www.pwc.co.uk Government and Public Sector North Norfolk District Council Report to those charged with governance (ISA 260 (UK&I)) September 2012 2011/12 Audit www.pwc.co.uk The Members of the Audit Committee North Norfolk District Council Council Offices Holt Road Cromer Norfolk. NR27 9EN September 2012 Ladies and Gentlemen We are pleased to enclose our report to the Audit Committee in respect of our audit of North Norfolk District Council (“the Authority” ) for the year ended 31 March 2012, the primary purpose of which is to communicate the significant findings arising from our audit. The scope and proposed focus of our audit work was summarised in our audit plan, which we presented to the Audit Committee in March 2012. We have subsequently reviewed our audit plan and concluded that our original risk assessment remains appropriate. The procedures we have performed in response to our assessment of significant audit risks are detailed on page 5. We have completed the majority of our audit work and expect to be able to issue an unqualified audit opinion on the financial statements on, or before, 30 September 2012. At the time of writing, the key outstanding matters, where our work has commenced but is not yet finalised are provided on page 8. We will provide an oral update on these matters at the meeting on 18 September 2012. We look forward to discussing our report with you on 18 September. Attending the meeting from PwC will be Julian Rickett and Charlotte Kennedy. Yours faithfully Julian Rickett PricewaterhouseCoopers LLP www.pwc.co.uk Contents Executive summary 4 Audit Approach 5 Significant audit and accounting matters 8 Fees update 12 Fees update for 2011/12 12 Appendices 13 Appendix 1: Letter of representation 14 Appendix 2: Control weaknesses and deficiencies 20 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 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. North Norfolk District Council Executive summary The purpose of this report Under the Auditing Practices Board’s International Auditing Standard (UK and Ireland) 260 (ISA (UK&I) 260) - “Communication of audit matters with those charged with governance” we are required to report to those charged with governance on the significant findings from our audit before giving our audit opinion on the accounts of North Norfolk District Council (‘the Authority’). As agreed with you, we consider that “those charged with governance”, at the Authority, are the Audit Committee. This letter contains the significant matters we wish to report to you arising from all aspects of our audit programme of work in accordance with ISA (UK&I) 260. Our audit work during the year was performed in accordance with the plan that we presented to you on 6 March 2012. An audit of financial statements is not designed to identify all matters that may be relevant to those charged with governance. Accordingly, the audit does not ordinarily identify all such matters. We have set out below what we consider to be the most significant matters that we have discussed with you in the course of our work. Significant Matters There are no significant matters that we have discussed with management during the course of our work affecting our ability to issue our “true and fair” opinion and therefore wish to raise with you. However, as is the case with any audit, we have identified a number of other less significant matters which we have included in this report for your information. These include: The difficulties encountered in the extraction of the required data set through Computer Assisted Auditing Techniques (CAATs) to facilitate our testing of the Authority’s manual journal transactions; The appropriateness of inclusion of transactions as Contingent Liabilities; The calculation of the Minimum Revenue Provision and the appropriate inclusion of finance leases within this calculation and how it is reported to members; and The inclusion of an accrual for over claimed benefit subsidy. Please note that this report will be sent to the Audit Commission in accordance with the requirements of their standing guidance. We would also like to take this opportunity to express our thanks for the co-operation and assistance we have received from the management and staff of the Authority throughout our work. 4 North Norfolk District Council Audit Approach ISA (UK&I) 260 requires us to communicate to you relevant matters relating to the audit of the financial statements sufficiently promptly to enable you to take appropriate action. In the table below we have detailed the risks and planned responses shown in our March audit plan, as updated for the work we have subsequently performed. Audit plan risk Significant Risks Fraud and 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. This includes consideration of the risk that management may override controls in order to manipulate the financial statements. Recognition of income and expenditure Under ISA (UK&I) 240 there is a (rebuttable) presumption that there are risks of fraud in revenue recognition. We extend this presumption to the recognition of expenditure in local government. Proposed Audit Approach Outcome We will perform procedures to: test the appropriateness of journal entries; review accounting estimates for biases and evaluate whether circumstances producing any bias, represent a risk of material misstatement due to fraud; evaluate the business rationale underlying significant transactions; perform ‘unpredictable’ procedures; and perform other audit procedures if necessary. A key process in this area is the authorisation and supporting evidence for journals. We found no exceptions in relation to our testing of journals. 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 We have reviewed the work of internal audit around key financial systems controls. We have been able to place the planned level of reliance on the work of internal audit. We have completed unpredictable procedures as referred to in our audit plan without additional indicators of fraud or management override being detected. These consisted of: review of transactions under the waste management contract. We have reviewed management estimates as part of our audit procedures. Our audit testing did not identify any areas of management bias in respect of estimation techniques and we are not minded to challenge the appropriateness of estimates used in the accounts. We have considered the accounting policies adopted by the Authority and subjected income and expenditure to the appropriate level of testing to identify any material misstatement. This included testing of selected income and expenditure transactions, review of journals and also testing on some smaller value income and expenditure items. 5 North Norfolk District Council Authority Accounting. Other Risks Heritage assets For the first time in the 2011/12 Statement of Accounts, the Code of Practice on Local Authority Accounting in the United Kingdom requires authorities to present information about the heritage assets that they hold. Where it is practicable to obtain a valuation (at a cost commensurate with the benefits to users of the Statement of Accounts), the Code also now requires material amounts of heritage assets to be carried in the Balance Sheet at that valuation. Valuation and accounting treatment of leases The Council continues to be party to several significant and complex leases. The Council changed the supplier of its waste management contract from 01 April 2011. The terms of this new arrangement will need to be carefully considered against the requirements of International Financial Reporting Interpretations Committee (IFRIC) 4 – Determining whether an arrangement contains a lease and, if applicable, International Accounting Standard (IAS) 17 – Leases. Redundancy costs As a result of continuous increase in pressure on budgets, the Council will need to continue to review its current workforce. Any termination of contracts, in particular in relation to senior staff could be high profile and are likely to result in initial one-off costs. We will assess the approach taken by the Council to implement the new accounting requirements, including the methods used to identify and assess heritage assets. We will assess whether the Council has made all appropriate accounting disclosures in relation to heritage assets, including carrying material heritage assets in the Balance Sheet. We will assess the approach taken by the Council in determining the value and classification of leases. We found that the Authority had followed its accounting policies in accounting for transactions and that these accounting policies were appropriate and in line with the CIPFA Code. We have considered and are not minded to challenge the approach taken by the Council in identifying heritage assets. Our review of the treatment of heritage assets identified a minor disclosure issue which has been adjusted for by the Council. We have considered significant lease transactions as part of our audit approach and found no significant matters to report to you in this context. We will evaluate and test a sample of leases to determine whether the Council’s approach to leases has been followed and applied correctly. We will review any significant redundancies, early retirement, severance and ex-gratia payments as part of our audit work on the accounts including, where appropriate the Council’s arrangements with respect to consideration of the legality and value for money of such payments. We have reviewed the exit packages disclosed in the Council’s financial statements. At the time of writing this work is ongoing and we will therefore provide members with a verbal update at the meeting on 18 September 2012 6 North Norfolk District Council Savings Plans The Council continues to need to achieve significant savings to meet its medium term financial plan, following a reduction in central government funding. We will continue to monitor the Council’s progress against its savings plans and budgets and the actions it is taking to identify future savings. We have reviewed the Authority’s savings plans as part of our value for money conclusion work. We identified the following matters: Whilst the Council is using reserves in the short term to balance its budgets, it is of the view that a prudent level of reserves remains on the balance sheet. There remain significant challenges in maintaining the medium term financial stability of the Council. In particular, the Council should: - Ensure savings are identified early on and action taken to address budgetary shortfalls; - Consider very closely the use of reserves in funding revenue expenditure; - Ensure members remain actively involved in the budget setting process so that the budget is aligned to the strategic direction of the Council. Our work has not identified any current indications that the Council is not putting in place appropriate procedures to address these points. 7 North Norfolk District Council Significant audit and accounting matters Accounts We have completed the audit of the financial statements in line with current Auditing Standards apart from the following: completion of our testing of exit packages; review of the explanatory foreword to ensure consistency with the Code and the rest of the accounts; conclusion of our testing of NNDR balances; completion of our testing of related parties; completion of our testing of members allowances; completion of our internal review and quality control procedures; our review of the final version of the financial statements with all of the agreed changes having been made; approval of the financial statements by the Audit Committee; and receipt of all relevant signed statements and the management representation letter. We will update the Audit Committee on our progress at its meeting on 18 September 2012. Accounting issues Testing of Manual Journals As part of our planned audit approach, we have engaged with our Data Assurance team to assist us in extracting a complete list of manual journals from the Authority’s general ledger system. This process was not as effective as it could have been as the Authority could not provide the data extracted in the format required. At the time of writing this report, we are working with the Authority to get to a satisfactory outcome. We will provide the committee with a verbal update at its meeting on 18 September 2012. Contingent Liabilities The Authority included a number of contingent liabilities within its draft financial statements. We have considered the appropriateness of these items under the relevant accounting standards. The Authority has agreed to make a small number of changes to the disclosure of contingent liabilities to comply with the prevailing accounting standards. Minimum Revenue Provision The Authority is required to report annually to members its MRP position under the CIPFA Prudential Code. Whilst the Authority is ‘debt free’, it does have a number of finance leases in order to deliver the waste management contract with Kier. These leases were excluded from the report to members in February 2012. The Authority has agreed that it will report the MRP including the leases going forward and we have confirmed that the provision in the financial statements has been calculated in line with the relevant guidance. Housing Subsidy liability A liability of £103,000 was included within the Authority’s draft financial statements in relation to the potential claw back of housing and Council Tax subsidy income received by Authority from the Department of Work and Pensions (DWP). The Authority based this amount on 0.5% of the subsidy within the 2011/12 claim. However, the Authority is unable to provide evidence to demonstrate that the DWP had clawed back, or intended to claw back or retain, subsidy due as a result of exceptions noted in previous audit certifications of the Housing and Council Tax Benefit Subsidy claim. In addition, the Council could not provide any evidence to support the liability at 0.5% of 2011/12 subsidy due. 8 North Norfolk District Council We do not consider that the £103,000 creditor meets the definition of liability because there is no contractual obligation. The authority has agreed to adjust its accounts for this, thus creating a reserve for this potential liability. Valuation of Property The Council’s accounting policy is for assets classified as infrastructure, community assets and assets under construction to be valued at depreciated historical cost with all other assets being valued at fair value in existing use. The Council arranges for periodic, professional valuations of property every five years with interim valuations considered in the intervening years to identify any factors that may indicate whether the fair value stated in the Balance Sheet might be materially misstated. The Council’s properties were valued by NPS or the Council’s internal valuers. In estimating the fair value to be included in the 2011/12 accounts, management has utilised the expertise of the Council’s internal valuers. However, the assumptions used by these experts remain the responsibility of management. Our internal valuers have reviewed the work performed by the Council. We are currently not minded to challenge the Council’s property valuations. Misstatements and significant audit adjustments We are required to report to you all uncorrected misstatements which we have identified during the course of our audit, other than those of a trivial nature (which we have agreed with you are those below £50,000). There are no such misstatements to report to you. We have also brought to your attention the misstatement relating to the DWP liability earlier in this report which has been corrected by management but which we consider you should be aware of in fulfilling your governance responsibilities. Significant accounting principles and policies Significant accounting principles and policies are disclosed in the notes to the financial statements. We will ask the Audit Committee to represent to us that they have considered the selection of, or changes in, significant accounting policies and practices that have, or could have, a material effect on the entity's financial statements. Judgements and accounting estimates The following significant judgments and accounting estimates were used in the preparation of the financial statements: Property, Plant and Equipment - Depreciation and Valuation – The Council charges depreciation based on an estimate of the Useful Economic Lives for the majority of Property, Plant and Equipment (PPE). This involves a degree of estimation. The Council also values PPE in accordance with its accounting policies to ensure that the carrying value is appropriate. This involves some judgement and reliance on the Council’s internal valuers. Bad Debt Provision – The Bad Debt Provision for sundry debtors is calculated on the basis of age and an assessment of the potential recoverability of invoices. There is an inherent level of judgement involved in calculating these provisions and the Council relies on the knowledge of the Departments for information on specific transactions. Accruals - The Council raises accruals for expenditure where an invoice has not been raised or received at the year end, but there is a known liability to be met which relates to the current year. This involves a degree of estimation. Provisions: Because provisions are liabilities of an uncertain timing or amount, there is an inherent level of judgement to be applied. Pensions: The Council relies on the work of an actuary in calculating these balances. 9 North Norfolk District Council Provision for accumulated absences - The Council calculates its accrual for untaken holiday and employment benefits at the year-end based on returns completed by managers. We will ask you to represent to us that you are satisfied with the assumptions made in arriving at these judgements and estimates in the accounts. Disagreements with management There have been no disagreements with management during the course of the audit which individually or in aggregate could be significant to your financial statements or our audit report. Management representations The final draft of the representation letter that we are requesting management to sign and those charged with governance to approve is attached in Appendix 1. Whilst much of this letter is standard for local government entities, we have specifically asked the Audit Committee to confirm the values attributed to the Authority’s property, plant and equipment in the financial statements are not materially misstated. Related parties There are no significant related party matters to be communicated. Audit independence We confirm that, in our professional judgment, as at the date of this document, we are independent of the Authority, within the meaning of UK regulatory and professional requirements and that the objectivity of the audit engagement leader and the audit staff is not impaired. Accounting systems and systems of internal control You have to develop and implement systems of internal financial control and put in place proper arrangements to monitor their adequacy and effectiveness. As auditors, we review these arrangements for the audit of the financial statements and our review of the Annual Governance Statement. We have no significant control issues to bring to your attention. We have included a report of minor internal control issues in Appendix 2 to this report. 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’. We reviewed the draft AGS to consider whether it complied 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. We found no areas of concern to report in this context. Economy, efficiency and effectiveness Our value for money code responsibility requires us to carry out sufficient and relevant work in order to conclude on whether you have put in place proper arrangements to secure economy, efficiency and effectiveness in the use of resources. In accordance with guidance issued by the Audit Commission, in 2011/12 our conclusion is based on two criteria: The organisation has proper arrangements for securing financial resilience; and The organisation has proper arrangements for challenging how you secure economy, efficiency and effectiveness. As was the case last year, but unlike in previous years, we have not had to reach a scored judgment on these criteria and the Audit Commission has not developed ‘key lines of enquiry’ for each criteria. Instead, we have 10 North Norfolk District Council determined a local programme of audit work based on our audit risk assessment, informed by these criteria and our statutory responsibilities. We anticipate issuing an unqualified value for money conclusion. Risk of Fraud We discussed with the Audit Committee their understanding of the risk of fraud and corruption and any instances thereof when presenting our Audit Plan. In presenting this report to the Audit Committee we seek members’ confirmation that there have been no changes to their view of fraud risk and that no additional matters have arisen that should be brought to our attention. A specific confirmation from management in relation to fraud is included in the letter of representation. 11 North Norfolk District Council Fees update Fees update for 2011/12 We reported our fee proposals as part of the Audit Plan for 2011/12. 2011/12 proposed Financial Statements Whole of Government Accounts Use of Resources Grant Certification Total £118,750 £48,650 £167,400 As noted above, our audit is still ongoing at the time of writing this report. Until we have finalised our work, we are not in a position to provide members with an update on actual fees for 2011/12. We will include this analysis as part of our Annual Audit Letter to be issued later in the year. Fees proposal for 2012/13 We are able to report to you the 2012/13 initial fee proposals as set out by the Audit Commission on its website (http://www.audit-commission.gov.ukaudit-regime/audit fees/201213fees/pages/201213 feesandworkprogramme.aspx ). The scale fee for North Norfolk District Council is as follows: 2012/13 Scale Fee Financial Statements Whole of Government Accounts Use of Resources Grant Certification Total 71,250 36,000 107,250 This represents an overall reduction of 36%. At this stage, we are not aware of any factors that would cause our fees to vary from the scale fee shown. The Audit Committee may also wish to be aware that we are no longer required to rebate a proportion of our audit fee to the Audit Commission for 2012/13 as we have done in previous years. This accounts for the apparent disparity in fees. 12 [Date] Appendices 13 North Norfolk District Council Appendix 1: Letter of representation 18 September 2012 To: PricewaterhouseCoopers LLP The Atrium St Georges Street Norwich NR3 1AG Your Ref: JCR/CK Dear Sirs This representation letter is provided in connection with your audit of the Statement of Accounts of North Norfolk District Council (the “Authority”) for the year ended 31 March 2012 for the purpose of expressing an opinion as to whether the Statement of Accounts gives a true and fair view, and has been properly prepared in accordance with the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom 2011/12 and the Service Reporting Code of Practice 2011/12. My responsibilities as Chief Financial Officer for preparing the financial statements are set out in the Statement of Responsibilities for the Statement of Accounts. I am also responsible for the administration of the financial affairs of the Authority I also acknowledge that I am responsible for making accurate representations to you. I confirm that the following representations are made on the basis of enquiries of other chief officers and members of North Norfolk District Council with relevant knowledge and experience and, where appropriate, of inspection of supporting documentation sufficient to satisfy myself that I can properly make each of the following representations to you. I confirm, to the best of my knowledge and belief, and having made the appropriate enquiries, the following representations: Financial Statements I have fulfilled my responsibilities, for the preparation of the Statement of Accounts in accordance with the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom; in particular the financial statements give a true and fair view in accordance therewith. Where instances of non compliance with the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom have been identified within the Authority’s accounting policies, I confirm that the policies adopted are the most appropriate to give a true and fair view for the authority's particular circumstances, as required by the aforementioned Code. All transactions have been recorded in the accounting records and are reflected in the financial statements. Significant assumptions used by the Authority in making accounting estimates, including those surrounding measurement at fair value, are reasonable. All events subsequent to the date of the financial statements for which the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom requires adjustment or disclosure have been adjusted or disclosed. 14 North Norfolk District Council Information Provided I have taken all the steps that I ought to have taken in order to make myself aware of any relevant audit information and to establish that you (the Authority's auditors) are aware of that information. I have provided you with: access to all information of which I am aware that is relevant to the preparation of the financial statements such as records, documentation and other matters, including minutes of the Council, relevant committees including the pension fund management board and other relevant management meetings; additional information that you have requested from us for the purpose of the audit; and unrestricted access to persons within the Authority from whom you determined it necessary to obtain audit evidence. So far as I am aware, there is no relevant audit information of which you are unaware. Fraud and non-compliance with laws and regulations I acknowledge responsibility for the design, implementation and maintenance of internal control to prevent and detect fraud. I have disclosed to you the results of our assessment of the risk that the financial statements may be materially misstated as a result of fraud. I have disclosed to you all information in relation to fraud or suspected fraud that we are aware of and that affects the Authority and involves: management; employees who have significant roles in internal control; or others where the fraud could have a material effect on the financial statements. I have disclosed to you all information in relation to allegations of fraud, or suspected fraud, affecting the Authority’s financial statements communicated by employees, former employees, analysts, regulators or others. I have disclosed to you all known instances of non-compliance or suspected non-compliance with laws and regulations whose effects should be considered when preparing financial statements. I am not aware of any instances of actual or potential breaches of or non-compliance with laws and regulations which provide a legal framework within which the Authority conducts its business and which are central to the Authority’s ability to conduct its business or that could have a material effect on the financial statements. I am not aware of any irregularities, or allegations of irregularities including fraud, involving members, management or employees who have a significant role in the accounting and internal control systems, or that could have a material effect on the financial statements. Related party transactions I confirm that we have disclosed to you the identity of the Authority’s related parties and all the related party relationships and transactions of which we are aware. 15 North Norfolk District Council Related party relationships and transactions have been appropriately accounted for and disclosed in accordance with the requirements of Section 3.9 of the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom. We confirm that we have identified to you all senior officers, as defined by the Accounts and Audit Regulations 2011, and included their remuneration in the disclosures of senior officer remuneration. Employee Benefits I confirm that the Authority has made you aware of all employee benefit schemes in which employees of the Authority participate. Contractual arrangements/agreements All contractual arrangements (including side-letters to agreements) entered into by the Authority have been properly reflected in the accounting records or, where material (or potentially material) to the financial statements, have been disclosed to you. Litigation and claims I have disclosed to you all known actual or possible litigation and claims whose effects should be considered when preparing the financial statements and such matters have been appropriately accounted for and disclosed in accordance with the Code of Practice on Local Authority Accounting in the United Kingdom. Taxation I have complied with UK taxation requirements and have brought to account all liabilities for taxation due to the relevant tax authorities whether in respect of any indirect taxes. I am not aware of any non-compliance that would give rise to additional liabilities by way of penalty or interest and I have made full disclosure regarding any Revenue Authority queries or investigations that we are aware of or that are ongoing. In particular: In connection with any tax accounting requirements, I am satisfied that our systems are capable of identifying all material tax liabilities and transactions subject to tax and have maintained all documents and records required to be kept by the relevant tax authorities in accordance with UK law or in accordance with any agreement reached with such authorities. I have submitted all returns and made all payments that were required to be made (within the relevant time limits) to the relevant tax authorities including any return requiring us to disclose any tax planning transactions that have been undertaken for the Authority’s benefit or any other party’s benefit. I am not aware of any taxation, penalties or interest that are yet to be assessed relating to either the Authority or any associated company for whose taxation liabilities the Authority may be responsible. Pension fund assets and liabilities All known assets and liabilities including contingent liabilities, as at the 31 March 2012, have been taken into account or referred to in the financial statements. Details of all financial instruments, including derivatives, entered into during the year have been made available to you. Any such instruments open at the 31 March 2012 have been properly valued and that valuation incorporated into the financial statements. 16 North Norfolk District Council Bank accounts I confirm that we have disclosed all bank accounts to you including those that are maintained in respect of the pension fund. Going Concern An assessment has been made of the financial health of the Authority for a period of at least one year from the approval of the financial statements. Accounting Estimates Regarding the accrual for uncompensated absences, an accounting estimate that was recognised in the financial statements: The Authority has used appropriate measurement processes, including related assumptions and odels, in determining the accounting estimate in the context of the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom. Assets and liabilities All known assets and liabilities including contingent liabilities, as at the 31 March 2012, have been taken into account or referred to in the financial statements. Details of all financial instruments, including derivatives, entered into during the year have been made available to you. Any such instruments open at the 31 March 2012 have been properly valued and that valuation incorporated into the financial statements. When appropriate, open positions in off-balance sheet financial instruments have also been properly disclosed in the financial statements. The value at which assets and liabilities are recorded in the net assets statement is, in the opinion of the Authority, the market value. We are responsible for the reasonableness of any significant assumptions underlying the valuation, including consideration of whether they appropriately reflect our intent and ability to carry out specific courses of action on behalf of the pension fund. Any significant changes in those values since the date of the financial statements have been disclosed to you. The Authority has no plans or intentions that may materially alter the carrying value and where relevant the fair value measurements or classification of assets and liabilities reflected in the financial statements. In my opinion, on realisation in the ordinary course of the business the current assets in the balance sheet are expected to produce no less than the net book amounts at which they are stated. The Authority has no plans or intentions that will result in any excess or obsolete inventory, and no inventory is stated at an amount in excess of net realisable value. The Authority has satisfactory title to all assets and there are no liens or encumbrances on the Authority's assets, except for those that are disclosed in the financial statements. I confirm that the current accounting for government grants whilst not in accordance with the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom is the most appropriate treatment to give a true and fair view for the authority's particular circumstances, as required by the aforementioned Code. I confirm that we have carried out impairment reviews appropriately, including an assessment of when such reviews are required, where they are not mandatory. I confirm that we have used the appropriate assumptions with those reviews. 17 North Norfolk District Council Using the work of experts I agree with the findings of our valuation experts in evaluating the value of our non-current assets and have adequately considered the competence and capabilities of the experts in determining the amounts and disclosures used in the preparation of the financial statements and underlying accounting records. The Authority did not give or cause any instructions to be given to experts with respect to the values or amounts derived in an attempt to bias their work, and I am not otherwise aware of any matters that have had an impact on the objectivity of the experts. Retirement Benefits All significant retirement benefits that Authority is committed to providing, including any arrangements that are statutory, contractual or implicit in Authority’s actions, wherever they arise, whether funded or unfunded, approved or unapproved, have been identified and accounted for in accordance with the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom and disclosed. All settlements and curtailments in respect of retirement benefit schemes have been identified and properly accounted for. The following actuarial assumptions underlying the valuation of retirement benefit scheme liabilities are consistent with my knowledge of the business and in my view would lead to the best estimate of the future cash flows that will arise under the scheme liabilities: Rate of Inflation Rate of Increase in Salaries Rate of Increase in Pensions Discount Rate Expected Return on Assets Longevity at 65 for current pensioners Men Women Longevity at 65 for future pensioners Men Women 3.3% 4.8% (1% until 2015) 2.5% 4.8% 5.5% 21.2 years 23.4 years 23.6 years 25.8 years We have considered the assumptions made by our actuary in relation to the take-up of the entitlement to a lump sum under Regulation 3 of the Local Government Pension Scheme (Amendment) Regulations 2006 (Statutory Instrument 2006/966), and, in our view, the assumption of 50% take-up reflected in the accounts is the most appropriate assumption for the preparation of our financial statements and leads to the best estimate of scheme liabilities. Financial Instruments All embedded derivatives and embedded leases have been identified and appropriately accounted for under the CIPFA/LASAAC Code of Practice on Local Authority Accounting in the United Kingdom. Where we have assigned fair values to financial instruments, we confirm that the valuation techniques, the inputs to those techniques and assumptions that have been made are appropriate, and reflect market conditions at the balance sheet date, and are in line with the business environment in which we operate. 18 North Norfolk District Council As minuted by the Audit Committee at its meeting on 18 September 2012 Chief Financial Officer For and on behalf of North Norfolk District Council Date: 19 North Norfolk District Council Appendix 2: Control weaknesses and deficiencies Ref 1 Description Password Parameters The password parameters for eFinancials do not meet the requirements of GSX Connect (also known as CoCo). The password parameters for Civica do not meet the requirements of the Authority’s own ICT security policy. 2 ITGC – Back Ups No recoverability testing has been undertaken or necessary in 2011/12. 3 ITGC – Back Ups We were unable to obtain reports to verify that back ups are run for the Civca system and the Network on a regular scheduled basis. 4 Collection Fund Reconciliation The council reconciles its council tax cash collections and refunds to the council tax system on a monthly basis however this reconciliation is not evidenced as having taken place. Recommendation Management Response Password parameters, should be set as follows: 20 passwords should be remembered; Password expiry time period should be a maximum of 90 days; Minimum password length should be 7 characters; and Passwords should have at least one alpha numeric digit. Efin password parameters: 10 remembered; Max 30 days; Minimum length 6; At least one alpha numeric. Recoverability testing should be run on a regular basis to test the integrity of back ups. A script to transfer information from the live system to the test system, is run regularly which provides a mitigating control. Reports should be retained to evidence that back ups have taken place. Records and reports are retained to verify that backups have been run for the old Civica system (now read only) and the Network. These can be inspected if required. A formal reconciliation process should be put into operation. Prior to the change of the cash receipting system monthly three way reconciliations (Cash Receipting System – General Ledger – Revenues System) were being completed. Some initial problems with reporting from the new (cash receipting) system meant that only two way reconciliations were being carried out. This has been rectified and monthly reconciliations are now being carried out which are reviewed by the Revenues Manager. An annual reconciliation will be completed for the position at 31 March. Civica parameters: 20 remembered; Max 30 days; Minimum length 7; At least one alpha numeric. Efin upgrade is due to take place November 2012, password parameters will be reviewed as part of the upgrade. 20 North Norfolk District Council 5 Officers’ Emoluments In previous years, details of the members of staff paid over £55k from the GL were compared to Payroll information to ensure all details were accurately taken from the GL. This was not completed this year which resulted in discrepancies. Amendments have subsequently been made to the accounts to ensure appropriate disclosure. Officers’ emoluments data per the GL should be reconciled to the payroll system. Agreed 21 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. ©2012 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.