1. The Council has fully accepted all recommendations made by the External Auditor.

2. There are five priority recommendations from the External Auditor for the Council to address; it is accepted that these are all to be considered as high priority.

Overall Accountability for the action plan rests with the Chief Operating Officer.

Recommendation One The Council should adopt and apply appropriate standards for business case preparation in relation to exit and pension discretions to improve information supporting decisions.
Action	Deadline (and approval where relevant)	Officer Accountability
Review of HR processes currently in place relating to the Council’s use of settlement agreements in relation to its employees including: - Revise the business case format for exit packages - Annual monitoring of the use of a revised framework will be undertaken by the Audit & Governance Committee	September 2021	Director of Governance, Chief Finance Officer and Head of HR

Recommendation Two Decision notes should be maintained that document the factors that explain the case for the use of public funds under the scheme of delegation such as where payments exceed contractual entitlements.
Action	Deadline	Officer Accountability
The introduction of a revised framework detailed under Recommendation One and Five will be accompanied by Officer training and development; a key part of that will be re-iterating the importance of maintaining clear records. The accompanying scheme of delegation will build in key points in time whereby reviews and decisions need to be captured by Officers Financial decisions affecting  Chief Officers will require the approval of Staffing Matters and Urgency Committee and relevant provisions will be included within the review of the Council’s Constitution	September 2021 and will remain subject to ongoing review	Director of Governance, Chief Finance Officer and Head of HR

Recommendation Three The Council should review the design of its governance policies and procedures to manage conflicts of interest (including self-interest threats). This should include updating the Council’s constitution and scheme of delegation.
Action	Deadline	Officer Accountability
A fundamental review of all aspects if the Council’s Constitution has already commenced and will pick up on issues on Member conflicts of interest, with a view to ensuring greater clarity. This aspect of the constitution will be prioritized for early consideration and approval. - The Monitoring Officer will undertake a six monthly review of all aspects of the constitution; - The Audit & Governance Committee will undertake an annual review of the Constitution to ensure it remains fit for purpose and report its findings to Full Council; - Guidance will be provided with all meeting agendas to assist Elected Members in the identification or not of a conflict of interest	July 2021 (subject to the scheduling of a meeting of Full Council).	Director of Governance

Recommendation Four The Council should ensure all Members fully understand the requirement of the Code of Conduct in relation to declaration of interests.
Action	Deadline	Accountability
The Council will work towards the adoption of the Model Code of Conduct issued by the LGA which will replace the current Code of Conduct and procedure for the handling of complaints: - The Joint Standards Committee will oversee the implementation of the Model Code of Conduct and make recommendations via the Audit & Governance Committee to Full Council; - The Council will commission specialist support to assist with the development, implementation and mandatory training of all Elected Members (and key officer groups) in respect of the Model Code of Conduct, awareness raising of conflicts of interest and the declaration of interests;  - Mandatory training will be required to undertaken by all Elected Members on an annual basis; - Guidance will be provided with all meeting agendas to assist Elected Members in the identification or not of a conflict of interest - The Council’s induction programme following City Council elections (due to take place in May 2023) will be reviewed in line with progress and outcomes of this recommendation	July 2021 (subject to the scheduling of a meeting of Full Council) Actions remaining subject to ongoing review	Director of Governance

Recommendation Five The Council should review its policies and procedures to reflect Government guidance in the use of non-disclosure agreements.
Action	Deadline	Accountability
Actions taken to fulfil this recommendation will be incorporated into the work detailed at Recommendation One above	September 2021	Director of Governance, Chief Finance Officer and Head of HR