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190607FinanceCtteePaper3Annex11901250CNPAFinancialregulationsandprocedures

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Fin­ance & Deliv­ery Com­mit­tee Paper 3 Annex I 7/06/19

CAIRNGORMS NATION­AL PARK AUTHOR­ITY ÙGH­DAR­RAS PÀIRC NÀISEANTA A’ MHON­AIDH RUAIDH

Fin­an­cial Reg­u­la­tions for the Cairngorms Nation­al Park Author­ity (CNPA) (updated 25 Janu­ary 2019)

FORE­WORD

To con­duct its busi­ness effect­ively, an organ­isa­tion needs to ensure that it has sound fin­an­cial man­age­ment sys­tems in place and that they are strictly fol­lowed. Part of this pro­cess is the estab­lish­ment of fin­an­cial reg­u­la­tions and pro­ced­ures which set out the fin­an­cial policies of the organisation.

Fin­an­cial reg­u­la­tions make good busi­ness sense. The Fin­an­cial Memor­andum between our Spon­sor­ing Depart­ment with­in Scot­tish Gov­ern­ment, the Nat­ur­al Resources Divi­sion, Envir­on­ment & Forestry Dir­ect­or­ate, and the Park Author­ity makes it a con­di­tion of grant-in-aid that the Park Author­ity ensures that it has a sound sys­tem of intern­al fin­an­cial man­age­ment and con­trol. Fin­an­cial reg­u­la­tions and pro­ced­ures are a core com­pon­ent of such a sys­tem. Sim­il­arly, both the Intern­al and Extern­al Aud­it­ors are required to give an assur­ance that we have fully doc­u­mented fin­an­cial pro­ced­ures in place.

This set of Fin­an­cial Reg­u­la­tions will con­tin­ue to evolve as the Author­ity matures. Twice-yearly, addi­tions and amend­ments will be con­sol­id­ated into the manu­al and all staff advised. If you have any sug­ges­tions for addi­tions, changes or cla­ri­fic­a­tion please advise either the Fin­ance Man­ager or myself.

Dav­id Camer­on Dir­ect­or of Cor­por­ate Services

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CON­TENTS

TER­MIN­O­LOGY FIN­AN­CIAL REG­U­LA­TIONS 4 A GEN­ER­AL PRO­VI­SIONS 4 | Back­ground 4 2 Status of Fin­an­cial Reg­u­la­tions 4 B COR­POR­ATE GOV­ERNANCE 6 3 The Board 6 4 Com­mit­tee Struc­ture 6 5 Account­able Officer 7 6 Oth­er Seni­or Man­agers with Fin­an­cial Respons­ib­il­ity 8 7 Risk Man­age­ment 9 8 Whis­tleblow­ing || 9 Code of Con­duct || C FIN­AN­CIAL MAN­AGE­MENT AND CON­TROL 13 10 Fin­an­cial Plan­ning 13 || Fin­an­cial Con­trol 14 12 Account­ing Arrange­ments 15 13 Audit Require­ments 17 14 Treas­ury Man­age­ment 19 Appendix I Del­eg­ated Author­ity Lim­its Mat­rix 20

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TER­MIN­O­LOGY The fol­low­ing gen­er­al terms have been used in this guide.

AUDIT AND RISK COMMITTEE

A com­mit­tee, inde­pend­ent of exec­ut­ive respons­ib­il­ity and the Man­age­ment Team, which advises the Board on issues related to intern­al audit, extern­al audit and fin­an­cial con­trol. It receives reports from both the intern­al and extern­al aud­it­ors and reports annu­ally to the full Board.

BOARD

The Authority’s gov­ern­ing body is the Board com­pris­ing 19 mem­bers (7 mem­bers dir­ectly appoin­ted by Scot­tish Min­is­ters, 7 mem­bers appoin­ted by Scot­tish Min­is­ters fol­low­ing nom­in­a­tion by loc­al author­it­ies in the area; and 5 mem­bers elec­ted by a postal bal­lot of the loc­al electorate).

BUDGET HOLD­ER

A mem­ber of staff who has been assigned their own budget. They are account­able for their man­age­ment of the budget and for expendit­ure under­taken, either to their imme­di­ate Head of Ser­vice, or ulti­mately to the Man­age­ment Team.

COR­POR­ATE PLAN

A doc­u­ment that reflects the Park Authority’s stat­utory duties, includ­ing pri­or­it­ies set from time to time by Scot­tish Min­is­ters. It sets out the Park Authority’s key object­ives and per­form­ance tar­gets for the com­ing years as well as review­ing the Authority’s per­form­ance in the pre­ced­ing years. This is form­ally adop­ted by the CNPA Board and the Nat­ur­al Resources Divi­sion, Envir­on­ment & Forestry Dir­ect­or­ate of the Scot­tish Government.

FIN­ANCE AND DELIV­ERY COMMITTEE

A com­mit­tee, inde­pend­ent of exec­ut­ive respons­ib­il­ity, with del­eg­ated respons­ib­il­ity for fin­an­cial matters.

FUND­ING BODY

The Park Author­ity receives Grant-in-Aid fund­ing from the Nat­ur­al Resources Divi­sion, Envir­on­ment & Forestry Dir­ect­or­ate, of the Scot­tish Government.

MAN­AGE­MENT TEAM

The Man­age­ment Team con­sists of the Chief Exec­ut­ive and three dir­ect­ors (Dir­ect­or of Cor­por­ate Ser­vices, Dir­ect­or of Con­ser­va­tion and Vis­it­or Exper­i­ence, and Dir­ect­or of Plan­ning and Rur­al Devel­op­ment) and gen­er­ally meets fortnightly.

NON-DEPART­MENT­AL PUB­LIC BODY (NDPB)

The Park Author­ity is an Exec­ut­ive NDPB.

OPER­A­TION­AL PLAN

This sets out in detail key tar­gets and mile­stones for the cur­rent year. It is derived from, and should be con­sist­ent with, object­ives and per­form­ance tar­gets set out in the Cor­por­ate Plan.

SPON­SOR­ING DEPARTMENT

For the Park Author­ity this is the Nat­ur­al Resources Divi­sion, Envir­on­ment & Forestry Dir­ect­or­ate, Scot­tish Government.

Each NDPB has a Spon­sor­ing Dir­ect­or­ate with­in Scot­tish Gov­ern­ment, with which it liaises closely and com­mu­nic­ates with Min­is­ters through. Min­is­ters and the Spon­sor­ing Dir­ect­or­ate will set broad policy object­ives and frame­works with­in which the CNPA is expec­ted to operate.

FIN­AN­CIAL REG­U­LA­TIONS AND PRO­CED­URESGEN­ER­AL PROVISIONS

1.1 Back­ground The Park Author­ity is an Exec­ut­ive NDPB. Its stat­utory respons­ib­il­it­ies and func­tions are set out in the Nation­al Parks (Scot­land) Act 2000. The Park Author­ity is account­able to its Spon­sor­ing Dir­ect­or­ate who, in turn, is account­able to Scot­tish Ministers.

1.2 The Fin­an­cial Memor­andum between Nat­ur­al Resources Divi­sion, Envir­on­ment & Forestry Dir­ect­or­ate and the Park Author­ity sets out the terms and con­di­tions on which grant is made. The gov­ern­ing body is respons­ible for ensur­ing that con­di­tions of grant are met. As part of this pro­cess, the Park Author­ity must adhere to the fund­ing body’s audit code of prac­tice, which requires it to have sound sys­tems of fin­an­cial and man­age­ment con­trol. The fin­an­cial reg­u­la­tions of the Park Author­ity form part of this over­all sys­tem of accountability.

1.3 The Fin­an­cial Memor­andum spe­cific­ally dir­ects the Park Author­ity to sat­is­fy the require­ments con­tained in the Scot­tish Pub­lic Fin­ance Manu­al and oth­er con­di­tions as the Scot­tish Min­is­ters or Spon­sor Dir­ect­or­ate may impose. 2

2.1 Status of Fin­an­cial Reg­u­la­tions This doc­u­ment sets out the Park Authority’s fin­an­cial reg­u­la­tions and procedures.

It trans­lates into prac­tic­al guid­ance the Park Authority’s broad policies relat­ing to fin­an­cial con­trol. This doc­u­ment was ori­gin­ally approved by the Audit Com­mit­tee in August 2005. It applies to all work under­taken by any part of the Park Authority.

2.2 These fin­an­cial reg­u­la­tions are sub­or­din­ate to the Park Authority’s found­ing legis­la­tion and to any restric­tions con­tained with­in the Park Authority’s Fin­an­cial Memor­andum. A copy is avail­able from Fin­ance for review.

2.3 The pur­pose of these fin­an­cial reg­u­la­tions is to provide con­trol over the total­ity of the Park Authority’s resources and provide the Man­age­ment Team and the Board with assur­ances that the resources are being prop­erly applied for the achieve­ment of the Park Authority’s aims:

2.4 In meet­ing the above aims the Park Author­ity needs to ensure it meets its oblig­a­tions regard­ing: • fin­an­cial viab­il­ity; • achiev­ing value for money and secur­ing best value; • ful­filling its respons­ib­il­ity for the pro­vi­sion of effect­ive fin­an­cial con­trols over the use of pub­lic funds; • ensur­ing that the Park Author­ity com­plies with all rel­ev­ant legis­la­tion; and safe­guard­ing the assets of the Park Authority.

2.5 Com­pli­ance with the fin­an­cial reg­u­la­tions is com­puls­ory for all staff con­nec­ted with the Park Author­ity. A mem­ber of staff who fails to com­ply with the financial

reg­u­la­tions may be sub­ject to dis­cip­lin­ary action under the Park Authority’s dis­cip­lin­ary policy. The Board will be noti­fied of any such breach through the Audit and Risk Com­mit­tee. It is the respons­ib­il­ity of the Dir­ect­ors, and in turn Heads of Ser­vice, to ensure that staff are made aware of the exist­ence and con­tent of the Park Authority’s fin­an­cial reg­u­la­tions. The Fin­ance staff, with­in Cor­por­ate Ser­vices, are avail­able to sup­port this process.

2.6 The Audit and Risk Com­mit­tee is respons­ible for main­tain­ing a con­tinu­ous review of the fin­an­cial reg­u­la­tions, through the Dir­ect­or of Cor­por­ate Ser­vices, and for advising the Board of any addi­tions or changes necessary.

2.7 Any depar­tures from the detailed pro­vi­sions shall be repor­ted to the Board at the earli­est opportunity.

2.8 The Park Authority’s detailed fin­an­cial pro­ced­ures set out pre­cisely how these reg­u­la­tions will be imple­men­ted and are con­tained in the appen­dices. B COR­POR­ATE GOVERNANCE

3 The Board 3.1 The Board has cor­por­ate respons­ib­il­ity for ensur­ing the Park Author­ity ful­fils the aims and object­ives set by the Scot­tish Min­is­ters and for pro­mot­ing the effi­cient and effect­ive use of staff and oth­er resources of the Author­ity in accord­ance with the prin­ciples of Best Value. To this end, and in pur­suit of its wider cor­por­ate respons­ib­il­it­ies, the Board shall:

a) b) c) d) e) estab­lish the over­all dir­ec­tion of the Park Author­ity; keep Scot­tish Min­is­ters informed of any changes that are likely to impact on the stra­tegic dir­ec­tion of the Park Author­ity or on the attain­ab­il­ity of tar­gets; receive and review reg­u­lar fin­an­cial inform­a­tion con­cern­ing the man­age­ment of the Park Author­ity; demon­strate high stand­ards of Cor­por­ate Gov­ernance at all times; provide com­mit­ment and lead­er­ship in the devel­op­ment and pro­mo­tion of Best Value prin­ciples through­out the Park Author­ity; and appoint, with the Scot­tish Minister’s approv­al, a Chief Exec­ut­ive and set per­form­ance object­ives and remu­ner­a­tion terms which give due weight to both the prop­er man­age­ment of pub­lic mon­ies and to the deliv­ery of out­comes in line with Scot­tish Minister’s priorities.

4 Com­mit­tee Struc­ture 4.1 The Board has ulti­mate respons­ib­il­ity for the Park Authority’s fin­ances. The Board del­eg­ates spe­cif­ic powers and pro­cesses to the com­mit­tees and Exec­ut­ive Officers detailed below. These com­mit­tees are account­able to the Board and their remits set out below were reviewed by the Board meet­ing on Septem­ber 2013. Com­mit­tees’ mem­ber­ships, chair­man­ship and remit are reviewed annu­ally (in September).

4.2 Fin­ance and Deliv­ery Com­mit­tee (6 mem­bers, quor­um 3) The Fin­ance and Deliv­ery Committee’s remit includes: a) over­see­ing the pre­par­a­tion of the annu­al budget; b) over­see­ing the pre­par­a­tion of the Cor­por­ate Plan and seek­ing approv­al of c) d) the whole Board pri­or to sub­mis­sion to Scot­tish Min­is­ters; mon­it­or­ing income and expendit­ure dur­ing the year against budget, seek­ing to ensure use of avail­able annu­al resources is max­im­ised; tak­ing over­sight on behalf of the Board of deliv­ery against Cor­por­ate and Oper­a­tion­al Plans, includ­ing review of devel­op­ment, imple­ment­a­tion and report­ing of per­form­ance man­age­ment sys­tems e) f) review­ing ini­tial design and planned out­comes of key pro­jects, ensur­ing pro­ject ini­ti­ation plans are appro­pri­ate to con­trib­ute to deliv­ery of the Authority’s cor­por­ate object­ives; and con­sid­er­ing pro­ject imple­ment­a­tion reviews and to determ­ine what les­sons for improve­ment in pro­ject design and deliv­ery may be applied from find­ings of such reviews to future pro­jects. Staff in attend­ance: by Chief Exec­ut­ive [non-vot­ing], Cor­por­ate Ser­vices Dir­ect­or [non-vot­ing], Fin­ance Man­ager [non-vot­ing].

4.3 Audit and Risk Com­mit­tee (6 mem­bers, quor­um 3) The Audit Committee’s remit includes: a) agree­ing the appoint­ment of the intern­al aud­it­or; b) over­see­ing and mon­it­or­ing the devel­op­ment of the Park Authority’s internal

audit plan (in accord­ance with the Scot­tish Pub­lic Fin­ance Manu­al; c) receiv­ing and con­sid­er­ing reports by the intern­al aud­it­or; review the adequacy of man­age­ment responses to issues iden­ti­fied by audit activ­ity, and to review arrange­ments for mon­it­or­ing imple­ment­a­tion of agreed recom­mend­a­tions; d) mon­it­or­ing the adequacy of the Park Authority’s intern­al con­trol sys­tems; e) con­sid­er­ing the appoint­ment and annu­al fees of extern­al aud­it­ors, review the f) planned activ­ity of the Park Authority’s extern­al aud­it­ors and to con­sider reports by the extern­al aud­it­or on the annu­al accounts and oth­er mat­ters; over­see­ing the Park Authority’s arrange­ments for ensur­ing use of resources eco­nom­ic­ally, effi­ciently and effect­ively (as required by s19 of the Nation­al Parks (Scot­land) Act 2000), and arrange­ments to com­ply with guid­ance on deliv­ery of best value; g) over­see­ing the Park Authority’s arrange­ments for risk man­age­ment and cor­por­ate gov­ernance arrange­ments; h) provid­ing advice to the Account­able Officer on com­ple­tion of the i) Gov­ernance State­ment, and to con­sider any wider issues arising on the Park Authority’s final accounts pri­or to their being signed by the Account­able Officer; review­ing major find­ings of oth­er rel­ev­ant audit reports of Par­lia­ment­ary Com­mit­tee find­ings, inso­far as they affect the over­all per­form­ance of the Park Author­ity; and j) review­ing the Park Authority’s work on its organ­isa­tion­al and green­ing plans and the pro­gress of work address­ing cli­mate change issues with­in the Park

Plan. Staff in attend­ance: by Chief Exec­ut­ive [non-vot­ing], Cor­por­ate Ser­vices Dir­ect­or [non- vot­ing], Fin­ance man­ager [non-vot­ing]. Both the intern­al and extern­al aud­it­ors attend as required. Both aud­it­ors have the right of free and con­fid­en­tial access to the Chair of the Audit and Risk Committee.

4.4 Staff­ing and Recruit­ment Com­mit­tee (6 mem­bers, quor­um 3) The Staff­ing and Recruit­ment Committee’s remit includes: a) b) c) d) over­see­ing and mon­it­or­ing the HR (human resources) sys­tems put in place for the Park Author­ity, includ­ing in par­tic­u­lar the pay and grad­ing sys­tem, per­form­ance apprais­al sys­tem and related per­form­ance related pay sys­tem; advising the Dir­ect­or of Cor­por­ate Ser­vices on behalf of the Park Author­ity on the nego­ti­ation of annu­al pay awards; provid­ing an inter­face between staff rep­res­ent­at­ive group(s) and the Board, and play a role in arbit­rat­ing on staff­ing issues as set out in the Park Authority’s policy and pro­ced­ures; and over­see­ing the recruit­ment of seni­or staff (Dir­ect­ors and Chief Exec­ut­ive) includ­ing agree­ing the job descrip­tions, adverts and salary; to take respons­ib­il­ity for inter­view­ing and select­ing the suc­cess­ful can­did­ates, and seek­ing the endorse­ment of the whole Board (and Scot­tish Min­is­ters in the case of the Chief Exec­ut­ive). Staff in attend­ance: Chief Exec­ut­ive [non-vot­ing], Dir­ect­or of Corporate

Ser­vices [non-vot­ing] and Head of Organ­isa­tion­al Devel­op­ment [non- vot­ing] 5 Account­able Officer 5.1 The Chief Exec­ut­ive is the Park Authority’s Account­able Officer respons­ible for the fin­an­cial admin­is­tra­tion of the Park Authority’s affairs. The Account­able Officer is per­son­ally liable for safe­guard­ing the pub­lic funds for which he/​she has charge; for ensur­ing pro­pri­ety and reg­u­lar­ity in the hand­ling of those pub­lic funds; and for the day-to-day oper­a­tions and man­age­ment of the Park Authority.

5.2 Spe­cif­ic respons­ib­il­it­ies of the Account­able Officer are detailed in the Park Authority’s Man­age­ment State­ment. Although the Chief Exec­ut­ive can del­eg­ate the day-to-day admin­is­tra­tion of his/​her Account­able Officer respons­ib­il­it­ies to oth­er Park Author­ity employ­ees, he/​she shall not assign abso­lutely any of the respons­ib­il­it­ies set out in the Man­age­ment State­ment. 6

6.1 Oth­er Seni­or Man­agers with Fin­an­cial Respons­ib­il­ity Dir­ect­or of Cor­por­ate Ser­vices Day-to-day fin­an­cial admin­is­tra­tion is con­trolled by the Dir­ect­or of Cor­por­ate Ser­vices, who is respons­ible to the Chief Exec­ut­ive for: a) pre­par­ing annu­al budgets and fin­an­cial plans; b) pre­par­ing accounts, man­age­ment inform­a­tion, mon­it­or­ing and con­trol of expendit­ure against budgets and all fin­an­cial oper­a­tions; c) pre­par­ing the Park Authority’s annu­al accounts and oth­er financial

state­ments and accounts which the Park Author­ity is required to sub­mit to oth­er bod­ies; d) ensur­ing that the Park Author­ity main­tains sat­is­fact­ory fin­an­cial sys­tems; e) provid­ing pro­fes­sion­al advice on all mat­ters relat­ing to fin­an­cial policies and pro­ced­ures; and f) day-to-day liais­on with intern­al and extern­al aud­it­ors in order to achieve effi­cient processes.

6.2 Oth­er Dir­ect­ors Oth­er Dir­ect­ors are respons­ible to the Chief Exec­ut­ive for fin­an­cial man­age­ment for the areas or activ­it­ies they con­trol. They are advised by the Dir­ect­or of Cor­por­ate Ser­vices in execut­ing their fin­an­cial duties. The Dir­ect­or of Cor­por­ate Ser­vices will also super­vise and approve the fin­an­cial sys­tems they oper­ate, includ­ing the form in which any accounts and fin­an­cial records are kept. Dir­ect­ors are respons­ible for estab­lish­ing and main­tain­ing clear lines of respons­ib­il­ity with­in their Dir­ect­or­ate for all fin­an­cial mat­ters. Where resources are devolved to budget hold­ers, they are account­able to their Head of Ser­vice for their own devolved budget. Appendix I con­tains a mat­rix of levels of del­eg­ated author­ity Oth­er Dir­ect­ors shall provide the Dir­ect­or of Cor­por­ate Ser­vices with such inform­a­tion as may be required to enable: a) com­pil­a­tion of the Park Authority’s fin­an­cial state­ments; b) imple­ment­a­tion of fin­an­cial plan­ning; c) imple­ment­a­tion of audit and fin­an­cial reviews, pro­jects and value for money

stud­ies; and d) appro­pri­ate action to be taken in the event of identi­fy­ing any poten­tial fin­an­cial liab­il­it­ies for the organ­isa­tion arising from their area of responsibility.

6.3 All mem­bers of staff All mem­bers of staff should be aware of and have a gen­er­al respons­ib­il­ity for the secur­ity of the Park Authority’s prop­erty, for avoid­ing loss and for due eco­nomy in the use of resources, and : a) should ensure that they are aware of the Park Authority’s fin­an­cial author­ity lim­its and the val­ues of pur­chases for which quo­ta­tions and tenders are required. These are repro­duced as Appendix 1: Del­eg­ated Author­ity. A sum­mary doc­u­ment list­ing staff mem­bers with del­eg­ated author­ity is main­tained on the CNPA serv­er with­in the Fin­ance Ref­er­ence folder. b) shall make avail­able any rel­ev­ant records or inform­a­tion to the Dir­ect­or of Cor­por­ate Ser­vices or their author­ised rep­res­ent­at­ive in con­nec­tion with the imple­ment­a­tion of the Park Authority’s fin­an­cial policies, these fin­an­cial reg­u­la­tions and the sys­tem of fin­an­cial con­trol. c) shall provide the Dir­ect­or of Cor­por­ate Ser­vices with such fin­an­cial and oth­er inform­a­tion as may be deemed neces­sary, from time to time, to carry out the require­ments of the gov­ern­ing body.

d) shall imme­di­ately noti­fy the Dir­ect­or of Cor­por­ate Ser­vices whenev­er any mat­ter arises which involves, or is thought to involve, irreg­u­lar­it­ies con­cern­ing, inter alia, cash or prop­erty of the park Author­ity. The Dir­ect­or of Cor­por­ate Ser­vices shall take such steps as con­sidered neces­sary by way of invest­ig­a­tion and report, as set out in the Fraud Policy and Response Plan con­tained in the Staff Hand­book. 7

7.1 Risk Man­age­ment The Park Author­ity acknow­ledges the risks inher­ent in its oper­a­tions, and is com­mit­ted to man­aging those risks that pose a sig­ni­fic­ant threat to the achieve­ment of its planned object­ives and fin­an­cial health. Detailed guid­ance on the level of risk con­sidered to be acceptable/​unacceptable by the Park Author­ity will be set out in a sep­ar­ate risk man­age­ment strategy.

7.2 The Board has over­all respons­ib­il­ity for ensur­ing there is a risk man­age­ment strategy and a com­mon approach to the man­age­ment of risk through­out the Park Author­ity, through the devel­op­ment and imple­ment­a­tion with­in the organisation

7.3 of a form­al, struc­tured risk man­age­ment pro­cess. In line with this policy, the risk man­age­ment strategy and sup­port­ing pro­ced­ures include: a) the adop­tion of com­mon ter­min­o­logy in rela­tion to the defin­i­tion of risk and risk man­age­ment; b) the estab­lish­ment of Park Author­ity-wide cri­ter­ia for the meas­ure­ment of risk,

link­ing the threats of their poten­tial impact and the like­li­hood of their occur­rence togeth­er with a sens­it­iv­ity ana­lys­is; c) a decision on the level of risk to be accep­ted, togeth­er with tol­er­ance levels expressed in terms of meas­ur­able out­comes; d) detailed reg­u­lar review at depart­ment or sup­port func­tion level to identi­fy sig­ni­fic­ant risks asso­ci­ated with the achieve­ment of key object­ives and oth­er rel­ev­ant areas; e) devel­op­ment of risk man­age­ment and con­tin­gency plans for all sig­ni­fic­ant risks, to include a des­ig­nated risk own­er’ who will be respons­ible and account­able for man­aging the risk in ques­tion; f) reg­u­lar report­ing to the Audit and Risk Com­mit­tee of all risks above estab­lished tol­er­ance levels; and g) an annu­al review of the imple­ment­a­tion of risk man­age­ment arrange­ments. h) the strategy and pro­ced­ures must be cap­able of inde­pend­ent verification.

7.4 Heads of Ser­vice must ensure that any agree­ments nego­ti­ated with­in their depart­ments with extern­al bod­ies cov­er any leg­al liab­il­it­ies to which the Park Author­ity may be exposed. The Dir­ect­or of Cor­por­ate Ser­vices’ advice should be sought to ensure that this is the case. 8 Whis­tleblow­ing 8.1 Whis­tleblow­ing in the con­text of the Pub­lic Interest Dis­clos­ure Act is the dis­clos­ure by an employ­ee (or oth­er party) about mal­prac­tice in the work­place. A

whis­tleblower can blow the whistle” about crime, civil offences (includ­ing neg­li­gence, breach of con­tract, etc), mis­car­riage of justice, danger to health and safety or the envir­on­ment and the cov­er-up of any of these. It does not mat­ter wheth­er or not the inform­a­tion is con­fid­en­tial and the whis­tleblow­ing can extend to mal­prac­tice occur­ring in the UK and any oth­er coun­try or territory.

8.2 The full pro­ced­ure for whis­tleblow­ing is set out in the Park Authority’s Staff Hand­book which all employ­ees have a copy of. 9 Code of Con­duct 9.1 The Park Author­ity is com­mit­ted to the highest stand­ards of open­ness, integ­rity and account­ab­il­ity. It seeks to con­duct its affairs in a respons­ible man­ner, hav­ing regard to the 7 prin­ciples estab­lished by the Com­mit­tee on Stand­ards in Pub­lic Life (formerly known as the Nolan Com­mit­tee, see Appendix 2), which mem­bers of staff at all levels are expec­ted to observe. In addi­tion, the Park Author­ity expects that staff at all levels will observe its code of con­duct, con­tained in its detailed fin­an­cial pro­ced­ures: a) prob­ity and pro­pri­ety; b) self­less­ness, objectiv­ity and hon­esty; and c) relationships.

9.2 Mem­bers of the Park Author­ity and all staff are required to dis­close interests in the Park Authority’s register of interests main­tained by Cor­por­ate Ser­vices. They will also be respons­ible for ensur­ing that entries in the register relat­ing to them

are kept up to date reg­u­larly and promptly. 9.3 In par­tic­u­lar, no per­son shall be a sig­nat­ory to a Park Author­ity con­tract where he or she also has an interest in the activ­it­ies of the oth­er party.

9.4 Receiv­ing gifts or hos­pit­al­ity It is an offence under the Bribery Act 2010 for mem­bers of staff to accept cor­ruptly any gift or con­sid­er­a­tion as an induce­ment or reward for doing, or refrain­ing from doing, any­thing in an offi­cial capa­city or show­ing favour or dis­fa­vour to any per­son in an offi­cial capa­city. The guid­ing prin­ciples to be fol­lowed by all mem­bers of staff must be: a) the con­duct of indi­vidu­als should not cre­ate sus­pi­cion of any con­flict between their offi­cial duty and their private interest; and b) the action of indi­vidu­als act­ing in an offi­cial capa­city should not give the impres­sion (to any mem­ber of the pub­lic, to any organ­isa­tion with whom they deal or to their col­leagues) that they have been (or may have been) influ­enced by a bene­fit to show favour or dis­fa­vour to any per­son or organ­isa­tion. There­fore, mem­bers of staff should not accept any gifts, rewards or hos­pit­al­ity (or have them giv­en to mem­bers of their fam­il­ies) from any organ­isa­tion or indi­vidu­al with whom they have con­tact in the course of their work that would cause them to reach a pos­i­tion whereby they might be, or might be deemed by oth­ers to have been, influ­enced in mak­ing a busi­ness decision as a con­sequence of accept­ing such hos­pit­al­ity. The fre­quency and scale of hos­pit­al­ity accep­ted should not be

sig­ni­fic­antly great­er than the Park Author­ity would be likely to provide in return. When it is not easy to decide between what is and what is not accept­able in terms of gifts or hos­pit­al­ity, the offer should be declined or advice sought from the rel­ev­ant Head of Ser­vice or the Dir­ect­or of Cor­por­ate Ser­vices. For the pro­tec­tion of those involved, the Dir­ect­or of Cor­por­ate Ser­vices (or oth­er des­ig­nated officer) will main­tain a register of gifts and hos­pit­al­ity received where the value is in excess of £10. Mem­bers of staff in receipt of such gifts or hos­pit­al­ity are obliged to noti­fy the Dir­ect­or of Cor­por­ate Ser­vices promptly.

C FIN­AN­CIAL MAN­AGE­MENT AND CON­TROL 10 Fin­an­cial Plan­ning 10.1 The Man­age­ment Team pre­pares a three-year Cor­por­ate Plan for approv­al by the Board. The Cor­por­ate Plan sets out the goals and actions of the Author­ity to deliv­er of its stat­utory object­ives, meet the Min­is­teri­al frame­works, in pur­su­ance of the Board’s over­all strategy dir­ec­tion. Detailed action plans are evolved from this into an annu­al Oper­a­tion­al Plan. Fin­an­cial plans should be con­sist­ent with the above doc­u­ments approved by the Spon­sor­ing Department.

10.2 Budget object­ives The Spon­sor­ing Dir­ect­or­ate and Park Author­ity Board will, from time to time, set budget object­ives. These will help the Dir­ect­or of Cor­por­ate Ser­vices in coordin­at­ing more detailed fin­an­cial plans for the Authority.

10.3 Resource alloc­a­tion Resources are alloc­ated annu­ally by the Board on the recom­mend­a­tion of the Man­age­ment Team, on the basis of the above object­ives and in line with agreed Cor­por­ate and Oper­a­tion­al Plans. Dir­ect­ors and Heads of Ser­vice are respons­ible for the eco­nom­ic, effect­ive and effi­cient use of resources alloc­ated to them.

10.4 Budget pre­par­a­tion The Dir­ect­or of Cor­por­ate Ser­vices is respons­ible for pre­par­ing each year an annu­al budget for con­sid­er­a­tion by the Fin­ance and Deliv­ery Com­mit­tee on behalf of the Park Author­ity. The budget should link to monthly cash flow fore­casts for

the year. The Dir­ect­or of Cor­por­ate Ser­vices must ensure that detailed budgets are pre­pared in order to sup­port the resource alloc­a­tion pro­cess and that these are com­mu­nic­ated to Heads of Ser­vice as soon as pos­sible fol­low­ing their approv­al by the Fin­ance and Deliv­ery Com­mit­tee. Dur­ing the year, the Dir­ect­or of Cor­por­ate Ser­vices is respons­ible for sub­mit­ting revised budgets as required to the Fin­ance and Deliv­ery Com­mit­tee for consideration.

10.5 Major expendit­ure Any new aspect of busi­ness which will require an invest­ment in cash resources between £5,001 and £25,000 should be presen­ted for approv­al to the Head of Ser­vice, with evid­ence that a Dir­ect­or has been con­sul­ted. Over £50,000 the order has to be ini­ti­ated by a Head of Ser­vice and approved by a Dir­ect­or. (See Appendix A for the lim­its of del­eg­ated author­ity.) *The cumu­lat­ive value of the sup­ply of a product or ser­vices over 3 years (whole life) from the same sup­pli­er. 11 Fin­an­cial Man­age­ment and Con­trol 11.1 Budget­ary con­trol The con­trol of income and expendit­ure with­in an agreed budget is the respons­ib­il­ity of the des­ig­nated budget hold­er, who must ensure that day-to-day mon­it­or­ing is under­taken effect­ively. Budget hold­ers are respons­ible to their Head of Ser­vice for the income and expendit­ure appro­pri­ate to their budget.

Sig­ni­fic­ant depar­tures from agreed budget­ary tar­gets must be repor­ted imme­di­ately to the Dir­ect­or of Cor­por­ate Ser­vices and the Fin­ance Man­ager by the Head of Ser­vice con­cerned and, if neces­sary, cor­rect­ive action taken.

11.2 Per­form­ance man­age­ment and dis­clos­ure The Man­age­ment team and Heads of Ser­vice are assisted in their duties by man­age­ment inform­a­tion provided by Cor­por­ate Ser­vices on a monthly basis. This includes reports on income and expendit­ure on CORE costs and Oper­a­tion­al Plan per­form­ance at Dir­ect­or­ate, Head of Ser­vice and Pro­rit­ies level. This fin­an­cial inform­a­tion is presen­ted on a month to” and the year to date” basis, show­ing the vari­ance from actu­al to budgeted spend on a high level” basis (ie the expendit­ure head­ings dis­closed in the Annu­al Report and Accounts in the State­ment of Com­pre­hens­ive Net Expendit­ure which are in turn is agreed by the Fin­ance and Deliv­ery Com­mit­tee). Heads of Ser­vice are also provided with ana­lys­is show­ing actu­al to budgeted expendit­ure by month and the remain­ing spend until the end of the fin­an­cial year. Mater­i­al vari­ances on actu­al to budgeted expendit­ure is also report with a brief explan­a­tion on the cir­cum­stances behind the variance.

The Dir­ect­or of Cor­por­ate Ser­vices is also respons­ible for sup­ply­ing peri­od­ic budget­ary reports on all aspects of the Park Authority’s fin­an­cial per­form­ance to the Fin­ance and Deliv­ery Com­mit­tee. These peri­od­ic reports are the same as provided to the Man­age­ment Team Monthly, with addi­tion­al inform­a­tion for clarity.

11.3 Changes to the approved budget Changes pro­posed to the approved budget will be first con­sidered by the Man­age­ment Team and Fin­ance and Deliv­ery Com­mit­tee. 11.4 Virement Virement is the term used for the trans­fer between dif­fer­ent budget allocations.

Virement is del­eg­ated to the Oper­a­tion­al Man­agers Group (OMG) who are allowed to trans­fer a max­im­um of 10% or £10,000 (whichever is the great­er) of the ser­vice budgets most recently agreed by the Board or its Fin­ance Com­mit­tee. Any vari­ation of ser­vice budgets above this level shall require pri­or author­iz­a­tion by the Fin­ance and Deliv­ery Com­mit­tee. The Fin­ance Manger will co-ordin­ate all planned resource trans­fers and report up to date total ser­vice budget alloc­a­tions to Man­age­ment Team and the Fin­ance and Deliv­ery Com­mit­tee for inform­a­tion or approv­al as appro­pri­ate. The Dir­ect­or of Cor­por­ate Ser­vices is also respons­ible for main­tain­ing an up-to- date record of under­spent funds that may be used in this way. The Dir­ect­or of Cor­por­ate Ser­vices is respons­ible for sub­mit­ting requests for virement of resources above £10,000 or 10%, (whichever is the great­er) of budget to the Man­age­ment Team for consideration.

11.5 Fin­an­cial Routines and Pro­ced­ures From time to time advise will be issued from Fin­ance on the account­ing and record­ing or incom­ing resources (grant-in-aid, grants and oth­er income) and

out­go­ing resources (pay­ments gen­er­ally). These routines and pro­ced­ures are sub­ject to con­stant revi­sion and amend­ment and are not con­sidered in detail in this doc­u­ment. Sep­ar­ate guid­ance and advice will be avail­able from Fin­ance on pro­ced­ures cov­er­ing rais­ing an invoice, pro­cure­ment gen­er­ally (with spe­cial­ist advice com­ing from the pro­cure­ment man­ager at the Loch Lomond & Trossachs Nation­al Park Author­ity), expendit­ure jus­ti­fic­a­tion and requis­i­tions, con­tract let­ting and ten­der­ing and the Park Authority’s Stand­ard Terms and Con­di­tions. 12 Account­ing Arrange­ments 12.1 Fin­an­cial year The Park Authority’s fin­an­cial year will run from I April until 31 March in the fol­low­ing year.

12.2 Basis of account­ing The fin­an­cial state­ments are pre­pared under the his­tor­ic­al cost con­ven­tion mod­i­fied to account for the revalu­ation of prop­erty, intan­gible assets and, where mater­i­al, cur­rent asset invest­ments and invent­or­ies to fair value as determ­ined by the rel­ev­ant account­ing stand­ard. 12.3 Format of the fin­an­cial state­ments The fin­an­cial state­ments are pre­pared in accord­ance with the accounts dir­ec­tion issued by Scot­tish Min­is­ters under sec­tion 19(4) of the Pub­lic Fin­ance and Account­ab­il­ity (Scot­land) Act 2000, and in com­pli­ance with the prin­ciples and dis­clos­ure require­ments of the Gov­ern­ment Fin­an­cial Report­ing Manu­al (FReM) which fol­lows Gen­er­ally Accep­ted Account­ing Prac­tice (GAAP) as defined in

Inter­na­tion­al Report­ing Stand­ards as adop­ted by the European Uni­on and the Com­pan­ies Act 2006 to the extent that it is mean­ing­ful and appro­pri­ate in the pub­lic sec­tor con­text. The account­ing policies adop­ted by the Park Author­ity are dis­closed in the note to the annu­al Report and Accounts. Account­ing policies are applied con­sist­ently with items con­sidered mater­i­al in rela­tion to the fin­an­cial statements.

The fin­an­cial state­ments are pre­pared using account­ing policies and, where neces­sary, estim­a­tion tech­niques which are selec­ted as the most appro­pri­ate for the pur­pose of giv­ing a true and fair view in accord­ance with the prin­ciples set out in Inter­na­tion­al Account­ing Stand­ard 8: Account­ing Policies, Changes in Account­ing Estim­ates and Errors. 12.4 Cap­it­al­isa­tion and depre­ci­ation New land and build­ings will be recor­ded in the bal­ance sheet at actu­al build or acquis­i­tion cost. Build­ings will be depre­ci­ated in equal instal­ments over their estim­ated remain­ing use­ful life. Land will not be depreciated.

Expendit­ure incurred on repair, refur­bish­ment or exten­sion of exist­ing build­ings will not be cap­it­al­ised unless it can be demon­strated that the res­ult­ant value of the build­ing, on the basis of depre­ci­ated replace­ment value, is great­er than the cur­rent book value.

Expendit­ure incurred on the acquis­i­tion of assets, oth­er than land and build­ings, will be recor­ded in the bal­ance sheet where the acquis­i­tion cost per item is £500 or more. Assets with a lower value may be cap­it­al­ised with the pri­or approv­al of Cor­por­ate Ser­vices. Assets cap­it­al­ised will be depre­ci­ated at the fol­low­ing rates, com­men­cing in the month of acquis­i­tion: a) ICT assets — over 3 years b) Intan­gible assets and soft­ware over 3 years c) oper­a­tion­al equip­ment — over 5 years d) motor vehicles over 5 years e) park mark­ers — over 25 years f) Depre­ci­ation runs until either the asset is fully depre­ci­ated or dis­posed. Fully depre­ci­ated assets are main­tained on the fixed asset register until i. dis­posed of, ii. is impaired to such an extent that it is not viable to repair, or iii. is ear­marked for san­it­a­tion” pri­or to recyc­ling. 12.5 Account­ing records The Dir­ect­or of Cor­por­ate Ser­vices is respons­ible for the reten­tion of fin­an­cial doc­u­ments. These should be kept in a form that is accept­able to the rel­ev­ant authorities.

The Park Author­ity is required by law to retain ori­gin­al doc­u­ments for sev­en years. These include: a) accounts raised; b) bank state­ments; c) cop­ies of receipts; d) paid cheques; and e) payroll records.

The Dir­ect­or of Cor­por­ate Ser­vices will make appro­pri­ate arrange­ments for the reten­tion of elec­tron­ic records. Mem­bers of staff should ensure that reten­tion arrange­ments com­ply with any spe­cif­ic require­ments of fund­ing organ­isa­tions. 12.6 Tax­a­tion The Dir­ect­or of Cor­por­ate Ser­vices is respons­ible for advising Ser­vice Dir­ect­ors, in the light of guid­ance issued by the appro­pri­ate bod­ies and rel­ev­ant legis­la­tion as it applies, on all tax­a­tion issues rel­ev­ant to the Park Author­ity. The Dir­ect­or of Cor­por­ate Ser­vices will issue instruc­tions to Heads of Ser­vice and staff on com­pli­ance with stat­utory require­ments includ­ing those con­cern­ing VAT, PAYE, Nation­al Insur­ance, and Cor­por­a­tion Tax. The Dir­ect­or of Cor­por­ate Ser­vices is respons­ible for main­tain­ing the Park Authority’s tax records, mak­ing all tax pay­ments, receiv­ing tax cred­its and sub­mit­ting tax returns by their due date as appropriate.

13 Audit Require­ments 13.1 Gen­er­al Extern­al aud­it­ors and intern­al aud­it­ors shall have author­ity to: a) access Park Author­ity premises at reas­on­able times; b) access all assets, records, doc­u­ments and cor­res­pond­ence relat­ing to any fin­an­cial and oth­er trans­ac­tions of the Park Author­ity; c) require and receive such explan­a­tions as are neces­sary con­cern­ing any mat­ter under exam­in­a­tion; d) require any employ­ee of the Park Author­ity to account for cash, stores or any oth­er Park Author­ity prop­erty under his or her con­trol; and e) access records belong­ing to third parties, such as con­tract­ors, when required. The Dir­ect­or of Cor­por­ate Ser­vices is respons­ible for draw­ing up a timetable for final accounts pur­poses and will advise staff and the extern­al aud­it­ors accord­ingly. Once the fin­an­cial state­ments have been agreed with the extern­al aud­it­ors they should be reviewed by the Audit Com­mit­tee on behalf of the Board.

13.2 Extern­al audit The accounts of the Park Author­ity are audited by an aud­it­or appoin­ted by the Aud­it­or Gen­er­al for Scot­land in accord­ance with para­graph 25 (2) of the Nation­al Parks (Scot­land) Act 2000. The primary role of this extern­al audit is to report on the Park Authority’s

fin­an­cial state­ments and to carry out such exam­in­a­tion of the state­ments and under­ly­ing records and con­trol sys­tems as are neces­sary to reach their opin­ion on the state­ments and to report on the appro­pri­ate use of funds. Their duties will be in accord­ance with advice set out in the fund­ing body’s audit code of prac­tice and the Audit­ing Prac­tices Board’s state­ments of audit­ing standards.

13.3 Intern­al audit The intern­al aud­it­or is appoin­ted by the Park Author­ity on the recom­mend­a­tion of the Audit Committee.

The Park Authority’s Fin­an­cial Memor­andum with the fund­ing body requires that it has an effect­ive intern­al audit func­tion and their duties and respons­ib­il­it­ies must be in accord­ance with the Scot­tish Pub­lic Fin­ance Manu­al (SPFM) and Pub­lic Sec­tor Intern­al Audit Stand­ards (PSI­AS). The main respons­ib­il­ity of intern­al audit is to provide the Park Author­ity, the Account­able Officer and the Seni­or Man­age­ment Team with assur­ances on the adequacy of the intern­al con­trol sys­tem. The intern­al audit ser­vice remains inde­pend­ent in its plan­ning and oper­a­tion but has dir­ect access to the Account­able Officer and Audit and Risk Com­mit­tee. The intern­al aud­it­or will also com­ply with Inter­na­tion­al Stand­ards on Audit­ing as adop­ted for use in the UK and Ire­land by the Fin­an­cial Report­ing Coun­cil. 13.4 Fraud and cor­rup­tion It is the duty of all mem­bers of staff, man­age­ment and the Park Author­ity to noti­fy the Dir­ect­or of Cor­por­ate Ser­vices imme­di­ately whenev­er any mat­ter arises which involves, or is thought to involve, irreg­u­lar­ity, includ­ing fraud, cor­rup­tion or

any oth­er impro­pri­ety. The Dir­ect­or of Cor­por­ate Ser­vices shall imme­di­ately invoke the fraud response plan, which incor­por­ates the fol­low­ing key ele­ments (see Staff Hand­book for fuller details): a) will noti­fy the Account­able Officer and the Audit Com­mit­tee of the sus­pec­ted irreg­u­lar­ity and shall take such steps as he or she con­siders neces­sary by way of invest­ig­a­tion and report; b) the Account­able Officer shall inform the police if a crim­in­al offence is sus­pec­ted of hav­ing been com­mit­ted; c) any sig­ni­fic­ant cases of fraud or irreg­u­lar­ity shall be repor­ted to the fund­ing body in accord­ance with their require­ments as set out in the audit code of prac­tice; d) the Audit Com­mit­tee shall com­mis­sion such invest­ig­a­tion as may be neces­sary of the sus­pec­ted irreg­u­lar­ity, by the intern­al audit func­tion or oth­ers, as appro­pri­ate; and e) the intern­al audit func­tion, or oth­ers com­mis­sioned to carry out an invest­ig­a­tion, shall pre­pare a report for the Audit Com­mit­tee on the sus­pec­ted irreg­u­lar­ity. Such report shall include advice on pre­vent­at­ive meas­ures. If the sus­pec­ted fraud is thought to involve the Dir­ect­or of Cor­por­ate Ser­vices and/​or the Account­able Officer, the mem­ber of staff shall noti­fy the Con­vener or Chair of the Audit Com­mit­tee dir­ect of their con­cerns regard­ing irregularities.

13.5 Best value It is a require­ment of the Fin­an­cial Memor­andum that the Park Author­ity is respons­ible for deliv­er­ing value for money from pub­lic funds. It should keep under review its arrange­ments for man­aging all the resources under its con­trol, tak­ing into account guid­ance on good prac­tice issued from time to time by the fund­ing body or oth­er rel­ev­ant third parties e.g. Audit Scot­land, Aud­it­or Gen­er­al for Scot­land. Intern­al audit is to have regard to value for money in its pro­gramme of work.

13.6 Oth­er aud­it­ors The Park Author­ity may, from time to time, be sub­ject to audit or invest­ig­a­tion by extern­al bod­ies such as the fund­ing body, Nation­al Audit Office, European Court of Aud­it­ors, HM Rev­en­ue and Cus­toms, who have the same rights of access as extern­al and intern­al aud­it­ors. 14 Treas­ury Man­age­ment 14.1 Appoint­ment of bankers The Park Author­ity is respons­ible for the appoint­ment of its bankers on the recom­mend­a­tion of the Fin­ance and Deliv­ery Com­mit­tee. Bank­ing arrange­ments should be reg­u­larly reviewed to ensure that the arrange­ments con­tin­ue to meet the Park Authority’s needs in the most eco­nom­ic­al, effi­cient and effect­ive manner.

14.2 Bank­ing arrange­ments The Dir­ect­or of Cor­por­ate Ser­vices is respons­ible, on behalf of the Fin­ance and

Deliv­ery Com­mit­tee, for liais­ing with the Park Authority’s bankers in rela­tion to its bank accounts and the issue of cheques. All cheques shall be ordered on the author­ity of the Dir­ect­or of Cor­por­ate Ser­vices, who shall make prop­er arrange­ments for their safe cus­tody. Only the Chief Exec­ut­ive or Dir­ect­or of Cor­por­ate Ser­vices may open or close a bank account for deal­ing with the Park Authority’s funds. All bank accounts

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