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Agenda Document Pack - Audit Committee - 07/03/2023

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

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Page 1

Notice of Meeting and Agenda 
Audit Committee 
Venue:  Council Chambers, 
Midlothian House, Dalkeith, EH22 1DN 
Date:  Tuesday, 07 March 2023 
Time:  11:00 
Executive Director : Place 
Contact:
Clerk Name: Democratic Services
Clerk Telephone: 
Clerk Email: democratic.services@midlothian.gov.uk 
Further Information: 
This is a meeting which is open to members of the public.  
Privacy notice: Please note that this meeting may be recorded. The
recording may be publicly available following the meeting. If you would
like to know how Midlothian Council collects, uses and shares your
personal information, please visit our website: www.midlothian.gov.uk 
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1          Welcome, Introductions and Apologies   
2          Order of Business 
Including notice of new business submitted as urgent for consideration at the
end of the meeting. 
3          Declaration of Interest 
Members should declare any financial and non-financial interests they have in
the items of business for consideration, identifying the relevant agenda item
and the nature of their interest. 
4          Minute of Previous Meeting
4.1 Minute of Audit Committee 07 February 2023 Submitted for
approval
3 - 8
4.2 Action log 9 - 10 
5          Public Reports
5.1 Internal Audit Work to February 2023 Report by Chief Internal
Auditor
11 - 20
5.2 Counter Fraud Annual Plan 2023/24 Report by Chief Internal
Auditor
21 - 26
5.3 Internal Audit Charter  Report by Chief Internal Auditor 27 - 36
5.4 Internal Audit Strategy and Annual Plan 2022/23 Report by Chief
Internal Auditor
37 - 54 
6          Private Reports 
No items for discussion 
7          Date of Next Meeting 
The next meeting will be held on the Tuesday 25 April 2023 at 11am. 
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Minute of Meeting 
Audit Committee 
Date Time Venue
Tuesday 7 February 2023 1.00pm 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
Morag Barrow Director Health and Social Care
Derek Oliver Chief Officer Place
David Gladwin Acting Chief Financial Officer 
Duncan Stainbank  Chief Internal Auditor
Sinead Urquhart  Executive Business Manager
Elaine Greaves Principal Internal Auditor
Gary Thomson Senior Finance Business Partner
Alan Turpie Legal and Governance Manager / Monitoring Officer
Robert Dick Audit Scotland
Patricia Fraser Audit Scotland
Andrew Henderson Democratic Services Officer 
Audit Committee
Tuesday 07 March 2023
Item 4.1
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1. Welcome and Apologies for Absence 
Apologies were submitted on behalf of Fiona Robertson and Gillian Woolman
(Audit Scotland). 
2. Order of Business 
The Chair outlined that item 5.6 would be taken in advance of item 5.1 with the
remaining items being heard in the order as outlined 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 06 December 2022 was submitted and approved
as correct record, moved by Councillor McKenzie and seconded by Councillor
McEwan. 
4.2 The Action log was submitted and noted. 
With regard to action point 1, the chair acknowledged that this would be an
ongoing action along with a future paper being submitted on CSG and ethical
depositing coming later in the year. 
5. Public Reports 
Report No. Report Title Submitted by:
5.6 Internal Audit Service – Update on Shared
Internal Audit Service between Midlothian
and East Lothian Councils
Executive Director
Place
Outline of report and summary of discussion
Kevin Anderson provided a brief overview of the report making reference to the
new Internal Audit arrangements with East Lothian Council which are now in
place. The Chair took the opportunity to welcome the Chief Internal Auditor to
Midlothian Council’s Audit Committee. 
Decision
Audit Committee noted that the Shared Internal Audit Service between Midlothian
and East Lothian Councils is now formally agreed and has commenced. 
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Report No. Report Title Submitted by:
5.1 Treasury Management and Investment
Strategy 2023/24 &
Prudential Indicators,
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 Code of Practice, which outlines that the
annual Treasury Management & Investment Strategy (TMIS) & Prudential
Indicators report which is required to be scrutinised before being recommended to
the Council. David Gladwin outlined that the Midlothian Council’s Treasury
Management and Investment Strategy was in line with those of other local
authorities and took the opportunity to confirm the exclusion of Qatar from
preferred partners. 
A brief discussion ensued in relation to ethical treasury management and the
capability for Council to react quickly on occasions where members saw a
potential issue. David Gladwin confirmed that member’s views were taken into
account when formulating the strategy and that members could flag potential
issues for discussion at any time. 
In response to comments regarding existing counter parties, Gary Thomson
confirmed that Midlothian Council’s deposit with Lloyds Bank Corporate Partners
was non-ring fenced and designed for corporate clients and medium sized
enterprises such as local authorities. 
A further discussion ensued in relation to a Midlothian Energy Ltd shareholder
injection for 24/25, The Acting Chief Financial Officer confirmed that as this would
feed through as capital expenditure it would sit within the Treasury Management
and Investment Strategy and agreed to reflect this going forward. 
Decision
a) Audit Committee approved 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; and
b) Noted 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;
and
c) Noted 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; and
d) Noted the retention of the current approach for the repayment of loans fund
advances as outlined in Section 7; and
e) Approved the Treasury Management and Investment Strategy for 2023/24. 
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Report No. Report Title Submitted by:
5.2 Internal Audit Work to December 2022  Chief Internal
Auditor
Outline of report and summary of discussion
Duncan Stainbank provided a brief overview of the report making reference to the
Internal Audit Annual Plan 2022/23, the final internal audit annual assurance
reports as attached to the report and acknowledged that all recommendations had
been acknowledged by management. Duncan Stainbank then took the
opportunity to respond to points of clarity. 
In response to comments regarding future utility prices, David Gladwin confirmed
that the decision had been taken to provide supplementary budget on 2022/23 to
meet higher than expected energy costs and that inflation projections for this
sector were included in Medium Term Financial Strategy projections.
With regard to the impact of inflation David Gladwin confirmed that procurement
bodies are undertaking forward purchasing. Derek Oliver also took the opportunity
to highlight that energy consumption is monitored across assets and that inflation
was added to create a forecast of future expenditure. 
Decision
a) Audit Committee 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 Internal Audit Mid-Term Performance
Report 2022/23
Chief Internal
Auditor
Outline of report and summary of discussion
In speaking to the report Duncan Stainbank outlined that it was intended to inform
Audit Committee about the progress made in the 9 months leading up to
December 2022. Duncan Stainbank continued to summarise the key comments
and status of audits as outlined in Appendix 1 and made reference to the Internal
Audit Annual Plan as approved by Audit Committee on the 14 March 2022. 
A discussion ensued in relation to Building Maintenance Services, Elaine Greaves
confirmed that an audit had previously been conducted and that some of the
actions were being carried out as part of the service review. Derek Oliver agreed
that he would bring a report following up actions to a future meeting of Audit
Committee. 
In response to comments regarding contracts, Derek Oliver confirmed that the full
procurement of contracts was contained within the service review and that
additional resource has been sought to complete this and that this would be in line
with the local procurement strategy. Derek Oliver further advised that payments of
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contractors was done as quickly as possible but that due diligence was also
required. 
Decision
a)     Derek Oliver agreed to bring a report following up audit actions in relation
to building maintenance services in future. 
b)     Audit Committee noted the progress Internal Audit has made with activity in
the Internal Audit Annual Plan 2022/23 to the end December 2022; and
c) Confirmed it’s satisfaction with the performance of the Internal Audit
service provision. 
Report No. Report Title Submitted by:
5.4 Risk Management Update – Strategic Risk
Profile Quarter 3 2022/23 
Chief Officer Place
Outline of report and summary of discussion
Derek Oliver provided a brief overview of the Risk Management Update making
reference to the risk responses implemented during quarter three, assured
members of the planned approach to response to the current risk climate and
provided an overview of the current risk evaluation and requested that Audit
Committee take note of the change in risks.
Responding to comments regarding the usage of the Borders Railway and the
101 bus service, Derek Oliver confirmed engagement with bus partners had
indicated that following the switch to hybrid working there had been a shift in
usage to different days and times. 
Decision
Audit Committee noted the current risk landscape and organisational response to
the most significant risks in Quarter 3 (Q3) 2022/23 (1 October to 31 December
2022). 
Report No. Report Title Submitted by:
5.5 Scotland’s Public Finances: Challenges and
Risks 
Acting Chief
Financial Officer
Outline of report and summary of discussion
David Gladwin provided a brief overview of the Audit Scotland report summarising
the key points of the report and outlined the three main messages. 
A brief discussion ensued in relation to lag times associated with Scottish
Government Grant funding, David Gladwin confirmed that lag times were linked to
population growth and that this was very nuanced depending of the area of
distribution. In response to comments relating to the usage of data to outline
population growth, Grace Vickers highlighted that Scottish Government growth
unit examine various datasets and agreed to circulate the NRS data and forward.
Decision
a) Grace Vickers agreed to circulate NRS data and forward profiles to Audit  
Committee Members; and
b) Considered and noted the Audit Scotland report; and
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c) Noted 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. 
6. Private Reports 
None 
7. Date of Next Meeting 
Date of Next Meeting: Tuesday 7 March 2023 at 11am. 
The meeting terminated at 1:53 pm 
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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  Carry forward, paper
coming forward regarding
CSG and ethical
depositing coming later in
the year. 
2 Internal Audit Mid-
Term Performance
Report 2022/23
07/02/2023 Derek Oliver to submit a
report to Audit Committee
following up on audit actions
for Building Maintenance
Services. 
Chief Officer
Place
Ongoing Report will be presented to
Audit Committee in April,
following update report to
BTSG in March.
3 Scotland’s Public
Finances: Challenges
and Risks
07/02/2023 Grace Vickers to circulate
NRS data and future profiles
to members. 
Chief Executive 07/03/2023 Complete – Circulated to
members 07/03/2023 
Audit Committee
Tuesday 07 March 2023
Item No: 4.2  
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Audit Committee
Tuesday 7 March 2023
Item 5.1 
Internal Audit Work to February 2023 
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 22 February 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 January to 28 February 2023
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:
• Employability Funded Programmes; and
• Performance Management and Performance Indicators. 
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
Care at Home Draft Report Issued
Mental Health Services Testing underway
Construction projects / social housing programme Testing 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 1
Low 5
Sub-total reported this period 6
Previously reported 34
Total 40 
Recommendations agreed with action plan 40
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) 
Appendices
APPENDIX A – Additional Report Implications
APPENDIX 1
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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: Employability Funded
Programmes 
Category: Assurance – Risk 
Date issued: 
13 January 2023 Draft 
02 February 2023 Final 
Level of Assurance: 
Substantial for providing
support to the community;
working in partnership with
other sectors; and meeting
priorities and outcomes of the
Single Midlothian Plan.   
Limited for the recording of
information, maintenance of
audit trails, compliance with the
NOLB grant criteria, the Data
Protection Act 2018 and the
Council’s FTPP. 
The purpose of this audit was to review employability funded programmes under
the terms of the associated agreements to assess compliance with the
requirements and delivery of outcomes.
Midlothian Council funds Arms Length and External Organisations (ALEOs) for a
range of purposes related to council services and its broader corporate
objectives set out in partnership with the community planning partners under the
“Single Midlothian Plan”, the local outcomes improvement plan for Midlothian
required by the Community Empowerment Act 2015.  The Council has a
Following the Public Pound (FTPP) policy and guidance which was last
reviewed and updated in March 2022.  
The Communities Lifelong Learning Employability (CLLE) team works with
young people, adults, families and community organisations to improve skills for
learning, life and work. The No One Left Behind (NOLB) Employability Funding
stream has been set up by the Scottish Government to deliver a flexible and
user-based model of employability support for people from school leaving age
up to 67 years (pensionable age). It is a partnership programme between the
Scottish Government and Local Authorities. During 2022/23, the Scottish
Government allocated funding of £845,679 to Midlothian Council to support local
residents who meet the relevant eligibility criteria included in the No One Left
Behind Employability funding streams. 
The United Kingdom Shared Prosperity Fund (UKSPF) was launched in April
2022 and is one strand of a suite of funding which superseded the EU structural
funds and is nationally funded by the UK Government. Midlothian Council will
receive £3,558,662 of funding over a 3 year period. This money will be
distributed locally and invested in the following priorities set by the UK
Government: Communities and Place, Support for Local Businesses, People
and Skills; and Multiply (improving adult numeracy for those aged 19 plus). 
Internal Audit considers that the level of assurance is: substantial for providing
support to the community; working in partnership with other sectors; and
meeting priorities and outcomes of the Single Midlothian Plan.  Quarterly
financial and narrative delivery reports were submitted to the Scottish
Government on time.  Assurance is limited for the recording of information,
maintenance of audit trails, compliance with the NOLB grant criteria, the Data
Protection Act 2018 and the Council’s FTPP.  Internal Audit made the following
recommendations: 
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
• To comply with the NOLB grant criteria and as good practice: further
evidence should be obtained; an adequate audit trail maintained; more
detailed information should be submitted in the narrative reports; action
plans, SLA templates and the privacy statement should be updated; and the
Council’s website should be updated to include more information on the
NOLB programme and the EQIA. Management should also ensure that the
CLLE team are using Egress where applicable. (Medium)
• Management should ensure that all Service Level agreements (SLAs) are
signed by the Council; and risk assessments should be completed for large
grants. Management should document the governance arrangements for
reporting different types of grants and demonstrate which Committees they
will be reported to. (Low)
• Roles and responsibilities for the grant panel should be documented;
conflicts of interest forms completed and evidence maintained showing that
factors stipulated in the FTPP for large grants were considered by the panel.
Future grant application forms should state what happens to applications
submitted after the deadline. Training on what should be treated as a
procurement or a grant should be provided to the CLLE team. (Low)
• An audit trail should be maintained of annual checks undertaken on
providers’ insurance documents; monitoring information received from the
provider should be recorded on the system; and officers should undertake
sample checks. (Low)
• Updated service level agreements should be issued on a timely basis and an
audit trail of the decision making process should be maintained. The FTPP
policy should be updated to document the governance required for the
authorisation of variations. (Low) 
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Report Summary of key findings and recommendations Recommendations Status
H M L
Subject: Performance
Management and
Performance Indicators 
Category: Assurance –
Risk 
Date issued: 
30 January 2023 Draft 
13 February 2023 Final 
Level of Assurance: 
Substantial for the
reporting of PIs. 
Limited for the
implementation of the
recommendations from the
audit of Performance
Management (LGBF)
undertaken in 2021. 
The purpose of this audit was to test a sample of performance indicators to ensure
that they are complete, accurate, based on current data and conform to the
stipulated criteria.  It included a follow up of the implementation of the
recommendations from the audit of Performance Management (LGBF) –
Improvement Service Return undertaken in 2021. 
Performance data is required for a number of purposes including internal monitoring,
statutory requirements and for benchmarking.  Key performance information is
recorded in the Pentana performance management system and there are currently
2,541 PIs recorded.  A range of statutory and non-statutory PIs are reported and
these are principally driven by the Single Midlothian Plan and Service Plans. 
Service Plans as well as defining service specific priorities provide a link to the
outcomes contained within the Single Midlothian Plan. 
Performance reports are submitted to Cabinet and the Performance Review and
Scrutiny Committee (PRSC) and are published on the Council’s website. Service
Plans 2021-22 were reported to Council in June 2021 and have been carried forward
for one year.  A draft 5 year Strategic Plan is currently under development which will
look at making targeted improvements to performance reporting.  The draft 5 year
strategic plan was reported to Council in October 2022.  The Council agreed to a
continuation of the Draft Midlothian Council Strategic Plan 2023 - 2026 until the
Medium Term Financial Strategy is agreed. 
Internal Audit considers that the level of assurance is: substantial in relation to the
reporting of PIs but is limited for the implementation of the recommendations from
the audit of Performance Management (LGBF) undertaken in 2021.  2
recommendations were made during this review and they have only been partially
completed.  Testing highlighted that, from the 12 performance indicators tested, 8
PIs were correct, 3 PIs had to be recalculated as no audit trail had been retained for
the reported figures, and 1 error was noted for housing repairs.  As detailed in the
previous audit, Internal Audit made the following recommendation: 
• Services should be reminded of the performance measure controls they should
have in place when calculating statutory and non-statutory performance
indicators such as: retain an audit trail of source documentation; create
procedure notes to enable indicators to be produced in the absence of key
individuals; and undertake quality assurance checks for the calculation of PIs.
(Low)
0 0 1 Management have
accepted the factual
accuracy of the
report and its
findings, and agreed
to implement the
recommendation. 
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Audit Committee
Tuesday 7 March 2023
Item 5.2 
Counter Fraud Annual Plan 2023/24 
Report by Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is invited to:
a) Approve the Counter Fraud Annual Plan 2023/24 (Appendix 1). 
2 Purpose of Report/Executive Summary 
The purpose of this report is to gain approval from the Audit Committee
for the proposed Counter Fraud Annual Plan 2023/24 to support the
delivery of the Council’s Counter Fraud Strategy and to demonstrate
compliance with the Council’s Counter Fraud Policy Statement. 
Having robust fraud prevention and investigation arrangements in place
contributes to safeguarding the Council’s financial resources, for
delivery of services, as part of protecting the public purse. A focus on
enhancing fraud prevention and detection to improve Midlothian
Council’s resilience to the risk of fraud, theft, corruption and crime
(including cybercrime and money laundering), and ensure these are
embedded preventative practices as specific changes associated with
the Counter Fraud Strategy approved by Council in August 2020. 
The Counter Fraud Annual Plan 2023/24 (Appendix 1) sets out the
planned counter fraud activity to support the approach and culture of
the Council in tackling fraud and corruption to deliver the Counter
Fraud Strategy. This will enable the Council to demonstrate compliance
with its Counter Fraud Policy Statement as its commitment to tackling
fraud and reflects the Integrity Group’s assessment of counter fraud
controls. 
Date 22 February 2023 
Report Contact:
Duncan Stainbank  
duncan.stainbank@midlothian.gov.uk
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3 Background 
3.1 A review was carried out in 2019/20 of counter fraud management
arrangements in place and to make improvements in light of the
significant fraud investigations that have occurred within Midlothian
Council in recent years, noting that some are ongoing. 
3.2 The conclusion of the review included a refresh to the corporate policy
and strategy for tackling fraud. A revised Counter Fraud Policy
Statement and Counter Fraud Strategy and proposal to have 2 FTE
Corporate Fraud Officers to deliver the revised Counter Fraud Policy
and Strategy were approved by Midlothian Council in August 2020. 
4        Counter Fraud Annual Plan 2022/23 
4.1 Having robust fraud prevention and investigation arrangements in place
contributes to safeguarding the Council’s financial resources, for
delivery of services, as part of protecting the public purse. A focus on
enhancing fraud prevention and detection to improve Midlothian
Council’s resilience to the risk of fraud, theft, corruption and crime
(including cybercrime and money laundering), and ensure these are
embedded preventative practices as specific changes associated with
the Counter Fraud Strategy approved by Council in August 2020. 
4.2 The Counter Fraud Annual Plan 2023/24 (Appendix 1) sets out the
planned Counter Fraud activity to support the change in approach and
culture for the Council for tackling fraud and corruption to deliver the
approved Counter Fraud Strategy. This will enable the Council to
demonstrate compliance with its Counter Fraud Policy Statement as its
commitment to tackling fraud and reflects the Integrity Group’s
assessment of counter fraud controls (update submitted to the Audit
Committee in January 2022). 
5 Report Implications (Resource, Digital, Risk and Equalities) 
5.1 Resource 
The primary responsibility for the prevention, detection and
investigation of fraud rests with Management, supported by the
Integrity Group and the Corporate Fraud Team. 
The purpose of the Integrity Group is to improve the Council’s
resilience to fraud, corruption, theft and crime (including cybercrime
and money laundering). The formal establishment of the Integrity
Group with a Terms of Reference (approved by the Audit Committee on
22 June 2020) enables the shift to more holistic working in multi-
disciplinary forums to tackle fraud in a consistent and collaborative way
across the Council.   
The revised Counter Fraud Policy Statement and Counter Fraud
Strategy and proposal to have 2 FTE Corporate Fraud Officers to
deliver the revised Counter Fraud Policy and Strategy were approved
by Midlothian Council in August 2020. The 2 Corporate Fraud Officers
are line managed by the Principal Internal Auditor who reports to the
Chief Internal Auditor.
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Savings will continue to be identified arising from Corporate Fraud
Team activity, which will be stated within the Counter Fraud Annual
Reports presented to the Audit Committee. 
5.2 Digital 
None. 
5.3 Risk 
The Council is committed to minimising the risk of loss due to fraud,
theft, corruption or crime and to taking appropriate action against those
who attempt to defraud the Council, whether from within the authority
or from outside. 
The Counter Fraud Policy Statement sets out the roles and
responsibilities for the prevention, detection and investigation of fraud.
The Counter Fraud Strategy provides a shift in approach to focus on
enhancing fraud prevention and detection to improve Midlothian
Council’s resilience to the risk of fraud. The work undertaken by the
Corporate Fraud Team in collaboration with other Services is designed
to reduce the fraud risks within the Council. 
5.4 Ensuring Equalities 
An Integrated Impact Assessment (IIA) Form was completed as part of
the development of the revised Counter Fraud Policy and Strategy. The
conclusion was that undertaking a Combined Impact Assessment was
not necessary as the policy / proposal has little relevance to equality,
negligible impact on the economy, and no impact on the environment.
The revised Counter Fraud Policy and Strategy set out enhancements
to internal Management arrangements though it is anticipated that
there will be minimal impact on internal staff only; there is no change to
the Whistleblowing external-facing arrangements. 
5.5 Additional Report Implications (See Appendix A) 
Appendices:
Appendix A – Additional Report Implications
Appendix 1 – Midlothian Council Counter Fraud Annual Plan 2022/23 
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan (Reducing the gap in economic
circumstances; Reducing the gap in learning outcomes; Reducing the
gap in health outcomes; and Reducing the impact of climate change)
by preventing and detecting fraud, additional resources might be
available to support the Council’s objectives. Any loss of funds due to
fraud, theft, corruption or crime might impact on the ability of Midlothian
Council to achieve its key priorities. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow
supported by the 9 drivers for change. Implementing the 9 drivers for
change in practice is applicable to the Council’s arrangements for
tackling fraud as set out in the Counter Fraud Policy Statement and
Counter Fraud Strategy that were approved by Council in August 2020.
The shift to the key drivers for change is an intrinsic part of the change
in approach and culture for the Council for tackling fraud and
corruption. For example:
(a) The formal establishment of an Integrity Group with a Terms of
Reference (approved by the Audit Committee in June 2020) shifting
to more holistic working in multi-disciplinary forums to tackle fraud
in a consistent and collaborative way across the Council;
(b) A focus on enhancing fraud prevention and detection to improve
Midlothian Council’s resilience to the risk of fraud, theft, corruption,
and crime and ensure these are embedded preventative practices; 
(c) Applying the minimum standard within the CIPFA Code of Practice
on ‘Managing the Risk of Fraud and Corruption (2014)’ for counter
fraud policy, strategy and other practices, and adopting the CIPFA
Counter Fraud Maturity Model as a means of self-assessment
moving forward will enable continuous improvement to be
evaluated, managed and evidenced; and
(d) Use of a blend of toolkits such as fraud risk assessments and e-
learning packages that can be tailored to specific Services. 
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A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
Having robust fraud prevention and investigation arrangements in place
contributes to safeguarding the Council’s financial resources, for
delivery of services, as part of protecting the public purse. The
approved Counter Fraud Strategy states the Council will measure
progress against the CIPFA Counter Fraud Maturity Model as a self-
assessment approach to continuous improvement in order to
continuous improvement to be evaluated, managed and evidenced
demonstrate best value in the use of resources. 
A.5 Involving Communities and Other Stakeholders 
Ensuring awareness of the Whistleblowing facility to report areas of
concern is important in the approach to tackling fraud. The facility has
been promoted in recent years and is being utilised, as stated in the
Counter Fraud Annual Report 2021/22 that reported outcomes of
corporate fraud activity, some of which arose from whistleblowing
received from staff, those within communities or other stakeholders. 
A.6 Impact on Performance and Outcomes 
The primary responsibility for the prevention, detection and
investigation of fraud rests with Management, supported by the
Integrity Group and the Corporate Fraud team. Internal Audit provides
advice and independent assurance on the effectiveness of processes
put in place by Management. The Findings and Recommendations
from Internal Audit and Corporate Fraud work which are presented to
the Audit Committee during the year assists the Council in maintaining
and / or enhancing fraud prevention and detection controls. 
A.7 Adopting a Preventative Approach 
Having robust fraud prevention and investigation arrangements in place
contributes to safeguarding the Council’s financial resources, for
delivery of services, as part of protecting the public purse. A focus on
enhancing fraud prevention and detection to improve Midlothian
Council’s resilience to the risk of fraud, theft, corruption and crime, and
ensure these are embedded preventative practices are specific
changes associated with the approved Counter Fraud Strategy. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable
development. Good governance is important to enable Midlothian
Council to achieve its objectives including sustainable outcomes.
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Midlothian Council Counter Fraud Annual Plan 2022/23          Appendix 1
Ref Category Activity Number
of Days
Commentary
1. Compliance Contract Management  40 Data analytics to test governance and internal controls in place over
Contract Management arrangements with third parties to assess
compliance with procurement rules.
2. Compliance Corporate Fraud Enquiries 155 Respond to whistleblowing notifications. 
3. Data Match National Fraud Initiative 100 Co-ordinate the NFI exercise across Council services, review and
investigate data matches, and periodically produce reports on the
outcomes. 
4. Data Match Social Housing 30 Data analytics on Social Housing, enquiries and investigations.
5. Data Match Council Tax  15 Data analytics on Council Tax, enquiries and investigations.
6.  Other Corporate Fraud Policy
Framework
15  Support the Integrity Group with monitoring of policies and
procedures review, update and communication. Assist with the self-
assessment of compliance against the CIPFA code on Managing the
Risk of Fraud and Corruption.
7. Other Fraud Risk Assessments 30 Support operational Service Managers to assess fraud risks and put
in place appropriate controls within processes and practices.
8. Other Fraud Awareness Training 15 Develop and deliver fraud awareness training modules (face-to-face,
virtual or via e-learning) to Management and Staff.
9. Other Integrity and SOC Groups 6 Attend and provide support to the Council’s Integrity Group and the
Serious and Organised Crime Group.  
Corporate Fraud Total 406 
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Audit Committee
Tuesday 7 March 2023
Item 5.3 
Internal Audit Charter 
Report by Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is invited to:
a) Note the changes to the Internal Audit Charter outlined in section 4
of this report in conformance with PSIAS; 
b) Approve the revised Internal Audit Charter shown at Appendix 1; and  
c) Note that the Internal Audit Charter will be reviewed annually. 
2 Purpose of Report/Executive Summary 
This report provides the Audit Committee with the updated Internal
Audit Charter for approval that defines the terms of reference for the
Internal Audit function to carry out its role to enable the Chief Audit
Executive to prepare annual Internal Audit opinions on the adequacy of
the overall control environment for Midlothian Council, and for
Midlothian Health and Social Care Integration Joint Board. 
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.” 
In accordance with the Public Sector Internal Audit Standards (PSIAS)
(2017), the purpose, authority and responsibility of the Internal Audit
activity must be formally defined in an Internal Audit Charter, consistent
with the Definition of Internal Auditing, the Code of Ethics and the
Standards. The Chief Audit Executive must periodically review the
Internal Audit Charter and present it to senior management (Corporate
Management team) and the board (Audit Committee) for approval. 
The Internal Audit Charter has been updated in conformance with the
PSIAS for approval by the Audit Committee to ensure that Internal
Audit is tasked to carry out its role in accordance with best Corporate
Governance practice, and is shown in Appendix 1. 
Date 22 February 2023 
Report Contacts
Duncan Stainbank, Chief Internal Auditor 
duncan.stainbank@midlothian.gov.uk      Page 27 of 54

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3 Background 
3.1 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.” 
3.2 The Midlothian Council Internal Audit function follows the professional
standards as set out in the Public Sector Internal Audit Standards
(PSIAS) which came into effect on 1 April 2013 (amended 2017), along
with the CIPFA Local Government Application Note for the United
Kingdom. The PSIAS have been developed by the standard setters
(CIPFA for local government) through the Internal Audit Standards
Advisory Board (IASAB) and have been based on the Institute of
Internal Auditors International Standards of Professional Practice. 
3.3 In accordance with the PSIAS, the purpose, authority and responsibility
of the Internal Audit activity must be formally defined in an Internal
Audit Charter, consistent with the Definition of Internal Auditing, the
Code of Ethics and the Standards. The Chief Audit Executive must
periodically review the Internal Audit Charter and present it to ‘senior
management’ (Corporate Management Team) and the ‘board’ (Audit
Committee) for approval. 
3.4 Within the PSIAS a Public Sector requirement states the Internal Audit
Charter must also:
o define the terms ‘board’ and ‘senior management’ for the
purposes of Internal Audit activity;
o cover the arrangements for appropriate resourcing;
o define the role of Internal Audit in any fraud-related work; and
o include arrangements for avoiding conflicts of interest if Internal
Audit undertakes non-audit activities. 
3.5 Internal Audit assurance resources and services are also provided by
Midlothian Council’s Internal Audit team to the Midlothian Health and
Social Care Integration Joint Board (MIJB), including the appointed
MIJB Chief Internal Auditor. The Internal Audit Charter and Strategy
are applicable to each organisation. 
4 Internal Audit Charter   
4.1 The authority for Internal Audit to operate in Midlothian Council is
contained in the Council’s Local Code of Corporate Governance,
Standing Orders, and Financial Regulations. This Internal Audit Charter
expands upon that framework. 
4.2 The Internal Audit Charter as shown in Appendix 1 to this report:
establishes the Internal Audit activity’s position within the organisation,
including the nature of the Chief Audit Executive’s functional reporting
relationship with the board; authorises access to records, personnel
and physical properties relevant to the performance of engagements;
and defines the scope of Internal Audit activities. 
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4.3 The Internal Audit Charter, which was previously approved by the Audit
Committee on 14 March 2022, has been updated by the Chief Audit
Executive (shared Chief Internal Auditor). The summary of the changes
reflect the following:
• The agreement for shared Internal Audit services with East
Lothian Council, , and the associated change in approach for
the provision of Internal Audit resources; and 
4.4 The Internal Audit Charter should be considered alongside the Internal
Audit Strategy and Plan 2023/24. The Internal Audit Strategy sets out
the Council’s assurance framework within which Internal Audit
operates, and the Chief Audit Executive’s strategy for discharging its
role and providing the necessary annual assurance opinions to
Midlothian Council and Midlothian Health and Social Care Integration
Joint Board (MIJB). The Internal Audit Charter and Strategy are
applicable to these organisations. There are separate Internal Audit
Annual Plans for each organisation, which set out the range and
breadth of audit activity. 
5 Report Implications (Resource, Digital, Risk and Equalities) 
5.1 Resource 
The Local Authority Accounts (Scotland) Regulations 2014 that came
into force on 10 October 2014 require a local authority to operate a
professional and objective internal auditing service. 
Internal Audit must have sufficient staff and other resources to enable it
to carry out the objectives of the Charter and to deliver a programme of
independent and objective audit assurance work alongside other
available sources of assurance to enable the Chief Audit Executive to
prepare annual opinions on the adequacy of the overall control
environment for Midlothian Council and the MIJB. Internal Audit
resources are set out in the Internal Audit Strategy and Plan 2022/23. 
5.2 Digital 
There are no digital implications arising from this report. 
5.3 Risk 
The authority for Internal Audit to operate in Midlothian Council is
contained in the Council’s Local Code of Corporate Governance,
Standing Orders, and Financial Regulations. This Internal Audit Charter
expands upon that framework. 
Approval of the Internal Audit Charter (Appendix 1), as recommended
in this report, will ensure that Internal Audit is tasked to carry out its role
in accordance with PSIAS and best Corporate Governance practice. 
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The PSIAS require Internal Audit to evaluate the effectiveness of the
Council’s Risk Management arrangements and contribute to
improvements in the process. The work of Internal Audit (including its
opinion on the control environment) shall contribute to the Council’s
review of its corporate governance arrangements the outcome of which
is published in the Annual Governance Statement. 
At all times, Management’s responsibilities (led by the Corporate
Management Team) include:
o Designing and maintaining proper risk management, governance
and internal control processes and systems for which they have
responsibility to ensure probity in systems and operations,
including the prevention, detection and resolution of fraud and
irregularities. These are not fixed but evolve as the Council
changes.
o Checking that these governance arrangements and internal
controls are operating effectively and obtaining assurances from
internal compliance, risk, inspection, quality, and control functions.
(The above are known as the first and second lines.)
o Engaging with Internal Audit (the third line) in a positive way to
achieve shared goals for robust internal control and governance,
best value and improvement, and ensuring that Internal Audit can
properly fulfil its role.
o Considering and acting upon Internal Audit findings and
recommendations, including implementation of audit
recommendations within agreed timescales and updating Pentana
performance system, or accepting responsibility for any resultant
risk from not doing so.
o Seeking advice and consultancy support from Internal Audit on
existing controls and on changes to and transformation of
governance, processes and procedures. 
5.4 Ensuring Equalities 
This report does not relate to a new or revised policy, service or budget
change, which affects people (the public or staff), so an Integrated
Impact Assessment (IIA) is not an applicable consideration. 
The Internal Audit work is carried out in accordance with the
appropriate legislation and professional standards. The latter includes
compliance by those within the Internal Audit function with the Code of
Ethics set out in the PSIAS. This is of particular importance and
relevance 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. 
5.5 Additional Report Implications (See Appendix A) 
Appendices:
APPENDIX A – Additional Report Implications
APPENDIX 1 – Internal Audit Charter 
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan to which Midlothian Council and its
Community Planning Partners have made a commitment (Reducing the
gap in economic circumstances; Reducing the gap in learning
outcomes; Reducing the gap in health outcomes; and Reducing the
impact of climate change), good governance is important to enable
Midlothian Council to deliver its key priorities in support of achieving the
Council’s objectives. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow
supported by the 9 drivers for change. Implementing the 9 drivers for
change in practice is applicable to the Council’s Internal Audit service
provision to assist the Council in achieving its objectives. 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
The definition of Internal Auditing within the Public Sector Internal Audit
Standards (PSIAS) is “Internal auditing is an independent, objective
assurance and consulting activity designed to add value and improve
an organisation’s operations. It helps an organisation accomplish its
objectives by bringing a systematic, disciplined approach to evaluate
and improve the effectiveness of risk management, control and
governance processes.” 
Internal Audit is a key element of good governance which is important
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Recommendations made by Internal Audit underpin 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 Audit Executive is accountable to the Audit Committee
which, in fulfilling its governance role, acts as a bridge between the
Council and other stakeholders. 
A.6 Impact on Performance and Outcomes 
Applying the framework of the PSIAS will give the Audit Committee
assurance that the Internal Audit function is compliant with legislative
requirements and current best practice. 
A.7 Adopting a Preventative Approach 
The PSIAS are applicable from 1 April 2013 (amended 2017) which
means the Internal Audit Service has taken steps to be fully compliant. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable
development. Internal Audit is a key element of good governance which
is important to enable Midlothian Council to achieve its objectives
including sustainable outcomes.
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1 
INTERNAL AUDIT CHARTER      Appendix 1
INTRODUCTION
The Public Sector Internal Audit Standards (PSIAS) requires that the purpose, authority and
responsibility of the Internal Audit activity must be formally defined in an Internal Audit Charter,
consistent with the Definition of Internal Auditing, the Code of Ethics and the International
Standards for the Professional Practice of Internal Auditing (Standards) detailed in the PSIAS.  
Midlothian Council has adopted from the PSIAS1: the definition of Internal Auditing “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”, the Mission Statement of Internal Audit “To
enhance and protect organisational value by providing risk-based and objective assurance, advice
and insight” and the Core Principles. 
OBJECTIVES OF INTERNAL AUDIT
Internal Audit’s responsibility is to report to Midlothian Council on its assessment of the adequacy
of the entire control environment, through the Corporate Management Team (‘senior
management’) and the Audit Committee (the ‘board’ for the purposes of Internal Audit activity).
Internal Audit adds value to the organisation (and its stakeholders) by enhancing governance, risk
management and control processes and objectively providing relevant assurance.
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.
Midlothian Council’s Internal Audit function provides assurance services to the Midlothian Health
and Social Care Integration Joint Board (MIJB) and will apply the same standards as defined in
this Charter to any work undertaken for MIJB, with separate Internal Audit plans and reports
presented to its ‘senior management’ (MIJB Chief Officer and MIJB Chief Finance Officer) and to
the ‘board’ (MIJB Audit and Risk Committee). 
1 Public Sector Internal Audit Standards (PSIAS) (2017)
Midlothian
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2 
POSITION OF INTERNAL AUDIT WITHIN MIDLOTHIAN COUNCIL 
In terms of the PSIAS, the status of Internal Audit should enable it to function effectively, with
recognition of the independence of Internal Audit fundamental to its effectiveness. The Chief Audit
Executive (CAE) should have “sufficient status to facilitate the effective discussion of audit
strategies, plans, results and improvement plans with senior management of the organisation.2” 
The CAE within Midlothian Council (the shared Chief Internal Auditor) has full access to those
charged with governance, specifically the Elected Members and the Corporate Management
Team. The latter includes the Council’s statutory officers: head of paid service (Chief Executive),
s95 finance officer (Chief Officer Corporate Solutions), monitoring officer (Legal & Governance
Manager) and chief social work officer (Chief Officer Children’s Services, Partnerships and
Communities). The CAE has free and unfettered access to the Chair of each organisation’s ‘board’
to discuss any matters the members or auditors believe should be raised privately.
In terms of accountability and independence to ensure conformance with PSIAS, the CAE reports
functionally to the Midlothian Council Audit Committee. In this context functional reporting3 means
the Audit Committee will:
➢ Approve the Internal Audit Charter.
➢ Approve the risk-based Internal Audit Annual Plan.
➢ Ratify the Internal Audit budget and resource plan to ensure that Internal Audit is
adequately resourced to meet assurance and other key responsibilities.
➢ Receive communications from the CAE on the Internal Audit activity’s performance relative
to its plan and other matters.
➢ Ratify all decisions regarding the appointment or removal of the CAE.
➢ Provide feedback to contribute to the performance appraisal of the CAE.
➢ Make appropriate enquiries of Management and the CAE to determine whether there are
inappropriate scope or resource limitations.
The CAE is line managed by the Chief Executive but retains responsibility for all operational audit
activity and reports in their own name and retains final right of edit over all Internal Audit reports.
The reporting line is managed in a manner which: ensures the CAE is accorded open and direct
communication with Management; and ensures the CAE and the Internal Audit function have an
adequate and timely flow of information concerning the activities, plans and initiatives of the
Council and IJB.
RIGHTS OF ACCESS
The CAE and any member of the Internal Audit function authorised by them, relevant to the
delivery of audit engagements for each of the organisations, has authority to:
➢ Have access at any reasonable times to all computer systems and records (paper/digital).
➢ Require and receive explanations concerning any matter under examination from personnel
relevant to their roles including Elected Members / Board Members.
➢ Enter at all reasonable times and without notice any properties, provided that where such
properties are leased to a third party the terms of the lease are observed.
➢ Require personnel to produce cash, stores, or other assets under their control.
Internal Audit safeguards all information obtained in the carrying out of its duties, only uses it for
defined purposes and makes no disclosure of any information held, unless this is authorised or
there is a legal or professional requirement to do so. 
2 Internal Audit Standards Advisory Board (IASAB) Public Sector Internal Audit Standards (PSIAS) (2017)
3 Chartered Institute of Internal Auditors (CIIA) – International Standards for Professional Practice of Internal Auditing
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3 
SCOPE OF INTERNAL AUDIT ACTIVITY
For each organisation Internal Audit shall systematically review, appraise, make appropriate
recommendations for improvement, and report upon:
• the governance arrangements and processes;
• the design, implementation and effectiveness of ethics-related objectives, programmes and
activities;
• the information technology governance in support of  strategies and objectives;
• the systems and processes in place to ensure effective performance management and
accountability;
• the effectiveness and appropriateness of controls and other arrangements put in place to
manage risk;
• the potential for the occurrence of fraud and how fraud risk is managed;
• the completeness, reliability, integrity and timeliness of information, both financial and
operational; 
• the systems and processes established to ensure compliance with policies, plans,
procedures, laws, and regulations, whether established internally or externally, and that
employees’ actions are in compliance;
• the action(s) taken to address significant legislative or regulatory issues; 
• the effectiveness of arrangements for safeguarding assets and interests; 
• the economy, efficiency and effectiveness with which resources are deployed; 
• the effectiveness and efficiency of operations and programmes; and
• the extent to which operations are being carried out as planned and strategic objectives and
goals are met.
Internal Audit’s work covers:
• all activities, systems, processes, controls, policies, and protocols that are currently existing
or under development;
• all records, personnel and properties; and 
• all services and other activities for which each organisation is responsible or accountable,
whether delivered directly or by third parties through contracts, partnerships or other
arrangements.
AUDIT RESOURCES AND WORK PRIORITISATION
The CAE ensures that Internal Audit resources are appropriate, sufficient and effectively deployed
to achieve the approved plan. Appropriate refers to the mix of qualifications, knowledge, skills and
other competencies needed to perform the plan such as compliance with the Code of Ethics set
out in the PSIAS and with the Nolan principles established in the Seven Principles of Public Life.
This is of particular importance and relevance for the profession of Internal Audit, founded as it is
on the trust placed in its objective assurance about risk management, internal control and
governance. The CAE holds a professional qualification (Bsc Hons, CIPFA) and is suitably
experienced. Sufficient refers to the quantity of resources needed to accomplish the plan.
Resources are effectively deployed when they are used in a way that optimises the achievement
of the approved plan. 
The Internal Audit Strategy, as approved by the Midlothian Council Audit Committee, outlines the
strategic direction for how Internal Audit will achieve its objectives in conformance with PSIAS. It
guides the Internal Audit function in delivering high quality Internal Audit services to Midlothian
Council and the MIJB.
The Midlothian Council Internal Audit Annual Plan, as approved by the Audit Committee, is the
main determinant of the relative priority to be placed on each part of the work of Internal Audit,
with an Internal Audit Annual Plan specific to the MIJB being approved and monitored by its
‘senior management’ and ‘board’ (MIJB Audit and Risk Committee). The Internal Audit planning
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4 
process, to determine the priorities of the Internal Audit activity consistent with the organisation’s
goals, includes consideration of the organisation’s priorities, plans, strategies, objectives, risks and
mitigating controls, and the internal and external assurances provided. The CAE determines the
actual deployment of available resources covering the range and breadth of audit areas which are
integral to the assurance process across the activities of Midlothian Council and MIJB in order to
provide the statutory annual Internal Audit opinion to each organisation’s ‘senior management’ and
‘board’. This plan also requires to be sufficiently flexible to reflect the changing risks and priorities
of each organisation.
The Plan has within it the provision of resources as Contingency to respond to specific control
issues highlighted during the year and covering other unforeseen variations in the level of
resources available to Internal Audit, such as staff vacancies.
The Plan has within it the provision of resources for Internal Audit ‘critical friend’ Consultancy that
are valued by Management to support them in delivering innovation, change and transformation.
Requests are considered and approved by the CAE subject to any consultancy activity being
deliverable within the boundaries of the role of Internal Audit and the resources available. 
In the event that there is a need for a greater audit work to provide the statutory audit opinions
than there are resources available, the CAE will identify the shortfall in the Plan and initially advise
the Chief Executive followed by the Audit Committee.  It will be for the Audit Committee to decide
whether to accept the risks associated with the non-delivery of such audit work or to recommend
to the Council that it requires Management to identify additional resources.  
NON-AUDIT ACTIVITIES
The Internal Audit service preserves its independence and objectivity by: ensuring that staff are
free from any conflicts of interest when undertaking assurance audits by following the
requirements of relevant professional bodies and HR policies; and providing clarity on duties
undertaken during audit consultancy engagements to ensure these do not impact on assurance
audits and do not impair its independence and objectivity.
APPROVAL
The Internal Audit Charter was reported to and approved by the Midlothian Council Audit
Committee at its meeting on 7 March 2023 and shall be subject to regular review by the CAE and
the Audit Committee. 
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Audit Committee
Tuesday 7 March 2023
Item 5.4 
Internal Audit Strategy and Annual Plan 2022/23 
Report by Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is invited to:
a) Note the changes to the Internal Audit Strategy outlined in section 4
of this report; 
b) Note the outline of the Internal Audit planning process outlined in
section 5 of this report;
c) Approve the Internal Audit Strategy (Appendix 1); and  
d) Approve the Internal Audit Annual Plan 2023/24 (Appendix 2). 
2 Purpose of Report/Executive Summary 
The purpose of this report is to gain approval from the Audit Committee
to the proposed Internal Audit Strategy and Annual Plan 2023/24 to
enable the Chief Internal Auditor to prepare annual opinions on the
adequacy of the overall control environment for Midlothian Council, and
Midlothian Health and Social Care Integration Joint Board (MIJB). 
The Internal Audit Strategy at Appendix 1 outlines the strategic
direction for how Internal Audit will achieve its objectives, which are set
out in the Internal Audit Charter, in conformance with PSIAS. It guides
the Internal Audit function in delivering high quality internal audit
services to Midlothian Council and the MIJB. 
The Internal Audit Annual Plan 2023/24 at Appendix 2 has been
developed by the shared Chief Internal Auditor and the Principal
Internal Auditor. It sets out the proposed range and breadth of audit
activity and sufficient work within the audit programme of work to
enable the Chief Internal Auditor to prepare the independent and
objective audit opinions for Midlothian Council and MIJB. A separate
Internal Audit Annual Plan 2023/24 for the MIJB will be presented to its
Audit and Risk Committee. Key components of the audit planning
process include a clear understanding of each organisation’s functions,
associated risks, and assurance framework. 
Date 24 February 2023 
Report Contacts
Duncan Stainbank, Chief Internal Auditor 
duncan.stainbank@midlothian.gov.uk     
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3 Background 
3.1 The Local Authority Accounts (Scotland) Regulations 2014 that came
into force on 10 October 2014 require a local authority to operate a
professional and objective internal auditing service. This service must
be provided in accordance with recognised standards and practices in
relation to internal auditing. Recognised standards and practices are
those set out in the 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 organisation. 
3.2 The Midlothian Council Internal Audit function follows the professional
standards as set out in Public Sector Internal Audit Standards (PSIAS)
effective 1 April 2013 (updated 2017) which requires the Chief Audit
Executive (CAE) to establish risk-based plans to determine the
priorities of the Internal Audit activity, consistent with the organisation’s
goals. The plans also require to be sufficiently flexible to reflect the
changing risks and priorities pertaining to each organisation. 
3.3 A fundamental role of the Council’s Internal Audit function is to provide
senior management and members with independent and objective
assurance, which is designed to add value and improve the
organisation’s operations. In addition, the CAE is also required to
prepare an Internal Audit annual opinion on the adequacy of each
organisation’s overall control environment. 
3.4 Internal Audit assurance resources and services are also provided by
Midlothian Council’s Internal Audit team to the Midlothian Health and
Social Care Integration Joint Board (MIJB), including the appointed
MIJB Chief Internal Auditor. The Internal Audit Charter and Strategy
are applicable to each organisation. 
4        Internal Audit Strategy 
4.1 The key standards within the PSIAS which relate to Managing the
Internal Audit Activity are summarised below:
“The chief audit executive must effectively manage the internal audit
activity to ensure it adds value to the organisation.
The internal audit activity is effectively managed when:
• The results of the internal audit activity’s work achieve the
purpose and responsibility included in the internal audit charter;
• The internal audit activity conforms with the Definition of Internal
Auditing and the Standards; and
• The individuals who are part of the internal audit activity
demonstrate conformance with the Code of Ethics and the
Standards.
The internal audit activity adds value to the organisation (and its
stakeholders) when it provides objective and relevant assurance, and
contributes to the effectiveness and efficiency of governance, risk
management and control processes.” 
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4.2 The Chief Internal Auditor (CAE) and the Principal Internal Auditor have
developed the Internal Audit Strategy at Appendix 1. It outlines the
strategic direction for how Internal Audit will achieve its objectives,
which are set out in the Internal Audit Charter, in conformance with
PSIAS. It guides the Internal Audit function in delivering high quality
internal audit services to Midlothian Council and Midlothian Health and
Social Care Integration Joint Board (MIJB). 
4.3 The Internal Audit Strategy, since its previous approval by the Audit
Committee on 14 March 2022, reflects the following:
• The implementation of the shared Internal Audit service with
East Lothian Council, and the associated change in approach for
the provision of Internal Audit resources;
• The prioritisation of audit activity on a risk basis from the cyclical
work to allow for appropriate utilisation of diminished Internal
Audit resources on the highest risk areas; and
• Greater clarity on the PSIAS requirement for an annual Internal
Self-Assessment and an External Quality Assessment (EQA),
the latter which is scheduled during 2023. 
4.4 The Internal Audit Strategy:
• Outlines the assurance framework, providing clarity of the
respective responsibilities of Management for designing and
monitoring governance and control systems and of the role of
Internal Audit in providing independent assurance thereon;
• States how the key themes which are integral to the assurance
gathering process across the organisation’s activities will be
covered to inform the annual Internal Audit opinion statement;
• Describes the approach to the development of the risk based
Internal Audit annual plan;
• Sets out the relative allocation of Internal Audit resources;
• Outlines how the Internal Audit programme of work will be
delivered to add value; and
• Describes the monitoring and reporting of the Internal Audit
findings from its work and progress with its plans to the relevant
organisation’s audit committee/board. 
5        Internal Audit Annual Plan 2023/24 
5.1 The key standards within the PSIAS which relate to the preparation of
the internal audit plan are summarised below:
• Standard 2010 – Planning which states that “the chief audit
executive must establish risk-based plans to determine the
priorities of the internal audit activity, consistent with the
organisation’s goals”
• Standard 2020 – Communication and Approval which states that
“the chief audit executive must communicate the internal audit
activity’s plans and resource requirements, including significant
interim changes, to senior management and the board for review
and approval. The chief audit executive must also communicate the
impact of resource limitations.” 
5.2 The CIPFA Publication ‘Audit Committees: Practical Guidance for Local
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should seek to make best use of the internal audit resource within the
assurance framework. In particular, the audit committee should seek
confirmation from internal audit that the audit plan takes into account
the requirement to provide an annual internal audit opinion that can be
used to inform the Annual Governance Statement. Specific activities
will include:
• Approving (but not directing) the risk-based plan, considering the
use made of other sources of assurance.” 
5.3 The CIPFA Publication also states that “The committee will wish to
seek assurance from the HIA that appropriate risk assessment has
been carried out as part of the preparation of the internal audit plans
when they are presented.” 
5.4 The Chief Internal Auditor (CAE) and the Principal Internal Auditor have
developed the Internal Audit Annual Plan 2023/24 at Appendix 2,
based on the Internal Audit staff resources set out in 6.1. It sets out the
proposed range and breadth of audit activity to be undertaken to
provide the independent and objective audit opinions to Midlothian
Council and MIJB. 
5.5 As part of the Internal Audit planning process it was necessary to
consider each organisation’s priorities, plans, strategies, objectives,
risks and mitigating controls, and the internal and external assurances
provided to determine the priorities of the Internal Audit activity
consistent with the organisation’s goals, as follows:
• Analysis was undertaken of Internal Audit work during the past 5
years against the Audit Universe which has been significantly
revised and realigned by the Principal Internal Auditor to reflect
the current strategic and operational management arrangements
and approach to service delivery to ensure appropriate coverage;
• The Strategic Risk Profile was checked to confirm coverage on
key strategic risks, as reliance is placed on the risk assessments
carried out by the Risk Owners taking account of the risk ratings
and mitigations; and 
• Account was taken of known external audit and inspection
activities to avoid duplication of assurance work. 
5.6 It is envisaged that 2023/24 will continue to be a year of change for the
Council and other partner organisations. Therefore the Internal Audit
Annual Plan 2023/24 should be considered to be flexible and will be
periodically reviewed, and amended as required, to reflect any new
arrangement or changing risks and priorities or available resources.
Any amendments relating to the Council will be brought to the
Corporate Management Team and the Audit Committee for approval. 
5.7 The Non MLC days reflect the Council’s partnership working
commitment to provide Internal Audit resource and services to the
Midlothian Health and Social Care Integration Joint Board (MIJB). A
separate Internal Audit Annual Plan 2023/24 will be presented to MIJB
Audit and Risk Committee for approval. 
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6 Report Implications (Resource, Digital, Risk and Equalities) 
6.1 Resource 
The Local Authority Accounts (Scotland) Regulations 2014 that came
into force on 10 October 2014 require a local authority to operate a
professional and objective internal auditing service. 
Internal Audit must have sufficient staff and other resources to enable it
to carry out the objectives of the Charter and to deliver a programme of
independent and objective audit assurance work alongside other
available sources of assurance to enable the Chief Audit Executive to
prepare annual opinions on the adequacy of the overall control
environment for Midlothian Council, and MIJB. 
The Internal Audit staff resource totalling 3.22 FTE comprises Chief
Internal Auditor (0.5 FTE), Principal Internal Auditor (0.72 FTE),
Internal Auditor (2.0 FTE). Each member of the current Internal Audit
team has a professional internal audit or accountancy qualification, and
has suitable experience, knowledge, skills and competencies (such as
the Code of Ethics set out in PSIAS and the Seven Principles of Public
Life) needed to deliver the Plan. After deduction for estimated annual
leave, public holidays, absence including staff turnover, learning and
development, and management and supervision, this equates to a total
of 522 days available for Internal Audit activity (2022/23 plan 751
days). 
The reduction in available days reflects the budget provision for the
staff and other resources set out above within the Revenue Financial
Plans which were approved by the Council on 21 February 2023. The
plans reflect the decrease in the budget available for Internal Audit and
whilst completion of the annual plan will be possible within the current
resources there is a risk of a lack of resilience in the Internal Audit
team, with any unplanned or additional work will result in elements of
the current plan becoming unachievable. 
6.2 Digital 
There are no digital implications arising from this report. 
6.3 Risk 
The Objectives of Internal Audit are set out in its Charter, including “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: As a contribution to the
Council’s corporate management of risk.” 
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Key components of the audit planning process include a clear
understanding of the Council’s functions, associated risks, and
potential range and breadth of audit activity for inclusion within the
plan. As in previous years, to capture potential areas of risk and
uncertainty more fully, reference has been made to the Strategic Risk
Profile and key stakeholders have been consulted. 
The PSIAS require Internal Audit to evaluate the effectiveness of the
Council’s Risk Management arrangements and contribute to
improvements in the process. The work of Internal Audit (including its
opinion on the control environment) shall contribute to the Council’s
review of its corporate governance arrangements the outcome of which
is published in the Annual Governance Statement. 
At all times, Management’s responsibilities (led by the Corporate
Management Team) include:
o Designing and maintaining proper risk management, governance
and internal control processes and systems for which they have
responsibility to ensure probity in systems and operations,
including the prevention, detection and resolution of fraud and
irregularities. These are not fixed but evolve as the Council
changes.
o Checking that these governance arrangements and internal
controls are operating effectively and obtaining assurances from
internal compliance, risk, inspection, quality, and control functions.
(The above are known as the first and second lines.)
o Engaging with Internal Audit (the third line) in a positive way to
achieve shared goals for robust internal control and governance,
best value and improvement, and ensuring that Internal Audit can
properly fulfil its role.
o Considering and acting upon Internal Audit findings and
recommendations, including implementation of audit
recommendations within agreed timescales and updating Pentana
performance system, or accepting responsibility for any resultant
risk from not doing so.
o Seeking advice and consultancy support from Internal Audit on
existing controls and on changes to and transformation of
governance, processes and procedures. 
6.4 Ensuring Equalities 
This report does not relate to a new or revised policy, service or budget
change, which affects people (the public or staff), so an Integrated
Impact Assessment (IIA) is not an applicable consideration. 
The Internal Audit work is carried out in accordance with the
appropriate legislation and professional standards. The latter includes
compliance by those within the Internal Audit function with the Code of
Ethics set out in the PSIAS. This is of particular importance and
relevance 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. 
6.5 Additional Report Implications (See Appendix A) 
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Appendices
Appendix A – Additional Report Implications
Appendix 1 – Internal Audit Strategy
Appendix 2 – Internal Audit Plan
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan to which Midlothian Council and its
Community Planning Partners have made a commitment (Reducing the
gap in economic circumstances; Reducing the gap in learning
outcomes; Reducing the gap in health outcomes; and Reducing the
impact of climate change), good governance is important to enable
Midlothian Council to deliver its key priorities in support of achieving the
Council’s objectives. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow
supported by the 9 drivers for change. Implementing the 9 drivers for
change in practice is applicable to the Council’s Internal Audit service
provision to assist the Council in achieving its objectives. 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
The definition of Internal Auditing within the Public Sector Internal Audit
Standards (PSIAS) is “Internal auditing is an independent, objective
assurance and consulting activity designed to add value and improve
an organisation’s operations. It helps an organisation accomplish its
objectives by bringing a systematic, disciplined approach to evaluate
and improve the effectiveness of risk management, control and
governance processes.” 
Internal Audit is a key element of good governance which is important
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Recommendations made by Internal Audit underpin 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 Audit Executive is accountable to the Audit Committee
which, in fulfilling its governance role, acts as a bridge between
the Council and other stakeholders. The Audit Committee remit
includes “To approve the risk-based internal audit plan, including
internal audit’s resources requirements, the approach to using other
sources of assurance and any work required to place reliance upon
those other sources”. 
The Executive Management Team has been consulted on the Internal
Audit resources, risk-based audit approach and the resultant planned
Internal Audit coverage to ensure it will provide assurance on controls
and governance relating to the key risks facing the Council and to
assist them in discharging their roles and responsibilities. 
A.6 Impact on Performance and Outcomes 
Applying the framework of the PSIAS will give the Audit Committee
assurance that the Internal Audit function is compliant with legislative
requirements and current best practice. 
The delivery of the Internal Audit strategy and annual plan assists the
Council in improving its performance and outcomes. 
A.7 Adopting a Preventative Approach 
The PSIAS are applicable from 1 April 2013 (amended 2017) which
means the Internal Audit Service has taken steps to be fully compliant. 
Specific audits within the 2023/24 plan will include assessments on
when a preventative approach can be adopted by the Council. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable
development. Internal Audit is a key element of good governance which
is important to enable Midlothian Council to achieve its objectives
including sustainable outcomes.
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INTERNAL AUDIT STRATEGY         APPENDIX 1 
1. AIM OF STRATEGY 
1.1. The aim of this strategy is to guide MLC Internal Audit function in delivering a high quality internal audit service
to Midlothian Council (MLC) and Midlothian Health & Social Care Integration Joint Board (MIJB), which is capable of: 
• providing the statutory annual assurance and audit opinion on the adequacy of each organisation’s risk
management, internal control and governance arrangements to the relevant organisation’s senior
management and board/audit committee; 
• carrying out all other objectives contained in Internal Audit’s Charter; and 
• adding value to each organisation by influencing and offering ways to enhance the governance and internal
control environment in alignment to their strategic priorities. 
2. STRATEGY OBJECTIVES 
2.1. The objectives of this strategy are to: 
• Outline the assurance framework which comprises assurances from within the organisation and from
external providers of assurance to improve the organisational understanding of the expectations of Internal
Audit; 
• State how the key themes which are integral to the assurance gathering process across the organisation’s
activities will be covered to inform the annual audit opinion statement; 
• Describe the approach to the development of the risk based Internal Audit annual plan; 
• Set out the relative allocation of Internal Audit resources; 
• Outline how the Internal Audit programme of work will be delivered to add value and will be prioritised to
ensure those areas of greatest risk are covered during the audit year; and 
• Describe the monitoring and reporting of the Internal Audit findings from its work and progress with its
plans to the relevant organisation’s audit committee/board. 
3. ASSURANCE FRAMEWORK 
3.1. It is Management’s responsibility to design and maintain proper risk management, governance and internal
control processes and systems to ensure probity in systems and operations, and mitigation of risks, including the
prevention, detection and resolution of fraud and irregularities. Management is also responsible for checking that
the arrangements and controls are operating effectively and obtaining assurances from internal compliance, risk,
inspection, quality, and control functions. These are known as the first and second lines. Internal Audit, as the third
line, is the review function which will provide independent assurance on the effectiveness of the first and second
lines of defence, challenge current practices, recommend best practice and improvements to lead to a
strengthening of the control environment and management of risks, thus assisting the organisation in achieving its
objectives. 
3.2. The organisation’s assurance framework is the means by which the relevant organisation’s Senior Management
and Audit Committee/Board ensures that they are properly informed on the risks of not meeting objectives or
delivering appropriate outcomes and that it has adequate assurances on the design and operation of systems in
place to mitigate those risks. 
3.3. The assurance framework comprises assurances from within the organisation (from Management and
compliance functions, and independent and objective assurance from Internal Audit) and from external providers of
assurance. Examples of the latter include the Accounts Commission, External Audit (Audit Scotland for MLC and
MIJB), Education Scotland, Care Inspectorate, Scottish Housing Regulator, and other regulators. 
3.4. The assurances are considered during the annual review of the effectiveness of each organisation’s overall
governance framework carried out by officers of each organisation and supported by Internal Audit. The output is
the Annual Governance Statement which is included within the relevant organisation’s Annual Report and Accounts. 
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3.5. Where audit assurance is required on services that are delivered jointly by public sector joint working
arrangements which include the organisation as a partner, these assurances will be sought as appropriate from
partners’ Internal Audit service providers and Management. 
4. KEY THEMES INTEGRAL TO INTERNAL AUDIT ASSURANCE 
4.1. Each organisation is responsible for ensuring that its business is conducted in accordance with the law and
proper standards, and that public money is safeguarded and properly accounted for, and used economically,
efficiently and effectively. Fundamentally corporate governance is about the systems and processes, and cultures
and values that are used by the organisation to discharge those responsibilities in a timely, inclusive, open, honest
and accountable manner. This includes: setting the strategic direction, vision, culture and values of the organisation;
effective operation of corporate systems; processes and internal controls; engaging with and, where appropriate,
lead communities; monitoring whether strategic objectives have been achieved and services delivered cost
effectively; and ensuring that appropriate arrangements are in place for the managing risks. 
4.2. The organisation’s statutory financial officer, Section 95 Officer or equivalent, i.e. Acting Chief Financial Officer
(MLC) and Chief Finance Officer (MIJB), is responsible for the proper administration of the organisation’s financial
affairs. Under his/her direction, the organisation’s system of internal financial control is based on a framework of
Financial Regulations (rules and regulations for financial management or administration arrangements linked to
other key financial documents that set out the policy framework, associated strategy, and the more detailed
procedures and guidelines), regular Management Information, administrative procedures (including segregation of
duties), Management Supervision, and a system of Delegation and Accountability. 
4.3. The continued use of and investment in technology to support service delivery, and digital change and
transformation to improve operations is a key part of the vision for each organisation. Arrangements in place are
underpinned by the overarching framework of the ICT security policy designed to ensure that computer systems are
secure, reliable and conform to nationally agreed standards, and by the ICT Strategy linked to Corporate Priorities
designed to support effective and modern service delivery and to meet service objectives. 
5. APPROACH TO PERIODIC PLANNING 
5.1. The Internal Audit Strategy and the Internal Audit Annual Plan 2023/24 have been prepared in conformance
with the Public Sector Internal Audit Standards (PSIAS) to fulfil the requirement to produce the statutory annual
assurance and audit opinion for each organisation. 
5.2. As part of the Internal Audit planning process it was necessary to consider each organisation’s priorities, plans,
strategies, objectives, risks and mitigating controls, and the internal and external assurances provided to determine
the priorities of the Internal Audit activity consistent with the organisation’s goals, as follows: 
• Analysis was undertaken of Internal Audit work during the past 5 years against the Audit Universe, which
has been significantly revised and realigned to reflect the current strategic and operational management
arrangements and approach to service delivery, to ensure appropriate coverage; 
• The Strategic Risk Profile was checked to confirm coverage on key strategic risks, as reliance is placed on the
risk assessments carried out by the Risk Owners taking account of the risk ratings and mitigations; and 
• Account was taken of known external audit and inspection activities to avoid duplication of assurance work. 
5.3. The audit planning process involves consultation with key stakeholders including discussions with Senior
Management of each organisation to capture potential areas of risk and uncertainty more fully. This is of particular
importance during a period of change and transformation as each organisation responds to new legislation or
service delivery arrangements that might affect plans, priorities and resources. 
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6. ALLOCATION OF INTERNAL AUDIT RESOURCES 
6.1. The Internal Audit staff resource totalling 3.22 FTE comprises Chief Internal Auditor (0.5 FTE), Principal Internal
Auditor (0.72 FTE), Internal Auditor (2.0 FTE). Each member of the Internal Audit team has a professional internal
audit or accountancy qualification, and has suitable experience, knowledge, skills and competencies (such as the
Code of Ethics set out in PSIAS and the Seven Principles of Public Life) needed to deliver the plan. The Available Days
has been amended to reflect the Internal Audit resources after consideration of estimated annual leave, public
holidays, absence including staff turnover, learning and development, and management and supervision. 
6.2. It is estimated that around 80% of Available Days will be spent on assurance, and legislative and other
compliance activities combined. The Assurance work includes sufficient work across a range and breadth of audit
areas which assure those processes that are currently in place and which Management rely on to deliver services,
and to enable preparation of the required annual audit opinion on the adequacy of the organisation’s control
environment. 
6.3. An estimate of 10% of Available Days will be spent on Other activities in support of the Internal Audit function
meeting its wider objectives as set out in the Internal Audit Charter. 
6.4. An estimate of around 4% of Available Days will be utilised on Consultancy activities which support
Management in delivering innovation, change and transformation. Management seek this value added activity
during this unprecedented period of change for Local Government though this allocation reflects a reasonable
estimate of what is actually deliverable within the boundaries of the role of Internal Audit and the resources
available. 
6.5. It is estimated that around 6% of Available Days will be spent on the provision of Internal Audit services to
Midlothian Health and Social Care Integration Joint Board (MIJB). This reflects MLC’s contribution of support
resources as governance arrangements have changed in response to statutory partnership working for the provision
of health and social care integration. 
7. APPROACH TO DELIVERY OF PROGRAMME OF WORK 
7.1. To facilitate operational delivery an Internal Audit Programme of Work will be developed which provides an
indication of when work will be scheduled during the year, taking account of discussions with Senior Management
and the availability of Internal Audit resources. 
7.2. For each Assurance audit, in line with recognised good practice, an Audit Assignment detailing the scope,
objectives and timing will be prepared and agreed with the relevant Chief Officer/Head of Service and Manager
prior to commencement of Internal Audit fieldwork. Within assurance work: 
• The organisation’s Local Code of Corporate Governance (MLC/MIJB) will be used by Internal Audit as an
integrated toolkit to test the extent of compliance. 
• End to end reviews of financial management and administration processes will be undertaken by Internal
Audit to test the extent of compliance (as integral part of protecting public finances, safeguarding assets,
and delivering services effectively and sustainably), and substantive testing of transactions including data
analytics will be carried out to ensure completeness and accuracy. 
• The Plans (Financial and Asset Management) to deliver the organisation’s strategies, plans and priorities will
be reviewed against best practice standards. 
• Internal Audit will consider fraud risk and prevention and detection controls, and other appropriate cross-
cutting risks and controls (such as risk management, performance management, community engagement,
equalities, business continuity, and health and safety), highlight examples of effective internal controls, and
share good practice across service areas. 
• The ICT arrangements in place to protect each organisation from attack in relation to data security, integrity
and availability will be tested and ICT Plans will be reviewed to confirm they support delivery of the
organisation’s strategies and priorities. 
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• National reports that give rise to introducing best practice arrangements or lessons learned from other local
authorities or other public sector bodies will be considered and applied by Internal Audit to influence and
offer ways to enhance governance and internal controls. 
7.3. The Legislative and Other Compliance work will include testing in accordance with the terms of the funders’
service level agreements or legislative requirements, as part of the wider assurance framework. 
7.4. Within Consultancy activities Internal Audit will add value to the Council as it transforms its service delivery
models, re-designs its business processes, and utilises technology to automate processes by influencing and offering
ways to ensure adequate governance, risk management and internal controls. Internal Audit in its ‘critical friend’
role will provide an independent view and challenge of a sample of programmes and projects, and an objective
assessment of self-evaluation arrangements and improvement that underpin the provision of Best Value. 
7.5. Other work will include: 
• Carrying out Follow-Up to monitor Management’s progress with implementation of Audit recommendations
to: ensure that improvement actions have been timeously and effectively implemented; check that these
have had the desired effect to manage identified risks; and demonstrate continuous improvement in
internal control and governance. To facilitate the Internal Audit follow-up activity, Audit recommendations
will continue to be input to Pentana, the corporate performance management system, to assist relevant
Management in tracking and recording their implementation in a consistent way; 
• Performing potentially high risk Contingency audits, investigations and review of issues highlighted during
the year that may be the result of a weakness in internal controls or that may be requested by Management
or the Audit Committee; and 
• Delivering the Help Desk Facility where Internal Audit guidance and advice is given to Management on
internal controls. 
8. MONITORING THE WORK OF INTERNAL AUDIT 
8.1. The Public Sector Internal Audit Standards (PSIAS) requires periodic reporting on the Internal Audit activity to
the relevant organisation’s Senior Management and Audit Committee/Board. 
8.2. Internal Audit assurance work completed and work in progress, and consultancy and other work for the Council
associated with the delivery of the Plan will be outlined within regular reports to its Audit Committee. Specifically
relating to Internal Audit assurance work, this report will include an Executive Summary of the audit objective, good
practice, findings, recommendations, and audit opinion of assurance for each Final Internal Audit Report issued to
relevant Senior Management in the period. 
8.3. Regular progress updates on implementation by Management of relevant Audit recommendations will be
reported periodically during the year to the relevant organisation’s Senior Management and Audit
Committee/Board. 
8.4. Internal Audit’s compliance with its Strategy, delivery of its risk-based Annual Plan, and outcomes of
assessment(s) against Public Sector Internal Audit Standards (PSIAS) will be considered by the Chief Internal Auditor
on a regular basis and formally reported every six months to the Council’s Corporate Management Team and the
Audit Committee, through a Mid-Term Performance Report and within the Annual Assurance Report. 
8.5. The Internal Audit Annual Assurance Report for each organisation (Midlothian Council and MIJB) to their
respective Senior Management and Audit Committee/Board will provide the statutory annual audit opinion on the
levels of assurance based on Internal Audit findings over the year to inform each organisation’s Annual Governance
Statement. 
8.6. The PSIAS requires an annual Internal Self-Assessment and an External Quality Assessment (EQA) each five years
by appropriately qualified and independent reviewers to assess conformance with the Definition of Internal Auditing
and Standards and the application of the Code of Ethics. The Scottish Local Authorities Chief Internal Auditors Group
(SLACIAG) have implemented a “peer review” framework, in which MLC participates, as a cost effective means of
complying with the EQA requirement. Reporting on outcomes includes a statement on conformance with PSIAS and
the quality assurance and improvement plan (QAIP) to enable an evaluation of the Internal Audit quality
management framework and to identify opportunities for improvement. 
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Internal Audit Annual Plan 2023/24        Appendix 2
Category Activity Days Commentary
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.
Assurance -
Risk
Growing Council,
Budgeting for
Growth
30 Review the approach to including Population
and infrastructure growth into future budget
requirements across Council Services. 
Assurance -
Risk
Workforce
Planning
30 Review of the strategy for recruitment,
retention and training of employees across
the Council, including a review of changes
made in relation to new ways of working. 
Assurance -
Cyclical
Care Homes,
Council and
Private. 
20 Review of the arrangements in place to
manage the process of utilising appropriate
bed spaces within care homes and the
monitoring and control mechanisms in place
to ensure quality care and best value. 
Assurance -
Cyclical
Council Tax
Discounts and
Exemptions
20 Review the processes in place to ensure that
the Council is providing the appropriate
Council Tax discounts and exemptions to
those households with an entitlement to
these discounts and exemptions whilst
preventing any error or fraud. 
Assurance -
Risk
IT Audit  30 Review Core IT controls following a more
detailed review of the current control
environment with the It teams to establish
best use assurance resources between
Internal and External Audit. 
Assurance -
Risk
Developer
Contributions 
30 Review the processes in place to ensure that
appropriate contributions are received for
Infrastructure as a result of Housing
Development and the governance, Control
and risk management processes in place to
ensure that the calculations for the value of
contributions to be received are based on
accurate and complete information.  
Category Activity Days Commentary
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Assurance -
Risk
Children's
Services
Continued Care
30 Review the processes around continuation of
care for looked after children. 
Assurance -
Cyclical
Payroll 20 Review the processes in place to ensure
complete, accurate and timely payment of
Council staff (including Teachers payroll) in
accordance with the Contractual terms and
Conditions of the employees.  
Assurance -
Risk
Absence &
Performance
Management 
30 Review the operation of the systems in place
for monitoring of absence to ensure
maintenance of staff wellbeing in new
working environments and capacity for service
delivery. Review the operation of
performance management processes across
the Council following COVID recovery. 
Assurance -
Cyclical
Licensing 20 Review the policies, processes and procedures
in place to ensure the effective licensing
services are in place and subject to effective
governance. 
Assurance -
Risk
School Budgets
Devolved School
Management
(DSM)
30 Review of internal financial controls and
business administrative procedures in place
and data analytics of expenditure (DSM, PEF
and other Funds including Schools Funds) to
ensure the efficient and effective use of
resources in the school establishments, to
complement the assurance received from
Education Scotland arising from their
inspection programme of schools.
Assurance -
Risk
Property assets
and property
strategy
20 Review the processes of developing a
property asset management strategy and the
governance of the implementation. 
Assurance -
Risk
Risk Management 20 Review the Risk Management governance and
control arrangements across the Council to
ensure that they are providing, good quality,
timely, complete and accurate reporting to all
senior management, council members and
other stakeholders Council risk information. 
Consultancy Consultancy  20 In its ‘critical friend’ role provide: an
independent view and challenge of a sample
of programmes and projects (including
Learning Estate Strategy, Business
Transformation Board, Information
Management Group); and an objective
assessment of self-evaluation arrangements. 
Category Activity Days Commentary
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Other 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.
Assurance -
Cyclical
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. 
Other Contingency  20 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.
Other Help Desk Enquiry
system 
20 Provide guidance and advice to Management
and Staff on internal controls. Manage any
enquiries received through the whistle-
blowing facilities offered by the Council. 
Other 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. 
Other Risk Management
Group
5 Attend and provide support to the Risk
Management Group, the Serious and
Organised Crime Group, and the Integrity
Group.
Other MLC Attendance
at Boards /
Committees
10 Prepare for and attend Audit Committee
meetings and other Boards/Committees as
relevant.
Other 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.
MIJB
Assurance
Midlothian Health
and Social Care
Integration Joint
Board
40 Audit reviews and support to be determined
and agreed by the Midlothian Health and
Social Care Integration Joint Board Audit and
Risk Committee for review of the adequacy of
the MIJB’s arrangements for risk
management, governance and internal control
for delegated resources.    
Total Days 2023/24 522 
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