Agenda item

The Fund Governance Manager will present a draft audit plan for the Fund for the scheme year 2024/25 for approval.

Richard Bullen, Fund Governance Manager, presented a draft audit plan for the Fund for the scheme year 2024/25. The plan included recommendations split between standard audits and audits of fund innovations, progress improvements and new regulations. Detail was provided that it had been hoped that the new Pension Regulator Code of Practice would have been in place by now, however this was likely to be delayed until April 2024. As the Fund had not been audited on its compliance against the Code of Practice this year, the Fund would assess itself against the old code and ask SWAP to audit itself against that. An internal audit could then be undertaken on implementation of the new code once in place.

An update was provided regarding the Phase II Payroll Migration Audit, and the audit scope being prepared by SWAP. Regarding the Fraud case this year, it was stated that an audit was desired to determine whether exceptional circumstances exist for the Fund to adopt its own policy which supplements the Council’s whistleblowing policy and arrangements.

The Committee discussed the update, with comments received but not limited to that it was perceived that the internal audit work looked thin, to which officers noted that a lot of work would be picked up by a full KFC audit next year and that the Fund was looking to introduce a customer service excellence project. These would take into account internal controls and consideration of how customers are treated.

Regarding the SWAP workload, it was clarified that SWAP would be aware of the Payroll Migrations Audit and the KFC audit, however as it stood an auditor had not yet been chosen for the Fraud audit and SWAP might feel conflicted if requested to do this as they had undertaken the fraud review. The Chairman raised concern that the SWAP workload was unable to be responsive to ad hoc demands which might arise through the year. Officers noted that with big projects on the horizon, more support might be required and that it could potentially be beneficial for the Fund to have its own contract with SWAP.

A further discussion took place regarding the potential for the Fund to purchase additional hours from SWAP as well as discussing how the Fund was currently assessed by SWAP as part of the Council’s risk profile, even though it was financially separate. It was stated that the suggested plan was focused on what was needed to be done rather than what the Fund would like to be done.

The Committee believed that a way forward might be for Officers, Committee and Board to articulate what extra work could be conducted by SWAP for it then to be considered by the Audit and Governance Committee.

Clarity was sought regarding the Phase II Payroll Migration Audit, which was set to be completed 30 April 2024, which suggested that the auditors would be reviewing work while it was taking place. It was clarified by officers that 30 April was a hard deadline and that this would be a readiness review rather than a full investigation. It was also noted that internal testing would take place in January, therefore meaning that data could be provided earlier.

A suggestion was made that a discussion should take place between the Chairman, the Head of the Pension Fund, and the Section 151 Officer to discuss resourcing and the relationship of the Wiltshire Pension Fund and Wiltshire Council.

It was suggested that the Fund’s Risk Register be added to the Audit Plan 2024/2025 as this would ensure that all operational and strategic risks were being managed efficiently.

It was suggested that the Chairman of the Wiltshire Pension Fund Committee have a discussion with the Chairman of the Audit and Governance Committee.

At the conclusion of debate, it was,

Resolved:

The Committee agreed:

·       To approve the scope of audits and auditors set out in paragraph 4 with the addition of the Fund Risk Register.

·       For the Chairman of the Wiltshire Pension Fund Committee have a discussion with the Chairman of the Audit and Governance Committee.