Code of Corporate Governance

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


Contents

 

Introduction. 3

What do we mean by Governance?. 3

Core Principles. 3

Responsibilities. 5

How we measure and report performance against the principles. 5

Appendix A - Actions and behaviours to be taken by the councils that demonstrate good governance. 9

 


Introduction


The councils’ Code of Corporate Governance is based upon the CIPFA / SOLACE publication entitled “Delivering Good Governance in Local Government: Framework 2016 Edition.”

This document replaces the previous code of governance – Delivering Good Governance: The Local Code of Governance our Local Code of Governance.

This updated Code, adds detail of expected behaviours and actions in order to comply with the 2016 CIPFA guidance and provides a best practice framework for governance across the council.

 

What do we mean by Governance?


‘The International Framework: Good Governance in the Public Sector’ defines ‘governance’ as comprising the arrangements (including political, economic, social, environmental, administrative, legal and other arrangements) put in place to ensure that the intended outcomes for stakeholders are defined and achieved. The Framework also states that to deliver good governance in the public sector both governing bodies and individuals working for them must aim to achieve the councils’ objectives while acting in the public interest at all times.

Governance is about how the council ensures that it is doing the right things, in the right way, for the right people in a timely, inclusive, open, honest and accountable manner. Good governance leads to effective:

•      leadership and management

•      performance and risk management

•      stewardship of public money

•      public engagement and outcomes for our citizens and service users.

Good governance will enable the council to provide services and deliver its Corporate Plan whilst ensuring that there are mechanisms in place to identify and mitigate any risk.

 

Core Principles


The councils’ Code of Corporate Governance is based on the following seven core principles as set out in ‘The International Framework: Good Governance in the Public Sector’ published by CIPFA / SOLACE:

A.    Behaving with integrity, demonstrating strong commitment to ethical values, and respecting the rule of law.

 

B.    Ensuring openness and comprehensive stakeholder engagement.

 

C.   Defining outcomes in terms of sustainable economic, social, and environmental benefits.

 

D.   Determining the interventions necessary to optimize the achievement of theintended outcomes.

 

E.    Developing the councils’ capacity, including the capability of its leadership and the individuals within it.

 

F.    Managing risks and performance through robust internal control and strong public financial management.

 

G.   Implementing good practices in transparency, reporting, and audit to delivereffective accountability.

 

Infographic setting out the seven core principles of governance

Source: ‘The International Framework: Good Governance in the Public Sector’ published by CIPFA / SOLACE

 

 

The Code specifically identifies the actions and behaviours taken by the councils in relation to each of these core principles and associated sub principles. The Code, along with its supporting infrastructure is set out below at Appendix A.

The Annual Governance Statement provides evidence of the council’s compliance with the seven core principles.

 

 

Responsibilities


Councillors and officers are collectively responsible for the governance of the council.  This is achieved by councillors setting the policy parameters and officers delivering services within these parameters.


The statutory officers, the Head of Paid Service (Chief Executive), Section 151 Officer (Chief Finance Officer) and the Monitoring Officer have responsibility for advising council and cabinet on legislative, financial operational matters and ensuring that the council is governed effectively in line with the requirements of this Code.

 

The Joint Audit and Governance Committee is responsible for monitoring, governance matters and recommending this Code to council for adoption and will ensure its effectiveness.

 

How we measure and report performance against the principles


 

On an annual basis, each of our Heads of Service will be asked to complete assurance statements explaining actions they have taken throughout the financial year to assess and evidence compliance with the expected behaviours, as set out in Appendix A, within their areas of responsibility. 

 

These statements then inform and support our Annual Governance Statement, which forms a part of our end of year Statement of Accounts, and also identify actions needed for the forthcoming year to address any areas of non-compliance.  We review the information from the Managers Assurance Statements to update this code with the evidence of our compliance.

 

The Joint Audit and Governance Committee is responsible for recommending this Code to council for adoption and ensuring it is reviewed annually to ensure its effectiveness and that it is updated accordingly.



Appendix A - Actions and behaviours to be taken by the councils that demonstrate good governance.

 

Core Principle A. Behaving with integrity, demonstrating strong commitment to ethical values, and respecting the rule of law.

 

Sub Principle: Behaving with integrity

 

Lead Officers

Evidence base

1.    Ensure that members and officers behave with integrity and lead a culture where acting in the public interest is visible and consistently demonstrated thereby protecting the reputation of the councils.

 

2.    Ensure that members take the lead in establishing values for the councils and officers and that they are communicated and understood. These will build on the Seven Principles of Public Life (The Nolan Principles).

 

3.    Lead by example and use the values as a framework for decision making and other actions.

 

4.    Demonstrate, communicate and embed values through appropriate policies and processes which will be reviewed on a regular basis to ensure they are operating effectively.

Head of Legal and Democratic / People and Culture Manager

 

 

 

Head of Legal and Democratic

 

 

 

 

 

 

All Heads of Service/Service Managers

 

 

All Heads of Service/Service Managers

·         The councils have a Councillor Code of Conduct which is in compliance with the Localism Act 2011 and sets out expected behaviours with the aim of maintaining public confidence in both the councils and council members. The code of conduct is embedded within our constitution which is published on each council’s website:

o   Constitution – South Oxfordshire District Council

o   Constitution – Vale of White Horse District Council

o   Councillor's Code of Conduct South Oxfordshire District Council

o   Councillor's Code of Conduct Vale of White Horse District Council

·         An Employee Conduct Policy forms part of each officer’s contract of employment and covers expected behaviours. The Employee Conduct Policy is published within a set of contractual policies on each council’s website:

o   Contractual Policies - South Oxfordshire District Council

o   Contractual Policies - Vale of White Horse District Council

·         There is also a Code of Conduct for Officers which, together with the Code of Conduct for Members includes and builds on the Nolan Principles.

·         For both officers and council members to maintain transparency and identify and mitigate any potential conflicts, the council maintains a Register of Interests and a Register of Gifts and Hospitalities.  Registers for officers are held internally but both registers for members are available within the details for each council member on our websites:

o   Councillors - South Oxfordshire District Council

o   Councillors - Vale of White Horse District Council

·         In keeping with our Constitution, council meetings and committees are conducted in accordance with procedure rules which include expected behaviours for decision makers. Declarations of interest are made and minuted at the start of each meeting to avoid conflict arising during the meetings. The constitution also includes a protocol for interaction between officers and members and can be found on each councils’ website:

o   Constitution – South Oxfordshire District Council

o   Constitution – Vale of White Horse District Council

 

Sub Principle: Demonstrating strong commitment to ethical values

Lead Officers

Evidence base

5.    Seek to establish, monitor and maintain the councils’ ethical standards and performance.

 

6.    Underpin personal behaviour with ethical values and ensure they permeate all aspects of the councils’ culture and operation.

 

7.    Develop and maintain robust policies and procedures which place emphasis on agreed ethical values.

 

8.    Ensure that external providers of services on behalf of the organisation are required to act with integrity and in compliance with ethical standards expected by the councils.

Head of Legal and Democratic

 

All Heads of Service/Service Managers

 

 

 

All Heads of Service/Service Managers

 

 

All Heads of Service/Service Managers

·         This Code of Corporate Governance is set out within our Constitution which includes a requirement to operate in an ethical manner. This is reinforced within both the Protocol on Member and Officer Relations and the Officer Code of Conduct. The standards of conduct for councillors and any complaints arising are overseen by the Joint Audit and Governance Committee.

o   Constitution – South Oxfordshire District Council

o   Constitution – Vale of White Horse District Council

·         Each council states a set of values on our internal intranet. These include an expectation for officers to demonstrate a commitment to upholding integrity and ethical values. We plan and provide services and policies in a fair, inclusive and equal way to promote good relations as set out in our Diversity and Inclusion Strategy available on our website.

o   Equalities – South Oxfordshire District Council

o   Equalities – Vale of White Horse District Council  

·         We recognise in our Procurement Strategy that the purchase of goods, services and works should promote ethical procurement. Each council publishes a statement on its website for organisations and individuals selling to the council which covers expected standards of conduct as well as ethical and legal requirements. These requirements also take into account the National Procurement Policy Statement PPN 5/21, the National Procurement Strategy for Local Government in England 2018, The Public Contracts Regulations 2015, the Local Government Transparency Code 2015 and the Modern Slavery Act 2015.

o   Selling to the council – South Oxfordshire District Council

o   Selling to the council – Vale of White Horse District Council

 

Sub Principle: Respecting the rule of law

 

Lead Officers

Evidence base

9.    Ensure members and officers demonstrate a strong commitment to the rule of the law as well as adhering to relevant laws and regulations.

 

 

10. Create the conditions to ensure that the statutory officers, other key post holders, and members are able to fulfil their responsibilities in accordance with legislative and regulatory provisions.

 

11. Strive to optimise the use of the full powers available for the benefit of citizens, communities and other stakeholders.

 

12. Deal with breaches of legal and regulatory provisions effectively.

 

13. Ensure corruption and misuse of power is dealt with effectively.

Head of Legal and Democratic / People and Culture Manger

 

 

Chief Executive

 

 

 

 

 

 

 

 

All Heads of Service/Service Managers

 

 

 

Head of Legal and Democratic / People and Culture Manager

 

·         Our templates for reports, policies and decision making are available to officers on our internal intranet and include sections to record legal implications.

·         Members on decision making committees, such as licensing panels and planning committees, receive bespoke training to cover the legal aspects of their roles.

·         The Monitoring Officer provides training to officer and members on good decision making.

 

·         Our Chief Executive has the role of Head of Paid Service with overall accountability for the governance arrangements and officers operating within the councils.

·         The Head of Legal and Democratic has the statutory role of Monitoring Officer, who ensures the council, council officers and members operate legally and maintain the highest standards of conduct in all they do.

·         The Chief Finance Officer (Section 151) has overall responsibility for the councils financial position.

·         All statutory officers meet regularly to discuss governance issues

·         We have an Anti-Fraud, Corruption and Bribery Policy which aims to help officers understand when and who to contact if they have concerns about fraud, bribery or corruption. This also emphasises the need for officers to adhere to legal requirements and ensure all procedures and practices remain above reproach. We publish the policy on our websites within the contractual policies section.

o   Contractual Policies – South Oxfordshire District Council

o   Contractual Policies – Vale of White Horse District Council

 

·         Our Whistleblowing Policy is available to officers on our internal intranet, and this explains how officers can raise concerns about suspected wrongdoing and how the councils manage any allegations.

 

 

Core Principle B. Ensuring openness and comprehensive stakeholder engagement.

 

Sub Principle: Openness

 

Lead Officers

Evidence base

14. Ensure an open culture through demonstrating, documenting and communicating the councils’ commitment to openness.

 

15. Make decisions that are open about actions, plans, resource use, forecasts, outputs and outcomes. The presumption will be for openness. If that is not the case, a justification for the reasoning for keeping a decision confidential will be provided.

 

16. Provide clear reasoning and evidence for decisions in both public records and explanations to stakeholders and will be explicit about the criteria, rationale and considerations used. In due course, the councils will ensure that the impact and consequences of those decisions are clear.

 

17. Use formal and informal consultation and engagement to determine the most appropriate and effective interventions / courses of action.

All Heads of

Service/Service

Managers

 

 

 

 

 

 

All Heads of Service/Service Managers

 

 

 

 

 

 

 

 

 

All Heads of Service/Service Managers

 

 

 

 

 

 

 

 

 

 

 

 

All Heads of Service/Service Managers

 

·         South Oxfordshire District Council has a specific theme of openness and accountability within its four-year Corporate Plan.  The plan is available on the council website:

o   Corporate Plan 2020- 2024 - South Oxfordshire District Council

·         Vale of White Horse District Council has a specific theme of working in an open and inclusive way within its four-year Corporate Plan.  The plan is available on the council website:

o   Corporate Plan 2020 – 2024 - Vale of White Horse District Council

·         We publish agendas and minutes for council meetings and committees on each councils’ website. Agenda items are supported by a reports pack with documents supporting topics being discussed and these can be accessed individually as well. The reports set out the background and information supporting the agenda item and explains if an item is considered confidential. This detail is available on the individual committee/meeting pages from the listing on the main meetings webpage. 

o   Meetings list – South Oxfordshire District Council

o   Meetings list – Vale of White Horse District Council

·         Exemptions from publication are the exception with the public interest test being applied.  The Monitoring Officer adjudicates on requests for exemption at the point of publication

·         Each council has a Decision Register on their website recording decisions made by any of the councils’ decision makers. The register can be searched by key words, by date ranges and by specific decision makers. As well as a summary outline, a link is provided to the individual decision notice which includes reasons for the decision.

o   Decision Register – South Oxfordshire District Council

o   Decision Register – Vale of White Horse District Council

·         We make information available in many ways and to support openness and accountability in how we operate we publish sets of easy to access information within a Data Hub on each council’s website. The information includes our decisions, performance and data reports and items we publish under the Transparency Regulations and Code 2015 and Model Publication Scheme.

o   Data Hub – South Oxfordshire District Council

o   Data Hub – Vale of White Horse District Council

·         Each council publishes live and closed consultations on their website and a specific Statement of Community Involvement covering the planning policy and planning development consultation process.

o   Data Hub – South Oxfordshire District Council

o   Data Hub – Vale of White Horse District Council

·         We have an in-house Consultation and Engagement Team to help officers gather views of organisations and residents to obtain feedback, plan a project, validate the decision-making process or fulfil a statutory duty. Various methods are used including online and postal surveys, focus groups exhibitions and use of social media channels. Specific details are set out in the next two sections.

·         The councils produce an Annual Consultations Report.

 

Sub Principle: Engaging comprehensively with institutional stakeholders

Lead Officers

Evidence base

18. Effectively engage with institutional stakeholders to ensure that the purpose, objectives and intended outcomes for each stakeholder relationship are clear so that outcomes are achieved successfully and sustainably.

 

19. Develop formal and informal partnerships to allow for resources to be used more efficiently and outcomes achieved more effectively.

 

20. Ensure that partnerships are based on trust, a shared commitment to change, a culture that promotes and accepts challenge among partners and that the added value of partnership working is explicit.

 

All Heads of Service/Service Managers

 

 

 

 

 

 

 

All Heads of Service/Service Managers

 

 

 

 

All Heads of Service/Service Managers

 

·         Each council has a Communications and Engagement Strategy setting out how we encourage our stakeholders to voice their views on our work and services. These are available on each councils’ website:

o   Communications and Engagement Strategy – South Oxfordshire District Council

o   Communications and Engagement Strategy – Vale of White Horse District Council

 

·         The councils have a Deputy Chief Executive with responsibility, set out in our constitution, for Partnerships who acts as the councils’ representative in communication with our strategic partners. This role is also the lead for the Five Councils’ Partnership.

 

Sub Principle: Engaging stakeholders effectively, including individual citizens and service users

Lead Officers

Evidence base

21. Establish a clear policy on the type of issues that the councils will meaningfully consult with or involve communities, individual citizens, service users and other stakeholders to ensure that service (or other) provision is contributing towards the achievement of intended outcomes.

 

22. Ensure that communication methods are effective, and that members and officers are clear about their roles with regard to community engagement.

 

23. Encourage, collect and evaluate the views and experiences of communities, citizens, service users and organisations of different backgrounds including reference to future needs.

 

24. Implement effective feedback mechanisms in order to demonstrate how their views have been taken into account.

 

25. Balance feedback from more active stakeholder groups with other stakeholder groups to ensure inclusivity.

 

 

26. Take account of the interests of future generations of taxpayers and service users.

All Heads of Service/Service Managers

 

 

 

 

 

 

 

 

 

All Heads of Service/Service Managers

 

 

All Heads of Service/Service Managers

 

 

 

All Heads of Service/Service Managers

 

All Heads of Service/Service Managers

 

All Heads of Service/Service Managers

 

·         The public are able to observe most business at council meetings and can register to speak to or ask questions about items on council or committee agendas. The agendas are published 5 working days ahead of the meetings and a calendar of meetings and explanation of the responsibilities for each meeting are published on the councils’ websites:

o   Meetings – South Oxfordshire District Council

o   Meetings – Vale of White Horse District Council 

·         Each council has a Communications and Engagement Strategy setting out how we encourage our stakeholders to voice their views on our work and services. These are available on each councils website:

o   Communications and Engagement Strategy – South Oxfordshire District Council

o   Communications and Engagement Strategy – Vale of White Horse District Council

·         We publish ways that residents can get involved and have their say in the councils’ work through Consultation and Engagement activities. This includes details on each council’s website and an option to register an interest to be kept informed of our consultations:

o   Consultations - South Oxfordshire District Council

o   Consultations - Vale of White Horse District Council

·         The above web pages also include specific guidance for consultation about planning policy and planning development by way of a Statement of Community Involvement.

·         Larger scale or longer-term projects may include their own ways of engaging with residents, such as through sounding boards and newsletters. For example the Didcot Garden Town delivery which spans both councils:

o   Didcot Garden Town – South Oxfordshire District Council

o   Didcot Garden Town - Vale of White Horse District Council

·         Both councils are working together on a Joint Local Plan which will inform planning policy and decisions for the districts. The consultation used interactive maps, a video and images designed to work on various platforms. An Equalities Impact Screening Assessment ensured proper consideration to equality and diversity. The next stage is a consultation statement and a statement of preferred options for further comment. Details are published on each councils’ website:

o   Joint Local Plan 2041 – South Oxfordshire District Council

o   Joint Local Plan 2041 – Vale of White Horse District Council

 

 

Core Principle C. Defining outcomes in terms of sustainable economic, social, and environmental benefits.

 

Sub Principle: Defining outcomes

 

Lead Officers

Evidence base

27. Have a clear vision set out in a corporate plan, which is an agreed formal statement of the councils’ purpose and intended outcomes containing appropriate performance indicators, which provide the basis for the councils’ overall strategy, planning and other decisions.

 

28. Specify the intended impact on, or changes for, stakeholders including citizens and service users which may be immediately or over the course of a year or longer.

 

29. Deliver defined outcomes on a sustainable basis within the resources that will be available.

 

30. Identify, mitigate and manage risks to the achievement of outcomes.

 

31. Manage residents’ expectations effectively with regard to determining priorities and making the best use of the resources available.

Head of Policy and Programmes

 

 

 

 

 

 

 

 

Head of Policy and Programmes

 

 

 

 

All Heads of Service/Service Managers

 

 

All Heads of Service/Service Managers

 

All Heads of Service/Service Managers

 

 

·         Both councils have a four-year Corporate Plan setting out strategic themes with projects and performance measures associated with each theme. The plans are available on the councils’ websites:

o   Corporate Plan 2020- 2024 - South Oxfordshire District Council

o   Corporate Plan 2020 – 2024 - Vale of White Horse District Council

 

·         The Corporate Plan for each council explains why each theme has been adopted and the aims over a four-year period and has focus on sustainability.  This is due to be reviewed and a new plan adopted in 2024

 

·         The councils have a risk management framework which includes corporate and operational Risk Registers to help identify, mitigate and manage the risks that may affect us achieving our stated aims. Individual projects include monitoring of the risks associated throughout the lifetime of the project through a risk register as part of our approach to project management.

 

·         Each council publishes a Corporate Performance Report on a quarterly basis which has explanations for key activities set out by each theme in the Corporate Plan as well as updates on performance and is monitored and updated by responsible officers. The Corporate Performance Report is available on each councils’ website:

o   Corporate Performance - South Oxfordshire District Council

o   Corporate performance - Vale of White Horse District Council

 

·         All officers are aware of their responsibility to achieve value for money with council resources.  The Corporate Plan provides residents with a detailed scheme of priorities.

Sub Principle: Sustainable economic, social, and environmental benefits

Lead Officers

Evidence base

32. Consider and balance the combined economic, social, equality and environmental impact of policies, plans and decisions when taking decisions about service provision.

 

33. Take a longer-term view with regard to decision making, taking account of risk and acting transparently where there are potential conflicts between the councils’ intended outcomes and short-term factors such as the political cycle or financial constraints.

 

34. Determine the wider public interest associated with balancing conflicting interests between achieving the various economic, social and environmental benefits, through consultation where possible, in order to ensure appropriate trade-offs.

 

35. Ensure fair access to services.

All Heads of Service/Service Managers

 

 

 

 

 

All Heads of Service/Service Managers

 

 

 

 

 

 

 

All Heads of Service/Service Managers

 

 

 

 

 

 

 

All Heads of Service/Service Managers

 

·         The councils’ activities are guided by our four-year Corporate Plan and by fulfilling our statutory responsibilities. Key measures are reviewed and reported via quarterly and annual corporate plan performance reports. The reports are subject to an approval process by our senior management team, Scrutiny Committee, Climate and Ecological Emergency Advisory Committee and Cabinet which ensures the necessary checks and balances are in place around monitoring, evaluation, decision-making and policymaking.

·         Our decision-making process includes statements explaining the implications of the decision affecting at least the following and these are embedded within our reporting and decision-making templates:

o   climate and ecological

o   legal

o   financial.

     Other implications that may be considered are:

o   equalities and diversity

o   health and safety

o   crime and disorder

o   risks.

    Consultation is required with council leads for:

o   legal advice

o   financial advice

o   procurement

o   infrastructure

o   equalities

o   communications.

·         In keeping with the Public Services Social Value Act 2012, our Procurement Strategy requires us to consider how the economic, social and environmental wellbeing of our area may be improved when we buy public service contracts. Each council publishes a statement on its website for organisations and individuals selling to the council which covers adding social value.

o   Selling to the council – South Oxfordshire District Council

o   Selling to the council – Vale of White Horse District Council

·         Each councils’ Corporate Plan has taken account of the wider public interest as each has been developed following engagement with residents and took account of hundreds of responses that informed the priorities each council will deliver.

·         Each council has declared a Climate Emergency and developed a Climate Action Plan. Regular reports and updates are published that tie in with each council’s Corporate Plan:

o   Climate Action – South Oxfordshire District Council

o   Climate Action – Vale of White Horse District Council

·         We plan and provide services and policies in a fair, inclusive and equal way to promote good relations as set out in our Corporate Equality Policy available on our website.

o   Equalities – South Oxfordshire District Council

o   Equalities – Vale of White Horse District Council

 

 

Core Principle D. Determining the interventions necessary to optimize the achievement of the intended outcomes.

 

Sub Principle: Determining interventions

 

Lead Officers

Evidence base

36. Ensure decision makers receive objective and rigorous analysis of a variety of options indicating how intended outcomes would be achieved and including the risks associated with those options. Therefore, ensuring value for money is achieved however services are provided.

 

37. Consider feedback from residents when making decisions about service improvements or where services are no longer required in order to prioritise competing demands within limited resources available including people, skills, land and assets and bearing in mind future impacts.

All Heads of Service/ Service Managers

 

 

 

 

 

 

All Heads of Service/ Service Managers

 

·         As covered in evidence for points 32 to 35 above, our decision-making documents include the need to record associated risks and seek input from key stakeholders. The documents also captures details of alternative options that we considered.

·         Our published decision records for decisions made by either council officers or members include:

o   A clear explanation of the reasons for the decision and the assessment criteria used

o   a statement about alternative options that were considered where appropriate

o   a list of consultees with brief comments, including from the councils’ risk and insurance officer.

·         We publish ways that residents can get involved and have their say in the councils’ work through consultation and engagement activities. This includes details on each council’s website and an option to register an interest to be kept informed of our consultations:

o   Consultations - South Oxfordshire District Council

o   Consultations - Vale of White Horse District Council

·         The above web pages also include specific guidance for consultation about planning policy and planning development by way of a Statement of Community Involvement.

·         Larger scale or longer-term projects may include their own ways of engaging with residents, such as through sounding boards and newsletters. For example the Didcot Garden Town delivery which spans both councils:

o   Didcot Garden Town – South Oxfordshire District Council

o   Didcot Garden Town - Vale of White Horse District Council

 

Sub Principle: Planning interventions

 

Lead Officers

Evidence base

38. Establish and implement robust planning and control cycles that cover strategic and operational plans, priorities and targets.

 

39. Engage with internal and external stakeholders in determining how services and other courses of action should be planned and delivered.

 

40. Consider and monitor risks facing each partner when working collaboratively including shared risks.

 

41. Ensure arrangements are flexible and agile so that the mechanisms for delivering outputs can be adapted to changing circumstances.

 

42. Establish appropriate key performance indicators (KPIs) as part of the planning process in order to identify how the performance of services and projects is to be measured.

 

43. Ensure capacity exists to generate the information required to review service quality regularly.

 

44. Prepare budgets in accordance with organisational objectives, strategies and the medium-term financial plan.

 

45. Inform medium- and long-term resource planning by drawing up realistic estimates of revenue and capital expenditure aimed at developing a sustainable funding strategy.

 

All Heads of Service/ Service Managers

All Heads of Service/ Service Managers

 

 

All Heads of Service/ Service Managers

 

All Heads of Service/ Service Managers

 

 

All Heads of Service/ Service Managers

 

 

 

 

All Heads of Service/ Service Managers

 

 

Head of Finance

 

 

 

 

Head of Finance

 

·         Both councils have a four-year Corporate Plan with projects and performance measures associated with each strategic theme. The plans are available on the councils’ websites:

o   Corporate Plan 2020- 2024 - South Oxfordshire District Council

o   Corporate Plan 2020 – 2024 - Vale of White Horse District Council

·         Both councils have a Performance Management Process ‘Let’s Talk’. This involves continuous constructive conversations between council officers and their line manager or supervisor.  Goals and objectives are identified for the coming 12 months along with support and development needs to achieve agreed targets..

 

·         Our Annual Budget Setting Process is explained in our reports on the Revenue Budget and Capital Programme presented to each council’s Cabinet, Scrutiny Committee and Council for approval. Issues affecting the budget setting are listed along with reflection of the budget base estimated in the previous year Medium Term Financial Plan. The annual budget follows a programme of internal scrutiny and challenge across the council by the Head of Finance and Strategic Finance Team. The budget information is available on each councils’ website by year of budget and has supporting documents including the Medium-Term Financial Plan:

o   Annual budget information – South Oxfordshire District Council

o   Annual budget information – Vale of White Horse District Council

 

Sub Principle: Optimising achievement of intended outcomes

Lead Officers

Evidence base

46. Ensure the medium-term financial plan integrates and balances service priorities, affordability and other resource constraints.

 

47. Ensure the budgeting process is all-inclusive, taking into account the full cost of operations over the medium and longer term.

 

48. Ensure the medium-term financial plan sets the context for ongoing decisions on significant delivery issues or responses to changes in the external environment that may arise during the budgetary period in order for outcomes to be achieved while optimising resource usage.

 

49. Ensure the achievement of ‘social value’ through service planning and commissioning.

Strategic Finance Manager/ S151 Officer

 

 

Strategic Finance Manager/ S151 Officer

 

 

Strategic Finance Manager/ S151 Officer

 

 

 

 

 

 

 

All Heads of Service/ Service Managers

 

·         Each council has a Treasury Management Strategy describing the management of cashflow, banking, money market and capital transactions which is approved annually for the year ahead. A report on activity and performance against the strategy for the previous year is presented to the Joint Audit and Governance Committee and includes a review of economic conditions and factors impacting investments. Both the annual reports and the strategies are available on each councils’ website:

o   Treasury Management - South Oxfordshire District Council

o   Treasury Management - Vale of White Horse District Council

·         A Medium-Term Financial Plan providing a forward budget model for the next five years is agreed as part of each council’s annual budget setting process.

·         Our Annual Budget Setting Process is explained in our reports on the Revenue Budget and Capital Programme presented to each council’s Cabinet, Scrutiny Committee and Council for approval. Issues affecting the budget setting are listed along with reflection of the budget base estimated in the previous year Medium Term Financial Plan. The annual budget follows a programme of internal scrutiny and challenge across the council by the Head of Finance and Strategic Finance Team. The budget information is available on each councils’ website by year of budget and has supporting documents including the Medium-Term Financial Plan:

o   Annual budget information – South Oxfordshire District Council

o   Annual budget information – Vale of White Horse District Council

·         In keeping with the Public Services Social Value Act 2012, our Procurement Strategy requires us to consider how the economic, social and environmental wellbeing of our area may be improved when we buy public service contracts. Each council publishes a statement on its website for organisations and individuals selling to the council which covers adding social value.

o   Selling to the council – South Oxfordshire District Council

o   Selling to the council – Vale of White Horse District Council

 

 

Core Principle E. Developing the councils’ capacity, including the capability of its leadership and the individuals within it.

 

Sub Principle: Developing the councils’ capacity

 

Lead Officers

Evidence base

50. Review operations, performance and use of assets on a regular basis to ensure their continuing effectiveness.

 

51. Improve resource use through appropriate application of techniques such as benchmarking and other options in order to determine how the councils’ resources are allocated so that outcomes are achieved effectively and efficiently.

 

52. Recognise the benefits of partnerships and collaborative working where added value can be achieved.

 

53. Develop and maintain an effective workforce plan to enhance the strategic allocation of resources.

All Heads of Service/ Service Managers

 

 

 

All Heads of Service/ Service Managers

 

 

 

 

 

 

 

All Heads of Service/ Service Managers

 

 

All Heads of Service/ Service Managers

 

·         Both councils operate a shared service, although remaining separate legal and sovereign entities so benefit from partnership and collaborative working across all service areas, for example working together on a Joint Local Plan 2041. The councils jointly work with other organisations for service delivery, for example through the 5 Councils Partnership.

·         Each council has identified organisations that can impact upon council services and representatives contribute through forums and committees that are responsible for them to maintain an effective partnership. The lists and representatives are available on each council’s website:

o   Partnership organisations – South Oxfordshire District Council

o   Partnership organisations – Vale of White Horse District Council

·         South Oxfordshire District Council recognises the benefit from collaborating and working in partnership. An example is set out in the Corporate Plan objective to protect and restore our natural world which lists projects to work in partnership and to establish a Local Nature Partnership now established.  The plan is available on the council website:

o  Corporate Plan 2020- 2024 - South Oxfordshire District Council

·         Vale of White Horse District Council has a specific theme of working in partnership within its four-year Corporate Plan.  This sets out a commitment to partnership working with other councils, authorities and businesses, non-profit organisations, community and residents’ groups to achieve our aims and objectives effectively, efficiently and fairly. The plan is available on the council website:

o  Corporate Plan 2020 – 2024 - Vale of White Horse District Council

·         Both councils have a Performance Management Process ‘Let’s Talk’. This involves continuous constructive conversations between council officers and their line manager or supervisor.  Goals and objectives are identified for the coming 12 months along with support and development needs to achieve agreed targets. The process includes training for managers or supervisors who need to review performance.

·         Each service area within the councils has a business recovery team and Business Resilience Plan which feeds into the corporate plan, where critical processes and contingencies are mapped.

·         Our internal audit team have responsibility to review, appraise and report on the soundness and adequacy of our control systems and also our economical, efficient and effective use of resources.

 

Sub Principle: Developing the capability of the councils’ leadership and other individuals.

Lead Officers

Evidence base

54. Develop protocols to ensure that elected and appointed leaders negotiate with each other regarding their respective roles early on in the relationship and that a shared understanding of roles and objectives is maintained.

 

55. Publish a statement that specifies the types of decisions that are delegated and those reserved for the collective decision making of the governing body.

 

56. Ensure the leaders and the chief executive have clearly defined and distinctive leadership roles within a structure whereby the chief executive leads the councils in implementing strategy and managing the delivery of services and other outputs set by members and each provides a check and a balance for each other’s authority.

 

57. Develop the capabilities of members and senior management to achieve effective shared leadership and to enable the organisation to respond successfully to changing legal and policy demands as well as economic, political and environmental changes and risks by ensuring:

  • members and officers have access to appropriate induction tailored to their role and that ongoing training and development matching individual and organisational requirements is available and encouraged;
  • members and officers have the appropriate skills, knowledge, resources and support to fulfil their roles and responsibilities and ensuring that they are able to update their knowledge on a continuing basis; and
  • personal, organisational and system-wide development through shared learning, including lessons learnt from governance weaknesses both internal and external.

 

58. Ensure that there are structures in place to encourage public participation.

 

59. Take steps to consider the leadership’s effectiveness and ensure leaders are open to constructive feedback from peer review and inspections.

 

60. Hold staff to account through regular performance reviews which take account of training or development needs.

 

61. Ensure arrangements are in place to maintain the health and wellbeing of the workforce and support individuals in maintaining their own physical and mental wellbeing.

 

Head of Legal and Democratic

 

 

 

 

 

 

 

Head of Legal and Democratic

 

 

 

 

 

Chief Executive

 

 

 

 

 

 

 

 

 

 

 

 

 

Head of Legal and Democratic / People and Culture Manager

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

All Heads of Service/ Service Managers

 

 

Head of People and Culture

 

 

 

All Heads of Service/ Service Managers

 

 

All Heads of Service/ Service Managers

 

 

·         The councils deliver mandatory councillor training for those newly appointed to the role. This is supported by:

o   a clear three-month training plan

o   members handbook

o   online resources

o   a ‘buddy system’ to provide support to those new to the role

·         Our Constitution includes a protocol for interaction between officers and members and a scheme of delegation.

·         Part 2 of the Constitution covers decision making processes and the Scheme of Delegation set out functions which are the responsibility of the Cabinet, Council and local choice functions, and delegation to officers. The constitution can be found on each councils’ website:

o   Constitution – South Oxfordshire District Council

o   Constitution – Vale of White Horse District Council

·         We have job descriptions in place setting out roles and responsibilities for all officers including our Chief Executive and senior management roles

·         Our senior officers and managers have development plans set out as part of their regular review under our Performance Management process.

·         We have an Induction Programme for officers which includes mandatory training and procedures in addition to service area specific requirements and personalisation to the individual officer.

·         Job Descriptions are in place for each role which set out the expected skills, knowledge and responsibilities. Our performance management programme, as covered in the section above, identifies ongoing training and development needs.

·         Each service area produces a Monthly Members Update which reports on service team performance and discusses key tasks and issues as well as budget and staffing pressures. The updates are discussed at monthly catch up meetings between the Head of Service and the relevant portfolio holder.

·         Our Annual Governance Statements, also see point 84 below, sets out actions for the coming year following review of the governance arrangements in order to address any issues identified.

·         All members undergo an induction process upon being elected with bespoke training provide, some of which is mandatory.

·         The councils operate a corporate training support programme.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

·         Both councils encourage participation by service teams in Local Government Association peer-supported improvement programmes, including peer challenges.

 

 

·         Both councils have a Performance Management Process ‘Let’s Talk’. This involves continuous constructive conversations between council officers and their line manager or supervisor.  Goals and objectives are identified for the coming 12 months along with support and development needs to achieve agreed targets. The process includes training for managers or supervisors who need to review performance. The Chief Executive Officer is held to account by the Leaders of the councils and their performance is monitored by the Joint Staff Committee.

·         We have a Corporate Training System ‘LEAH’ to deliver training modules and to ensure key policies and procedures are read by council officers. This includes statutory policies such as those covering data protection and health and safety.

·         Both councils promote and support the need to take care of Personal Wellbeing both physically and mentally. Our internal intranet has a list of wellbeing resources officers can use, which includes a free and confidential telephone support programme and ‘Healthy Advantage’ app. A wellbeing group works with our Strategic HR team to identify wellbeing activities.

 

Core Principle F. Managing risks and performance through robust internal control and strong public financial management.

 

Sub Principle: Managing risk

 

Lead Officers

Evidence base

62. Recognise that risk management is an integral part of all activities which must be considered in all aspects of decision making.

 

63. Implement robust and integrated risk management arrangements and ensure that they are working effectively.

 

64. Ensure that responsibilities for managing individual risks are clearly allocated.

Head of Finance/ Internal Audit Manager

 

 

 

 

Head of Finance/ Internal Audit Manager

 

 

 

All Heads of Service/ Service Managers

 

 

 

 

·         The councils have a Risk Management Framework comprising a Risk Management Strategy and Risk Management Policy and Guidance. These documents set out the approach to assessing and managing risks across all operations and are available to officers within our intranet. The overall process for managing risks is:

Infographic with the overall process for managing risks
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 


·         The approach includes regular review and update of corporate and operational Risk Registers to help manage the risks that may affect us achieving our stated aims. The risks identified are aligned with our Corporate Plan objectives and specific officers are named as owners of each risk.

 

·         A Corporate Risk Review is repeated each half year to the councils’ Joint Audit and Governance Committee. This reports on progress of the corporate risk registers as outlined in the risk management strategy.

 

·         Individual projects include monitoring of the risks associated throughout the lifetime of the project as part of our approach to project management.

 

·         The councils internal audit function takes a risk-based approach.

 

Sub Principle: Managing performance

 

Lead Officers

Evidence base

65. Monitor service delivery effectively including planning, specification, execution and independent post implementation review.

 

66. Make decisions based on relevant, clear objective analysis and advice pointing out the implications and risks inherent in the councils’ financial, social and environmental position and outlook.

 

67. Ensure effective audit, scrutiny or oversight function is in place which encourages constructive challenge and debate on policies and objectives before, during and after decisions are made thereby enhancing the councils’ performance and that of any organisation for which it is responsible.

 

68. Provide members and senior management with regular reports on service delivery plans and on progress towards outcome achievement.

69. Ensure there is consistency between specification stages (such as budgets) and post implementation reporting (e.g. financial statements).

 

All Heads of Service/ Service Managers

 

 

 

 

All Heads of Service/ Service Managers

 

 

 

 

 

 

 

Head of Legal and Democratic / Head of Finance/ Internal Audit Manager

 

 

 

 

 

 

 

All Heads of Service/ Service Managers

 

 

 

 

All Heads of Service/ Service Managers

 

 

 

·         Our decision-making process includes statements explaining the implications of the decision affecting at least the following and these are embedded within our reporting and decision making templates:

o   climate and ecological

o   legal

o   financial.

     Other implications that may be considered are:

o   equalities and diversity

o   health and safety

o   crime and disorder

o   risks.

    Consultation is required with council leads for:

o   legal advice

o   financial advice

o   climate and ecological advice

o   procurement

o   infrastructure

o   equalities

o   communications.

·         Each council’s committee structure, as set out in our Constitution, which includes a Scrutiny Committee with functions including

o   review and scrutiny of decisions made by the Cabinet, Council, committees and officers

o   review the councils’ progress in achieving policy aims and performance targets

o   review the performance of individual services or Cabinet member portfolios

o   consider and make recommendations on mechanisms to encourage and enhance community participation in the development of policy options.

·         Heads of service have monthly catch-up meetings with the relevant portfolio holder to provide a Monthly Members Update covering progress within the service area.

 

 

Sub Principle: Robust internal control

 

Lead Officers

Evidence base

70. Align the risk management strategy and policies on internal control with achieving objectives.

 

71. Evaluate and monitor the councils risk management and internal control arrangements on a regular basis.

 

72. Ensure effective counter fraud, anti-corruption and whistleblowing arrangements are in place.

 

 

 

73. Ensure additional assurance on the overall adequacy and effectiveness of the framework of governance, risk management and control is provided by the internal auditor.

 

74. Ensure an effective audit and scrutiny function is in place which is independent of the executive and accountable to each council and which

  • provides a further source of effective assurance regarding arrangements for managing risk and maintaining an effective control environment; and
  • that recommendations are listened to and acted upon.

Head of Finance/ Internal Audit Manager

 

 

 

Head of Finance/ Internal Audit Manager

 

 

Head of Finance/ Internal Audit Manager/Head of Legal and Democratic

 

 

Head of Finance/ Internal Audit Manager

 

 

 

 

 

Head of Finance/ Internal Audit Manager/Head of Legal and Democratic Services

 

·         (70) As set out in Core Principle F above, our Risk Management Strategy aligns identified risks with our Corporate Plan objectives.

·         (71) There is a half yearly review of risks which is reported to our Joint Audit and Governance Committees.

·         (71) In line with the Public Sector Internal Audit Standards (PSIAS), the internal audit and risk manager (chief audit executive) provides an annual internal opinion and report to the Joint Audit and Governance Committee (JAGC) on the overall effectiveness of the councils’ governance framework, risk management and control. The annual opinion is used by the councils to inform the annual governance statement.

·         (72) The councils have an in-house Counter Fraud Team and Corporate Fraud is managed through our internal audit team. Our approach to procurement is to ensure high standards of conduct are in place for employees engaged in procurement activity including honesty, integrity, impartiality and objectivity.  Our Whistleblowing Policy is available to all staff through our intranet. Contractual policies for staff are included on each council’s website and include our Anti-Fraud, Corruption and Bribery Policy and Anti Money Laundering Policy:

o   Contractual Policies - South Oxfordshire District Council

o   Contractual Policies - Vale of White Horse District Council

·         73 & 74 ties in with 87 & 88

 

·         (73) The internal audit plan is a risk-based plan, which is developed through consideration of the corporate risk registers and corporate objectives. The plan focuses on areas where internal audit can provide assurance on the effectiveness of governance, risk management, and internal control processes.

 

·         (73) Quarterly updates are provided to the JAGC on the internal audit plan, other audit work (e.g. government returns), and status of internal audit recommendations.

 

·         (73) Work is underway to establish an organisational wide assurance map. The purpose of assurance mapping is to draw all sources of assurance together in one chart or table to show the areas where assurance is received. It can be used as a tool for governance arrangements by management and the audit committee to take an objective view of the councils’ risks, identify any gaps and confirm ‘Do we really know what we think we know?’. It also informs the internal audit plan

 

Sub Principle: Managing data

 

Lead Officers

Evidence base

75. Ensure effective arrangements are in place for the safe collection, storage, use and sharing of data, including processes to safeguard personal data.

 

76. Ensure effective arrangements are in place and operating effectively when sharing data with other bodies.

 

77. Review and audit regularly the quality and accuracy of data used in decision making and performance monitoring.

 

Data Protection Officer/ All Heads of Service/ Service Managers

 

 

Data Protection Officer/ All Heads of Service/ Service Managers

 

Head of Finance/Internal Audit Manager

·         We have an Information Governance Framework of policies, procedures and guidance which covers topics across four main themes of:

o   Data Protection and Privacy

o   Information Access and Rights

o   Information Security

o   Records Management.

·         Arrangements for data sharing with other bodies is detailed within contractual clauses or within Data Sharing/Processing Agreements for partnerships which are not contract based.

·         The need for accuracy of information is a key data protection principle set out in our Data Protection Policy

·         We have an Information Governance Team which liaises with service areas to provide advice and review compliance with the requirements of our Information Governance Framework. We also use the Information Commissioner’s Office self-assessment tool to monitor the councils’ compliance with expected Information Governance Accountability requirements.

·         We have a Security Policy to ensure that the requirement for and use of critical employee facing information technologies, within the councils’ managed network service infrastructure, are properly managed to minimise any security risks to the business.

 

Sub Principle: Strong public financial management

 

Lead Officers

Evidence base

78. Ensure financial management supports both long term achievement of outcomes and short-term financial and operational performance.

 

79. Ensure well developed financial management is integrated at all levels of planning and control, including management of financial risks and controls.

S151 Officer

 

 

 

 

 

S151 Officer

·         A Medium-Term Financial Plan providing a forward budget model for the next five years is agreed as part of each council’s annual budget setting process.

·         Each council has a Treasury Management Strategy describing the management of cashflow, banking, money market and capital transactions which is approved annually for the year ahead. A report on activity and performance against the strategy for the previous year is presented to the Joint Audit and Governance Committee and includes a review of economic conditions and factors impacting investments. Both the annual reports and the strategies are available on each councils’ website:

o   Treasury Management - South Oxfordshire District Council

o   Treasury Management - Vale of White Horse District Council

·         Part 3 of the Constitution covers codes, protocols and procedures and includes Financial Procedure Rules setting out how the councils’ financial affairs are to be managed. This includes the following:

o   Heads of Service, in consultation with the Head of Finance, prepare, monitor and report on financial plans for the services for which they are responsible.

o   The Head of Finance ensures there are adequate levels of internal control and check taking into account the risks involved.

The constitution can be found on each councils’ website:

o   Constitution – South Oxfordshire District Council

o   Constitution – Vale of White Horse District Council

 

 

Core Principle G. Implementing good practices in transparency, reporting, and audit to deliver effective accountability.

 

Sub Principle: Implementing good practice in transparency

Lead Officers

Evidence base

80. Write and communicate reports for the public and other stakeholders in a fair, balanced and understandable style appropriate to the intended audience ensuring that they are easy to access and interrogate.

 

81. Strike a balance between providing the right amount of information to satisfy transparency demands and enhance public scrutiny while not being too onerous to provide and for users to understand.

 

All Heads of Service/ Service Managers

 

 

 

 

 

All Heads of Service/ Service Managers

·         Both councils have a style guide published internally, which emphasises the need for plain English, encourages use of active language and discourages the use of jargon and acronyms.

·         Each council has a Communications and Engagement Strategy setting out our commitment to:

o   Have a clear and defined purpose and audience

o   Be accessible and inclusive

o   To be timely with our communications and feedback

o   The be concise and honest

The strategies are available on each council’s website:

o   Communications and Engagement Strategy – South Oxfordshire District Council

·         Communications and Engagement Strategy – Vale of White Horse District Council

·         Both councils’ websites offer easy access to up to date information.

 

Sub Principle: Implementing good practice in reporting

 

Lead Officers

Evidence base

82. Report at least annually on performance, value for money and the stewardship of its resources to stakeholders in a timely and understandable way.

 

83. Ensure members and senior management own the results.

 

84. Ensure robust arrangements for assessing the extent to which the principles contained in this framework have been applied and publish the results on this assessment including an action plan for improvement and evidence to demonstrate good governance in an annual governance statement.

 

85. Ensure that the framework is applied to jointly managed or shared service organisations as appropriate.

 

86. Ensure the performance information that accompanies the financial statements is prepared on a consistent and timely basis and the statements allow for comparison with other similar organisations.

 

S151 Officer/ Internal Audit Manager

 

 

 

Chief Executive

Head of Finance

 

 

 

 

 

 

 

 

All Heads of Service/ Service Managers

 

All Heads of Service/ Service Managers

·         Each year both councils’ statement of accounts is subject to an external audit review which includes an assessment of whether the councils have made proper arrangements to secure value for money in its use of resources. The External Auditor’s report is embedded within the approved statement of accounts which are published annually on each council’s website:

·         External Audit of Accounts - South Oxfordshire District Council

·         External Audit of Accounts - Vale of White Horse District Council

·         An Annual Governance Statement forms a part of each councils’ statement of accounts. This reports on the extent of the councils’ compliance with their principles and practices of good governance, including how we have monitored the effectiveness of the governance arrangements and sets out action for planned changes in the coming year. This statement provides an assurance to the council and its stakeholders that good governance arrangements are in place. The Annual Governance Statement is published on each councils’ website:

·         Annual Governance Statement – South Oxfordshire District Council

·         Annual Governance Statement – Vale of White Horse District Council  

 

·         Information that accompanies the financial statements is compiled in accordance with the CIPFA Code of Practice for Local Authority Accounting.

 

 

 

Sub Principle: Assurance and effective accountability

 

Lead Officers

Evidence base

87. Ensure that recommendations for corrective action made by external audit are acted upon.

 

88. Ensure an effective internal audit service with direct access to members is in place which provides assurance with regard to governance arrangements and that recommendations are acted upon.

 

89. Welcome peer challenge, reviews and inspections from regulatory bodies and implement recommendations.

 

90. Gain assurance on risks associated with delivering services through third parties and evidence this in the annual governance statement

 

 

91. Ensure that when working in partnership, arrangements for accountability are clear and that the need for wider public accountability has been recognised and met.

Head of Finance/S151 officer

All Heads of Service/ Service Managers

 

 

 

 

All Heads of Service/ Service Managers

 

 

Head of Finance/ All Heads of Service/ Service Managers

 

 

 

 

All Heads of Service/ Service Managers

·         The External Auditor’s report is embedded within the approved statement of accounts which are published annually on each council’s website:

§  External Audit of Accounts - South Oxfordshire District Council

§  External Audit of Accounts - Vale of White Horse District Council

·         Recommendations raised by External Auditors are discussed at the Joint Audit and Governance Committees and actioned accordingly.

·         The structure of the councils in house internal audit function is such that the internal audit and risk manager (chief audit executive) reports functionally to the Joint Audit and Governance Committee (JAGC), with unfettered access to the co-chairs of the committee. The internal audit and risk manager provides assurance to the JAGC with regard to governance arrangements through individual audit reports and a quarterly update report. 

·         Reports from the councils’ Joint Audit and Governance Committee are published though each council’s website:

§  Joint Audit and Governance Committee - South Oxfordshire District Council

§  Joint Audit and Governance Committee - Vale of White Horse District Council

·         Quarterly, internal audit recommendations are reviewed in detail with action owners and progress is reported to the JAGC.

 

 

89. (also see 59)

  • Member Peer Review management
  • Peer reviews

 

 

 

 

 


 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Code of Corporate Governance 2023 – 2024