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Audit and Risk Committee Meeting Papers
Tuesday 12 May 2020, 6.30pm
By Tele Conference
Item Subject Report For Status Page Time
1 Welcome and apologies - 6.30
2 Declarations of interest - 6.31
3 Meeting minutes – 18 February 2020 Decision Public 1 6.32
4 Actions log Information Public 6 6.35
5 Themed presentation – COVID-19 Discussion Public - 6.40
6 Internal audit reports:
a) Internal audit progress report
b) Internal audit outstanding
recommendations report
c) Estate management
d) Housing rents
e) Safeguarding
f) Accounts payable and procurement
g) Payroll (Oral update)
h) Resident engagement
i) Counter fraud report Q4 2019/20
Discussion Public
8
12
13
25
36
46
-
52
63
6.55
7 Discussion Confidential 70 7.35
8 Resident scrutiny – customer contact centre Discussion Public 74 7.45
9 Risk register Q1 2020/21 and assurance map Discussion Public 83 8.00
10 Audit Committee forward plan 2020 Information Public 92 8.20
11 Any other business - - 8.30
Audit & Risk Committee Meeting 12 May 2020
Agenda
Homes for Haringey
Audit and Risk Committee Meeting 18 February 2020
Meeting: Audit and Risk Committee Meeting
Date & Time: 18 February 2020, 6.30pm
Venue: Conference Room 1, 48 Station Road, Wood Green
Present: Adzowa Kwabla-Oklikah (AKO) – Chair, Andrew Crompton (AC), Cllr
Dana Carlin (DC), Edward Robinson (ER), Costa Elia (CE)
Officers in
Attendance:
Sean McLaughlin (SM), Puneet Rajput (PR), Tracey Downie (TD), Minesh
Jani (MJ), Pete Davey (PD)
Apologies: Denise Gandy (DG)
Item Minutes Action
01/20 Welcome, Apologies and Declarations of Interest
The Chair welcomed members and officers to the meeting. New
members were introduced. Apologies were noted as above. There
were no declarations of interest.
02/20 External Audit Plan 2019/20
AKO welcomed Andy Lowe (AL), Partner at PWC, who presented the
external audit plan. He set out the proposed strategy for the external
audit and highlighted the key risks in relation to the audit. Significant
risks were mandated by auditing standards and the risk in relation to
inaccurate recording of pension scheme liabilities was a regulatory
requirement.
The audit would include transactions relating to HfH’s management
agreement to run the Haringey Community Benefit Society and also
HfH’s accounting for fire safety.
AL highlighted recent developments in auditing which would be
covered by the audit including the introduction of a new Streamlined
Energy and Carbon Reporting Framework. AL would provide material
to assist with reporting on this in the financial statements.
The Committee approved the external audit fee of £33,880 for the
2019/20 external audit.
AL left the meeting at this point.
03/20 Presentation on IT at HfH
PD gave a presentation on the use of business systems at HfH. The
main housing management system (OHMS) was currently being
1
Homes for Haringey
Audit and Risk Committee Meeting 18 February 2020
Item Minutes
Action
upgraded and was due for completion by December this year. In
response to a question, PD confirmed there was good project
oversight of the upgrade by both the Council and HfH. For the three
months since commencement, the project was on schedule.
The Council and HfH Apps currently in use were discussed and whilst
residents seemed generally happy with them there was some
confusion between the two.
PD set out arrangements and systems for data security management
and information on how vulnerability is recorded.
The Committee thanked PD for an informative presentation and
asked for the slides to be circulated.
PD left at this point.
PR
04/20 Minutes of the Meeting 15 October 2019
The minutes of the meeting held on 15 October 2019 were
approved as an accurate record of the meeting and signed by the
Chair.
05/20 Actions Log
PR informed the Committee that non-compliant spend was
continuing at a similar level previously reported to the Committee
and that this was currently being re-assessed following changes in the
Property Services department. A report would be presented at the
next Committee meeting.
In relation to the internal audit progress summary, the Committee
requested inclusion of the original due date for each audit in a
separate column.
PR
MJ
06/20 Internal Audit Outstanding Recommendations
PR reported slippage with progressing internal audit
recommendations, largely in Property Services due to changes in
personnel. SM informed the Committee of arrangements for the
management of the directorate and the appointment of interim
senior staff. DC asked for incorporation of a traffic light rating
against the list of outstanding recommendations to assist the
Committee to focus on any key areas of concern.
PR
2
Homes for Haringey
Audit and Risk Committee Meeting 18 February 2020
Item Minutes
Action
07/20 Internal Audit – Vehicle Management
This report had received limited assurance. This was largely due to
re-procurement risks inherent at the time. In relation to vehicle
inspection (recommendation 4.5), the Committee asked for more
assurance on the existence of a list and a process.
More assurance in general was requested by the Committee on fleet
management, policies and procedures and comparison against good
practice. The Committee also asked to what extent the fleet could be
more ‘green’ and environmentally sustainable in line with Council
objectives on carbon emissions. This would be covered in a
presentation to the Committee at its meeting in July.
HRS
Director
HRS
Director
08/20 Internal Audit – Disrepair Claims
This report had received limited assurance.
There was some concern about the responsiveness of the Council’s
legal service but this was not considered to be an issue generally.
AKO reminded officers of the need for good clear management
responses to internal audit recommendations.
09/20 Internal Audit – Sickness Absence
This report had received adequate assurance and was noted.
10/20 Internal Audit – HRS Bonus Scheme
This report had received adequate assurance and was noted.
11/20 Counter Fraud Report Q3 2019/20
In relation to a programme of visits to homelessness units, AKO
cautioned in relation to a need for sensitivity. SM confirmed this
would be the case and that from experience, residents were generally
pleased to see officers when conducting home visits.
MJ brought the Committee’s attention to a suspected irregularity and
checks within the repairs service that were currently underway
following receipt of a complaint. The fraud team were carrying out
an investigation in conjunction with the police.
ER asked about the checking process for completed works. This was
covered by surveyors carrying out post inspections.
3
Homes for Haringey
Audit and Risk Committee Meeting 18 February 2020
Item Minutes
Action
12/20 Internal Controls Assurance Review
The Committee discussed how to achieve a diverse range of sources
of assurance and to not solely rely on internal audit as its only
source. SM highlighted a range of additional sources of assurance
being relied upon including the use of external consultants, peer
reviews, Adults and Children’s Safeguarding Boards and the London
Councils Network. DC asked for the Board to be more engaged with
this process.
The assurance map would be updated following feedback and would
remain as a standing item of business on the Committee’s agenda
and kept under review as circumstances changed.
PR
PR
13/20 Internal Audit Plan 2020/21
MJ presented a proposed audit plan for 2020/21 based on the key
risks identified by HfH and following input from the executive team.
The Committee approved the internal audit plan for 2020/21
MJ left at this point.
14/20 Arrears Write Off Proposals
TD presented proposals for writing off aged rent arrears debt, the
majority of which was now statute barred. The Committee asked how
debt was progressing to this level and age and what actions were
being taken to mitigate this continuing. TD explained the complexities
where former tenant arrears were linked to tenants who move
between council homes and the focus on collecting current arrears
and not arrears from former properties.
The Committee approved recommendation to the Council to write
off £1,051,031.83 of aged rent arrears debt.
15/20 Resident Scrutiny Report
CE presented the key findings from the Resident Scrutiny Panel’s
(RSP) recent review of void management. The report was insightful
and the recommendations had been accepted by management.
CE updated the Committee on other activity the RSP was currently
involved in. Following recent staff changes within the Property
Services department, progress had fallen behind with implementation
4
Homes for Haringey
Audit and Risk Committee Meeting 18 February 2020
Item Minutes
Action
of the RSP’s recommendations from their scrutiny review of the
repairs service. CE also expressed concern with the lack of action in
response to the RSP’s review of the Supported Housing Service in
2017. He suggested that the Committee should track outstanding
recommendations from RSP scrutiny reviews in a similar way that it
tracks outstanding internal audit recommendations. This was agreed
by the Committee and would be implemented from the next meeting.
Mystery shopping of the contact call centre had revealed a mixed
picture with some areas of good performance as well as areas in
need of improvement. A report had been submitted to HfH and the
Council.
AKO asked CE to convey the Committee’s thanks to the RSP.
PR
16/20 Risk Register Q4 2019/20
The risk register was reviewed and the movements on the previous
quarter discussed. The changes were supported by the Committee.
The Committee asked for risks associated with the corona virus to be
assessed and added to the register.
PR
17/20 AOB
There was no other business. The meeting closed at 8.47pm.
Signed:
Date:
5
Homes for Haringey
Audit and Risk Committee Meeting 18 February 2020
Action log
Date of
meeting
Agenda
item
Action Action
owner
Target
completion
date
Status and comments
14/05/19 31/19 &
05/20
Non-compliant spend to continue to be
monitored by the Committee.
PR Oct-19
May-20
A report is on the agenda for the meeting.
18/02/20 03/20 Slides from IT presentation to be
circulated
PR Feb-20 Complete
18/02/20 05/20 Internal audit progress summary to
include original due date for each audit
in a separate column.
MJ May-20 Complete – this has been added for recent
audits and will continue for others from now on.
18/02/20 07/20 In relation to the internal audit of vehicle
management (recommendation 4.5), the
Committee asked for more assurance on
the existence of a list and a process.
JG May-20 An update will be given at the meeting
18/02/20 07/20 A presentation on fleet management to
be scheduled for the July Committee
meeting.
JG Jul-20 This is scheduled for the meeting on 14 July
18/02/20 12/20 Internal controls assurance to be
discussed with the Board
PR Mar-20 Complete – this was reported to the Board on
31 March
18/02/20 12/20 Assurance map to be updated and
remain as a standing item on the
Committee agenda
PR May-20 Complete – this is on the agenda for the
meeting
18/02/20 15/20 RSP scrutiny review recommendations to
be tracked and monitored by the
Committee
PR May-20
Jul-20
The recommendations are currently being
reviewed by management for completion. They
will be verified by the RSP and an update report
will be presented to the Committee in July.
6
Homes for Haringey
Audit and Risk Committee Meeting 18 February 2020
Action log
Date of
meeting
Agenda
item
Action Action
owner
Target
completion
date
Status and comments
18/02/20 16/20 Corona virus related risks to be assessed
and added to the register
ELT May-20 Complete – this is on the agenda for discussion
7
Homes for Haringey Internal Audit Progress Report May 2020
This report has been prepared on the basis of the limitations set out on page 4.
This report (“Report”) was prepared by Mazars LLP at the request of London Borough of Haringey and terms for the preparation and scope of the Report have been agreed with them. The matters raised in this Report are only those which came to our attention during our internal audit work. Whilst every care has been taken to ensure that the information provided in this Report is as accurate as possible, Internal Audit have only been able to base findings on the information and documentation provided and consequently no complete guarantee can be given that this Report is necessarily a comprehensive statement of all the weaknesses that exist, or of all the improvements that may be required. The Report was prepared solely for the use and benefit of London Borough of Haringey to the fullest extent permitted by law Mazars LLP. accepts no responsibility and disclaims all liability to any third party who purports to use or rely for any reason whatsoever on the Report, its contents, conclusions, any extract, reinterpretation, amendment and/or modification. Accordingly, any reliance placed on the Report, its contents, conclusions, any extract, reinterpretation, amendment and/or modification by any third party is entirely at their own risk.
Please refer to the Statement of Responsibility at the end of this report for further information about responsibilities, limitations and confidentiality.
8
Internal Audit Progress Summary – May 2020
2
Delivery of 2019/20 Internal Audit Plan Current progress with delivery of the 2019/20 Internal Audit Plan is detailed below. Final Reports on Safeguarding, Resident Engagement, Estate Management, Housing Rents and the outcomes of continuous audit work on procurement and accounts payable have been issued since the last meeting. The Payroll Continuous Audit work is in progress and a verbal update will be provided at the meeting.
The following table sets out the audits that were finalised since the last meeting of the Audit and Risk Committee and the status of the systems at the time of the audit.
Audit Title Date of Audit Date of Final
Report / (Date Due)
Assurance level
Direction of Travel
Number of Recommendations
(Priority)
1 2 3
2019/20
Estate Management November 2019 March 2020 (Feb 2020)
Limited N/a 2 2 1
Safeguarding February 2020 April 2020 (Apr 2020)
Substantial 0 1 1
Resident Engagement November 2020 March 2020 (Feb 2020)
Adequate 1 0 2
Housing Rents January 2020 April 2020 (Apr 2020)
Limited 1 2 0
9
Homes for Haringey Internal Audit – May 2020 3
Current progress with delivery of the 2019/20 Internal Audit Plan is detailed in the following table:
Ref Audit area Agreed start date
Status Assurance Comments
1 Health and safety 23/04/19 Final Adequate Final Report issued
2 Management of Voids 15/04/19 Final Adequate Final Report issued
3 Bespoke Systems 17/06/19 Final Limited Final Report issued
4 Risk Management 07/08/19 Final Adequate Final Report issued
5 Safeguarding 10/02/20 Final Substantial Final Report issued
6 Disrepair Claims 01/08/19 Final Limited Final Report issued
7 Vehicle Management Process 22/07/19 Final Limited Final Report issued
8 Management of Sickness Absence 12/08/19 Final Adequate Final Report issued
9 Resident Engagement 07/10/19 Final Adequate Final Report issued
10 Estate Management 14/10/19 Final Limited Final Report issued
11 Procurement Compliance - Complete N/a Continuous audit
12 Housing Rents 06/01/20 Final Limited Final Report issued
13 Accounts Payable - Complete N/a Continuous audit
14 Payroll - Bonus 27/08/19 Final Adequate Final Report Issued
15 Payroll - In progress N/a Continuous audit
16 Temporary Accommodation 22/07/19 Final Adequate Final Report issued
10
Homes for Haringey Internal Audit – May 2020 4
Statement of Responsibility
We take responsibility to the London Borough of Haringey for this report which is prepared on the basis of the limitations set out below. The responsibility for designing and maintaining a sound system of internal control and the prevention and detection of fraud and other irregularities rests with management, with internal audit providing a service to management to enable them to achieve this objective. Specifically, we assess the adequacy and effectiveness of the system of internal control arrangements implemented by management and perform sample testing on those controls in the period under review with a view to providing an opinion on the extent to which risks in this area are managed. We plan our work in order to ensure that we have a reasonable expectation of detecting significant control weaknesses. However, our procedures alone should not be relied upon to identify all strengths and weaknesses in internal controls, nor relied upon to identify any circumstances of fraud or irregularity. Even sound systems of internal control can only provide reasonable and not absolute assurance and may not be proof against collusive fraud. The matters raised in this report are only those which came to our attention during the course of our work and are not necessarily a comprehensive statement of all the weaknesses that exist or all improvements that might be made. Recommendations for improvements should be assessed by you for their full impact before they are implemented. The performance of our work is not and should not be taken as a substitute for management’s responsibilities for the application of sound management practices. This report is confidential and must not be disclosed to any third party or reproduced in whole or in part without our prior written consent. To the fullest extent permitted by law Mazars LLP accepts no responsibility and disclaims all liability to any third party who purports to use or reply for any reason whatsoever on the Report, its contents, conclusions, any extract, reinterpretation amendment and/or modification by any third party is entirely at their own risk. Mazars LLP London May 2020 In this document references to Mazars are references to Mazars LLP. Registered office: Tower Bridge House, St Katharine’s Way, London E1W 1DD, United Kingdom. Registered in England and Wales No 4585162. Mazars LLP. Mazars LLP is the UK firm of Mazars, an international advisory and accountancy group. Mazars LLP is registered by the Institute of Chartered Accountants in England and Wales to carry out company audit work.
11
Homes for Haringey
Audit and Risk Committee 12 May 2020
Report for Audit & Risk Committee
Title Internal Audit Outstanding Recommendations
Agenda item 6b
Report for Discussion
Classification Public
Report author Puneet Rajput, Director of Corporate Affairs
Contact email [email protected]
Contact telephone 020 8489 3728
1. Introduction
1.1 This report presents the committee with information on outstanding internal
audit recommendations for review and discussion.
2. Summary Position
2.1
No. of outstanding recommendations at February 2020 31
No. of new recommendations from subsequent audits 13
No. of recommendations actioned in the period 5
No. of outstanding recommendations at May 2020 39
3. Internal Audit Outstanding Recommendations
3.1 A list of the 39 recommendations currently outstanding is enclosed separately
with the Committee papers.
3.2 Outstanding recommendations broken down by directorate and audit year is set
out below.
16/17 17/18 18/19 20/21 Total
Corporate 1 4 5
Housing Management 1 1 10 12
Property Services 1 3 18 22
Total 2 1 4 32 39
3.3 29 out of the 39 recommendations outstanding have exceeded their original
target date. The majority (21) are in Property Services.
3.4 A further update will be given in the Committee meeting.
12
FINAL REPORT
Internal Audit Report
Homes for Haringey – Estate Management
March 2020
13
Contents
01 Executive Summary
02 Introduction
03 Background
04 Areas for Further Improvement and Action
05 Audit Observations
Appendices
A1 Audit Information
Disclaimer
This report (“Report”) was prepared by Mazars LLP at the request of the London Borough of Haringey (LB Haringey) and terms for the
preparation and scope of the Report have been agreed with them. The matters raised in this Report are only those which came to our attention
during our internal audit work. Whilst every care has been taken to ensure that the information provided in this Report is as accurate as
possible, Internal Audit have only been able to base findings on the information and documentation provided and consequently no complete
guarantee can be given that this Report is necessarily a comprehensive statement of all the weaknesses that exist, or of all the improvements
that may be required.
The Report was prepared solely for the use and benefit the LB of Haringey and to the fullest extent permitted by law Mazars LLP accepts no
responsibility and disclaims all liability to any third party who purports to use or rely for any reason whatsoever on the Report, its contents,
conclusions, any extract, reinterpretation, amendment and/or modification. Accordingly, any reliance placed on the Report, its contents,
conclusions, any extract, reinterpretation, amendment and/or modification by any third party is entirely at their own risk. Please refer to the
Statement of Responsibility in Appendix A1of this report for further information about responsibilities, limitations and confidentiality.
If you wish to discuss any aspect of this report, please contact Jerry Barton, Senior Manager, Mazars LLP
[email protected] or Minesh Jani, Head of Internal Audit and Risk Management
14
Page 1
Homes for Haringey – Estate Management – March 2020 – FINAL
01 Executive Summary This is a summary of matters arising from the audit.
Service Information
Department and Service: Estates and Neighbourhood Services
Audit Sponsor: Jonathan Gregory (Interim Head of Estate Management)
Date of Review: November 2019
Overall Assurance and Direction of Travel
N/A
Rationale
The work carried out by Internal Audit indicated that overall we can provide a Limited Assurance. Please see Appendix A1 for
definitions of our assurance levels, direction of travel and
recommendation priority.
Priority Number of recommendations
1 (Fundamental) 2
2 (Significant) 2
3 (Housekeeping) 1
TOTAL 5
Key Issues and Unmitigated Risks
1. There is currently no strategy in place for Estate Management that
outlines the overall objectives of the service and how these feed in to
the wider objectives of the organisation.
2. There is no standard approach for the setting of targets for staff.
3. There is currently inventory procedures and no central inventory
record
Risk Areas Reviewed
Strategy, Policies, and Procedures
Roles and Responsibilities
Staff Supervision and Management
Health and Safety
Stock Controls and Inventories
Performance Management
15
Page 2
Homes for Haringey – Estate Management – March 2020 – FINAL
02 Introduction As part of the Internal Audit Plan for 2019/20 we have undertaken a review
of key controls and processes around Estate Management at Homes for
Haringey.
We are grateful to the Interim Head of Estates and Neighbourhood Services
and all other Homes for Haringey staff for their assistance provided to us
during the course of the audit.
The report summarises the results of the internal audit work and, therefore,
does not include all matters that came to our attention during the audit. Such
matters have been discussed with the relevant staff.
03 Background Estates and Neighbourhood Services administer the communal areas in and
around Council housing estates and blocks of flats. Their duties include
caretaking and cleaning as well as oversight of ground maintenance and
parking on the council’s housing estates. The current Interim Head of
Estates and Neighbourhood Services has been in post since 9 September
2019.
There is a work delivery specification for the work required and
Neighbourhood Improvement act as client to ensure Estate Services are
delivering as expected. Management has confirmed there has not been a
skills audit to match requirements to the staffing levels available.
Staff are employed on fixed hour contracts and all overtime has to be
planned in advance.
In initial discussions with the Interim Head of Estates and Neighbourhood
Services it was suggested that stores levels were high and there were
excessive levels of equipment given stores records and inventories were
not adequately maintained. We have therefore included a review of the
current procedures around inventory maintenance and identified two areas
for improvement. We understand the service holds large quantities of
consumable items and expensive machinery but without a full inventory it is
impossible to identify whether these are in line with service needs.
Management also raised concerns over whether management information
provided sufficient detail to demonstrate whether duties were being
completed to the required standard. This was outside the scope of this
review.
16
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Homes for Haringey – Estate Management – March 2020 – FINAL
04 Areas for Further Improvement and Action Plan
Definitions for the levels of assurance and recommendations used within our reports are included in Appendix A1.
We identified areas where there is scope for improvement in the control environment. The matters arising have been discussed with management, to whom we
have made recommendations. The recommendations are detailed in the management action plan below.
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
5.1 Establishment of an inventory record
Observation: It was determined via
discussions with the Interim Head of Estates
and Neighbourhood Services and
Neighbourhood Improvement Team
Manager that there is currently no inventory
procedure and no central or local inventory
record.
Risk: Where there is no central inventory
record, there is an increased risk the senior
leadership team is unaware of the true
inventory position of the service. There is
also an increased risk that items may be lost
or stolen without management knowledge.
Inventory and stores procedures should
be developed and a single central
inventory produced.
The inventory should be audited on an
annual basis.
1 We are currently in the process of
identifying a central store location;
in conjunction with this we will
introducing stock control
measures that will include up to
date stock levels and triggers for
reordering and access will be
restricted to team managers only.
The above will be formalised into a
working procedure/manual.
July 2020
Estate
Services Team
Managers
5.2 Establishment of inventory change
procedures
Observation: It was determined via
discussions with the Interim Head of Estates
and Neighbourhood Services and
Neighbourhood Improvement Team
Manager that there is currently no procedure
A procedure for making additions to and
drawings from inventories should be
established and records should be
maintained of all inventory transactions.
1 As above As above
17
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Homes for Haringey – Estate Management – March 2020 – FINAL
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
for adding or removing from the inventory
record.
Risk: Where there is no standard approach
to making additions and subtractions from
local inventory records, there is an increased
risk those records are inaccurate either
accidentally or due to fraudulent actions.
5.3 Compilation of Estates Service Strategy
Observation: It was determined there is
currently no strategy or service plan in place
that outlines the overall objectives of the
service and how these feed in to the wider
objectives of the organisation. Furthermore,
it is unclear with the absence of a strategy
what external consultation has been had with
those benefitting from the service on how the
service should operate to provide the optimal
service.
Risk: Where a strategy does not exist, there
is an increased risk Homes for Haringey staff
and external stakeholders are unaware of
the organisations objectives with regards to
Estates Services resulting in a less effective
service.
A strategy should be prepared that
outlines the objectives of Estates
Services and Neighbourhood
Improvement, how these feed in to the
wider objectives of organisation, and
meet the needs and requirements of the
service recipients.
2 An Estates and Neighbourhoods
action plan is currently being
developed which will feed into a
wider review looking at
aligning/streamlining the entire
service.
Head of
Estates &
Neighbourhoo
ds
18
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Homes for Haringey – Estate Management – March 2020 – FINAL
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
5.4 Establishment of SMART (Specific
Measurable, Achievable, Realistic,
Timely) targets
Observation: It was determined there is no
structure for the setting of targets for staff.
We obtained performance monitoring
records for two members of staff under the
management of an Estate Services Team
Manager. The two records were in different
formats, and neither have SMART targets
set.
Risk: Where there is no agreed structure for
monitoring staff performance against annual
SMART targets, there is an increased risk
staff performance cannot be effectively and
reliably monitored resulting in potentially
poor performance going unaddressed.
Managers and staff working within Estate
Services and Neighbourhood
Improvement should agree on annual
SMART targets that are monitored in
regular one to one meetings over the
year.
2 The action plan mentioned above
is based on SMART targets and
will form the basis of the services
targets.
To be
implemented
following the
review of the
E&N’s
HOS, & Team
Managers
5.5 Establishment of Work Instruction review
schedule
Observation: We obtained and reviewed the
20 Homes for Haringey Work Instructions
that outline the different procedures used to
provide Estates Services. Examination of
these documents confirmed ES1 'Residents
Reporting Procedures' is no longer
operational. Therefore there is currently no
policy in place to govern resident reporting
A Work Instruction review schedule
should be prepared that outlines the
deadlines for policy and procedure
review, and that is updated on an annual
basis.
3 A schedule will be implemented
that splits the work instructions into
quarters to ensure they are all
thoroughly reviewed annually and
signed off.
May 2020
Team
Managers
19
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Homes for Haringey – Estate Management – March 2020 – FINAL
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
procedures. Furthermore, no policies above
have been reviewed since June 2018.
Risk: Where policies and procedures are not
reviewed on a regular basis, there is an
increased risk they do not reflect current
working practice and are ineffective in
achieving organisational objectives.
20
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Homes for Haringey – Estate Management – March 2020 – FINAL
05 Audit Observations
Examples of good practice identified
� Discussions with a Neighbourhood Improvement Officer who also
acts as a Weekend Manager confirmed all weekend staff sign in at a
single central location where the manager will record their attendance
before the staff then go out to fulfil their duties. Weekend managers
will then go out and randomly inspect different sites to ensure
weekend staff are fulfilling their duties appropriately.
� As part of our Health and Safety audit for 2019/20 we confirmed there
are appropriate and adequate reporting arrangements in place for
Health and Safety related incidents. In addition, we confirmed there
is a Health and Safety Training Matrix outlining 24 different training
modules, some of which are different levels of the same training
programme, that are considered either Mandatory, Required, or
Desirable based on the officers job title and service line.
Risk Management
In conducting our review, we have focused on those risks and areas
outlined in Appendix A1. We have looked at the above mitigations for
example the robustness of the data and found that these controls were in
place and operating notwithstanding issues identified with working with
Haringey. In testing, we have identified some opportunities for
improvement in the control environment to reduce risk exposure in this
area as outlined in Section 04 below. Risks pertaining to Estates
Management have been captured and are regularly reported on as part
of the Homes for Haringey corporate risk register, where all risks are
allocated to a risk owner, and are assessed based on probability and
impact.
Value for money
As part of this audit we have identified significant areas of weakness
around stock control and the recording of inventory. Reduced
effectiveness of controls in these areas create the potential of excessive
stock orders being made prior to them being required as part of the
service function, and as a result could result in stock deterioration and
financial loss to Homes for Haringey.
Sector Comparison
Our review of other client management of Estate Services confirmed the
procedures and control environment at Homes for Haringey is broadly in
line with the rest of the sector.
One of our clients has compiled a five year ‘Asset Management Plan’ that
outlines the objectives of the organisation in maintaining its estates.
Similarly, other clients have implemented strategies that are
supplementary strategies to the wider corporate plan and have been
compiled in accordance with objectives set out in corporate plans.
At other clients, regular management reports are produced regarding the
maintenance and management of estates. Key Performance Indicators
are measured against agreed annual targets that reflect the objectives
set out in defined strategies.
21
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Homes for Haringey – Estate Management – March 2020 – FINAL
A1 Audit Information
Audit Control Schedule
Client contacts:
Jonathan Gregory: Interim Head of Estates and Neighbourhood Services
Chris Vavlekis: Neighbourhood Improvement Team Manager
Internal Audit Team:
Graeme Clarke: Director
Jerry Barton: Senior Manager
Matt Biggs: Senior Auditor
Finish on site and Exit meeting:
29/11/2019
Last information received: 3/12/2019
Draft report issued: 13/2/2019
Management responses received:
13/3/2019
Final report issued: 19/3/2019
Scope and Objectives
The objective of our audit was to evaluate the adequacy of key controls
and the extent to which controls have been applied, with a view to providing
an opinion on the extent to which risks in this area are managed. In giving
this assessment, it should be noted that assurance cannot be absolute.
The most an Internal Audit service can provide is reasonable assurance
that there are no major weaknesses in the framework of internal control.
The limitations to this audit were that testing was performed on a sample
basis and as a result our work does not provide absolute assurance that
material error, loss or fraud does not exist.
22
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Homes for Haringey – Estate Management – March 2020 – FINAL
Definitions of Assurance Levels
Level Description
Substantial
Assurance:
Our audit finds no significant weaknesses and we feel that overall risks are being effectively managed. The issues raised tend to be minor issues or areas for improvement within an adequate control framework.
Adequate
Assurance:
There is generally a sound control framework in place, but there are significant issues of compliance or efficiency or some specific gaps in the control framework which need to be addressed. Adequate assurance indicates that despite this, there is no indication that risks are crystallising at present.
Limited
Assurance:
Weaknesses in the system and/or application of controls are such that the system objectives are put at risk. Significant improvements are required to the control environment.
Nil Assurance: There is no framework of key controls in place to manage risks. This substantially increases the likelihood that the service will not achieve its objectives. Where key controls do exist, they are not applied.
Definitions of Recommendations
Priority Description
Priority 1 (Fundamental)
Recommendations represent fundamental control weaknesses, which expose the organisation to a high degree of unnecessary risk.
Priority 2 (Significant)
Recommendations represent significant control weaknesses, which expose the organisation to a moderate degree of unnecessary risk.
Priority 3 (Housekeeping)
Recommendations show areas where we have highlighted opportunities to implement a good or better practice, to improve efficiency or further reduce exposure to risk.
Direction
Direction Description
Improved since the last audit visit.
Deteriorated since the last audit visit.
Unchanged since the last audit report.
No arrow Not previously visited by Internal Audit.
23
Page 10
Homes for Haringey – Estate Management – March 2020 – FINAL
Statement of Responsibility
We take responsibility to the London Borough of Haringey for this report
which is prepared on the basis of the limitations set out below.
The responsibility for designing and maintaining a sound system of internal
control and the prevention and detection of fraud and other irregularities
rests with management, with internal audit providing a service to
management to enable them to achieve this objective. Specifically, we
assess the adequacy and effectiveness of the system of internal control
arrangements implemented by management and perform sample testing
on those controls in the period under review with a view to providing an
opinion on the extent to which risks in this area are managed.
We plan our work in order to ensure that we have a reasonable expectation
of detecting significant control weaknesses. However, our procedures
alone should not be relied upon to identify all strengths and weaknesses in
internal controls, nor relied upon to identify any circumstances of fraud or
irregularity. Even sound systems of internal control can only provide
reasonable and not absolute assurance and may not be proof against
collusive fraud. The matters raised in this report are only those which came
to our attention during the course of our work and are not necessarily a
comprehensive statement of all the weaknesses that exist or all
improvements that might be made. Recommendations for improvements
should be assessed by you for their full impact before they are
implemented. The performance of our work is not and should not be taken
as a substitute for management’s responsibilities for the application of
sound management practices.
This report is confidential and must not be disclosed to any third party or
reproduced in whole or in part without our prior written consent. To the
fullest extent permitted by law Mazars LLP accepts no responsibility and
disclaims all liability to any third party who purports to use or reply for any
reason whatsoever on the Report, its contents, conclusions, any extract,
reinterpretation amendment and/or modification by any third party is
entirely at their own risk.
In this document references to Mazars are references to Mazars LLP.
Registered office: Tower Bridge House, St Katharine’s Way, London E1W
1DD, United Kingdom. Registered in England and Wales No 4585162.
Mazars LLP is the UK firm of Mazars, an international advisory and accountancy group. Mazars LLP is registered by the Institute of Chartered Accountants in England and Wales to carry out company audit work.
24
DRAFT REPORT
Internal Audit Report
Homes for Haringey: Housing Rents
April 2020
25
Contents
01 Executive Summary
02 Introduction
03 Background
04 Areas for Further Improvement and Action
05 Audit Observations
Appendices
A1 Audit Information
Disclaimer
This report (“Report”) was prepared by Mazars LLP at the request of the London Borough of Haringey (LB Haringey) and terms for the
preparation and scope of the Report have been agreed with them. The matters raised in this Report are only those which came to our attention
during our internal audit work. Whilst every care has been taken to ensure that the information provided in this Report is as accurate as
possible, Internal Audit have only been able to base findings on the information and documentation provided and consequently no complete
guarantee can be given that this Report is necessarily a comprehensive statement of all the weaknesses that exist, or of all the improvements
that may be required.
The Report was prepared solely for the use and benefit the LB of Haringey and to the fullest extent permitted by law Mazars LLP accepts no
responsibility and disclaims all liability to any third party who purports to use or rely for any reason whatsoever on the Report, its contents,
conclusions, any extract, reinterpretation, amendment and/or modification. Accordingly, any reliance placed on the Report, its contents,
conclusions, any extract, reinterpretation, amendment and/or modification by any third party is entirely at their own risk. Please refer to the
Statement of Responsibility in Appendix A1of this report for further information about responsibilities, limitations and confidentiality.
If you wish to discuss any aspect of this report, please contact Jerry Barton, Senior Manager, Mazars LLP
[email protected] or Minesh Jani, Head of Internal Audit and Risk Management
26
Page 1
Housing Rents – April 2020 – FINAL
01 Executive Summary This is a summary of matters arising from the audit.
Service Information
Department and Service: Homes for Haringey
Audit Sponsor: Puneet Rajput, Director of Corporate Services
Date of Review: January 2020
Overall Assurance and Direction of Travel
Rationale
The work carried out by Internal Audit indicated that overall we can provide a Limited Assurance level. Please see Appendix A1 for
definitions of our assurance levels, direction of travel and
recommendation priority
Priority Number of recommendations
1 (Fundamental) 1
2 (Significant) 2
3 (Housekeeping) 0
TOTAL 3
Key Issues and Unmitigated Risks
1. It was confirmed that a review of all Former Tenant Arrears (FTA) is
currently underway with a large number being put forward for write
off due to the time elapsed. Due to the workload in reviewing historic
cases, new FTA cases have not had recovery action taken since
October 2019. We were also unable to ascertain what is being
reported to management on the current state of arrears both of
current and former tenants, so we are unsure if management are
aware of the current position. This increasing the risk that debts may
not be recovered due to failure to chase in a timely fashion.
2. Testing of a random sample of 20 arrears cases confirmed the
evidence of debt chasing letters having been sent could not be
provided. Therefore, we could not verify that appropriate efforts to
collect outstanding balances had been taken. It was confirmed that
there is currently a total of £7.28m of outstanding debts, however this
figure includes accounts which have payment arrangements in place.
3. Examination of the Financial Regulations available on the Homes for
Haringey public website identified that they had not been updated
since March 2011. Therefore, increasing the risk that inefficient
working practices are adopted.
Risk Areas Reviewed
Identification and Recording of income due
Receipt and recording of income
Rent arrears and debt recovery
Write off
27
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Housing Rents – April 2020 – FINAL
02 Introduction As part of the Internal Audit Plan for 2019/20 we have undertaken a review
of key controls and processes around Housing Rents at Homes for
Haringey.
We are grateful to the Rents Accounts Manager and all other staff for their
assistance provided to us during the course of the audit.
The report summarises the results of the internal audit work and, therefore,
does not include all matters that came to our attention during the audit. Such
matters have been discussed with the relevant staff.
03 Background Homes for Haringey (HfH) are an Arms Length Management Organisation
(ALMO), which was set up in April 2006 to manage Haringey’s council
housing. HfH currently manage around 16,000 tenanted and 4,500
leasehold properties. Homes for Haringey were created as a limited liability
company, whose sole shareholder is Haringey Council.
While Haringey Council owns the homes and takes responsibility for
housing policy and strategy, Homes for Haringey is responsible for the day-
to-day management of council homes. Homes for Haringey is responsible
for the following:
• Housing Management;
• Service development;
• Housing finance (including home ownership and housing
information);
• Supported housing (the support service is provided by Haringey
Council’s social services team);
• Resident involvement;
• Design and engineering;
• Voids, general repairs and specialist works; and
• Asset management.
Housing rental income is received by Homes for Haringey from dwellings,
garages and shops through the Managed Account. That is, those Council
funds managed on behalf of the Council by Homes for Haringey.
28
Page 3
Housing Rents – April 2020 – FINAL
04 Areas for Further Improvement and Action Plan
Definitions for the levels of assurance and recommendations used within our reports are included in Appendix A1.
We identified areas where there is scope for improvement in the control environment. The matters arising have been discussed with management, to whom we
have made recommendations. The recommendations are detailed in the management action plan below.
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
4.1 Former Tenant Arrears
Observation:
Work to concentrate on the collection and
write off of former tenant arears has meant
that current arrears are not being chased.
It was confirmed that a review of all FTAs is
currently underway with a large number
being put forward for write off due to the time
elapsed. Examination of the FTA
spreadsheet confirmed the level of debt was
£9.4m at the time of the audit. Due to the
workload in reviewing historic cases new
FTA cases have not had recovery action
taken since October 2019. To date £1.3m
has been submitted for write off.
We have also been unable to ascertain what
regular reporting there is on the current and
former tenant arrears position to make senior
management aware of the current position
A Report to Senior Management should
be made detailing the current position
and balances on Current and FTAs.
Senior Management should then make
the decision based on risk and staff
availability if the current position on
current and FTA collections should
continue or whether additional resources
should be allocated to recovering FTAs.
Regular management reporting should
then take place detailing the current
position on current and former tenant
arrears including current balances,
movement over time, age of debt, inter
alia.
1 Currently the FTA process is
separated into two. The former,
former accounts are currently
being completed by one Former
Tenants Officer.
The accounts which are former but
are linked to a current account are
currently being looked at by the
Income Collection Officers.
The work currently being
completed by the FTA Officer is
looking at cases which are coming
into the statue barred status. A
search is completed for these
cases but if no contact can be
made or a suitable arrangement
made then cases are prepared for
W/O and are submitted through
the Council.
Moving on HFH are to have a new
system hopefully by December.
This system unfortunately does
Nehal Shah
December
2020
29
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Housing Rents – April 2020 – FINAL
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
Risk: There is an increased risk that debts
owed may not be recovered due to recovery
action not being taken in a timely manner.
not link cases how they currently
are so it will not be possible for
Officers to see the debt which is
linked to current accounts nor
previous formers.
Currently we have gone through a
restructure whereby it was
confirmed that the FTA process
would be being dealt with by one
Team Support Officer. This is quite
technical and will require a review
of the work conducted after Q1.
4.2 Rent arrears and debt recovery
Observation: We found that appropriate
processes are not followed in the chasing of
debt. Testing of a random sample of 20
outstanding debts confirmed the following:
- RA1s - 17 cases identified where the
letter itself could not be located.
- RA2s - 3 cases where the letter should
have been sent but it could not be located
- RA3s - 9 cases identified where the RA3
could not be located.
- RA4s - 6 cases identified where the letter
could not be located.
- RA5s - 4 cases identified where the letter
could not be located.
Staff should be reminded of the
importance of saving debt chasing letters
in the relevant tenant file on SharePoint.
Periodic spot checks should take place in
order to help ensure all relevant
documentation is being saved.
2 All staff have been reminded of
saving letters on SharePoint.
Quality audits have been
introduced to our processes which
will encompass this.
Nehal Shah
Already
Implemented
30
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Housing Rents – April 2020 – FINAL
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
- RA7s - 1 case where the letter could not
be located
We were informed that there are currently
no quality checks undertaken over
adherence to rent arrears and debt recovery
processes.
Risk: There is an increased risk that debts
may not be recovered, leading to financial
loss for the ALMO.
4.3 Financial Regulations
Observation: Examination of the Financial
Regulations available on the Homes for
Haringey public website identified that they
had not been updated since March 2011.
Risk: There is an increased risk that the
Financial Regulations do not accurately
reflect management wishes and/or working
practices, potentially resulting in
inefficient/ineffective working practices being
adopted.
The Homes for Haringey Financial
Regulations should be subject to regular
review (e.g. annually). Inclusion on the
Board and Audit and Risk Committee
Forward Planners should be considered.
2 Three yearly reviews of the
Financial regulations will be
conducted. The last review was
carried out in June 2019
Puneet Rajput
June 2022
We would like to take this opportunity to thank management and staff for their assistance during the audit.
31
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Housing Rents – April 2020 – FINAL
05 Audit Observations
Examples of good practice identified
The following areas of good practice were identified as part of our audit:
- It was confirmed that individual Rent Accounts Officers are
responsible for the following specific areas of the borough:
North Tottenham/Hornsey, Wood Green/Elderly & Special
Needs, Private Sector Leased/Broadwater, and Hostels and
Bed & Breakfast Accounts.
- Creation of rent accounts is restricted to the Rent Accounts
Team and IT Team. A system report was obtained which
confirmed this.
- Daily reconciliations are undertaken between amounts posted
onto the Council’s Financial Management System (SAP) as per
Crystal Reports, to amounts as per OHMS and amounts
received through All Pay.
- Testing of a random sample of 20 write offs processed on the
OHMS confirmed they had all been approved in line with
delegated limits as per the Councils Financial Regulations.
- Reasons for debts being written off were also confirmed to be
detailed on the cover sheet which is submitted for approval.
Risk Management
In conducting our review, we have focused on those risks and areas
outlined in our terms of reference and identified by us during our review.
Homes for Haringey list the roll out of universal credit as a corporate risk
in relation to the potential increase of rent arrears. This was deemed to
be outside the scope of this review. Weak income management is listed
in the Housing Management departmental risk register and we have
consider this as part of our review We have assessed the above
mitigations and the robustness of the associated data and found that
these controls were in place and operating notwithstanding issues
identified during the audit In testing, we have identified some
opportunities for improvement in the control environment to reduce risk
exposure in this area as outlined in Section 04 above.
Value for money
Value for Money (VfM) must be taken into consideration for all Council
activities as they are a public body and rely on public funding, therefore
meaning they have a duty to achieve the best value for money.
Housing Rents must consider VfM in a number of ways with Homes for
Haringey needing a robust debt chasing process in place to ensure that
all amounts owed are collected. Our testing has identified some
weaknesses in this process and as a result a recommendation has been
raised to help strengthen the control environment. See Section 04 for
details.
Sector Comparison
Our review of other client’s management of Housing Rents confirmed the
procedures and control environment adopted by Homes for Haringey is
broadly in line with the rest of the sector.
Common areas of weakness found across our client base relate to the
timely chasing and recovery of arrears. While we were able to evidence
that a clear control environment is in place for debt recovery at Homes for
Haringey issues were identified with compliance with procedures.
Another common weakness identified is the failure to update procedural
documents regularly. Our audit confirmed that the Financial Regulations
for Homes for Haringey had not been updated for a number of years.
Areas of good practice have already been identified above.
32
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Housing Rents – April 2020 – FINAL
A1 Audit Information
Audit Control Schedule
Client contacts:
Lesley Bott, Rent Accounts Manager
Tracey Downie, Interim Head of Income Management
Puneet Rajput, Director of Corporate Affairs
Internal Audit Team:
Peter Cudlip - Partner
Jerry Barton: Senior Manager
Ryan Fisher: Senior Auditor
Finish on site and Exit meeting:
27/01/2020
Last information received: 3/03/2020
Draft report issued: 16/03/2020
Management responses received:
06/04/2020
Final report issued: 06/04/2020
Scope and Objectives
The objective of our audit was to evaluate the adequacy of key controls
and the extent to which controls have been applied, with a view to providing
an opinion on the extent to which risks in this area are managed. In giving
this assessment, it should be noted that assurance cannot be absolute.
The most an Internal Audit service can provide is reasonable assurance
that there are no major weaknesses in the framework of internal control.
The limitations to this audit were that testing was performed on a sample
basis and as a result our work does not provide absolute assurance that
material error, loss or fraud does not exist.
33
Page 8
Housing Rents – April 2020 – FINAL
Definitions of Assurance Levels
Level Description
Substantial
Assurance:
Our audit finds no significant weaknesses and we feel that overall risks are being effectively managed. The issues raised tend to be minor issues or areas for improvement within an adequate control framework.
Adequate
Assurance:
There is generally a sound control framework in place, but there are significant issues of compliance or efficiency or some specific gaps in the control framework which need to be addressed. Adequate assurance indicates that despite this, there is no indication that risks are crystallising at present.
Limited
Assurance:
Weaknesses in the system and/or application of controls are such that the system objectives are put at risk. Significant improvements are required to the control environment.
Nil Assurance: There is no framework of key controls in place to manage risks. This substantially increases the likelihood that the service will not achieve its objectives. Where key controls do exist, they are not applied.
Definitions of Recommendations
Priority Description
Priority 1 (Fundamental)
Recommendations represent fundamental control weaknesses, which expose the organisation to a high degree of unnecessary risk.
Priority 2 (Significant)
Recommendations represent significant control weaknesses, which expose the organisation to a moderate degree of unnecessary risk.
Priority 3 (Housekeeping)
Recommendations show areas where we have highlighted opportunities to implement a good or better practice, to improve efficiency or further reduce exposure to risk.
Direction
Direction Description
Improved since the last audit visit.
Deteriorated since the last audit visit.
Unchanged since the last audit report.
No arrow Not previously visited by Internal Audit.
34
Page 9
Housing Rents – April 2020 – FINAL
Statement of Responsibility
We take responsibility to the London Borough of Haringey for this report
which is prepared on the basis of the limitations set out below.
The responsibility for designing and maintaining a sound system of internal
control and the prevention and detection of fraud and other irregularities
rests with management, with internal audit providing a service to
management to enable them to achieve this objective. Specifically, we
assess the adequacy and effectiveness of the system of internal control
arrangements implemented by management and perform sample testing
on those controls in the period under review with a view to providing an
opinion on the extent to which risks in this area are managed.
We plan our work in order to ensure that we have a reasonable expectation
of detecting significant control weaknesses. However, our procedures
alone should not be relied upon to identify all strengths and weaknesses in
internal controls, nor relied upon to identify any circumstances of fraud or
irregularity. Even sound systems of internal control can only provide
reasonable and not absolute assurance and may not be proof against
collusive fraud. The matters raised in this report are only those which came
to our attention during the course of our work and are not necessarily a
comprehensive statement of all the weaknesses that exist or all
improvements that might be made. Recommendations for improvements
should be assessed by you for their full impact before they are
implemented. The performance of our work is not and should not be taken
as a substitute for management’s responsibilities for the application of
sound management practices.
This report is confidential and must not be disclosed to any third party or
reproduced in whole or in part without our prior written consent. To the
fullest extent permitted by law Mazars LLP accepts no responsibility and
disclaims all liability to any third party who purports to use or reply for any
reason whatsoever on the Report, its contents, conclusions, any extract,
reinterpretation amendment and/or modification by any third party is
entirely at their own risk.
In this document references to Mazars are references to Mazars LLP.
Registered office: Tower Bridge House, St Katharine’s Way, London E1W
1DD, United Kingdom. Registered in England and Wales No 4585162.
Mazars LLP is the UK firm of Mazars, an international advisory and accountancy group. Mazars LLP is registered by the Institute of Chartered Accountants in England and Wales to carry out company audit work.
35
FINAL REPORT
Internal Audit Report
Safeguarding - Homes for Haringey
April 2020
36
Contents
01 Executive Summary
02 Introduction
03 Background
04 Areas for Further Improvement and Action
05 Audit Observations
Appendices
A1 Audit Information
Disclaimer
This report (“Report”) was prepared by Mazars LLP at the request of the London Borough of Haringey (LB Haringey) and terms for the
preparation and scope of the Report have been agreed with them. The matters raised in this Report are only those which came to our attention
during our internal audit work. Whilst every care has been taken to ensure that the information provided in this Report is as accurate as
possible, Internal Audit have only been able to base findings on the information and documentation provided and consequently no complete
guarantee can be given that this Report is necessarily a comprehensive statement of all the weaknesses that exist, or of all the improvements
that may be required.
The Report was prepared solely for the use and benefit the LB of Haringey and to the fullest extent permitted by law Mazars LLP accepts no
responsibility and disclaims all liability to any third party who purports to use or rely for any reason whatsoever on the Report, its contents,
conclusions, any extract, reinterpretation, amendment and/or modification. Accordingly, any reliance placed on the Report, its contents,
conclusions, any extract, reinterpretation, amendment and/or modification by any third party is entirely at their own risk. Please refer to the
Statement of Responsibility in Appendix A1of this report for further information about responsibilities, limitations and confidentiality.
If you wish to discuss any aspect of this report, please contact Jerry Barton, Senior Manager, Mazars LLP
[email protected] or Minesh Jani, Head of Internal Audit and Risk Management
37
Safeguarding – April 2020 – Final Page 1
01 Executive Summary
This is a summary of matters arising from the audit.
Service Information
Department and Service: Homes for Haringey
Audit Sponsor: Puneet Rajput (Director of Corporate Services)
Date of Review: February 2020
Overall Assurance and Direction of Travel
Rationale The work carried out by Internal Audit indicated that overall we can
provide Substantial Assurance. Please see Appendix A1 for
definitions of our assurance levels, direction of travel and
recommendation priority
Priority Number of recommendations
1 (Fundamental) 0
2 (Significant) 1
3 (Housekeeping) 1
Key Issues and unmitigated Risks
1. The Corporate Safeguarding group only meet annually, there is
an increased risk that issues are not resolved in a timely fashion.
Risk Areas Reviewed
Policies and Procedures
Service and Care Plans
Joint Working
Service Reviews
Management Information
38
Safeguarding – April 2020 – Final Page 2
02 Introduction As part of the 2019/20 Internal Audit Plan, we have undertaken an internal
audit of the Safeguarding Service. The report summarises the results of the
internal audit work and, therefore, does not include all matters that came to
our attention during the audit. Such matters have been discussed with the
relevant staff.
03 Background Safeguarding is the action that is taken to promote the welfare of children
and vulnerable adults and protect them from harm. Safeguarding involves
protection from abuse and maltreatment, preventing harm to health or
development, ensuring safe and effective care and taking action to ensure
the best outcomes for those at risk from harm. Safeguarding is a strategic
risk area for the organisation.
Homes for Haringey works closely with the Council and partner agencies to
ensure that they fulfil the duties around safeguarding. Safeguarding issues
will be reported to the Audit & Risk Committee.
A Safeguarding Policy is in place which states that Home for Haringey will
discharge their responsibilities to children and vulnerable adults by:
Valuing, listening to and respecting them.
When a safeguarding concern arises about a child or a vulnerable
adult, act to raise that concern.
Ensuring recruitment and selection, training and vetting procedures
are effective.
Appropriate and timely information sharing.
Attending multi-agency meetings and joint planning to promote best
interests.
Effective management of staff and volunteers through supervision,
support and training; and effective partnerships with contractors.
Sheltered Housing or good community neighbour supporting housing is
provided for people over 50 years old with support needs. Younger
applicants with severe disability may also be considered for the service. Two
types of accommodation are offered, which are sheltered and good
neighbour self-contained. The properties include flats and some bungalows
and there around 1,400 properties allocated to the service. Assessments
are undertaken to determine eligibility for the service and the needs of the
applicant. In cases where supported living is required, a care and support
plan is implemented to provide support for areas such as maintaining a
home, accessing employment, training or volunteering opportunities and
developing and keeping personal relationships. The service aims to provide
opportunities for service users to live as independently as possible and
promote community living.
A hub and cluster service model came into effect in July 2017, which
comprises of 4 hubs in both the East and West of the Borough. Each hub
has a coordinator in place to manage the support provided to the service
users. Service users have access to an alarm system in order to alert
management when required. The service operates during normal working
hours between Monday to Friday and responsibility is passed over to the
Community Alarms service during evenings and weekends.
Property checks including fire safety checks are undertaken to help ensure
that the properties remain fit for purpose and comply with health and safety
regulations.
The death of a resident in a sheltered housing scheme has led to a review
by the Safeguarding Adults Board and a number of actions by the Sheltered
Housing Service. There is a need to ensure that expected actions have been
completed.
39
Safeguarding – April 2020 – Final Page 3
04 Areas for Further Improvement and Action Plan
Definitions for the levels of assurance and recommendations used within our reports are included in Appendix A1.
We identified areas where there is scope for improvement in the control environment. The matters arising have been discussed with management, to whom we
have made recommendations. The recommendations are detailed in the management action plan below.
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
4.1 Policies and Procedures
Policies and procedures are in place
covering safeguarding, support delivery and
support planning. However, these were in
draft and have not been finalised and made
available to staff.
Where policies and procedures have not
been approved and finalised, there is an
increased risk that guidance available to staff
is inadequate or inappropriate.
Policies and procedures should be
reviewed at least annually and updated
accordingly with any necessary changes.
Updated policies should be approved
and circulated to all relevant staff.
3 Accepted and achieved. Will
ensure the Policies continue to be
promoted among staff:
Review of the key Policies and
Procedures;
Safeguarding (Adults) Policy
Feb 2020 and due for another
review in 2022;
Safeguarding (Children and
Young People) Policy. Feb
2020 and due another review
in 2022;
New Domestic Violence Policy
– Residents. October 2019
and due another review in
2021;
New Domestic Violence Policy
– Staff. As above; and
Revised Vulnerable Tenants
Procedure. March 2020.
April 2020 and
ongoing.
40
Safeguarding – April 2020 – Final Page 4
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
4.2 Management Information
A Corporate Safeguarding Group is in place
chaired by the Director of Housing Need and
including other senior managers. We were
provided with the minutes of the last meeting
of this group which was on 27th February
2019. Minutes do not indicate when the next
meeting will be held.
Review of the minutes do not indicate that
any performance data was discussed at the
meeting.
Where management are not provided with
safeguarding monitoring information
regularly, there is an increased risk that
issues are not dealt with promptly.
The Corporate Safeguarding Group
should meet at least quarterly to discuss
any issues, and this should be minuted
and retained on file.
Management information should also be
presented at these meetings.
2 Accepted. The last meeting was
held in July 2019 and subsequent
one cancelled due to leave and
key staff changes. The Group will
reconvene shortly.
July 2020 and
ongoing
41
Safeguarding – April 2020 – Final Page 5
05 Audit Observations
Examples of good practice identified
Sufficient training is provided to all staff and progress is monitored.
Care plans are completed for all residents. From a sample of ten
residents randomly selected, all ten had a care plan in place.
Service level agreements are in place for joint working arrangements.
Service reviews are completed annually.
Risk Management
In conducting our review, we have focused on those risks and areas
outlined in our terms of reference that came to our attention during the
audit. We have looked at the above mitigations for example the
robustness of the controls in place and procedures and found that these
controls were in place and operating. Given the nature of these issues the
risk associated is low. In testing, we have identified an opportunity for
improvement in the control environment to reduce risk exposure in this
area as outlined in Section 04.
Value for money
Value for Money (VfM) considerations can arise in various ways and our
audit process aims to include an overview of the efficiency of systems
and processes in place within the auditable area.
The Council is responsible for ensuring that value for money in the use of
resources is achieved. For example, this is achieved through the joint
working protocol and service level agreement (SLA) between Homes for
Haringey and the Council services for joint working arrangements.
Sector Comparison
We have taken the findings from this audit of Haringey and compared
them to findings from other audits recently carried out regarding other
Local Authority clients. It was found the controls in place at Haringey are
broadly similar to those used across the sector and that plans are in place
to ensure that discrepancies are minimised.
42
Safeguarding – April 2020 – Final Page 6
A1 Audit Information
Audit Control Schedule
Client contacts:
Helidon Topulli – Service Manager
Anton Suleman – Learning and Development officer
Internal Audit Team:
Peter Cudlip – Partner
Syed Shah – Senior Manager
Jerry Barton – Senior Manager
Thushika Jegathasan – Auditor
Finish on site and Exit meeting:
13 February 2020
Last information received: 13 February 2020
Draft report issued: 9 April 2020
Management responses received:
20 April 2020
Final report issued: 29 April 2020
Scope and Objectives
The objective of our audit was to evaluate the adequacy of key controls
and the extent to which controls have been applied, with a view to providing
an opinion on the extent to which risks in this area are managed. In giving
this assessment, it should be noted that assurance cannot be absolute.
The most an Internal Audit service can provide is reasonable assurance
that there are no major weaknesses in the framework of internal control.
The limitations to this audit were that testing was performed on a sample
basis and as a result our work does not provide absolute assurance that
material error, loss or fraud do not exist.
43
Safeguarding – April 2020 – Final Page 7
Definitions of Assurance Levels
Level Description
Substantial
Assurance:
Our audit finds no significant weaknesses and we feel that overall risks are being effectively managed. The issues raised tend to be minor issues or areas for improvement within an adequate control framework.
Adequate
Assurance:
There is generally a sound control framework in place, but there are significant issues of compliance or efficiency or some specific gaps in the control framework which need to be addressed. Adequate assurance indicates that despite this, there is no indication that risks are crystallising at present.
Limited
Assurance:
Weaknesses in the system and/or application of controls are such that the system objectives are put at risk. Significant improvements are required to the control environment.
Nil Assurance: There is no framework of key controls in place to manage risks. This substantially increases the likelihood that the service will not achieve its objectives. Where key controls do exist, they are not applied.
Definitions of Recommendations
Priority Description
Priority 1 (Fundamental)
Recommendations represent fundamental control weaknesses, which expose the organisation to a high degree of unnecessary risk.
Priority 2 (Significant)
Recommendations represent significant control weaknesses, which expose the organisation to a moderate degree of unnecessary risk.
Priority 3 (Housekeeping)
Recommendations show areas where we have highlighted opportunities to implement a good or better practice, to improve efficiency or further reduce exposure to risk.
Direction
Direction Description
Improved since the last audit visit.
Deteriorated since the last audit visit.
Unchanged since the last audit report.
No arrow Not previously visited by Internal Audit.
44
Safeguarding – April 2020 – Final Page 8
Statement of Responsibility
We take responsibility to the London Borough of Haringey for this report
which is prepared on the basis of the limitations set out below.
The responsibility for designing and maintaining a sound system of internal
control and the prevention and detection of fraud and other irregularities
rests with management, with internal audit providing a service to
management to enable them to achieve this objective. Specifically, we
assess the adequacy and effectiveness of the system of internal control
arrangements implemented by management and perform sample testing
on those controls in the period under review with a view to providing an
opinion on the extent to which risks in this area are managed.
We plan our work in order to ensure that we have a reasonable expectation
of detecting significant control weaknesses. However, our procedures
alone should not be relied upon to identify all strengths and weaknesses in
internal controls, nor relied upon to identify any circumstances of fraud or
irregularity. Even sound systems of internal control can only provide
reasonable and not absolute assurance and may not be proof against
collusive fraud. The matters raised in this report are only those which came
to our attention during the course of our work and are not necessarily a
comprehensive statement of all the weaknesses that exist or all
improvements that might be made. Recommendations for improvements
should be assessed by you for their full impact before they are
implemented. The performance of our work is not and should not be taken
as a substitute for management’s responsibilities for the application of
sound management practices.
This report is confidential and must not be disclosed to any third party or
reproduced in whole or in part without our prior written consent. To the
fullest extent permitted by law Mazars LLP accepts no responsibility and
disclaims all liability to any third party who purports to use or reply for any
reason whatsoever on the Report, its contents, conclusions, any extract,
reinterpretation amendment and/or modification by any third party is
entirely at their own risk.
In this document references to Mazars are references to Mazars LLP.
Registered office: Tower Bridge House, St Katharine’s Way, London E1W
1DD, United Kingdom. Registered in England and Wales No 4585162.
Mazars LLP is the UK firm of Mazars, an international advisory and accountancy group. Mazars LLP is registered by the Institute of Chartered Accountants in England and Wales to carry out company audit work.
45
FINAL REPORT
Internal Audit Report
Homes for Haringey – Resident Engagement
March 2020
52
Contents
01 Executive Summary
02 Introduction
03 Background
04 Areas for Further Improvement and Action
05 Audit Observations
Appendices
A1 Audit Information
Disclaimer
This report (“Report”) was prepared by Mazars LLP at the request of the London Borough of Haringey (LB Haringey) and terms for the
preparation and scope of the Report have been agreed with them. The matters raised in this Report are only those which came to our attention
during our internal audit work. Whilst every care has been taken to ensure that the information provided in this Report is as accurate as
possible, Internal Audit have only been able to base findings on the information and documentation provided and consequently no complete
guarantee can be given that this Report is necessarily a comprehensive statement of all the weaknesses that exist, or of all the improvements
that may be required.
The Report was prepared solely for the use and benefit the LB of Haringey and to the fullest extent permitted by law Mazars LLP accepts no
responsibility and disclaims all liability to any third party who purports to use or rely for any reason whatsoever on the Report, its contents,
conclusions, any extract, reinterpretation, amendment and/or modification. Accordingly, any reliance placed on the Report, its contents,
conclusions, any extract, reinterpretation, amendment and/or modification by any third party is entirely at their own risk. Please refer to the
Statement of Responsibility in Appendix A1of this report for further information about responsibilities, limitations and confidentiality.
If you wish to discuss any aspect of this report, please contact Jerry Barton, Senior Manager, Mazars LLP
[email protected] or Minesh Jani, Head of Internal Audit and Risk Management
53
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Homes for Haringey – Resident Engagement – March 2020 – FINAL
01 Executive Summary This is a summary of matters arising from the audit.
Service Information
Department and Service: Community and Customer Relations
Audit Sponsor: Chinyere Ugwu
Date of Review: November 2019
Overall Assurance and Direction of Travel
Rationale
The work carried out by Internal Audit indicated that overall we can provide an Adequate Assurance. Please see Appendix A1 for
definitions of our assurance levels, direction of travel and
recommendation priority.
Priority Number of recommendations
1 (Fundamental) 1
2 (Significant) 0
3 (Housekeeping) 2
TOTAL 3
Key Issues and Unmitigated Risks
1. There are no clear metrics for customer satisfaction which could lead
to false assumptions being made about the current.
Risk Areas Reviewed
Governance
Objectives and Responsibilities
Communication
Performance Management
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Homes for Haringey – Resident Engagement – March 2020 – FINAL
02 Introduction As part of the Internal Audit Plan for 2019/20 we have undertaken a review
of key controls and processes around the management of Resident
Engagement at Homes for Haringey.
We are grateful to the Community and Customer Relations Director, the
Community and Resident Engagement Manager, and all other Homes for
Haringey staff for their assistance provided to us during the course of the
audit.
The report summarises the results of the internal audit work and,
therefore, does not include all matters that came to our attention during the
audit. Such matters have been discussed with the relevant staff.
03 Background Homes for Haringey has an objective of putting residents (including
leaseholders) and the community at the heart of everything they do. To
support this objective, Homes for Haringey has a Community & Resident
Engagement Strategy and a related action plan. The strategy provides
guiding principles and core objectives for engagement, and a framework to
deliver this and embed engagement in everything Homes for Haringey does.
It also provides guidance on how success will be measured going forward.
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Homes for Haringey – Resident Engagement – March 2020 – FINAL
04 Areas for Further Improvement and Action Plan
Definitions for the levels of assurance and recommendations used within our reports are included in Appendix A1.
We identified areas where there is scope for improvement in the control environment. The matters arising have been discussed with management, to whom we
have made recommendations. The recommendations are detailed in the management action plan below.
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
5.1 Customer satisfaction reporting
Observation: Examination of July,
September and October, monthly customer
satisfaction highlight reports indicated that it
is undefined how customer satisfaction
levels are being determined and reported.
Risk: Where it is undefined how customer
satisfaction is being determined and
reported, there is an increased risk the
method for determining customer
satisfaction levels is inappropriate resulting
in unrepresentative positions being reported
to the Senior Leadership Team.
Customer satisfaction with regards to
resident engagement should be
determined via the use of quantifiable
results that are reported in the monthly
highlight reports against again SMART
(Specific, Measurable, Achievable,
Realistic Timely) targets.
The metrics should:
• Define agreed customer
satisfaction metrics.
• Define a level of expected
activity.
They should report monthly on where
performance is against the agreed level
and what is the trend.
1 We use evaluation sheets that
measure satisfaction and gather
feedback on:
• Events
• Training
• Conferences/large
meetings
We also use the star survey to
measure satisfaction with
involvement and benchmark it
against data from the sector. The
last BMG satisfaction report
measured this and identified
improvement areas.
Going forward, we will publish
quarterly data summarising
customer satisfaction with
engagement activities starting
April 2020
June 2020
Reda Khelladi
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Homes for Haringey – Resident Engagement – March 2020 – FINAL
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
5.2 Leaseholder Improvement Forum
schedule
Observation: According to the Terms of
Reference of the Leaseholder Improvement
Forum, leaseholders will be given 10 days’
notice for meetings and events and meetings
will be held quarterly.
We reviewed the Leaseholder Improvement
Forum page on the Homes for Haringey
website. The schedule for 2019 has been
included on the Leaseholder Improvement
Forum page up to 3 September 2019.
However, all these dates have now passed
and there is no indication of future arranged
dates on the Homes for Haringey website.
Risk: Where it is unclear to leaseholders of
how frequently the Leaseholder
Improvement Forum will meet and when the
next meeting date is scheduled for, there is
an increased risk of decreased attendance
and participation.
The next scheduled Leaseholder
Improvement Forums should be
confirmed and communicated on the
Homes for Haringey website and
published in the next newsletter.
Dates should be planned and
communicated for at least the next 12
months
3 We are currently reviewing the
forum structure and we are
working with a group of
leaseholders to co-design the new
structure for engagement.
Progress and outcome of this
review will be communicated to
Leaseholders.
This process has started in
January 2020 and will take 6
months to complete.
July 2020
Nehal Shah
5.3 Publishing of Leaseholder Improvement
Forum newsletters
Observation: Homes for Haringey will
publish newsletters pertaining to the
Leaseholder Improvement Forum where
future dates are reported. We obtained the
Newsletter for the forum held on 4 December
Homes for Haringey should mail and also
publish all Leaseholder Improvement
Forum newsletters on their website.
3 Information on this will be included
in the next e-newsletter for
leaseholders
June 2020
Nehal Shah
57
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Homes for Haringey – Resident Engagement – March 2020 – FINAL
Ref Observation/Risk Recommendation Priority Management response Timescale/
responsibility
2018, however, there are no other
newsletters on the Homes for Haringey
website pertaining to forums held since then.
Risk: Where newsletters pertaining to
Leaseholder Improvement Forums are not
published regularly, there is an increased
risk anyone who was not able to attend may
not be aware of items discussed or future
forum dates.
We would like to take this opportunity to thank management and staff for their assistance during the audit.
We have added risks of the services to the organisation’s risk register now
58
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Homes for Haringey – Resident Engagement – March 2020 – FINAL
05 Audit Observations Examples of good practice identified
� We obtained and confirmed the establishment of the Community and
Resident Engagement Strategy for 2019/22. The strategy sets out the
key objectives and priorities over the next three years aimed at
putting tenants and leaseholders at the heart of the Homes for
Haringey service and has been published on the Homes for Haringey
website.
� The revised strategy has incorporated the outcome of various
consultations and reviews of key aspects of the current engagement
strategy and structures since the summer of 2017. This includes a
Resident Scrutiny Panel, a Residents Complaints Panel and resident
representation on the Homes for Haringey Board.
Risk Management
In conducting our review, we have focused on those risks and areas
outlined in the terms of reference and other risks that came to our
attention during the audit. We have looked at the above mitigations for
example the robustness of the data and found that these controls were in
place and operating notwithstanding issues identified with working with
Homes for Haringey. In testing, we have identified some opportunities for
improvement in the control environment to reduce risk exposure in this
area as outlined in Section 04 below. It was determined via a
conversation with the Communication and Customer Relations Director
that there is currently no central risk register regarding resident
engagement.
Value for money
Our review of the resident engagement procedures identified no areas of
significant weakness or assurance concern regarding value for money.
Sector Comparison
Our review of other client’s management of Resident Engagement
confirmed the procedures and control environment at Homes for Haringey
is broadly in line with the rest of the sector.
One of our other clients has elected to monitor response rates of residents
who attend conferences and forums as a tool for monitoring overall
customer satisfaction. However, generally we find that surveys are the
most common method for obtaining feedback from residents.
59
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Homes for Haringey – Resident Engagement – March 2020 – FINAL
A1 Audit Information
Audit Control Schedule
Client contacts:
Chinyere Ugwu: Communication and Customer Relations Director
Reda Khelladi: Community and Resident Engagement Manager
Internal Audit Team:
Graeme Clarke: Director
Jerry Barton: Senior Manager
Matt Biggs: Senior Auditor
Finish on site and Exit meeting:
02/12/2019
Last information received: 02/12/2019
Draft report issued: 17/02/2020
Management responses received:
23/03/2020
Final report issued: 26/03/2020
Scope and Objectives
The objective of our audit was to evaluate the adequacy of key controls
and the extent to which controls have been applied, with a view to providing
an opinion on the extent to which risks in this area are managed. In giving
this assessment, it should be noted that assurance cannot be absolute.
The most an Internal Audit service can provide is reasonable assurance
that there are no major weaknesses in the framework of internal control.
The limitations to this audit were that testing was performed on a sample
basis and as a result our work does not provide absolute assurance that
material error, loss or fraud does not exist.
60
Page 8
Homes for Haringey – Resident Engagement – March 2020 – FINAL
Definitions of Assurance Levels
Level Description
Substantial
Assurance:
Our audit finds no significant weaknesses and we feel that overall risks are being effectively managed. The issues raised tend to be minor issues or areas for improvement within an adequate control framework.
Adequate
Assurance:
There is generally a sound control framework in place, but there are significant issues of compliance or efficiency or some specific gaps in the control framework which need to be addressed. Adequate assurance indicates that despite this, there is no indication that risks are crystallising at present.
Limited
Assurance:
Weaknesses in the system and/or application of controls are such that the system objectives are put at risk. Significant improvements are required to the control environment.
Nil Assurance: There is no framework of key controls in place to manage risks. This substantially increases the likelihood that the service will not achieve its objectives. Where key controls do exist, they are not applied.
Definitions of Recommendations
Priority Description
Priority 1 (Fundamental)
Recommendations represent fundamental control weaknesses, which expose the organisation to a high degree of unnecessary risk.
Priority 2 (Significant)
Recommendations represent significant control weaknesses, which expose the organisation to a moderate degree of unnecessary risk.
Priority 3 (Housekeeping)
Recommendations show areas where we have highlighted opportunities to implement a good or better practice, to improve efficiency or further reduce exposure to risk.
Direction
Direction Description
Improved since the last audit visit.
Deteriorated since the last audit visit.
Unchanged since the last audit report.
No arrow Not previously visited by Internal Audit.
61
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Homes for Haringey – Resident Engagement – March 2020 – FINAL
Statement of Responsibility
We take responsibility to the London Borough of Haringey for this report
which is prepared on the basis of the limitations set out below.
The responsibility for designing and maintaining a sound system of internal
control and the prevention and detection of fraud and other irregularities
rests with management, with internal audit providing a service to
management to enable them to achieve this objective. Specifically, we
assess the adequacy and effectiveness of the system of internal control
arrangements implemented by management and perform sample testing
on those controls in the period under review with a view to providing an
opinion on the extent to which risks in this area are managed.
We plan our work in order to ensure that we have a reasonable expectation
of detecting significant control weaknesses. However, our procedures
alone should not be relied upon to identify all strengths and weaknesses in
internal controls, nor relied upon to identify any circumstances of fraud or
irregularity. Even sound systems of internal control can only provide
reasonable and not absolute assurance and may not be proof against
collusive fraud. The matters raised in this report are only those which came
to our attention during the course of our work and are not necessarily a
comprehensive statement of all the weaknesses that exist or all
improvements that might be made. Recommendations for improvements
should be assessed by you for their full impact before they are
implemented. The performance of our work is not and should not be taken
as a substitute for management’s responsibilities for the application of
sound management practices.
This report is confidential and must not be disclosed to any third party or
reproduced in whole or in part without our prior written consent. To the
fullest extent permitted by law Mazars LLP accepts no responsibility and
disclaims all liability to any third party who purports to use or reply for any
reason whatsoever on the Report, its contents, conclusions, any extract,
reinterpretation amendment and/or modification by any third party is
entirely at their own risk.
In this document references to Mazars are references to Mazars LLP.
Registered office: Tower Bridge House, St Katharine’s Way, London E1W
1DD, United Kingdom. Registered in England and Wales No 4585162.
Mazars LLP is the UK firm of Mazars, an international advisory and accountancy group. Mazars LLP is registered by the Institute of Chartered Accountants in England and Wales to carry out company audit work.
62
Counter-fraud Report
2019/20 – Quarter 4
63
Counter-fraud outcomes 2019/20 – Quarter 4
Tenancy Fraud Investigations
Haringey Council’s Fraud Team works with Homes for Haringey to target and investigate housing and tenancy fraud. The Audit Commission* estimated that each fraudulent tenancy costs councils an estimated £18k in temporary accommodation and other associated costs. Although this figure is considered low if the properties have been sublet for some years, no new national indicators have been produced.
The HfH Tenancy Management Officer’s secondment to the Fraud Team to assist with the tenancy fraud work has been formally extended on a long term basis as a result of the successful outcomes achieved in and previous years; the post will be funded by HfH.
The Fraud Team will continue to work with HfH to develop the most effective use of fraud prevention and detection resources across both organisations to enable a joined up approach to be taken, especially where cases of multiple fraud are identified e.g. tenancy fraud, right to buy fraud and benefit fraud.
* No new national indicators have been developed since the Audit Commission was dissolved in 2015 and the Cabinet Office assumed this function
64
Counter-fraud outcomes 2019/20 – Quarter 4
Referrals received and outcomes
Brought forward from 2018/19 148
New referrals in 2019/20 204
Total referrals for investigation 352
Properties recovered 56
No fraud identified 171
Total investigations completed 227
Ongoing Investigations 125*
Tenancy FraudAt Quarter 4 of 2019/20, the numbers of referrals received, investigations completed and properties recovered by the Fraud Team are summarised below. The property will be included in the ‘recovered’ data when the keys are returned and the property vacated.
*Note 1: Due to COVID-19 a number of court dates for evictions have been cancelled. This number includes cases waiting for a rescheduled court date.
65
Counter-fraud outcomes 2019/20 – Quarter 4
Right to Buy (RTB) Investigations
The team currently has approximately 212 ongoing applications under investigation. The team reviews every RTB application to ensure that any property where potential tenancy, benefit or succession fraud is indicated can be investigated further. In the last two quarters, the numbers of tenants applying to purchase their properties under the Right to Buy legislation has reduced as valuations continue to rise. However, the proportion of fraudulent applications remains consistent.
At end of Quarter 4, 90 applications have been withdrawn or refused either following the applicants’ interview with the Fraud Team, further investigations and/or failing to complete money laundering processes.
66
Counter-fraud outcomes 2019/20 – Quarter 4
Pro-active counter-fraud projects
During 2019/20, the Fraud Team have continued with a number of pro-active counter-fraud projects. Progress reports on this work will be reported to the Audit & Risk Committee on an ongoing basis; the findings and outcomes are all shared with service managers as the projects are delivered.
Homelessness
A joint working programme is continuing to utilise grant funding around homelessness. The purpose of this programme is to visit all homelessness units and ensure legitimate claimant is living at the unit.
Other
Following a review of a complaint received by HfH, an investigation has been launched into suspected irregularity by staff. This investigation is on-going.
67
Counter-fraud outcomes 2019/20 – Quarter 4
Gas safety – execution of warrant visits
Since July 2016, the Fraud Team accompany warrant officers on all executions of warrant of entry visits where it was suspected that the named tenant was not in occupation.
The Fraud Team aim to interview any occupant and establish the legitimacy of the tenancy, or investigate further if the property is empty, or identified as being potentially sublet or abandoned. The Fraud Team may also identify cases where the tenant is a vulnerable adult, in which case a referral is made to social workers and/or tenancy management. The Gas Safety Team can (and do) make referrals to the Fraud Team if they identify any potential fraud indicators through the normal course of their work.
In 2019/20, the Fraud Team has assisted with Gas Safety warrants of execution and 19 properties were re-possessed as a result of the Fraud Team’s investigations; these figures are included in the ‘properties recovered figures reported as part of the tenancy fraud table.
68
Counter-fraud outcomes 2019/20 – Quarter 4
Financial Values 2019/20
Tenancy Fraud – council stock and temporary accommodation: The Audit Commission valued the recovery of a tenancy, which has previously been fraudulently occupied, at an annual value of £18,000, mainly relating to average Temporary Accommodation (TA) costs. No new national indicators have been produced; therefore although this value is considered low compared to potential TA costs if the property has been identified as sub-let for several years, Audit and Risk Management continue to use this figure of £18k per property for reporting purposes.
At the end of Quarter 4, 56 council stock properties had been recovered through the actions and investigations of the Fraud Team; therefore a total value of just over £1mcan be attributed to the recovery, or cessation, of fraudulent council and temporary accommodation tenancies.
Right to Buy Fraud: Overall, the 90 RTB applications withdrawn or refused represent over £8m in potential RTB discounts; and means the properties are retained for social housing use.
69
RSP Mystery Shopping Call Centre Report February 2020
Mystery Shopping ExerciseContact Call Centre - Focus on responsive repairs.
74
1. Why we did it
• HRS requested RSP in November 2019 to carry outmystery shopping through the Call Centre to review theway that responsive and communal repairs are beingreported and managed.
• Last review was done in 2017
75
2. What we did
• Observation at the Call Centre of call handlers on two site visits on 24 and 28 January.
• Listening into live calls using headphones in the Call Centre.
• Telephone – reporting actual repairs, and using scenario questions.
• Emailing – reporting repairs and sending requests via the dedicated email address.
• Using the app.
• Case studies provided by RSP members 76
3. What we found
• Repairs service is considered a priority service area.
• Once the CRM housing system is installed repair enquiries will be quicker and waiting times will improve.
• Call Centre Manager wants to understand the strengths and weaknesses.
• Dedicated 19 call handlers plus additional call handlers remotely dealing with HfH enquiries to meet the needs of a complex service.
• High levels of good customer service was identified on site visits.
• The Call Centre appears to be a comfortable environment to work in.
77
3. What we found
• An awareness of the RSP monitoring delivered a higher quality service than when there was no notification. RSP members felt that the call handlers managed 88% of calls very good. No caller was rated poor. However, when RSP members made mystery-shopping calls they rated the call handlers 40% as poor.
• Not enough support from back office. In 39% of calls observed call handlers sought advice from other colleagues on how to respond, attempted to call the back office or sent an email without response.
• Priority of repair and timescales not always given. When handling repair requests, 47% of callers were advised of the repair priority and 12% of a timescale when the work would be completed. This may account for the high number of follow up calls.
78
• Inconsistency regarding emergency repairs. Supported Housing residents feel that they are not given a priority for emergency repairs but at other times same repair was given priority.
• Inconsistencies in training provided. The Supervisor confirmed that all new members are provided with two weeks training. However, those asked stated that they only had a week or 2 days training.
• Callers not meeting 5-minute target. 59% of monitored calls did not meet the 5-minute target. The shortest call lasted 1 minute and the longest was 17 minutes.
• High percentage of abandoned calls. a total of 140 calls were abandoned representing 23% of the total incoming calls.
3. What we found
79
• No user surveys. No confirmation that any ‘user’ surveys are carried out on a regular basis on those that have used the Call Centre service.
• Long waiting times. On Monday, 3rd of February, a day of high calls to the service, the waiting time averaged between 12 to 40 minutes and 87% of calls were put on hold.
• Few callers were advised on the use of digital options. The ambition of the service is to get 80% of users to access the service using digital technology. However, only 9% of callers are being directed to on-line services.
• Promoting the digital options can reduce volume of calls. Helping to set up the SeeMyData could possibly reduce the number of calls received by 68%.
3. What we found
80
• SeeMyData regarded as a difficult interface to use. Tenants reported registering for SeeMyData as being a complicated process. Only one call handler was trained to set up accounts on-line.
• HfH app easier to use. The app received a response including job reference number and a booked appointment within 2 working days but no message of acknowledgement.
• E-mail requests take too long to be handled. These are supposed to be handled within 5 days, but some had not been dealt with in 7+ days
3. What we found
81
4. Recommendations
1. Regular monitoring of call users
2. Use feedback positively to look at opportunities to remedy service-operating issues byempowering all call handlers to go the extra mile
3. Ensure procedures and guidelines are consistently followed
4. Promote service standards so the customer expectations and aspirations are met
5. Training for call handlers and personal support is enhanced
6. HRS to look at the support and access to the back office
7. Ensure that when appointments are cancelled by HRS that the customer is advisedto prevent follow up calls
8. Ensure the new call back facility works well to build customer confidence
9. Using every opportunity to promote digital access to the service
10.Review language and instructions for setting up on-line accounts
11.Ensure call handlers can assist callers with setting up on-line account82
Homes for Haringey
Audit and Risk Committee 12 May 20
Report for Audit and Risk Committee
Title Risk Register Q1 2020-21 and Assurance Map
Agenda item 9
Report for Discussion
Classification Public
Report author Puneet Rajput, Director of Corporate Affairs
Contact email [email protected]
Contact telephone 020 8489 3728
1. Introduction
1.1 This report presents the risk register for quarter 1, April – June 2020 and
assurance map, for committee review and comment.
2. Risk and Assurance Documents
2.1 Appendix 1 – Combined summary of all risks in descending order of net severity
and summarised comments on any changes since Q4 2019-20.
2.2 Appendix 2 – Graphical illustration of where risks sit on a chart plotting impact
and likelihood and grading them from high to low.
2.3 The full risk registers for the risk areas identified in the risk strategy, enclosed
separately, for:
i) Corporate (organisation wide and including safeguarding)
ii) Homelessness
iii) Housing management
iv) Property and maintenance
v) Health and safety
2.4 Appendix 3 – Assurance map
3. Quarter 1 (April – June) Risk Review
3.1 The risk register identifies 31 risks in total, the same number as the previous
period. These have been reviewed and continue to remain under review. A
single new risk for the impact of COVID-19 has not been added to the register
as the impact of COVID-19 is reflected in a number of the existing risks. The
impact of COVID-19 will be covered in a separate presentation to the
Committee.
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Audit and Risk Committee 12 May 20
3.2 The aggregate severity helps to provide a view on the overall level of risk within
the organisation and the direction of travel between one period and the next.
The aggregate severity (gross and net) for the five quarters to Q1 2020/21 is set
out in the graph below:
3.3 Changes since the previous quarter’s assessment are summarised in the
paragraphs below.
3.4 Corporate
a) An increase in risk associated with ineffective budget management
largely due to sizeable variances and swings in outturn in HRS
operations.
b) An increase in risk associated with failures to follow policies and
procedures following financial irregularities and more diversified
operations within HRS.
c) A reduction in risk associated with poor performing SLAs for Q4
2019/20 and Q1 2020/21 and Finance and IT in particular in light of
good Finance support to Property Services and similarly IT support in
response to COVID-19.
d) An increase in risk associated with poor procurement practices for
financial issues in Property Services.
e) An increase in the risk that changes in the operating environment make it
harder for HfH to fulfil its purpose. This is primarily due to service
restrictions associated with COVID-19, Health & Safety/Property
400 415 406430
450
239 238 224249
279
0
50
100
150
200
250
300
350
400
450
500
Q1 19/20 Q2 19/20 Q3 19/20 Q4 19/20 Q1 20/21
Aggregate level of Risk in HfH
Gross Net
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Homes for Haringey
Audit and Risk Committee 12 May 20
compliance issues and service weaknesses uncovered following the death
of a resident last year.
f) An increase in risk associated with data quality due to poor Health &
Safety compliance data, tenancy data and old stock condition data.
g) An increase in risk associated with poor management of Haringey
Community Benefit Society operations in light of early performance in
relation to income collection (47% rent collection as at March 2020) and
a need to review the level of resources as more properties are transferred
into HCBS.
3.5 Housing management
a) An increase in the risk of untidy / poorly maintained estates due to the
impact of COVID-19 and restrictions on the ability of front line services
to operate as normal.
3.6 Health and safety
a) An increase in risks associated with employee sickness where frontline
services that come into contact with residents are more exposed to
contracting COVID-19.
b) An increase in the risk of failure to comply with property compliance
obligations in light of current Health & Safety property compliance
concerns.
4. Assurance Map
4.1 The assurance map continues to be reviewed and an updated version
accompanies this report.
4.2 The map has been updated to include service resumption planning to help
assure effective and safe service resumption once current lock down restrictions
ease.
5. Committee Review
5.1 The Committee is recommended to review the risk register and:
a) Identify if it feels there are other risks that should be included on the register
b) Identify if it feels additional controls should be put in place for any particular
risk(s)
c) Identify if it feels any particular sources of assurance should be sought for
confirmation that a risk is being managed effectively
d) Broadly consider the positioning of risks (net severity) in relation to each
other.
85
Key for Risk Register
Score Probability Description Likelihood
1 Almost certain not to
happen
It would be surprising if this happened. There would have to be a combination of unlikely events for it to happen.
Chance of occurrence is once every 25 years.
0% - 10%
2 Unlikely Not anticipated. We won't worry about it happening. Chance of occurrence is once every 15 years. 11% - 39%
3 Possible Just as likely to happen as not. We don't expect it to happen, but there is a chance. Chance of occurrence is once
every 5 years.
40% - 60%
4 Likely It will happen this financial year if control measures are not adequate and regularly monitored. Chance of occurrence
is once every 3 years.
61% - 79%
5 Almost certain It will happen this financial year or during the term of the current business plan. Chance of occurrence is once a year
or more frequently.
80% - 100%
Score Impact
1 Insignificant
2 Minor
3 Moderate
4 Major
5 Catastrophic
Control Ratings
n A strong control and effective at managing the risk in question
n An adequate control but could be strengthened
n The control requires strengthening. It cannot be relied on solely to effectively manage the risk in question
n A weak control, ineffective and cannot be relied on to effectively manage the risk in question
No movement in risk severity Gross: Initial assessment before taking into account any controls
Increase in risk severity Net: Assessment after taking into account controls in place
Reduction in risk severity
An event that requires a major realignment of how the service is delivered. Significant event that has a long recovery period. Large
scale financial mismanagement.
A major disaster from which there is little or no recovery. Significant damage to business credibility or integrity. Complete loss of
ability to deliver a critical programme. Loss of life on a large scale.
Risk Likelihood
Risk ImpactDescription
Can be dealt with locally internally. No escalation required. No media attention and no, or manageable, stakeholder or client
interest.
Can be dealt with at directorate level. Stakeholder or client would take note.
Recovery from the event requires cooperation across directorates. It may generate Council and / or media attention.
86
Appendix 1 - HfH Risk Register Q1 2020/21 - Combined Summary (Descending Order)
Ref Description Risk Lead Gross
Severity
Net
Severity
Move-
ment
Comments
CO11 Changes in the social, political, economic and
technological environment making it harder for HfH
to fulfil its purpose.
Managing
Director
20 15
Impact of COVID-19, resident
death and H&S compliance
issues
CO14 Out of date, inaccurate or missing data resulting in
poor information management and decision making
Director of
Corporate Affairs
20 15
H&S compliance data, tenancy
management data, stock
condition data
CO1 Low levels of satisfaction across different tenures
resulting in a failure to achieve a key Council objective
and Management Agreement requirement.
Managing
Director
15 12
CO2 Failure to manage budgets effectively impacting the
ability for timely planning for the use of a projected
underspend or mitigation of a projected overspend.
Director of
Corporate Affairs
20 12
2019/20 experience in Property
Services and adverse impact on
budget performance
CO3 Adverse impact of Universal Credit resulting in
increased rent arrears, poor tenancy sustainment and
liklihood of increasing homelessness
Executive
Director of
Housing
Management
15 12
CO8 Poor procurement practices resulting in more costly
engagement of supply chain, possible breach of
regulations, external challenge and potential fines.
Director of
Corporate Affairs
15 12
Size of procurement non-
compliance within Property
Services
CO9 Serious breach of data protection resulting in sanction
from the ICO and possible reputational damage.
Director of
Corporate Affairs
16 12
HM1 Weak income management resulting in substantially
unrecoverable debt in both rent and service charge.
Executive
Director of
Housing
Management
20 12
HS2 Serious injury or death of a resident / member of
public as a result of breach of duty by HfH to fulfil its
obligations
Executive
Director of
Housing
Management
16 12
HS3 Serious injury or death as a result of breach of
obligations by HfH to manage properties
Executive
Director of
Property Services
20 12
H&S compliance property
compliance issues
CO12 Inadequate or out of date IT systems that hinder
service effectiveness, efficiency and data
management
Director of
Corporate Affairs
15 10
CO4 Poor people management resulting in average
performance, low productivity, unnecessary costs and
poor talent development.
Director of
Corporate Affairs
15 9
CO5 Failure of staff to follow policies, procedures and
business terms and conditions resulting in serious
injury, reputational damage, external challenge or
financial irregularity such as bribery or fraud
Director of
Corporate Affairs
12 9
Procurement non-compliance,
Gas safety, HRS
CO6 Poor ability to recruit to, or retain, staff in key
positions due to uncompetitive salary levels or
current recruitment processes impacting on the
ability to function and deliver services.
Director of
Corporate Affairs
15 9
CO10 A Council review of the ALMO leading to a decision to
bring the service in house resulting in interim
uncertainty for the ALMO and potential adverse
impact on services to residents.
Managing
Director
16 9
CO13 Failure to manage our safeguarding responsibilities
leading to service failure and reputational damage
Executive
Director of
Housing Demand
12 9
HD1 Excessive reliance on Temporary Accommodation
resulting in substantial financial pressure on LBH and
harm to HfH reputation
Executive
Director of
Housing Demand
16 9
HD4 Inability to source accommodation within pan London
rates which may result in the use of more expensive
TA and shared B&B accommodation
Executive
Director of
Housing Demand
12 9
87
Ref Description Risk Lead Gross
Severity
Net
Severity
Move-
ment
Comments
HM3 Untidy / poorly maintained estates impacting
lettability and creating a negative perception of
council housing.
Executive
Director of
Housing
Management
20 9
Impact of COVID-19
PM3 Delays / lengthy timescale / lack of clarity for
determining capital works programmes (1-30 year)
impacting ability to mobilise resources and deliver,
resulting in poorer standard assets.
Executive
Director of
Property Services
12 9
PM5 Poor sub-contractor management resulting in a
fraudulent activity, loss of assets and reputational
damage.
Deputy Managing
Director
16 9
HD6 Interruption of AST supply during implementation of
Capital Letters and risk of competition resulting in not
meeting core AST target
Executive
Director of
Housing Demand
12 8
HM2 Customer fraud (e.g. Illegal subletting) leading to loss
of revenue / assets and reputational damage.
Executive
Director of
Housing
Management
15 8
CO7 Poor performing services under SLA from the Council
impacting HfH's ability to function effectively and
demonstrate value for money
Managing
Director
12 6
Improved experience over the
last quarter with Finance and IT
CO15 A failure to effectively manage HCBS operations as its
managing agent impacting its service and cost
effectiveness and HfH reputation
Managing
Director
12 6
Low income collection
performance and resources to
be reviewed as more
properties have been acquired
HD3 Loss of the use of Council stock as TA (stock utilised
within regeneration areas, shortlife lodges, Council
owned hostels - e.g. Brunel Walk) resulting in reliance
in more expensive TA types.
Executive
Director of
Housing Demand
9 6
HS1 Serious injury or death of an employee as a result of
breach of duty by HfH as an employer
Executive
Director of
Property Services
9 6
Increased risk of sickness of
those employees continuing to
provide front line services
under threat of COVID-19
PM1 Claims against HfH from contractors resulting in
financial loss / contract overspend.
Executive
Director of
Property Services
12 4
PM2 Insufficient budget provision to meet property
compliance related responsibilities.
Executive
Director of
Property Services
12 4
PM7 Progressive collapse of the tower blocks at
Broadwater Farm in the unlikely event of a gas
explosion
Director of BWF 10 3
PM4 Contractor insolvency impacting ability to repair and
maintain homes and possible financial loss.
Executive
Director of
Property Services
9 2
450 279
88
Appendix 2 - HfH Risk Map Q1 2020/21
5 Catestrophic High
4 Major PM2, HS2, Medium - High
3 Moderate PM7, CO7, HS1,
CO4, CO5, CO6, CO10,
C013, HD1, HD4,
HM3, PM3, PM5,
CO1, CO2, CO3, CO8,
CO9, HM1, CO11, CO14, HS3 Medium
2 Minor PM4 PM1, C015, HD3, HD6, HM2, C012, Low - Medium
1 Insignificant Low
1 Almost certain not to
happen 0-10%
2 Unlikely 10-40% 3 Possible 40-60% 4 Likely 60-80% 5 Almost certain 80-
100%
Imp
act
Likelihood
89
Appendix 3
Internal Controls Assurance Map
Key Strategic Risks
Sources of Assurance
Internal Resident External
A failure in our obligations under health and
safety to our residents, employees and the
properties we manage.
Corporate Health & Safety
Board
Management reporting
Resident Scrutiny Panel
(RSP) review of fire safety
British Safety Council
accreditation
Gas safety (Morgan
Lambert)
A failure to safeguard vulnerable adults and
children.
Safeguarding officer
Management reporting
DAHA accreditation
Adults and Children’s
Safeguarding Boards
Poor financial management of HfH budgets,
including income management, and those
budgets managed by HfH on behalf of the
Council.
Internal audits of contract
procurement, payroll,
housing rents, materials
stock and accounts payable
Management reporting
External audit
Poor workforce performance management
and engagement.
Management reporting
Internal audit of HR
IIP accreditation
A failure in continuity and ability to deliver
services to an acceptable standard.
Data quality audits
Internal audit of
homelessness service
Business Continuity Plans
Service Resumption Plans
(COVID-19)
RSP review of customer
services
Peer review LB Southwark
homelessness service
90
Key Strategic Risks
Sources of Assurance
Internal Resident External
Acts or omissions by HfH that have a
detrimental impact on its reputation.
Internal audits of estate
management and sheltered
housing
Audits of compliance with
processes governing high
risk functions
Resident satisfaction survey
RSP mystery shopping
exercises
Review of Board
governance information
Changes in the social, political, economic
and technological environment, e.g. Brexit,
virus pandemic, making it harder for HfH to
fulfil its purpose.
Management briefings
Business Continuity /
Service Resumption Plans
Haringey Council
91
Audit & Risk Committee Forward Plan 2020
18 February 2020 12 May 2020 14 July 2020 20 October 2020
Presentation: IT Presentation: COVID-19 Presentation: Fleet Management Presentation: TBA
Internal Audit Programme Progress Internal Audit Programme Progress Internal Audit Programme Progress Internal Audit Programme Progress
Internal Audits:
a) Recommendations tracker
b) Vehicle management
c) Disrepair claims
d) Sickness absence
e) HRS bonus scheme
f) Counter fraud Q2&3
19/20
Internal Audits:
a) Internal audit progress
report
b) Internal audit
outstanding
recommendations report
c) Estate management
d) Housing rents
e) Safeguarding
f) Accounts payable and
procurement
g) Payroll
h) Resident engagement
i) Counter fraud report Q4
2019/20
Internal Audits:
a) Internal audit progress
report
b) Internal audit outstanding
recommendations report
c) Internal audit annual report
d) Counter fraud Q1 20/21
TBA
Internal Audits:
e) Internal audit progress
report
f) Internal audit outstanding
recommendations report
g) Counter fraud Q2 20/21
TBA
Internal controls assurance Non-compliant spend report Risk register Q2 2020/21 and
assurance map
Risk register Q3 2020/21 and
assurance map
Internal audit plan 20/21 Resident scrutiny – customer
contact centre
Draft financial statements
(presented by PwC)
Forward plan
External audit plan 2019/20 Risk register Q1 2020/21 and
assurance map
Executive internal controls
assurance
Resident scrutiny of voids
management
Forward plan Audit Committee assurance report
to Board
Arrears write off report Forward plan
Risk register Q4 2019/20
92