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GOVERNMENT<br />

Interim Audit<br />

<strong>Report</strong> 2008/09<br />

Dorset County<br />

Council<br />

Pension Fund<br />

June 2009<br />

AUDIT


Content<br />

The contacts at <strong>KPMG</strong><br />

in connection with this<br />

report are:<br />

June Awty<br />

Partner<br />

<strong>KPMG</strong> LLP (UK)<br />

Tel: 02073 111769<br />

June.awty@kpmg.co.uk<br />

Gemma Broom<br />

Manager<br />

<strong>KPMG</strong> LLP (UK)<br />

Tel: 0117 9054382<br />

Gemma.broom@kpmg.co.uk<br />

Page<br />

Executive summary 2<br />

Financial statements 3<br />

Appendices 5<br />

A. Re<strong>com</strong>mendations<br />

B. Accounts risks<br />

C. Review of internal audit<br />

This report is addressed to the Council and has been prepared for the sole use of the Council. We<br />

take no responsibility to any member of staff acting in their individual capacities, or to third parties.<br />

The Audit Commission has issued a document entitled Statement of Responsibilities of Auditors<br />

and Audited Bodies. This summarises where the responsibilities of auditors begin and end and<br />

what is expected from the audited body. We draw your attention to this document.<br />

External auditors do not act as a substitute for the audited body’s own responsibility for putting in<br />

place proper arrangements to ensure that public business is conducted in accordance with the law<br />

and proper standards, and that public money is safeguarded and properly accounted for, and used<br />

economically, efficiently and effectively.<br />

If you have any concerns or are dissatisfied with any part of <strong>KPMG</strong>’s work, in the first instance you<br />

should contact June Awty, who is the engagement partner to the Council, telephone 02703111769,<br />

email june.awty@kpmg.co.uk who will try to resolve your <strong>com</strong>plaint. If you are dissatisfied with your<br />

response please contact Trevor Rees on 0161 236 4000, email trevor.rees@kpmg.co.uk, who is the<br />

national contact partner for all of <strong>KPMG</strong>’s work with the Audit Commission After this, if you are still<br />

dissatisfied with how your <strong>com</strong>plaint has been handled you can access the Audit Commission’s<br />

<strong>com</strong>plaints procedure. Put your <strong>com</strong>plaint in writing to the Complaints Investigation Officer,<br />

Westward House, Lime Kiln Close, Stoke Gifford, Bristol, BS34 8SR or by e mail to:<br />

<strong>com</strong>plaints@audit-<strong>com</strong>mission.gov.uk. Their telephone number is 0844 798 3131, textphone<br />

(mini<strong>com</strong>) 020 7630 0421<br />

© 2009 <strong>KPMG</strong> LLP, a UK limited liability partnership, is a subsidiary of <strong>KPMG</strong> Europe LLP and a member firm of the <strong>KPMG</strong> network of independent member<br />

firms affiliated with <strong>KPMG</strong> International, a Swiss cooperative. All rights reserved. This document is confidential and its circulation and use are restricted.<br />

<strong>KPMG</strong> and the <strong>KPMG</strong> logo are registered trademarks of <strong>KPMG</strong> International, a Swiss cooperative.<br />

1


Section one<br />

Executive summary<br />

Scope of this report<br />

This report summarises our planning and interim audit work for the Dorset County Council Pension Scheme (‘the<br />

Scheme’) in relation to the 2008/09 financial statements. A significant proportion of our accounts audit is<br />

<strong>com</strong>pleted before we receive your financial statements. In particular, our work to date covers the following areas:<br />

• Audit planning and risk analysis: We have identified the key issues for the 2008/09 financial statements and<br />

discussed your progress in addressing these.<br />

• Control evaluation: We have reviewed your progress with the closedown and accounts production process. We<br />

have also tested controls over the key financial systems. We rely on the work of internal audit at the Council<br />

wherever possible, and <strong>com</strong>plete an assessment of the internal audit function as part of this work.<br />

Section 2 provides further details of the work <strong>com</strong>pleted and sets out our findings.<br />

Our re<strong>com</strong>mendations are included in Appendix A.<br />

Summary of findings<br />

• We have reviewed the Scheme’s plans for closedown and accounts preparation. The process in place should<br />

support the timely production of materially accurate financial statements.<br />

• We have identified four key accounting areas for the 2008/09 financial statements. These are summarised in<br />

more detail in Appendix B. These issues are being taken seriously by the Council and progress has been made<br />

to date in addressing each of the risks identified.<br />

• We assessed your high level financial control framework as good overall. Our audit identified one significant<br />

issues in relation to the organisational control environment which is detailed in Appendix A.<br />

• We were able to rely on the relevant work undertaken by the internal audit team in respect of the Pension Fund<br />

in the year for the key financial systems.<br />

• There is no clear segregation of funds or documented investment responsibilities between the Council and the<br />

Pension Fund. As a result it is unclear which organisation is liable for the Fund’s potential loss of monies<br />

following the banking collapse in Iceland.<br />

Acknowledgements<br />

We would like to take this opportunity to thank officers and members for their continuing help and co-operation<br />

throughout our audit work.<br />

© 2009 <strong>KPMG</strong> LLP, a UK limited liability partnership, is a subsidiary of <strong>KPMG</strong> Europe LLP and a member firm of the <strong>KPMG</strong> network of independent member<br />

firms affiliated with <strong>KPMG</strong> International, a Swiss cooperative. All rights reserved. This document is confidential and its circulation and use are restricted.<br />

<strong>KPMG</strong> and the <strong>KPMG</strong> logo are registered trademarks of <strong>KPMG</strong> International, a Swiss cooperative.<br />

2


Section two<br />

Financial statements<br />

Introduction<br />

Our work in respect of the audit of financial statements is split into the stages shown below:<br />

Stage Tasks Timing<br />

Completed<br />

Planning<br />

• Updating our business understanding and risk<br />

assessment<br />

• Assessing the organisational control environment<br />

• Issuing our accounts audit protocol<br />

December 2008 to<br />

February 2009<br />

<br />

• Reviewing the accounts production process<br />

Control<br />

Evaluation<br />

• Evaluating and testing controls over key financial systems<br />

• Review of internal audit<br />

• Evaluating and testing controls over authority<br />

management and control<br />

March to<br />

April 2009<br />

<br />

Substantive<br />

Testing<br />

• Planning and performing substantive work<br />

• Concluding on critical accounting matters<br />

June to July 2009<br />

-<br />

Completion<br />

• Completion procedures<br />

• Forming our audit opinion<br />

August to<br />

September 2009<br />

-<br />

Key issues in respect of each of these tasks is summarised below.<br />

Planning - Risk assessment<br />

Our 2008/09 Audit and Inspection Plan included our initial assessment of the risks impacting on the 2008/09<br />

financial statements. We have updated this during the course of our interim audit and include a detailed outline of<br />

the key accounting issues and risks for the Pension Fund accounts for 2008/09 in Appendix B.<br />

We have discussed these risks with the finance team as part of our planning and update meetings. It is noted that<br />

these issues are being taken seriously by the Scheme and progress has been made to date in addressing each of<br />

the risks identified as outlined in Appendix B. However, these still present significant challenges that require<br />

careful management and focus. We will revisit these areas during our final accounts audit.<br />

Planning - Organisational control environment<br />

The organisational controls we assess are based on your high level system of internal control which includes how<br />

the Fund is governed.<br />

As noted on page 2, arrangements in respect of investment responsibilities and treasury management between<br />

the Council and the Pension Fund would benefit from further consideration with a view to clarifying and<br />

documenting roles and responsibilities.<br />

Re<strong>com</strong>mendations are included in Appendix A.<br />

© 2009 <strong>KPMG</strong> LLP, a UK limited liability partnership, is a subsidiary of <strong>KPMG</strong> Europe LLP and a member firm of the <strong>KPMG</strong> network of independent member<br />

firms affiliated with <strong>KPMG</strong> International, a Swiss cooperative. All rights reserved. This document is confidential and its circulation and use are restricted.<br />

<strong>KPMG</strong> and the <strong>KPMG</strong> logo are registered trademarks of <strong>KPMG</strong> International, a Swiss cooperative.<br />

3


Section two<br />

Financial statements (continued)<br />

Planning - Accounts audit protocol<br />

This important document explains our audit process with details of our audit team, audit approach and timetable. It<br />

also summarises the working papers and other evidence we require you to provide as part of the preparation of the<br />

financial statements. We issued this to the finance team in April 2009. We have tailored the document to reflect<br />

our requirements in respect of the specific accounting issues identified above.<br />

Control Evaluation - Accounts production process<br />

We have reviewed your plans for preparing for your closedown and accounts preparation. You have incorporated a<br />

number of measures into your closedown plan to further improve the project management of this process.<br />

We consider that your planned processes for the preparation of your financial statements are adequate and should<br />

support the timely production of materially accurate financial statements.<br />

Control Evaluation - Controls over key financial systems<br />

We work with internal audit to:<br />

• update our understanding of key financial systems;<br />

• confirm our understanding of these systems by <strong>com</strong>pleting walkthrough testing; and<br />

• document, evaluate and test the control framework for these systems.<br />

We have relied on the work <strong>com</strong>pleted by internal audit for 2008/09 over the Pension Fund’s key systems and<br />

controls. For each of the key financial systems internal audit tested high level controls, which are strong controls<br />

that should address the key risks. Examples are reconciliations or exception reports.<br />

We assessed your high level financial control framework as good overall.<br />

Internal audit gave a substantial assurance opinion in respect of the systems and internal controls operating within<br />

the area audited and included re<strong>com</strong>mendations in their reports as appropriate in respect of contributions and<br />

refunds.<br />

The weaknesses identified by internal audit over contributions and refunds have not resulted in additional external<br />

audit testing as the high level controls were in place.<br />

Control Evaluation - Review of internal audit<br />

The Accounts and Audit Regulations 2003 require public bodies to maintain an adequate and effective system of<br />

internal audit of their accounting records and of their system of internal control. For principal local authorities,<br />

guidance is contained in the Code of Practice for Internal Audit in Local Government (‘the Code’). The Code<br />

defines the way in which internal audit should be established and operated and applies equally to in-house audit<br />

teams and those provided by external contractors.<br />

We did not identify any significant issues with their work and are pleased to report that we have been able to place<br />

full reliance on internal audit’s work on the key financial systems. We particularly noted improvements in terms of<br />

the quality of system documentation and the adequacy of sample sizes used by internal audit.<br />

© 2009 <strong>KPMG</strong> LLP, a UK limited liability partnership, is a subsidiary of <strong>KPMG</strong> Europe LLP and a member firm of the <strong>KPMG</strong> network of independent member<br />

firms affiliated with <strong>KPMG</strong> International, a Swiss cooperative. All rights reserved. This document is confidential and its circulation and use are restricted.<br />

<strong>KPMG</strong> and the <strong>KPMG</strong> logo are registered trademarks of <strong>KPMG</strong> International, a Swiss cooperative.<br />

4


Appendices<br />

Appendix A: Re<strong>com</strong>mendations<br />

We have given each re<strong>com</strong>mendation a risk rating (as explained below) and agreed what action management will<br />

need to take. We will follow up these re<strong>com</strong>mendations next year.<br />

Priority rating for re<strong>com</strong>mendation<br />

Priority one: issues that are<br />

fundamental and material to your<br />

system of internal control. We believe<br />

that these issues might mean that you<br />

do not meet a system objective or<br />

reduce (mitigate) a risk.<br />

Priority two: issues that have an<br />

important effect on internal controls<br />

but do not need immediate action. You<br />

may still meet a system objective in full<br />

or in part or reduce (mitigate) a risk<br />

adequately but the weakness remains<br />

in the system.<br />

Priority three: issues that would, if<br />

corrected, improve the internal control<br />

in general but are not vital to the overall<br />

system. These are generally issues of<br />

best practice that we feel would<br />

benefit you if you introduced them.<br />

No.<br />

Risk<br />

Issue and re<strong>com</strong>mendation<br />

Management response<br />

Officer and due date<br />

Issue<br />

The Council invested monies on<br />

behalf of the Pension Fund in the<br />

Icelandic banking system.<br />

However, following the collapse of<br />

the banking system, recoverability<br />

of these monies is uncertain.<br />

Impact<br />

There is no clear segregation of<br />

funds or documented investment<br />

responsibilities, making it unclear<br />

whether the Council or the Fund is<br />

liable for the Fund’s potential loss<br />

of monies from the banking<br />

collapse.<br />

Re<strong>com</strong>mendation<br />

The Pension Fund Investment<br />

Committee should seek legal<br />

advice in respect of this matter.<br />

The Committee should also<br />

formalise its arrangements with<br />

the Council in respect of the<br />

treasury role the Council carries out<br />

on behalf of the Fund.<br />

1<br />

•<br />

(one)<br />

1. The current position with<br />

regard to any liability falling on<br />

the Pension Fund is be<strong>com</strong>ing<br />

clearer nationally. Currently we<br />

are assuming that the Fund<br />

will assume no liability for any<br />

potential losses relating to<br />

deposits in Icelandic banks,<br />

however, this needs to be<br />

clarified. Advice has been<br />

sought from Counsel as to the<br />

appropriate treatment, and a<br />

response is expected shortly.<br />

2. With effect from 5 October<br />

2009, the Pension Fund will be<br />

operating <strong>com</strong>pletely separate<br />

bank accounts, and treasury<br />

management arrangements,<br />

thus clearly segregating the<br />

cash balances.<br />

Paul Kent (Pension Fund<br />

Administrator)<br />

30 September 2009<br />

© 2009 <strong>KPMG</strong> LLP, a UK limited liability partnership, is a subsidiary of <strong>KPMG</strong> Europe LLP and a member firm of the <strong>KPMG</strong> network of independent member<br />

firms affiliated with <strong>KPMG</strong> International, a Swiss cooperative. All rights reserved. This document is confidential and its circulation and use are restricted.<br />

<strong>KPMG</strong> and the <strong>KPMG</strong> logo are registered trademarks of <strong>KPMG</strong> International, a Swiss cooperative.<br />

5


Appendices<br />

Appendix B: Accounts risks<br />

This appendix summarises the key accounting issues for the 2008/09 financial statements and the progress you<br />

have made to date to address these.<br />

Changes to accounting requirements<br />

Issue Risk and implications Progress<br />

The 2008 Statement of Re<strong>com</strong>mended Practice on<br />

Local Authority Accounting the UK (SORP) includes<br />

a number of changes, including aligning the<br />

disclosure of the Pension Fund accounts with the<br />

Statement of Re<strong>com</strong>mended Practice (SORP):<br />

Financial <strong>Report</strong> of Pension Schemes (revised May<br />

2007).<br />

There is a risk that the financial<br />

statements prepared by the Council<br />

will not appropriately <strong>com</strong>ply with the<br />

updated SORP. This would result in<br />

additional time required by both local<br />

management and <strong>KPMG</strong> to address<br />

any non-<strong>com</strong>pliance with the SORP<br />

and could delay the finalisation of the<br />

financial statements.<br />

Finance staff have familiarised<br />

themselves with the changes<br />

required under the SORP 2008.<br />

The Council will make use of the<br />

SORP disclosure checklist when<br />

preparing the draft financial<br />

statements to help ensure<br />

<strong>com</strong>pliance with the SORP.<br />

Impairment of Icelandic bank investments<br />

In October 2008 the Icelandic banking system<br />

collapsed resulting in the recoverability of the<br />

investments held by the Council with Icelandic<br />

banks be<strong>com</strong>ing questionable. The accounting<br />

treatment of the balance held by the Fund therefore<br />

needs to represent the best estimate of the likely<br />

amount that can be recovered. LAAP Bulletins 78<br />

and 79 provide guidance on the accounting<br />

treatment to be adopted in the year and should be<br />

considered by the Council. This has been<br />

supplemented by LAAP bulletin 82, covering the<br />

latest information from the administrators of the<br />

banks concerned regarding the extent to which local<br />

authority investments may be recoverable.<br />

The Pension Fund should confirm that this is<br />

applicable for the Pension Fund accounts.<br />

There is a risk that the investments<br />

held with the Icelandic banks are not<br />

disclosed appropriately in the financial<br />

statements in line with the guidance<br />

provided in LAAP Bulletins 78, 79 and<br />

82.<br />

The Council has considered the<br />

guidance outlined in LAAP<br />

Bulletins 78, 79 and 82.<br />

Discussion over the liability in<br />

relation to the Icelandic monies<br />

held by the Fund is ongoing<br />

between the Council and<br />

Investment Committee.<br />

Other investments with uncertain recoverability<br />

During an economic downturn the valuation of some<br />

investments be<strong>com</strong>e more uncertain especially<br />

where markets are illiquid or investments are in<br />

markets such as property.<br />

There is a risk some investments will<br />

not be recoverable and therefore<br />

consideration of the recoverability of<br />

these will need to be addressed by<br />

the Council in the financial<br />

statements.<br />

The Council is to consider the<br />

recoverability of their investment<br />

portfolio.<br />

Accounting estimates and valuations<br />

The current economic environment introduces a<br />

number of risks for the financial statements, in<br />

particular for estimates and valuations. This<br />

includes the valuation of investments which are<br />

carried at market value.<br />

There is a risk that estimates or<br />

valuations within the financial<br />

statements are not appropriately<br />

considered on a regular basis and<br />

therefore are not representative of the<br />

current economic environment.<br />

A formal valuation of property<br />

assets will be undertaken for the<br />

2008/09 financial statements to<br />

ensure they are reflective of the<br />

current economic environment at<br />

the balance sheet date. The<br />

Council is to consider the<br />

valuation of investments as part<br />

of the closedown process.<br />

© 2009 <strong>KPMG</strong> LLP, a UK limited liability partnership, is a subsidiary of <strong>KPMG</strong> Europe LLP and a member firm of the <strong>KPMG</strong> network of independent member<br />

firms affiliated with <strong>KPMG</strong> International, a Swiss cooperative. All rights reserved. This document is confidential and its circulation and use are restricted.<br />

<strong>KPMG</strong> and the <strong>KPMG</strong> logo are registered trademarks of <strong>KPMG</strong> International, a Swiss cooperative.<br />

6


Appendices<br />

Appendix C: Review of internal audit<br />

The following table summarises the findings of our review of the Council’s internal audit function against the<br />

standards set out in the Code of Practice for Internal Audit in Local Government:<br />

Standard<br />

Scope of internal audit<br />

Independence<br />

Ethics for internal auditors<br />

Audit Committee (or equivalent)<br />

Relationships with management,<br />

other auditors and other review<br />

bodies<br />

Staffing, training and<br />

development<br />

Audit strategy and planning<br />

Undertaking audit work<br />

Due professional care<br />

<strong>Report</strong>ing<br />

Performance, Quality and<br />

Effectiveness<br />

Commentary on your internal audit<br />

The scope of internal audit’s strategic plan, presented to the Audit & Scrutiny<br />

Committee on 22 April 2008, is adequate. It includes reviews of core financial<br />

systems, operational reviews, ICT audit and corporate governance. The Internal Audit<br />

Strategy is an overarching strategy, which is a high level statement of how Internal<br />

Audit will be delivered and how it links to the Council’s objectives and priorities.<br />

The Head of Internal Audit, Insurance and Risk Management has line manager<br />

responsibility for both the Council’s insurance and risk management processes and<br />

procedures. However, this is mitigated by the independent review undertaken by its<br />

internal audit partner, Deloitte, who report the results directly to the Chief Financial<br />

Officer. External review is also undertaken by the Council’s insurers.<br />

In addition to the Staff Code of Conduct, the Audit Section has also issued an 'Ethical<br />

Guidance Note' to auditors. Also, prior to the <strong>com</strong>mencement of each audit<br />

assignment, staff are required to identify any potential conflict of interest that may<br />

exist.<br />

Internal audit staff have been made aware of the ethics requirements in the Internal<br />

Audit Manual. The performance of auditors in terms of integrity, objectivity,<br />

<strong>com</strong>petence and confidentiality are monitored as part of the internal audit’s appraisal<br />

system.<br />

The internal auditors presented their plan and progress reports against the plan to the<br />

Council’s Audit & Scrutiny Committee throughout 2008/09.<br />

Relationships between internal audit and management appear to be co-operative and<br />

collaborative. Internal and external audit work together and we have been able to rely<br />

on internal audit’s work.<br />

Internal audit consists of trained, qualified internal auditors and the Head of Internal<br />

Audit is CCAB qualified. The service is provided in partnership with Deloitte. A staff<br />

training programme exists including mandatory modules for all auditors as well as<br />

supplementary developmental training.<br />

The Internal Audit Strategy is an overarching strategy providing a high level statement<br />

of how Internal Audit will be delivered and how it links to the Council’s objectives and<br />

priorities. Internal audit have a master-file of audits and the frequency of review of<br />

each area is determined by an annual risk assessment.<br />

The management of audit assignments is generally well controlled through the setting<br />

of standards and deadlines for the <strong>com</strong>pletion of fieldwork, receipt of management<br />

responses and finalisation of audit reports.<br />

The internal auditors appear to exercise due professional care in undertaking their work<br />

at the Council.<br />

The out<strong>com</strong>e of each audit assignment, identified in the annual operational plan, is<br />

reported to management. Internal audit <strong>com</strong>plete the reporting cycle with their<br />

quarterly reports to the Audit & Scrutiny Committee. These reports summarise the key<br />

reviews undertaken in the year and the audit opinion reached for each review.<br />

The quality assurance of audit reviews is achieved through a file review by the Group<br />

Auditor and audit reports are second reviewed by the Internal Audit Manager.<br />

Internal Audit have in place a series of performance measures , which are reviewed on<br />

a monthly basis and reported annually to the Audit and Scrutiny Committee<br />

© 2009 <strong>KPMG</strong> LLP, a UK limited liability partnership, is a subsidiary of <strong>KPMG</strong> Europe LLP and a member firm of the <strong>KPMG</strong> network of independent member<br />

firms affiliated with <strong>KPMG</strong> International, a Swiss cooperative. All rights reserved. This document is confidential and its circulation and use are restricted.<br />

<strong>KPMG</strong> and the <strong>KPMG</strong> logo are registered trademarks of <strong>KPMG</strong> International, a Swiss cooperative.<br />

7

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