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Agenda Document Pack - Audit Committee - 29/01/2024

Midlothian Council · 29 January 2024
Back to Audit Committee — 29 January 2024 and its agenda

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Page 1

Notice of Meeting and Agenda 
Audit Committee 
Venue:  Council Chambers/Hybrid, 
Midlothian House, Dalkeith, EH22 1DN 
Date:  Monday, 29 January 2024 
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 Meeting of 30 October 2023 - submitted for approval 3 - 12
4.2 Minute of the Special Meeting of 5 December 2023 - submitted for
approval
13 - 20
4.3 Action log 21 - 22 
5          Public Reports
5.1 Treasury Management and Investment Strategy 2024/25 U
Prudential Indicators – Report by Chief Financial Officer
23 - 104
5.2 Follow-Up Review of Completed Internal Audit Recommendations
– Report by Chief Internal Auditor
105 - 116
5.3 Internal Audit Mid-Term Performance Report 2023/24 – Report by
Chief Internal  Auditor
117 - 128
5.4 Internal Audit Work to December 2023 – Report by Chief Internal
Auditor
129 - 142
5.5 Lease of Retail Premises Burnbrae Road Bonnyrigg – Report by
Chief Internal Auditor
143 - 148 
6          Private Reports 
No items for discussion 
7          Date of Next Meeting 
The next meeting will be held on Monday, 18 March 2024 at 11:00am. 
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Minute of Meeting 
Audit Committee 
Date Time Venue
Tuesday 30 October 2023 2.00 pm Council Chamber/Hybrid 
Present:
Councillor Smaill (Chair)
Councillor Bowen
Councillor McCall
Councillor McEwan
Councillor Russell (substitute) 
In Attendance:
Grace Vickers Chief Executive
Alan Turpie Legal and Governance Manager/Monitoring Officer
Kevin Anderson Executive Director Place
Fiona Robertson Executive Director Children, Young People & Partnerships
Derek Oliver Chief Officer Place
David Gladwin Chief Financial Officer 
Duncan Stainbank  Chief Internal Auditor
Janet Ritchie Democratic Services Officer
Hannah Forbes  Democratic Services Assistant 
Audit Committee
Monday 29 January 2024
Item No: 4.1 
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1. Welcome and Apologies for Absence 
The Chair welcomed Claire Gardiner and Paticia Fraser, Audit Scotland and
intimated apologies on behalf of Councillor Milligan and welcomed Councillor
Imrie who would be substituting for Councillor Milligan.
The Chair drew the committee’s attention to the issues with today’s meeting
and that the accounts had been circulated late but also highlighted that the
agenda pack had been published but then was not available due to a technical
issue but considering that the deadline for the accounts was 31 October 2023
+and the fact that the bulk of the accounts had been published in June in the
interest of the council and the public that all the matters are considered today
including the prior minutes of the previous meeting and unless anyone has a
different view on that basis the meeting would proceed.
2. Order of Business 
The order of business was as detailed in the agenda previously circulated. 
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 7 March 2023, carried over from the last meeting
was submitted and approved as a correct record. 
4.2 The minute of the meeting of 26 June 2023 was submitted and approved as a 
correct record. 
4.2 The Action log was submitted and noted. 
1. Responsible Treasury Management:  ongoing
2. Internal Audit Mid-Term Performance Report 2022/23: Completed 
3. Internal Audit work to February 2023: Recommended for Closure
4. Internal Audit Work to February 2023: Recommended for Closure 
5. Internal Audit Work to May 2023: Recommended for Closure. 
6. Unaudited Accounts 2022/23:  Recommended for Closure. 
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5. Public Reports 
Report No. Report Title Submitted by:
5.1 Annual Audit Report to Members and the
Controller of Audit - year ended 31 March
2023
External Auditors
Outline of report and summary of discussion
This report summarises the findings from the 2022/23 annual audit of Midlothian
Council (the Council). The scope of the audit was set out in an annual audit plan
presented to the June 2023 meeting of the Audit Committee. Audit appointment
from 2022/23. 
Claire Gardiner apologised for the delay in receiving the reports and thanked the
committee for their patience.  Ms Gardiner then explained the approach to the
reporting and that normally at this stage the committee would receive a much
longer annual audit report but to preserve the quality of the audit it has been split
with a fuller audit report coming to the next meeting which will include the wider
scope and best value and that the audit report presented to today’s meeting
would focus on the annual accounts and accounts process. 
Ms Gardiner proceeded to present the annual audit report to members
highlighting the first report brings conclusion of the audit and highlights that there
was an unmodified opinion which was attached as appendix A to this report and
advised that there were no issues to highlight.  Ms Gardiner also advised that
there were two unadjusted errors highlighted in this letter and full details are
contained within Appendix 2 to the audit report.  Ms Gardiner also drew the
committee’s attention to Appendix B which was a letter of representation and
highlighted the main sections within the letter and asked that before approving
this letter, committee members are asked to consider their knowledge of any
frauds, non-compliance with laws and regulations or post balance sheet events. 
In response to a question raised by Councillor Smaill with regards to adjustments,
Ms Gardiner provided clarity with regards to adjustments which were included in
the annual accounts and would be covered in the next section and the
adjustments which were not included were just above the triviality level so would
not expect any adjustments to be made.  Mr Gladwin also provided some clarity
on the two unadjusted errors.    Following this discussion Ms Gardiner confirmed
that the officers of the Council were clear to sign off these accounts.
Ms Gardiner presented the Audit of 2022/23 annual accounts highlighting in her
introduction that they were independent throughout the audit and that they comply
with the Financial Reporting Council’s Ethical Standard.  Ms Gardiner also
highlighted that they intend to issue an unmodified audit opinion and provided a
brief overview of the Exhibits covering Materiality values (Exhibit 1); Significant
findings and key audit matters (Exhibit 2); Significant risks of material
misstatement (Exhibit 3); Identified areas of audit focus (Exhibit 4) and key
findings from review of key controls (Exhibit 5).
The Chair thanks the external auditors for all their work. 
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Decision
The Audit Committee approved the letter of representation was signed and
returned with the signed annual accounts.
Action
Section 75 Officer/External Auditors 
Report No. Report Title Submitted by:
5.2 Annual Accounts for the year ended 31
March 2023
Chief Financial
Officer & Section 95
Officer 
Outline of report and summary of discussion
The purpose of this report was to present the Council’s audited Financial
Statements for 2022/23 to Audit Committee and to provide a brief overview of
findings during the audit process. 
Mr Gladwin, Chief Financial Officer & Section 95 Officer presented this report to
the committee outlining the main changes to the accounts from those reviewed at
the Audit committee in June 2023 and highlighting the work undertaken to finalise
the accounts.  Mr Gladwin commented that Audit Scotland had indicated that the
working papers submitted to them to support the accounts were of a good
standard and colleagues within finance and across the council provided good
support to the Audit team.  Mr Gladwin expressed his personal thanks to the
finance team for their dedication and hard work. 
Mr Gladwin in responding to a question raised by the Chair with regards to the
impact of the new interest rate, advised on the commitment to pay interest below
the level currently on the market and confirmed that we have a positive treasury
position with long term loans at an attractive interest rate and if the council were
to repay one of those loans early there would be a financial benefit from doing so 
and that was what was reflected in the fair value but the council would then have
to replace that borrowing which would have a net financial hit on the council rather
than a benefit. 
The Chair asked the Chief Finance Officer to comment on the ratio of finance
costs to net revenue stream which measures how affordable the council’s capital
plans are and the 0.38% figure.   Mr Gladwin confirmed that the ratios in context
of the capital plan prioritisation discussions are currently higher and will continue
to go up as we add to the capital plan and provided an explanation on the two
ratio rates presented in the table was due to the financial flexibility the council
took advantage of in 2021/22 and 2022/23 and advised that these rates will go up. 
The Chair further raised movement on the housing revenue account and the
valuation of the council’s stock and the impact this has on the council.  In
responding Mr Gladwin confirmed that this has no impact on the operation of the
revenue account and provided an explanation on the movement which was due
to revaluation of the housing stock in 2021/22 which resulted in an increase to the
overall stock and in 2022/23 due to an increased discount rate this showed a
reduction.
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Page 7

The Chair referred to the table which shows a spend on housing and asked if the
council was building houses competitively to the private market.  Mr Gladwin
advised on the increase in stock and the value of the capital expenditure and that
it reflects a large amount of work in progress and the two big factors which have
affected this are inflation and build costs and the standard of these builds.   
Mr Gladwin in responding to a question raised by the provost confirmed that the
Croyden loan was paid in full, and all interest obligations were met.  Mr Gladwin
further confirmed that the council has not deposited money with any local
authorities for a long time and post-meeting confirmed for the minute that there
are currently no local authority deposits in place. 
Mr Gladwin in responding to comments made by Councillor Imrie and the Chair
with regards to the growth in Midlothian and the impact on the council and the
services it provides and the grant received from the Scottish Government,
advised that later this year we will be advised on the up to date Scottish
government grant based on the updated methodology which reflects the statistics
which have come out of the census and other regular statistics and expects
Midlothian to receive a higher share of the national pot.  He further advised to
support this he will pulling together an analysis of the grant over the last two or
three years looking at the statistical measures on each of the grants to try and get
an understanding of key statistics that are affecting us as a council and will bring
back a report to council.  He further confirmed that the figures should have been
updated to reflect the latest population and confirmed there has been subsequent
information provided so apologised that this had not been updated but assured
the committee that they are looking at the growth information and discussions are
ongoing. 
Councillor Bowen raised a question in relation to capital projects and any trigger
mechanism in place if a capital project was going over budget and also enquired
if it would be appropriate to have two Councillors on the Capital Plan Asset
Management board which was at present entirely officers.  Mr Gladwin in
responding advised that there were several gateways and controls in place if
expenditure exceeded the prescribed measures laid out and that automatic
reporting was triggered which ensures this was identified at an early stage and
then reported to council and also reviewed at the Capital Plan Asset Management
board.   Mr Gladwin in responding to a follow up question by the Chair confirmed
the difference between capital expenditure which relates to a cash amount and
the valuation of an asset which was done on a different basis and would not be a
cash adjustment. 
Mr Anderson provided clarity on the remit of Capital Plan Asset Management
board which was an officer forum and advised that any projects which come
through this forum that are not externally funded are reported to council either in
the governance reporting or as a standalone item therefore Members are
involved and in terms of the capital plan prioritisation Members are fully involved
in the different sessions which have been taking place and the regular updates to
the Business Transformation Steering Group.   
Further discussion took place on the reporting of any overspends and the
governance route for this being reported to Members.  The Chair suggested that
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Page 8

this was taken away and brought back following further discussions within the
individual groups. 
Decision
The Audit Committee: 
• Agreed that Members would discuss the governance arrangements in place
for reporting any capital projects overspends within their individual groups and
provided further feedback to officers.
• Approved the 2022/23 audited accounts for signature considering the
appointed auditor’s report for 2022/23.
Action
Elected Members/Executive Director, Place and Chief Financial Officer/Section 95
Officer 
Report No. Report Title Submitted by:
5.3 Risk Management Update – Strategic
Risk Profile Quarter 1 2023/24
Chief Officer Place
Outline of report and summary of discussion
The purpose of this report was to provide Audit Committee with: 
•  An update on the risk responses Midlothian Council has 
implemented during Q1 2023/24 to respond to the current risk 
climate 
•  Assurance that Midlothian Council took a proportionate and 
planned approach to prepare and respond to the current risk 
climate 
•  The risk evaluation of current strategic risks and opportunities 
for the Council 
Mr Oliver, Chief Officer Place presented this retrospective report highlighting that
this report provides the risk landscape and organisational response to the most
significant risks faced by the Council in Q1 in 2023/24.  He further advised that
Section 3 of the cover report provides a summary of risk responses and
evaluations.
The Chair proposed that specific risks were identified on the two major projects
that this council has that other councils don’t have, Hillend and Lothian Energy
acknowledging that there are reporting mechanisms in place for Hillend but there
has been some delays in this project and also suggested that following on from
the announcement that there may be a council tax freeze next year that this is
expanded on within the report that we may not have the flexibility of increasing
the council tax in 2024/25. 
The provost also expressed her agreement to these suggestions being added to
the risk report.
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The provost further commented on the Strategic issues and raised why Brexit
was a high and not critical risk.  Mr Oliver advised that this was monitored and
advised on the Economic Recovery Plan and also the ambitious plan for the next
5 years and the organisational impact to the Council. 
Following on from a further question raised by the provost Mr Oliver advised that
in terms of the pandemic this hit everyone and in terms of Midlothian Council’s
response the emergency plans kicked in and that the impact of this had been
captured in various risks.  He further advised that a pandemic plan was in place
and provided an explanation on why this was now considered low impact on the
council.  
Councillor McEwan raised questions with regards to delays to Hillend and the
exposure risk with loss of income and if the council had any compensatory
claims to the companies who are holding up the delays.  Mr Stainbank advised
on proposed internal review which would start once there was a solution to the
current delay problems as this would allow them to assess how the processes
worked thereafter.  Mr Anderson advised that he was limited on what he could
report but scrutiny was given to the situation.
The Chair congratulated and thanked Mr Oliver for the work after the severe
weather in clearing the drains at Fala and Fala Dam and the provision of
sandbags.
Decion
Audit Committee noted the current risk landscape and organisational response
to the most significant risks in Quarter 1 (Q1) 2023/24 (1 April to 30 June 2023). 
Report No. Report Title Submitted by:
5.4 Audit Committee Annual / End of Term
Report 2022/23
Chair of the Audit
Committee
Outline of report and summary of discussion
The purpose of this report was to provide Members with the Audit Committee
Annual / End of Term Report 2022/23, which sets out how the Audit Committee
has performed against its remit and the effectiveness of the Audit Committee in
meeting its purpose based on the annual self-assessments of the Committee
against best practice and provides assurances to the Council. 
It was important that the Council’s Audit Committee fully complies with best
practice guidance on Audit Committees to ensure it can demonstrate its
effectiveness as a scrutiny body as a foundation for sound corporate governance
of the Council. 
The Chartered Institute of Public Finance and Accountancy (CIPFA) Audit
Committees Practical Guidance for Local Authorities and Police 2022 Edition
(hereinafter referred to as CIPFA Audit Committees Guidance) includes the
production of an annual report on the performance of the Audit Committee for
submission to the Council. The Audit Committee Annual / End of Term Report
2022/23 was appended to this report as Appendix 1 for consideration. Midlothian
Council adopts the 2022 revisions to this best practice.
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The Chair in presenting this report highlighted some of the key points of the report
including the good attendance, the checklist and training provided to members
and commented very positively on the session on internet IT security with Ian
Wragg Wragg which was very informative.
Decision
The Audit Committee approved the Audit Committee Annual / End of Term Report
2022/23 (Appendix 1) and its self-assessments using the CIPFA Audit
Committees Guidance (Appendices 2 and 3) and agreed that the Audit Committee
Annual / End of Term Report 2022/23 should be presented to the Council.
Action
Chair of the Audit Committee 
Report No. Report Title Submitted by:
5.5 Internal Audit Work to September 2023 Chief Internal Auditor
Outline of report and summary of discussion
The purpose of this report was 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 2023/24 was approved by the Audit Committee on
7 March 2023. 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, was shown in Appendix 1. 
The Internal Audit function conforms to the professional standards as set out in
Public Sector Internal Audit Standards (PSIAS) (2017) including the production of
this report to communicate the results of the reviews. 
The Chief Internal Auditor presented this report outlining the main sections in the
report highlighting a summary of the key findings and recommendations as set out
in the report. 
In response to a question raised by the Chair with regards to payments made by
cash in one of the libraries and no option to pay by card,  the Chief Internal
Auditor and the Executive Director Place confirmed that the aim was to be a
cashless council but at the moment this was not always possible in some of the
services the council provides but the council will continue to be digital by default
and roll this out where effective. 
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Mr Stainbank in responding to a question raised by the Chair with regards to the
implications of the loss of collection of council tax confirmed from that the audit
work there would not be a figure for this but the expectation was that the longer it
takes the more difficult it was to collect and that this was not on the audit plan at
present but if required collectability could be considered.
Decision 
The Audit Committee: 
a)  Considered the Executive Summaries of the final Internal Audit
assurance reports issued associated with the delivery of the approved
Internal Audit Annual Plan 2022/23 and 2023/24;
b)  Noted the Internal Audit Consultancy and Other Work carried out in
accordance with the approved Internal audit Charter; and
c)  Acknowledged the assurance provided on internal controls and
governance. 
Report No. Report Title Submitted by:
5.6 Council House Building Programme -
Progress Update 2023
Executive Director,
Place
Outline of report and summary of discussion
Following presentation to Council on 10 October 2023, this report updates the
Audit Committee on the status of the overall housing programme, on approved
sites and proposed new sites for the Council new build affordable housing
programme and other initiatives. 
The Executive Director Place, Kevin Anderson confirmed that this paper had been
considered at council and outlined the main sections as contained within the
report and the factors contributed to the delays in the housing programme. 
In responding questions raised by the Chair with regards to the cost of passive
housing to non-passive housing and option of purchasing existing properties to
refurbish, Mr Anderson provided an explanation on the standards which are
required and the reasons why they tend to purchase previous council properties
and confirmed that are options with new builds under Section 75 requirements but
highlighted that the private sector do not have to comply with the energy
efficiencies for Scottish social housing.   
Mr Anderson in responding to questions raised by Councillor McEwan confirmed
that there were 6 passive houses in the Buccleuch street development and 4
flatted developments which were not passive house as they were existing
properties.  Mr Anderson also confirmed that they would provide a breakdown of
detail with regards to properties and would provide this detail at the workshop
session arranged.  With regards to the question raised on asset register and
appropriate values   Mr Anderson advised that this was a pilot project and beyond
individual cost this will be reviewed in a year’s time for total cost and benefit to the
individual, he also advised that the total cost value will have a variation, and this
will be considered with insurers and valuers. 
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Action:  Mr Anderson to report back in due course on the actual cost per unit of
the 10 houses within the Buccleuch Street development. 
Councillor Imrie raised a question with regards to the cost of passive house
standards and if this was reflected in the rent.  In response Mr Anderson advised
that there was a premium applied for new developments for the first 10 years
supplement to the rent but there was no additional levy in terms of it being a
passive house.    
Mr Anderson in responding to a question raised by Councillor Imrie regarding
ongoing costs to the council, confirmed that there will be additional ongoing
revenue costs that the council as the landlord will have.  Mr Oliver also confirmed
the ongoing costs to the building maintenance with regards to training
requirements.
Councillor Bowen commented on using the word delivered which indicates they
are complete, but this is not the case and asked if this could this be made clearer. 
In responding Mr Anderson advised with regards to terminology this will be made
clearer in future reporting and provided an explanation on the different variations
on housing completions.
Mr Anderson in responding to a further question from the Chair with regards the
Newbattle site and the cost implications in future for having to purchase land for
passive housing, advised that there may be additional cost but there will also be
benefits from these and with the expertise and timescales in delivering this should
also reduce the unit cost.  
Decision
Audit Committee: 
a)  Noted the content of this report and the progress made on
Phases 2 to 5;
b)  Noted the sites now underway to complete Phase 4 and Phase
5, projected handover programme and progress related to Open
Market Purchases;
c)  Noted the potential Phase 5 sites currently under consideration
to progress; and
d)  Noted the projected costs/budget expenditure in this report. 
6. Private Reports 
None 
7. Date of Next Meeting 
Date of Next Meeting: Tuesday 29 January 2024 at 11am. 
The meeting terminated at 15.30 pm
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Minute of Meeting 
Audit Committee – Special meeting 
Date Time Venue
Tuesday 5 December 2023 11:00am Council Chamber/Hybrid 
Present:
Councillor Milligan (Chair)
Councillor Smaill
Councillor Bowen
Councillor McCall (MS Teams) 
Councillor Imrie (substitute for Councillor McEwan) 
In Attendance:
Grace Vickers Chief Executive
Kevin Anderson Executive Director Place
Nick Clater Head of Adult Services
Alan Turpie Legal and Governance Manager / Monitoring Officer
David Gladwin Chief Financial Officer 
Gary Thomson Senior Finance Officer
Duncan Stainbank  Chief Internal Auditor
Derek Oliver Chief Officer Place
Saty Kaur Chief Officer Corporate Solutions
Claire Gardiner Audit Scotland
Patricia Fraser Audit Scotland
Robert Dick Audit Scotland
Janet Ritchie Democratic Services Officer 
Audit Committee
Monday 29 January 2024
Item No: 4.2
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1. Welcome and Apologies for Absence 
The Chair took the opportunity to welcome those in attendance to the meeting.  
Apologies were intimated on behalf of Councillor McEwan, and that Councillor
Imrie was in attendance as substitute.
2. Order of Business 
The order of business was as detailed in the agenda. 
3. Declarations of interest 
No declarations of interest were intimated at this stage of the proceedings. 
4. Minutes of Previous Meetings 
No previous minutes were submitted to this meeting. 
5. Public Reports 
Report No. Report Title Submitted by:
5.1 Annual Audit Report to Members and the
Controller of Audit year ended 31 March
2023.
Audit Scotland
External Auditors
Outline of report and summary of discussion
This report summarises the findings from the 2022/23 annual audit of Midlothian
Council (the Council). The scope of the audit was set out in an annual audit plan
presented to the June 2023 meeting of the Audit Committee. 
This Annual Audit Report comprises:
• significant matters arising from an audit of Midlothian Council’s annual
accounts.
• conclusions on the following wider scope areas that frame public audit as
set out in the Code of Audit Practice:
o Financial Management
o Financial Sustainability
o Vision, Leadership, and Governance
o Use of Resources to Improve Outcomes. 
• conclusions on Midlothian Council’s performance in meeting its Best Value
duties.
Claire Gardiner, Audit Scotland presented this report advising that this report
concludes the 2022/23 audit work, and that section 1 was previously presented to
the committee along with the annual report and that today the focus would be the
wider section of the report.  Ms Gardiner outlined the relevant sections of the
report and highlighted the key findings and areas of focus as detailed within the
report.
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Ms Gardiner thanked all the council staff involved in this and the financial
statements audit work and highlighted that this first year has been challenging but
commented on the good progress in getting to know the team.
Thereafter Ms Gardiner in responding to a question raised by Councillor Smaill
regarding the budget setting and the adverse variances in particular regarding
Hillend and the reduction in the contribution to the Integration Joint Board,
advised that this will be a consideration as part of the audit work next year and 
Ms Gardiner highlighted that this is an area of ongoing challenge and was across
most Councils where there are significant challenges in the budget setting. 
Councillor Smaill advised that the Internal Audit team are looking at the Hillend
situation and commented positively on the work done by Mr Oliver on the
business maintenance services.
The Chair, Councillor Milligan commented positively on the budget setting
process which was done fairly, openly and transparently and that the chief officers
of the Integration Joint Board (IJB) were advised at the start of the budget setting
process that a percentage of savings would be looked at across all services and
one of the consequences of the budget cutting savings was the funding of the
transformation programme to move on to electronic appointments.  Councillor
Milligan also highlighted that the IJB advised that they have received fair funding
from Midlothian over the years and that the challenge for the IJB will be to find
smarter ways of working.  Councillor Milligan also commented on the Hillend
situation and the dependency on both the revenue budget and capital budget and
how these are both linked and that council is short of what they require for capital
funding and the only way to increase this is by revenue cost for borrowing
therefore these both must be linked for forth coming budgets.
The Chief Financial Officer, Mr Gladwin confirmed the comments made by
Councillor Milligan with regards the IJB and provided clarity on the Hillend
situation advising that the issues were not related to the loan charges but the
income expected from the alpine coaster and advised that the business case was
carefully pulled together and scrutinised by officers and that the income target had
not been achieved but highlighted that this was a unique situation with Hillend due
to the civil work and the complexities with the water pipes and this could not have
been anticipated so this has been the contributor to the loss income in the
financial year.  
Mr Gladwin then provided an explanation on reserves advising that although the
audit report is accurate and is a fair reflection of these figures these could be
misunderstood and he provided an explanation on the details of the reserves and
what is earmarked, committed reserves, repairs and renewal fund and the general
fund and also details on the underspends and overspends for last year.  He
further highlighted the reserves need be viewed intelligently and that when the
figures appear in national reports, they can be misunderstood and misrepresented
and highlighted the sound financial planning reasons behind reserves that
Midlothian Council hold. 
The Chair also commented on the reserves supporting the explanations from the
Chief Financial Officer.
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The Provost, Councillor McCall commented on the positive report highlighting the
positive partnership working with community planning partners, comments on
leadership, engaging with communities, gender balance and engaging in local
equality groups.  Councillor McCall also acknowledged that the report highlighted
that Midlothian Council is the only council in Scotland with an all-female council
leadership team.
Decision
The Audit Committee approved this report and recommended that it is presented
to Council.
Action
Chief Financial Officer 
Report No. Report Title Submitted by:
5.1a Midlothian Council Best Value Thematic
Work 2022/23
Audit Scotland,
External Auditors
Outline of report and summary of discussion
Patricia Fraser, external auditor presented the Midlothian Council Best Value
Thematic Work 2022/23 highlighting the work performed and the production of
this report marks the move to more regular reporting on how the Council is
performing regarding its duty of best value and that an overarching best value
assurance report and this will be due on the last year of the audit appointment
and provided an explanation on the best value reporting leading up to 2026/27.
Ms Fraser advised that the thematic report was a positive report with some areas
highlighted which present challenges to the Council.  Ms Fraser also highlighted
from the work carried out including discussions with officers and members and
review of plans, strategies, and committee minutes it was clear that Midlothian
council continues to demonstrate ongoing commitment to best value.  It was
noted that all the recommendations in the 2019 report had been actioned and
furthermore the council continues to develop performance reporting and medium-
term financial planning as well as strengthening officer member relationships.
Ms Fraser then highlighted some of the key messages as detailed in the report
and commented on the Transformation blueprint which aligns with the five-year
budget strategy to 2027/28.  Ms Fraser further highlighted some of the main
sections as contained within the report and advised that robust financial planning
and delivery of the transformation blueprint are critical to delivering financial
sustainable services in the medium to long-term and that management have
provided responses to addressing the risks associated with these actions and are
included in appendix 1 of the report.
Ms Fraser expressed her sincere thanks to officers and members of the council
for the assistance they provided in performing the work and producing this report,
particularly Mr Gladwin.
Councillor Smaill raised the concerns with regards to the population in Midlothian
and that it is not reflected in the settlement from the Scottish government and
asked the Chief Financial Officer if there was any update on this situation.  
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Councillor Milligan also commented on the population growth and provided an
overview of actions that have already taken place to address this and advised that
the paragraph on page 53 should be amended as the funding allocation does not
align with the growth in population.  
Mr Gladwin agreed that perhaps the wording should be amended in paragraph 53
and provided an update on discussions which have taken place and advised on a
future meeting to discuss the position Midlothian is in and that the funding does
not sit alongside the growth.  Mr Gladwin also advised on what they were hoping
to achieve at this meeting and provided an update on the work that has been
done with regards to the census figures.  Councillor Milligan provided further
details on the work that has been undertaken to highlight the growth in Midlothian
with the Scottish Government highlighting that this has been ongoing for many
years.
Ms Fraser welcomed the discussion and advised that she was happy to amend
the report to reflect the discussion that had taken place and confirmed that after
these amendments had been done to the report, the revised report would be sent
to Mr Gladwin.
The Chief Executive thanked Ms Fraser for her comments and asked if the
publication of the census data could be referenced as well and explained that the
Council considered 2022 census data at October 2023 Council meeting and
where they previously thought Midlothian was growing at 15.8% it was growing
faster at 16.1% so this was something that had to be closely monitored.  The
Chief Executive also highlighted although their estimates were relatively accurate
the data was still out and highlighted that this council was growing across all age
groups, and this had an impact on revenue and capital spend.  She further
advised that it was agreed at the October council meeting to write formally to UK
government, Scottish government and COSLA to ask that the most up to date
census data be considered in any funding applications for Midlothian.
Ms Kaur in responding to a question raised by Councillor Smaill with regards to
workforce planning and the workforce comparative to other Scottish councils,
confirmed we are quite a lean council, but we are not alone on this and explained
some of the challenges in recruitment in some sectors of the council, but also
advised that this was being addressed.  Ms Kaur also highlighted some of the
digital transformation work, which was taking place, the work through
apprenticeships and grow your own staff.  Ms Kaur highlighted that at Cabinet
there was a discussion about working with the workforce and celebrating
successes and officers were keen to expand on this.  Ms Kaur further advised on
some of the work around foster carers, recruitment campaigns, different ways of
working and generic working and the work done with neighbourhood services.
The Chair also commented on the staffing situation in Midlothian compared with
other councils and the challenges Midlothian face.
Mr Fraser confirmed to the committee that the thematic review next year would be
on workforce planning and innovation.
The Chair highlighted on P54 (paragraph 67) that 600 people attended a
budgeting event and highlighted that nothing had happened within the last 2 or 3
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years so was unsure what this referred too.  The Chair also highlighted that the
consultation detailed in paragraph 68 was all done online.
Councillor Bowen also advised on a typo on page 44 of the report and in
response Ms Fraser confirmed that she would check on the comments from the
Chair and also confirmed they had identified some other typos within the report,
and this would be proofread before the report was finalised.
Decision
Audit Scotland would make the necessary checks and amendments to the
document as discussed prior to it being finalised.
Action
Audit Scotland. 
Report No. Report Title Submitted by:
5.2 Treasury Management Mid-Year Review
Report 2023/24
Chief Financial
Officer
Outline of report and summary of discussion
The purpose of this report was to inform members of the Audit Committee, and
subsequently Council, of the Treasury Management activity undertaken during the
first half of 2023/24 and the forecast activity for the second half of 2023/24 in
accordance with the Treasury Management and Annual Investment Strategy
approved by Council on 21 February 2023.  It also provided an update to the
Treasury and Prudential Indicators for 2023/24.
The Chief Financial Officer, Mr Gladwin on presenting this report highlighted the
main sections as contained within the report and outlined the contents of the
appendices attached.  Mr Gladwin introduced Gary Thomson who was in
attendance to answer any questions as Gary provided strategic direction for the
council’s treasury function.
Councillor Smaill expressed his congratulations on the report and the confidence
the council now has on the treasury management, Councillor Smaill followed on
with questions regarding reduction on deposits and capital spend and secondly on
debt rescheduling.
Mr Gladwin in responding to Councillor Smail’s first question advised that he was
correct on his assumption that the cash balances are running down as the capital
expenditure catches up and the council is in a position not to take more borrowing
because of the cash balances and advised that they do not want to lock into
borrowing at high interest rates so looking at ways to minimise this.  
Mr Gladwin advised with regards to debt rescheduling, the Council has done this
in the past although not a lot and advised that this is not something they would
jump into without getting a detailed appraisal on what benefits this would bring as
they must ensure they are not getting short term gains for long term pressures, 
Mr Gladwin then passed over to Mr Thomson to provide further clarity on this.
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Mr Thomson advised with regard to debt rescheduling they would be looking at
that on a discounted cash flow basis and one of the options that has been actively
looked at was the replacement of the PWLB Annuities loan explaining that in
paying this off early although there would be a premium this would be spread over
the remaining life of the loans but this would be offset on the discounted cash flow
basis by the saving on the interest cost on the loan which would no longer be
incurred.
Mr Gladwin in responding to a further question raised by Councillor Smaill
regarding the council becoming an active trader of the deposit positions, advised
that the current treasury policies and practices would not allow the council to do
this so it is not something that would be considered.  Any changes to existing
practices would have to be discussed at the Audit Committee and approved
through Council.
The Chair commented that this was a very good report and goes some way to get
the council back up to number 1 in the performance chart.  The Chair also
commented that it would be interesting to know if the Council was sitting mid-
market what the difference would be from being the top players as a comparative
council.  He expressed his thanks to David Gladwin, Gary Thomson, and the rest
of the finance team for the fantastic report.
The Chair also expressed his thanks to the External Auditors for their time and
support and thanked everyone for their attendance.
Decision
The Audit Committee noted the report and in particular, noted the following
recommendations which are proposed to be put to Council on 19 December
2023:- 
a) Note the report and the treasury activity undertaken in the period to 30
September 2023, as outlined in Section 5;
b) Note the actual and forecast activity during the second-half of the year
as outlined in Section 6;
c) Approve the technical revisions to the Prudential Indicators in Section 7
of this report;
d) Note the loans fund rate performance relative to other Scottish Local
authorities, as outlined in Section 8, and the cash saving (compared to
the Scottish Average) that the Treasury Management function brings to
support the Council’s in-year revenue budget. 
6. Private Reports 
None 
7. Date of Next Meeting 
Date of Next Meeting: Monday 29 January 2024 at   at 11am. 
The meeting terminated at 11:58 am 
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Page 20

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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.
Chief Financial
Officer
Ongoing  Carry forward, paper
coming forward regarding
CSG and ethical
depositing coming later in
the year. 
2 Annual Accounts for
the year ended 31
March 2023
30/10/2023  Agreed that Members would
discuss the governance
arrangements in place for
reporting any capital projects
overspends within their
individual groups and provided
further feedback to officers
Committee  
3 Council House Building
Programme – Progress
Update 2023
30/10/2023 Mr Anderson to report back in
due course on the actual cost
per unit of the 10 houses within
the Buccleuch Street
development
Kevin Anderson TBC 
Audit Committee
Monday, 29 January 2024
Item No: 4.3  
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Audit Committee
Monday 29 January 2024
Item 5.1   
Treasury Management and Investment Strategy 2024/25 & Prudential
Indicators 
Report by David Gladwin, Chief Financial Officer & Section 95 Officer 
Report for Decision 
1 Recommendations 
The Audit Committee is invited to comment on this report before it is
presented to Council.  In particular, Audit Committee should note the
following recommendations which are proposed to be put to Council on
27 February 2024:- 
a) Approve the restriction of the Authorised Limit to the value of
the Capital Financing Requirement at 31 March 2025
(£545.673 million), pending finalisation of the General
Services Capital Plan Prioritisation; 
b) Note that there are no other material changes proposed to the
Treasury Management and Investment Strategy (TMIS) for
2024/25 from the strategy currently in place, other than to
update the Prudential Indicators (Section 5 and Appendix 2),
to reflect the revised capital plans; 
c) Note the retention of the current approach for the repayment
of loans fund advances as outlined in Section 6 and that any
changes arising from the Scottish Government’s consultation
on the Amendment to the Local Authority (Capital Finance
and Accounting) (Scotland) Regulations 2016 will be reflected
in a revised TMIS if required; and 
d) Accordingly approve the Treasury Management and
Investment Strategy for 2024/25. 
2 Purpose of Report/Executive Summary 
In accordance with the Treasury Management Code of Practice, the
annual Treasury Management & Investment Strategy (TMIS) &
Prudential Indicators report is required to be adequately scrutinised
before being recommended to the Council.  For Midlothian, this role is
undertaken by the Audit Committee, with this report being presented to
Audit Committee on 29 January 2024 prior to consideration by Council
on 27 February 2024. 
The purpose of the report to Council will be to provide an update on the
implementation of the Council’s TMIS 2023/24, and to make
recommendations to facilitate consideration of the 2024/25 Strategy,
specifically the TMIS for 2024/25, the Prudential and Treasury
indicators contained therein, and the approach to the statutory
repayment of loans fund advances.
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2 
Any revisions arising from Audit Committee consideration of the report
on 29 January 2024 will be incorporated into the final version of the
report to Council on 27 February 2024. 
Date: 18 January 2024
Report Contact:
Gary Thomson, Senior Finance Business Partner
gary.thomson@midlothian.gov.uk 
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3. Update on implementation of TMIS for 2023/24 
3.1 Borrowing 
The Council’s borrowing position as set out in the 2023/24 Treasury
Management Mid-Year Review Report was £321.754 million at 31
March 2023, and six months later was £321.314 million on 30
September 2023. 
The principal source of borrowing is the UK Debt Management
Office’s Public Works Loans Board (PWLB) and fixed rate loans are
taken at a time and tenure which takes cognisance of the PWLB rates
(derived from the UK Gilts market) and the management of maturity
risk in the long term across the Council’s loan portfolio. 
The Council’s loan portfolio, as at 17 January 2024, is shown in table
1 below:- 
Table 1: Current Loan Portfolio as at 17 January 2024 
Loan Type
Principal
Outstanding
£000’s
Weighted
Average
Rate
PWLB Annuity 452 8.91%
PWLB Maturity 284,128 2.90%
LOBO 20,000 4.51%
Market Loans 16,221 2.68%
Salix Loans 70 0.00%
Total Loans 320,871 3.00% 
The repayment profile of this debt is shown in graphical and tabular
form below:- 
Figure 1: Loan Maturity Structure 
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Table 2: Loan Maturity Profile 
Financial Year 2023/24
Remaining
£000’s
2024/25-
2025/26
£000’s
2025/26-
2027/28
£000’s
2028/29-
2032/33
£000’s
2033/34-
2037/38
£000’s
2038/39+ 
£000’s
Debt Maturing 0 1,426 2,795 45,136 32,239 239,275
% of total portfolio 0.00% 0.44% 0.87% 14.07% 10.05% 74.57% 
As can be noted in the graph and table above, proactive Treasury
Management by the Council in the last decade has placed the Council
in an extremely strong refinancing position for its existing external
debt portfolio, with only £4.221 million, or just 1.31%, of the Council’s
total Loan Portfolio of £320.871 million requiring refinancing over the
current and forthcoming four financial years. 
This extremely low short-term exposure to refinancing risk has put the
Council in a strong position to plan its new borrowings in advance,
take advantage of any dips in longer-term borrowing rates from PWLB
(as demonstrated above) and other sources, and maintain a low
weighted average coupon rate on external debt. 
3.2 Deposits 
The Council’s position for funds on deposit fluctuates on a daily basis,
with the 2023/24 Treasury Management Mid-Year Review Report
setting out the position at 31 March 2023 of £113.982 million and six
months later on 30 September 2023, at £111.344 million. 
The position at 17 January 2024, as set out in Table 3 below, totals
£72.416 million. 
Table 3: Current Deposits as at 17 January 2024 
Deposit Type
Principal
Outstanding
£000’s
Weighted
Average
Rate
Bank Call Accounts 7,343 5.09%
Money Market Funds 35,073 5.32%
Bank Fixed Term Deposits 30,000 4.98%
Total Deposits 72,416 5.15% 
The cash balances above represent the following: 
• Funds held in Bank Fixed Term Deposits and Money Market
Funds which are cash backing £65.073m of the Council’s
projected useable reserves (at 31 March 2024);
• A balance held in instant access bank accounts and Money
Market Funds which are used for day to day liquidity to meet
cashflow requirements; 
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The Council’s current deposit portfolio is broadly reflective of the wider
UK Local Authority position, as noted in the Treasury Management &
Annual Investment Strategy Statement – 2024/25 Detailed in
Appendix 3, Section 4.4.  
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4. Treasury Management & Investment Strategy 2024/25 
4.1 Main Objectives of TMIS 2024/25 
The objectives of the current and proposed TMIS are:- 
• To secure long-term borrowing to fund capital investment,
through locking in to long-term interest rates and de-risking
the Council’s Capital Financing Requirement (CFR); 
• To ensure short-term liquidity to manage the Council’s day-to-
day cashflow.  This is achieved through the utilisation of
instant access Money Market Fund and Bank Accounts, with
the amount held in these reflecting the Council’s level of
working capital and fluctuating throughout the year due to a
number of factors; 
• To cash back the Council’s usable reserves. 
No material changes are proposed to the current 2023/24 TMIS which
was scrutinised by Audit Committee in January 2023 and approved by
Council in February 2023, other than for the following:- 
a) Approve the restriction of the Authorised Limit to the value of the
Capital Financing Requirement at 31 March 2025 (£545.673
million), pending finalisation of the General Services Capital
Plan Prioritisation; 
Similarly no changes are recommended to the Permitted Investments. 
More detail on the borrowing and investment strategy for 2024/25 is
provided in Sections 4.2, 4.3 and 4.4 below. 
4.2 Borrowing Requirement 2023/24 to 2027/28 
The Council’s capital plans contain projections of capital expenditure
and income over the forthcoming financial years.  Any expenditure not
financed directly by income, requires funding through borrowing. 
The projected borrowing requirement arising from the Council’s
Capital Plans, the Midlothian Energy Limited (MEL) Shareholder
Injection, and the maturing long-term loans that require to be
refinanced, over the period 2023/24 to 2027/28 is shown in table 4:- 
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Table 4: Total Borrowing Requirement over the period 2023/24 to 2027/28 
2023/24
£000’s
2024/25
£000’s
2025/26
£000’s
2026/27
£000’s
2027/28
£000’s
Total
£000’s
Capital Expenditure      
General Services 64,921 108,857 121,975 89,765 12,128 397,645
HRA 52,125 99,585 91,901 36,647 26,128 306,386
Total Capital Expenditure 117,046 208,442 213,876 126,412 38,256 704,031
Total Available Financing -46,865 -64,914 -34,333 -19,432 -10,893 -176,437
Principal Debt Repayments -9,206 -10,760 -11,670 -12,557 -14,195 -58,388
Capital Expenditure less
available Financing 
60,974 132,767 167,873 94,423 13,168 469,206
MEL Shareholder Injection 710 3,560 0 0 0 4,270
Maturing Long-term Loans 830 1,426 1,355 851 700 5,162
Total Borrowing
Requirement
62,514 137,753 169,228 95,274 13,868 478,638 
Note that the Capital Expenditure and Financing in the table above is
based on the Council’s existing Capital Plans which will be updated to
reflect Quarter 3 Monitoring for 2023/24 and future year budget
reprofiling, prior to submission of this report to the Council meeting of
27 February 2024. 
4.3 Borrowing Strategy for remainder of 2023/24 and 2024/25 
Borrowing is undertaken to finance the Council’s approved Capital
plans and to do so in the most cost-effective way.  As can been noted
from Table 4 above the Council has a significant borrowing
requirement across the current and forthcoming four financial years
(2023/24 to 2027/28). 
This TMIS provides for this capital investment to be underpinned by
long-term borrowing, recognising the current interest rate
environment, the significant borrowing requirement arising from the
Council’s capital plans, and the long term benefits of de risking the
delivery and affordability of these capital plans by locking into the
certainty brought by PWLB fixed rate loans. 
The Council’s external loan debt at 31 March 2024 is projected to be
£384.346 million.  Based on the Council’s historic and current
approved Capital Plans, the Underlying Borrowing Requirement
(UBR) – which is the Council’s underlying need to borrow for capital
purposes (excluding the long-term liability arising from PFI/DBFM
projects) – at 31 March 2024 is expected to equate to £409.346
million. 
This means that the Council is expected to be £25.000 million (6%)
under-borrowed at the end of the 2023/24 financial year i.e. the
Council has funded the majority (94%) of its underlying borrowing
requirement as at 31 March 2024.  In the current economic climate,
this is a prudent approach which balances (a) de-risking the longer
term borrowing requirement at current longer term borrowing rates;
against (b) the current year and forthcoming financial year budget
projections.  As noted in Section 3.1 above, the Council has an
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8
extremely low short-medium term exposure to refinancing risk and is
therefore in a strong position to plan its new borrowing requirements
in advance, taking advantage of any dips in longer-term borrowing
rates from PWLB and other sources, and maintain a low weighted
average coupon rate on external debt. 
The Underlying Borrowing Requirement is projected to rise to
£821.137 million by 31 March 2028 – more than double the current
Underlying Borrowing Requirement.  The profile of this, and the
projected external loan portfolio to fund the Underlying Borrowing
Requirement over the period 2023/24 to 2027/28, is shown in
graphical format below. 
Figure 3: Loan Portfolio & Underlying Borrowing Requirement 
Interest Rates
The current PWLB yield curve is bell shaped with the low point in the
curve is at the 5 year mark (4.40%) with rates trending upwards
towards the 20-30 year tenor (5.25%) before easing back slightly to sit
at c. 5.10% in the 50 year duration.  Current rates have generally
eased off 30-40bps from levels reported at the time of the 2023/24
Treasury Management Mid-Year Review Report to Council, with no
material change to the medium term forecast for rates. 
The yield curve is expected to remain bell shaped over the short-
medium term, with a gradual shift downwards of the entire curve by c.
40-60bps over the next 12 months and a further 40-50bps over the
subsequent 12 months.  This is forecast to bring longer-term
borrowing rates down to between 4.10-4.60% by March 2025 and
between 3.70%-4.20% by March 2026.  Further commentary on this is
provided in Appendix 3 Section 3.3. 
The funding of the Council’s in-year and forward CFR is typically for
infrastructure with long asset lives (50-60 years), and the tenor of
PWLB and market loans are typically drawn with this in mind. 
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Borrowing Strategy
Consideration for any new borrowing in the remainder of the 2023/24
financial year and during the 2024/25 financial year, to fund the
Council’s in-year CFR, will seek to balance:- 
a) the security/certainty of current relatively high longer-term
borrowing rates of upwards of 5.25% in the 30-50 year duration
(which are forecast to drop by 60bps within one year and
100bps within 24 months) and the potential additional
budgetary pressure that this brings in both the short/medium
and longer term; with 
b) the option to borrow initially for a shorter-term duration from
PWLB or other markets, for 3 to 5 years (at say c. 4.40%), to
allow the Council to fund the immediate in-year borrowing
requirement.  Based on current interest rate forecasts (see
Appendix 3 Section 3.3), this would then allow the Council the
option to refinance this borrowing at initial 3-5 year maturity
with less expensive, longer term borrowing, e.g. a 45 to 47 year
tenor in, say, 36 months at a forecast rate of c. 3.90%. 
As noted in Section 3.1, the Council’s proactive Treasury
Management over the last decade has put the Council in a strong
refinancing position for its external debt portfolio which allows the
Council to slot in shorter dated external borrowing into the current
debt maturity profile to fund the current & forthcoming in-year
borrowing requirements, to allow the Council to navigate past the
current expected hump in longer-term borrowing rates. 
It is expected that any further long-term borrowing that is undertaken
during 2023/24 and 2024/25 to finance the current & future year
capital plans will be sourced by drawing new PWLB loans at the
Certainty Rate (which has been available to the Council since 2012
and is priced at Gilts+80bps), and/or the HRA rate.  The HRA rate is
available to all Councils to fund HRA capital expenditure, at a rate that
is priced at Gilts+60bps.  On 22 November 2023, the availability over
which Councils can draw HRA rate borrowing from PWLB was
extended to 30 June 2025. 
Both the General Services and HRA capital programmes are being
kept under regular review due to the effects of inflationary pressures,
shortages of materials and labour, and the ratios of financing costs to
the net revenue streams.  The Council’s borrowing strategy will,
therefore, also be regularly reviewed and then revised, if necessary,
to achieve optimum value and risk exposure in the medium-long-term. 
The impact particularly of the General Services Capital Plan
Prioritisation – which will be reported to Council in February 2024 –
will have a significant bearing on this. 
Appendix 3 Section 3.3 provides forecasts for interest rates from the
Council’s Treasury Management advisor, Link Treasury Solutions
Limited.  Council officers, in conjunction with Link, will continue to
monitor daily long-term borrowing rates in order to take advantage of
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any dips in the market or to de-risk any change in the medium-longer
term forecast for gilt yields. 
Forward Borrowing
The opportunity also continues to exist to consider further loans on a
‘forward dealing’ basis, and officers will continue to explore the
viability of these loans as part of securing the long term borrowing
required to meet the Council’s Underlying Borrowing Requirement. 
Debt Rescheduling 
As noted in the Mid-Year Review Report, now that the whole of the
yield curve has shifted higher there may be opportunities for debt
rescheduling in the remainder of the financial year. 
This would involve the Council repaying loans prematurely (both
market and PWLB) whilst high discount rates on premature
repayment prevail. 
Any debt rescheduling will be considered when the difference
between the refinancing rate and the redemption rate is most
advantageous and the situation will be continually monitored in order
to take advantage of any perceived anomalies in the yield curve.  The
reasons for any rescheduling taking place would include: 
- the generation of cash savings at minimum risk;
- to reduce the average interest rate;
- to amend the maturity profile and/or the balance of volatility of
the debt portfolio. 
Council officers will explore debt rescheduling opportunities with Link
Treasury Solutions; with only prudent and affordable debt
rescheduling that considers both the short and medium-longer term
impact being considered. 
4.4 Investment Strategy for remainder of 2023/24 and 2024/25 
No changes are proposed to the Investment Strategy from that
approved by Council in the 2023/24 TMIS. 
Council should note that in parallel to securing its external borrowing
to finance the capital financing requirement, the strategy means that
Council should continue to cash back the Council’s useable reserves. 
In doing so, the Council are able to continue to minimise the extent of
under-borrowing and at the same time de-risk the Council’s forward
borrowing requirement; whilst also ensuring that all deposits are
securely placed with high creditworthy counterparties, complying with
the CIPFA Treasury Management Code principles of security, liquidity
and then yield – in that order. 
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All deposits will be placed with high creditworthy counterparties in
accordance with the approved creditworthiness policy as outlined in
Appendix 1, with a tenor reflective of the expected drawdown of
useable reserve forecasts, and at a yield commensurate with this. 
The list of Permitted Investments in Appendix 1 also remains
unchanged from that approved by Council in the 2023/24 TMIS. 
As required by the CIPFA Treasury Management Code, Local
authorities “must not borrow to invest for the primary purpose of
financial return.”  Midlothian Council does not and has not borrowed to
invest for the primary purpose of financial return. 
Environmental, Social and Governance (ESG) in credit and
counterparty policies (Treasury Management Practice 1) 
As noted in the 2023/24 TMIS, the inclusion of ESG criteria continues
to be an emerging area in the Local Authority environment which will
require ongoing monitoring. 
For the 2024/25 financial year, the Council’s priorities of security,
liquidity and then yield remain paramount and unchanged (and in that
order), with ESG criteria an added 4th element to consider in the
decision making process. 
For short term investments with counterparties, this Council utilises
the Link creditworthiness service which uses the ratings provided by
Fitch, Moody’s and Standard & Poor’s to assess creditworthiness,
which in themselves include analysis of ESG factors, and specifically
the “G” element, when assigning ratings.  Of the 3 elements of ESG,
the most important element when considering treasury deposits is the
Governance aspect – given the majority of treasury deposits
undertaken by Midlothian Council are naturally short dated in duration,
poor governance can have a more immediate impact on the financial
circumstances of an entity and potential for a default event that could
impact the amount of principal returned on the deposit. 
Those financial institutions viewed as having poor/weak corporate
governance are generally less well credit rated in the first instance or
have a higher propensity for being subject to negative rating action,
and the Council’s existing creditworthiness policy will therefore take
this into account. 
Environment and Social factors are also important, but relate more to
the long-term impact.  Council should note that in relation to the
security aspect of Treasury deposits, placing an undue weight on the
Environmental and Social factors in the decision making process
could have an adverse effect of limiting the list of potential
counterparty options, thus decreasing diversification.  This could then
in turn lead to a widening of credit (security) criteria, or those with a
stronger “ESG” performance, in order to restore a balance of
diversification across the deposit portfolio, potentially increasing credit
risk – and placing the cornerstone of prudent investing at risk. 
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The inclusion of ESG criteria therefore remains an area which
requires ongoing review.  Council officers, in conjunction with the
Council’s treasury advisers Link, will therefore continue to monitor and
assess ongoing developments and emerging standards in this area,
and methods in which the Council can incorporate ESG factors into
our creditworthiness assessment process, and report back to Council
accordingly. 
5 Prudential Indicators – Midlothian Council 
The Prudential Code for Capital Finance in Local Authorities requires
that Councils can demonstrate that their Capital Plans are affordable,
prudent and sustainable, taking into account the financial provisions
made in current and future revenue budgets; and that Treasury
Management decisions are taken in accordance with good practice. 
The Prudential Indicators that Councils need to consider relate to both
actual, historic outcomes, and future estimated outcomes (covering
the same period as the Council’s Capital Plans), as follows:- 
• Actual outcomes for 2022/23;
• Revised estimates of the 2023/24 indicators; and
• Estimates of indicators for 2024/25 to 2027/28. 
The Prudential Indicators required by the Code are listed individually
in Appendix 2. 
The key Prudential Indicators relating to the Underlying Borrowing
Requirement, the expected Gross External Debt, and the proposed
Authorised Limit, are shown in graphical format below. 
Figure 4: Prudential Indicators for Borrowing 
The Capital Financing Requirement (CFR) denotes the Council’s
underlying need to borrow for capital purposes.  The CFR includes
borrowing arising as a result of the Council’s Capital Plans, plus the
long-term liability arising from the Council’s PPP/DBFM contracts. 
The Underlying Borrowing Requirement as shown in Figure 4
384,346
520,674
688,547
782,969 796,137
£-
£100,000
£200,000
£300,000
£400,000
£500,000
£600,000
£700,000
£800,000
£900,000
2023/24 2024/25 2025/26 2026/27 2027/28
£000's
Financial Year
Prudential Indicators for Borrowing
External Debt Authorised Limit Underlying Borrowing Requirement / Operational Boundary
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13
above strips out the latter of these (long-term liability arising from the
Council’s PPP/DBFM contracts) from the CFR. 
The Authorised Limit for Borrowing represents the limit beyond
which borrowing is prohibited, and needs to be set and revised by
Members.  It is the expected maximum borrowing need with some
headroom for unexpected movements. 
The Authorised Limit for Borrowing for the 2024/25 financial year has
been calculated to equate to the maximum value of the Underlying
Borrowing Requirement in 2024/25.  This equates to £545.673 million
as outlined in Table 5 below. 
Table 5: Authorised Limit for Borrowing: Calculation 
Authorised Limit for Borrowing Amount
£000’s
CFR – General Services (31 March 2025) 228,109
CFR – HRA (31 March 2025) 317,564
Proposed Authorised Limit for Borrowing 545,673
Council is therefore asked to approve an authorised limit for borrowing
of £545.673 million.  
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14
6 Statutory repayment of loans fund advances 
Under the Local Government Finance Circular 7/2016, Council is
required to set out its policy for the statutory repayment of loans fund
advances prior to the start of each financial year. The repayment of
loans fund advances ensures that the Council makes a prudent
provision each year to pay off an element of the accumulated loans
fund advances made in previous financial years. 
The TMIS retains the methodology adopted in 2023/24 – that is as
follows:- 
6.1 New Assets 
In accordance with Finance Circular 7/2016, for all advances made in
relation to the provision of a new asset, the policy will be to defer the
commencement of the first principal repayment of the loans fund
advance until the financial year following the one in which the asset is
first available for use. 
6.2 Prudent Repayment of Loans Fund Advances 
Finance Circular 7/2016 provides a variety of options to Councils for
the profiling of the repayment of each loans fund advance, so long as
the principle of prudence is maintained.  There are 4 options available:
(a) Asset Life method; (b) Statutory method; (c) Depreciation method;
and (d) Funding/income profile method. 
In line with the policy adopted in 2023/24, the Asset Life method shall
be used for those assets in Table 6. 
Table 6: Asset Classes to adopt the “Asset Life” method
Infrastructure
Current
Loans
Fund
Advance
Period
New Primary Schools/Extensions 60
New Leisure Centres 60
New Offices 60
Road Upgrades 50
Street Lighting Columns 50
Structures/Bridges 50
Footway/Cyclepaths 50
Town Centre Environmental Improvements 50
New Care Homes 45
Children’s Play Equipment 20
* Average loans fund advance length 
The annual repayments under the “Asset Life” method for those asset
classes as noted above will be calculated using the asset lives and will
use the annuity method, to ensure consistency of approach with the
Statutory method for all other asset classes (see below).  The annuity
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15
interest rate that will be used to calculate loans fund principal
repayments under the “Asset Life” method will be the in-year loans fund
rate, which for 2023/24 is currently estimated to be 2.29%. 
For all other asset classes, the policy will be to maintain the practice of
previous years and apply what is termed “the Statutory Method” –
following the principles of Schedule 3 of the Local Government
(Scotland) Act 1975 – with all loans fund advances being repaid by the
annuity method.  The annuity rate that is proposed to be applied to the
loans fund repayments varies and will be the in-year loans fund rate,
reflecting the Council’s current loan and investment portfolio.  The loans
fund rate for 2023/24 is forecast to be 2.29% 
Whilst neither the Depreciation nor the Funding/income profile methods
are currently proposed, Council officers will continue to monitor whether
it is appropriate to use this for future capital projects. 
6.3 Scottish Government Consultation 
The Scottish Government issued a formal consultation on 28 November
2023 on the Amendment to the Local Authority (Capital Finance and
Accounting) (Scotland) Regulations 2016.  This consultation outlined
proposed changes to the methodology for the repayment of loans fund
advances.  The consultation closed on 22 December 2023 with
Midlothian Council, the Scottish Local Authority Directors of Finance
Group, and Link Treasury Solutions Limited amongst those submitting
formal responses to the consultation.  The outcome of any changes to
these Regulations will be reflected in a revised 2024/25 TMIS if
required.  
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16
7. Report Implications 
7.1 Resource 
There are no direct resource implications arising from this report. 
7.2 Digital 
None 
7.3 Risk 
The strategies outlined in this report are designed to maintain the
effectiveness of the overall risk management arrangements for
Treasury activity.  Providing the limits outlined in the strategies are
observed they will support the controls already in place in the
Treasury Management Practices within which the treasury function
operates. 
The Prudential Indicators contained in Appendix 2 maintain the
effectiveness of the overall risk management of Capital Investment
and Treasury Management. 
7.4 Ensuring Equalities 
There are no equality issues arising from this report. 
7.5 Additional Report Implications 
See Appendix A.  
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17
Appendix A: Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Not applicable. 
A.2 Key Drivers for Change 
A.3 Key Delivery Streams 
Themes addressed in this report: 
One Council Working with you, for you 
Preventative and Sustainable 
Efficient and Modern 
Innovative and Ambitious 
None of the above 
A.4 Delivering Best Value 
The report does not directly impact on Delivering Best Value. 
A.5 Involving Communities and Other Stakeholders 
Although no external consultation has taken place, cognisance has
been taken of professional advice obtained from Link Asset Services,
the Council’s appointed Treasury Consultants. 
A.6 Impact on Performance and Outcomes 
The strategies to be adopted are an integral part of the corporate aim
to achieve Best Value as they seek to minimise the cost of borrowing
by exercising prudent debt management and investment. This in turn
helps to ensure that the Council’s capital expenditure is sustainable in
revenue terms. 
A.7 Adopting a Preventative Approach 
Not applicable. 
A.8 Supporting Sustainable Development 
Not applicable. 
Background Papers:-
Appendix 1:- Permitted Investments
Appendix 2:- Prudential Indicators
Appendix 3:- Treasury Management & Annual Investment Strategy
Statement – 2024/25 Detailed
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Page 41

Permitted Investments Appendix 1 
The Council uses the Link creditworthiness service for specific categories of permitted
investments.  This utilises credit ratings from the three main credit rating agencies – Fitch,
Moody’s and Standard & Poors, along with credit watches, outlooks, CDS spreads and country
sovereign ratings in a weighted scoring system with an end product of a series of colour coded
bands which indicate the relative creditworthiness of specific categories of counterparties for
investment. 
These colour codes are used by the Council to determine the maximum suggested duration for
investment with that counterparty.  These are as follows:- 
Link Asset Services
Colour Code
Maximum Suggested
Duration for Investment
Yellow 6 years*
Dark Pink 6 years**
Light Pink 6 years**
Purple 2.5 years
Blue 1.25 years***
Orange 1.25 years
Red 7 months
Green 120 days
No colour Not to be used
* Note the yellow colour category is for:- UK Government Debt, or its equivalent, Money
Market Funds (MMF's), and collateralised deposits where the collateral is UK Government
Debt
** Dark Pink for Ultra Short Dated Bond Funds with a credit score of 1.25; Light Pink for Ultra
Short Dated Bond Funds with a credit score of 1.5
*** Only applies to nationalised or semi-nationalised UK banks 
Note that the maximum suggested durations listed above have been extended by 1 year (when
compared to the suggested maximum durations provided by Link) for the Yellow, Dark Pink, Light
Pink categories (and so to 6 years); the Purple category by 6 months to 2.5 years; the Blue and
Orange categories by 3 months to 1.25 years; the Red category by a month to 7 months, and the
Green category by 20 days to 120 days.  This is to allow flexibility around these durations on the
margins e.g. the placement of a 13 month fixed term deposit for a counterparty rated Orange or
Blue.  A thorough appraisal of the additional risk involved in extending the duration of any deposit
(marginally) beyond the maximum suggested by Link, against any enhanced value to the portfolio,
will be undertaken prior to the placement of any deposit. 
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1.1  Deposits 
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m
of total
investments
Max. maturity
period
Debt Management Agency
Deposit Facility -- Term No 100% 6 months
Term deposits – local authorities -- Term No 100% 5 years
Call accounts – banks and
building societies Green Instant No 100% 1 day
Term deposits / Notice Accounts
– banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use 
1.2 Deposits with counterparties currently in receipt of government support / ownership 
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
UK nationalised banks – Call
accounts Blue Instant No 100% 1 day
UK nationalised banks – Term
Deposits / Notice Accounts Blue Term No 100% 1.25 years
UK nationalised banks – Fixed
term deposits with variable rate
and variable maturities: -
Structured deposits
Blue Term No 100% 1.25 years
Non-UK(high sovereign rated
country) nationalised banks –
Call accounts
Green Instant No 100% 1 day
Non-UK (high sovereign rated
country) nationalised banks:-
Term Deposits / Notice Accounts
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Non-UK (high sovereign rated
country) nationalised banks:- 
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits  
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
If forward deposits are made, the forward period plus the deal period equate to the maximum maturity
period. 
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1.3  Collective investment schemes structured as Open Ended Investment Companies (OEICs) 
Investment Category
Minimum
Credit
Criteria 
Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
Government Liquidity Funds AAA Instant No 100% 1 day
Money Market Funds CNAV AAA Instant No 100% 1 day
Money Market Funds LVNAV AAA Instant No 100% 1 day
Money Market Funds VNAV AAA Instant No 100% 1 day
Ultra Short Dated Bond Funds
with a credit score of 1.25 AAA T+1 to
T+5 Yes 100% 1 week
Ultra Short Dated Bond Funds
with a credit score of 1.5 AAA T+1 to
T+5 Yes 100% 1 week
Bond Funds AAA T+2 or
longer Yes 50% 2 days
Gilt Funds AAA T+2 or
longer Yes 50% 2 days 
1.4 Securities issued or guaranteed by governments 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max %?£m 
of total
investments
Max. maturity
period
Treasury Bills
UK
sovereign
rating
Sale T+1 Yes 100% 50 years
UK Government Gilts
UK
sovereign
rating 
Sale T+1 Yes 100% 50 years
Bond issuance issued by a
financial institution which is
explicitly guaranteed by  the
UK Government  e.g. National
Rail
UK
sovereign
rating 
Sale T+3 Yes 100% 50 years
Sovereign bond issues (other
than the UK govt)
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years
Bonds issued by multilateral
development banks 
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years 
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1.5 Securities issued by corporate organisations 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max % 
of total
investments
Max. maturity
period
Certificates of deposit issued
by banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+0 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Commercial paper other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+0 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Floating rate notes
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
Corporate Bonds other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use 
1.6 Other 
Investment Category Minimum Credit
Criteria  Liquidity
risk
Market
risk 
Max %/£m 
of total
investments
Max.
maturity
period
Local authority mortgage guarantee
scheme. Blue Term No 50% 5 years
Loans to Third Parties n/a Term No £25m 25 years
Subordinated Debt Subscription to
Newbattle Centre SPV n/a Term No £0.326m 22 years
Midlothian Energy Limited n/a Term No £10.2m n/a 
Treasury Risks and Mitigating Controls for each type of investment are as outlined in the Treasury
Management & Annual Investment Strategy Statement – 2023/24 Detailed – Appendix 5.3.  The Council’s
Treasury Management Practices have also been updated in line with the new CIPFA Prudential and
Treasury Management Codes which were approved by Audit Committee on 6 December 2022.  
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Prudential Indicators Appendix 2 
1. Prudential Indicators for Affordability 
These indicators provide an indication of the impact of the capital investment plans on the
Council’s overall finances. 
1.1 Estimates of Ratio of Financing Costs to Net Revenue Stream 
This indicator identifies the trend in the cost of capital (borrowing and other long term obligation
costs net of investment income) against the net revenue stream. 
The figures above are based on the current General Services and HRA Capital Plans. 
1.2 HRA Ratios 
The following indicator identifies the ratio of overall debt on the HRA account compared to annual
house rent revenue. 
The following indicator identifies the ratio of overall debt on the HRA account per HRA dwelling. 
1.3 Net Income from Service & Commercial Investments as a proportion of Net Revenue Stream 
A new indicator, which is a requirement of the new Prudential Code, identifies the ratio of net
income from service and commercial investments as a proportion of the net General Services
revenue stream. 
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
General Services 0.38% 0.76% 2.40% 4.37% 5.62% 5.95%
HRA 36.03% 42.47% 48.01% 52.14% 55.00% 56.97%
Ratio of Financing Costs to Net Revenue Stream
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
HRA debt £000's 209,129£  244,290£  317,564£  390,437£  418,804£  436,365£ 
HRA Revenues £000's 32,165      32,492      34,719      38,546      41,828      43,276     
Ratio of HRA Debt to Revenues % 650% 752% 915% 1013% 1001% 1008%
HRA Debt as a % of Gross Revenue
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
HRA debt £000's 209,129£  244,290£  317,564£  390,437£  418,804£  436,365£ 
Number of HRA dwellings 7,372        7,470        7,675        8,029        8,284        8,289       
Debt per dwelling £ 28,368£    32,703£    41,376£    48,628£    50,556£    52,644£   
HRA Debt per Dwelling
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Estimate
£000's
Income from Service Investments          34           34           34           34           34           34
Net Revenue Stream 254,015  257,849  259,731  261,670  263,667  265,723
% 0.01% 0.01% 0.01% 0.01% 0.01% 0.01%
Net Income from Service Investments as a proportion of Net Revenue Stream
%
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2. Prudential Indicators for Capital Expenditure 
The Council’s capital expenditure plans are the key driver of treasury management activity.  The
output of the capital expenditure plans is reflected in the prudential indicators, which are designed
to assist members’ overview and confirm capital expenditure plans. 
2.1 Estimated Capital Expenditure 
This indicator shows the gross capital spend included in the relevant capital plans. 
2.2 Financing of Capital Expenditure 
This indicator shows how the Capital Expenditure forecasts are being financed by capital or
revenue resources.  Any shortfall of resources results in a funding borrowing need. 
2.3 Estimated Capital Financing Requirement 
This indicator measures the Council’s maximum underlying need to borrow for capital purposes
and other long term liabilities over the next three years. 
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
General Services
Children, Young People & Estates 5,300£    29,096£    45,647£    104,189£  81,483£    8,610£   
Asset Management 11,439£  14,204£    18,682£    10,597£    9,982£      5,912£   
Transport, Energy & Infrastructure 551£       3,412£      17,122£    3,254£      425£         425£      
Regeneration & Development 1,059£    15,380£    18,371£    721£         800£         -£           
Other 5,014£    3,334£      11,574£    6,104£      701£         528£      
Provision for return of contingencies (41)£        (506)£        (2,539)£     (2,890)£     (3,627)£     (3,347)£  
Total General Services 23,322£  64,921£    108,857£  121,975£  89,765£    12,128£ 
Total HRA 51,710£  52,125£    99,585£    91,901£    36,647£    26,128£ 
Combined Total 75,032£  117,046£  208,442£  213,876£  126,412£  38,256£ 
Capital Expenditure
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Expenditure
General Services 23,322£  64,921£    108,857£  121,975£  89,765£    12,128£  
HRA 51,710£  52,125£    99,585£    91,901£    36,647£    26,128£  
Total 75,032£  117,046£  208,442£  213,876£  126,412£  38,256£  
Financed by:
Capital receipts 3£           60£           -£              -£              -£              -£           
Capital grants 20,203£  26,397£    38,962£    19,791£    7,231£      7,121£    
Capital reserves 3,000£    2,473£      7,694£      -£              -£              -£           
Developer/Other Contributions 5,353£    17,935£    18,258£    14,542£    12,201£    3,772£    
Net financing need for the year 46,473£  70,181£    143,528£  179,543£  106,980£  27,363£  
Capital Expenditure and Available Financing
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3. Prudential Indicators for Prudence 
3.1 Net Borrowing Requirement 
This indicator shows the amount of external borrowing required to finance the current debt
outstanding on capital projects. 
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Financing Requirement
CFR – General Services 138,532£  165,056£   228,109£  323,109£   389,164£  384,772£ 
CFR – HRA 209,129£  244,290£   317,564£  390,437£   418,804£  436,365£ 
CFR – PFI Schemes 92,433£    88,739£     84,815£    80,661£     76,277£    71,663£   
Total CFR 440,094£  498,085£   630,488£  794,207£   884,246£  892,800£ 
Movement in CFR 37,230£    57,991£     132,404£  163,719£   90,039£    8,554£     
Movement in CFR represented by
Net financing need for the year (previous table) 46,473£    70,181£     143,528£  179,543£   106,980£  27,363£   
MEL Shareholder Injection -£              710£          3,560£      -£               -£              -£             
Less Scheduled Debt Amortisation (5,762)£     (9,206)£      (10,760)£   (11,670)£    (12,557)£   (14,195)£  
Less net PFI Finance Lease Principal Payments (3,481)£     (3,694)£      (3,924)£     (4,154)£      (4,384)£     (4,614)£    
Movement in CFR 37,230£    57,991£     132,404£  163,719£   90,039£    8,554£     
Capital Financing Requirement (CFR)
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
External Debt
Debt at 1 April 323,271£  321,753£  384,346£  520,674£  688,547£  782,969£ 
Actual/Expected change in Debt (1,518)£     62,593£    136,328£  167,873£  94,423£    13,168£   
Other long-term liabilities (OLTL) at 1 April 95,914£    92,433£    88,739£    84,815£    80,661£    76,277£   
Actual/Expected change in OLTL (3,481)£     (3,694)£     (3,924)£     (4,154)£     (4,384)£     (4,614)£    
Actual/Expected Gross Debt at 31 March 414,186£  473,085£  605,489£  769,208£  859,246£  867,800£ 
The Capital Financing Requirement 440,094£  498,085£  630,488£  794,207£  884,246£  892,800£ 
Under / (over) borrowing 25,908£    25,000£    25,000£    25,000£    25,000£    25,000£   
Deposits
Cash & Cash Equivalents 15,982£    25,000£    25,000£    25,000£    25,000£    25,000£   
Short-Term Investments 98,000£    70,000£    57,000£    57,000£    57,000£    57,000£   
Total Deposits 113,982£  95,000£    82,000£    82,000£    82,000£    82,000£   
Net Borrowing Requirement
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4. Prudential Indicators for External Debt 
4.1 Operational Boundary 
This is the limit beyond which external debt is not normally expected to exceed and will be the
focus of day to day treasury management.  Typically, this would be a similar figure to the CFR,
but may be lower or higher depending on the levels of actual debt.
For this Council:-
• the Operational Boundary for Borrowing has been calculated to equate directly to the
value of the CFR for General Services and HRA combined, over the current financial
year and the following 4 financial years (2023/24 to 2027/28); and
• the Operational Boundary for Other Long-Term Liabilities has been calculated to
equate directly to the in-year CFR for Other Long-Term Liabilities, given the known
contractual provisions for the repayment of debt within the Council’s two PPP
agreements. 
Should the Operational Boundary be breached, for example as a result of a decision taken to
borrow in advance (should market conditions indicate that it is prudent to do so), this will be
reported to Council at the next available opportunity. 
4.2 Authorised Limit of Total External Debt 
This indicator sets the limit for total external debt. 
The Authorised Limit for Borrowing for the 2024/25 financial year has been calculated to equate
to the maximum value of the Underlying Borrowing Requirement in 2024/25.  This equates to
£545.673 million as outlined below. 
2023/24 2024/25 2025/26 2026/27 2027/28
Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's
Operational Boundary - Borrowing 409,346£  545,673£  713,546£  807,969£  821,137£ 
Operational Boundary - Other long term liabilities 88,739£    84,815£    80,661£    76,277£    71,663£   
Total 498,085£  630,488£  794,207£  884,246£  892,800£ 
Operational Boundary
£000's
CFR - General Services at 31 March 2025 228,109£ 
CFR - HRA at 31 March 2025 317,564£ 
Authorised Limit for Borrowing 545,673£ 
Authorised Limit for Borrowing
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5. Prudential Indicators for Treasury Management 
5.1 Upper limits on Fixed and Variable Interest Rates 
This indicator limits the amount of external debt that may be held at fixed or variable rates.  These
limits are proposed to be as follows:- 
5.2 Maturity Structure of Borrowing 
This indicator sets the upper and lower limits of the time scales within which external debt may be
held. 
The Treasury Management Code of Practice requires that LOBO’s with a call date in the next 12
months are classified as short-term borrowing rather than longer-term (10 year+) borrowing. 
In addition, the Code also recommends that where an authority’s debt is typically very long term
(i.e. for a period of greater than 10 years), that authorities should break down the period in excess
of 10 years into several ranges, for example 10 to 20 years, 20 to 30 years, etc. 
With the above in mind, the proposed upper and lower limits for each maturity band are shown
below, with the overall aim to ensure a spreading approach to avoid a cluster of high value loans
maturing/requiring refinancing within a short period of time. 
Limits on fixed interest rates based on gross debt 100.00%
Limits on variable interest rates based on gross debt 30.00%
Limits on fixed interest rates based on investments 100.00%
Limits on variable interest rates based on investments 100.00%
Upper Limits on Exposure to Fixed and Variable Interest Rates 2024/25
Interest rate exposures Upper
Limit
Maturity structure of fixed interest rate borrowing 2024/25 Lower Upper
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
Maturity structure of variable interest rate borrowing 2024/25 Lower Upper
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
Maturity Structure of Borrowing 2024/25
5 years to 10 years
10 years to 20 years
20 years to 30 years
30 years to 40 years
40 years to 50 years
50 years and above
Under 12 months
12 months to 2 years
2 years to 5 years
2 years to 5 years
5 years to 10 years
10 years to 20 years
20 years to 30 years
30 years to 40 years
Under 12 months
12 months to 2 years
50 years and above
40 years to 50 years
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5.4 Total Principal Sums Invested for Periods Longer than 365 Days 
This indicator relates to the total level of investments held for periods longer than 365 days. 
The current strategy as outlined in the body of these reports is to continue to cash-back the
Council’s balance sheet reserves.  It is expected that the majority of this will be in the form of fixed
term deposits and/or certificates of deposit.  Given expected reserve forecasts and the current
interest rate environment, in particular the short-medium term forecast for the Council’s Capital
Fund and HRA Reserve, the limit for prinicipal sums invested for > 365 days has been retained at
£70m. 
For its cash flow generated balances, the Council will seek to utilise its business reserve instant
access accounts and money market funds. 
5.5 Liability Benchmark 
The “Liability Benchmark” identifies future borrowing needs across the short, medium and longer
terms, against the maturity profile of the Council’s existing loan portfolio. 
The Council’s Liability Benchmark in graphical format is as shown below. 
There are four components to the Liability Benchmark: - 
1 Existing loan debt outstanding: the Council’s existing loans that are still
outstanding in future years – shown as the stacked bar elements of the figure
above.
Limit £70m
Principal Sums Invested for > 365 Days
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2 Loans CFR: this is calculated in accordance with the loans CFR definition in the
Prudential Code and projected into the future based on approved prudential
borrowing and planned Loans Fund advances/Loans Fund principal repayments. 
3 Net loans requirement: this shows the Council’s gross loan debt less treasury
management investments at the last financial year-end, projected into the future
and based on its approved prudential borrowing, planned Loans Fund principal
repayments and any other major cash flows (drawdowns/enhancement of
reserves) forecast.
4 Liability benchmark (or gross loans requirement): this equals net loans
requirement plus short-term liquidity/working capital allowance. 
The Liability Benchmark Indicator identifies the Council’s expected future capital financing
requirement, as driven by the Council’s approved Capital Plans – and therefore the Council’s
future borrowing needs; along with how this matches to the existing debt maturity profile.  It is
therefore a key tool to support the financing risk management of the capital financing
requirement. 
As can be noted from the figure above, the Council has a significant borrowing requirement
(which equates to £478.638 million) in the short-medium term, arising as a direct result of the
Council’s approved Capital Plans.  The proposed approach to securing this borrowing need for
the 2024/25 financial year is outlined in the main body of this report, Section 4.3. 
The Liability Benchmark also outlines the profile of the Council’s CFR over the medium-long term,
against the Council’s existing debt portfolio maturity profile.  As can be seen from the figure
above, the profile of the CFR movements in the medium-long term broadly matches the
movements in the Councils external debt portfolio over this period. 
The Debt Liability Benchmark will assist the Council with plotting the tenor of borrowing to finance
the Council’s approved capital plans that is undertaken in the remainder of 2023/24 and the
forthcoming 2024/25 period, to ensure that this aligns with the Council’s future expected CFR
profile and Liability Benchmark projections, taking into account the profile of existing loan
maturities as identified in the figure above. 
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Page 52

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Page 53

Appendix 3 
Treasury Management Strategy Statement
and Annual Investment Strategy 
Midlothian Council
2024/25 
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INDEX 
1 INTRODUCTION ............................................................................................................................ 3
1.1 Background ............................................................................................................................................... 3
1.2 Reporting requirements ............................................................................................................................ 3
1.3 Treasury Management Strategy for 2024/25 ........................................................................................... 5
1.4 Training ...................................................................................................................................................... 5
1.5 Treasury management consultants .......................................................................................................... 6
2 THE CAPITAL PRUDENTIAL INDICATORS 2024/25 – 2027/28 ............................................. 7
2.1 Capital expenditure ................................................................................................................................... 7
2.2 The Council’s borrowing need (the Capital Financing Requirement) ...................................................... 8
3 Borrowing .................................................................................................................................... 11
3.1 Current portfolio position ......................................................................................................................... 11
3.2 Treasury Indicators: limits to borrowing activity ...................................................................................... 13
3.3 Prospects for interest rates ..................................................................................................................... 14
3.4 Borrowing strategy .................................................................................................................................. 17
3.5 Policy on borrowing in advance of need ................................................................................................. 21
3.6 Debt rescheduling ................................................................................................................................... 21
4 ANNUAL INVESTMENT STRATEGY ........................................................................................ 22
4.1 Investment policy ..................................................................................................................................... 22
4.2 Creditworthiness policy ........................................................................................................................... 24
4.3 Country and sector limits ......................................................................................................................... 25
4.4 Investment strategy ................................................................................................................................. 26
4.5 Investment risk benchmarking ................................................................................................................ 27
4.6 End of year investment report ................................................................................................................. 27
5 Appendices .................................................................................................................................. 28
5.1 APPENDIX: Economic Background ....................................................................................................... 29
5.2 APPENDIX: Treasury Management Practice (TMP1): Permitted Investments .................................... 29
5.3 APPENDIX: Treasury Management Practice (TMP1) – Credit and Counterparty Risk Management 42
5.4 APPENDIX: Approved countries for investments .................................................................................. 48
5.5 APPENDIX: Treasury management scheme of delegation .................................................................. 49
5.6 APPENDIX: The treasury management role of the section 95 officer .................................................. 50 
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1 INTRODUCTION
1.1 Background
The main function of the treasury management service is the funding of the Council’s
capital plans.  These capital plans provide a guide to the borrowing need of the Council,
essentially the longer term cash flow planning to ensure that the Council can meet its
capital spending obligations.  This management of longer term cash may involve
arranging long or short term loans, or using longer term cash flow surpluses.   On
occasion any debt previously drawn may be restructured to meet Council risk or cost
objectives. 
The Council is required to operate a balanced budget, which broadly means that cash
raised during the year will meet cash expenditure.  As such, the second part of the treasury
management operation is to ensure that this cash flow is adequately planned, with cash
being available when it is needed.  Surplus monies are deposited with low risk
counterparties or instruments commensurate with the Council’s low risk appetite, providing
adequate liquidity initially before considering investment return. 
The contribution the treasury management function makes to the authority is critical, as the
balance of debt and investment operations ensure liquidity or the ability to meet spending
commitments as they fall due, either on day-to-day revenue or for larger capital projects. 
The treasury operations will see a balance of the interest costs of debt and the investment
income arising from cash deposits affecting the available budget.  Since cash balances
generally result from reserves and balances, it is paramount to ensure adequate security
of the sums invested, as a loss of principal will in effect result in a loss to the General Fund
Balance. 
Whilst any loans to third parties, commercial investment initiatives or other non-financial
investments will impact on the treasury function, these activities are generally classed as
non-treasury activities, (arising usually from capital expenditure),and are separate from the
day to day treasury management activities. 
CIPFA defines treasury management as: 
“The management of the local authority’s borrowing, investments and cash flows, its
banking, money market and capital market transactions; the effective control of the risks
associated with those activities; and the pursuit of optimum performance consistent with
those risks.” 
Whilst any commercial initiatives or loans to third parties will impact on the treasury
function, these activities are generally classed as non-treasury activities, (arising
usually from capital expenditure), and are separate from the day-to-day treasury
management activities 
1.2 Reporting requirements
1.2.1 Capital Strategy 
The CIPFA Prudential and Treasury Management Codes require all local authorities
to prepare an additional report, a capital strategy report, which provides the following: 
• a high-level long term overview of how capital expenditure, capital financing
and treasury management activity contribute to the provision of services
• an overview of how the associated risk is managed
• the implications for future financial sustainability 
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The aim of the capital strategy is to ensure that all elected members on the full council
fully understand the overall long-term policy objectives and resulting capital strategy
requirements, governance procedures and risk appetite. 
1.2.2 Treasury Management Reporting 
The Council is required to receive and approve, as a minimum, three main reports each
year, which incorporate a variety of polices, estimates and actuals.   
a) Prudential and treasury indicators and treasury strategy (this report) - The
first, and most important report covers:
• the capital plans (including prudential indicators) for 2023/24 to 2027/28;
• a policy for the statutory repayment of debt, (how residual capital expenditure
is charged to revenue over time);
• the treasury management strategy (how the investments and borrowings are
to be organised) for 2024/25, including treasury indicators; and 
• a permitted investment strategy for 2024/25 (the parameters on how
investments are to be managed). 
b) A mid year treasury management report – This will update members with
the progress of the capital position, amending prudential indicators as
necessary, and whether the actual treasury strategy is meeting the strategy
outlined in advance of the year, or whether any policies require revision. 
c) An annual treasury outturn report – This provides details of a selection of
actual prudential and treasury indicators for the previous financial year and
actual treasury operations compared to the estimates within the strategy. 
Scrutiny
The above reports are required to be adequately scrutinised before being
recommended to the Council.  This role is undertaken by the Audit Committee with this
report being presented to Audit Committee prior to consideration by Council.  Revisions
arising from Audit Committee consideration of the report on 29 January 2024 will be
incorporated into the final version of the report to Council on 27 February 2024. 
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1.3 Treasury Management Strategy for 2024/25
The strategy for 2024/25 covers two main areas: 
Capital issues
• the capital expenditure plans and the prudential indicators (Section 2 of this report);
• The policy for the statutory repayment of loans fund advance (Section 2.4 of this
report). 
Treasury management issues
• policy on use of external service providers (Section 1.5);
• the current treasury position (Section 3.1);
• treasury indicators which limit the treasury risk and activities of the Council (Section
3.2);
• prospects for interest rates (Section 3.3);
• the borrowing strategy (Section 3.4);
• policy on borrowing in advance of need (Section 3.5);
• debt rescheduling (Section 3.6);
• the investment strategy (Section 4.1); and
• creditworthiness policy (Section 4.2). 
These elements cover the requirements of the Local Government in Scotland Act 2003, the
CIPFA Prudential Code, the CIPFA Treasury Management Code and The Scottish
Government Local Authority (Capital Finance & Accounting) (Scotland) Regulations 2016.
1.4 Training
The CIPFA Code requires the responsible officer to ensure that members with responsibility
for treasury management receive adequate training in treasury management.  This
especially applies to members responsibe for scrutiny.   
Furthermore, pages 47 and 48 of the Code state that they expect “all organisations to have
a formal and comprehensive knowledge and skills or training policy for the effective
acquisition and retention of treasury management knowledge and skills for those
responsible for management, delivery, governance and decision making. 
Organisations need to consider how to assess whether treasury management staff and
board/ council members have the required knowledge and skills to undertake their roles
and whether they have been able to maintain those skills and keep them up to date. 
As a minimum, authorities should carry out the following to monitor and review knowledge
and skills: 
• Record attendance at training.
• Prepare tailored learning plans for treasury management officers and
board/council members.
• Require treasury management officers and board/council members to
undertake self-assessment against the required competencies. 
• Have regular communication with officers and board/council members,
encouraging them to highlight training needs on an ongoing basis.” 
In further support of the revised training requirements, CIPFA’s Better Governance Forum
and Treasury Management Network have produced a ‘self-assessment by members
responsible for the scrutiny of treasury management’, which is available from the CIPFA
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website to download.  This was presented to members of the Audit Committee and Council
as part of the Council’s Treasury Management 2021-22 Mid-Year Review Report. 
A formal record of Knowledge & Skills Schedule has been developed as part of the
Council’s Treasury Management Practices.  This will be periodically reviewed to assess
suitability, and updated to reflect ongoing training, knowledge and skills gained.  Similarly,
a formal record of the treasury management/capital finance training received by members
will also be periodically reviewed and updated. 
1.5 Treasury management consultants
The Council uses Link Group, Link  Treasury Services Limited as its external treasury
management advisors. 
The Council recognises that responsibility for treasury management decisions remains with
the organisation at all times and will ensure that undue reliance is not placed upon our
external service providers.  All decisions will be undertaken with regards to all available
information, including, but not solely, our treasury advisers. 
It also recognises that there is value in employing external providers of treasury
management services in order to acquire access to specialist skills and resources. The
Council will ensure that the terms of their appointment and the methods by which their value
will be assessed are properly agreed and documented, and subjected to regular review. 
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2 THE CAPITAL PRUDENTIAL INDICATORS 2023/24 –
2027/28
The Council’s capital expenditure plans are the key driver of treasury management
activity.  The output of the capital expenditure plans is reflected in the prudential
indicators, which are designed to assist members’ overview and confirm capital
expenditure plans.
2.1 Capital expenditure
This prudential indicator is a summary of the Council’s capital expenditure plans,
both those agreed previously, and those forming part of this budget cycle.
The table below summarises the Capital Expenditure forecasts:- 
The table below shows how the Capital Expenditure forecasts are being financed
by capital or revenue resources.  Any shortfall of resources results in a funding
borrowing need. 
Note: The above financing need excludes other long term liabilities, such as PFI
and leasing arrangements which already include borrowing instruments.  
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
General Services
Children, Young People & Estates 5,300£    29,096£    45,647£    104,189£  81,483£    8,610£   
Asset Management 11,439£  14,204£    18,682£    10,597£    9,982£      5,912£   
Transport, Energy & Infrastructure 551£       3,412£      17,122£    3,254£      425£         425£      
Regeneration & Development 1,059£    15,380£    18,371£    721£         800£         -£           
Other 5,014£    3,334£      11,574£    6,104£      701£         528£      
Provision for return of contingencies (41)£        (506)£        (2,539)£     (2,890)£     (3,627)£     (3,347)£  
Total General Services 23,322£  64,921£    108,857£  121,975£  89,765£    12,128£ 
Total HRA 51,710£  52,125£    99,585£    91,901£    36,647£    26,128£ 
Combined Total 75,032£  117,046£  208,442£  213,876£  126,412£  38,256£ 
Table 1: Capital Expenditure
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Expenditure
General Services 23,322£  64,921£    108,857£  121,975£  89,765£    12,128£  
HRA 51,710£  52,125£    99,585£    91,901£    36,647£    26,128£  
Total 75,032£  117,046£  208,442£  213,876£  126,412£  38,256£  
Financed by:
Capital receipts 3£           60£           -£              -£              -£              -£           
Capital grants 20,203£  26,397£    38,962£    19,791£    7,231£      7,121£    
Capital reserves 3,000£    2,473£      7,694£      -£              -£              -£           
Developer/Other Contributions 5,353£    17,935£    18,258£    14,542£    12,201£    3,772£    
Net financing need for the year 46,473£  70,181£    143,528£  179,543£  106,980£  27,363£  
Table 2: Capital Expenditure and Available Financing
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2.2 The Council’s borrowing need (the Capital Financing Requirement)
The second prudential indicator is the Council’s Capital Financing Requirement
(CFR).  The CFR is simply the total historic outstanding capital expenditure which
has not yet been paid for from either revenue or capital resources.  It is essentially
a measure of the Council’s underlying borrowing need.  Any capital expenditure
above, which has not immediately been paid for (financed), will increase the CFR.
The CFR does not increase indefinitely, as annual repayments from revenue need
to be made which reflect the useful life of capital assets financed from borrowing. 
From 1st April 2016, Local Authorities may choose whether to use scheduled debt
amortisation (loans pool charges) or another suitable method of calculation in order
to repay borrowing.
The CFR includes any other long term liabilities (e.g. PFI schemes, finance leases). 
Whilst these increase the CFR, and therefore the Council’s borrowing requirement,
these types of scheme already include a borrowing facility and so the Council is
not required to separately borrow for these schemes.  The Council currently has
£95.914m of such schemes within the CFR.  The Council is asked to approve the
CFR projections below: 
A key aspect of the regulatory and professional guidance is that elected members
are aware of the size and scope of any commercial activity in relation to the
authority’s overall financial position.  The capital expenditure figures shown in 2.1
and the details above demonstrate the scope of this activity and, by approving
these figures, consider the scale proportionate to the Authority’s remaining activity.
2.3 Liability Benchmark
A third prudential indicator is the Debt Liability Benchmark (LB).  The Authority is
required to estimate and measure the LB for the forthcoming financial year and
the following two financial years, as a minimum. 
There are four components to the Liability Benchmark: - 
1 Existing loan debt outstanding: the Council’s existing loans that are still
outstanding in future years.
2 Loans CFR: this is calculated in accordance with the loans CFR definition
in the Prudential Code and projected into the future based on approved
prudential borrowing and planned Loans Fund advances/Loans Fund
principal repayments. 
3 Net loans requirement: this shows the Council’s gross loan debt less
treasury management investments at the last financial year-end, projected
into the future and based on its approved prudential borrowing, planned
Loans Fund principal repayments and any other major cash flows
(drawdowns/enhancement of reserves) forecast.
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
Capital Financing Requirement
CFR – General Services 138,532£  165,056£   228,109£  323,109£   389,164£  384,772£ 
CFR – HRA 209,129£  244,290£   317,564£  390,437£   418,804£  436,365£ 
CFR – PFI Schemes 92,433£    88,739£     84,815£    80,661£     76,277£    71,663£   
Total CFR 440,094£  498,085£   630,488£  794,207£   884,246£  892,800£ 
Movement in CFR 37,230£    57,991£     132,404£  163,719£   90,039£    8,554£     
Movement in CFR represented by
Net financing need for the year (previous table) 46,473£    70,181£     143,528£  179,543£   106,980£  27,363£   
MEL Shareholder Injection -£              710£          3,560£      -£               -£              -£             
Less Scheduled Debt Amortisation (5,762)£     (9,206)£      (10,760)£   (11,670)£    (12,557)£   (14,195)£  
Less net PFI Finance Lease Principal Payments (3,481)£     (3,694)£      (3,924)£     (4,154)£      (4,384)£     (4,614)£    
Movement in CFR 37,230£    57,991£     132,404£  163,719£   90,039£    8,554£     
Table 3: Capital Financing Requirement (CFR)
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4 Liability benchmark (or gross loans requirement): this equals net
loans requirement plus short-term liquidity/working capital allowance. 
2.4 Core funds and expected investment balances
The application of resources (capital receipts, reserves etc.) to either finance
capital expenditure or other budget decisions to support the revenue budget will
have an ongoing impact on investments unless resources are supplemented each
year from new sources (asset sales etc.).  Detailed below are estimates of the year-
end balances for each resource and anticipated day-to-day cash flow balances. 
*Working capital balances shown are estimated year-end; these may be higher
mid-year 
2.5 Statutory repayment of loans fund advances
Under the Local Government Finance Circular 7/2016, Council is now required to set
out its policy for the statutory repayment of loans fund advances prior to the start of
each financial year. The repayment of loans fund advances ensures that the Council
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
HRA Balances 32,143£    34,384£    35,762£      37,087£      38,367£    39,100£ 
General Fund Balances 9,877£      7,000£      5,000£        5,000£        5,000£      5,000£   
Earmarked reserves 24,317£    4,399£     2,000£        -£                -£              -£           
Provisions 4,138£      4,000£      3,900£        3,800£        3,700£      3,600£   
Capital Fund 20,107£    17,984£    10,290£      10,290£      10,290£    10,290£ 
Total Reserves / Core Funds 90,582£    67,767£    56,952£      56,177£      57,357£    57,990£ 
Working capital* 49,308£    52,233£    50,048£      50,823£      49,643£    49,010£ 
Under/over borrowing 25,908£    25,000£    25,000£      25,000£      25,000£    25,000£ 
Expected investments 113,982£  95,000£    82,000£      82,000£      82,000£    82,000£ 
Reserve
Table 4: Balance Sheet Resources
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makes a prudent provision each year to pay off an element of the accumulated loans
fund advances made in previous financial years.
It is proposed to retain the methodology adopted in 2023/24 – that is as follows:-
New Assets
In accordance with Finance Circular 7/2016, for all advances made in relation to the
provision of a new asset, the policy will be to defer the commencement of the first
principal repayment of the loans fund advance until the financial year following the one
in which the asset is first available for use.
Prudent Repayment of Loans Fund Advances
Finance Circular 7/2016 provides a variety of options to Councils for the profiling of the
repayment of each loans fund advance, so long as the principle of prudence is
maintained.  There are 4 options available: (a) Asset Life method; (b) Statutory method;
(c) Depreciation method; and (d) Funding/income profile method.
In line with the policy adopted in 2023/24, the Asset Life method shall be used for those
assets in Table 6.
Table 5: Asset Classes to adopt the “Asset Life” method
Infrastructure
Curren
Loans Fund
Advance
Period
New Primary Schools/Extensions 60
New Leisure Centres 60
New Offices 60
Road Upgrades 50
Street Lighting Columns 50
Structures/Bridges 50
Footway/Cyclepaths 50
Town Centre Environmental Improvements 50
New Care Homes 45
Children’s Play Equipment 20
* Average loans fund advance length
The annual repayments under the “Asset Life” method for those asset classes as noted
above will be calculated using the asset lives and will use the annuity method, to
ensure consistency of approach with the Statutory method for all other asset classes
(see below).  The annuity interest rate that will be used to calculate loans fund principal
repayments under the “Asset Life” method will be the in-year loans fund rate, which for
2023/24 is currently estimated to be 2.21%.
For all other asset classes, the policy will be to maintain the practice of previous years
and apply what is termed “the Statutory Method” – following the principles of Schedule
3 of the Local Government (Scotland) Act 1975 – with all loans fund advances being
repaid by the annuity method.  The annuity rate that is proposed to be applied to the
loans fund repayments varies will be the in-year loans fund rate, reflecting the Council’s
current loan and investment portfolio.  The loans fund rate for 2023/24 is forecast to be
2.21%
Whilst neither the Depreciation nor the Funding/income profile methods are currently
proposed, Council officers will continue to monitor whether it is appropriate to use this
for future capital projects.  
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3 Borrowing
The capital expenditure plans set out in Section 2 provide details of the service activity of
the Council.  The treasury management function ensures that the Council’s cash is
organised in accordance with the the relevant professional codes, so that sufficient cash is
available to meet this service activity.  This will involve both the organisation of the cash
flow and, where capital plans require, the organisation of approporiate borrowing facilities. 
The strategy covers the relevant treasury / prudential indicators, the current and projected
debt positions and the annual investment strategy.
3.1 Treasury management portfolio position
The overall treasury management portfolio as at 31 March 2023 and for the position as at
17 January 2024 are shown below for both borrowing and investments.
Table 6: Portfolio Position 31 March 2023 and 17 January 2024 
The Council’s forward projections for borrowing and investments are summarised below.
The table shows the actual external debt (the treasury management operations), against
the underlying capital borrowing need (the Capital Financing Requirement - CFR),
highlighting any over or under borrowing. 
Within the range of prudential indicators there are a number of key indicators to ensure
that the Council operates its activities within well-defined limits.  One of these is that
the Council needs to ensure that its gross debt does not, except in the short term, exceed
Principal Weighted Principal Weighted
Outstanding Average Outstanding Average
£000’s Rate £000’s Rate
PWLB Annuity                505 8.91%                452 8.91%
PWLB Maturity         284,128 2.90%         284,128 2.90%
LOBO           20,000 4.51%           20,000 4.51%
Market Loans           16,886 2.68%           16,221 2.68%
Salix Loans                235 0.00%                  70 0.00%
Total Loans         321,754 3.00%         320,871 3.00%
Principal Weighted Principal Weighted
Outstanding Average Outstanding Average
£000’s Rate £000’s Rate
Bank Call Accounts                    2 3.80%             7,343 5.09%
Money Market Funds           15,980 3.96%           35,073 5.32%
Bank Fixed Term Deposits           86,000 3.93%           30,000 4.98%
Bank Certificates of Deposit           10,000 2.85%                  -   0.00%
Other Local Authorities             2,000 1.60%                  -   0.00%
Total Deposits         113,982 3.80%           72,416 5.15%
17 January 202431 March 2023
31 March 2023 17 January 2024
Loan Type
Deposit Type
2022/23 2023/24 2024/25 2025/26 2026/27 2027/28
Actual Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's £000's
External Debt
Debt at 1 April 323,271£  321,753£  384,346£  520,674£  688,547£  782,969£ 
Actual/Expected change in Debt (1,518)£     62,593£    136,328£  167,873£  94,423£    13,168£   
Other long-term liabilities (OLTL) at 1 April 95,914£    92,433£    88,739£    84,815£    80,661£    76,277£   
Actual/Expected change in OLTL (3,481)£     (3,694)£     (3,924)£     (4,154)£     (4,384)£     (4,614)£    
Actual/Expected Gross Debt at 31 March 414,186£  473,085£  605,489£  769,208£  859,246£  867,800£ 
The Capital Financing Requirement 440,094£  498,085£  630,488£  794,207£  884,246£  892,800£ 
Under / (over) borrowing 25,908£    25,000£    25,000£    25,000£    25,000£    25,000£   
Deposits
Cash & Cash Equivalents 15,982£    25,000£    25,000£    25,000£    25,000£    25,000£   
Short-Term Investments 98,000£    70,000£    57,000£    57,000£    57,000£    57,000£   
Total Deposits 113,982£  95,000£    82,000£    82,000£    82,000£    82,000£   
Table 7: Net Borrowing Requirement
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the total of the CFR in the preceding year plus the estimates of any additional CFR for
2024/25.
The Chief Financial Officer & Section 95 Officer reports that the Council complied with
this prudential indicator in the current year and does not envisage difficulties for the
future.  This view takes into account current commitments, existing plans, and the
proposals in this budget report.  
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3.2 Treasury Indicators: limits to borrowing activity
The operational boundary
This is the limit beyond which external debt is not normally expected to exceed.  In
most cases, this would be a similar figure to the CFR, but may be lower or higher
depending on the levels of actual debt.
For this Council:-
• the Operational Boundary for Borrowing has been calculated to equate directly
to the in-year value of the CFR over the current and following 4 financial years
(2023/24 to 2027/28); and
• the Operational Boundary for Other Long-Term Liabilities has been calculated
to equate directly to the in-year CFR for Other Long-Term Liabilities, given the
known contractual provisions for the repayment of debt within the Council’s two
PPP agreements. 
The authorised limit for external debt
This indicator sets the limit for total external debt. 
The Authorised Limit for Borrowing for the 2024/25 financial year has been calculated to
equate to the maximum value of the Underlying Borrowing Requirement in 2024/25.  This
equates to £545.673 million as outlined below. 
2023/24 2024/25 2025/26 2026/27 2027/28
Estimate Estimate Estimate Estimate Estimate
£000's £000's £000's £000's £000's
Operational Boundary - Borrowing 409,346£  545,673£  713,546£  807,969£  821,137£ 
Operational Boundary - Other long term liabilities 88,739£    84,815£    80,661£    76,277£    71,663£   
Total 498,085£  630,488£  794,207£  884,246£  892,800£ 
Table 8: Operational Boundary
£000's
CFR - General Services at 31 March 2025 228,109£ 
CFR - HRA at 31 March 2025 317,564£ 
Authorised Limit for Borrowing 545,673£ 
Table 9: Authorised Limit for Borrowing
384,346
520,674
688,547
782,969 796,137
£-
£100,000
£200,000
£300,000
£400,000
£500,000
£600,000
£700,000
£800,000
£900,000
2023/24 2024/25 2025/26 2026/27 2027/28
£000's
Financial Year
Prudential Indicators for Borrowing
External Debt Authorised Limit Underlying Borrowing Requirement / Operational Boundary
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3.3 Prospects for interest rates
The Council has appointed Link Group, Link  Treasury Services Limited as its treasury
advisor and part of their service is to assist the Council to formulate a view on interest
rates. Link provided the following forecasts for certainty rates, gilt yields plus 80 bps
on 8 January 2024. 
At its 14th December meeting, the Bank of England’s Monetary Policy Committee
(MPC) kept rates on hold for the third time in a row, pushing back against the prospect
of near-term interest rate cuts. The vote in favour of keeping rates on hold was 6-3. 
However, recent softer wage and inflation data (annual CPI is currently 3.9%) mean
that markets have moved significantly in the direction of Link’s November interest rate
forecast, pricing in a first rate cut in Q2 2024.  Link now expects Bank Rate to be cut
to 4.25% by the end of 2024 and 3% by the end of 2025. The low point of the interest
rate cycle is also expected to be 3%. 
Regarding the Bank of England, it continued to sound hawkish last month. Indeed, the
evidence of subsiding price pressures did not dissuade the more hawkish members of
the Monetary Policy Committee (MPC) – Catherine Mann, Megan Greene and
Jonathan Haskel – from again voting to raise interest rates by 25 basis points (bps).
The MPC maintained its tightening bias saying that “further tightening in monetary
policy would be required if there were evidence of more persistent inflationary
pressures”. And it reiterated that policy will be “sufficiently restrictive for sufficiently
long” and that “monetary policy is likely to need to be restrictive for an extended period
of time”. 
At the time of the meeting, the Bank did not appear to have taken any comfort from
subsiding price pressures in the US and the Eurozone either, saying that measures of
inflation persistence are higher in the UK than in other major advanced economies.
And its statement that relative to developments in the US and the Eurozone “measures
of wage inflation were considerably higher in the UK and services price inflation had
fallen back by less so far”. Nonetheless, even if the Bank would prefer to cut interest
rates after the Fed and the ECB, Capital Economics’ forecast for the CPI measure of
inflation to drop below 2% by April, and for core inflation to drop below 2% only three
months later, adds further grist to the mill that rates will be cut sharply in the second
half of 2024 if not before. 
Since the December rate decision, the Bank’s hawkish bias has also not prevented the
markets from forming a view that rates will be falling soon. Accordingly, swap rates and
gilt yields have reduced significantly over the past month despite a partial rebound
upwards since the turn of the year. This will have the effect of ensuring upcoming
mortgage rate resets (c400k per quarter) will be somewhat lower than they were
through the second half of 2023. Indeed, it is noteworthy that the Halifax house price
index has recently moved into positive territory after registering only a slight fall in
house prices from their peak in the summer of 2022. 
Looking further afield, we suspect the wider economy may only endure the lightest of
recessions or, possibly, not at all. The Bank’s November Quarterly Monetary Policy
Report saw it revise down its Q3 and Q4 GDP forecasts for 2023 and its annual
forecast for 2024 from 0.4% to 0.0% (2023 stayed at 0.5%). But it could be this outlook
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underestimates the robustness and resilience of the UK economy, particularly
considering upward revisions to GDP stemming from the pandemic years. 
There are, of course, significant risks to Link’s central forecast. First, it is likely still the
early days of the Gaza-Israel conflict, and a meaningful and prolonged shift up in oil
prices from $75 per barrel to something closer to $120 would keep inflation higher for
longer. Furthermore, the UK domestic labour market is still having to contend with very
low unemployment (4.2%) and the total number of job vacancies is only a little below
one million. It is unlikely that a fundamental overhaul of immigration policy, with a view
to addressing staff shortages in various sectors of the economy, is going to be a priority
regardless of the current/future government, so keeping a lid on wages is going to be
a tough challenge even if some of the more recent signs are that wage growth is
moderating (still c7% y/y). 
Regarding PWLB rates, movement in the short part of the curve has reflected the
revised Bank Rate expectations to a large degree, whilst medium to longer-dated
PWLB rates will remain influenced not only by the outlook for inflation, but by the
market’s appetite for significant gilt issuance. Indeed, although Link have a slightly
lower starting point for the envisaged reduction in short and medium dated gilts, they
now forecast the 10, 25 and 50 years part of the curve to stay a bit higher than earlier
forecasts from 2023/24. 
Furthermore, a General Election is expected in the next year, so Government fiscal
policy may potentially loosen at the same time as the Bank’s monetary policy is still
trying to take momentum out of the economy. That may mean that Bank Rate stays
elevated for a little longer than Link’s central forecast. 
Of course, what happens outside of the UK remains critical to movement in gilt yields
as well. The ECB has made it clear that policy tightening is at, or close to, the terminal
rate (currently 4%), whilst the US FOMC has held its Bank Rate equivalent in the range
of 5.25% - 5.5%. 
A SUMMARY OVERVIEW OF THE FUTURE PATH OF BANK RATE 
Link’s current central forecast for interest rates expects rate cuts to start when both the
CPI inflation and wage/employment data are supportive of such a move, and when
there is a likelihood of the overall economy enduring at least a slowdown or mild
recession over the coming months (although most recent GDP releases have surprised
with their on-going robustness). 
Naturally, timing on this matter will remain one of fine judgment: cut too soon, and
inflationary pressures may well build up further; cut too late and any downturn or
recession may be prolonged. 
In the upcoming months, Link’s forecasts will be guided not only by economic data
releases and clarifications from the MPC over its monetary policies and the
Government over its fiscal policies, but also international factors such as policy
development in the US and Europe, the provision of fresh support packages to support
the faltering recovery in China as well as the on-going conflict between Russia and
Ukraine, and Gaza and Israel. 
PWLB RATES 
The short and medium part of the gilt curve has rallied since the start of November as
markets price in a quicker reduction in Bank Rate through 2024 and 2025 than held
sway back then. This reflects market confidence in inflation falling back in a similar
manner to that already seen in the US and the Euro-zone. At the time of writing there
is c70 basis points difference between the 5 and 50 year parts of the curve. 
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The balance of risks to the UK economy: - 
The overall balance of risks to economic growth in the UK is even. 
Downside risks to current forecasts for UK gilt yields and PWLB rates include: - 
- Labour and supply shortages prove more enduring and disruptive and
depress economic activity (accepting that in the near-term this is also an
upside risk to inflation and, thus, could keep gilt yields high for longer). 
- The Bank of England has increased Bank Rate too fast and too far over
recent months, and subsequently brings about a deeper and longer UK
recession than we currently anticipate. 
- Geopolitical risks, for example in Ukraine/Russia, the Middle East,
China/Taiwan/US, Iran and North Korea, which could lead to increasing
safe-haven flows. 
Upside risks to current forecasts for UK gilt yields and PWLB rates: - 
- Despite the tightening in Bank Rate to 5.25%, the Bank of England allows
inflationary pressures to remain elevated for a long period within the UK
economy, which then necessitates Bank Rate staying higher for longer than
we currently project. 
- The pound weakens because of a lack of confidence in the UK
Government’s pre-election fiscal policies, which may prove inflationary,
resulting in investors pricing in a risk premium for holding UK sovereign
debt. 
- Projected gilt issuance, inclusive of natural maturities and QT, could be too
much for the markets to comfortably digest without higher yields
compensating. 
LINK GROUP FORECASTS 
Link expect the MPC will keep Bank Rate at 5.25% until the second half of 2024, to
combat on-going inflationary and wage pressures, even if they have dampened
somewhat of late. Link do not think that the MPC will increase Bank Rate above 5.25%. 
A more detailed interest rate view and economic commentary is provided at
appendix 5.1. 
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3.4 Borrowing strategy 
Borrowing is undertaken to finance the Council’s approved Capital plans and to do so
in the most cost-effective way.  As can been noted from Table 4 above the Council has
a significant borrowing requirement across the current and forthcoming four financial
years (2023/24 to 2027/28). 
This TMIS provides for this capital investment to be underpinned by long-term
borrowing, recognising the current interest rate environment, the significant borrowing
requirement arising from the Council’s capital plans, and the long term benefits of de
risking the delivery and affordability of these capital plans by locking into the certainty
brought by PWLB fixed rate loans. 
The Council’s external loan debt at 31 March 2024 is projected to be £384.346
million.  Based on the Council’s historic and current approved Capital Plans, the
Underlying Borrowing Requirement (UBR) – which is the Council’s underlying need
to borrow for capital purposes (excluding the long-term liability arising from PFI/DBFM
projects) – at 31 March 2024 is expected to equate to £409.346 million. 
This means that the Council is expected to be £25.000 million (6%) under-borrowed at
the end of the 2023/24 financial year i.e. the Council has funded the majority (94%) of
its underlying borrowing requirement as at 31 March 2024.  In the current economic
climate, this is a prudent approach which balances (a) de-risking the longer term
borrowing requirement at current longer term borrowing rates; against (b) the current
year and forthcoming financial year budget projections.  The Council has an extremely
low short-medium term exposure to refinancing risk and is therefore in a strong
position to plan its new borrowing requirements in advance, taking advantage of any
dips in longer-term borrowing rates from PWLB and other sources, and maintain a low
weighted average coupon rate on external debt.   
The Underlying Borrowing Requirement is projected to rise to £821.137 million by
31 March 2028 – more than double the current Underlying Borrowing Requirement. 
The profile of this, and the projected external loan portfolio to fund the Underlying
Borrowing Requirement over the period 2023/24 to 2027/28, is shown in graphical
format below. 
Figure 3: Loan Portfolio & Underlying Borrowing Requirement 
Interest Rates
The current PWLB yield curve is bell shaped with the low point in the curve is at the 5
year mark (4.40%) with rates trending upwards towards the 20-30 year tenor (5.25%)
before easing back slightly to sit at c. 5.10% in the 50 year duration.  Current rates
have generally eased off 30-40bps from levels reported at the time of the 2023/24
Treasury Management Mid-Year Review Report to Council, with no material change to
the medium term forecast for rates.
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The yield curve is expected to remain bell shaped over the short-medium term, with a
gradual shift downwards of the entire curve by c. 40-60bps over the next 12 months
and a further 40-50bps over the subsequent 12 months.  This is forecast to bring
longer-term borrowing rates down to between 4.10-4.60% by March 2025 and
between 3.70%-4.20% by March 2026.  Further commentary on this is provided in
Appendix 3 Section 3.3. 
The funding of the Council’s in-year and forward CFR is typically for infrastructure with
long asset lives (50-60 years), and the tenor of PWLB and market loans are typically
drawn with this in mind. 
Consideration for any new borrowing in the remainder of the 2023/24 financial year
and during the 2024/25 financial year, to fund the Council’s in-year CFR, will seek to
balance:- 
a) the security/certainty of current relatively high longer-term borrowing
rates of upwards of 5.25% in the 30-50 year duration (which are
forecast to drop by 60bps within one year and 100bps within 24 months)
and the potential additional budgetary pressure that this brings in both
the short/medium and longer term; with 
b) the option to borrow initially for a shorter-term duration from PWLB or
other markets, for 3 to 5 years (at say c. 4.40%), to allow the Council to
fund the immediate in-year borrowing requirement.  Based on current
interest rate forecasts (see Appendix 3 Section 3.3), this would then
allow the Council the option to refinance this borrowing at initial 3-5 year
maturity with less expensive, longer term borrowing, e.g. a 45 to 47 year
tenor in, say, 36 months at a forecast rate of c. 3.90%. 
As noted in Section 3.1, the Council’s proactive Treasury Management over the last
decade has put the Council in a strong refinancing position for its external debt
portfolio which allows the Council to slot in shorter dated external borrowing into the
current debt maturity profile to fund the current & forthcoming in-year borrowing
requirements, to allow the Council to navigate past the current expected hump in
longer-term borrowing rates. 
It is expected that any further long-term borrowing that is undertaken during 2023/24
and 2024/25 to finance the current & future year capital plans will be sourced by
drawing new PWLB loans at the Certainty Rate (which has been available to the
Council since 2012 and is priced at Gilts+80bps), and/or the HRA rate.  The HRA rate
is available to all Councils to fund HRA capital expenditure, at a rate that is priced at
Gilts+60bps.  On 22 November 2023, the availability over which Councils can draw
HRA rate borrowing from PWLB was extended to 30 June 2025. 
Both the General Services and HRA capital programmes are being kept under regular
review due to the effects of inflationary pressures, shortages of materials and labour,
and the ratios of financing costs to the net revenue streams.  The Council’s borrowing
strategy will, therefore, also be regularly reviewed and then revised, if necessary, to
achieve optimum value and risk exposure in the medium-long-term.  The impact
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particularly of the General Services Capital Plan Prioritisation – which will be reported
to Council in February 2024 – will have a significant bearing on this. 
Council officers, in conjunction with Link, will continue to monitor daily long-term
borrowing rates in order to take advantage of any dips in the market or to de-risk any
change in the medium-longer term forecast for gilt yields. 
Forward Borrowing
The opportunity also continues to exist to consider further loans on a ‘forward dealing’
basis, and officers will continue to explore the viability of these loans as part of
securing the long term borrowing required to meet the Council’s Underlying Borrowing
Requirement. 
Treasury management limits on activity
There are three debt related treasury activity limits.  The purpose of these are to
restrain the activity of the treasury function within certain limits, thereby managing
risk and reducing the impact of any adverse movement in interest rates.  However,
if these are set to be too restrictive they will impair the opportunities to reduce costs
/ improve performance.  The indicators are:
• Upper limits on variable interest rate exposure. This identifies a
maximum limit for variable interest rates for borrowing based upon the
gross debt position, and variable interest rates for investments based
upon the total investment position;
• Upper limits on fixed interest rate exposure.  This is similar to the
previous indicator and covers a maximum limit on fixed interest rates
for both borrowing and investments;
• Maturity structure of borrowing. These gross limits are set to reduce the
Council’s exposure to large fixed rate sums falling due for refinancing,
and are required for upper and lower limits.
The Council is asked to approve the following treasury indicators and limits: 
Limits on fixed interest rates based on gross debt 100.00%
Limits on variable interest rates based on gross debt 30.00%
Limits on fixed interest rates based on investments 100.00%
Limits on variable interest rates based on investments 100.00%
Upper Limits on Exposure to Fixed and Variable Interest Rates 2024/25
Interest rate exposures Upper
Limit
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Maturity structure of fixed interest rate borrowing 2024/25 Lower Upper
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
0.00% 50.00%
Maturity structure of variable interest rate borrowing 2024/25 Lower Upper
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
0.00% 30.00%
Maturity Structure of Borrowing 2024/25
5 years to 10 years
10 years to 20 years
20 years to 30 years
30 years to 40 years
40 years to 50 years
50 years and above
Under 12 months
12 months to 2 years
2 years to 5 years
2 years to 5 years
5 years to 10 years
10 years to 20 years
20 years to 30 years
30 years to 40 years
Under 12 months
12 months to 2 years
50 years and above
40 years to 50 years
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3.5 Policy on borrowing in advance of need
The Council will not borrow more than or in advance of its needs purely in order to profit
from the investment of the extra sum borrowed.  Any decision to borrow in advance will be
within forward approved Capital Financing Requirement estimates (as detailed in Section
3.2) and will be considered carefully to ensure that value for money can be demonstrated
and that the Council can ensure the security of such funds. 
Risks associated with any borrowing in advance activity will be subject to prior
appraisal and subsequent reporting through the mid-year or annual reporting
mechanism. 
3.6 Debt rescheduling
As noted in the Mid-Year Review Report, now that the whole of the yield curve has shifted
higher there may be opportunities for debt rescheduling in the remainder of the financial
year. 
This would involve the Council repaying loans prematurely (both market and PWLB) whilst
high discount rates on premature repayment prevail. 
Any debt rescheduling will be considered when the difference between the refinancing rate
and the redemption rate is most advantageous and the situation will be continually
monitored in order to take advantage of any perceived anomalies in the yield curve.  The
reasons for any rescheduling taking place would include: 
- the generation of cash savings at minimum risk;
- to reduce the average interest rate;
- to amend the maturity profile and/or the balance of volatility of the debt
portfolio. 
Council officers will explore debt rescheduling opportunities with Link Group, Link Treasury
Services Limited; with only prudent and affordable debt rescheduling that considers both
the short and medium-longer term impact being considered. 
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4 ANNUAL INVESTMENT STRATEGY
4.1 Investment policy
The Council’s investment policy implements the requirements of the following: - 
• Local Government Investments (Scotland) Regulations 2010, (and
accompanying Finance Circular 5/2010);
• CIPFA Treasury Management in the Public Services: Code of Practice and
Cross Sectoral Guidance Notes 2021 (“the Code”);
• CIPFA Treasury Management Guidance Notes 2021 
The Council’s investment priorities will be security first, portfolio liquidity second and then
yield, (return).  The Council will aim to achieve the optimum return (yield) on its investments
commensurate with proper levels of security and liquidity and with the Council’s risk
appetite. 
In the current economic climate, it is considered appropriate to maintain a degree of liquidity
to cover cash flow needs but to also consider “laddering” investments for periods up to 12
months with high credit rated financial institutions, whilst investment rates remain elevated,
as well as wider range fund options. 
The above regulations and guidance place a high priority on the management of risk. This
authority has adopted a prudent approach to managing risk and defines its risk appetite by
the following means: - 
1. The Council applies minimum acceptable credit criteria in order to generate
a list of highly creditworthy counterparties which also enables diversification
and thus avoidance of concentration risk.  The key ratings used to monitor
counterparties are the short-term and long-term ratings. 
2. Ratings will not be the sole determinant of the quality of an institution; it is
important to continually assess and monitor the financial sector on both a micro
and macro basis and in relation to the economic and political environments in
which institutions operate. The assessment will also take account of information
that reflects the opinion of the markets. To this end the Council will engage with
its advisors to maintain a monitor on market pricing such as “credit default
swaps” and overlay that information on top of the credit ratings. 
3. Other information sources used will include the financial press, share price
and other such information pertaining to the banking sector in order to establish
the most robust scrutiny process on the suitability of potential investment
counterparties. 
4. This authority has defined the list of types of investment instruments that are
permitted investments authorised for use in appendix 5.2.  Appendix 5.3
expands on the risks involved in each type of investment and the mitigating
controls. 
5. Lending limits, (maturity tenors), for each counterparty will be set through
applying the matrix table in Section 4.2 (maturity durations). 
6. Investments will only placed with counterparties from countries with a specified
minimum sovereign rating, (see paragraph 4.3). 
7. Lending per Country and Institution will be set through the application of the
criteria in Section 4.3 (amounts). 
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8. Transaction limits are set for each type of investment in appendix 5.2. 
9. This authority will set a limit for the amount of its investments which are invested
for longer than 365 days, (see paragraph 4.4). 
10. This authority has engaged external consultants, (see paragraph 1.5), to
provide expert advice on how to optimise an appropriate balance of security,
liquidity and yield, given the risk appetite of this authority in the context of the
expected level of cash balances and need for liquidity throughout the year. 
11. All investments will be denominated in sterling. 
However, this authority will also pursue value for money in treasury management and will
monitor the yield from investment income against appropriate benchmarks for investment
performance, (see paragraph 4.5). Regular monitoring of investment performance will be
carried out during the year.  
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4.2 Creditworthiness policy
This Council applies the creditworthiness service provided by Link Group, Link  Treasury
Services Limited.  This service employs a sophisticated modelling approach utilising credit
ratings from the three main credit rating agencies - Fitch, Moody’s and Standard and Poor’s. 
The credit ratings of counterparties are supplemented with the following overlays:- 
• credit watches and credit outlooks from credit rating agencies;
• CDS spreads to give early warning of likely changes in credit ratings;
• sovereign ratings to select counterparties from only the most creditworthy countries. 
This modelling approach combines credit ratings, credit watches and credit outlooks in a
weighted scoring system which is then combined with an overlay of CDS spreads for which
the end product is a series of colour coded bands which indicate the relative
creditworthiness of counterparties.  These colour codes are used by the Council to
determine the suggested duration for investments.   The Council will therefore use
counterparties within the following durational bands:- 
Note that the maximum suggested durations listed above have been extended by 1 year
(when compared to the suggested maximum durations provided by Link) for the Yellow,
Dark Pink, Light Pink, Purple, Blue and Orange categories, to allow flexibility around these
durations on the margins e.g. the placement of a 13 month fixed term deposit for a
counterparty rated Orange or Blue.  Equally, the maximum suggested duration for the Red
category has been extended by a month to 8 months, on the same basis.  A thorough
appraisal of the additional risk involved in extending the duration of any deposit (marginally)
beyond the maximum suggested by Capita, against any enhanced value to the portfolio,
will be undertaken prior to the placement of any deposit. 
The Link Group, Link  Treasury Services Limited creditworthiness service uses a wider
array of information than just primary ratings.  Furthermore, by using a risk weighted scoring
system, it does not give undue preponderance to just one agency’s ratings. 
Link Asset
Services
Colour Code
Maximum
Suggested
Duration for
Investment
Yellow 6 years*
Dark Pink 6 years**
Light Pink 6 years**
Purple 2.5 years
Blue 1.25 years***
Orange 1.25 years
Red 7 months
Green 120 days
No colour Not to be used
* Note the yellow colour category is for:- UK Government Debt, or its equivalent,  
Money Market Funds (MMF's), and collateralised deposits where
the collateral is UK Government Debt
** Dark Pink for Ultra Short Dated Bond Funds with a credit score of 1.25
Light Pink for Ultra Short Dated Bond Funds with a credit score of 1.5
*** Applies only to nationalised or semi-nationalised UK Banks
Table 14: Recommended Maximum
Durations for Investments
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Typically the minimum credit ratings criteria the Council use will be (Fitch or equivalents):- 
• Short term rating F1;
• Long term rating A-. 
There may be occasions when the counterparty ratings from one rating agency are
marginally lower than these ratings but may still be used.  In these instances consideration
will be given to the whole range of ratings available, or other topical market information, to
support their use. 
All credit ratings will be monitored weekly.  The Council is alerted to changes to ratings of
all three agencies through its use of the Link Group, Link Treasury Services Limited
creditworthiness service. 
• if a downgrade results in the counterparty / investment scheme no longer meeting
the Council’s minimum criteria, its further use as a new investment will be withdrawn
immediately;
• in addition to the use of credit ratings the Council will be advised of information in
movements in credit default swap spreads against the iTraxx benchmark and other
market data on a daily basis via its Passport website, provided exclusively to the
Council by Link Group, Link  Treasury Services Limited. Extreme market
movements may result in downgrade of an institution or removal from the Council’s
lending list. 
Sole reliance will not be placed on the use of this external service.  In addition this Council
will also use market data and market information, information on sovereign support for
banks and the credit ratings of that supporting government.
UK banks – ring fencing
The largest UK banks, (those with more than £25bn of retail / Small and Medium-sized
Enterprise (SME) deposits), are required, by UK law, to separate core retail banking
services from their investment and international banking activities by 1st January 2019. This
is known as “ring-fencing”. Whilst smaller banks with less than £25bn in deposits are
exempt, they can choose to opt up. Several banks are very close to the threshold already
and so may come into scope in the future regardless.
Ring-fencing is a regulatory initiative created in response to the global financial crisis. It
mandates the separation of retail and SME deposits from investment banking, in order to
improve the resilience and resolvability of banks by changing their structure. In general,
simpler, activities offered from within a ring-fenced bank, (RFB), will be focused on lower
risk, day-to-day core transactions, whilst more complex and “riskier” activities are required
to be housed in a separate entity, a non-ring-fenced bank, (NRFB). This is intended to
ensure that an entity’s core activities are not adversely affected by the acts or omissions of
other members of its group.
While the structure of the banks included within this process may have changed, the
fundamentals of credit assessment have not. The Council will continue to assess the new-
formed entities in the same way that it does others and those with sufficiently high ratings,
(and any other metrics considered), will be considered for investment purposes.
4.3 Country and sector limits
The Council has determined that it will only use approved counterparties from the UK, or
approved counterparties from other countries with a minimum sovereign credit rating of AA-
from Fitch.
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The list of countries that qualify using the above criteria as at the date of this report are
shown in Appendix 5.4.  This list will be added to, or deducted from, by officers should
ratings change in accordance with this policy.
The Council will avoid a concentration of investments in too few counterparties or countries
by adopting a spreading approach to investing whereby no more than £30 million will be
invested in Lloyds Banking Group and the NatWest (Royal Bank of Scotland) Group, £15
million in any other UK counterparty, and £15 million in any one counterparty, group or
country outwith the UK.
4.4 Investment strategy
Current Deposits 
As at 17 January 2024, the Council’s deposits were as follows:- 
Counterparty Amount
£000’s
Security
Long/Short
Term Rating*
(Colour)**
Liquidity Yield UK Local
Authority
Investment***
£000’s
MMF
Aberdeen 5,279 AAAmmf
(Yellow) Instant Access 5.28% 516,393
MMF
Federated 14,951 AAAmmf
(Yellow) Instant Access 5.32% 1,059,536
MMF
LGIM 14,843 AAAmmf
(Yellow) Instant Access 5.33% 291,934
Handelsbanken AB
Call Account 7,343 AA/F1+
(Orange) Instant Access 5.09% 142,698
National Westminster
Bank plc 15,000 A+/F1
(Blue)
Start: 08 Mar 2023
End: 08 Mar 2024 4.80%
578,003 National Westminster
Bank plc 15,000 Start: 01 Jun 2023
End: 28 Feb 2024 5.15%
Total 72,416    2,588,564 
* Credit Rating from Fitch
** Colour represents maximum recommended duration for investment per Link Group, Link  Treasury
Services Limited Credit Scoring methodology – see Appendix 2.
*** As at 31 December 2023 
In-house funds. Investments will be made with reference to the core balance and cash
flow requirements and the outlook for short-term interest rates (i.e., rates for investments
up to 12 months). Greater returns are usually obtainable by investing for longer periods. 
The current shape of the yield curve suggests that is the case at present, but there is the
prospect of Bank Rate having peaked in the second half of 2023 and possibly reducing as
early as the second half of 2024 so an agile investment strategy would be appropriate to
optimise returns. 
While an element of cash balances are required in order to manage the ups and downs of
cash flow, where cash sums can be identified that could be invested for longer periods, the
value to be obtained from longer term investments will be carefully assessed. 
• If it is thought that Bank Rate is likely to rise significantly within the time
horizon being considered, then consideration will be given to keeping most
investments as being short term or variable;
• Conversely, if it is thought that Bank Rate is likely to fall within that time
period, consideration will be given to locking in higher rates currently
obtainable, for longer periods. 
Investment returns expectations
The current forecast shown in paragraph 3.3, includes a forecast for Bank Rate to have
peaked at 5.25% in Q4 2023. 
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The suggested budgeted investment earnings rates for returns on investments placed for
periods up to about three months during each financial year are as follows: - 
Average earnings in
each year 
2023/24 (residual) 5.30%
2024/25 4.70%
2025/26 3.20%
2026/27 3.00%
2027/28 3.25%
Long term later years 3.25% 
As there are so many variables at this time, caution must be exercised in respect of all
interest rate forecasts.
Investment treasury indicator and limit - total principal funds invested for greater than
365 days. These limits are set with regard to the Council’s liquidity requirements and
expected usable reserve forecasts, and are based on the availability of funds after each
year-end. 
The Council is asked to retain the following treasury indicator and limit: - 
The current strategy as outlined in the body of these reports is to continue to cash-back the
Council’s balance sheet reserves.  It is expected that the majority of this will be in the form
of fixed term deposits and/or certificates of deposit.  Given expected reserve forecasts and
the current interest rate environment, in particular the short-medium term forecast for the
Council’s Capital Fund and HRA Reserve, the limit for prinicipal sums invested for > 365
days has been retained at £70m. 
For its cash flow generated balances, the Council will seek to utilise its business reserve
instant access accounts and money market funds.
4.5 Investment risk benchmarking
The Council will use an investment benchmark to assess the investment performance of its
investment portfolio of 6 month SONIA compounded.  The Council also participates in
Investment Benchmarking groups with Link Group, Link  Treasury Services Limited
whereby performance with other Benchmarking club members and the wider Scottish and
UK Local Authority Investment benchmarking is compared. 
4.6 End of year investment report
At the end of the financial year, the Council will report on its investment activity as part of
its Annual Treasury Report.
Limit £70m
Principal Sums Invested for > 365 Days
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5 Appendices 
1. Economic background
2. Treasury Management Practice 1 – Permitted Investments
3. Treasury Management Practice 1 – Credit and Counterparty Risk Management
4. Approved countries for investments
5. Treasury management scheme of delegation
6. The treasury management role of the section 95 officer 
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5.1 APPENDIX: Economic Background 
The first half of 2023/24 saw: 
- Interest rates rise by a further 100bps, taking Bank Rate from 4.25% to
5.25% and, possibly, the peak in the tightening cycle.
- Short, medium and long-dated gilts remain elevated as inflation
continually surprised to the upside.
- CPI inflation falling from 8.7% in April to 6.7% in September, its lowest
rate since February 2022, but still the highest in the G7.
- Core CPI inflation declining to 6.1% in September from 7.1% in April and
May, a then 31 years high.
- A cooling in labour market conditions, but no evidence yet that it has led
to an easing in wage growth (as the 3myy growth of average earnings
rose by 7.8% for the period June to August, excluding bonuses). 
The registering of 0% GDP for Q3 suggests that underlying growth has lost momentum
since earlier in the year. Some of the weakness in July was due to there being almost
twice as many working days lost to strikes in July (281,000) than in June (160,000). But
with output falling in 10 out of the 17 sectors, there is an air of underlying weakness. 
The fall in the composite Purchasing Managers Index from 48.6 in August to 46.7 in
September left it at its lowest level since COVID-19 lockdowns reduced activity in January
2021. At face value, it is consistent with the 0% q/q rise in real GDP in the period July to
September, being followed by a contraction in the next couple of quarters. 
The 0.4% m/m rebound in retail sales volumes in August is not as good as it looks as it
partly reflected a pickup in sales after the unusually wet weather in July. Sales volumes in
August were 0.2% below their level in May, suggesting much of the resilience in retail
activity in the first half of the year has faded. 
As the growing drag from higher interest rates intensifies over the next six monthsthe
economy is expected to continue to lose momentum and soon fall into a mild recession.
Strong labour demand, fast wage growth and government financial support packages
have all supported household incomes over the past year. And with CPI inflation past its
peak and expected to decline further, the economy has got through the cost-of- living
crisis without recession. But even though the worst of the falls in real household
disposable incomes are behind us, the phasing out of financial support packages
provided by the government during the energy crisis means real incomes are unlikely to
grow strongly. Higher interest rates will soon bite harder too. We expect the Bank of
England to keep interest rates at the probable peak of 5.25% until the second half of
2024.  Mortgage rates are likely to stay above 5.0% for around a year. 
The tightness of the labour market continued to ease, with employment in the three
months to July falling by 207,000. The further decline in the number of job vacancies from
1.017m in July to 0.989m in August suggests that the labour market has loosened a bit
further since July. That is the first time it has fallen below 1m since July 2021. At 3.0% in
July, and likely to have fallen to 2.9% in August, the job vacancy rate is getting closer to
2.5%, which would be consistent with slower wage growth. Meanwhile, the 48,000 decline
in the supply of workers in the three months to July offset some of the loosening in the
tightness of the labour market. That was due to a 63,000 increase in inactivity in the three
months to July as more people left the labour market due to long term sickness or to enter
education. The supply of labour is still 0.3% below its pre-pandemic February 2020 level. 
But the cooling in labour market conditions still has not fed through to an easing in wage
growth. The headline 3myy rate rose 7.8% for the period June to August, which meant
UK wage growth remains much faster than in the US and in the Euro-zone. Moreover,
while the Bank of England’s closely watched measure of regular annual average total pay
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growth for the private sector was 7.1% in June to August 2023, for the public sector this
was 12.5% and is the highest total pay annual growth rate since comparable records
began in 2001. However, this is affected by the NHS and civil service one-off non-
consolidated payments made in June, July and August 2023.  The Bank of England’s
prediction was for private sector wage growth to fall to 6.9% in September. 
CPI inflation declined from 6.8% in July to 6.7% in August and September, the lowest rate
since February 2022. The biggest positive surprise was the drop in core CPI inflation,
which declined from 6.9% to 6.1%. That reverses all the rise since March. 
In its latest monetary policy meeting on 13 December 2023, the Bank of England left
interest rates unchanged at 5.25%. The vote to keep rates on hold was a split vote, 6-3.  It
is clear that some members of the MPC are still concerned about the stickiness of
inflation. 
Like the US Fed, the Bank of England wants the markets to believe in the higher for
longer narrative. In terms of messaging, the Bank once again said that “further tightening
in monetary policy would be required if there were evidence of more persistent inflationary
pressures”, citing the rise in global bond yields and the upside risks to inflation from
“energy prices given events in the Middle East”. So, like the Fed, the Bank is keeping the
door open to the possibility of further rate hikes.  However, it also repeated the phrase that
policy will be “sufficiently restrictive for sufficiently long” and that the “MPC’s projections
indicate that monetary policy is likely to need to be restrictive for an extended period of
time”.  Indeed, Governor Bailey was at pains in his press conference to drum home to
markets that the Bank means business in squeezing inflation out of the economy. 
This narrative makes sense as the Bank of England does not want the markets to decide
that a peak in rates will be soon followed by rate cuts, which would loosen financial
conditions and undermine its attempts to quash inflation. The language also gives the
Bank of England the flexibility to respond to new developments. A rebound in services
inflation, another surge in wage growth and/or a further leap in oil prices could
conceivably force it to raise rates in the future. 
In the table below, the rise in gilt yields across the curve as a whole in 2023/24, and
therein PWLB rates, is clear to see. 
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HIGH/LOW/AVERAGE PWLB RATES FOR 01.04.23 – 29.09.23 
The peak in medium to longer dated rates has generally arisen in August and September
and has been primarily driven by continuing high UK inflation, concerns that gilt issuance
may be too much for the market to absorb comfortably, and unfavourable movements in
US Treasuries. 
The S&P 500 and FTSE 100 have struggled to make much ground through 2023. 
CENTRAL BANK CONCERNS 
Currently, the Fed has pushed up US rates to a range of 5.25% to 5.5%, whilst the MPC
followed by raising Bank Rate to 5.25%.  EZ rates have also increased to 4% with further
tightening a possibility. 
Ultimately, however, from a UK perspective it will not only be inflation data but also
employment data that will mostly impact the decision-making process, although any
softening in the interest rate outlook in the US may also have an effect (just as,
conversely, greater tightening may also).  
3.00
3.40
3.80
4.20
4.60
5.00
5.40
5.80
6.20
6.60
7.00
PWLB Certainty Rate Variations 3.4.23 to 29.9.23
3-Apr-23 29-Sep-23 Average
1 Year 5 Year 10 Year 25 Year 50 Year
Low 4.65% 4.14% 4.20% 4.58% 4.27%
Date 06/04/2023 06/04/2023 06/04/2023 06/04/2023 05/04/2023
High 6.36% 5.93% 5.51% 5.73% 5.45%
Date 06/07/2023 07/07/2023 22/08/2023 17/08/2023 28/09/2023
Average 5.62% 5.16% 5.01% 5.29% 5.00%
Spread 1.71% 1.79% 1.31% 1.15% 1.18%
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5.2 APPENDIX: Treasury Management Practice (TMP1): Permitted Investments 
This Council is asked to approve the following forms of investment instrument for use as
permitted investments as set out in tables 1.1-1.4. 
Treasury risks
All the investment instruments in tables 1.1-1.4 are subject to the following risks:- 
1. Credit and counter-party risk: this is the risk of failure by a counterparty (bank or
building society) to meet its contractual obligations to the organisation particularly
as a result of the counterparty’s diminished creditworthiness, and the resulting
detrimental effect on the organisation’s capital or current (revenue) resources.
There are no counterparties where this risk is zero although AAA rated
organisations have the highest, relative, level of creditworthiness. 
2. Liquidity risk: this is the risk that cash will not be available when it is needed.  
While it could be said that all counterparties are subject to at least a very small level
of liquidity risk as credit risk can never be zero, in this document, liquidity risk has
been treated as whether or not instant access to cash can be obtained from each
form of investment instrument.  However, it has to be pointed out that while some
forms of investment e.g. gilts, CDs, corporate bonds can usually be sold
immediately if the need arises, there are two caveats: - a.  cash may not be available
until a settlement date up to three days after the sale  b.  there is an implied
assumption that markets will not freeze up and so the instrument in question will
find a ready buyer.  The column in tables 1.1-1.4 headed as ‘market risk’ will show
each investment instrument as being instant access, sale T+3 = transaction date
plus 3 business days before you get cash, or term i.e. money is locked in until an
agreed maturity date. 
3. Market risk: this is the risk that, through adverse market fluctuations in the value
of the principal sums an organisation borrows and invests, its stated treasury
management policies and objectives are compromised, against which effects it has
failed to protect itself adequately.  However, some cash rich local authorities may
positively want exposure to market risk e.g. those investing in investment
instruments with a view to obtaining a long term increase in value. 
4. Interest rate risk: this is the risk that fluctuations in the levels of interest rates create
an unexpected or unbudgeted burden on the organisation’s finances, against which
the organisation has failed to protect itself adequately.  This authority has set limits
for its fixed and variable rate exposure in its Treasury Indicators in this report (see
Section 3.4). 
5. Legal and regulatory risk: this is the risk that the organisation itself, or an
organisation with which it is dealing in its treasury management activities, fails to
act in accordance with its legal powers or regulatory requirements, and that the
organisation suffers losses accordingly.   
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Controls on treasury risks
1. Credit and counter-party risk: this authority has set minimum credit criteria to
determine which counterparties and countries are of sufficiently high
creditworthiness to be considered for investment purposes.  See Sections 4.2 and
4.3. 
2. Liquidity risk: this authority has a cash flow forecasting model to enable it to
determine how long investments can be made for and how much can be invested. 
3. Market risk: this authority does not purchase investment instruments which are
subject to market risk in terms of fluctuation in their value. 
4. Interest rate risk: this authority manages this risk by having a view of the future
course of interest rates and then formulating a treasury management strategy
accordingly which aims to maximise investment earnings consistent with control of
risk or alternatively, seeks to minimise expenditure on interest costs on borrowing. 
See Section 4.4. 
5. Legal and regulatory risk: this authority will not undertake any form of investing
until it has ensured that it has all necessary powers and also complied with all
regulations. 
Unlimited investments 
Regulation 24 states that an investment can be shown in tables 1 / 2 as being ‘unlimited’ in
terms of the maximum amount or percentage of the total portfolio that can be put into that
type of investment.  However, it also requires that an explanation must be given for using
that category.  The authority has given the following types of investment an unlimited
category: - 
1. Debt Management Agency Deposit Facility.  This is considered to be the
lowest risk form of investment available to local authorities as it is operated
by the Debt Management Office which is part of H.M. Treasury i.e. the UK
Government’s sovereign rating stands behind the DMADF.  It is also a deposit
account and avoids the complications of buying and holding Government
issued treasury bills or gilts. 
2. High credit worthiness banks and building societies.  See paragraph 4.2
for an explanation of this authority’s definition of high credit worthiness.  While
an unlimited amount of the investment portfolio may be put into banks and
building societies with high credit worthiness, the authority will ensure
diversification of its portfolio ensuring that no more than £15 million can be
placed with any one institution or group at any one time, other than the Bank
of Scotland or Royal Bank of Scotland where the limit is £30 million. 
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Objectives of each type of investment instrument
Regulation 25 requires an explanation of the objectives of every type of investment
instrument which an authority approves as being ‘permitted’.
1. DEPOSITS
The following forms of ‘investments’ are actually more accurately called deposits as cash
is deposited in an account until an agreed maturity date or is held at call. 
a) Debt Management Agency Deposit Facility.  This offers the lowest risk form of
investment available to local authorities as it is effectively an investment placed with the
Government.  It is also easy to use as it is a deposit account and avoids the
complications of buying and holding Government issued treasury bills or gilts.  As it is
low risk it also earns low rates of interest.  However, it is very useful for authorities
whose overriding priority is the avoidance of risk.  The longest period for a term deposit
with the DMADF is 6 months. 
b) Term Deposits – Local Authorities.  They are quasi-Government bodies with low
counterparty and value risk.  Typical deposit terms vary from 1 month to 2 years, with
longer term deposits offering an opportunity to increase investment returns by locking
in high rates ahead of an expected fall in the level of interest rates.  At other times,
longer term rates can offer good value when the markets incorrectly assess the speed
and timing of interest rate increases.  This form of investing therefore, offers a lot of
flexibility and typically higher earnings than the DMADF.  Where it is restricted is that
once a longer term investment is made, that cash is locked in until the maturity date
other than with agreement of the counterparty, at which point penalties would typically
apply.
c) Call accounts with high credit worthiness banks and building societies.  See
Section 4.2 for an explanation of this authority’s definition of high credit worthiness. 
These typically offer a much higher rate of return than the DMADF and now that
measures have been put in place to avoid over reliance on credit ratings, the authority
feels much more confident that the residual risks around using such banks and building
societies are at a low, reasonable and acceptable level. There is instant access to
recalling cash deposited (or short-dated notice e.g. 15-30 days).  This generally means
accepting a lower rate of interest than that which could be earned from the same
institution by making a term deposit (see 1d below).  However, there are a number of
call accounts which at the time of writing, offer rates 2 – 3 times more than term deposits
with the DMADF.  Some use of call accounts is highly desirable to ensure that the
authority has ready access to cash when needed to pay bills. 
d) Term deposits with high credit worthiness banks and building societies.  The
objectives are as for 1c.  These offer a much higher rate of return than the DMADF and
deposits made with other Local Authorities (dependent upon term) and, similar to 1c,
now that measures have been put in place to avoid over reliance on credit ratings, the
authority feels much more confident that the residual risks around using such banks
and building societies are at a low, reasonable and acceptable level.  This is the most
widely used form of investing used by local authorities.  The authority will ensure
diversification of its portfolio of deposits ensuring that no more than £15 million is
invested with any (non-nationalised) UK counterparty, and no more than £15 million is
invested with any other non-UK counterparty, group or country.  In addition, longer term
deposits offer an opportunity to increase investment returns by locking in high rates
ahead of an expected fall in the level of interest rates.  At other times, longer term rates
can offer good value when the markets incorrectly assess the speed and timing of
interest rate increases.  This form of investing therefore, offers a lot of flexibility and
higher earnings than the DMADF.  Where it is restricted is that once a longer term
investment is made, that cash is locked in until the maturity date. 
e) Fixed term deposits with variable rate and variable maturities (structured
deposits).  This encompasses ALL types of structured deposits.  There has been
considerable change in the types of structured deposits brought to the market over the
last few years, some of which are already no longer available.  In view of the fluidity of
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this area, this is a generic title for all structured deposits so as to provide councils with
greater flexibility to adopt new instruments as and when they are brought to the market. 
This line encompasses ALL types of structured deposits.  There has been considerable
change in the types of structured deposits brought to the market over the last few years,
some of which are already no longer available.  In view of the fluidity of this area, this is
a generic title for all structured deposits so as to provide greater flexibility to adopt new
instruments as and when they are brought to the market.
2. DEPOSITS WITH COUNTERPARTIES CURRENTLY IN RECEIPT OF UK
GOVERNMENT SUPPORT / OWNERSHIP
These banks offer another dimension of creditworthiness in terms of UK Government
backing through either direct (partial or full) ownership.  The view of this authority is that
such backing makes these banks attractive institutions with whom to place deposits, and
that will remain our view if the UK sovereign rating were to be downgraded in the coming
year. 
a. Call accounts.  As for 1c. but UK Government stated support implies that the UK
Government stands behind these banks and building societies and will be deeply
committed to providing whatever support that may be required to ensure the
continuity of such institutions.  This authority feels this indicates a low and
acceptable level of residual risk. 
b. Term deposits with high credit worthiness banks which are fully or semi
nationalised. As for 1d. but Government ownership partial or full implies that the UK
Government stands behind this bank and will be deeply committed to providing
whatever support that may be required to ensure the continuity of that bank.  This
authority considers   this indicates a low and acceptable level of residual risk. 
c. Fixed term deposits with variable rate and variable maturities (structured
deposits).  As for 1e but UK Government stated support implies that the UK
Government stands behind eligible banks and building societies and will be deeply
committed to providing whatever support that may be required to ensure the continuity
of such institutions.  This authority feels this indicates a low and acceptable level of
residual risk.  This line encompasses ALL types of structured deposits.  There has been
considerable change in the types of structured deposits brought to the market over the
last few years, some of which are already no longer available.  In view of the fluidity of
this area, this is a generic title for all structured deposits so as to provide greater
flexibility to adopt new instruments as and when they are brought to the market.  
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3. COLLECTIVE INVESTMENT SCHEMES STRUCTURED AS OPEN ENDED
INVESTMENT COMPANIES (OEICS)
a. Government liquidity funds.  These are the same as money market funds (see
below) but only invest in government debt issuance with highly rated governments.  Due
to the higher quality of underlying investments, they offer a lower rate of return than
MMFs.  However, their net return is typically on a par with the DMADF, but with instant
access. 
b. Money Market Funds (MMFs).  By definition, MMFs are AAA rated and are widely
diversified, using many forms of money market securities including types which this
authority does not currently have the expertise or capabilities to hold directly.  However,
due to the high level of expertise of the fund managers and the huge amounts of money
invested in MMFs, and the fact that the weighted average maturity (WAM) cannot
exceed 60 days, MMFs offer a combination of high security, instant access to funds,
high diversification and good rates of return compared to equivalent instant access
facilities. They are particularly advantageous in falling interest rate environments as
their 60 day WAM means they have locked in investments earning higher rates of
interest than are currently available in the market.  MMFs also help an authority to
diversify its own portfolio as e.g. a £2m investment placed directly with HSBC is a 100%
risk exposure to HSBC whereas £2m invested in a MMF may end up with say £10,000
being invested with HSBC through the MMF.  For authorities particularly concerned
with risk exposure to banks, MMFs offer an effective way of minimising risk exposure
while still getting much better rates of return than available through the DMADF. 
c. Ultra Short Dated Bond Funds .  These funds are similar to MMFs, can still be AAA
rated but have Variable Net Asset Values (VNAV) as opposed to a traditional MMF
which has a Constant Net Asset Value (CNAV). They aim to achieve a higher yield and
to do this either take more credit risk or invest out for longer periods of time, which
means they are more volatile. These funds can have WAM’s and Weighted Average
Life (WAL’s) of 90 – 365 days or even longer. Their primary objective is yield and capital
preservation is second.  They therefore are a higher risk than MMFs and
correspondingly have the potential to earn higher returns than MMFs. 
d. Gilt funds.  These are funds which invest only in U.K. Government gilts.  They offer a
lower rate of return than bond funds but are highly rated both as a fund and through
investing only in highly rated government securities.  They offer a higher rate of return
than investing in the DMADF but they do have an exposure to movements in market
prices of assets held. 
e. Bond funds.  These can invest in both government and corporate bonds.  This
therefore entails a higher level of risk exposure than gilt funds and the aim is to achieve
a higher rate of return than normally available from gilt funds by trading in non-
government bonds.    
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4.  SECURITIES ISSUED OR GUARANTEED BY GOVERNMENTS 
The following types of investments are where an authority directly purchases a particular
investment instrument, a security, i.e. it has a market price when purchased and that value
can change during the period the instrument is held until it matures or is sold.  The annual
earnings on a security is called a yield i.e. it is normally the interest paid by the issuer divided
by the price you paid to purchase the security unless a security is initially issued at a
discount e.g. treasury bills..   
a. Treasury bills.  These are short term bills (up to 12 months, although none have
ever been issued for this maturity) issued by the Government and so are backed
by the sovereign rating of the UK.  The yield is higher than the rate of interest paid
by the DMADF and another advantage compared to a time deposit in the DMADF
is that they can be sold if there is a need for access to cash at any point in time. 
However, there is a spread between purchase and sale prices so early sales could
incur a net cost during the period of ownership. 
b. Gilts.  These are longer term debt issuance by the UK Government and are backed by
the sovereign rating of the UK. The yield is higher than the rate of interest paid by the
DMADF and another advantage compared to a time deposit in the DMADF is that they
can be sold if there is a need for access to cash at any point in time.  However, there is
a spread between purchase and sale prices so early sales may incur a net cost. Market
movements that occur between purchase and sale may also have an adverse impact
on proceeds. The advantage over Treasury bills is that they generally offer higher yields
the longer it is to maturity (for most periods) if the yield curve is positive. 
c. Bond issuance issued by a financial institution which is explicitly guaranteed by
the UK Government e.g. National Rail.  This is similar to a gilt due to the explicit
Government guarantee. 
d. Sovereign bond issues (other than the UK govt) denominated in Sterling.  As for
gilts but issued by other nations.  Use limited to issues of nations with at least the same
sovereign rating as for the UK. 
e. Bonds issued by Multi Lateral Development Banks (MLDBs).  These are similar to
c. and e. above but are issued by MLDBs which are typically guaranteed by a group of
sovereign states e.g. European Bank for Reconstruction and Development.
5.  SECURITIES ISSUED BY CORPORATE ORGANISATIONS 
The following types of investments are where an authority directly purchases a particular
investment instrument, a security, i.e. it has a market price when purchased and that value
can change during the period the instrument is held until it is sold.  The annual earnings on
a security is called a yield i.e. is the interest paid by the issuer divided by the price you paid
to purchase the security.  These are similar to the previous category but corporate
organisations can have a wide variety of credit worthiness so it is essential for local
authorities to only select the organisations with the highest levels of credit worthiness. 
Corporate securities are generally a higher risk than government debt issuance and so earn
higher yields. 
a. Certificates of deposit (CDs).  These are shorter term securities issued by deposit
taking institutions (mainly financial institutions). They are negotiable instruments, so can
be sold ahead of maturity and also purchased after they have been issued.  However,
that liquidity can come at a price, where the yield could be marginally less than placing
a deposit with the same bank as the issuing bank. 
b. Commercial paper.  This is similar to CDs but is issued by commercial
organisations or other entities.  Maturity periods are up to 365 days but commonly
90 days.  
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c. Corporate bonds.  These are (long term) bonds (usually bearing a fixed rate of
interest) issued by a financial institution, company or other non-government issuer
in order to raise capital for the institution as an alternative to issuing shares or
borrowing from banks.  They are generally seen to be of a lower creditworthiness
than government issued debt and so usually offer higher rates of yield. 
d. Floating rate notes.  These are bonds on which the rate of interest is established
periodically with reference to short-term interest rates.  
6.  OTHER
a. Local Authority Mortgage Scheme.  Authorities who are participating in the Local
Authority Mortgage Guarantee Scheme (LAMS) may be required to place a deposit
with the mortgage provider(s) up to the full value of the guarantee.  The deposit will
be in place for the term of the guarantee i.e. 5 years (with the possibility of a further
2 year extension if the account is 90+ days in arrears at the end of the initial 5
years) - and may have conditions / structures attached.  The mortgage provider will
not hold a legal charge over the deposit.
b. Loans to third parties – This would involve the Council borrowing from the
PWLB/markets and onward lending to Registered Social Landlords to enable them
to access lower cost loans and kickstart developments of affordable mid-market
homes.  The risk associated with such an investment would be mitigated by an
assessment of the counterparty in advance of any loan being granted and through
the application of a premium on the loan rate.  Interest would be paid by the RSL
over the term of the loan, with repayment of principal upon the earlier of 10/20
years or at the point of house sales.  The Council will also request that a standard
security is taken over the property which would allow the Council to require the sale
of the homes to another landlord, providing greater risk mitigation.
c. Subordinated Debt Subscription to the SPV set up to deliver the Newbattle
Centre project – this involved the Council subscribing £332,806 of subordinated
debt to the SPV that was set up to deliver the Newbattle Centre project (2 year
construction and 25 year operational contract length). The length of the investment
is 25 years with the subscription made at operation commencement of the contract. 
The repayment profile will comprise 81% of the principal remaining invested until
the final two years of the contract. The risk associated with this type of investment
will be mitigated through an annual assessment as a minimum to review the holding
of such debt, and whether the exposure to risk arising from the investment has
changed over the period.
d. ESCO: Midlothian Energy Limited (MEL) Joint Venture between Midlothian Council
and Vattenfall to deliver energy supply to Shawfair using heat supplied from the
Millerhill Energy from Waste plant and related projects.
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Table 1: Permitted Investments 
1.1  Deposits
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m
of total
investments
Max. maturity
period
Max
Transaction
Value
Debt Management Agency
Deposit Facility
UK
Government Term No 100% 6 months n/a
Term deposits – local authorities Quasi-UK
Government Term No 100% 5 years £15m
Call accounts – banks and
building societies
Green  Instant No 100% 1 day £15m
Term deposits / Notice Accounts
– banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m 
1.2 Deposits with counterparties currently in receipt of government support / ownership
Investment Category
Minimum
Credit
Criteria
Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
Max
Transaction
Value
UK nationalised banks – Call
accounts Blue Instant No 100% 1 day £30m
UK  nationalised banks – Term
Deposits / Notice Accounts Blue Term No 100% 2 years £30m
UK  nationalised banks – Fixed
term deposits with variable rate
and variable maturities: -
Structured deposits
Blue Term No 100% 2 years £30m
Non-UK (high sovereign rated
country) nationalised banks –
Call accounts
Green Instant No 100% 1 day £15m
Non-UK (high sovereign rated
country) nationalised banks:-
Term Deposits / Notice Accounts
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Non-UK (high sovereign rated
country) nationalised banks:- 
Fixed term deposits with variable
rate and variable maturities: -
Structured deposits  
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Term No 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
If forward deposits are made, the forward period plus the deal period equate to the maximum
maturity period. 
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1.3  Collective investment schemes structured as Open Ended Investment Companies
(OEICs) 
Investment Category Minimum
Credit Criteria  Liquidity
risk
Market
risk
Max %/£m of
total
investments
Max. maturity
period
Max
Transaction
Value
Government Liquidity Funds AAA Instant No 100% 1 day £15m
Money Market Funds CNAV AAA Instant No 100% 1 day £15m
Money Market Funds LVNAV AAA Instant No 100% 1 day £15m
Money Market Funds VNAV AAA Instant No 100% 1 day £15m
Ultra Short Dated Bond Funds
with a credit score of 1.25 AAA T+1 to
T+5 Yes 100% 1 week £15m
Ultra Short Dated Bond Funds
with a credit score of 1.5 AAA T+1 to
T+5 Yes 100% 1 week £15m
Bond Funds AAA T+2 or
longer Yes 50% 2 days £15m
Gilt Funds AAA T+2 or
longer Yes 50% 2 days £15m 
1.4 Securities issued or guaranteed by governments 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max %?£m 
of total
investments
Max. maturity
period
Treasury Bills
UK
sovereign
rating
Sale T+1 Yes 100% 6 months
UK Government Gilts
UK
sovereign
rating 
Sale T+1 Yes 100% 50 years
Bond issuance issued by a
financial institution which is
explicitly guaranteed by  the
UK Government  e.g. National
Rail
UK
sovereign
rating 
Sale T+3 Yes 100% 50 years
Sovereign bond issues (other
than the UK govt)
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years
Bonds issued by multilateral
development banks 
AAA (or
state your
criteria if
different)
Sale T+1 Yes 100% 50 years 
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1.5 Securities issued by corporate organisations 
Investment Category
* Minimum
Credit
Criteria 
Liquidity
risk
Market
risk 
Max % 
of total
investments
Max. maturity
period
Max
Transaction
Value
Certificates of deposit issued
by banks and building societies
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+1 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Commercial paper other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+0 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Floating rate notes
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m
Corporate Bonds other 
Yellow
Purple
Blue
Orange
Red
Green
No Colour
Sale T+2 Yes 100%
Up to 6 yrs
Up to 2.5 yrs
Up to 1.25 yrs
Up to 1.25 yrs
Up to 7 mths
Up to 120 days
Not for use
£15m 
1.6 Other 
Investment Category Minimum Credit
Criteria  Liquidity
risk
Market
risk 
Max %/£m 
of total
investments
Max.
maturity
period
Local authority mortgage guarantee
scheme. Blue Term No 50% 5 years
Loans to Third Parties n/a Term No £25m 20 years
Subordinated Debt Subscription to
Newbattle Centre SPV n/a Term No £0.326m 22 years
ESCO n/a Term No £10.2m n/a 
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5.3 APPENDIX: Treasury Management Practice (TMP1) – Credit and Counterparty Risk Management 
Midlothian Council Permitted Investments, Associated Controls and Limits
Type of Investment Treasury Risks Mitigating Controls Council
Limits
Cash type instruments
a. Deposits with the Debt
Management Account
Facility (UK
Government) (Very
low risk)
This is a deposit with the UK Government and as
such counterparty and liquidity risk is very low, and
there is no risk to value.  Deposits can be between
overnight and 6 months.
Little mitigating controls required.  As
this is a UK Government investment the
monetary limit is unlimited to allow for a
safe haven for investments.
As shown in
Appendix 5.2.
b. Deposits with other
local authorities or
public bodies (Very
low risk)
These are considered quasi UK Government debt
and as such counterparty risk is very low, and there
is no risk to value.  Deposits can only be broken with
the agreement of the counterparty, and penalties can
apply.
Deposits with other non-local authority bodies will be
restricted to the overall credit rating criteria.
Little mitigating controls required for
local authority deposits, as this is a
quasi UK Government investment.
Non- local authority deposits will follow
the approved credit rating criteria.
As shown in
Appendix 5.2.
c. CNAV, LVNAV and
VNAV Money Market
Funds (MMFs) (Low to
very low risk)
Pooled cash investment vehicle which provides very
low counterparty, liquidity and market risk.  These
will primarily be used as liquidity instruments.
Funds will only be used where the MMF
has a “AAA” rated status from either
Fitch, Moody’s or Standard & Poors.
As shown in
Appendix 5.2.
d. Ultra Short Dated Bond
Funds (low risk)
Pooled cash investment vehicle which provides very
low counterparty, liquidity and market risk.  These
will primarily be used as liquidity instruments.
Funds will only be used where the Ultra
Short Dated Bond Fund has a “AAA”
rated status from either Fitch, Moody’s
or Standard and Poor’s.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
e. Call account deposit
accounts with financial
institutions (banks and
building societies)
(Low risk depending
on credit rating)
These tend to be low risk investments, but will
exhibit higher risks than categories (a), (b) and (c)
above.  Whilst there is no risk to value with these
types of investments, liquidity is high and
investments can be returned at short notice.
The counterparty selection criteria
approved above restricts lending only to
high quality counterparties, measured
primarily by credit ratings from Fitch,
Moody’s and Standard and Poor’s, with
the credit scoring methodology by Link
Group, Link  Treasury Services Limited
overlaid.
On day to day investment dealing with
this criteria will be further strengthened
by the use of additional market
intelligence.
As shown in
Appendix 5.2.
f. Term deposits with
financial institutions
(banks and building
societies) (Low to
medium risk
depending on period
& credit rating)
These tend to be low risk investments, but will
exhibit higher risks than categories (a), (b), (c) and
(d) above.  Whilst there is no risk to value with these
types of investments, liquidity is low and term
deposits can only be broken with the agreement of
the counterparty, and penalties may apply.  
The counterparty selection criteria
approved above restricts lending only to
high quality counterparties, measured
primarily by credit ratings from Fitch,
Moody’s and Standard and Poor’s, with
the credit scoring methodology by Link
Group, Link  Treasury Services Limited
overlaid.
On day to day investment dealing, this
criteria will be further strengthened by
the use of additional market
intelligence.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
g. Government Gilts and
Treasury Bills (Very low
risk)
These are marketable securities issued by the
UK Government and as such counterparty and
liquidity risk is very low, although there is
potential risk to value arising from an adverse
movement in interest rates (no loss if these
are held to maturity.
Little counterparty mitigating controls are
required, as this is a UK Government
investment.   The potential for capital loss will
be reduced by limiting the maximum
monetary and time exposures
As shown in
Appendix 5.2.
h. Certificates of deposits with
financial institutions (Low
risk)
These are short dated marketable securities
issued by financial institutions and as such
counterparty risk is low, but will exhibit higher
risks than categories (a), (b) and (c) above. 
There is risk to value of capital loss arising
from selling ahead of maturity if combined with
an adverse movement in interest rates (no
loss if these are held to maturity).  Liquidity
risk will normally be low.
The counterparty selection criteria approved
above restricts lending only to high quality
counterparties, measured primarily by credit
ratings from Fitch, Moody’s and Standard and
Poor’s.  The selection defaults to the lowest
available colour band / credit rating to provide
additional risk control measures.
Day to day investment dealing with this
criteria will be further strengthened by the use
of additional market intelligence.
As shown in
Appendix 5.2.
i. Structured deposit facilities
with banks and building
societies (escalating rates,
de-escalating rates etc.)
(Low to medium risk
depending on period &
credit rating)
These tend to be medium to low risk
investments, but will exhibit higher risks than
categories (a), (b), (c) and (d) above.  Whilst
there is no risk to value with these types of
investments, liquidity is very low and
investments can only be broken with the
agreement of the counterparty (penalties may
apply).  
The counterparty selection criteria approved
above restricts lending only to high quality
counterparties, measured primarily by credit
ratings from Fitch, Moody’s and Standard and
Poor’s, with the credit scoring methodology
by Link Group, Link  Treasury Services
Limited overlaid.
On day to day investment dealing, this criteria
will be further strengthened by the use of
additional market intelligence.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
j. Corporate bonds (Medium to
high risk depending on
period & credit rating)
These are marketable securities issued by
financial and corporate institutions.
Counterparty risk will vary and there is risk to
value of capital loss arising from selling ahead
of maturity if combined with an adverse
movement in interest rates.  Liquidity risk will
be low.
The counterparty selection criteria
approved above restricts lending only to
high quality counterparties, measured
primarily by credit ratings from Fitch,
Moody’s and Standard and Poor’s.  The
selection defaults to the lowest
available colour band / credit rating to
provide additional risk control
measures.  Corporate bonds will be
restricted to those meeting the base
criteria.
Day to day investment dealing with this
criteria will be further strengthened by
the use of additional market
intelligence.
As shown in
Appendix 5.2.  
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Type of Investment Treasury Risks Mitigating Controls Council
Limits
Other types of investments
k. Loans to third parties Using the example of a loan to a RSL, these
would be medium risk investments, exhibiting
higher risks than categories (a)-(f) above. 
They are also highly illiquid and are only repaid
at the end of a defined period of time (up to 20
years) or on the sale of a property, whichever is
the earlier.
The risk associated with such an
investment would be mitigated through
the application of a premium on the
loan rate.  The Council will also request
that a standard security is taken over
the property which would allow the
Council to require the sale of the homes
to another landlord, providing greater
risk mitigation.
£25m
l. Non-local authority
shareholdings
These are non-service investments which may
exhibit market risk, be only considered for
longer term investments and will be likely to be
liquid.
Any non-service equity investment will
require separate Member approval and
each application will be supported by
the service rational behind the
investment and the likelihood of loss.
Per Existing
m. Local Authority Mortgage
Scheme (LAMS)
These are service investments at market rates
of interest plus a premium. 
As shown in
Appendix 5.2.
n. Subordinated Debt Subscription
to Newbattle Centre SPV
These are investments that are exposed to the
success or failure of individual projects and are
highly illiquid.
The Council and Scottish Government
(via the SFT) are participants in and
party to the governance and controls
within the project structure. As such
they are well placed to influence and
ensure the successful completion of the
project’s term.
As shown in
Appendix 5.2.
o. ESCO These are investments that are exposed to the
success or failure of individual projects and are
highly illiquid.
The Council is in a joint venture
partnership and therefore party to the
governance and controls within the
project structure. As such the Council is
As shown in
Appendix 5.2.
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47
well placed to influence and ensure the
successful completion of the project’s
term 
The Monitoring of Deposit Counterparties - The status of counterparties will be monitored regularly.  The Council receives credit rating and
market information from Link Group, Link  Treasury Services Limited, including when ratings change, and counterparties are checked promptly. 
On occasion ratings may be downgraded when an investment has already been made.  The criteria used are such that a minor downgrading
should not affect the full receipt of the principal and interest.  Any counterparty failing to meet the criteria will be removed from the list
immediately by the Chief Financial Officer & Section 95 Officer, and if required new counterparties which meet the criteria will be added to the
list. 
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5.4 APPENDIX: Approved countries for investments 
Based on the lowest available rating as at 17.01.2024 
AAA
• Australia
• Denmark
• Germany
• Netherlands
• Norway
• Singapore
• Sweden
• Switzerland 
AA+
• Canada
• Finland
• U.S.A. 
AA
• Abu Dhabi (UAE) 
AA-
• Belgium
• France
• U.K. 
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5.5 APPENDIX: Treasury management scheme of delegation
(i) Full Council
• receiving and reviewing reports on treasury management policies, practices and
activities;
• approval of annual strategy.
• approval of/amendments to the organisation’s adopted clauses, treasury
management policy statement and treasury management practices;
• budget consideration and approval;
• approval of the division of responsibilities;
• receiving and reviewing regular monitoring reports and acting on
recommendations;
• approving the selection of external service providers and agreeing terms of
appointment. 
(iii) Audit Committee
• reviewing treasury management reports, the treasury management policy and
procedures, and making recommendations to the responsible body. 
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5.6 APPENDIX: The treasury management role of the section 95 officer
The S95 (responsible) officer
• recommending clauses, treasury management policy/practices for approval,
reviewing the same regularly, and monitoring compliance;
• submitting regular treasury management policy reports;
• submitting budgets and budget variations;
• receiving and reviewing management information reports;
• reviewing the performance of the treasury management function;
• ensuring the adequacy of treasury management resources and skills, and the
effective division of responsibilities within the treasury management function;
• ensuring the adequacy of internal audit, and liaising with external audit;
• recommending the appointment of external service providers;
• preparation of a capital strategy to include capital expenditure, capital financing,
non-financial investments and treasury management, with a long term timeframe;
• ensuring that the capital strategy is prudent, sustainable, affordable and prudent in
the long term and provides value for money;
• ensuring that due diligence has been carried out on all treasury and non-financial
investments and is in accordance with the risk appetite of the authority;
• ensure that the authority has appropriate legal powers to undertake expenditure
on non-financial assets and their financing;
• ensuring the proportionality of all investments so that the authority does not
undertake a level of investing which exposes the authority to an excessive level of
risk compared to its financial resources;
• ensuring that an adequate governance process is in place for the approval,
monitoring and ongoing risk management of all non-financial investments and
long term liabilities;
• provision to members of a schedule of all non-treasury investments including
material investments in subsidiaries, joint ventures, loans and financial guarantees
ensuring that members are adequately informed and understand the risk
exposures taken on by an authority;
• ensuring that the authority has adequate expertise, either in house or externally
provided, to carry out the above;
• creation of Treasury Management Practices which specifically deal with how non-
treasury investments will be carried out and managed, to include the following:-
o Risk management (TMP1 and schedules), including investment and risk
management criteria for any material non-treasury investment portfolios;
o Performance measurement and management (TMP2 and schedules),
including methodology and criteria for assessing the performance and
success of non-treasury investments;
o Decision making, governance and organisation (TMP5 and schedules),
including a statement of the governance requirements for decision making
in relation to non-treasury investments; and arrangements to ensure that
appropriate professional due diligence is carried out to support decision
making;
o Reporting and management information (TMP6 and schedules), including
where and how often monitoring reports are taken;
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51
o Training and qualifications (TMP10 and schedules), including how the
relevant knowledge and skills in relation to non-treasury investments will
be arranged.
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Page 105

Audit Committee            
Monday 29 January 2024
Item 5.2 
Follow-Up Review of Completed Internal Audit Recommendations 
Duncan Stainbank, Chief Internal Auditor 
Report for Decision 
1 Recommendations
The Audit Committee is asked to:
a) Note the results from the sample check of Internal Audit
recommendations that have been marked as completed by
Management in the period April 2022 to March 2023 to improve
internal controls and governance, and mitigate risks; 
b) Acknowledge the progress made by Management in implementing
Internal Audit recommendations to improve internal controls and
governance, to mitigate risks, and consider whether it is satisfied with
the progress made by Management;
c) Considers whether it is satisfied with the outcomes or whether any
further action is required;
d) Endorse the proposal to extend the due dates for the overdue
recommendations; and 
e) Note that Internal Audit will continue to monitor for completion the
outstanding recommendations and will provide update reports to the
Audit Committee. 
2 Purpose of Report/Executive Summary 
The purpose of this report is to provide an update to members of the
Audit Committee on the results of the Internal Audit Follow-up review
which included a sample check on the adequacy of new internal
controls for Internal Audit recommendations marked as completed by
Management in the period April 2022 to March 2023. 
This report also provides an update to members of the Audit Committee
on the status of the implementation by Management of audit
recommendations made and agreed in Internal Audit reports. 
Internal Audit is an independent appraisal function established for the
review of the internal control system as a service to Midlothian Council. 
It objectively examines, evaluates and reports on the adequacy of
internal control as a contribution to the proper, economic, efficient and
effective use of resources and the management of risk. 
The Internal Audit activity adds value to the organisation (and its
stakeholders) when it considers strategies, objectives, and risks; strives
to offer ways to enhance governance, risk management and control
processes (by way of making audit recommendations); and objectively
provides relevant assurance.
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2 
The remit of the Audit Committee includes “To consider reports on the
effectiveness of internal controls and monitor the implementation of
agreed actions”, as part of its high-level oversight of the Council’s
governance, risk management and control framework. 
Date 17 January 2024 
Report Contact:
Duncan Stainbank
Chief Internal Auditor  
duncan.stainbank@midlothian.gov.uk
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3
3 Background 
3.1 Internal Audit is an independent appraisal function established for the
review of the internal control system as a service to Midlothian Council. 
It objectively examines, evaluates and reports on the adequacy of
internal control as a contribution to the proper, economic, efficient and
effective use of resources and the management of risk. 
3.2 The Internal Audit activity adds value to the organisation (and its
stakeholders) when it considers strategies, objectives, and risks; strives
to offer ways to enhance governance, risk management and control
processes (by way of making audit recommendations); and objectively
provides relevant assurance. 
3.3 Management has the responsibility for ensuring that agreed audit
actions are implemented to improve internal controls, risk management
and governance. At Internal Audit final report stage, the audit
recommendations are input to the Pentana Performance system, the
Council’s corporate performance management system. This is designed
to assist with Management tracking of implementation, link with relevant
risks and evidence improvement. 
3.4 Each year, Internal Audit undertakes two follow up reviews on the
recommendations it has raised. The first checks a sample of Internal
Audit recommendations which have been reported as complete and
reviews the adequacy of the actions taken and improvements made.
The second reports on the progress Management have made in
implementing the recommendations by the expected date. This year we
have combined the two follow up reviews into one report. 
3.5 The remit of the Audit Committee includes “To consider reports on the
effectiveness of internal controls and monitor the implementation of
agreed actions”, as part of its high-level oversight of the Council’s
governance, risk management and control framework. 
4        Review of Completion of Internal Audit Recommendations 
4.1 The objective of this follow-up audit was to review a sample of Internal
Audit recommendations that have been signed off by Management as
complete during the period 1 April 2022 to 31 March 2023 to assess the
evidence that recommendations have been implemented satisfactorily
and to ensure that the new controls had the desired effect on improving
internal control and governance and reducing risk. 
4.2 A sample of 41 audit recommendations (plus 1 sub-action) which were
at the ‘completed’ status on the Pentana Performance system were
selected and evidence was obtained to support the satisfactory
completion of each recommendation. Recommendations from the
following Internal Audit reports were selected: 
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4
Financial
Year
Internal Audit Report  No. High
Rated
Medium
Rated
Low
Rated
2018/19 Sales to Cash 1  1 
2019/20 Electronic Payment Systems 2   2
2019/20 Information Governance - Records
Management 
1  1 
2019/20 Leisure Management System 1  1 
2020/21 Social Housing Rents 1  1 
2021/22 Digital Learning Strategy and
Equipped for Learning Project 
2  2 
2021/22 Early Years Childcare (ELC)
Expansion
5 1 3 1
2021/22 Housing Allocations 4 1 1 2
2021/22 ICT and Cyber Security 1  1 
2021/22 Learning Disabilities and Physical
Disabilities (sub-action)
Sub
action  
Sub
action 
2021/22 Risk Management 4  4 
2021/22 Roads Maintenance Service 1   1
2021/22 Sustainable Environment 1  1 
2021/21 Waste Management and Recycling 1  1 
2022/22 Accounts Receivable  3  1 2
2022/23 Care at Home 1  1 
2022/23 Freedom of Information and
Environmental Information
Regulations
4  2 2
2022/23 PPP Schools Contract
Management and Payment
Mechanism
5  2 3
2022/23 Street Lighting 3  2 1 
Total 41 2 25 14 
4.3 From the 41 recommendations tested, 27 (66%) plus the sub-action,
were found to have been completed satisfactorily, 8 (20%) were
identified as partially satisfactory requiring further work, and 6 (14%)
were not satisfactory. 
4.4 For the audit recommendations that had been completed satisfactorily
the evidence that was provided by Management indicated that the
action taken had the desired effect on improving internal control and
governance and reducing risk. 
4.5 For the 8 audit recommendations identified as partially satisfactory
requiring further work: 2 were Low-rated and 6 were Medium-rated.
Further work required for the 8 recommendations is detailed in the table
below: 
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5 
Audit Further Work required Rating
1 2019/20 –
Electronic
Payments 
There should be up to date documentation mapping
out the flow of transactions for all relevant payment
systems. 
Low
2 2019/20 –
Electronic
Payments
Authorisation types in the Payment Guidelines need to
be clarified.  Low
3 2019/20 –
Leisure
Management
System
The outstanding debt recorded on the Legend system
should be reviewed and updated.  Medium
4 2021/22 Digital
Learning
Strategy and
Equipped for
Learning Project
The Digital Learning Strategy should be updated to
reflect the impact of the Equipped for Learning Project
and provide a framework for future developments. 
Medium
5 2021/22 – Early
Years Children
(ELC)
Expansion
Undertake early years child roll projections. Medium
6 2021/22 – Early
Years Children
(ELC)
Expansion
Undertake appropriate lessons learned processes for
ELC expansion projects when completed. Medium
7 2021/22 – Risk
Management
Risk management processes needs to be consistently
applied across Council Services, and then maintain
standards at this level. 
Medium
8 2022/23 - PPP
Schools
Contract
Management
and Payment
Mechanism 
PPP2 MD forms should be provided. A reconciliation of
the lifecycle element of all variations should be
undertaken.
Medium 
4.6 Of the 6 audit actions identified as not satisfied: 2 were Low-rated and 4
were medium related which are summarised in the table below: 
Audit Recommendation Rating
1 2021/22 – Risk
Management
Arrangements for monitoring and reporting of risks
requires improvement in some areas:         
• The CMT and Audit Committee should receive, on
an annual basis, assurances of compliance with
the Risk Management Policy.
• Operational risk level information in respect of
high or critical risks should be considered at
DMTs for potential escalation to CMT.
• Quality assurance checks on the application of
risk management process should be undertaken
and reported to DMTs as required in the Risk
Management Policy.
Medium
2 2021/22 -
Waste
Management
and Recycling 
The benefits of having performance data on various
aspects of the waste collection process should be
considered and if judged to be beneficial, performance
targets should be set and monitored through the use
of appropriate performance indicators.
Medium
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6
3 2022/22 - PPP
Schools
Contract
Management
and Payment
Mechanism
A risk register, in line with the Council’s Risk
Management Policy, should be created for PPP
Services.
Low
4 2022/23 –
Street Lighting
An effective lighting inspection programme should be
developed and maintained.  Medium
5 2022/23 –
Street Lighting
When calculating Performance Indicators, the
following should be implemented:
• retain an audit trail of source documentation for
reported PIs;
• create procedure notes to enable indicators to be
produced in the absence of key individuals;
• undertake quality assurance checks; and
• consider benchmarking information with other
councils to identify areas of improvements.
Medium 
6 2022/23 –
Street Lighting
The service risk register requires to be reviewed and
updated Low 
4.7 Discussions have been held with the action owners to highlight what is
required to ensure the remaining elements of the audit actions are fully
completed or a sustained control is established. A number of
recommendations have not been completed as they are dependent on
new systems being implemented. 14 audit actions have been re-opened
on the Pentana Performance system to enable the recommendation to
be completed by the new agreed action date with evidence of the
improvement action undertaken. 
5 Progress Update 
5.1  The objective of the second review is to assess Management’s reported
performance in closing actions raised by Internal Audit by the agreed
due date. It is Management’s responsibility to design and maintain
adequate risk management, governance and internal control processes
and checking that the arrangements and controls are operating
effectively which are also known as the first and second lines. The
quarterly performance monitoring process provides an opportunity for
Management to have a discussion on all of the open audit actions,
including those that are overdue, the reasons why they were not
completed by the original due date, risk mitigations in place in the
interim and requests to Internal Audit for extensions to due dates. 
5.2    An Internal Audit action report was generated from the Pentana
Performance system on 18 December 2023 which reflected the Quarter
2 updates 2022/23. 3 actions were overdue and 129 actions (including
sub-actions) were in progress which are summarised as follows:   
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7
Financial
Year
Action
Status
High Medium Low Total
2018/19 In Progress 2 1 1 4
2019/20 In Progress 1 2 5 8
2020/21 In Progress 2 7 4 13
2021/22 In Progress 3 20 18 41
2022/23 In Progress 0 20 25 45 
Overdue 0 0 1 1
2023/24 In Progress 1 3 14 18 
Overdue  0 0 2 2
Total  9 53 70 132 
5.3 The 3 overdue actions are summarised in Appendix B. The due dates
for these are now to be extended to 31 January 2024 in the Pentana
system, following further updates from management, which will ensure
the actions are completed within a reasonable time (1 of the actions will
be superseded by an action raised in the Risk Management internal
audit report). CMT are in support of this proposal and the Audit
Committee are asked to endorse this proposal. 
5.4  In addition to our normal review a requested follow up review of all of
the outstanding recommendations that an update is provided on the
progress of the audit recommendations from the Construction Projects
audit completed in May 2023. 7 of the 9 recommendations made have
been marked as fully complete by management the one overdue
recommendation in relation to risk management will be superseded by
recommendations to be made in the Risk Management Audit that will be
completed by March 2024, and the final recommendation will be fully
implemented when draft procedures are finalised in the first quarter of
2024. Further work will now be completed by internal audit that will
confirm the impact of the implementation of these recommendations
and will be confirmed by June 2024 if there is complete evidence of
implementation. 
5.5  This report was prepared for presentation to the Audit Committee on 29
January 2024. As this report was produced from the Pentana system as
of 18 December 2023, it should be noted that some actions will have
been updated as completed during the Quarter 3 updates and some
actions will have moved from ‘In Progress’ to ‘Overdue’ as they’ve gone
beyond their due date.  The progress on implementation of Internal
Audit recommendations has been discussed with the Corporate
Management Team on 17 January 2024. 
5.6      A further update on progress with the implementation of Internal Audit
recommendations will be included within the Internal Audit Annual
Assurance Report 2023/24 for Midlothian Council which is scheduled
for presentation to the Audit Committee in May 2024. 
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8
6    Report Implications (Resource, Digital, Risk and Equalities) 
6.1 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. 
6.2 Digital 
There are no digital implications arising from this report. 
6.3 Risk 
The recommendations made by Internal Audit are designed to reduce
the level of risk to which the Council is exposed through the
strengthening of the control environment and management of risks. 
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. 
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 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. 
6.5 Additional Report Implications (See Appendix A)
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9
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.” 
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10
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 is presented to the Audit Committee
to fulfil its remit “monitor the implementation of agreed actions”, as part
of its high-level oversight of the Council’s governance, risk management
and control framework. 
This report has been presented to the Corporate Management Team to
outline the key messages of assurance and areas of improvement. The
implementation of Audit recommendations will continue to be tracked by
Management using the Pentana Performance system and followed-up
by Internal Audit. Any further matters of concern will be raised to CMT
and the Audit Committee as appropriate. 
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 Internal Audit Recommendations – Overdue Actions 
As at 18 December 2023 
Audit Recommendation (Risk Rating) Rating Due Date  Progress Service
2022/23 - Construction Projects - Substantial Assurance
Appropriate service risk registers should be established in the Pentana Performance System for the Development
Team. Low 30-Sep-2023 0% Place
2023/24 - Licensing - substantial for the processing of applications and evidence compilation.  Assurance is limited for the governance arrangements
in place to support the licensing activity and the ongoing risk-based monitoring arrangements.
There is a need to clarify some aspects of the roles and responsibilities for Protective Services and the Clerk of
the Licensing Board. Low 31-Oct-2023 10% Place
Application forms should be updated with the Council’s Privacy Policy and should be available online for all
licences. Low 31-Oct-2023 25% Place 
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Page 116

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Page 117

Audit Committee
Monday 29 January 2024
Item 5.3 
Internal Audit Mid-Term Performance Report 2023/24 
Report by Chief Internal Auditor 
Report for Decision 
1 Recommendations 
The Audit Committee is asked to:
a) Note the progress Internal Audit has made with activity in the Internal
Audit Annual Plan 2023/24 to the end of December 2023;
b) Confirm that it is satisfied with the performance of the Internal Audit
service provision. 
2 Purpose of Report/Executive Summary 
The purpose of this report is to inform the Audit Committee of the
progress Internal Audit has made in the first 9 months of the year to 31
December 2023, towards completing the Internal Audit Annual Plan
2023/24. It also summarises the statutory obligations for Internal Audit
and requirements of the Public Sector Internal Audit Standards. 
Internal Audit provides assurance to Management and the Audit
Committee on the effectiveness of internal controls and governance
within the Council. 
The Internal Audit Annual Plan 2023/24 that was approved by the Audit
Committee on 7 March 2023 sets out the audit coverage for the year
utilising the expected available Internal Audit staff resources to enable
the Chief Internal Auditor, as the Council’s Chief Audit Executive
(CAE), to provide the statutory annual internal audit opinion regarding
the adequacy and effectiveness of internal control within the Council. 
The report provides details of the progress to date by Internal Audit
with its programme of work and highlights changes that require
approval to reflect the changes in resourcing available throughout the
year. 
Date 12 January 2024 
Report Contact:
Duncan Stainbank  Tel No 01620 827353
duncan.stainbank@midlothian.gov.uk
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3 Background 
3.1 As part of Midlothian Council’s system of corporate governance,
Internal Audit’s purpose is to support the Council in its activities
designed to achieve its declared objectives and to do so:
➢ In support of the Council’s vision, values and priorities.
➢ As a contribution to the Council’s corporate management of risk,
including assisting Management to improve the risk identification
and management process in particular where there is exposure to
significant financial, strategic, reputational and operational risk to
the achievement of the Council’s objectives.
➢ As an aid to ensuring that the Council and its elected members,
employees and contracted third parties are operating within the law
and relevant regulations, and that public money is safeguarded and
properly accounted for, and used economically, efficiently and
effectively.
➢ As a contribution towards establishing and maintaining a culture of
honesty, integrity, openness, accountability and transparency
throughout the Council in all its activities and transactions.
➢ As a contribution towards ensuring that financial statements and
other published performance information are accurate and reliable. 
3.2 Internal Audit provides assurance to Management and the Audit
Committee on the effectiveness of internal controls, risk management
and governance within the Council. 
3.3 The Internal Audit Annual Plan 2023/24 that was approved by the Audit
Committee on 7 March 2023 set out the audit coverage for the year
utilising anticipated available Internal Audit staff resources to enable
the Chief Internal Auditor, as the Council’s Chief Audit Executive
(CAE), to provide the statutory annual internal audit opinion regarding
the adequacy and effectiveness of internal control within the Council. 
3.4 Internal Audit assurance services are also provided during the year to
the Midlothian Health and Social Care Integration Joint Board, and a
statutory annual Internal Audit opinion is provided to its respective
Management and Board/Audit and Risk Committee to meet its
obligations. 
4 Mid-Year Results Against Internal Audit Plan 2023/24 
4.1 The Internal Audit programme of work led by the Principal Internal
Auditor takes account of the availability of auditor resources and
consultation with Management to consider operational service delivery
demands and timing of the Council’s transformation programmes. 
4.2 The Appendix B to this report provides details of the progress by
Internal Audit with its programme of work. Those audits which are
complete are highlighted in dark shading, those underway to reflect
their continuous audit approach are highlighted in light shading, and
those scheduled for the final quarter of the year are not shaded. 
4.3 In addition, 2 audits: Workforce Planning and Property Assets and
Property Strategy (shaded in grey) have now been removed from the
audit plan as this is not the appropriate time to complete these audits
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4.4 The Internal Audit plan had, in addition to regularly required review
processes, 13 audits scheduled for completion in 2023/24.  2
assignments are being substituted for other risk work which has been
identified during the year. The team has completed 5 assignments
(39%), 2 further assignments will be complete for the March Audit
Committee (15%). 6 further assignments (46%) are scheduled with
current team capacity to be substantially complete prior to the annual
governance reports in June 2024. Substantial completion of the plan
will allow for an appropriate assessment of the Councils governance,
risk and control environment. 
4.5 The continuous audit approach, in accordance with the Internal Audit
Strategy approved by Audit Committee on 7 March 2023, enables
Internal Audit to provide added value advice on internal controls and
governance and ‘critical friend’ consultancy services. For example,
Capital Planning and Asset Management Board, and Information
Management Group. 
5 Continued Reporting on the Internal Audit Plan for 2023/24 
5.1 The Internal Audit work will continue to be reported to the Corporate
Management Team and to the Audit Committee. The Internal Audit
reports will include: an Executive Summary of the audit objective,
findings, good practice, recommendations (where appropriate) and
audit opinion of assurance for each Final Internal Audit Report issued
to relevant Management; a summary of Internal Audit Assurance Work
in Progress; and an outline of Internal Audit Consultancy and Other
Work carried out in accordance with the approved Internal Audit
Charter. 
5.2 Internal Audit’s compliance with its Strategy and delivery of its risk-
based Annual Plan will be communicated within the Internal Audit
Annual Assurance Report which will also provide the statutory annual
Internal Audit opinion based on audit findings over the year. 
6 The Local Authority Accounts (Scotland) Regulations 2014 
6.1 The Local Authority Accounts (Scotland) Regulations 2014 which came
into force on 10 October 2014 require a local authority to operate a
professional and objective internal auditing service. This service must
be provided in accordance with recognised standards and practices in
relation to internal auditing. Recognised standards and practices are
those set out in the Public Sector Internal Audit Standards: Applying the
IIA International Standards to the UK Public Sector (PSIAS). The
standards require internal audit to have suitable operational
independence from the authority. 
6.2 The regulations require a local authority to assess the efficiency and
effectiveness of internal auditing activity from time to time in
accordance with recognised internal auditing standards and practices. 
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7  Public Sector Internal Audit Standards (PSIAS) and Quality
Assurance & Improvement Plan (QAIP) 
7.1 The Internal Audit function follows the professional standards as set out
in Public Sector Internal Audit Standards (PSIAS) effective April 2013
(updated April 2017) which includes:
➢ Definition of Internal Auditing;
➢ Code of Ethics;
➢ Attribute Standards (responsibility, independence, proficiency,
quality);
➢ Professional Standards (managing activity, nature of work,
engagement planning, performing the engagement, communicating
results, monitoring progress, risk management). 
7.2 The PSIAS requires the Chief Audit Executive (CAE), the Council’s
Chief Internal Auditor, to carry out an annual internal self-assessment
against the PSIAS, develop a quality assurance and improvement plan
(QAIP) based on the outcome, and report the results of the QAIP to
senior management and elected members. 
7.3 An annual internal self-assessment against the PSIAS of the Internal
Audit function will be completed prior to the end of 2023/24. The results
and any associated improvement actions will continue to be reported to
the Corporate Management Team and the Audit Committee within the
Internal Audit Annual Assurance Report. This will enable the Council to
meet the requirements of the Local Authority Accounts (Scotland)
Regulations 2014 to consider the findings of assessments as part of the
consideration of the system of internal control required by regulation 5. 
7.4 The PSIAS also requires the self-assessment to be subject to an
External Quality Assessment (EQA) each five years, by appropriately
qualified and independent reviewers. This EQA was carried out by
Highland Council in March 2018 and the results were outlined in the
Internal Audit Annual Assurance Report 2017/18 reported to the Audit
Committee in June 2018. The schedule for the second cycle of EQAs,
with other participating Scottish Councils as peer reviewers, indicates
that Midlothian will be reviewed by East Renfrewshire Council in 2024. 
8 Report Implications (Resource, Digital, Risk and Equalities) 
8.1 Resource 
The Internal Audit function reports directly to the Chief Executive
(operationally) and the Audit Committee (functionally). There is
currently a staff resource of 3.22 FTE, comprising Chief Internal Auditor
(0.5 FTE – shared with East Lothian Council), Principal Internal Auditor
(0.72 FTE), and Internal Auditor (2.0 FTE).  Each member of the
Internal Audit team has a professional internal audit or accountancy
qualification, and has suitable experience, knowledge, skills and
competencies (such as the Code of Ethics set out in PSIAS and the
Seven Principles of Public Life) needed to perform the plan. 
Budget monitoring of the Service is discussed by the Chief Internal
Auditor and the Principal Internal Auditor with the Financial Services
Manager on a quarterly basis to address any budgetary pressures. 
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There is a commitment to provide resource to the Midlothian Health
and Social Care Integration Joint Board (MIJB) as part of the Council’s
commitment to partnership working. Separate plans and reports are
presented to MIJB Audit and Risk Committee to fulfil this role. 
8.2 Digital 
There are no digital implications arising from this report. 
8.3 Risk 
The PSIAS require Internal Audit to evaluate the effectiveness of the
Council’s Risk Management arrangements and contribute to
improvements in the process. 
Key components of the audit planning process include a clear
understanding of the Council’s functions, associated risks, and
potential range and breadth of audit areas for inclusion. During the
development of the Internal Audit Annual Plan 2023/24, at the start of
each audit engagement, and during the re-assessment of the plan, to
capture potential areas of risk and uncertainty more fully, key
stakeholders have been consulted and risk registers have been
considered, to ensure the plan is formulated on a risk-based approach. 
If Internal Audit staffing levels fall below that assumed for the remaining
three-month period or if there is an unexpected and unplanned level of
contingency audit work, there is a high level of risk that the remaining
elements of the Annual Plan 2023/24 will not be delivered in full. This
could only be mitigated by use of external resource. Regular monitoring
will be undertaken to ensure that a sufficient range and breadth of
assurance audit work will be carried out during 2023/24 to underpin, a
‘not limited’ statutory Internal Audit opinion to Management and the
Audit Committee on the effectiveness of internal controls and
governance within the Council. 
8.4 Ensuring Equalities 
This report does not relate to a new or revised policy, service or budget
change, which affects people (the public or staff), so an Integrated
Impact Assessment (IIA) is not an applicable consideration. 
The Internal Audit work is carried out in accordance with the
appropriate legislation and professional standards. The latter includes
compliance by those within the Internal Audit function with the Code of
Ethics set out in the PSIAS which is appropriate for the profession of
Internal Audit founded as it is on trust placed in its independent and
objective assurance about risk management, internal control and
governance. 
8.5 Additional Report Implications (See Appendix A) 
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan to which Midlothian Council and its
Community Planning Partners have made a commitment (Reducing the
gap in economic circumstances; Reducing the gap in learning
outcomes; Reducing the gap in health outcomes; and Reducing the
impact of climate change), by providing an independent and objective
annual assessment of the adequacy of the entire control environment,
Internal Audit supports the Council to achieve its objectives. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow
supported by the 9 drivers for change. Implementing the 9 drivers for
change in practice is applicable to the Council’s Internal Audit service
provision to assist the Council in achieving its objectives. 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
The definition of Internal Auditing within the Public Sector Internal Audit
Standards (PSIAS) is “Internal auditing is an independent, objective
assurance and consulting activity designed to add value and improve
an organisation’s operations. It helps an organisation accomplish its
objectives by bringing a systematic, disciplined approach to evaluate
and improve the effectiveness of risk management, control and
governance processes.” 
Implementation by Management of the actions associated with Internal
Audit recommendations, that are designed to improve internal control Page 122 of 148

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and governance arrangements and management of risks, underpins
the Council’s own continuous improvement arrangements to enhance
its effectiveness, thus supporting the delivery of the Council’s best
value duties. 
A.5 Involving Communities and Other Stakeholders 
Internal Audit’s purpose is to support the Council in its activities
designed to achieve its declared objectives for the benefit of
Midlothian’s communities and other stakeholders. 
The Chief Internal Auditor is accountable to the Audit Committee which,
in fulfilling its governance role, acts as a bridge between the Council
and other stakeholders. 
This report has been presented to the Corporate Management Team to
outline the key messages of assurance plans. 
A.6 Impact on Performance and Outcomes 
The Findings and Recommendations from Internal Audit work during
the year, which are designed to maintain and / or enhance internal
controls, governance arrangements and risk management, assists the
Council in improving its performance and outcomes. 
A.7 Adopting a Preventative Approach 
Having robust internal controls, governance arrangements and risk
management in place contributes to safeguarding the Council’s
resources for delivery of services, as part of protecting the public purse.
Internal Audit assurance and consultancy activity is designed to
improve operations and assist the Council in accomplishing its
objectives. 
A.8 Supporting Sustainable Development 
This report does not relate directly to supporting sustainable
development. Good governance, including the provision of an Internal
Audit service, is important to enable Midlothian Council to achieve its
objectives.
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Appendix B
AUDIT DAYS COMMENTARY STATUS 
Assurance - Cyclical 
MLC Annual
Assessment of
Internal Control
and Governance
20 Prepare an annual assurance report for
Management and the Audit Committee
summarising the work undertaken by
Internal Audit during the year and forming an
opinion on adequacy of the Council’s
arrangements for risk management,
governance and internal control. Continuous
audit approach on progress with areas of
improvement. Annual evaluation of
compliance with the Local Code of Corporate
Governance covering the corporate whole
and individual Directorates / Services.
Continuous audit
approach to follow-up on
implementation of actions
on Areas of Improvement
set out in the Annual
Governance Statement
2022/23. Annual
evaluation of compliance
with the Local Code of
Corporate Governance
scheduled 4th Qtr.
Internal Audit opinion,
work undertaken and
compliance with PSIAS will
be outlined in Internal
Audit Annual Assurance
Report 2023/24.
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. 
Complete: Final Report
issued January 2024.
Executive Summary to
Audit Committee 29
January 2024. 
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. 
Complete: Final Report
issued 21 September
2023. Executive Summary
to Audit Committee 26
October 2023. 
Licensing 20
Review the policies, processes and
procedures in place to ensure the effective
licensing services are in place and subject to
effective governance. 
Complete: Final Report
issued 6 September 2023.
Executive Summary to
Audit Committee 26
October 2023. 
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.  
Audit Testing currently
underway with the
Executive Summary of the
report due to be
submitted to the 18
March 2024 Audit
Committee.   
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AUDIT DAYS COMMENTARY STATUS 
Assurance – Risk Based 
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. 
This audit is scheduled to
commence in the 4th
quarter of the financial
year with reporting of the
Executive Summary to the
Audit Committee on 14
May 2024.
Children's
Services
Continued Care
30 Review the processes around continuation of
care for looked after children. 
This audit is scheduled to
commence in the 4th
quarter of the financial
year with reporting of the
Executive Summary to the
Audit Committee on 24
June 2024.
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. 
This audit is scheduled to
commence in the 4th
quarter of the financial
year with reporting of the
Executive Summary to the
Audit Committee on 24
June 2024. 
Property Assets
and Property
Strategy
20
Review the processes of developing a
property asset management strategy and the
governance of the implementation. 
This audit has been
delayed until 2024/25 as a
result of additional work
being completed on the
review of Hillend project
post delays. 
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. 
The draft report has been
issued to management on
18 December 2023. The
Executive Summary will be
reported to the Audit
Committee on 18 March
2024.
Attainment
Scotland Funding 30
Review the governance and internal control
arrangements in place to support the
effective utilisation of Attainment Scotland
Funding (Pupil Equity, Strategic Equity and
Care Experienced Children and Young People
Funding). 
Planning has commenced
on this audit with
reporting of the Executive
Summary to the Audit
Committee on 24 June
2024. 
Growing Council,
Budgeting for
Growth
30
Review the approach to including population
and infrastructure growth into future budget
requirements across Council services. 
This audit is scheduled to
commence in the 4th
quarter of the financial
year with reporting of the
Executive Summary to the
Audit Committee on 24
June 2024.
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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. 
This audit has been
delayed until 2024/25 as a
result of additional work
being completed on the
review of leases reported
to the 29 January 2023
Audit Committee. 
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. 
Complete: Final Report
issued December 2023.
Executive Summary to
Audit Committee 29
January 2024. 
AUDIT DAYS COMMENTARY STATUS 
Consultancy 
Consultancy 30 In its ‘critical friend’ role provide: an
independent view and challenge of a sample of
programmes and projects (including Learning
Estate Strategy, Business Transformation
Board, Information Management Group); and
an objective assessment of self-evaluation
arrangements.
In its critical friend role
provided an independent
view and challenge at
various forums including
Business Transformation
Board, Capital Plan and
Asset Management Board,
and Information
Management Group. 
AUDIT DAYS COMMENTARY STATUS 
Other 
PSIAS Self-
Assessment
10 Undertake annual self-assessment of the
Internal Audit function against the Public Sector
Internal Audit Standards (PSIAS) and report
findings to the Audit Committee.
Scheduled 4th Qtr. Findings
will be outlined in Internal
Audit Annual Assurance
Report 2023/24.
MLC Audit
Committee Self-
Assessment
5 Provide assistance to Chair in undertaking a
self-assessment of the Audit Committee against
the CIPFA best practice guidance.
The Chair presented the
Audit Committee Annual
Report 2022/23 to Council
in October 2023. 2023/24
self-assessment is 
scheduled 4th Qtr.
MLC
Recommendation
Follow Up
Reviews
30 Undertake 2 reviews: the first includes a
sample check on the adequacy of new internal
controls for audit actions flagged as closed, and
the second assesses performance against
closing audit actions by the agreed due date.
Follow-up Review of
Completed and In Progress
Internal Audit
Recommendations 
reported to Audit
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Committee 29 January
2024.  
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.
Contingency days are being
used to support completion
of Internal Audit plan due
to resource constraints and
investigation/reactive work. 
Help Desk Enquiry
system
20 Provide guidance and advice to management
on internal controls.
Ongoing
MLC
Administration of
Audit Scotland
Reports
2 Monitor publication of Audit Scotland reports
and co-ordinate submission by management of
Audit Scotland reports to the relevant
Committee.
Ongoing
Management
Groups
4 Attend and provide support to Risk
Management and Integrity Groups.
Ongoing
MLC Attendance
at Boards /
Committees
10 Prepare for and attend Audit Committee
meetings and other Boards/Committees.
Ongoing
MLC Audit
Planning for
2024/25
10 Update the Audit Universe, check risk registers
and other sources of assurance, and develop
and consult on proposed coverage within the
Internal Audit Annual Plan 2024/25. 
Scheduled 4 Qtr. Internal
Audit Annual Plan 2024/25
will be presented to Audit
Committee for approval in
March 2024. 
AUDIT DAYS COMMENTARY STATUS 
Non MLC 
Midlothian Health
and Social Care
Integration Joint
Board
30 Audit reviews and support to be determined
and agreed by the MIJB Audit and Risk
Committee for review of the adequacy of the
MIJB’s arrangements for risk management,
governance and internal control for delegated
resources.
MIJB Internal Audit Annual
Plan 2023/24 approved by
MIJB Audit and Risk
Committee in March 2023.
Audit work ongoing.
Reports will be presented
to MIJB Audit and Risk
Committee. 
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Audit Committee
Monday 29 January 2024
Item 5.4 
Internal Audit Work to December 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 associated with the delivery of the approved Internal Audit
Annual Plan 2023/24;
b) Note the Internal Audit Consultancy and Other Work carried out in
accordance with the approved Internal audit Charter; and
c) Acknowledge the assurance provided on internal controls and
governance arrangements in place for the areas covered by this Internal
Audit work. 
2 Purpose of Report/Executive Summary 
The purpose of this report is to provide members of the Audit Committee with
details of the recent work carried out by Internal Audit and the findings and
recommended audit actions agreed by Management to improve internal
controls and governance arrangements. 
The Internal Audit Annual Plan 2023/24 was approved by the Audit
Committee on 7 March 2023. 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 Internal Audit function conforms to the professional standards as set
out in Public Sector Internal Audit Standards (PSIAS) (2017) including the
production of this report to communicate the results of the reviews. 
Date 17 January 2024 
Report Contact:
Duncan Stainbank
duncan.stainbank@midlothian.gov.uk
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2
3 Progress Report 
3.1 The Internal Audit Annual Plan 2023/24 was approved by the Audit
Committee on 7 March 2023. Internal Audit has completed the following
work in the period from 1 September to 31 December 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 Internal Audit function conforms to the professional standards as set
out in Public Sector Internal Audit Standards (PSIAS) (2017), including the
production of this report to communicate the results. 
3.3 Internal Audit issued final assurance reports on the following subjects:
• Developer Contributions; and
• Care Homes Public and Private. 
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. 
Internal Audit Consultancy and Other Work
3.5 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 Management 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. 
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3
Recommendations
3.6 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 lo
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. 
3.7 The table below summarises the number of Internal Audit recommendations
made during 2023/24:
Recs Rating 2023/24 Number of Recs
High 0
Medium 5
Low 7
Sub-total reported this period 12
Previously reported 33
Total 45 
Recommendations agreed with action plan 45
Not agreed; risk accepted 0
Total 45 
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. 
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4
It is anticipated that improvements in the management and mitigation of
risks will arise as a direct result of Management implementing the Internal
Audit recommendations made. If audit recommendations are not
implemented, there is a greater risk of financial loss and/or reduced
operational efficiency and effectiveness, and Management may not be able
to demonstrate improvement in internal control and governance
arrangements, and effective management of risks. 
4.4 Ensuring Equalities 
This report does not relate to a new or revised policy, service or budget
change, which affects people (the public or staff), so an Integrated Impact
Assessment (IIA) is not an applicable consideration. 
The Internal Audit work is carried out in accordance with the appropriate
legislation and professional standards. The latter includes compliance by
those within the Internal Audit function with the Code of Ethics set out in the
PSIAS which is appropriate for the profession of Internal Audit founded as it
is on trust placed in its independent and objective assurance about risk
management, internal control and governance. 
4.5 Additional Report Implications (See Appendix A) 
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5
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.” 
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6
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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Report Summary of key findings and recommendations Recommendations Status
H M L
Subject: Care Homes Council
and Private 
Category: Assurance –
Cyclical 
Date issued: 
12 December 2023 Draft 
18 January 2023 Final 
Level of Assurance: 
Substantial for governance
arrangements, procurement
of care home contracts and
assessments for funding.
Limited for service capacity,
checking compliance with the
National Care Home
Contract, periodic care plan
reviews for residential care,
and assurance over business
continuity arrangements
within external care homes.   
The purpose of the audit was to 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. 
The Health and Social Care Partnership (HSCP) is required under statute to
provide care and support services to those who are assessed as being in need.
Care homes for older people are provided by the Council and external providers in
Midlothian. The Council currently runs 1 care home and 1 intermediate care
service. A National Care Home Contract (NCHC) is in place which is negotiated
by COSLA on behalf of all Scottish local authorities. The Care Home Support
Team (CHST) undertakes quality monitoring audits at each care home. The Chief
Nurse provides clinical support to care homes and liaises with the CHST.  A
multidisciplinary Rapid Run Down group was established early in the pandemic to
provide a responsive reporting structure for the CHST. Periodic care plan reviews
for residential care are set on Mosaic and are undertaken by the Social Work
team. 
In August 2023, it was reported to the MIJB that the Social Care overall forecast is
projecting a £4.4m overspend.  Areas reporting an overspend were the resource
panel budget (particularly learning disabilities) and Newbyres Care Home and
Highbank Intermediate care home.  Following challenges in securing workforce,
there has been a temporary pause to admissions (61 to 48 bed spaces) at
Newbyres Care Home. The temporary decision to reduce bed space was not
related to budget but about ensuring the safe care of residents.  The HSCP were
unable to ensure that there were sufficient care workers available to work, due to
both a local and national issue around the workforce in this line of work.  Safety of
both residents and staff is the prime focus.
As at end of Q2, 2023/24, the forecasted overspend for care homes (including
clients with learning disabilities placed in external care homes) was £2.6m. In the
Council owned care home, there has been a reliance on agency staff to support
resident complexity and the increasing complexity of care needs is contributing to
the significant financial pressures on the Learning Disability budget. 
0 2 3 Management have
accepted the factual
accuracy of the
report and its
findings, and agreed
to implement the
recommendations. 
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Internal Audit considers that the level of assurance is substantial for governance
arrangements, procurement of care home contracts and assessments for funding. 
Assurance is limited for service capacity (based on increasing demographic
demands in Midlothian), checking compliance with the National Care Home
Contract, periodic care plan reviews for residential care, and assurance over
business continuity arrangements within external care homes.  Although budget
management processes and recovery plans are in place, there are significant
financial pressures over funding of internal care homes and external care home
placements. There are currently insufficient care home placements within
Midlothian with only 474 beds (both self-funding and standard funded beds). This
number of beds is below the national average against age demographic and
means vacancies within Midlothian are limited and require families to think of
placements out with Midlothian. In addition, there are currently clients who have
been resident in Highbank Intermediate Care Home for longer than the planned 6
weeks. Management have advised that a commissioned review of all beds across
Midlothian will be undertaken, and the outcome of this review is expected to be
reported in early 2024. Whilst it has been advised that there are service plans in
place for care homes, Internal Audit made the following recommendations: 
• Overarching guidance should be in place for managing Newbyres and
Highbank care homes. The guidance should explain the roles and
responsibilities of services, legislative requirements and monitoring
arrangements. (Low)
• The Rapid Run Down group should have a formal terms of reference
describing the purpose of the group; the frequency of meetings and the
responsibilities of the group members. (Low)
• Care plan reviews for residential care should be undertaken on a timely basis
and the community care home review policy should be reviewed and updated.
(Medium)
• Care Home Service risks should be recorded within an Adult Social Care Risk
Register in line with the Council’s Risk Management Policy. (Low)
• Monitoring of care homes should be undertaken to ensure they are complying
with the National Care Home contract (eg. ensuring relevant policies and
procedures are in place and reviewing the residency agreements used by the
provider). Building and contents insurance for care home providers should be
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checked annually and maintained by the Council. Management should ensure
that all external care home providers have adequate business continuity plans
in place. (Medium)
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Report Summary of key findings and recommendations Recommendations Status
H M L
Subject:  Developer
Contributions 
Category: Assurance –
Risk-based 
Date issued: 
30 November 2023 Draft 
20 December 2023 Final 
Level of Assurance: 
Substantial 
Midlothian has been experiencing significant growth and investment for a number
of years.  The 2022 census highlighted that Midlothian’s percentage population
growth has been almost six times higher than the national average over the last
decade (16.1% in Midlothian compared to a Scottish national average of 2.7%). 
Developer Contributions are a means of mitigating against the impact of growth
by providing the Council with a financial contribution towards the cost of new
capital infrastructure.  
Midlothian’s development plan is comprised of National Planning Framework 4
(which superseded the Edinburgh and South East Scotland Strategic
Development Plan June 2013 in February 2023) and the Midlothian Local
Development Plan 2017 (MLDP), adopted in November 2017 following
consultation.  Policies set out within the MLDP require the developer to deliver, or
contribute to, the required infrastructure or mitigate the impact of the
development.  The MLDP sets out the following topic areas for developer
contributions: education provision; transport infrastructure (including towards
Borders Rail, the A7 urbanisation scheme, Sheriffhall Roundabout upgrade and
the A701 realignment and A702 spur); affordable housing provision (which could
include a financial contribution); community facilities; sport and leisure facilities;
town centre improvements; and open space and play provision/upgrades.
Developer Contributions towards these areas generally only cover the capital cost
of the development, not the ongoing revenue costs.  However, new housing
should in theory increase the ongoing revenue for the Council through additional
Council tax and increases in the block grant to reflect the increase in population.
Local Authorities are required to set out their plans in Supplementary Guidance
(SG) (Circular 1/2009, Scottish Government, 2009).  The purpose of this guidance
is to detail the Council’s requirements in respect of planning obligations to be
secured from new developments and provide further detail in support of the
development plan.  The Council’s Supplementary Guidance was published in
2012. 
0 3 4 Management have
accepted the factual
accuracy of the
report and its
findings, and agreed
to implement the
recommendations. 
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Report Summary of key findings and recommendations Recommendations Status
H M L
As at 31 March 2023, the Council held £43.092m of Developer Contributions with
contribution receipts in the year of £9.029m and contributions applied of £6.074m. 
£1.598m of planning obligations were entered into in 2022/23 and £2.139m were
entered into in 2021/22.
The Council’s Planning team, as part of the planning application process, assess
whether Developer Contributions are required, and the decision is logged in the
Idox Uniform system.  Applications are assessed against the Council’s Local
Development Plans and Supplementary Guidance to determine whether
contributions are relevant.  If the application is not covered by the Local
Development Plans (windfall housing), the Planning team will engage with service
areas as required to establish the necessary contributions and follow the process
set out in the MLDP and SG.  
The Lead Officer Planning Obligations is responsible for the majority of
negotiations with developers.  Following negotiation, a Heads of Terms document
is prepared setting out the contributions required for the development, and this is
submitted to the Executive Director, Place, for review and approval under the
Council’s delegated authority. Following approval, the Legal Services team
produce a legal agreement in conjunction with the developer’s solicitors.
Developer Contributions are logged on the Exacom Planning Obligations Suite
system which records documentation relevant to the agreement, the financial
details of each agreement, the trigger points when contributions are due (e.g.
when a specific number of houses are completed), the receipt of contributions
from developers, the projects contributions are to be allocated to, and the
subsequent application of contributions to these projects.  The majority of the
update and maintenance of the system is undertaken by the Lead Officer
Planning Obligations.  Financial Services coordinate with the Lead Officer
Planning Obligations to monitor the contributions received and their subsequent
application to projects.  The allocation of contributions to projects is initially on
approval from Council, and this is administered by Financial Services in the
financial ledger and annually updated on the Exacom system.  Unutilised
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Report Summary of key findings and recommendations Recommendations Status
H M L
contributions are allocated to interest bearing accounts in line with the Council’s
Treasury Management Strategy.
The Capital Plan and Asset Management Board (CP&AMB) has responsibility for
monitoring the Council’s Developer Contributions and receives twice yearly
update reports which includes reporting on the expiry dates of contributions. 
Additionally, an annual report is submitted to Council providing an update on
planning obligations (The Planning (Scotland) Act 2019 will make this a
mandatory requirement, but the Council has implemented this in advance of it
coming into force).
A previous internal audit in 2016 reported that there was not an adequate
database to manage the Council’s developer contributions resulting in no central
repository to hold details of all agreements and modifications and a significant
reliance on developers to advise the Council when contributions were due. This
issue has been resolved with the implementation of the Exacom system. 
Similarly, reporting on expiry dates of contributions to an appropriate governance
body is now in place - this was not in place in 2016.  
Internal Audit considers that the level of assurance is substantial for Developer
Contributions.   Since the last full audit review in 2016 there has been a significant
improvement in this area.  Internal Audit made the following recommendations:
• Written procedures should be developed for the Developer Contributions
calculation process and creation of the Heads of Term document.  The
service risk register should be updated to take into account the risk of
contributions not utilised used in time and completeness of the MLDP. An
annual declaration process should be introduced for declaring conflicts of
interest for those involved in negotiating with developers. (Low)
• Procedures should be prepared covering the invoicing, ongoing monitoring
and reconciliation processes within Financial Services. (Low)
• Sufficient resource should be in place to support the Developer Contributions
process, ensure that the database is kept up to date, all relevant documents
are uploaded to the system and demand notices are generated promptly. 
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Report Summary of key findings and recommendations Recommendations Status
H M L
Additionally, an appropriate audit trail should be retained of the calculation
workings supporting the Heads of Terms. (Medium)
• The Supplementary Guidance for Developer Contributions should be updated
and include adequate detail as to how contributions should be calculated.
(Medium)
• For the next LDP, management should liaise with NHS Lothian and other
stakeholders to establish if there is a need or basis for contributions in their
respective areas. (Medium)
• The reconciliation between the Financial Ledger and the Exacom system
should be undertaken annually, and any differences promptly investigated.
(Low)
• Reporting to the Capital Plan and Asset Management Board should highlight
developer contributions that are due to expire but do not have an assigned
project.  Additionally, consideration should be given to reporting 3 times a
year instead of two given the importance of this area. (Low)
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Audit Committee
Monday 29 January 2024
Item 5.5 
Lease of Premises: Burnbrae Road, Bonnyrigg 
Report by: Chief Internal Auditor 
Report for Information 
1 Recommendations 
The Audit Committee is asked to note the work undertaken by Internal
Audit in response to the instruction, from the Council on 29 August 2023
to review the lease of the retail premises at Burnbrae Road Bonnyrigg. 
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
following an instruction from the Council meeting on 29 August 2023.   
The instruction in the minute was that the Council had agreed: 
• That Internal Auditors investigate the position of the retail unit at
Burnbrae Road and that the Council are at no undue risk. 
• That an update is provided ‘in private’ on the retail unit currently
being constructed adjacent to this building, in Buccleuch Street. 
Internal Audit has reviewed the situation of the retail unit at Burnbrae
Road which was subject to the inherent commercial risks of developing
retail unit space as part of any place making development. The risk of
leasing retail space to commercial partners materialised as an issue in
relation to this development as a result of an identified partner
potentially not being able to take on the lease of the building when
complete. However, on identification of this issue, Council Officers
acted in an appropriate manner to reduce the risks to the Council.
Processes were undertaken to identify a new preferred partner and an
appropriate organisation was identified who will be taking on the lease
for this premises.   
Internal Audit found that whilst commercial risk has been identified in
relation to the development of this retail unit, this risk is being
appropriately managed. 
The retail units in Buccleuch Street are in the process of being let and
have interactions with the Dalkeith Town Centre regeneration plans.
Internal Audit have no concerns over the processes being undertaken
in relation to these units that they would bring to the attention of the
Audit Committee, although the process remains ongoing. 
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2
Date 17 January 2024 
Report Contact:
Duncan Stainbank
duncan.stainbank@midlothian.gov.uk
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3 Background 
3.1 The 29 August 2023 Council meeting was presented with report 8.4 for
noting in relation to the Chief Executive in consultation with the Leader
of the Council using Standing Order 19.2 powers to secure lease
arrangements with a supermarket provider to occupy the retail unit
being developed by the Council at Burnbrae Road, Bonnyrigg. The
minute of the 29 August 2023 Council meeting instructed that the
Council had agreed: 
• That Internal Auditors investigate the position of the retail unit at
Burnbrae Road and that the Council are at no undue risk. 
• That an update is provided ‘in private’ on the retail unit currently
being constructed adjacent to this building, in Buccleuch Street. 
3.2 Internal Audit, having been advised of this instruction on 5 October
2023, met with officers from the Property and Facilities team who
provided further documentation in relation to these properties through
to December 2023. A final report is now being provided to the Audit
Committee identifying the agreed conclusions of this Internal Audit
work.     
3.3 The Internal Audit work completed as instructed has focused on the
leasing of the retail unit at Burnbrae Road which was being developed
as part of a development to deliver 20 housing units in addition to the
retail unit. A review of the processes being undertaken to let the retail
units in Buccleuch Street has been completed at a high level. 
Findings 
3.4 As part of the development of the retail unit at Burnbrae Road,
Bonnyrigg a documented preferred client had been identified for the
retail unit who had signed a pre-lease agreement to conclude a lease
when the unit had been completed. Towards the end of 2022 and
beginning of 2023, as a result of multiple contacts with this client, the
Property and Facilities Management Service had ascertained that due
to a change of circumstances with this client, they would not be in a
position to enter a lease agreement when the building was completed. 
3.5 The Property and Facilities Management Service undertook an open
market exercise for this property (with a closing date in June 2023) and
4 offers were received to be the preferred lease client. In July 2023, the
Council decided (as described in paper 8.4 to the Council on 29 August
2023) to progress with the offer that provided the highest rental value
and largest retailer who had offered to take on the lease.
3.6 The retail unit at Burnbrae Road was completed and passed over to the
Council in December 2023. The major supermarket retailer who agreed
to take over the lease has been confirming the lease terms and
conditions with the Council appointed legal firm and a final lease is now
available for signature during January 2024 (with a commencement
date of the lease shortly after this). 
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3.7 The risk of potential clients being unable to continue with a lease are
understood by the Property and Facilities Management Service and
has been monitored and mitigated and on that basis no undue risk has
been taken. 
3.8 The retail units in Buccleuch Street are in the process of being let by
the Council.  They have interactions with the wider Dalkeith Town
Centre regeneration plans and are not being let directly through the
market. However, when required, independent advice on rent levels is
being sought to ensure rates are in line with the market. At the time of
writing, no leases have yet been finalised for the units. 
4 Report Implications (Resource, Digital, Risk and Equalities) 
4.1 Resource 
Resource implications 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 
This review identifies the risks associated with retail development and
how they are managed. 
4.4 Ensuring Equalities 
This report does not relate to a new or revised policy, service or budget
change, which affects people (the public or staff), so an Integrated
Impact Assessment (IIA) is not an applicable consideration. 
The Internal Audit work is carried out in accordance with the
appropriate legislation and professional standards. The latter includes
compliance by those within the Internal Audit function with the Code of
Ethics set out in the PSIAS which is appropriate for the profession of
Internal Audit founded as it is on trust placed in its independent and
objective assurance about risk management, internal control and
governance. 
4.5 Additional Report Implications (See Appendix A) 
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APPENDIX A – Additional Report Implications 
A.1 Key Priorities within the Single Midlothian Plan 
Although this report does not relate directly to the key priorities within
the Single Midlothian Plan to which Midlothian Council and its
Community Planning Partners have made a commitment (Reducing the
gap in economic circumstances; Reducing the gap in learning
outcomes; Reducing the gap in health outcomes; and Reducing the
impact of climate change), good governance is important to enable
Midlothian Council to deliver its key priorities in support of achieving the
Council’s objectives. 
A.2 Key Drivers for Change 
Key drivers addressed in this report: 
Holistic Working  
Hub and Spoke  
Modern  
Sustainable  
Transformational  
Preventative  
Asset-based  
Continuous Improvement  
One size fits one 
None of the above 
Midlothian Council is committed to creating a great place to grow
supported by the 9 drivers for change. Implementing the 9 drivers for
change in practice is applicable to the Council’s Internal Audit service
provision to assist the Council in achieving its objectives. 
A.3 Key Delivery Streams 
Key delivery streams addressed in this report: 
One Council Working with you, for you  
Preventative and Sustainable  
Efficient and Modern  
Innovative and Ambitious 
A.4 Delivering Best Value 
The definition of Internal Auditing within the Public Sector Internal Audit
Standards (PSIAS) is “Internal auditing is an independent, objective
assurance and consulting activity designed to add value and improve
an organisation’s operations. It helps an organisation accomplish its
objectives by bringing a systematic, disciplined approach to evaluate
and improve the effectiveness of risk management, control and
governance processes.” 
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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. 
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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