Please Contact: Tessa Gilder-Smith Please email: Tessa.Gilder-Smith@north-norfolk.gov.uk Please Direct Dial on: 01263 516047 06 March 2014 A meeting of the Audit Committee of North Norfolk District Council will be held in the Committee Room at the Council Offices, Holt Road, Cromer on Monday 17 March 2014 at 2.00 pm Members of the public who wish to ask a question or speak on an agenda item are requested to arrive at least 15 minutes before the start of the meeting. It will not always be possible to accommodate requests after that time. This is to allow time for the Committee Chair to rearrange the order of items on the agenda for the convenience of members of the public. Further information on the procedure for public speaking can be obtained from Democratic Services, Tel: 01263 516047, Email: democraticservices@north-norfolk.gov.uk Sheila Oxtoby Chief Executive To: Mr N D Dixon, Mr B Jarvis, Mrs A Moore, Miss B Palmer, Mr R Reynolds and Mr D Young All other Members of the Council for information. Members of the Management Team, appropriate Officers, Press and Public If you have any special requirements in order to attend this meeting, please let us know in advance If you would like any document in large print, audio, Braille, alternative format or in a different language please contact us Chief Executive: Sheila Oxtoby Strategic Directors: Nick Baker and Steve Blatch Tel 01263 513811 Fax 01263 515042 Minicom 01263 516005 Email districtcouncil@north-norfolk.gov.uk Web site northnorfolk.org AGENDA 1. TO RECEIVE APOLOGIES FOR ABSENCE 2. PUBLIC QUESTIONS To receive public questions, if any 3. ITEMS OF URGENT BUSINESS To determine any items of business which the Chairman decides should be considered as a matter of urgency pursuant to Section 100B(4)(b) of the Local Government Act 1972. 4. DECLARATIONS OF INTEREST Members are asked at this stage to declare any interests that they may have in any of the following items on the agenda. The Code of Conduct for Members requires that declarations include the nature of the interest and whether it is a disclosable pecuniary interest. 5. MINUTES (Page 1) To approve as a correct record, the minutes of the meeting of the Audit Committee held on 10 December 2013. 6. AUDIT UPDATE AND ACTION LIST (Page 6) To monitor progress on items requiring action from the meeting of 10 December 2013, including progress on implementation of audit recommendations 7. AUDIT COMMITTEE WORK PROGRAMME (Page 7) To review the Audit Committee Work Programme. 8. ANNUAL CERTIFICATION REPORT 2012/13 (Page 9) To receive the Annual Certification Report 2012/13 as provided by external auditors, PricewaterhouseCoopers 9. EXTERNAL AUDIT PLAN 2013/14 (Page 23) To discuss the External Audit Plan 2013/14 as provided by external auditors, PricewaterhouseCoopers 10. INTERNAL AUDIT’S CHARTER, CODE OF ETHICS, AUDIT STRATEGY, STRATEGIC AND ANNUAL PLANS, SUMMARY OF INTERNAL AUDIT COVERAGE AND PERFORMANCE INDICATORS FOR 2014/15 (Page 52) (Appendix 1- p.58)(Appendix 2 – p.69)(Appendix 3 – p.73)(Appendix 4 – p.76)(Appendix 5 – p.81)(Appendix 6 – p.83)(Appendix 7 – p.93)(Appendix 8 – p.95) Summary: This report provides an overview of the stages followed prior to the formulation of the Strategic Audit Plan for 2014/15 to 2016/17 and the Annual Audit Plan for 2014/15. The Annual Audit Plan will then serve as the work programme for the Council‟s Internal Audit Services Contractor, Mazars Public Sector Internal Audit Ltd, and provide the basis upon which the Internal Audit Consortium Manager will subsequently give Audit Opinions on North Norfolk Council‟s system of internal control and risk management, and corporate governance arrangements for 2014/15. Members‟ attention is also drawn to the fact that this is the first time that an Audit Charter has been presented. Previously, Terms of Reference had been submitted annually, but now, in accordance with Public Sector Internal Audit Standards, which came into effect from 1 April 2013, it has been necessary to develop an Audit Charter to reflect how the Internal Audit Service will operate in accordance with updated mandatory standards. The foundations of the Public Sector Internal Audit Standards however are not so fundamentally different to those requirements formerly specified in the CIPFA Code of Practice for Internal Audit, although the structure of the Charter must follow a prescribed format which defines the purpose, authority and responsibility of the Internal Audit activity, and clear definitions need to be given of those governance elements fulfilling responsibilities of the „board‟ and „senior management‟. Conclusions: Recommendations: In reviewing and approving the Audit Charter and related strategic and operational audit planning information, the Audit Committee is making appropriate provisions to ensure that the Internal Audit requirements as stated in the Local Government Finance Act 1982, c.32 and the Accounts and Audit Regulations 2011 are being properly met, and due support is being given to securing an Internal Audit Service, which is compliant with statutory internal auditing standards applicable to public sector organisations. The Committee is requested to approve: Internal Audit‟s Charter for 2014/15; Internal Audit‟s Code of Ethics for 2014/15; Internal Audit‟s Strategy for 2014/15; The Strategic Audit Plan for 2014/15 to 2016/17; The Annual Audit Plan for 2014/15; The Summary of Internal Audit Coverage for 2014/15; and, Performance Indicators for 2014/15. Cabinet member(s): Wards: Contact Officer, telephone number, and e-mail: All All Emma Hodds, Deputy Audit Manager 01508 533791 ehodds@s-norfolk.gov.uk 11. PROGRESS REPORT ON INTERNAL AUDIT ACTIVITY, 26 NOVEMBER 2013 TO 25 FEBRUARY 2014 (Page 97) (Appendix 9 – p.100) (Appendix 10 – p.102) Summary: Conclusions: Recommendations: Cabinet member(s): Wards: Contact Officer, telephone number, and e-mail: 12. This report examines progress made between 26 November 2013 and 25 February 2014 in relation to delivery of the Annual Audit Plan for 2013/14. A total of 1 audit assignment has been processed culminating in a mix of good and adequate assurances being awarded to date this financial year. It is recommended that the Committee notes the outcome of the audit completed between 26 November 2013 and 25 February 2014 where an assurance level has been given and the progress to date with the annual audit plan. All All Emma Hodds, Deputy Audit Manager 01508 533791 elhodds@s-norfolk.gov.uk EXCLUSION OF THE PRESS AND PUBLIC To pass the following resolution, if necessary: “That under Section 100A(4) of the Local Government Act 1972 the press and public be excluded from the meeting for the following items of business on the grounds that they involve the likely disclosure of exempt information as defined in of Part I of Schedule 12A (as amended) to the Act.” Agenda item _5_ AUDIT COMMITTEE Minutes of a meeting of the Audit Committee held on Tuesday 10 December 2013 in the Committee Room, Council Offices, Holt Road, Cromer at 2.00 pm. Members Present: Committee: Mr N D Dixon (Chairman) Mr B Jarvis Officers in Attendance: Chief Accountant, Internal Audit Consortium Manager, Regulatory Officer, Democratic Services Officer. Also in attendance: Aphrodite Antoniades (PriceWaterhouseCoopers) 31. Miss B Palmer Mr D Young APOLOGIES Apologies for absence were received from Mrs A Moore and Mr R Reynolds. Mr R Shepherd had also sent apologies as he had been due to attend as substitute for Mr Reynolds but was unwell. 32. PUBLIC QUESTIONS None received. 33. ITEMS OF URGENT BUSINESS The Chairman referred to the Business Continuity plans which had been considered by the Committee over a period of time. This work had proved very valuable in preparation for and response to the recent storm surge which had caused major damage to communities and the Council’s assets along the coast. He commended the work done by Civil Contingencies Manager and his team in minimising the impact as far as possible and supporting the community both during and following the event. He requested that thanks be recorded to the Civil Contingencies team, Communications team and other staff who were involved. 34. DECLARATIONS OF INTEREST None 35. MINUTES The Minutes of the meeting of the Audit Committee held on 17 September 2013 were approved as a correct record. 36. AUDIT UPDATE AND ACTION LIST Members were updated on progress on actions arising from the minutes of the meeting of 17 September 2013. Audit Committee 1 10 December 2013 Pensions benchmarking The Committee considered the data which had been supplied by PWC relating to pensions liability. It was noted that the liability was rising in line with other authorities and whilst this was not of significant concern at the present time, it should be monitored so that action could be taken if necessary. It was agreed to review the matter annually in September as part of the Committee’s Work Programme. Annual Report of the Monitoring Officer 2012/13 It was not known if the complaints data had been supplied to Mrs Moore. The Chairman requested the Chief Accountant to contact the Monitoring Officer on this matter. Local Code of Corporate Governance and Annual Governance Statement 2012/13 The Head of Finance had been unable to attend the meeting due to another commitment. The Chief Accountant agreed to confirm the status of the actions relating to the rewording of Appendix B and the inclusion of metrics. The Democratic Services Officer stated that the dates of other Councils’ Scrutiny meetings had been included in the Members’ Bulletin. Audit Committee Self-Assessment Outcomes It was noted that training on Internal and External Audit was programmed for March 2014. 37. AUDIT COMMITTEE WORK PROGRAMME RESOLVED That, subject to the inclusion of a review of pensions liability in September 2014, the Work Programme be noted. 38. ANNUAL AUDIT LETTER 2012-13 Aphrodite Antoniades presented the Annual Audit Letter, which summarised the results of the work undertaken by External Audit for the year 2012/13. There were no issues of concern. Mr D Young considered that the use of colours in the original letter made some of it difficult to read when reproduced. Ms Antoniades agreed to take this matter forward to ensure it was addressed. The Committee noted that the fee for certification of claims and returns was yet to be finalised. Ms Antoniades explained that confirmation was awaited from the Audit Commission that the proposed fee submitted by PWC was appropriate. Additional work had been carried out so the fee was likely to be higher than estimated but less than it had been in the previous year. At the request of the Chairman, Ms Antoniades agreed to forward the indicative certification fee with reasons for the increase above the estimate and when available, the final fee with reasons for adjustment, if any. The Chairman stated that the report was pleasing and indicated that the Council was in a better position than it had been a few years ago. Audit Committee 2 10 December 2013 6 RESOLVED That the Annual Audit Letter 2012-13 be noted. 40. PROGRESS REPORT ON INTERNAL AUDIT ACTIVITY, 1 SEPTEMBER TO 25 NOVEMBER 2013 The Internal Audit Consortium Manager presented the report, which examined progress made between 1 September and 25 November 2013 in relation to delivery of the Annual Audit Plan for 2013/14, and included abbreviated management summaries in respect of the audit reviews which had been finalised in the course of this period. A total of 6 audit assignments had been processed, and it was noted that all audits finalised in the period had received a positive assurance. It was also noted that all audit reports issued so far in the current financial year had resulted in positive assurances being awarded, which emphasised that the systems of internal control evaluated to date had been found to be working effectively and efficiently. The Committee noted that the overall planned audit days for the year had been reduced from 213 days to 186 days, due to the envisaged Phase 2 element of ad-hoc work requested by management in relation to the Revenues and Benefits service not progressing as originally envisaged. Management was re-examining partnership arrangements with a view to securing savings and efficiencies from service delivery in the future. In addition, it had been agreed to defer the audit of Development Management to 2014/15 as there was still considerable work to be done to complete the Planning Peer Challenge Action Plan before a meaningful audit could be performed in this service area. 74% of the revised Audit Plan had been completed, which was a significant achievement and the highest level of all Consortium clients. The Internal Audit Consortium Manager confirmed that there had been no change in the assurance levels for Document Imaging and Workflow and Revenues and Benefits compared to the previous year, as this was not indicated in the report. In response to a question the Chief Accountant explained that the issue regarding the frequency of bank reconciliations had now been addressed. A report on the outcomes of a Computer Audit Needs Assessment would be considered later in the meeting. RESOLVED That the outcomes of the 6 audits completed between 1 September and 25 November be noted, together with in-year revisions made to the approved Annual Audit Plan for 2013/14 concerning the rescheduling of some reviews and the requirement, endorsed by management, to defer two pieces of work to 2014/15. 41. THE STATUS OF AGREED AUDIT RECOMMENDATIONS DUE FOR IMPLEMENTATION BETWEEN 1 APRIL AND 31 OCTOBER 2013 The Internal Audit Consortium Manager reported on the progress made in implementing agreed audit recommendations due for completion in the first half of the financial year. Audit Committee 3 10 December 2013 7 The Internal Audit Consortium Manager drew attention to one high priority action which remained outstanding, relating to Housing and Council Tax benefit, and the explanation contained in Appendix D to the report. It was noted that the improvement in management responses had continued. A high percentage of recommendations were being completed within agreed timeframes. However, the number of outstanding recommendations was beginning to increase. This remained lower than the comparable period last year but showed a slight deterioration on the year end position. Internal Audit was working closely with managers on the agreed actions. Of the 36 outstanding actions agreed with management following completion of the 2013/14 audit assignments, 22 had not yet reached the date set for their completion. The Internal Audit Consortium Manager considered that good progress had been achieved in relation to the completion of agreed Internal Audit recommendations. It was noted that the table at Appendix C to the report was incomplete, there being a total of 8 recommendations to be actioned in respect of IT Security, Procurement and End User Controls, with a grand total of 14 recommendations to be actioned at 31 October 2013. RESOLVED That the management action taken to date regarding the implementation of audit recommendations be noted. 11. REVIEW OF THE OUTCOMES OF A RECENTLY PERFORMED COMPUTER AUDIT NEEDS ASSESSMENT AND ITS IMPACT ON THE STRATEGIC AUDIT PLAN FOR 2013/14 The Internal Audit Consortium Manager reported the outcomes of the Computer Audit Needs Assessment exercise carried out during September 2013. A programme of computer audits had been formulated to address areas of risk which had been identified. No changes had been sought to the computer audit coverage timetabled for 2013/14, much of which had already been scheduled with management at the time of undertaking the assessment. Ten audits had been identified for completion over the next three years, with a further assessment required in 2016/17 to set a further programme of IT reviews for successive years. The current audit contract was due to end in September 2014 and it was therefore possible that the proposed audits would be revisited by a new contractor and may change. There was an ongoing need to revisit agreed actions from previous audit work to confirm progress made to address internal control weaknesses and/or introduce enhancements to existing operational arrangements. Mr D Young expressed concern regarding the reduction in the number of audit days and the number of audits on the reserve list. The Internal Audit Consortium Manager explained that it would be unrealistic in terms of cost to include all of the audits in the Audit Plan. There was a sufficient level of coverage to provide an audit opinion. Audit Committee 4 10 December 2013 8 In response to a question by the Chairman, the Internal Audit Consortium Manager stated that all tenderers for the new Internal Audit contract would have sight of the Audit Plan. RESOLVED That the findings of the Computer Audit Needs Assessment be noted and the amended planned audit coverage for the period 2014/15 to 2016/17 as recorded in the amended Strategic Audit Plan be approved. 12. CORPORATE RISK REGISTER The Chief Accountant stated that the Corporate Risk Register had been considered by the Performance and Risk Management Board. The Chief Accountant drew attention to a new risk relating to the downgrading of the Co-op Bank. Whilst it now appeared that the bank would remain in existence, it had given notice that it wished to withdraw from local authority funding and would assist if local authorities wished to end their contracts early. The Head of Finance had been exploring the possibility of a joint tender with other authorities. In answer to Members’ questions, the Chief Accountant explained the measures which had been put in place to protect the Council’s financial interests and minimise disruption in the event of the bank collapsing. In answer to a question regarding the recent storm surge, the Chief Accountant considered that the event had reinforced the risks stated and that this matter would be revisited when the register was next updated. It was suggested that RAG ratings be used on the summary register as the colours were lost in monochrome reproduction and, if produced in colour, could be confusing for colour blind people. It was also suggested that a projector be used during the meeting for coloured charts. RESOLVED That the Corporate Risk Register be noted. The meeting ended at 3.37 pm. ______________________ Chairman Audit Committee 5 10 December 2013 9 Agenda Item 6 AUDIT COMMITTEE 10 DECEMBER 2013 – ACTIONS ARISING FROM THE MINUTES 1. Local Code of Corporate Governance and Annual Governance Statement 2012/13 1. Appendix B, section 1.2 possible rewording. Malcolm Fry 2. Possible inclusion of metrics in the appendix to support the evidence. Malcolm Fry 2. Annual Report of the Monitoring Officer 2012/13 Comparison of number of complaints to the Ombudsman in 1012/13 compared to other years to be supplied to Cllr A Moore. Malcolm to check with Karen if these have been actioned. Malcolm Fry Information has now been supplied & copied to Audit Committee members. 3. Pensions Benchmarking To be added to the Work Programme as a matter for review in September. Linda Yarham Has been added to work programme. 4. Annual Audit Letter 1. Use of colour makes the report difficult to read when reproduced – needs to be addressed. Aphrodite Antoniades 2. Indicative certification fee and reasons for increase above estimate, and final figure with reasons for any adjustments, to be supplied. Aphrodite Antoniades Information supplied (13/12/13) re indicative fee and reasons for increase. Confirmation of final fee awaited. 5. Corporate Risk Register Possible use of RAG ratings in summary risk register. Karen Sly/ Malcolm Fry 6. Display of documents at meetings Consideration to be given to the display of coloured charts etc on screen at meetings where appropriate All 10 Agenda Item 7 AUDIT COMMITTEE WORK PROGRAMME 2013 - 2014 JUNE 2013 SEPTEMBER 2013 DECEMBER 2013 MARCH 2014 PWC PWC 2012/13 Annual Governance report (ISA260) Annual Audit Letter (PWC) Audit Plan (PWC) (with overview) Annual Grant Certification Report Half yearly progress reports on the overall performance of the audit contract Quarterly Summaries of completed audits Report on follow-up work Computer Audit Audit Plan Corporate Risk Register Risk Management Framework Protocol for liaison between internal and external auditors Internal Audit Annual Review of the Effectiveness of Internal Audit Annual Report and Opinion Status of agreed actions Undertake selfassessment NNDC Corporate Risk Register/ risk management framework Business Continuity Plan Review Quarterly Summaries of completed audits Internal Audit training Statement of Accounts (+ informal training) Business Continuity Monitoring Officer’s Report Local Code of Corporate Governance and Action Plan – update and Annual Governance Statement 2012/13 – update 11 Agenda Item 7 AUDIT COMMITTEE WORK PROGRAMME 2013 - 2014 JUNE 2014 SEPTEMBER 2014 DECEMBER 2014 MARCH 2015 PWC PWC 2012/13 Annual Governance report (ISA260) Annual Audit Letter (PWC) Audit Plan (PWC) (with overview) Annual Grant Certification Report Half yearly progress reports on the overall performance of the audit contract Quarterly Summaries of completed audits Report on follow-up work Audit Plan Protocol for liaison between internal and external auditors Internal Audit Annual Review of the Effectiveness of Internal Audit Annual Report and Opinion Status of agreed actions Undertake selfassessment NNDC Corporate Risk Register/ risk management framework Business Continuity Plan Review Quarterly Summaries of completed audits Internal Audit training Statement of Accounts (+ informal training) Business Continuity Monitoring Officer’s Report Local Code of Corporate Governance and Action Plan – update and Annual Governance Statement 2012/13 – update Review of Pensions liability 12 Corporate Risk Register Risk Management Framework www.pwc.co.uk Annual Certification Report to those charged with governance 2012/13 Government and Public Sector – Annual Certification Report to those charged with governance North Norfolk District Council February 2014 13 The Members of the Audit Committee Council Offices Holt Road Cromer Norfolk NR27 9EN February 2014 Ladies and Gentlemen Annual Certification Report (2012/13) We are pleased to present our Annual Certification Report which provides members of the Audit Committee with a high level overview of the results of certification work we have undertaken at North Norfolk District Council in 2012/13. We have also summarised our fees for 2012/13 certification work in Appendix A. Results of Certification work For the period ended 31 March 2013 we certified two claims and returns worth a final net total of £58,386,555. Both were amended following certification work and both also required a qualification letter to set out matters arising. We set out further details in the attached report. We identified a number of matters relating to the Council’s arrangements for preparation of claims and returns during the course of our work, some of which were of a minor nature. The most important of these matters have been brought to your attention in this report. We ask the Audit Committee to consider: the adequacy of the proposed management action plan for 2012/13 set out in Appendix B, and; the adequacy of progress made in implementing the prior year action plan in Appendix C. Yours faithfully PricewaterhouseCoopers LLP PricewaterhouseCoopers LLP, 2nd Floor, 3 St James Court, Whitefriars, Norwich, NR3 1RJ T: +44 (0) 1603 615244, F: +44 (0) 1603 631060, www.pwc.co.uk PricewaterhouseCoopers LLP is a limited liability partnership registered in England with registered number OC303525. The registered office of PricewaterhouseCoopers LLP is 1 Embankment Place, London WC2N 6RH. PricewaterhouseCoopers LLP is authorised and regulated by the Financial Services Authority for designated investment business. 14 Table of Contents Introduction 4 Scope of work 4 Statement of Responsibilities of Grant-Paying Bodies, Authorities, the Audit Commission and Appointed Auditors in Relation to Claims and Returns 4 Code of Audit Practice and Statement of Responsibilities of Auditors and of Audited Bodies 4 Results of Certification Work 5 Claims and returns certified 6 Matters arising 6 National Non-Domestic Rates Return 6 Housing and Council Tax Benefits Scheme 2012/13 7 Appendix A 9 Certification Fees 9 Appendix B 10 2012/13 Management Action Plan 10 Appendix C 12 2011/12 Management Action Plan – Progress made 12 Glossary 13 PwC 3 15 Introduction Scope of work Grant-paying bodies pay billions of pounds in subsidies and grants each year to local authorities and often require certification, by an appropriately qualified auditor, of the claims and returns submitted to them. Certification work is not an audit but a different kind of assurance engagement which reaches a conclusion but does not express an opinion. This involves applying prescribed tests, as set out within Certification Instructions (“CIs”) issued to us by the Audit Commission, which are designed to give reasonable assurance that claims and returns are fairly stated and in accordance with specified terms and conditions; where this is not the case matters are raised in a ‘qualification letter’. The Audit Commission is required by law to make certification arrangements for grant-paying bodies when requested to do so and sets thresholds for claim and return certification, as well as the prescribed tests which we as local government appointed auditors must undertake. We certify claims and returns as they arise throughout the year to meet the certified claim/return submission deadlines set by grant-paying bodies. Our role is to act as ‘agents’ of the Audit Commission when undertaking certification work; certification work is not an audit but a different form of assurance engagement, the precise nature of which will vary according to the claim or return; we are required to carry out work and complete the auditor certificate in accordance with the arrangements and requirements set by the Commission. We consider the results of certification work when performing other Code of Audit Practice work at the Authority, including for our conclusions on the financial statements and on value for money. Statement of Responsibilities of Grant-Paying Bodies, Authorities, the Audit Commission and Appointed Auditors in Relation to Claims and Returns In November 2010 the Audit Commission updated the ‘Statement of Responsibilities of Grant-Paying Bodies, Authorities, the Audit Commission and Appointed Auditors in Relation to Claims and Returns’. This is available from the Audit Commission’s website. The purpose of this Statement is to summarise the Audit Commission's framework for making certification arrangements and to assist grant-paying bodies, authorities, and the Audit Commission’s appointed auditors by summarising their respective responsibilities and explaining where their different responsibilities begin and end. Code of Audit Practice and Statement of Responsibilities of Auditors and of Audited Bodies In March 2010 the Audit Commission issued a revised version of the ‘Statement of Responsibilities of Auditors and of Audited Bodies’. It is available from the Chief Executive of each audited body and on the Audit Commission’s website. The purpose of the Statement is to assist auditors and audited bodies by explaining where the responsibilities of auditors begin and end and what is to be expected of the audited body in certain areas. Reports and letters prepared by appointed auditors and addressed to members or officers are prepared for the sole use of the audited body and no responsibility is taken by auditors to any member or officer in their individual capacity or to any third party. PwC 4 16 Results of Certification Work PwC 5 17 Results of Certification Work Claims and returns certified A summary of the claims and returns certified during the year is set out in the table below. In both cases a qualification letter was required to set out matters arising from the certification of the claim/return. Both claims were also amended following the certification work undertaken. All deadlines for submission of certified claims/returns were met. Fee information for the claims and returns is summarised in Appendix A. Claims and returns certified in 2012/13 CI Reference Scheme Title Form Original Value (£) Final Value (£) Amendment Qualification BEN01 Housing and Council Tax Benefits Scheme MPF720A 36,344,709 36,343,959 Yes Yes LA01 National Non Domestic Rates Return NNDR3 22,041,846 22,041,846 Yes Yes Matters arising The most important matters we identified through our certification work are summarised below. National Non-Domestic Rates Return Through our work on this return we identified that the return was signed and sent to DCLG on 12 July 2013. This is after the deadline of 28 June 2013 per the CI and as a result we were required to report this matter to the CLG in our qualification letter. Whilst this matter did not impact our certification of the claim within the required timescale, the Council should ensure that the form is submitted in a timely manner going forward. CI Test 8 requires us to consider whether all Valuation Office (VO) directions received on or before 31 January 2013 have been taken into account. The Council can also take account of directions received after that date. The Council’s original claim disclosed 28 March 2013 as the date the latest information was taken into account when calculating the contribution to the NNDR pool. Our work identified that VO directions up to 27 February 2013 had been taken into account. The claim was updated to reflect this revised date. PwC 6 18 CI Test 4 requires us to confirm that all entries on the return and supporting working papers agree with underlying records. Testing identified some discrepancies between the total amount per the return and Civica (the Council’s NNDR information system) depending on which system report (the financial control account report or another, more detailed report) is used. The financial control account report was used to compile the claim form. We highlighted the discrepancies between the two reports and the return within our qualification letter. Housing and Council Tax Benefits Scheme 2012/13 Our testing identified a number of errors in relation to the Council’s compliance with Housing and Council Tax Benefit regulations. In a number of cases, it was possible to quantify these errors and make appropriate amendments to the claim form. However, we also reported a number of matters to the DWP in a qualification letter where no amendment could be agreed which would be representative of the whole population. In summary, the matters related to: Incorrect earning calculations used (1 case from total sample of 20); Incorrect Child Tax credit calculations used (1 case from total sample of 20); Incorrect useage of non dependent deductions (2 cases from total sample of 20); and Expenditure misclassification (4 cases from total sample of 40). The majority of these error types were also identified in previous years. Extended (“40+”) testing was performed in relation to the above errors, and also upon errors identified within the prior year testing but not noted within the current year testing, as required by CI. The extended testing was performed this year by the Council with a sample of the testing reperformed by us to ensure the quality of the work. This approach is also in accordance with the CI. We are pleased to report that the Council’s testing was of appropriate quality. The extended testing identified further errors as follows: Misclassification of reason for the overpayment of benefits (24 cases from a total sample of 80); and Incorrect assessment of claimant income (27 cases from a total sample of 92). Whilst we recognise the complexity of this particular claim, it is recommended that additional training is instigated for relevant personnel to avoid continuing issues. PwC 7 19 Appendices PwC 8 20 Appendix A Certification Fees The fees for certification of each claim/return are set out below: Claim/Return 2012/13 (£) 2011/12 (£) BEN01 Housing and Council Tax Benefits Scheme 42,627* 56,065 - 2,700 2,600 No CI Part B testing was required to be carried out in 2011/12. This reduced the fee for that particular year. 45,327 58,665 LA01 National Non Domestic Return (NNDR) Total Comment * Included in this fee is an additional fee of £9,327 which has been agreed with Council officers. This fee has arisen as a result of the extended testing we needed to perform in respect of the certification and the additional work required as a result of the Council’s change in the IT system responsible for the processing of housing and council tax benefits during the year. As at 13 February 2014, we are awaiting final Audit Commission approval for this fee, in accordance with the protocol for external audit fees agreed with the Audit Commission. These fees reflect the Council’s current performance and arrangements for certification. It should be noted that the Audit Commission updated the fee approach for certification in 2012/13. This applied a 40% discount to the 2010/11 billed fee and required external auditors to agree fees that were higher than this level with the Audit Commission, as well as the audited body. The Council could improve its performance by: reviewing the final claim / return against supporting working papers to ensure there are no discrepancies; reviewing guidance issued by the grant paying body in relation to the claim / return and completion; and ensuring the adequacy of evidence to support the claim / return entries. We will continue to seek ways in which we can improve the overall level of liaison with senior officers regarding the progress of certification work, time and issues. PwC 9 21 Appendix B 2012/13 Management Action Plan Claim/Return Housing and Council Tax Benefits Subsidy (BEN01) Issue Errors in the assessment of claims were identified including: Expenditure misclassification; Incorrect application of child tax credits; Incorrect application of non dependent deductions; and Incorrect claimant income calculations. Recommendation The Council should consider why the errors identified in our testing occurred on a case-bycase basis and implement corrective measures as appropriate. This may include claim assessor training, further guidance material and increased level of review of applicable case assessments. Management Response It should be noted that 12/13 was the first year following the implementation of the replacement revenues & benefits system and workflow. It was identified that there was some additional training that was necessary for staff to understand some of the new functionality/application of the new system. This has now been delivered in conjunction with overpayment classification training. Claims go through a quality assurance check and training issues are identified and addressed. The Council request that the level of error be considered in light of a total subsidy claim of £36m. PwC 22 Responsibility (implementation date) Louise Wolsey (Revenues & Benefits Manager) Ongoing QA and training National Non Domestic Rates Return (LA01) The Council is required to provide the original signed hard-copy of the return to the auditors for certification by 28 June 2013. This was not received until 12 July 2013. All hard-copy claims and returns should be submitted to the appointed auditor for certification in accordance with the certification instruction. It should be noted that 12/13 was the first year following the implementation of the replacement revenues & benefits system and workflow. The authority considered it appropriate to delay submission (which was notified to DCLG) and return an accurate form rather than an inaccurate form. The new reports and the need to reconcile two systems significantly contributed to the delay. Karen Sly (Head of Financial Services) Louise Wolsey (Revenues & Benefits Manager) We agree claims should be submitted within deadlines. The return did not accurately reflect the last date from which Valuation Office directions were taken into account when calculating the contribution to the NNDR pool. The date of the last VO direction incorporated into the calculation of the NNDR pool contribution should be disclosed within the Return. Agreed Sean Knight (Revenues Manager) Although the return reconciled to the financial control report produced by Civica, the Council’s NNDR system, this report did not match a more detailed report produced by Civica. As a result, we raised this matter in our qualification letter. The discrepancies may have been as a result of the change in IT systems during the financial year. The Council should identify whether the discrepancies between the Civica reports are on-going. If so, the reasons for the differences should be investigated and resolved, in conjunction with Civica, prior to the 2013/14 return compilation, submission and certification process. It should be noted that 12/13 was the first year following the implementation of the replacement revenues & benefits system and workflow. Sean Knight (Revenues Manager) PwC 23 The discrepancies were as a result of the need to reconcile the two systems. Work has been done to fully understand the Civca reports contributing to the return and parameters etc. amended as required. Appendix C 2011/12 Management Action Plan – Progress made Claim/Return Issue Recommendation Management response Responsibility (Implementati on date) All hard-copy claims and returns should be submitted to the appointed auditor for certification in accordance with the certification instructions. This is acknowledged, however due to delays in receiving and implementing software releases this has meant there has been some delay. Revenues and Cleared Benefits Manager (30/04/2013) We recommend that the Authority considers why the errors identified in our testing occurred on a caseby-case basis and implement corrective measures as appropriate. This recommendation has Revenues and Ongoing been noted. Training is onBenefits Manager going for Benefit Assessors (on-going) and it is anticipated that with the implementation of the new software that user error will be reduced. (deadline) Housing and Council Tax Benefits Subsidy (BEN01) Final claims on form MPF720A are to be completed and sent to DWP and to the auditor appointed by the Audit Commission by 30 April 2012. PwC did not receive a hard copy of the claim form; however this did not prevent us from starting our work as agreed. Housing and Errors were identified including: Council Tax Expenditure misclassification; Benefits Subsidy (BEN01) Incorrect application of service charges; Incorrect entry of data into the subsidy form; Data input incorrectly into the calculation of benefit resulting in under / overpayment of benefit; and Insufficient documentation maintained on file to support benefit assessment. PwC 24 Recommendation Status Glossary Audit Commission Definitions for Certification work Abbreviations used in certification work are:‘appointed auditor’ is the auditor appointed by the Audit Commission under section 3 of ‘claims’ includes claims for grant or subsidies and for contractual payments due under agency the Audit Commission Act 1998 to audit an authority’s accounts who, for the purpose of certifying claims and returns under section 28 of the Act, acts as an agent of the Commission. In this capacity, whilst qualified to act as an independent external auditor, the appointed auditor acts as a professional accountant undertaking an assurance engagement governed by the Commission’s certification instruction arrangements; agreements, co-financing schemes or otherwise; ‘assurance engagement’ is an engagement performed by a professional accountant in ‘Commission’ refers to either the Audit Commission or the Grants Team of the Audit Policy which a subject matter that is the responsibility of another party is evaluated or measured against identified suitable criteria, with the objective of expressing a conclusion that provides the intended user with reasonable assurance about that subject matter; and Regulation Directorate of the Commission which is responsible for making certification arrangements and for all liaison with grant-paying bodies and auditors on certification issues; ‘auditor’ is a person carrying out the detailed checking of claims and returns on behalf of the ‘grant-paying bodies’ includes government departments, public authorities, directorates appointed auditor, in accordance with the Commission’s and appointed auditor’s scheme of delegation; and related agencies, requiring authorities to complete claims and returns; ‘authorities’ means all bodies whose auditors are appointed under the Audit Commission ‘returns’ are either: Act 1998, which have requested the certification of claims and returns under section 28(1) of that Act; - returns in respect of grant which do not constitute a claim, for example, statements of expenditure from which the grant-paying body may determine grant entitlement; or returns other than those in respect of grant, which must or may be certified by the appointed auditor, or under arrangements made by the Commission; ‘certification instructions’ (‘CIs’) are written instructions from the Commission to ‘Statement’ is the Statement of responsibilities of grant-paying bodies, authorities, the appointed auditors on the certification of claims and returns; Audit Commission and appointed auditors in relation to claims and returns, available from www.audit-commission.gov.uk; ‘certify’ means the completion of the certificate on a claim or return by the appointed auditor ‘underlying records’ are the accounts, data and other working papers supporting entries in accordance with arrangements made by the Commission; on a claim or return. PwC 25 This document has been prepared for the intended recipients only. To the extent permitted by law, PricewaterhouseCoopers LLP does not accept or assume any liability, responsibility or duty of care for any use of or reliance on this document by anyone, other than (i) the intended recipient to the extent agreed in the relevant contract for the matter to which this document relates (if any), or (ii) as expressly agreed by PricewaterhouseCoopers LLP at its sole discretion in writing in advance. © 2014 PricewaterhouseCoopers LLP. All rights reserved. 'PricewaterhouseCoopers' refers to PricewaterhouseCoopers LLP (a limited liability partnership in the United Kingdom) or, as the context requires, other member firms of PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity. PwC 26 www.pwc.co.uk North Norfolk District Council External Audit Plan 2013/14 Government and Public Sector March 2014 27 Contents Code of Audit Practice and Statement of Responsibilities of Auditors and of Audited Bodies In April 2010 the Audit Commission issued a revised version of the ‘Statement of responsibilities of auditors and of audited bodies’. It is available from the Chief Executive of each audited body. The purpose of the statement is to assist auditors and audited bodies by explaining where the responsibilities of auditors begin and end and what is to be expected of the audited body in certain areas. Our reports and management letters are prepared in the context of this Statement. Reports and letters prepared by appointed auditors and addressed to members or officers are prepared for the sole use of the audited body and no responsibility is taken by auditors to any Member or officer in their individual capacity or to any third party. Executive summary 2 Audit approach 3 Risk of fraud 10 Your PwC team 12 Your audit fees 13 Appendices 14 Appendix A: Independence threats and safeguards 15 Appendix B: Communications Plan 17 Appendix C: Recent developments 18 Appendix D: Audit quality 19 Appendix E: Other engagement information 23 PwC Contents North Norfolk District Council 28 Executive summary Background Our Responsibilities We have prepared this audit plan to provide the Audit Committee of North Norfolk District Council (the ‘Council’) with information about our responsibilities as external auditors and how we plan to discharge them for the audit of the financial year ended 31 March 2014. Our responsibilities are as follows: Framework for our audit Report to the National Audit Office on the accuracy of the consolidation pack the Council is required to prepare for the Whole of Government Accounts. We are appointed as your auditors by the Audit Commission as part of a national framework contract and consequently we are required to incorporate the requirements of the Audit Commission Act 1998 and the Code of Audit Practice 2010 for local government bodies (the ‘Audit Code’) as well as the requirements of International Standards on Auditing (UK & Ireland) (‘ISAs’). The remainder of this document sets out how we will discharge these responsibilities and we welcome any feedback or comments that you may have on our approach. We look forward to discussing our report with you on 17 March. Attending the meeting from PwC will be Julian Rickett and Aphrodite Antoniades. Perform an audit of the accounts in accordance with the Auditing Practice Board’s International Standards on Auditing (ISAs (UK&I)). Form a conclusion on the arrangements the Council has made for securing economy, efficiency and effectiveness in its use of resources. Consider the completeness of disclosures in the Council’s annual governance statement, identify any inconsistencies with the other information of which we are aware from ourwork and consider whether it complies with CIPFA / SOLACE guidance. Consider whether, in the public interest, we should make a report on any matter coming to our notice in the course of the audit. Determine whether any other action should be taken in relation to our other responsibilities under the Audit Commission Act. Issue a certificate that we have completed the audit in accordance with the requirements of the Audit Commission Act 1998 and the Code of Practice issued by the Audit Commission. PwC 2 North Norfolk District Council 29 Our audit engagement begins with an evaluation of the Council on our ‘acceptance & continuance database’ which highlights an overall engagement risk score and highlights areas of heightened risk. Audit approach Our audit is risk based which means that we focus on the areas that matter. We have carried out a risk assessment for 2013/14 prior to considering the impact of controls, as required by auditing standards, which also draws on our understanding of your business. We determine if risks are significant, elevated or normal and whether we are concerned with fraud, error or judgement as this helps to drive the design of our testing procedures: Significant Those risks with the highest potential for material misstatement due to a combination of their size, nature and likelihood and which, in our judgement, require specific audit consideration. Elevated Although not considered significant, the nature of the balance/area requires specific consideration. The table below highlights all risks which we consider to be either significant or elevated in relation to our audit for the year ended 31 March 2014. PwC 3 North Norfolk District Council 30 Main Council Audit Risk Categorisation Audit approach Management override of controls ISA (UK&I) 240 requires that we plan our audit work to consider the risk of fraud, which is presumed to be a significant risk in any audit. In every organisation, management may be in a position to override the routine day to day financial controls. Accordingly, for all of our audits, we consider this risk and adapt our audit procedures accordingly. Significant As part of our assessment of your control environment we will consider those areas where management could use discretion outside of the financial controls in place to misstate the financial statements. We will perform procedures to: - Review the appropriateness of accounting policies and estimation bases, focusing on any changes not driven by amendments to reporting standards; - Test the appropriateness of journal entries and other year-end adjustments, targeting higher risk items such as those that affect the reported deficit/surplus; - Review accounting estimates for bias and evaluate whether judgment and estimates used are reasonable (for example pension scheme assumptions, valuation and impairment assumptions); - Evaluate the business rationale underlying significant transactions outside the normal course of business; and - Perform unpredictable procedures targeted on fraud risks. We may perform other audit procedures if necessary. Risk of fraud in revenue and expenditure recognition Under ISA (UK&I) 240 there is a presumption that there are risks of fraud in revenue recognition. Significant We will obtain an understanding of revenue and expenditure controls. We will evaluate and test the accounting policy for income and expenditure recognition to ensure that this is consistent with the requirements of the Code of Practice on Local Authority Accounting. We extend this presumption to the recognition of expenditure in local government. We will also perform detailed testing of revenue and expenditure transactions, focussing on the areas we consider to be of greatest risk. PwC 4 North Norfolk District Council 31 Risk Categorisation Audit approach Valuation: Property, Plant and Equipment Elevated Property, plant and equipment (PPE) represents the largest balance in the Council’s balance sheet. The Council measures its properties at fair value involving a range of assumptions and the use of external valuation expertise. ISAs (UK&I) 500 and 540 require us, respectively, to undertake certain procedures on the use of external expert valuers and processes and assumptions underlying fair value estimates. Property, Plant and Equipment is the largest figure on your Balance Sheet. Economic conditions continue to be uncertain, which has a potential impact upon the valuation of your property, plant and equipment. The Authority is required to assess the fair value of all of its assets every year. Specific areas of risk include: The accuracy and completeness of detailed information on assets. Whether the Council’s assumptions underlying the classification of properties are appropriate. Whether properties that are not programmed to be revalued in the year might have undergone material changes in their fair value. The valuer’s methodology, assumptions and underlying data, and our access to these. Where asset valuations are undertaken in-year we will: agree the source data used by your valuer to supporting records. assess the work of your Valuer through use of our own internal specialists where required; and agree the outputs to your Fixed Asset Register and accounts. Where any changes to valuation bases are proposed we will work with you to understand and evaluate the rationale you are using on a timely basis. Where assets are not re-valued in year, we will review your impairment assessment and evaluation as to whether your assets are held at an appropriate value in your accounts at the year-end. PwC 5 North Norfolk District Council 32 Risk Categorisation Savings Requirements including localisation of business rates and council tax benefit The Council continues to need to achieve significant savings to meet its medium term financial plan, following a reduction in central government funding. Elevated Audit approach We will review your savings plan, understand how the Council manages the plan, and the reasons behind any significant variations from the plan. We will specifically consider: your record in delivering savings; the governance structure in place to deliver the targets (including extent of member involvement); the level and extent of accountability; monitoring and reporting; and progress on delivering the plan. We will consider the accounting implications of your savings plans and would welcome early discussion of any new and unusual proposals. In particular, we will consider the impact of the efficiency challenge on the recognition of both income and expenditure. PwC 6 North Norfolk District Council 33 Overall Materiality (prior year): £1,241,000 Intelligent scoping Materiality Triviality (prior year): £50,000 £ Overall materiality 1,241,000 Clearly trivial reporting de minimis 50,000 We set overall materiality to assist our planning of the overall audit strategy and to assess the impact of any adjustments identified. Overall materiality has been set at 2% of prior year expenditure for the year ended 31 March 2013. We will update this assessment as necessary in light of the Council’s actual results for the year ending 31 March 2014. ISA (UK&I) 450 (revised) requires that we record all misstatements identified except those which are “clearly trivial” i.e. those which we do expect not to have a material effect on the financial statements even if accumulated. We would like to seek the Audit Committee’s views on this de minimis threshold. PwC 7 North Norfolk District Council 34 Robust Testing The Audit Commission guidance includes two criteria: Where we do our work As previously mentioned our audit is risk based which means we focus our work on those areas which, in our judgement, are most likely to lead to a material misstatement. In summary, we will: Consider the key risks arising from internal developments and external factors such as policy, regulatory or accounting changes; Consider the robustness of the control environment, including the governance structure, the operating environment, the information systems and processes and the financial reporting procedures in operation; Understand the control activities operating over key financial cycles which affect the production of the yearend financial statements; Validate key controls relevant to the audit approach; and Perform substantive testing on transactions and balances as required. When we do our work Our audit is designed to quickly consider and evaluate the impact of issues arising to ensure that we deliver a no surprises audit at year-end. This involves early testing at an interim stage and open and timely communication with management to ensure that we meet all statutory reporting deadlines. We engage early, enabling us to debate issues with you. We have summarised our formal communications plan in Appendix B. Value for Money Work Our value for money code responsibility requires us to carry out sufficient and relevant work in order to conclude on whether the Council has put in place proper arrangements to secure economy, efficiency and effectiveness in the use of resources. The organisation has proper arrangements in place for securing financial resilience; and The organisation has proper arrangements for challenging how it secures economy, efficiency and effectiveness. We determine a local programme of audit work based on our audit risk assessment, informed by these criteria and our statutory responsibilities. Annual Governance Statement Local Authorities are required to produce an Annual Governance Statement (AGS), which is consistent with guidance issued by CIPFA / SOLACE: “Delivering Good Governance in Local Government”. The AGS is required to be presented by the Council with the Statement of Accounts. We will review the AGS to consider whether it complies with the CIPFA / SOLACE “Delivering Good Governance in Local Government” framework and whether it is misleading or inconsistent with other information known to us from our audit work. Whole of Government Accounts We are required to examine the Whole of Government Accounts schedules submitted to the Department for Communities and Local Government and issue an opinion stating in our view if they are consistent or inconsistent with the Statement of Accounts. Meaningful conclusions We believe fundamentally in the value of the audit and that audits need to be designed to be valuable to our clients to properly fulfil our role as auditors. PwC 8 North Norfolk District Council 35 In designing the Council’s audit, our primary objective is to form an independent audit opinion on the financial statements; however, we also aim to provide insight. out some recent developments in Appendix C and we will provide other insights and observations to you in our audit reports throughout the year. Audit value comes from the same source as audit quality so the work that we do in support of our audit opinion also means that we should be giving you value through our observations, recommendations and insights. We have set We have also developed a Local Government Centre of Excellence which supports your audit team in all aspects of the audit, including sharing insight and observations gained from audit teams across the country. PwC 9 North Norfolk District Council 36 As part of the audit engagement, per ISA 240, we are required to consider the risk of fraud throughout the audit and to communicate with management and those charged with governance. Risk of fraud International Standards on Auditing (UK&I) state that we, as auditors, are responsible for obtaining reasonable assurance that the financial statements taken as a whole are free from material misstatement, whether caused by fraud or error. The respective responsibilities of auditors, management and those charged with governance are summarised below: Auditors’ responsibility Management’s responsibility Responsibility of the Audit Committee Our objectives are: Management’s responsibilities in relation to fraud are: Your responsibility as part of your governance role is: To identify and assess the risks of material misstatement of the financial statements due to fraud; To obtain sufficient appropriate audit evidence regarding the assessed risks of material misstatement due to fraud, through designing and implementing appropriate responses; and To respond appropriately to fraud or suspected fraud identified during the audit. To design and implement programmes and controls to prevent, deter and detect fraud; To ensure that the entity’s culture and environment promote ethical behaviour; and To perform a risk assessment that specifically includes the risk of fraud addressing incentives and pressures, opportunities, and attitudes and rationalisation. To evaluate management’s identification of fraud risk, implementation of anti-fraud measures and creation of appropriate ‘tone at the top’; and To ensure any alleged or suspected instances of fraud brought to your attention are investigated appropriately. PwC 10 North Norfolk District Council 37 Conditions under which fraud may occur Your views on fraud We enquire of the Audit Committee: Whether you have knowledge of fraud, either actual, suspected or alleged, including those involving management? What fraud detection or prevention measures (e.g. whistleblower lines) are in place in the entity? What role you have in relation to fraud? What protocols / procedures have been established between those charged with governance and management to keep you informed of instances of fraud, either actual, suspected or alleged? PwC 11 North Norfolk District Council 38 The engagement team has been drawn from our government and public sector team based on the South East. Your PwC team The individuals in your PwC team have been selected to bring you extensive audit experience from working with Local Authorities, the wider public sector and the commercial sector. We also recognise that continuity in the audit team is important to you and the senior members of our team are committed to developing longer term relationships with you. The core members of your audit team are: Audit Team Responsibilities Engagement Leader Engagement Leader responsible for independently delivering the audit in line with the Audit Code (including agreeing the Audit Plan, ISA 260 Report to Those Charged with Governance and the Annual Audit Letter), quality of outputs and signing of opinions and conclusions. Also responsible for liaison with the Chief Executive and the Members. Julian Rickett 01603 883321 Engagement Manager Aphrodite Antoniades 01603 883170 Team Leader Louise Shaw 01603 883039 Responsible for leading the field team, including the audit of the statement of accounts, and governance aspects of our work. Regular liaison with the finance team. Manager on the assignment responsible for overall control of the audit engagement, ensuring delivery to timetable, delivery and management of targeted work and overall review of audit outputs. Completion of the Audit Plan, ISA 260 Report and Annual Audit Letter. PwC 12 North Norfolk District Council 39 Fees for the engagement are set out in line with the indicative scale fees set by the Audit Commission. Your audit fees The Audit Commission has provided indicative scale fees for Local Authorities for the year ended 31 March 2014. No changes to the work programme have been proposed therefore scale audit fees for have been set at the same level as the fees applicable for 2012/13. Our indicative audit fee, as agreed in our audit fee letter dated 09 April 2013, compared to the actual fee for 2012/13 is as follows: Audit fee Actual fee 2011/12 Actual fee 2012/13 Indicative fee 2013/14 £ £ £ Audit work performed under the Code of Audit Practice 118,750 74,350* 71,250 Certification of Claims and Returns 59,040 45,327** 33,600 Total Audit Code work 177,415 119,677 104,850 0 0 0 177,415 119,677 104,850 - Whole of Government Accounts Planned non-audit work Total fees - Statement of Accounts - Conclusion on the ability of the organisation to secure proper arrangements for the economy, efficiency and effectiveness in its use of resources We have based the fee level on the following assumptions: * An additional £3,100 is included within the fee as was approved by the Audit Commission for additional IT work on Revenues and Benefits. ** Included in the Certification fee is an additional fee of £9,327 which has been agreed with Council officers. This fee has arisen as a result of the extended testing we needed to perform in respect of the housing and council tax benefits claim. We are currently waiting for Audit Commission approval for this. Officers meeting the timetable of deliverables, which we will agree in writing; We are able to use, as planned, the work of internal audit; We do not review more than 3 iterations of the statement of accounts; We are able to obtain assurance from your management controls; No significant changes being made by the Audit Commission to the local value for money work requirements; and Our value for money conclusion and accounts opinion being unqualified. If these prove to be unfounded, we will seek a variation order to the agreed fee, to be discussed and agreed in advance with you and the Audit Commission. We anticipate that the Audit Commission will reduce the certification arrangements for the Housing and Council Tax Benefit Grant Claim to reflect the fact that arrangements for Council Tax Benefits have been localised in 2013/14. We also anticipate that the LA01 (National Non Domestic Rates) claim will no longer require certification given the localisation of Business Rates. We therefore expect that we will need to obtain audit comfort over Council Tax Benefit expenditure and Business Rates income in the statement of accounts from additional audit procedures over these items. We anticipate this will increase the proposed fee however we will update the Audit Committee regarding the impact of this on our audit fee for the Statement of Accounts once we have understood and considered the impact on our work. PwC 13 North Norfolk District Council 40 Appendices PwC 14 North Norfolk District Council 41 We have assessed the independence of our team and found no issues. Appendix A: Independence threats and safeguards At the beginning of our audit process we are required to assess our independence as your external auditor. We have made enquiries of all PwC teams providing services to you and of those responsible in the UK Firm for compliance matters and there are no matters which we perceive may impact our independence and objectivity of the audit team. Other services Support provided by PwC Value Certification of claims and returns Threats to independence and safeguards in place Self Review Threat: The audit team will conduct the grant certification and this has arisen due to our appointment as external auditors. There is no self review threat as we are certifying management completed grant returns and claims. Self Interest Threat: As a firm, we have no financial or other interest in the results of the Council. We have concluded that this work does not pose a self interest threat. Management Threat: PwC is not required to take any decisions on behalf of management as part of this work. Advocacy Threat: We will not be acting for, or alongside, management and we have therefore concluded that this work does not pose an advocacy threat. Familiarity Threat: Work complements our external audit appointment and does not present a familiarity threat. Intimidation Threat: We have concluded that this work does not pose an intimidation threat as all officers and members have conducted themselves with utmost integrity and professionalism PwC 15 North Norfolk District Council 42 Relationships and Investments Senior officers should not seek or receive personal financial or tax advice from PwC. Non-executives who receive such advice from us (perhaps in connection with employment by a client of the firm) or who also act as director for another audit or advisory client of the firm should notify us, so that we can put appropriate conflict management arrangements in place. Therefore at the date of this plan we confirm that in our professional judgement, we are independent accountants with respect to the Council, within the meaning of UK regulatory and professional requirements and that the objectivity of the audit team is not impaired. PwC 16 North Norfolk District Council 43 Appendix B: Communications Plan Planning (February) Discussion of business risks with key management and plan detailed audit approach Detailed planning meetings with Finance, HR and IT. Audit strategy and timetable agreed with management Presentation of the audit strategy to those charged with governance Interim (April) Update understanding of key processes and controls Key accounting and audit findings/significant deficiencies in internal control identified, discussed and resolved Early substantive testing Update our planning work Audit Cycle Completion (August/September) Management letter to the Audit Committee including report on significant deficiencies in internal control. Statutory audit opinions Representation Letter Annual Audit Letter Year end audit (July/August) Detailed audit testing • Review of financial statements Clearance meetings with management Continuous Communication • Continuous proactive discussion of issues as and when they arise; ‘no surprises’ • Continuous evaluation and improvement of the audit • Bringing you experience of sector and best practice PwC 17 North Norfolk District Council 44 Appendix C: Recent developments strategic ambition and purpose and serve to influence decisions and behaviour within the organisation. The Future of Government The Local State We’re In Delivering on the Citizen Promise In the face of recurrent budget cuts to reduce fiscal deficits in many countries, affordable government has become the watchword. This means doing more for less – meeting rising citizens’ expectations by doing things differently to deliver services more effectively and efficiently. Where Next for public services? Public sector organisations need to re-evaluate their purpose and role and decide if current visions and missions, and ways of operating to achieve them, are relevant enough to ride the waves of these shifts, or be overwhelmed by them. Government and public sector organisations will also need to respond to these shifts proactively and pre-emptively, to avoid falling one or more steps behind. What guides and shapes the future public body? As such, tomorrow’s public bodies need to navigate themselves by first formulating a strong and clear vision and mission. Together, these will capture the organisation’s Over the past few years, local government has demonstrated its ability to deliver ambitious and far reaching savings programmes. While council Chief Executives are still holding on to their confidence in meeting savings targets for 2013/14, our third annual local government survey shows that confidence in being able to protect services as well has fallen by 40% over the past year. Beyond 2013/14, confidence in meeting savings targets falls further. Tough choices are ahead as the cracks begin to show and decisions get closer to the frontline. Councils need to act urgently to transform themselves into agile organisations and shape a role for themselves through a future of continued austerity. PwC 18 North Norfolk District Council 45 Appendix D: Audit quality Quality is built into every aspect of the way that we deliver the Council’s audit. We take great pride in being your auditors and in the value of assurance that the audit opinion provides. A timely, independent and rigorous audit is fundamental. This in turn necessitates getting the basics right – clarity on audit risks, scope, resource, timetables, deliverables and areas of judgement – which is supported by our team that has extensive experience and relevant training. The table below sets out some of the key ways in which we ensure we deliver a high quality audit. Procedure Description People Quality begins with our people. To ensure that every engagement team provides quality, we use carefully designed protocols for recruiting, training, promoting, assigning responsibility and managing and overseeing the work of our people. We invest significant amounts of time and money for the training and development of our audit professionals. Every new team member is carefully selected to ensure they have the right blend of technical expertise and industry experience to support the Council’s audit. Client acceptance and retention Our client acceptance and retention standards and procedures are designed to identify risks of a client or prospective client to determine whether the risks are manageable. Audit methodology The same audit methodology is used for all Local Authority audit engagements, thereby ensuring uniformity and consistency in approach. Compliance with this methodology is regularly reviewed and evaluated. Comprehensive policies and procedures governing our accounting and auditing practice – covering professional and regulatory standards as well as implementation issues – are constantly updated for new professional developments and emerging issues, needs and concerns of the practice. Technical consultation Consultations by engagement teams, typically with senior technical partners unaffiliated with the audit engagement, are required in particular circumstances involving auditing, accounting or reporting matters including matters such as going concern and clinical quality issues. In addition, we regularly consult with our industry specialists in the Local Government Centre of Excellence and our accounting technical experts that sit on the Audit Commission Auditors’ Group. PwC 19 North Norfolk District Council 46 Procedure Description Technical updates PwC prepares numerous publications to keep both PwC staff and our clients abreast of the latest technical guidance. These include: A weekly publication covering the week’s accounting and business developments; A periodic publication providing in-depth analysis of significant accounting developments; and A publication issued shortly after meetings of standard setters, including IFRIC and the EITF, to provide timely feedback on issues discussed at the meeting. We also provide Local Government specific technical updates through regular publications issued by our Local Government Centre of Excellence and weekly conference calls for all Local Authority engagement teams during the final audit period. We will share our technical updates with you throughout the year. Independence standards PwC has policies and systems designed to comply with relevant independence and client retention standards. Before a piece of non-audit work can begin for the Council, it must first be authorised by the engagement leader who evaluates the project against our own internal policies and safeguards and against your policy on non-audit services. Above a certain fee threshold, we then seek approval from the Audit Commission before proceeding with any work. Ethics Our Ethics and Business Conduct Programme includes confidential communication channels to voice questions and concerns 24 hours a day, seven days a week. Confidentiality helps us to ensure that we receive the candid information and that we respond with the appropriate technical and risk management resources. Independent review Our audits are subject to ongoing review and evaluation by review teams within PwC and also by the Audit Quality Review Team (AQRT, formerly the Audit Inspection Unit). The most recent report on PwC was issued in May 2013 and although there are some areas for development identified the general theme was that audit quality has continued to improve. The firm has developed action plans for all areas for development identified by the AQRT. As auditors appointed by the Audit Commission we are also required to comply with their annual Regulatory Compliance and Quality Review programme. The results for our 2012/13 audits are expected in early 2014 and will be publicly available on the Audit Commission’s website should you wish to take a look. PwC 20 North Norfolk District Council 47 Smart People We deploy quality people on your audit, supported by a substantial investment in training and in our industry programme. The members of staff deployed on your audit have been primarily taken from our dedicated Government and Public Sector team. These staff members have a wide and deep knowledge both of the Council and the local government sector. Key members of the audit team including the engagement leader and engagement manager have been involved in the audit of the Council for a number of years. This ensures continuity which is beneficial both for our people and your audit through ensuring that accumulated knowledge remains within the audit team, improving the quality of the audit we deliver. We use dedicated IT specialists on the audit and will share their insight and experience of best practices with you. Smart Approach Data auditing We use technology-enabled audit techniques to drive quality, efficiency and insight. In 2013/2014 we anticipate the work will include: Testing manual journals using data analytics, ensuring we consider the complete population of manual journals and target our detailed testing on the items with the highest inherent risk. The production of a journals ‘insight report’ which shows the comparable use of journals across the organisation and explores some of the root causes. We use the data gathered as part of our journals testing to share our findings and observations with management. Centre of Excellence We have a Centre of Excellence in the UK for Local Government which is a dedicated team of specialists which advises, assists and shares best practice with our audit teams in more complex areas of the audit. Our team has been working side by side with the Centre of Excellence to ensure we are executing the best possible audit approach. Delivery centres We use dedicated delivery centres to deliver parts of our audit work that are routine and can be done by teams dedicated to specific tasks; for example these include confirmation procedures, preliminary independence checks and consistency and casting checks of the financial statements. The use of our delivery centres frees up your audit team to focus on other areas of the audit. PwC 21 North Norfolk District Council 48 We have agreed a process with the Audit Commission, under which data can be off-shored to PwC Service delivery Centres in India and Poland for the facilitation of basic audit tasks, as highlighted earlier. We have also agreed with the Audit Commission how this will be regulated, together with their independent review of our internal processes to ensure compliance, with the Audit Commission requirements for off-shoring. Further information is included in Appendix E. Smart Technology We have designed processes that automate and simplify audit activity wherever possible. Central to this is PwC’s Aura software, which has set the standard for audit technology. It is a powerful tool, enabling us to direct and oversee audit activities. Aura’s risk-based approach and workflow technology results in a higher quality, more effective audit and the tailored testing libraries allow us to build standard work programmes for key Council audit cycles. Smart people Smart approach Smart technology The PwC Audit Our ‘smart’ approach underpins your audit PwC 22 North Norfolk District Council 49 Appendix E: Other engagement information The Audit Commission appoint us as auditors to North Norfolk District Council and the terms of our appointment are governed by: The Code of Audit Practice; and The Standing Guidance for Auditors. There are five further matters which are not currently included within the guidance, but which our firm’s practice requires that we raise with you. Electronic communication During the engagement we may from time to time communicate electronically with each other. However, the electronic transmission of information cannot be guaranteed to be secure, virus or error free and such information could be intercepted, corrupted, lost, destroyed, arrive late or incomplete or otherwise be adversely affected or unsafe to use. PwC partners and staff may also need to access PwC electronic information and resources during the engagement. You agree that there are benefits to each of us in their being able to access the PwC network via your internet connection and that they may do this by connecting their PwC laptop computers to your network. We each understand that there are risks to each of us associated with such access, including in relation to security and the transmission of viruses. We each recognise that systems and procedures cannot be a guarantee that transmissions, our respective networks and the devices connected to these networks will be unaffected by risks such as those identified in the previous two paragraphs. We each agree to accept the risks of and authorise (a) electronic communications between us and (b) the use of your network and internet connection as set out above. We each agree to use commercially reasonable procedures (i) to check for the then most commonly known viruses before either of us sends information electronically or we connect to your network and (ii) to prevent unauthorised access to each other’s systems. We shall each be responsible for protecting our own systems and interests and you and PwC (in each case including our respective directors, members, partners, employees, agents or servants) shall have no liability to each other on any basis, whether in contract, tort (including negligence) or otherwise, in respect of any error, damage, loss or omission arising from or in connection with the electronic communication of information between us and our reliance on such information or our use of your network and internet connection. The exclusion of liability in the previous paragraph shall not apply to the extent that such liability cannot by law be excluded. PwC 23 North Norfolk District Council 50 Access to audit working papers We may be required to give access to our audit working papers to the Audit Commission or the National Audit Office for quality assurance purposes. Overseas processing of information Recently, as with other firms, we have agreed a process with the Audit Commission, under which data can be off-shored to PwC Service Delivery Centres in Germany and Poland for the facilitation of basic audit tasks. Please refer to the letter at the end of this Appendix for further information on the types of tasks we may off-shore. We confirm that: When work is off-shored the firm delivering the audit remains entirely responsible for the conduct of the audit. As such the data will be subject to similar data quality control procedures as if the work had not been off-shored, maintaining the security of your data. All firms within the PricewaterhouseCoopers network, including the PwC Service Delivery Centres, have signed an intra-group data protection agreement which includes data protection obligations equivalent to those set out in the EU model contract for the transfer of personal data to data processors outside of the European Economic Area. We shall comply at all times with the seventh principle in Part 1 of Schedule 1 to the Data Protection Act 1998. Your audit team members will remain your key audit contacts, you will not need to communicate with our overseas delivery teams. The audit team members are responsible for reviewing all of the work performed by the overseas delivery teams. We already successfully use a UK based delivery centre for financial statements quality checks and that this service will remain in the UK. If you have any questions regarding this process or if you require further information then please contact Aphrodite Antoniades. Quality arrangements We want to provide you at all times with a high quality service to meet your needs. If at any time you would like to discuss with us how our service could be improved or if you are dissatisfied with any aspect of our services, please raise the matter immediately with the partner responsible for that aspect of our services to you. If, for any reason, you would prefer to discuss these matters with someone other than that partner, please contact Richard Bacon, our Government & Public Sector Assurance Lead Partner at our office at Cornwall Court, Birmingham, B3 2DT, or James Chalmers, UK Head of Assurance, at our office at 1 Embankment Place, London, WC2N 6NN. In this way we can ensure that your concerns are dealt with carefully and promptly. We undertake to look into any complaint carefully and promptly and to do all we can to explain the position to PwC 24 North Norfolk District Council 51 you. This will not affect your right to complain to the Institute of Chartered Accountants in England and Wales or to the Audit Commission. Events arising between signature of accounts and their publication ISA (UK&I) 560 places a number of requirements on us in the event of material events arising between the signing of the accounts and their publication. You need to inform us of any such matters that arise so we can fulfil our responsibilities. If you have any queries on the above, please let us know before approving the Audit Plan or, if arising subsequently, at any point during the year. PwC 25 North Norfolk District Council 52 Private & Confidential Members of the Audit Committee North Norfolk District Council Council Offices Holt Road Cromer Norfolk NR27 9EN England March 2014 Ladies and Gentlemen, Working more efficiently As you know the Audit Commission recently tendered the audit work previously delivered by the District Audit service. This realised significant savings which have been passed on to your organisation in a reduction to your scale fee of around 40%. As a result of this tender, suppliers have sought for opportunities to increase efficiency, whilst maintaining the level of quality. One principle which has recently been established is that certain basic parts of the audit can be off-shored. This is common practice in the private sector. When work is off-shored the firm delivering the audit and thus your audit team, remains entirely responsible for the conduct of the audit. As such the data would be subject to similar data quality control procedures as if the work had not been off-shored, maintaining the security of your data. Examples of the work that can be off-shored are: Request for confirmations (Receivables, Bank or Payables); Verification/vouching of information to source documentation (e.g. agreeing a payable balance to invoice); Financial statements review; Mathematical accuracy checks of data; Research; and Preparation of lead schedules. PwC 26 North Norfolk District Council 53 Recently, as with other firms, we have agreed a process with the Audit Commission, under which data can be off-shored to PwC Service delivery Centres in Germany and Poland for the facilitation of basic audit tasks, as highlighted above. We have agreed with the Audit Commission how this will be regulated, together with their independent review of our internal processes to ensure compliance, with the Audit Commission requirements for off-shoring. If you have any questions regarding the above, please do not hesitate to get in touch. Yours sincerely Julian Rickett Engagement Leader PwC 27 North Norfolk District Council 54 In the event that, pursuant to a request which North Norfolk District Council has received under the Freedom of Information Act 2000, it is required to disclose any information contained in this report, it will notify PwC promptly and consult with PwC prior to disclosing such report. North Norfolk District Council agrees to pay due regard to any representations which PwC may make in connection with such disclosure and North Norfolk District Council shall apply any relevant exemptions which may exist under the Act to such report. If, following consultation with PwC, North Norfolk District Council discloses this report or any part thereof, it shall ensure that any disclaimer which PwC has included or may subsequently wish to include in the information is reproduced in full in any copies disclosed. This document has been prepared only for North Norfolk District Council and solely for the purpose and on the terms agreed through our contract with the Audit Commission. We accept no liability (including for negligence) to anyone else in connection with this document, and it may not be provided to anyone else. © 2014 PricewaterhouseCoopers LLP. All rights reserved. In this document, "PwC" refers to the UK member firm, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details. 130610-142627-JA-UK 55 Audit Committee 17 March 2014 Agenda Item No______10_______ Internal Audit’s Charter, Code of Ethics, Audit Strategy, Strategic and Annual Audit Plans, Summary of Internal Audit Coverage and Performance Indicators for 2014/15 Summary: This report provides an overview of the stages followed prior to the formulation of the Strategic Audit Plan for 2014/15 to 2016/17 and the Annual Audit Plan for 2014/15. The Annual Audit Plan will then serve as the work programme for the Council’s Internal Audit Services Contractor, Mazars Public Sector Internal Audit Ltd, and provide the basis upon which the Internal Audit Consortium Manager will subsequently give Audit Opinions on North Norfolk Council’s system of internal control and risk management, and corporate governance arrangements for 2014/15. Members’ attention is also drawn to the fact that this is the first time that an Audit Charter has been presented. Previously, Terms of Reference had been submitted annually, but now, in accordance with Public Sector Internal Audit Standards, which came into effect from 1 April 2013, it has been necessary to develop an Audit Charter to reflect how the Internal Audit Service will operate in accordance with updated mandatory standards. The foundations of the Public Sector Internal Audit Standards however are not so fundamentally different to those requirements formerly specified in the CIPFA Code of Practice for Internal Audit, although the structure of the Charter must follow a prescribed format which defines the purpose, authority and responsibility of the Internal Audit activity, and clear definitions need to be given of those governance elements fulfilling responsibilities of the ‘board’ and ‘senior management’. Conclusions: Recommendations: In reviewing and approving the Audit Charter and related strategic and operational audit planning information, the Audit Committee is making appropriate provisions to ensure that the Internal Audit requirements as stated in the Local Government Finance Act 1982, c.32 and the Accounts and Audit Regulations 2011 are being properly met, and due support is being given to securing an Internal Audit Service, which is compliant with statutory internal auditing standards applicable to public sector organisations. The Committee is requested to approve: Internal Audit’s Charter for 2014/15; 56 Audit Committee 17 March 2014 Internal Audit’s Code of Ethics for 2014/15; Internal Audit’s Strategy for 2014/15; The Strategic Audit Plan for 2014/15 to 2016/17; The Annual Audit Plan for 2014/15; The Summary of Internal Audit Coverage for 2014/15; and, Performance Indicators for 2014/15. Cabinet member(s): Wards: Contact Officer, telephone number, and e-mail: All All Emma Hodds, Deputy Audit Manager 01508 533791 ehodds@s-norfolk.gov.uk 1. BACKGROUND 1.1 In accordance with legislative, regulatory and best practice requirements, North Norfolk Council has made arrangements for a continuous internal audit to examine the accounting, financial and other operations of the organisation. This is effectively achieved through contractual and group agreement arrangements, which exist between North Norfolk Council and South Norfolk Council, whereby the Internal Audit Consortium Manager, based at South Norfolk Council, has developed on behalf of North Norfolk Council, an Audit Charter and overarching Strategy which explain the methodology that has been applied when determining future audit coverage of the organisation’s business operations. 1.2 A number of other key supporting papers have also been developed to ensure clarity regarding the Code of Ethics that will be adopted by the Internal Auditors, together with the Performance Indicators to be used to monitor service delivery. In conjunction with these documents, an insight into future audit input envisaged over the next 3 years has been provided via a new Strategic Audit Plan for 2014/15 onwards, alongside a more detailed analysis of audit assignments being lined up for the next financial year. The sequencing of the latter is encapsulated in the Annual Audit Plan for 2014/15 and a Summary of Internal Audit Coverage has also been compiled, which explains where audit focus will be directed. 2. INTERNAL AUDIT’S AUDIT CHARTER, 2014/15 2.1 The Public Sector Internal Audit Standards have been primarily introduced to: Define the nature of internal auditing; Set basic principles for carrying out internal audit; Establish a framework for providing internal audit services, which add value to the organisation, leading to improved organisational processes and operations. Establish the basis for the evaluation of internal audit performance and to drive improvement planning. 2.2 As part of evidencing that these requirements are being adhered to, there is a duty on the Internal Audit Service to construct an Audit Charter which demonstrates how these elements are being handled and managed. The Internal Audit Consortium Manager for North Norfolk Council has therefore 57 Audit Committee 17 March 2014 compiled a Charter which covers off the above requirements, acknowledging too that some additional appendices have been needed to give further clarity on important issues such as the Code of Ethics and the Performance Indicators adopted by the Internal Audit function. 2.3 In migrating from previously maintained Terms of Reference (which were last reviewed by the Audit Committee in March 2013) to the establishment of an Audit Charter that fully complies with the mandatory standards, it has been necessary to: Apply a revised definition of internal auditing. Under previous Code of Practice arrangements, the emphasis had been on Internal Audit as an assurance function, whereas now there is recognition that the function should be operating on two levels, providing assurance and also giving advice and guidance on governance and control, in a consulting capacity. Utilise the Audit Charter to establish the purpose, authority and responsibilities of the Service provision, its rights of access and the scope of its activities. Develop information explaining Quality Assurance and Improvement processes that will be followed, which contains commentary on how both internal and external assessments will be addressed going forward. Recognise and define the terms ‘board’ and ‘senior management’ for the purposes of Internal Audit activity and acknowledge the role of the Chief Audit Executive. The interpretation of these important governance roles at North Norfolk Council has therefore been examined at Section 4 of the Charter in the section covering Organisation and Relationships. 2.4 Finally, there is an obligation under the mandatory standards to review and represent the Audit Charter in much the same way that previous Terms of Reference had to be revisited annually. The Charter has to be re-evaluated by the Internal Audit Consortium Manager to confirm its ongoing validity and completeness, and thereafter, the documentation requires the scrutiny and endorsement of senior management and the Audit Committee. 2.5 The Audit Charter can be found attached at Appendix 1 and is sub-divided into 10 Sections, which dovetail with key elements of the Public Sector Internal Audit Standards, whilst the Performance Indicators by which service delivery will be measured are included at Appendix 8. 3. INTERNAL AUDIT’S CODE OF ETHICS, 2014/15 3.1 An addendum to the Audit Charter headed up ‘Internal Audit - The Code of Ethics for 2014/15’ sets out the expected behaviours of Internal Audit staff in relation to service delivery and is located at Appendix 2. The basis of standards of conduct for 2014/15 remain unchanged with reference to those followed by Internal Audit in 2013/14, as the Code of Ethics developed for the current financial year was written such that it completely mirrored the obligations under the new Public Sector Internal Audit Standards. It has, however, been necessary to make one small amendment to Section 6 of the Code of Ethics for 2014/15, to mark the changeover from the Deloitte auditors to the Mazars auditors, the latter now being engaged to deliver the Annual Audit Plan for North Norfolk Council. It is to be noted that the nature of the Internal Audit Services contractor’s role has been fully documented in several sections of the Audit Charter. 58 Audit Committee 17 March 2014 3.2 Aside from the Code of Ethics, the Internal Audit Consortium Manager in the role of the Chief Audit Executive will also be cognisant of and comply with requirements laid down in CIPFA’s Statement on the Role of the Head of Internal Audit, and it is further acknowledged that all Internal Audit staff will operate in accordance with their own professional bodies’ Code of Ethics, as well as any organisational Codes of Ethics or Conduct relating to their employer or the client authority served. 4. INTERNAL AUDIT STRATEGY, 2014/15 4.1 The Internal Audit Strategy (see Appendix 3) is another document that sits alongside the Audit Charter, but with the overarching purpose of establishing how the annual programme of audit assignments has been devised, in terms of the stages followed when undertaking the annual audit needs assessment, the risk factors applied and how this information is then used to populate the Strategic and Annual Audit Plans. 4.2 Having completed the annual audit needs assessment and extracted draft strategic and annual planning proposals, these were then discussed with the Head of Finance (in their role of Section 151 Officer) on 5 February 2014, with all Heads of Service on the same date, and finally with Corporate Leadership Team on 11 February 2014. The outcome of this rigorous, 3-tier consultation process was management’s significant contribution to shaping future audit coverage and providing assistance with developing the timetable for the delivery of audit projects during 2014/15, ensuring that the timing would enable audit work to add value, wherever possible. In the course of liaison with management, it was further confirmed that it was no longer viable to support a previously agreed move from annual to 2-yearly audit examination of the system of risk management and corporate governance arrangements. The Public Sector Internal Audit Standards have influenced this change of approach, whereby Internal Audit will once again undertake annual assessments of the provisions in these areas. 4.3 When compiling the new Strategic Audit Plan for 2014/15 onwards, it was further noted that two audits earmarked for completion in 2013/14 subsequently had to be deferred. These pieces of work concerned Development Management and Revenues and Benefits Governance. The two audits were postponed to allow more time for internal reviews of arrangements to take place; potential new working practices to be developed and rolled out, and activity against schemes and initiatives to advance, such that Internal Audit’s review work would be more meaningful when eventually carried out. Hence, the requisite rescheduling of these two particular audits has been noted in the new Strategic Plan, as well as the new Annual Audit Plan for 2014/15. 5. THE STRATEGIC AUDIT PLAN, 2014/15 TO 2016/17 5.1 The overarching objective of the Strategic Audit Plan (included at Appendix 4) is to provide a comprehensive programme of review work over the next three years, with each year providing sufficient audit coverage to give annual opinions, which can be used to inform the organisation’s Annual Governance Statement. 59 Audit Committee 17 March 2014 5.2 In the past, there has been some variation, year-on-year, with regards to the number of planned audit days and projects requiring delivery by Internal Audit Services. Moreover, going forward, we confirm that there is a continuing need for wide ranging review work in order to meet Public Sector Internal Audit Standards and the revised definition of Internal Auditing that they have introduced, which has again resulted in fluctuations in planned audit days required in future years. 5.3 In terms of bottom line yearly totals on the new Strategic Plan, they appear to have risen compared with 2013/14, but this has been due to the fact that the previously approved Annual Audit Plan for 2013/14 had featured 213 days, a figure that was then revised downwards to 186 days due to 2 assignments which amounted to 27 days, removed from the Plan, and subsequently agreed to be performed in 2014/15. 6. THE ANNUAL AUDIT PLAN, 2014/15 6.1 Having developed the Strategic Audit Plan, the Annual Audit Plan is next extracted, as can be seen in Appendix 5 to the report, with timings added to show the sequencing of assignments over the course of the financial year. The Annual Audit Plan for 2014/15 encompasses 218 days, allocated across 17 individual assignments plus audit verification work concerning audit recommendations implemented to improve the Council’s internal control environment. 7 SUMMARY OF PROPOSED AUDIT COVERAGE, 2014/15 7.1 Summary information, attached at Appendix 6 has also been formulated to give an indication as to the nature of forthcoming work over the next 12 months. The information has been developed to ensure that the relevant Service Managers and members of Corporate Leadership Team are aware of the direction of Internal Audit work over the course of the new financial year and that the Audit Committee can obtain an overview of the focus of work scheduled. Additionally, the documentation also ensures both External Audit and the Internal Audit Services contractor receive a steer as to the nature of individual audits over the coming year. Certainly, as far as the Internal Audit Services contractor is concerned; the Summary document offers a starting point for more detailed audit planning meetings with management. However, the guidance therein should be viewed with some flexibility, as the scope and subsequent parameters for some audits may need to alter in the event of changing corporate priorities, and/or terms of reference requiring adoption may not become wholly clear until discussions have been held with management as to the key priorities and risks facing service delivery, and where they feel an expanded scope is required to add further value. 7.2 Having reviewed the Summary of Internal Audit Coverage, it is also useful to take into account how the internal control environment at the Council has been evolving over time and how future audit input will continue to monitor this situation providing the Council with additional independent assurance during 2014/15. Appendix 7 is therefore included to highlight the historical and current position, as well as future coverage being put forward. Crosses within the table indicate where audits have been earmarked in 2014/15, as well as identifying those audits still progressing as part of the 2013/14 Annual Audit Plan. 60 Audit Committee 17 March 2014 8. OPTIONS 8.1 The Audit Plans presented have been derived from the Annual Audit Needs Assessment undertaken by the Internal Audit Consortium Manager. Failure to support these plans, and potentially consider further reductions in the audit coverage, could result in the Internal Audit Consortium Manager not being able to provide the requisite annual audit opinions, and may lead to the Council’s External Auditors having to increase the work they are required to perform. 9. RISK IMPLICATIONS 9.1 As mentioned above at paragraph 8.1, a failure to approve the Plans presented could result in additional risks to the authority, through the Internal Audit Consortium Manager not being able to provide the necessary opinions, and the External Auditors being required to perform additional audit testing. There is also the risk that reductions in Internal Audit coverage could lead to ongoing weaknesses in the internal control environment at the Council not being detected and reported upon, and subsequently resolved through remedial work being taken. 10. FINANCIAL IMPLICATIONS 10.1 Steps have been taken when formulating Internal Audit coverage for the year ahead, to ensure that the proposals put forward are affordable and do not exceed the approved audit budget for 2014/15. Appendices attached to this report: Appendix 1 Appendix 2 Appendix 3 Appendix 4 Appendix 5 Appendix 6 Appendix 7 Appendix 8 Internal Audit’s Charter for 2014/15 Internal Audit – Code of Ethics for 2014/15 Internal Audit Strategy for 2014/15 Strategic Audit Plan – April 2014 to March 2017 Annual Audit Plan – April 2014 to March 2015 Summary of Internal Audit Coverage for 2014/15 Levels of Assurance Awarded from 2008/09 onwards Performance Indicators for 2014/15 61 Appendix 1 NORTH NORFOLK COUNCIL INTERNAL AUDIT CHARTER FOR 2014/15 1. Introduction 1.1 Organisations in the UK public sector have historically been governed by an array of differing internal audit standards. The Public Sector Internal Audit Standards (the PSIAS), which took effect from the 1 April 2013, and are based on the mandatory elements of the Institute of Internal Auditors (IIA) International Professional Practices Framework (IPPF) now provide a consolidated approach to promoting further improvement in the professionalism, quality, consistency, transparency and effectiveness of Internal Audit across the whole of the public sector. 1.2 The PSIAS require that all aspects of Internal Audit operations are acknowledged within an Audit Charter that basically defines the purpose, authority and responsibilities of the service provision. The Charter therefore establishes the position of the Internal Audit Service within North Norfolk Council; its authority to access to records, personnel and physical properties relevant to the performance of engagements; in addition to defining the scope of Internal Audit activities. 1.3 There is also an obligation under the PSIAS for the Charter to be periodically reviewed and presented to the Audit Committee, the Section 151 Officer and senior management. This Charter will therefore be revisited annually to confirm its ongoing validity and completeness, and be circulated in accordance with the requirements specified above. 2. Purpose 2.1 In accordance with the PSIAS, Internal Auditing is defined as an independent, objective assurance and consulting activity designed to add value and improve the Council‟s operations. It helps the Council accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control and governance processes. 2.2 However, it should also be appreciated that the existence of Internal Audit does not diminish the responsibility of senior management to establish appropriate and adequate systems of internal control and risk management. Internal Audit is not a substitute for the functions of senior management, who should ensure that Council activities are conducted in a secure, efficient and well ordered manner with arrangements sufficient to address the risks which might adversely impact on the delivery of corporate priorities and objectives. 3. Authorisation 3.1 The requirement for an Internal Audit Service is outlined within the Accounts and Audit Regulations 2003, as amended in 2006 and 2011, which state that “a relevant body must undertake an adequate and effective internal audit of its accounting records and of its system of internal control in accordance with 62 the proper practices in relation to internal control”. This statutory requirement for continuous Internal Audit has been formally recognised and endorsed within North Norfolk Council‟s Constitution. 3.2 Further, there are additional requirements place upon the Chief Audit Executive (as more fully defined below in Section 4 - Organisation and Relationships), to fulfil all aspects of CIPFA‟s Statement on the Role of the Head of Internal Audit in Public Sector Organisations, whilst the Council‟s Constitution makes Internal Audit primarily responsible for carrying out an examination of the accounting, financial and other operations of the Council, under the independent control and direction of the Section 151 Officer. The role of Section 151 Officer at North Norfolk Council is fulfilled by the Head of Finance. 3.3 The internal audit activity, with strict accountability for confidentiality and safeguarding records and information, is authorised to have full, free, and unrestricted access to any and all of the organisation's: records, documents and correspondence (manual and electronic) relating to any financial and other transactions; physical properties, i.e. premises and land, plus cash, stores or any other Council property; and, personnel – requiring and receiving such explanations as are necessary concerning any matter under examination and generally assisting the Internal Audit activity in fulfilling its roles and responsibilities; recognising that all of the requirements stated above are pertinent to Internal Audit being able to carry out its commitments/engagements. Such access shall be granted on demand and shall not be subject to prior notice, although in principle, the provision of prior notice will be given wherever possible and appropriate, unless circumstances dictate otherwise. 4. Organisation and Relationships 4.1 Within the PSIAS, the terms ‟Chief Audit Executive,‟ „Board‟ and „Senior Management‟ are used to describe key elements of the organisation‟s governance, and the ways in which they interact with Internal Audit. The PSIAS require that the terms are defined in the context of the governance arrangements in each public sector organisation, in order to safeguard the independence and objectivity of Internal Audit. At North Norfolk Council, the following interpretations are applied, so as to ensure the continuation of the current relationships between Internal Audit and other key bodies at the Council. 4.2 Chief Audit Executive 4.2.1 At North Norfolk Council, the Chief Audit Executive is the Internal Audit Consortium Manager based at South Norfolk Council. This is due to the fact that North Norfolk‟s Internal Audit Service is delivered by means of a Group Agreement that exists between Breckland, Broadland, South Norfolk and North Norfolk District Councils, Great Yarmouth Borough Council and the Broads Authority, collectively known as the Norfolk Internal Audit Consortium. All authorities have signed an agreement under which South Norfolk Council procures delivery of Annual Audit Plans and any specified ad-hoc assignments 63 from an external contractor on behalf of the six named organisations. The contractor was originally Deloitte & Touche Public Sector Internal Audit Ltd but following a shares purchase agreement is now Mazars Public Sector Internal Audit Ltd, with effect from 1 February 2014. It is further noted that the current contract has been in place since 1 October 2007 and is due to expire on 30 September 2014. 4.3 4.2.2 As a consequence of the service structure outlined above, the Internal Audit Consortium Manager heads up an Audit Management Team situated within South Norfolk Council‟s Corporate Resources Directorate, acts as the Contract Manager to Mazars Public Sector Internal Audit Ltd, and reports directly to the Deputy Chief Executive at South Norfolk Council for administrative purposes. 4.2.3 The Internal Audit Consortium Manager also has a direct line of reporting to the Head of Finance at North Norfolk Council given that this individual is the Council‟s „Responsible Financial Officer/Section 151 Officer‟, who is charged with controlling and directing a continuous Internal Audit. 4.2.4 In response to requirements laid down within the PSIAS, it is further confirmed that the Internal Audit Consortium Manager has a direct reporting line and free and unfettered access to the Chief Executive at North Norfolk Council. Board 4.3.1 In the context of overseeing the work of Internal Audit at North Norfolk Council, the „Board‟ will be the Audit Committee of the Council, which has been established as part of the Corporate Governance arrangements at the Council. The Committee is responsible for the following with reference to Internal Audit: Agreeing the Internal Audit Charter. Approving the risk based Strategic and Annual Audit Plans, together with a Summary of Internal Audit Coverage for the forthcoming financial year. Reviewing progress achieved in relation to the completion of assignments featuring in the Annual Audit Plan. Monitoring delivery of agreed Audit Recommendations. Approving updated versions of the Counter Fraud, Corruption and Bribery Policy and Whistleblowing Policy, as appropriate. Considering the findings and conclusions of any Special/Ad-hoc investigations commissioned by the Audit Committee or members of the authority‟s senior management, i.e. Corporate Leadership Team. Noting the Annual Report and Opinion of the Internal Audit Consortium Manager. Undertaking Annual Audit Committee Self Assessment exercises. Considering the outcomes of the Annual Review of the Effectiveness of the Internal Audit Service. Overseeing External Assessments of the Internal Audit Service, at least once every 5 years. 64 4.3.2 4.4 In the context of ensuring effective liaison between Internal Audit and senior officers responsible at North Norfolk Council for specific aspects of internal control and governance, in a way that ensures the independence of Internal Audit, and provides for a critical challenge to the way that Internal Audit activities are carried out, „Senior Management‟ for the purposes of this Charter is the Management Team of which the Section 151 Officer (Head of Finance) is a key member. External Audit 4.5.1 4.6 Internal Audit will work closely with the Chair and members of the Audit Committee to facilitate and support the activities of the Committee. Moreover, the Internal Audit Consortium Manager also has a direct reporting line, and free and unfettered access to the Chair of the Audit Committee. Senior Management 4.4.1 4.5 Approving the Audit Joint Working Protocol between Internal and External Audit. In terms of Internal Audit‟s interaction with the Council‟s External Auditors – PriceWaterhousCooopers, an Audit Joint Working Protocol has been developed, which recognises the respective responsibilities of each body, relevant audit areas that will be covered, liaison and information sharing arrangements between the two bodies, audit testing and sample size requirements to be observed by the two bodies and generic key financial controls requiring examination each year. The Protocol has been primarily devised to minimise any potential duplication of work and determine the assurance that can be placed on the respective work of the two parties, whilst also ensuring that External Audit can place maximum reliance on the work of Internal Audit, wherever possible. Other Internal Audit Service Providers 4.6.1 Internal Audit will also liase with other Council‟s Internal Audit Service providers, where shared service arrangements exist between themselves and North Norfolk Council. In such cases, a dialogue will be opened with the other Council‟s equivalent Chief Audit Executive to agree a way forward regarding the future auditing of „shared‟ services, which will be both efficient and cost effective for all parties involved, and cause least disruption to the area(s) being audited. 4.6.2 In the event of North Norfolk‟s Internal Auditors undertaking work for other Councils outside the Norfolk Internal Audit Consortium, arrangements over liability of internal audit work performed will be covered by either a Hold Harmless letter with Mazars Public Sector Internal Audit Ltd, or contractual arrangements will be extended through a Standard Letter of Engagement – whichever is the appropriate response at the time. Conversely, if the other Council‟s Internal Auditors are nominated to undertake audit work on behalf of North Norfolk Council, formal confirmation of their 65 liability/accountability for that work will be required, so that full reliance can be placed upon the audit working papers and report generated in consequence. In addition, North Norfolk‟s Internal Audit Consortium Manager will review all such work to ensure that it is providing the requisite assurances to feed into her annual audit opinion and should it be found that insufficient or inadequate work has been carried out, North Norfolk‟s Internal Audit Consortium Manager reserves the right to request additional work is undertaken. 4.7 Other External Review and Inspection Bodies 4.7.1 The Internal Audit Section confirms it will likewise co-operate with all external review and inspection bodies that are authorised to assess and evaluate the activities of the Council, to determine compliance with regulations, standards or targets. Internal Audit will, wherever possible, utilise third party assurances arising from this work. 5. Objectives and Scope 5.1 The provision of assurance services is the primary role of Internal Audit and there is a duty of care on the Chief Audit Executive to give an annual internal audit opinion based on an objective assessment of the framework of governance, risk management and control. This responsibility to evaluate the governance framework far exceeds examination of controls applying to the Council‟s core financial systems. Instead, Internal Audit is required to scrutinise the whole system of risk management, internal control and governance processes established by management. 5.2 Internal Audit also has a secondary role, whereby it will provide consultancy services which are advisory in nature and generally performed at the request of the Council to facilitate improved governance, risk management and control, and potentially contribute to the annual audit opinion. 5.3 A risk based Strategic Audit Plan will be developed each year to determine an appropriate level of audit coverage to generate an annual audit opinion, which can then be used to assist with the formulation of the Council‟s Annual Governance Statement. Moreover, audit work performed will seek to enhance the Council‟s overall internal control environment. In the event of deficiencies in arrangements being identified during audit assignments, Internal Audit will put forward recommendations aimed at improving existing arrangements and restoring systems of internal control to a satisfactory level, where relevant. The way in which the Strategic Audit Plan is evolved, is explored further within the Charter at Section 8.2 Audit Planning and, in Appendix 3 – Internal Audit Strategy. 5.4 In accordance with the PSIAS, the Internal Audit Service will evaluate and contribute to the improvement of: 5.4.1 The design, implementation and effectiveness of the organisation‟s ethics-related objectives, programmes and activities. 5.4.2 The effectiveness of the Council‟s processes for performance management and accountability. 66 5.4.3 The Council‟s IT governance provisions in supporting organisation‟s corporate priorities, objectives and strategies. 5.4.4 The Council‟s risk management processes in terms of significant risks being identified and assessed; appropriate risk responses being made that align with the organisation‟s risk appetite, the capturing and communicating of risk information in a timely manner, and its use by staff, senior management and members to carry out their responsibilities and inform decision making generally. of the 5.4.5 The provisions developed to support achievement organisation‟s strategic objectives and goals. the 5.4.6 The systems formulated to secure an effective internal control environment. 5.4.7 The completeness, reliability, integrity and timeliness of management and financial information. 5.4.8 The systems established to ensure compliance with legislation, regulations, policies, plans, procedures and contracts, encompassing those set by the Council and those determined externally. 5.4.9 The systems designed to safeguard Council assets and employees. 5.4.10 The economy, efficiency and effectiveness with which resources are used in operations and programmes at the Council. 5.5 In addition to the areas recorded above, where Internal Audit will give input to their continuing enhancement; as previously acknowledged at Section 4.2.3 of the Charter, the Service will also provide support to the Head of Finance in the discharge of her duties as the Section 151 Officer with responsibility for the probity and effectiveness of the Authority‟s financial arrangements and internal control systems. 5.6 Managing the risk of fraud and corruption is the responsibility of management. However, as part of the scope of Internal Audit, it will be alert in all its work to the risks and exposures that could allow fraud or corruption to occur and will monitor the extent and adequacy of risk controls built into systems by management, sharing this information with External Audit. 5.7 In the course of delivering services encompassing all the elements stated above, should any significant risk exposures and control issues subsequently be identified, Internal Audit will report these matters to senior management, propose action to resolve or mitigate these, and appraise the Audit Committee of such situations. 6. Independence 6.1 The Internal Audit Section operates within an organisational framework that preserves the independence and objectivity of the assurance function, and ensures that Internal Audit activity is free from interference in determining the scope of internal auditing, performing work and communicating results. 67 6.2 The framework allows the Internal Audit Consortium Manager direct access to and the freedom to report unedited in her own name, as she deems appropriate, to the Audit Committee, the Chief Executive, Head of Finance (Section 151 Officer) and the Corporate Leadership Team. 6.3 Internal Auditors have no operational responsibilities or authority over any of the activities that they are required to review. As a consequence, they do not develop procedures, install systems, prepare records, or engage in any other activity, which would impair their judgement. In addition, Internal Auditors will not assess specific operations for which they were previously responsible, and objectivity is presumed to be impaired if an Internal Auditor provides assurance services for an activity for which they had responsibility within the previous 12 months. Internal Auditors may however provide consulting services relating to operations over which they had previous responsibility. 6.4 If however, Internal Audit‟s independence or objectivity is impaired in fact or appearance, the details of impairment will be disclosed to senior management and the Audit Committee. The nature of the disclosure will depend upon the impairment. 6.5 The Internal Audit Consortium Manager will confirm to the Audit Committee, at least annually, the organisational independence of the Internal Audit activity. 7. Professional Standards 7.1 North Norfolk Council‟s Internal Auditors operate in accordance with the Public Sector Internal Audit Standards, 2013. 7.2 The Internal Auditors are also governed by the policies, procedures, rules and regulations established by North Norfolk Council. These include the Constitution (with special attention to Financial Regulations and Finance Procedure Rules, plus Contract Standing Orders), the Counter Fraud, Corruption and Bribery Policy, and the Code of Conduct. Similarly, the Council‟s Internal Auditors will be heedful of external bodies‟ requirements (e.g. as identified by CIPFA), and all legislation affecting the Council‟s activities. 7.3 The Council‟s Internal Auditors will additionally adhere to the Code of Ethics as contained within the PSIAS, details of which are explained at Appendix 2. 7.4 Internal Auditors will also demonstrate due professional care in the course of their work and consider the use of technology-based audit and other data analysis techniques, wherever feasible and considered beneficial to the Council. 7.5 All working arrangements and methodologies, which will be followed by the North Norfolk Council‟s Internal Auditors are set out in the Audit Manual maintained by the Audit Management Team, the Specification within the Internal Audit Services Contract, and the Internal Audit Services contractor‟s own Audit Manual and quality assurance processes. 8. Audit Resources and Planning 68 8.1 8.2 9. Audit Resources 8.1.1 The Internal Audit Consortium Manager will be professionally qualified (CMIIA, CCAB or equivalent) and have wide internal audit management experience, to enable them to deliver the responsibilities of the role. 8.1.2 The Internal Audit Consortium Manager will ensure that the Internal Audit Service has access to a team of staff that have an appropriate range of knowledge, skills, qualifications and experience to deliver requisite audit assignments. The type of reviews that will be provided in year include computer audits, contract audits, systems reviews, grant certification work, consultancy input to new/modified systems, and special/fraud investigations. 8.1.3 In the event of special/fraud investigations being required, there is no contingency in the Audit Plans to absorb this work. Hence, additional resources will need to be made available to the Internal Audit Service when such input is necessary. Audit Planning 8.2.1 In accordance with earlier statements made at Section 5.3 of the Charter, the Chief Audit Executive will develop an annual audit strategy, together with strategic and annual audit plans and a summary of annual audit coverage using a risk based methodology, which takes into account documented corporate and operational risks, as well as any risks or concerns subsequently notified to the Internal Audit Consortium Manager by senior management. Copies of these documents will then be submitted to Corporate Leadership Team for their approval prior to being taken forward to the Audit Committee for final endorsement, in advance of the new financial year to which they relate. 8.2.2 The audit strategy can be found in Appendix 3 and explains the processes followed to populate the risk based Strategic Audit Plan attached at Appendix 4. From the Strategic Audit Plan, an Annual Audit Plan will be extracted, which is included at Appendix 5 and a Summary of Annual Audit Coverage drawn up after consultation with senior management. Audit Coverage information is contained within Appendix 6. 8.2.3 The Annual Audit Plan includes the timing, as well as budget and resource requirements for the next fiscal year. Completion of the assignments is contracted to Mazars Public Sector Internal Audit Ltd and the outcomes of their work will be monitored throughout the year with any requested deviations to the approved Plan being agreed with the Section 151 Officer, before then being brought to the attention of the Audit Committee through the periodic activity reporting process. Reporting 69 9.1 Upon completion of each audit assignment, an Internal Audit report will be prepared that: Provides an opinion on the risks and controls of the area reviewed, and this will contribute to the annual opinion on the internal control environment, which, in turn, informs the Council‟s Annual Governance Statement. Provides a formal record of points arising from the audit and management responses to issues raised, to include acceptance of audit recommendations with implementation timescales, as well as reasons for rejecting recommendations. Prompts management to implement agreed actions within targeted dates. 9.2 The Internal Audit Consortium Manager or their nominated Deputy will approve a draft version of all reports before their issue to the relevant officer, e.g. Chief Executive, Director, Head of Service and/or Service Manager. A copy is also supplied to the Head of Finance. 9.3 Exit meetings will be accommodated if senior management wish to discuss issued Draft Audit Reports with the Internal Audit Services contractor, the Internal Audit Consortium Manager or their nominated Deputy. 9.4 Accountability for management‟s response to Internal Audit recommendations lies with the Chief Executive, Directors, Heads of Service and/or Service Managers, as appropriate, who can either, accept and implement guidance given or formally reject it. However, if audit proposals to strengthen the internal control environment are disregarded and there are no compensating controls justifying this course of action, an audit comment will be made in the Final Audit Report, reiterating the nature of the risk that remains and recognising that management has chosen to accept this risk. Furthermore, depending on the severity of the risk, the matter may be escalated upwards and drawn to the attention of the Audit Committee. 9.5 Final Audit Reports will be issued in line with agreed working protocols to the relevant nominated officers. The Audit Committee will also be provided with management summaries from Final Audit Reports at each meeting, via Internal Audit‟s Progress Report and the Internal Audit Consortium Manager‟s Annual Report. 9.6 Where Action Plans apply to Final Audit Reports – these will be subject to follow up input. Management are requested to comment on progress achieved in relation to agreed actions at 3-monthly intervals, following formal issue of the Final Audit Report. In addition, Internal Audit will undertake verification work to review evidence of action initiated and the outcomes of this work will be communicated to the Audit Committee at agreed intervals. 9.7 The Internal Audit Consortium Manager’s Annual Report This will contain the annual audit opinion commenting upon: 9.7.1 The scope including the time period to which the opinions pertains; 9.7.2 Scope limitations; 70 9.7.3 Consideration of all related projects including the reliance on other assurance providers; 9.7.4 The risk or control framework or other criteria used as a basis for the overall opinion; 9.7.5 The overall opinion, providing reasons where an unfavourable overall opinion is given; and 9.7.6 A statement on conformance with the Public Sector Internal Audit Standards and the results of the quality assurance and improvement programme. 9.8 The full range of Internal Audit related reports to be brought to the attention of North Norfolk‟s Audit Committee are listed out at Section 4.3.1 of this Charter. 10. Quality Assurance and Improvement 10.1 The PSIAS require that the Internal Audit Consortium Manager develops and maintains a quality assurance and improvement programme that covers all aspects of the Internal Audit activity, and includes both internal and external assessments. In the event of an improvement plan proving necessary to formulate and implement, in order to further develop existing service provisions, the Internal Audit Consortium Manager will initiate the appropriate action and annually, the results of the quality and assurance programme together with progress made against the improvement plan will be reported to senior management and the Audit Committee. 10.2 Internal Assessments 10.2.1 Internal Assessments must include on-going monitoring of the performance of the internal audit activity. The Service operates in accordance with a number of key performance indicators, which are confirmed in the Internal Audit Services contract and detailed at Appendix 8. Contractor performance is subject to regular review by the Audit Management Team. 10.2.2 Internal arrangements also include receipt of post audit feedback from auditees and should criticism be received, this will immediately be investigated with the Internal Audit Services contractor and steps taken to resolve matters raised. 10.2.3 The PSIAS additionally require periodic self-assessments or assessments by other persons within the organisation with sufficient knowledge of Internal Audit practices. This obligation is satisfied by the Internal Audit Consortium Manager performing an annual selfassessment of the effectiveness of Internal Audit, the outcomes of which are then forwarded to the Section 151 Officer with appropriate evidence, for their independent scrutiny, before the results are submitted to the Audit Committee. Presenting this information to the Audit Committee enables members to be assured that the Internal Audit Service is operating in a satisfactory manner such that reliance can be placed on the subsequent annual audit opinion provided by the Internal Audit Consortium Manager. 71 10.3 External Assessments 10.3.1 External assessments must be conducted at least once every five years by a qualified, independent assessor or assessment team from outside the organisation. External assessments can be in the form of a full external assessment, or a self assessment with independent external verification. The Internal Audit Consortium Manager will agree with the Audit Committee and the Head of Finance: The form of the external assessments; and, The qualifications and independence of the external assessor or assessment team, including any potential conflict of interest. 10.3.2 The Internal Audit Consortium Manager will use their professional judgement when assessing whether an assessor or assessment team demonstrates sufficient competence to be qualified. An independent assessor or assessment team means not having any real or apparent conflict of interest and not being part of, or under the control of North Norfolk Council, i.e. the organisation to which the Internal Audit activity belongs. 72 Appendix 2 NORTH NORFOLK DISTRICT COUNCIL INTERNAL AUDIT – CODE OF ETHICS FOR 2014/15 1. Introduction 1.1 This Code of Ethics sets the minimum standards for the performance and conduct of North Norfolk District Council’s Internal Auditors. It is intended to clarify the standards of conduct expected from the Internal Auditors when carrying out their duties and promote an ethical, professional culture at all times when undertaking audit duties. This Code applies to all staff responsible for delivering Internal Audit within Breckland, Broadland, South Norfolk and North Norfolk District Councils, Great Yarmouth Borough Council and the Broads Authority, but does not supersede or replace the requirement on individual auditors to comply with their own professional bodies’ Codes of Ethics, as qualified members or student members, as well as any organisational Codes of Ethics or Conduct relating to their employer or the client authorities they serve. There are four main principles, which must be observed in addition to having due regard to the Committee on Standards of Public Life’s ‘Seven Principles of Public Life’. The principles involved are as follows: Integrity; Objectivity; Confidentiality; and, Competency. 2. Integrity 2.1 Principle 2.1.1 The integrity of Internal Auditors establishes trust and thus provides the basis for reliance on their judgement. 2.2 Rules of Conduct North Norfolk Council’s Internal Auditors shall: 2.2.1 Perform their work with honesty, diligence and responsibility. 2.2.2 Observe the law and make disclosures expected by the law and the profession. 2.2.3 Not knowingly be a party to any illegal activity, or engage in acts that are discreditable to the profession of internal auditing or to the organisation. 2.2.4 Respect and contribute to the legitimate and ethical objectives of the organisation. 73 2.3 Summary 2.3.1 Thus North Norfolk Council’s Internal Auditors will demonstrate integrity in all aspects of their work. Their relationship with colleagues and external contacts should be one of honesty and propriety. Such conduct will both support and develop an environment of trust, which provides the basis for reliance on all activities carried out by the Internal Auditors. 3. Objectivity 3.1 Principle 3.1.1 Internal Auditors exhibit the highest level of professional objectivity in gathering, evaluating and communicating information about the activity or process being examined. 3.1.2 Furthermore, Internal Auditors make a balanced assessment of all the relevant circumstances and are not unduly influenced by their own interests or by others in forming judgements. 3.2 Rules of Conduct North Norfolk Council’s Internal Auditors shall: 3.2.1 Not participate in any activity or relationship that may impair or be presumed to impair their unbiased assessment. This participation includes those activities or relationships that may be in conflict with the interests of the organisation. 3.2.2 Not accept anything that may impair or be presumed to impair their professional judgement. 3.2.3 Disclose all material facts known to them that, if not disclosed, may distort the reporting of activities under review. 3.3 Summary 3.3.1 Objectivity is a state of mind that has regard to all considerations relevant to the activity or process being examined without being unduly influenced by personal interest or the views of others. North Norfolk Council’s Internal Auditors will display professional objectivity at all times when providing opinions, assessments and recommendations. 4. Confidentiality 4.1 Principle 4.1.1 Internal Auditors respect the value and ownership of information they receive and do not disclose information without appropriate authority unless there is a legal or professional obligation to do so. 74 4.2 Rules of Conduct North Norfolk Council’s Internal Auditors shall: 4.2.1 Be prudent in the use and protection of information acquired in the course of their duties. 4.2.2 Not use information for any personal gain or in any manner that would be contrary to the law or detrimental to the legitimate and ethical objectives of the organisation. 4.3 Summary 4.3.1 North Norfolk Council’s Internal Auditors will therefore utilise information received in the appropriate manner and for the purpose it was originally requested and provided, as prescribed by the requirements of the above Rules of Conduct, and will additionally take suitable steps to safeguard all information made available. 5. Competency 5.1 Principle 5.1.1 Internal Auditors apply the knowledge, skills and experience needed in the performance of internal auditing services. 5.2 Rules of Conduct North Norfolk Council’s Internal Auditors shall: 5.2.1 Engage only in those services for which they have the necessary knowledge, skills and experience. 5.2.2 Perform internal auditing services in accordance with the International Standards for the Professional Practice of Internal Auditing. 5.2.3 Continually improve their proficiency and effectiveness and quality of their services. 5.3 Summary 5.3.1 North Norfolk Council’s Internal Auditors will not accept or perform work that they are not competent to undertake, unless they have received adequate training and support to carry out the work to an appropriate standard. 5.3.2 It is also essential that the Head of Internal Audit operates in accordance with the best practice guidance recommended in CIPFA’s Statement on ‘The Role of the Head of Internal Audit’ and undertakes an annual compliance check against the core principles stated therein. 75 6. Operational Arrangements 6.1 Achieving Compliance with the Code of Ethics 6.1.1 On an annual basis, the Internal Audit Consortium Manager, the Deputy Audit Manager and the Mazars Auditors will revisit the Code of Ethics to reinforce their understanding of and confirm their on-going commitment to the obligations placed upon them as specified in this document, and ensure that they continue to fully comply with these when discharging their day-to-day duties in relation to North Norfolk Council. 6.2 Securing Integrity 6.2.1 In order to be assured that the Internal Auditors demonstrate integrity in all aspects of their work, quality control processes have been developed to protect North Norfolk Council’s position in this matter. 6.3 Maintaining Audit Objectivity 6.3.1 In addition, it is essential that Internal Audit personnel are able to demonstrate independence and hence, objectivity. To this end, Internal Audit staff are obligated to declare potential conflicts of interest as they arise, so as to enable other staff to be assigned to specific reviews, thereby avoiding any compromising of independence. Audit objectivity will also be upheld, in so far as Internal Auditors will not be able to carry out audits in an area where they have had previous operational roles within the last 12 months. 6.4 Observing Confidentiality 6.4.1 A breach of confidentiality by an Internal Auditor will not be tolerated and will result in the expulsion of the individual from the Internal Audit Services contract. 6.5 Demonstrating Competency 6.5.1 It is a pre-requisite that all Internal Audit staff are aware of and understand: The organisation’s aims, objectives, risk and governance arrangements; The purpose, risks and issues affecting the service area to be audited; The terms of reference for the audit assignment so that there is a proper appreciation of the parameters within which the review will be conducted; and, The relevant legislation and other regulatory arrangements that relate to the service areas to be audited, e.g. Statutes, the Authority’s Scheme of Powers delegated to Officers, the Authority’s Financial Regulations and Standing Orders relating to Contracts, Partnership/Service Level Agreements, Internal Strategies/Policies/Procedural Notes. 76 Appendix 3 NORTH NORFOLK DISTRICT COUNCIL INTERNAL AUDIT STRATEGY FOR 2014/15 1 1.1 INTRODUCTION AND OVERVIEW The objectives of North Norfolk Council’s Internal Audit Service are set out in Internal Audit’s Charter, although they can essentially be summarised as follows: ‘To deliver a risk-based audit plan in a professional, independent manner, to provide the organisation with an opinion on the level of assurance it can place upon the internal control environment, systems of risk management and corporate governance arrangements, and to make recommendations to improve these provisions, where further development would be beneficial’. 1.2 Internal Audit’s Charter is subject to annual review by the Internal Audit Consortium Manager and will then be re-presented to the Audit Committee for formal approval. 1.3 Each year, an audit needs assessment is undertaken by the Internal Audit Consortium Manager in order to develop an updated 3-year Strategic Audit Plan, with an Annual Audit Plan being extracted from the latter for adoption in the succeeding financial year. 1.4 A computer audit needs assessment (CANA) is also usually performed on a 3-yearly cycle by the Internal Audit Services contractor, and the outcomes of this exercise will additionally feed into the reworked 3-year Strategic Audit Plan and the Annual Audit Plan. 2 2.1 WHAT THE INTERNAL AUDIT STRATEGY SETS OUT TO ACHIEVE The purpose of the Internal Audit Strategy is to confirm: How the service will be delivered to the Council over the next 12 months. The level of audit resources (i.e. planned audit days) required to secure annual audit opinions in relation to the Council’s systems of internal control and risk management, and corporate governance arrangements. The range and scope of the assignments selected for scrutiny, which collectively will provide an appropriate body work and corresponding evidence to derive annual audit opinions as required by the Public Sector Internal Audit Standards for the year ahead. The opinions will generate independent sources of assurance which will serve to inform the authority’s Annual Governance Statement. Internal Audit coverage has recognised and responded to the changing risks and priorities that face the Council. There is adequate annual examination of the fundamental financial systems with audit sampling and testing sufficient for External Audit purposes, such that PriceWaterhouseCoopers can place reliance upon the outcomes of Internal Audit work in these areas. Appropriate audit support has been made available to senior management and steps initiated to provide added value, wherever possible. 77 3 3.1 DEVELOPMENT OF THE CURRENT INTERNAL AUDIT STRATEGY The formation of the present Internal Audit Strategy is essentially risk driven, whilst also acknowledging that the primary issues to the Council at present are the ongoing need to deliver financial savings and legislative changes, and this in itself generates additional risks for the authority. As a result, extensive consultations have been undertaken with the Heads of Service, in order to refine draft strategic audit planning proposals, and thereafter, a meeting has been held with Corporate Leadership Team to finalise future audit coverage and the sequencing of audit projects to provide a programme of planned work that utilises audit resources to best advantage, supports the authority in the delivery of its corporate aims and generates independent assurances on operational arrangements where they are needed most. In undertaking the audit needs assessment, we have also considered a number of core documents that have enhanced our understanding of the operational environment at the Council. These documents have encompassed the Corporate priorities and objectives, plus the risks to their achievement as noted in the Corporate Risk Register and via documented operational risks, a range of Cabinet and Committee Reports, new and amended Policies and Strategies, as well as External Audit documentation. 3.2 Seven key risk factors have then been applied to potential auditable areas and their impact on the organisation evaluated in terms of: Materiality – the value of annual direct income/expenditure associated with the systems/activities; Materiality – an estimate of the number of transactions processed by the systems/activities per annum; Significance – the significance of the systems to the objectives and activities of the Council; Complexity of the organisation’s systems/activities in terms of their operation and auditability; Modifications to the organisation’s systems/activities or the likelihood of changes (i.e. new arrangements) being introduced within the duration of Audit Plans being put forward; Inherent risk, i.e. the likelihood of threats, error or malpractice to the organisation, because of the nature of its business activity, the regulatory framework, its size, its growth, its history, etc; and, Profile of auditable areas, reflecting on the political sensitivity of the systems/activities. 3.3 With reference to inherent risk, the Audit Needs Assessment is cognisant of those areas where there is a higher incentive, motivation and rationalisation to commit a fraudulent or corrupt act, e.g. o Housing Benefits o Provision of Discounts (e.g. Council Tax Discounts) o Awarding of Grants – Community Grants and Private Sector Housing, and other similar “direct” payments o Cash Collection o Credit Income o Creditor Payments o Contracts and Procurement o Loans and Investments o Payroll, Expense Claims and Recruitment o Disposal of Assets 78 o o o o Awarding of Planning Consents Awarding of Licences Gifts and Hospitality Car Parking Income 3.4 The risk factors have been weighted to produce a risk score, expressed as a percentage that is, in turn, translated into a risk rating of Very High, High, Medium or Low. Once risks have been categorised, it is then possible to determine the frequency with which areas identified, should be subject to audit scrutiny. Low risk systems will be examined on a 5-yearly cycle. Medium risk assessed systems should be reviewed on a 3-yearly basis. High risk areas will be audited on a 2-yearly basis, and Very High areas will be scrutinised on an annual basis. There can be exceptions to the rule but these are explained on both the Strategic and Annual Audit Plans, where relevant. 3.5 Prior to finalising our annual audit needs assessment, we have also been mindful of changes to the Annual Audit Plan for 2013/14 and where previously agreed with management, have brought forward a deferred audit to 2014/15 – this concerns Development Management. 3.6 As mentioned previously in paragraph 1.4, a computer audit needs assessment is also performed by the Internal Audit Services contractor in parallel to the audit needs assessment work carried out by the Internal Audit Consortium Manager. The CANA effectively evaluates the key risks affecting the IT environment within the Council and having identified risk priority ratings, it is then possible to use this information to populate a Strategic Computer Audit Priority Analysis and Annual Computer Audit Plans. The Internal Audit Services contractor applies a different methodology to the Internal Audit Consortium Manager however, i.e. very high risk scores call for 2-yearly audit input, high risk scores warrant 3-yearly review and medium risk scores dictate 4-yearly audit involvement. 4 FORMULATION OF THE STRATEGIC AND ANNUAL AUDIT PLANS 4.1 As noted above in Section 3 of the Strategy, prior to completing the annual audit needs assessment for 2014/15, there has been liaison with key personnel at the Council to identify a level of audit coverage necessary to provide requisite annual audit opinions. 4.2 Draft strategic audit planning proposals for 2014/15 were discussed with key personnel on 5 February 2014, after which Corporate Leadership Team’s views were canvassed on 11 February 2014 to confirm their acceptance of the coverage to be submitted to the Audit Committee for approval. Moreover, we have also provided External Audit with copies of the new Strategic and Annual Audit Plans, prior to their presentation to the Audit Committee. 4.3 Upon receiving the Audit Committee’s approval to the new year Audit Plans, the Internal Audit Consortium Manager will instruct the Internal Audit Service contractor (Mazars Public Sector Internal Audit Ltd) to adopt the Annual Audit Plan as their work programme for 2014/15. 79 North Norfolk District Council - Strategic Audit Plan - April 2014 to March 2017 Description of audit Audit Days Delivered 2013/14 Strategic risk Reference Assessed audit risk Frequency of coverage Appendix 4 2014/15 2015/16 2016/17 Days planned Days planned Days planned ANNUAL OPINION AUDITS Review of Corporate Governance and Risk Management arrangements 003 (CR), 005 (CR) High 2-yearly 8 8 8 Work to support the preparation of the Annual Governance Statement 15 Very High Annual 10 15 10 Follow up previous systems audit recommendations 8 Annual Not applicable 8 8 8 001 (CR), 004 (CR), 015 (CR) High 2-yearly 009 (CR) High High 2-yearly 2-yearly 13 High 2-yearly 20 High Ad-hoc request by management High 2-yearly 20 High 2-yearly FUNDAMENTAL FINANCIAL SYSTEMS Head of Finance Accountancy services - control accounts, banking, bank reconciliation, asset management / capital expenditure, budgetary control and treasury management Creditors - ordering and payments and insurance Receipt, handling and banking of remittances, tourist information centres, etc 17 12 Council Tax and NNDR 011 (CR), 012 (CR), 015 (CR) 011 (CR) Local Council Tax Support / Housing Benefits Revenues and Benefits Partnership - Data Transfer, Governance and Risk Sundry Debtors 10 17 13 12 20 20 5 2-yearly 10 Head of Organisation Development Payroll, human resources and officers & member expenses 003 (CR), 005 (CR), 006 (CR) 19 19 Page 1 of 4 80 North Norfolk District Council - Strategic Audit Plan - April 2014 to March 2017 Description of audit Audit Days Delivered 2013/14 Strategic risk Reference Assessed audit risk Frequency of coverage Appendix 4 2014/15 2015/16 2016/17 Days planned Days planned Days planned OTHER SYSTEMS AUDIT Head of Economic and Community Development Tourism & Economic Development Coastal Protection Homelessness and Housing Options 10 Housing Strategy and Affordable Housing Initiatives Private Sector Housing - Disabled Facilities Grants (to be undertaken in conjunction with Broadland Council) & discretionary improvement grants Localism and Communities - including focus on Big Society Fund Grant Scheme Medium Medium High Medium Medium 3-yearly 3-yearly 2-yearly 3-yearly 3-yearly Medium 3-yearly 004 (CR) High 2-yearly 10 004 (CR), 010 (CR) Medium 3-yearly 22 007 (CR) Medium 3-yearly 10 Medium 3-yearly 10 Medium 3-yearly 10 002 (CR) 010 (CR) 010 (CR) 8 10 10 10 10 8 10 Head of Development Management Development Management includes planning applications, planning enforcement, s106 agreements, Community Infrastructure Levy, Land Charges and Building Control Head of Assets and Leisure & Head of Economic and Community Development Partnerships Head of Assets and Leisure & Head of Environmental Health Parks and Open Spaces, plus Woodland Management Corporate Leadership Team Media and Communications 005 CR) Page 2 of 4 81 North Norfolk District Council - Strategic Audit Plan - April 2014 to March 2017 Description of audit Audit Days Delivered 2013/14 Strategic risk Reference Assessed audit risk Frequency of coverage Appendix 4 2014/15 2015/16 2016/17 Days planned Days planned Days planned OTHER SYSTEMS AUDIT Head of Environmental Health Waste Management including contract / agreement monitoring, income collection and monitoring, refuse collection, street cleansing, recycling, clinical waste, abandoned vehicles and grounds maintenance 18 High 2-yearly 18 Environmental Health Services includes emergency planning, food safety, environmental protection, pest control, dog warden, licensing and pollution control 19 Medium 3-yearly Medium Medium 3-yearly 3-yearly Medium High 3-yearly 2-yearly Medium 3-yearly 12 High 2-yearly 10 Low 5-yearly 008 (CR) Medium 3-yearly 009 (CR) Medium 3-yearly 19 Head of Assets and Leisure Sports Halls/Centres & Sports Development Leisure Complexes, Other Sports, Arts & Entertainment, including Pier Pavilion Property services Car parking & markets 001 (CR) 16 12 10 12 16 Head of Organisational Development Elections and Electoral Registration Performance management, corporate policy and business planning including annual action plans Democratic Services - Member Services, Training and Allowances 015 (CR) 10 8 Head of Legal Freedom of Information and Data Protection 8 8 Head of Finance Procurement TOTAL DAYS PER ANNUM FOR SYSTEMS AUDIT 141.0 10 184 189 163 Page 3 of 4 82 North Norfolk District Council - Strategic Audit Plan - April 2014 to March 2017 Description of audit Audit Days Delivered 2013/14 Strategic risk Reference Assessed audit risk Frequency of coverage Appendix 4 2014/15 2015/16 2016/17 Days planned Days planned Days planned 4 4 4 COMPUTER AUDIT Head of Business Transformation and IT Follow up of previous computer audit recommendations 4 Computer audit needs assessment 5 Annual Not applicable 5 Provision for computer audit coverage pending results of needs assessment 30 Infrastructure Network Infrastructure Very High 2-yearly 7 Network Security Very High 2-yearly 8 High 3-yearly 8 Medium 4-yearly 7 Virus Protection / Spyware Firewalls Management Issues Project Management Medium 4-yearly 008 (CR) Very High 2-yearly 013 (CR) Very High 2-yearly Business Continuity High 3-yearly Software Licensing High 3-yearly 6 Very High 2-yearly 10 IT Security, Procurement and End User Controls 13 Data Centre, Back Up, Disaster Recovery Information Governance (Data Protection and Freedom of Information) 7 Application Systems Cedar Financial Application Document Imaging - Civica (Revenues and Benefits) 10 Revenues and Benefits - Civica OpenRevs 13 012 (CR) High 3-yearly Medium 4-yearly High 3-yearly Cash Receipting Application High 3-yearly Register of Electors (eXpress) High 3-yearly TOTAL DAYS PER ANNUM FOR COMPUTER AUDIT TOTAL AUDIT DAYS PER ANNUM 7 45 34 39 34 186.0 218 228 197 Page 4 of 4 83 Appendix 5 North Norfolk District Council Annual Audit Plan - April 2014 to March 2015 2014/15 Client Officer Quarter 1 Quarter 2 Quarter 3 Assessed Audit Risk Frequency of audit coverage Days Planned High Annual 8 Very High Annual 10 Annual Not applicable 8 Creditors - ordering and payments and insurance High 2-yearly 13 Council Tax and NNDR High 2-yearly 20 Local Council Tax Support / Housing Benefit High 2-yearly 20 20 Payroll, human resources and officer & member expenses High 2-yearly 19 19 Identification of areas to be audited Apr May Jun Jul Aug Sep Oct Nov Quarter 4 Dec Jan Feb Mar ANNUAL OPINION AUDITS HEAD OF FINANCE Review of Corporate Governance and Risk Management Work to Support the preparation of the Annual Governance Statement Follow Up previous systems audit recommendations 8 10 4 4 FUNDAMENTAL FINANCIAL SYSTEMS HEAD OF FINANCE HEAD OF ORGANISATIONAL DEVELOPMENT 13 20 OTHER SYSTEMS AUDIT HEAD OF FINANCE Procurement Medium 3-yearly 10 HEAD OF ECONOMIC AND COMMUNITY DEVELOPMENT Coastal Protection Medium 3-yearly 10 Page 1 84 10 10 February 2013 Appendix 5 North Norfolk District Council Annual Audit Plan - April 2014 to March 2015 2014/15 Quarter 1 Assessed Audit Risk Frequency of audit coverage Days Planned Localism and Communities - including focus on Big Society Fund Grant Scheme High 2-yearly 10 Development Management includes planning applications, planning enforcement, s106 agreements, Community Infrastructure Levy and Land Charges Medium 3-yearly 22 HEAD OF ASSETS AND Sports Halls / Centres & Sports Development LEISURE Medium 3-yearly 12 HEAD OF ORGANISATIONAL DEVELOPMENT Medium 3-yearly 12 High 2-yearly 10 Client Officer HEAD OF DEVELOPMENT MANAGEMENT Identification of areas to be audited Elections and Electoral Registration Performance Management, Corporate Policy and Business Planning including annual action plans TOTAL SYSTEMS AUDIT DAYS 184 Page 2 85 Apr May Quarter 2 Jun Jul Aug Quarter 3 Sep Oct Nov Quarter 4 Dec Jan Feb Mar 10 4 10 22 12 12 10 0 0 10 42 0 4 22 39 20 33 February 2013 Appendix 5 North Norfolk District Council Annual Audit Plan - April 2014 to March 2015 2014/15 Client Officer Quarter 1 Assessed Audit Risk Frequency of audit coverage Days Planned Annual Not applicable 4 Network Infrastructure Very High 2-yearly 7 Network Security Very High 2-yearly 8 High 3-yearly 8 Medium 4-yearly 7 Identification of areas to be audited Apr May Quarter 2 Jun Jul Aug Quarter 3 Sep Oct Nov Quarter 4 Dec Jan Feb Mar COMPUTER AUDIT STRATEGIC DIRECTOR - Follow up of previous computer audit recommendations INFORMATION Virus Protection / Spyware Firewalls 2 2 7 8 8 7 TOTAL COMPUTER AUDIT DAYS 34 7 0 8 0 0 2 0 8 7 0 0 2 TOTAL DAYS FOR SYSTEMS AND COMPUTER AUDIT IN 2014/2015 218 7 0 18 42 0 6 22 47 27 33 10 6 Page 3 86 February 2013 Appendix 6 Summary of Internal Audit Coverage for 2014/15 The following table sets out the proposed coverage of each audit identified in the Annual Audit Plan for 2013/14. The more detailed scoping of reviews will be determined at the planning stage for each audit, with terms of reference being confirmed in audit briefs, drawn up in consultation with client officers. Systems Audits Title Review of Governance Management Description Corporate In 2012/13, we were able to give a good audit opinion in relation to Corporate Governance and an adequate and Risk assurance in relation to Risk Management. Thereafter, we had intended to adopt a 2-yearly cycle of audit coverage; however, the Public Sector Internal Audit Standards (PSIAS) require annual scrutiny and assurance to be obtained. In order to meet this obligation, we are thus reintroducing annual reviews and in 2014/15., propose to fulfil the Corporate Governance aspect by examining change and transformation at the Council, the standards also call for a review of how the authority is promoting appropriate ethics and values. It is recognised that the new post of Head of Business Transformation and IT will be taking a number of projects through the Council, at the time of the audit progress with these projects will be discussed and inclusion of review of some of these will be considered for review, if appropriate. The audit will additionally give due attention to risk management provisions, to confirm that: Significant risk are identified and assessed; Appropriate risk responses are forthcoming that align risks with the organisation’s risk appetite; and, Relevant risk information is captured and communicated in a timely manner across the organisation, enabling staff, management and members/Cabinet to carry out their responsibilities. Work to support the Annual This audit is used to assist the Internal Audit Consortium Manager to produce the Annual Report and Governance Statement 2013/14 Opinion for 2014/15. Essentially, testing will be performed on the Council’s key controls (that have not otherwise been tested as part of the Annual Audit Plan) to highlight any significant control weaknesses. In addition, where appropriate, there will be top up testing in relation to core financial systems reviewed in 87 Appendix 6 Summary of Internal Audit Coverage for 2014/15 detail earlier in the year, to ensure that audit samples cover a full year of transactions. We will work closely with the External Auditors to ensure that our sample testing is sufficient for their purposes, and hence they are able to place maximum reliance on our work. This audit typically covers the key controls in relation to the following fundamental financial systems; Payroll, Creditors / Accounts Payable, Council Tax and National Non-Domestic Rates, Local Council Tax Support and Housing Benefits, Fixed Assets, General Ledger, Debtors / Accounts Receivable, Cash / Remittances, Treasury Management – Investments / Loans, Budgetary Control, Car Park Income. The audit also covers the Council’s assurance framework. Creditors – ordering payments and insurance and This area was last reviewed in 2012/13, is a key system for the Council and thus audited on a 2-yearly basis. On conclusion of the last audit an adequate assurance opinion was awarded. The audit typically covers the following areas and ensures that the key controls, as required by External Audit are also included:: Policy, Procedure and Systems (Related to the associated areas detailed below); Ordering; Creditors; VAT; Visa Purchase Card Usage; and Insurances. Through discussion it is recognised that the use of purchase orders is on the increase and it is the desire of the Head of Finance that these are used more frequently and steps are being taken to ensure this. The audit will therefore review the use of these and where improvements can be made. The Council now also widely uses Purchasing Cards and testing will review the controls in place within this part of the system. Council Tax and NNDR This area is reviewed on a 2-yearly basis and in 2012/13 the audit concluded in a limited assurance level being awarded. Recommendations were made to ensure that there is regular reconciliation of refunds and authorisation of these refunds, independent review of reliefs, discounts and exemptions and retrospective void reliefs, a regular timetable in place to ensure ongoing eligibility of these discounts and prompt processing and authorisation of write offs. 88 Appendix 6 Summary of Internal Audit Coverage for 2014/15 All of these recommendations have been reported as implemented and the audit will ensure that these are now being consistently applied across the system. This is a key system for the Council and coverage will include the following areas, also ensuring that external audits requirements in relation to key control testing is also reviewed: Valuation and Billing Records; Billing; Collection of Income; Suspense Accounts; Reconciliation to the General Ledger; Refunds and Transfers; Discounts, Exemptions and Reliefs; Arrears Recovery; and Write Offs. Local Council Tax Support / Local Council Tax Support and Housing Benefits is a key system for the Council, and as such audited on a Housing Benefits 2-yearly basis. On conclusion of the audit in 2012/13 a limited assurance level was awarded. Recommendations were made to ensure that new claims and changes are dealt with in a timely manner, prompt clearance of suspense items, prompt processing and authorisation of write offs, prompt actioning of declarations of interest and dealing with appeals in a timely manner. All of the recommendations have been addressed, however in relation to timely processing of new applications and changes this is continually monitored by the service and reported through the quarterly performance reports, with action being taken to address this. The coverage for 2014/15 will encompass the key controls applying to Local Council Tax Support / Housing Benefits with reference to: Procedures and Legislation; Receipt and Assessment of Applications; Payment of Housing Benefit; 89 Appendix 6 Summary of Internal Audit Coverage for 2014/15 Overpayments, Arrears and Write Offs; Fraud; Backdated Claims; Discretionary Payments; and Appeals. It is recognised that as a result of the Local Council Tax Support Scheme there are more applications now for Discretionary Housing Payments, testing in this area will look at the application process and also how decisions are made on whether to award this payment. There is also a new integrated Overpayments module and all new overpayments are within this module, testing will focus on this new module and the processes and procedures in place to ensure that appropriate controls are within this new part of the system. Payroll, human resources and Payroll and HR is a key system for the Council, and as such audited on a 2-yearly basis, and in 2012/13 was officer & member expenses awarded an adequate assurance level. An element of the review is therefore dictated by the requirement to test the key controls operating in this area, in particular: Starters and Leavers; Controls over completeness and accuracy of data held on the payroll system; Processing of payment runs; and, Reconciliations of the payroll system. Further testing will be performed to ensure sufficient coverage of the wider control environment, as well as focusing in on more specific areas to give greater scrutiny of arrangements. This will be determined during the detailed audit planning process but has previously included areas such as; Officer and Members Expenses, Removal and Disturbance Allowances, Sickness Absence, HR and Organisational Development and Mileage Claims. The Council is also part of Coast Share whereby back office services are provided by the Council to small businesses and nor for profit organisations, through this group. It is early days, however it is recognised that 90 Appendix 6 Summary of Internal Audit Coverage for 2014/15 there is the appetite for providing Human Resources services through this avenue. At the time of the audit the uptake of this service will be established and how this is balanced in relation to meeting the Council needs will be reviewed. Procurement This area was last reviewed in 2012/13, with an adequate assurance level being awarded. The audit reviews the Council’s Contract Standing Orders and ensures that these are complied with and follow current law and regulation, in particular in light of the new EU Procurements Directives, due for implementation into national law by 30 June 2014. The audit will also ensure that the Council is obtaining economy, efficiency and effectiveness in its spending. The audit typically reviews the following scope: Policies, Procedures, Laws and Regulations; Resources, Roles and Responsibilities; Tender and Quotations Rules; Purchase ledger analysis; and Contracts Register. It is noted that there has been a lot of procurement activity in relation to the effects of the recent tidal surge, testing within this audit will not cover this and these payments will be reviewed as part of the Coastal Protection audit. Coastal Protection Coastal Protection is reviewed on a 3-yearly basis and was last reviewed in 2011/12 with a good assurance opinion being awarded on conclusion of the work. Since we last audited this area a Measured Term Contract was procured in 2012 and is now in place with Reno Steel. The audit will review how the contract is managed and monitored to ensure it meets with the Council’s requirements The scope will include: Strategy and Governance; Financial Management; and Contract Monitoring. In addition the audit will also review the recent expenditure incurred by the service as a result of the tidal 91 Appendix 6 Summary of Internal Audit Coverage for 2014/15 surge across the County, to ensure that Procurement rules were followed and how this is to be funded. Localism and Communities This is a new audit for 2014/15 and has been introduced mainly as a result of the Localism Act, which has introduced new rights and powers for communities and individuals in relation to the Community Right to Challenge the Community Right to Bid, and Neighbourhood Planning. This audit will review the preparedness of the Council in relation to these areas. However during discussion with Senior Management it has been agreed that the main scope of the audit will be to review the Big Society Fund Grant Scheme. This is the second year of the scheme and has recently been brought in house. The audit will look at the processes that organisations have to follow to apply for grants and how this is subsequently awarded by the Big Society Board. Development Management includes planning applications, planning enforcement, s106 agreements, building control, Community Infrastructure Levy and Land Charges The Planning Service hosted a Local Government Association / Planning Advisory Service Peer Challenge in 2013 to support, promote and improve the authority’s Planning Service, and in particular, the Development Management Service. It is hoped that the review of staffing structures, processes, negotiation with developers and planning enforcement activity with a team of External Specialists will enable an Improvement Plan to be formulated, which can resolve service delivery problems which have been steadily increasing since 2010/11. This audit was initially planned for coverage in 2013/14 however it was agreed that more value would be added if the audit was postponed to 2014/15, enabling full comment to be provided upon the new operational arrangements put in place following the Peer Review, providing an independent focus on internal control systems relating to planning application processes, planning enforcement, building control, income processing and section 106 agreements. It was envisaged that coverage would also include the Community Infrastructure Levy however it is noted that in July 2013 the Council agreed that introduction of CIL at that time represented a risk to the development strategy and it was recommended that consideration of CIL should be suspended and reconsidered at a future date when there are cleared signs of economic recovery. The current position in relation to CIL will be discussed at the time of the audit. 92 Appendix 6 Summary of Internal Audit Coverage for 2014/15 If time permits, Land Charges represents a further area where audit coverage might additionally be included. Sports Halls / Centres & Sports This area is subject to 3-yearly review and on conclusion of the most recent audit in 2011/12 an adequate Development assurance opinion was awarded. This audit traditionally looks at the following areas: Procedures (including staff verification checks); Income and Expenditure, including stock and security; Maintenance; Monitoring of the service; and The audit has also previously reviewed the Mobile Gym / Fit Together initiative. At the time of audit planning this currently has funding until March 2014 and there are moves to get this funding extended. If successful this will also form part of the scope of the audit. It is acknowledged that there is a current review of the lease agreements in place at North Walsham, Cromer and Stalham, with the first almost being finalised and the other 2 currently ongoing. The buildings are leased by the Council and are dual use i.e. used by the school during the day and by the public in the evening and at weekends. The agreements have been in place a long time and they are being revised to ensure that they are efficient and effective for the Council, and ultimately provide savings for the Council. This aspect will also be reviewed as part of the audit. Elections Registration and Electoral This area was last reviewed in 2011/12 and is subject to 3-yearly scrutiny. On conclusion of the last audit a good assurance level was awarded. The scope however will be quite different this year as it is appreciated that this audit is being undertaken in the year that the Individual Electoral Registration (IER) is introduced, which paves the way for a fundamental change to the way people can register to vote. At present, one person in every household is responsible for registering everyone else who lives at that address, whereas the Government is proposing that, from summer 2014, each person will be required to register to vote individually, rather than by household. The key principles that should underpin the effective introduction of IER are: The system should ensure that anyone is eligible to take part in elections in Great Britain from registering to vote. The system should ensure that anyone who is not eligible to vote is not included in an Electoral 93 Appendix 6 Summary of Internal Audit Coverage for 2014/15 Register. These changes to the system should be easily explained to, and understood by electors. The system should ensure that all personal data is properly managed and protected. The system should be capable of being implemented efficiently and without a detrimental impact on the existing duties and responsibilities of Electoral Registration Officers. We will be checking to see how the Council is performing against the above criteria. The Electoral Registration and Administration Act 2013, which received Royal Assent on 31st January 2013, provides the legal framework for IER. Work on introducing IER is scheduled during the spring and summer of 2014 and will involve comparison between existing Council Registers and records held by the Department for Work and Pensions (DWP) in order to verify the identity of people currently on the registers. This process is known as ‘confirmation’. The final household canvass will take place in spring 2014 with planned confirmation in the summer of 2014. Performance Management, This audit was last undertaken in 2012/13 and is subject to 2-yearly review, with an adequate assurance Corporate Planning and being provided on conclusion of the audit. Business Planning including annual action plans The audit will focus on the performance management framework, including the annual action plans at the Council. It is recognised that the current Corporate Plan is dated 2012 to 2015, and the annual action plans ensure delivery of the corporate plan. The quarterly performance reports cover annual action plans, performance indicators and service risks. The recently published Equality Policy will also link into the performance reports so that this becomes integrated into the continual review process at the Council. The audit will review the processes behind the quarterly performance reports, the collection of all the data and how this is presented to Senior Officers and Members. 94 Appendix 6 Summary of Internal Audit Coverage for 2014/15 Computer Audits Network Infrastructure The network infrastructure enables users to connect to servers and equipment, which is not directly connected to their own physical PC or workstation. The review of the network infrastructure includes reviewing the following key areas: Network administration; Network monitoring; Network topology and resilience; Remote access servers and security; Routers; and Virus detection / prevention. Network Security A Network security audit looks at the following areas: Domain accounts policies; Audit policy settings; User privileges; Trusted and trusting hosts; User accounts and passwords; Services and drivers; Home directories, logon scripts Security Option settings; Logical drives; Default login accounts; and Discretionary access controls (DACLs) Virus Protection / Spyware Computer viruses can infect the Council’s IT systems from a number of sources including downloads from the internet and e-mail attachments to a user bringing in infected portable media. The result of an infection could range from temporary annoyance due to an increase in processing to the complete shutdown and corruption of the network. The recent trend has also been for systems to be infected with Spyware that are programs that can cause re-direction to internet sites or the monitoring of users internet habits. Virus and Spyware controls are designed to protect the Council’s systems from such threats and this audit will look that the controls in place to protect the Council from this risk. This audit has previously been on the reserve list, 95 Appendix 6 Summary of Internal Audit Coverage for 2014/15 although is now deemed to be an area that should be included within the Plan. Firewalls The primary objective of a firewall is to control the incoming and outgoing network traffic by analysing the data packets and determining whether it should be allowed through or not, based on a predetermined rule set. As this is an area that has not previously been audited at the Council, it has been selected for scrutiny in this plan. The audit will look at the Council’s firewalls in the following areas of management responsibilities: Topology and resilience; Firewall configuration settings; Change controls; and Security validation tests. 96 Appendix 7 North Norfolk District Council Map of Audit Assurances provided since 2008/09 2008-09 2009-10 2010-11 2011-12 Adequate Adequate Adequate Adequate 2012-13 2013-14 2014-15 Annual Opinion Audits Corporate Governance and Risk Management Corporate Governance Risk Management X Good Adequate Ethical Governance Adequate One-off audit AGS - Assurance Framework Adequate Key - AGS relates to Work to Support the preparation of the Annual Governance Statement. This work scrutinises key controls only, rather than providing for an in-depth review of systems in their entirety and because of this, the type of assurance that we are able to give is restricted to adequate or limited. Fundamental Financial Systems Sundry Debtors AGS - Sundry Debtors Remittances AGS - Cash Accountancy Services Treasury Management, Control Accounts, Banking, Asset Register, Budgetary Control and Journals Bank Reconciliation AGS - Fixed Assets AGS - General Ledger AGS - Treasury Management AGS - Budgetary Control Local Council Tax Support and Housing Benefits Council Tax / NNDR Exchequer/Creditors Payroll / HR Budgetary Control Revenues and Benefits Partnership - Data Transfer, Governance and Risk Adequate Limited X Adequate Adequate Adequate X Adequate Adequate Adequate See below Good Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Good Limited Limited Adequate Adequate X X X X Incorporated into accountancy Good Adequate Head of Economic and Community Development Tourism and Economic Development Coastal Protection Adequate Homelessness and Housing Options Housing Strategy and Affordable Housing Adequate Private Sector Housing and Disabled Facilities Grants Adequate Communities and Safety Adequate X Good Adequate X Adequate Good Adequate Adequate Absorbed into future audits concerning Localism and Communities Limited Localism and Communities X Head of Development Management & Head of Economic and Community Development Development Management, Planning, s106 Agreements, Community Infrastructure Levy and Land Charges Postponed to 2014/15 Adequate Head of Assets and Leisure & Head of Economic and Community Development Partnerships Limited Head of Environmental Health Waste Management Environmental Health Head of Assets and Leisure Sports Halls/Centres Leisure Complexes Property Services Car Parking and Markets AGS - Car Park Income Limited X Adequate Adequate Adequate Limited Limited Adequate Adequate Limited Adequate Adequate Adequate X Adequate Adequate Limited Adequate Adequate February 2013 97 Appendix 7 North Norfolk District Council Map of Audit Assurances provided since 2008/09 Head of Assets and Leisure & Head of Environmental Health Parks and Open Spaces Limited Head of Organisational Development Elections / Electoral Registration Data Quality Adequate Performance Management, Corporate Policy and Business Planning, inc Annual Action Plans Head of Legal Legal Services, Data Protection, Freedom of Information Whistleblowing Concessionary Fares Adequate Head of Finance Projects and Procurement Car Allowances Adequate Adequate Limited Adequate Good Discontinued as NI's ending Good Deferred to 2012/13 Adequate Adequate Unsatisfactory X X Good One-off audit Function transferred to County Council Adequate Adequate X One-off audit IT Audits - Head of Business Improvement and IT General Ledger/Cedar Financials Application Project Management General IT Controls Cash Receipting Document Imaging and Workflow Application - Civica Revenues and Benefits IT Security IT Security, Procurement and End User Controls Software Licensing Revenues and Benefits Application Network Infrastructure Business Continuity Data Centre, Back Up, Disaster Recovery Data Consistency Payroll and Personnel Content Management Network Security Virus Protection / Spyware Firewalls Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Adequate Limited Adequate X Limited Adequate Adequate Adequate Adequate X X X February 2013 98 Appendix 8 Performance Indicators for the Internal Audit Service Internal Audit performance is monitored as detailed below. Indicator % audit recommendations accepted by management Target 90% % high priority recommendations implemented 100% Number of days between the issue of Internal audit briefs and commencement of audit fieldwork 10 working days Number of days between the expected completion of audit fieldwork (as per the audit brief) and actual completion of audit fieldwork Number of days between the completion of audit fieldwork and issue of draft report 0 working days Number of days between the issue of the draft and final report Number of days between the completion of the fieldwork and issue of a final report 15 working days 10 working days Purpose Acceptance of audit recommendations by management ensures that where improvements are required to the internal control environment, appropriate action will be taken to secure these enhancements. However, there can be occasions where recommendations are disputed. In these cases, there may be justifiable reasons for management not supporting the recommendation, e.g. compensating controls have been put in place. Conversely, management can take the decision to accept the risks identified, particularly if insufficient resources preclude action being taken. However, this will mean that there are vulnerabilities in systems of internal control, which are not being addressed. Management’s commitment in implementing high priority recommendations ensures that high profile risks/fundamental flaws in systems of internal control are suitably resolved. Management should have sufficient time to consider and shape audit objectives driving review work before the fieldwork starts. Hence, adequate consultation is permitted enabling management to make a contribution to terms of reference thereby ensuring the audit adds value to their service area. This indicator seeks to check that audit fieldwork finishes in a timely manner and thus audits progress as expected, and there are no unnecessary delays. The draft report is the first stage after which management will have written confirmation of the audit outcomes. Issue on a timely basis provides better opportunity for management to be able to comment, and also ensures that the audit plan is delivered as expected. Delivery of a timely final report ensures that management can commence the process of addressing internal control weaknesses. This is a combination of the two performance indicators above and reflects the total time incurred in completion of the audit process. 25 working days 99 Indicator Average score given to audit feedback Target Adequate Compliance with the Public Sector Internal Audit Standards Full Compliance with the CIPFA Statement on the Role of the Head of Internal Audit Purpose This is the main indicator of audit quality and is based upon the feedback received by management for individual audit assignments, which range on a 6-point basis, namely poor, weak, less than adequate, adequate, good and excellent. These Standards encompass the mandatory elements of the Institute of Internal Auditors (IIA) International Professional Practices Framework. A checklist has been developed from the guidance, which will be completed annually, with the results feeding into our review of the effectiveness of internal audit. This Statement sets out what CIPFA considers being best practice for Heads of Internal Audit in terms of providing a summary of the core responsibilities entailed in the role to support the Council in achieving its objectives, by giving assurance on its internal control arrangements and playing a key part in promoting good corporate governance. A checklist has been developed from the guidance, which is completed annually and feeds into our review of the effectiveness of internal audit. Full 100 Audit Committee 17 March 2014 Agenda Item No______11_______ Progress Report on Internal Audit Activity, 26 November 2013 to 25 February 2014 Summary: This report examines progress made between 26 November 2013 and 25 February 2014 in relation to delivery of the Annual Audit Plan for 2013/14. Conclusions: A total of 1 audit assignment has been processed culminating in a mix of good and adequate assurances being awarded to date this financial year. Recommendations: It is recommended that the Committee notes the outcome of the audit completed between 26 November 2013 and 25 February 2014 where an assurance level has been given and the progress to date with the annual audit plan. Cabinet member(s): All All Wards: Contact Officer, telephone number, and e-mail: 1. Emma Hodds, Deputy Audit Manager 01508 533791 elhodds@s-norfolk.gov.uk Background 1.1 The Accounts and Audit Regulations 2011 require that the Council must undertake an adequate and effective internal audit of its accounting records and of its system of internal control in accordance with the proper practices in relation to internal controls. To assist the authority with fulfilling this responsibility, this Activity Report seeks to build on the findings of the previous two Progress Reports provided to members in September and December 2013, examining further progress made with regards to progressing assignments featuring in the approved Annual Internal Audit Plan for 2013/14, which was endorsed by the Audit Committee on 19 March 2013. 1.2 The Public Sector Internal Audit Standards which came into affect on 1 April 2013 also require that this Committee receives regular communications regarding Internal Audit’s performance in relation to the Annual Audit Plan. This 101 Audit Committee 17 March 2014 report thus aims to meet this requirement and ensure that independence and objectivity (Standard 1100) are maintained. 2. Amendments to the Annual Audit Plan 2.1 Since we last reported on the status of the Annual Audit Plan and provided members with details regarding two minor amendments to timings of audits and the requirement to defer 2 audits (Revenues and Benefits Services – Data Transfer, Governance and Risk and Development Management) there has been no further adjustments to the annual audit plan. 3. Delivery of Programmed Audit Work in accordance with the Revised Annual Audit Plan 3.1 As demonstrated in Appendix 9, 171 days of programmed work had been completed at the time of writing this report. This figure equates to 92% of revised audit planned days earmarked for completion in 2013/14. The status of individual audits can be summarised thus: One assignment has been completed and final reports issued where audit assurance levels have been generated – Audit No. NN/14/09 Sundry Debtors. The audit fieldwork is under way for the remaining audits; NN/14/05 Economic Development, NN/14/10 Work to Support the Annual Governance Statement, and NN/14/11 Receipt, handling and banking of Remittances. 4. Outcomes of Work Undertaken 4.1 With reference to work completed between 26 November 2013 and 25 February 2014, as mentioned above, the corresponding management summary is attached at Appendix 10 to the report. 4.2 In relation to the audit of Sundry Debtors (NN/14/09) an adequate assurance level has been awarded on conclusion of the review, which indicates an improvement in the control environment since the last review. Two medium priority recommendations were raised in relation to reviewing and refreshing the Corporate Debt Policy and to ensure that there is a clear audit trail in relation to transfers. 4.3 Members should note that all audits finalised in this period have received a positive assurance, i.e. good or adequate and that all audit reports issued so far in the current financial year, have resulted in positive assurances being awarded, which emphasises that the systems of internal control evaluated to date, have been found to be working effectively and efficiently. 4.4 Members should also note that all audit work is currently on track for completion by the financial year end and to the agreed timetable of work. 5. Conclusion 102 Audit Committee 17 March 2014 5.1 Good progress has been made with the delivery of the Audit Plan to date; positive assurances have been awarded and all other work scheduled is on track as expected. 6. Recommendation 6.1 That members note the outcomes of the completed audit and the progress made to date with the completion of the Annual Audit Plan. Appendices attached to this report: Appendix 9 – Review Work delivered in accordance with the Annual Audit Plan for 2013/14 Appendix 10 – Abbreviated Management Summaries of Completed Audit Assignments Appendix 10 (1) NN/14/09 Sundry Debtors 103 Appendix 9 Review Work delivered in accordance with the Annual Audit Plan for 2013/14 plus Ad-Hoc Work requested by Management Audit No. Description of Audit PLANNED SYSTEMS AUDIT WORK Environmental Health Services NN/14/01 Frequency of Audit Coverage Original Days Planned Revised Days Planned Days Delivered Scheduling 3-yearly 19 19 19 April NN/14/02 Private Sector Housing - Disabled Facilities Grants 3-yearly 8 8 8 June NN/14/03 Car Parking and Markets 2-yearly 16 16 16 July NN/14/04 Waste Management 2-yearly 18 18 18 August NN/14/05 Tourism and Economic Development 3-yearly 10 10 3 September January February NN/14/06 Freedom of Information and Data Protection 3-yearly 8 8 8 October NN/14/07 Accountancy Services 2-yearly 17 17 17 October Status Complete Final report issued 16 July 2013 Complete Final Report issued 8 August 2013 Complete Final Report issued 20 August 2013 Complete Final Report issued 14 October 2013 Fieldwork underway Complete Final Report issued 13 November 2013 Complete Final Report issued 21 November 2013 Treasury Management Control Accounts Banking Asset Register Budgetary Control Journal Entries Bank Reconciliations Revenues and Benefits Services - Data Transfer, Governance and Risk Ad-hoc 5 0 0 October Quarter 4 Deferred to 2014/15 Audit deferred to 2014/15 at the request of management NN/14/09 Sundry Debtors 2-yearly 10 10 10 November NN/14/10 Work to Support the AGS Annually 15 15 14 January Complete Final Report issued 30 January 2014 Fieldwork underway, draft report imminent NN/14/11 Receipt, handling and banking of remittances and tourist information centres Development Management 2-yearly 12 12 11 3-yearly 22 0 0 January February February Deferred to 2014/15 Annually 8 168 8 141 4 128 Systems Audit Follow Up TOTAL PLANNED SYSTEMS AUDIT WORK Summary Report Details presented to Members Adequate 17 September 2013 Adequate 17 September 2013 Adequate 17 September 2013 Adequate 10 December 2013 Good 10 December 2013 See Below 10 December 2013 Good Good Good Good Good Good Adequate NN/14/08 NN/14/12 Assurance Level applicable Fieldwork underway, draft report imminent Audit deferred to 2014/15 at the request of management 2 x 6-monthly validation 91% 104 Adequate 17 March 2014 Audit No. Description of Audit PLANNED COMPUTER AUDIT WORK Document Imaging - Civica (Revenues and Benefits) NN/14/13 Frequency of Audit Coverage Original Days Planned Revised Days Planned Days Delivered Scheduling 4-yearly 10 10 10 NN/14/14 Revenues and Benefits Application - Civica 3-yearly 13 13 13 July September September NN/14/15 IT Security, Procurement and End User Controls 2-yearly 13 13 13 October NN/14/16 Computer Audit Needs Assessment 3-yearly 5 5 5 October September Annually 4 45 4 45 2 43 96% 213 186 171 92% Computer Audit Follow Up TOTAL PLANNED COMPUTER AUDIT WORK TOTAL PLANNED WORK Status Complete Final Report issued 25 October 2013 Complete Final Report issued 28 October 2013 Complete Final Report issued 14 November 2013 Complete Final Report issued 26 September 2013 2 x 6-monthly validation EXTRA WORK REQUESTED TOTAL OF EXTRA WORK UNDERTAKEN GRAND WORK TOTAL 0 0 0 213 186 171 92% 101 Assurance Level applicable Summary Report Details presented to Members Adequate 10 December 2013 Adequate 10 December 2013 Adequate 10 December 2013 N/A 10 December 2013 Appendix 10 Report No. NN/14/09 – Final Report issued 30 January 2014 Audit Report on Sundry Debtors Audit Scope The audit covered; Policies and procedures; The raising of Sundry debtors, refunds and transfers; Direct debits; Suspense items; Processing and Recovery of Outstanding Debts Writing off outstanding debts; Debtors reconciliation; and Security arrangements. The audit also tested the expected controls as contained in external audit’s key control flowcharts. This work is relied upon by the external auditors during their annual statutory review of the Council’s accounts and financial processes. Assurance Opinion Unsatisfactory Assurance Limited Assurance Adequate Assurance Good Assurance Rationale supporting the award of the opinion Based on the testing undertaken in line with the scope of our work, the control environment is overall deemed to be adequate in managing the risks associated with this area, which indicates an improvement in the control environment since it was last reviewed in 2011/12.It is also worth noting that eight out of the nine recommendations from NN12/08 that cross-over with the scope of this audit have been verified fully through this audit. One further recommendation from NN12/08, which was outside the scope of this audit and related to performance management, has also been confirmed as complete. However, there are areas of risk that remain, in relation to segregation of duties. This issue, as determined in the previous audit of this area (NN12/08), relates to the merging of the Exchequer and Sundry Income functions and the downsizing of the teams, which means that the Team Leader, Exchequer and Sundry Income has full access to both the sales ledger and purchase ledger functionality within the eFinancials system. This lack of segregation of duty has been mitigated in the area of write offs and refunds with manual controls being put in place to mitigate the associated risks. However there is not the same level of mitigation in place in relation to transfers as there is no form of independent check of transfers from the sundry debtors suspense account to charge payers accounts, between debtors accounts and from the sales ledger to purchase ledger (for refunds) and with the absence of a clear electronic audit trail within eFinancials leave the system open to the risk of potential fraud. Management had previously informed us through our cyclical follow-up checks that a similar action had been completed following a recommendation raised in NN12/08, therefore another recommendation has been raised. The Council also does not undertake credit checks on large debtors. This issue has been raised previously with the Council will to accept the risks in not doing so. 102 The Council may also benefit from reviewing and, if necessary, refreshing the Corporate Debt Management Policy. Positive Findings We have acknowledged It is also acknowledged there are areas where sound controls are in place and operating consistently A range of aged debt reports are run on either a weekly, fortnightly or monthly basis, depending on the particular status of the debts. Individual cases are subject to review and proactive follow-up action where necessary. An overarching aged debt report is separately reviewed by the Team Leader, Exchequer and Sundry Income, with a sample of individual debts selected and reviewed in terms of validity of their status each month. Direct debit rejections and recalls are identified and reviewed in a timely manner, to ensure appropriate action is taken. New direct debits are set up in a timely manner. Receipt of debtors income is independently reconciled to bank statements and the general ledger on a monthly basis and is independently checked. Write-offs are undertaken in line with the write-off policy which is aligned to the Scheme of Delegation. Records are retained to support write-offs with reasons documented by an officer independent of the authorisation process. Control weaknesses to be addressed During our work we have identified the following key area(s) where we believe that the processes / arrangements within sundry debtors would benefit from being strengthened, and as a result of these findings two medium priority recommendations have been made. The Council may benefit from formally reviewing and refreshing its Corporate Debt Management Policy, to help ensure that it remains in line with the wider organisational context and objectives. The version located on the Council’s website did not contain a date of previous review and neither the Team Leader - Exchequer and Sundry Income, nor the Head of Finance and S151 Officer, could confirm whether the policy had been subject to recent review. Additional control should be introduced over the processing of transfers (from suspense, between the sales ledger and purchase ledger and between charge payers accounts). The absence of a clear electronic audit trail within eFinancials, showing the officers who have processed transfers coupled with the absence of any form of independent checking increases the risk of inaccurate and / or potentially fraudulent transfers being made. 103 Summary of the adequacy and effectiveness of controls Area of Scope Adequacy and Effectiveness Assessments Policies and Procedures Raising of Debts, Refunds and Transfers Direct Debits Suspense Items Processing and Recovery Debtors Reconciliation Write Offs Security Adequacy of Controls Effectiveness of Controls Recommendations Raised High Medium Low Green Amber 0 1 0 Amber Green 0 1 0 Green Green 0 0 0 Amber Green 0 * 0 Green Green 0 0 0 Green Green 0 0 0 Green Amber Green Green 0 0 0 * 0 0 0 2 0 Total *Covered by recommendation covered in area 2. High Priority Recommendations No high priority recommendations have been raised as a result of this audit Management Responses Management have accepted the recommendations raised. 104