear how changes in budgets affect performance if
value for money is to be attained
86. It is important that it is clear how spending is affecting the outcomes the
Scottish Government wants to achieve. In The 2020/21 audit of the Scottish
Government Consolidated Accounts, the Auditor General noted that based on
the current information published on Scottish Government spending and
outcomes, it is hard to form an overall picture of the performance of the Scottish
Government and assess whether the national outcomes are being achieved. 
87. In its recent paper on the National Performance Framework (NPF), the
Finance and Public Administration Committee (FPAC) set out some
recommendations to better link budgets to outcomes. This highlighted the need
to consider how money can be allocated (including through procurement and
grants) based on the intended impact of the programmes it will fund and how
these will contribute to the NPF. It also recommended looking at how funding
can be used to incentivise different parts of the public sector to work together.51
Linking performance and budgets requires good quality data
88. To understand how to best target support and monitor how reform and
change is affecting people, it is essential that public bodies have access to
good quality and up-to-date data. 
89. A lack of data limits public bodies’ ability to target spending to where it is
needed, as it is harder to understand and predict where demand for services
will come from. For example, in recent outputs both the Auditor General and the
Accounts Commission have highlighted some significant gaps in the outcome
data available:
• The NHS in Scotland 2021 report (February 2022) highlights a lack of
robust data in relation to health inequalities and the need for
intersectional equality data. Without this data it will be hard to measure
the impact of the cost of living crisis and find appropriate ways to
target support.
• The Accounts Commission’s Local government in Scotland: Overview
2022 highlights that a lack of up-to-date, publicly available data makes it
difficult to assess the extent to which council activities have returned to
pre-pandemic levels, the level of demand for services and levels of
unmet need.
90. The national indicators that underpin the NPF give a measure of national
wellbeing. Ideally, these indicators could be monitored in real time to evaluate
the impacts of budget changes and prioritisations on the people of Scotland.
However, many of the indicators reflect data from the pre-pandemic period, or
have no data available at all. 
51 Finance and Public Administration Committee, Report on the National Performance
Framework: Ambitions into Action, October 2022
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Reforms to public services are now required | 24 
91. Given that outcomes are long-term in nature, milestones are helpful in
judging progress. The current lack of milestones for National Outcomes will
make monitoring how changes to budgets impact on people and longer-term
goals much more difficult. It also makes it harder for parliament and other
bodies to scrutinise the work of public bodies and have assurance that spending
is providing maximum value for money. 
92. The Planning for outcomes briefing paper published in 2019 noted that for
equalities and poverty outcomes, public bodies should consider whether the
data they have is sufficient to measure the impact of decisions about services,
funding and taxation on different equality groups affected. 
93. Collecting this data will require both time and money, but will be an
important step towards mapping spending to the aspirations of the Scottish
Government. We have recently published a blog on data and the radical action
needed in Scotland’s public sector.
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Conclusion | 25 
Conclusion 
94. At the time of writing, the picture for the Scottish public spending is still
developing. The UK Autumn Statement is expected 17 November, with the
Scottish Budget 2023/24 budget to be announced in December. The Spring
Budget Revision in the new year will set out the final budget for 2022/23.
In March 2023, the Scottish Fiscal Commission will publish its first Fiscal
Sustainability Report, which will give a long-term outlook for the Scottish
Government’s finances. 
95. Audit Scotland will continue to monitor how the Scottish Government’s
financial position develops, through both financial audit work and performance
audit work. The Auditor General will shortly publish the 2021/22 audit of the
Scottish Government Consolidated Accounts, which will contain key information
from the 2021/22 Consolidated Accounts and explain what they show about the
Scottish Government’s management of its budget. 
96. This paper has set out the urgent case for the reform of public services.
The Auditor General and the Accounts Commission will return to these issues
through the forward work programme in the coming months. Examples of
relevant planned work for 2023/24 includes performance audits relating to:
• Early learning and childcare
• Drug and alcohol services
• Social care 
• Climate change. 
97. For more information on planned outputs, please see our work programme.
This is dynamic and regularly updated, meaning that we can respond to
changing circumstances as required. 
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Scotland’s public finances
Challenges and risks
Audit Scotland’s published material is available for
download on the website in a number of formats.
For information on our accessibility principles, please
visit: www.audit-scotland.gov.uk/accessibility
For the latest news follow us on social media or
subscribe to our email alerts.
Audit Scotland, 4th Floor, 102 West Port, Edinburgh EH3 9DN
Phone: 0131 625 1500 Email: info@audit-scotland.gov.uk
www.audit-scotland.gov.uk
ISBN 978 1 913287 98 6  AGS/2022/10
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Audit Committee
Tuesday 7 February 2023
Item 5.6 
Internal Audit Service – Update on Shared Internal Audit Service
between Midlothian and East Lothian Councils 
Report by Kevin Anderson, Executive Director Place 
Report for Information 
1 Recommendations 
Audit Committee are recommended to note that the Shared Internal
Audit Service between Midlothian and East Lothian Councils is now
formally agreed and has commenced. 
2 Purpose of Report/Executive Summary 
This report advises Audit Committee that Midlothian Council and East
Lothian Council have now established a shared Internal Audit Service
and is anticipated to be in place for a minimum 18 month period. 
Date: Thursday 26 January 2023 
Report Contact:
Kevin Anderson, Executive Director Place
Kevin.Anderson@midlothian.gov.uk 
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2 
3 Background/Main Body of Report 
3.1 At its meeting of 27 September 2022, Audit Committee were presented
with a report providing detail of the Council’s interim internal audit
arrangements and the work that was ongoing to develop a shared
service with East Lothian Council. 
3.2 On 4 January 2023, the shared Internal Audit Service commenced
between Midlothian Council and East Lothian Council. The shared
service is led by East Lothian’s Service Manager – Internal Audit
(Duncan Stainbank) and is anticipated to be in place for a minimum 18
month period (subject to regular review). 
3.3 The shared service supports both Councils and Integrated Joint Board.
The service is working to align audit plans for all bodies and further
information on the audit forward work plan is also on today’s agenda. 
4 Report Implications (Resource, Digital and Risk 
4.1 Resource 
Financial implications of the shared service are being met from existing
budgets. 
4.2 Digital 
None 
4.3 Risk 
There is significant risk to the Council of not having a robust and
effective audit arrangement. 
4.4 Ensuring Equalities (if required a separate IIA must be completed) 
None 
4.4 Additional Report Implications (See Appendix A) 
See Appendix A 
Appendices 
Appendix A – Additional Report Implications
Appendix B – Background information/Links 
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3
APPENDIX A – Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Taking steps to maintain the resilience, capability and effectiveness of
Internal Audit services is necessary to support the delivery of the
priorities of Single Midlothian 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 
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 
Maintaining an effective internal audit service and the relevance of the
audit plan is an important aspect on delivering best value. 
A.5 Involving Communities and Other Stakeholders 
Engagement took place between both Councils as part of developing
the agreement. 
A.6 Impact on Performance and Outcomes 
An effective internal audit service will support continuous improvement
across all Council service and in its governance arrangements and the
Council’s business processes. 
A.7 Adopting a Preventative Approach 
Internal audit provides an important line of defence in reducing risk,
fraud and error.
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4
A.8 Supporting Sustainable Development 
Not applicable 
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5 
APPENDIX B 
Background Papers/Resource Links (insert applicable papers/links) 
Internal Audit Service report- Audit Committee, 27 September 2022
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