SECTION 7 - FINANCIAL PROCEDURES

BACS

Bankers Automated Clearing Services. The main method of making payments from and receiving income into the Company’s bank accounts.

Board of Trustees

The Board of Trustees of Active Stirling Limited

Company

Active Stirling Limited, a company limited by guarantee. Charity Number SC037632 and Company Number SC298585. The Company has a wholly owned subsidiary Active Stirling Trading Limited which is not a charity. Company Number SC318814

Disclosure Scotland

The Scottish Government Agency that manages and operates a vetting and barring service as provided for in the Protection of Vulnerable Groups (Scotland) Act 2007 and Part V of the Police Act 1997

Financial Systems

Any process which has an element of financial activity either within the process itself or within its input or output

GDPR

General Data Protection Regulation (effective 25 May 2018)

Head Office

Stirling Sports Village, Forthside Way, Stirling FK8 1QZ

Navision

The finance system used currently by the Company

RBS

The Royal Bank of Scotland PLC. the Company’s bankers

RBS Bankline

Method of making secure periodic individual payments from the company’s RBS bank accounts. Also used for transfers between Company Bank accounts

1.1. Budget forecasts for the future years (generally at least 5 years), updated on a rolling basis, will be presented annually by the Director of Governance to the Active Stirling Board.

1.2. Actual performance will be measured against budget forecasts by budget holders on a monthly basis.

1.3. Summarised financial information will be presented to the Active Stirling Board of Trustees at each meeting, see Section 2 (Financial Reporting), with significant variances explained and action plans put in place to bring back to budget, where appropriate.

1.4. The Board of Trustees will approve the budgets subject to any amendments it may consider appropriate and pass such resolutions as may be required.

1.5. It will be the duty of the Board of Trustees, Senior Leadership Team and budget holders to monitor and control expenditure within the financial allocation provided in the approved budget.

1.6. Budget monitoring reports (finance packs) will be produced and reviewed monthly by budget holders, who have been assigned to specific cost centres, to analyse actual performance against budget forecast and take any measures necessary to meet the budget.

The Senior Leadership Team will review forecast reports regularly to ensure that forecasts are within the overall budget.

2.1. The annual accounts will be prepared by the Director of Governance in a timely manner in accordance with the Companies Act 2006, the Charities and Trustee Investment (Scotland) Act 2011, Regulation 8 of the Charities Accounts (Scotland) Regulations and United Kingdom Accounting Standards (United Kingdom Generally Accepted Accounting Practice). In common with many other companies of similar size and nature, the company may use the services of its external auditors to assist with the preparation of the annual financial statements.

2.2. The accounts will report the Company’s financial performance each financial year ended 31 March.

2.3. In preparing those financial statements the Director of Governance on behalf of the Chief Executive is required to:

• select suitable accounting policies and then apply them consistently;
• make judgements and estimates that are reasonable and prudent; and
• prepare the financial statements on the going concern basis unless it is inappropriate to presume that the Company will continue in business.

2.4. The accounts will be audited by the Company’s external auditor and the audited accounts submitted to the Board of Trustees for approval in a timely manner.

2.5. The approved accounts will then be submitted to Companies House within nine months of the year end, this being by 31 December in the same year.

2.6. Each year the Board of Trustees will review the effectiveness of external audit and, provided the auditors’ work is of a sufficiently high standard and reasonably priced, they are likely to be reappointed.

2.7. If the Board of Trustees decides not to reappoint the external auditors, a competitive tendering exercise will be performed to appoint new auditors.

2.8. The Active Stirling Board of Trustees will receive, at each Board meeting, summary management accounts from the Director of Governance, comprising actual results, budgeted results and projections for all cost centres within the nominal ledger.

2.9. Actual performance will be measured against budget forecast by the Senior Leadership Team, budget holders and Board of Directors, see Section 1 (Financial Budgeting), with significant variances explained and acted upon if necessary.

3.1. The Director of Governance will regularly review debtors with the Finance team member responsible for credit control to ensure outstanding balances are being pursued.

3.2. Only where all possible methods of recovery have been exhausted and consequently it is clear that an amount will not be recovered will debt be written off.

3.3. A list of any specific balances which are considered to be irrecoverable will be written off by the Director of Governance where there are good and sufficient reasons for doing so.

4.1. The Board of Trustees will be responsible for the appointment of the Company’s bankers in consultation with the Director of Governance and Chief Executive. At present the Company has found it expedient to follow the Banking contract agreed between Stirling Council and RBS.

4.2. All banking facilities will be approved by the Board of Trustees before they can be utilised by the Company.

4.3. All bank accounts will be reconciled on a monthly basis by a member of the Finance Team and agreed by the Director of Governance.

4.4. Payments will be made from the bank account by Bankers Automated Clearing Services (BACS), direct debit, standing order, RBS Bankline or cheque. The use of cheques will be limited to only those payments where BACS or direct debit is not available.

- BACS, direct debit and standing order payments will be authorised, in accordance with the set limits detailed in Section 14 Payment of Accounts, by a member of the Finance Team.

- RBS Bankline payments may be used under arrangements approved by the Board of Directors. RBS Bankline payments will be made for payments up to a value of £650k and are authorised by the Director of Governance. Payments over £50K will be co-authorised by the Chief Executive.

- Individual transactions will be authorised by the Director of Corporate Services or Chief Executive as follows:

Payments < £25k – authorised by either the Director of Governance or Chief Executive

Payments > £25k – authorised by both the Director of Governance and Chief Executive

4.5. Receipts from customers may be made by BACS, direct debit, standing order, cheque or cash.

- Receipts paid directly into the Company’s bank account (BACS, direct debit and standing orders) will be reconciled by a member of the Finance Team to the remittance advice and sales invoice, or other supporting documentation available.

- Cheques received from debtors will be reconciled by a member of the Finance Team to the sales invoice or other supporting documentation available. Cheques will be paid into the Company’s bank as they are received.

- Cash received is reconciled daily by receptionists to the till Z-total report. Cash is collected at least once a week from each of the Company’s facilities by a carrier and banked.

4.6. Receipts of grants will be paid into the Company’s bank account and reconciled by the Finance Team to the remittance advice or other supporting documentation available.

4.7. All income received will be assigned to an accounting code and processed to the Company’s accounting system.

4.8. The Company has no overdraft facility currently. Any overdraft facility will require to be authorised by the Board of Trustees on an annual basis.

4.9. Significant borrowing must be approved by the Board of Trustees. If a security is required to be granted over the assets of the Company, approval will also be required by the Board of Trustees.

4.10. To maximise interest generated, funds will be automatically transferred to the Company’s high interest deposit account once they breach a defined threshold in the Company’s current account.

Subject to the amount of available funds, the company may put in place an investment strategy, which will be reviewed annually by the Active Stirling Board and updated as required.

5.1. The Company may enter into a business partnership with another Company to obtain a number of benefits, such as:

- increased market share;

- access to new markets that would otherwise be unavailable to the Company;

- gain new skills and competencies; and

- to obtain work where the Company may lack resources or skills.

5.2. Before the business partnership is entered into, a non-disclosure agreement may be required. Where required, it will be signed by the Chief Executive and the third party partner.

5.3. A formal partnership agreement will then be created by the Company’s solicitors. It will be signed by the Chief Executive, the third-party partner and a witness locking both parties into the joint working agreement. In the event that the agreement is deemed to be of a strategic nature (e.g. of significant value), the Board of Trustees should be consulted prior to signing.

5.4. If the partnership agreement is created by a third party solicitor, the document will be checked and agreed by the Company’s solicitors before it is signed.

6.1. The Chief Executive has overall responsibility for ensuring that the Company complies with GDPR.

6.2. The Director of Governance is responsible for implementing and maintaining policies and procedures to ensure compliance with GDPR.

6.3. Any employee seeking advice on matters relating to data protection should initially refer to the Employee Handbook, the Company’s Data Protection Policies and guidance and thereafter the Director of Governance and finally the Chief Executive.

6.4. All employees that deal with sensitive personal data as defined by GDPR will be screened to ensure that they are fit and proper by Disclosure Scotland. They will also be provided with suitable training to perform their duties in an appropriate manner.

6.5. Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.

7.1. It is the policy of the Company to capitalise expenditure of capital nature in excess of £5k per individual item. Depreciation is charged to write off the cost less the estimated residual value of fixed assets by equal monthly instalments from the month they are brought into use over their estimated useful lives as follows:

- Leasehold improvements - 5 years

- Furniture and equipment - 4 years

- Motor vehicles - 4 years

- Computer equipment - 4 years

There may be certain exceptions to this policy say for a group of items costing < £1k individually but collectively > £5k. In practice most asset additions are < £5k and significant investments in equipment are by operating lease.

7.2. Like all goods and services fixed assets will be purchased in accordance with the procedures and authorisation limits documented in Sections 13 and 14 (Order of Goods & Services and Payment of Accounts).

7.3. It is the responsibility of the relevant budget holder to enter all assets which are purchased for the use of the Company into the company inventory detailing information such as:

- an identification reference for the asset;

- the asset’s location;

- the date the asset was purchased;

- the cost centre and account code of the asset;

- the cost of the purchase; and

- Accumulated depreciation and net book value of the asset.

7.4. Expensive or attractive assets should be clearly marked with an asset reference label, so that identification of that asset is possible.

7.5. The Director of Governance will be responsible for arranging the physical verification of all assets within the company inventory at least annually. Action will then be taken in relation to any surpluses or deficiencies, investigating and updating the asset listings accordingly. Any material deficiency will immediately be notified to the Chief Executive.

7.6. The inventory will be used to ensure that appropriate insurance cover is in place for all equipment used by the company and will also be used to determine whether or not items require to be replaced.

7.7. The Company’s assets will not be removed from the premises otherwise than in accordance with the ordinary course of business or used otherwise than for the Company’s purposes.

7.8. All company assets will be serviced and maintained regularly to ensure they are fit for the company’s business.

8.1. The Company requires that employees and members of the Board of Trustees apply the highest standards of conduct and integrity in the conduct of their business and to their dealings with external organisations and members of the public. Details of the standards expected are included in the Employee Handbook.

8.2. The Senior Leadership Team will be responsible for ensuring that all are aware of the contents of the Employee Handbook and that employees adhere to the rules and regulations contained therein.

8.3. All employees will be required to notify their Line Manager immediately of all financial irregularities or of any circumstances which may suggest the possibility of irregularities, including those affecting cash, stock, contracts or assets.

The Line Manager should then contact the Director of Governance or Chief Executive, who will instruct the designated person to take such steps by way of investigation and report as considered necessary.

A report must be made by the designated person or Chief Executive to the Police in all circumstances of financial irregularity where there is evidence that a material crime or an offence may have been committed.

8.4. The Director of Governance or Chief Executive will inform the Board of Trustees in all cases where there is evidence that there may be a crime or offence involved.

9.1. The Company has five main income streams, being:

- Management Fee from Stirling Council

- Charitable Activity Operating Income e.g.

Membership fees

‘Pay-as-you-use’ fees

Sports development classes including Swim Programme

- Commercial Activity Income e.g.

• Catering income

• Income from the sale of goods purchased specifically for resale

• Conference room hire

- Grant Income

- Bank/Investment Interest Received

9.2. The Chief Executive, in consultation with the Senior Leadership Team, will review the rates to be charged for its goods and services at least annually. All rates will be approved by the Board of Trustees.

To preserve the real value of income, increases recommended to the Board of Trustees will take into account the current rate of CPI and reflect the impact of any change in the rate of VAT.

9.3. The Director of Governance will define arrangements to ensure the appropriate recording of all income due, and the proper collection, control and banking of all income due to the Company.

9.4. All receipt forms used to record financial transactions, including refunds, will be in a form approved by the Director of Governance. Receipt forms will be used for all money received on behalf of the Company.

9.5. All money received will be kept secure as detailed in Section 19 and comply with insurance requirements as detailed in Section 10 until banking takes place.

9.6. Payments received will be processed as detailed in Section 4 (banking facilities).

9.7. Payment is required by a customer on receipt of the invoice. The exception to this will be if other payment terms are agreed or an agreed direct debit facility has been set up, e.g. whereby the customer will pay their membership fee in advance on a monthly basis.

9.8. If the payment is outstanding after 14 days a reminder for payment is sent to the customer. A second reminder is sent 21 days after the due date. If payment is still outstanding 28 days after the due date, with unsatisfactory reasons for the debt being unpaid, a debt collection agency may be used to collect the money from the customer. For further information see Section 3 (Bad debts).

9.9. Contracts

9.9.1. Appropriate controls will be in place to ensure large scale contracts are correctly entered into and best value is being achieved.

9.9.2. Contracts of a value < £250k may be approved by the Chief Executive. Contracts of a value of

> £250k must be approved by the Active Stirling Board of Trustees.

9.9.3. A standard formal contract will be signed by the supplier and the Chief Executive before work can commence, binding both parties to the Terms of Business. The contract will detail at the very least the following:

- the commencement date and period of the service;

- the purpose of the service;

- the cost of the service provided; and

- invoicing arrangements and payment terms.

10.1. Risk Management

10.1.1. All strategic and operational risks identified by the Senior Leadership Team and the Board of Trustees will be entered into the Risk Register maintained by the Director of Governance.

10.1.2. The Register will be reviewed by the Board of Trustees regularly (at least annually) and an action plan thereby established by the Senior Leadership Team to mitigate risks.

10.1.3. The Senior Leadership Team will require to draw the attention to the Board of Trustees at any time any additional risks of which they should be aware.

10.1.4. All operational risks identified will be managed by the Senior Leadership Team in a manner appropriate to the significance of the risk.

10.1.5. Individual employees will manage risk effectively in their roles within the Company Line Managers will be responsible for ensuring individual employees are aware of their responsibilities for risk management.

10.2. Insurance

10.2.1. A review of the services provided by the Company’s Insurance Broker should be carried out by the Board of Trustees regularly (at least every 5 years) on a ‘value for money’ basis, whilst ensuring satisfactory insurance cover is in place.

10.2.2. The Director of Governance will renew the insurance policy annually and by doing so will ensure that satisfactory cover is in place for the Company. When the Company’s long term contract with Stirling Council is agreed longer term arrangements will be put in place.

10.2.3. The Director of Governance will inform the insurance provider in a timely manner of all new or increased risks, properties, vehicles, equipment and other assets which require to be insured and of any alterations affecting existing insurances. This will include items of equipment on operating or finance lease.

10.2.4. The Director of Governance will arrange for all appropriate employees of the Company to be included in suitable fidelity guarantee insurance cover and for Trustee Indemnity insurance to be in place for Board trustees.

10.2.5. The Director of Governance will immediately notify the Chief Executive/ Board of Trustees of any loss, liability or damage or any other event likely to lead to a claim and shall inform the Police where there is an obligation to do so, or where, after consulting the appropriate employees of the Company, they have been advised to do so.

10.2.6. Any insurance claim will be notified by the Director of Governance or designated person to the Company’s insurance broker in order to identity the appropriate actions that the Company should take.

10.2.7. A regular note (at least quarterly) of the progress of claims made against the company will be obtained from the Insurance Brokers.

11.1. Internal controls are implemented to ensure that the business of the Company is conducted in an orderly and efficient manner; its policies and procedures adhered to, its assets protected and its records complete and accurate.

11.2. Internal controls will vary throughout the Company depending upon activity, size and volume of transactions. However, four types of internal control will apply as a minimum requirement where possible:

- Segregation of duties;

- Physical controls (See Section 19 – Security);

- Internal checks; and

- Management review.

11.3. Segregation of duties will be introduced where possible so that individuals cannot influence financial transactions from start to finish. Due to the small number of staff, this may not be possible in all situations and therefore, authorisation should be sought from a senior member of the Company at all times.

11.4. To reduce the chance of errors, all financial transactions must be subject to internal checks at every stage. Controls will be evidenced by signing the documents involved, where appropriate, by both the person undertaking the work and the person checking the work.

11.5. When the internal control is performed by way of a computerised system, the access rights must be password controlled and authorisation must be made in the manner specified for the computer application, as detailed in the relevant User Manual. See Section 19 (Security).

11.6. The Director of Governance will also regularly review financial transactions, through the use of regular reports, see Section 2 (Financial Reporting). Figures will be compared to independent statistics or performance information for reasonableness. In the absence of internal audit the Director of Governance will carry out spot checks on a sample of payments selected from the weekly BACS run.

11.7. The Director of Governance is responsible for advising on effective systems of internal control. In order to provide assurances as to the effectiveness of internal controls within financial systems, a review of controls will be performed by the Company’s external auditors who will report twice annually on any weaknesses or errors they have discovered during the course of their visits. See Section 11 (External Audit).

11.8. All financial transactions must be authorised by the appropriate person before being effected.

11.9. By authorising financial transactions, employees are accepting responsibility for them, confirming that they are satisfied the transactions are correct, appropriate for the Company, genuine and supported by appropriate documentation.

11.10. Employees will not authorise transactions in which they have a personal interest.

11.11. The Senior Leadership Team is responsible for determining the numbers and distribution of authorised signatories and authorised users to meet their needs within the management structures of their area.

12.1. Purchase orders for all goods and services will be made only from suppliers listed in the accounting system (Central Purchasing). Wherever possible existing suppliers (vendors) should be used. If a new supplier is required to be used, an account will be added to the accounting system by the Finance or Admin Team following an approval process.

12.2. The same purchase order process will be followed for all goods or services supplied to the Company, except as follows:

a) Work, goods or services which are covered by a prior written agreement which prescribes that payments will be made at certain intervals or under certain recurring conditions;

b) Periodic payments such as insurance;

c) Purchase in cash for which reimbursement is made through a petty cash account;

d) Some purchases through company credit cards. See Section 17.2 (Petty Cash & Company Credit Cards).

12.3. Purchase orders will be numbered sequentially by Central Purchasing. Each purchase order will be sent to the supplier once the purchase is authorised and the administration department at Head Office will maintain a master list of purchase orders for matching purposes.

12.4. Purchase orders for goods or services will be authorised by an employee whose authorisation limits are defined in the signatory list, before the order can be placed with a supplier:

12.5. The relevant person authorising any order will ensure that the expenditure to be incurred is legal, that funds have been provided in the budget to cover such expenditure, the order indicates clearly the nature and quantity to be supplied, the cost centre and account code budget that the expenditure should be made from and any contract or agreed price relating to that order.

12.6. All purchase orders will be documented and given to the supplier in advance of any work, goods or services being provided to the Company. However, in an emergency arising from circumstances outside the control of the Company, a verbal order may be given in advance, but must then be followed by a purchase order as soon as possible thereafter.

12.7. Tendering and best value

12.7.1. In the absence of a formal tendering process due to uncertainty around the Company’s long term contract position, a minimum of 3 quotes will be required for the purchase of goods and services > than £20k.

12.7.2. In the absence of a formal tendering process, appropriate controls are in place to demonstrate that the purchase of goods and services > £60k deliver best value to the Company. In practice transactions of this amount are very rare, are identified in advance and discussed by SLT and the Board of Trustees.

12.7.3. In the event that the nature of the goods or services are sufficiently specialist to restrict the number of potential suppliers to one, or there is compelling urgency to proceed with the transaction, a specification will be produced and the Company will negotiate with the supplier on the basis of the specification. A Single Supplier Justification form will be completed and passed to Finance prior to any procurement.

12.7.4. In determining whether the above thresholds have been reached, the Company will assess whether the values of separate orders need to be aggregated. Aggregation will not apply where the services or works provided are subject to separate, distinctive and contracted work which have clear outputs and deliverables

12.7.5. In future, under the Company’s long-term contract with Stirling Council, a formal tender process will be performed in line with best practice, including some or all of the following steps:

• A specification of requirements will be produced;

• Evaluation and award criteria will be set prior to the commencement of the tendering exercise;

• Sufficient suppliers will be asked to tender either through direct contact or appropriate advertising to ensure robust competition;

• If considered necessary, the Company may ask suppliers to pre-qualify to receive a tender;

• Tenders will be evaluated by a panel made up of key operational staff and finance representatives. Any conflicts of interest must be declared by proposed panel members and they will be excluded from the panel;

• The Company may request a short list of suppliers to present their proposals in front of the evaluation panel;

• The contract award will be subject to finalisation of the bid and due diligence on the final terms of the contract.

13.1. Purchase invoices received will be certified by an authorised employee, whose authorisation limits are defined in the signatory list, before the payment is made. Purchase invoices require to quote an Active Stirling Purchase Order number.

13.2. Invoices are certified by the appropriate persons, ensuring the following:

- the charge is a proper liability of the Company;

- the work, goods or services to which the invoice relates has been correctly ordered, received, carried out, examined and approved; and is in accordance with the purchase order;

- the prices, extensions, calculations, trade discounts, other allowances, credits, and VAT and other taxes are correct;

- the invoice has not been previously passed for payment;

- the invoice is in the name of the Company;

- invoices have been submitted by the supplier and not an employee of the Company;

- the invoice has been assigned an appropriate accounting cost centre and account code corresponding with the types of goods or service described on the invoice.

13.3. In the absence of a formal tendering process, individual invoices > £25k are countersigned by the Director of Governance and the Chief Executive before being processed through the Finance system in addition to going through the purchase order system.

13.4. If the invoice or receipt relates to goods purchased by employee credit cards, the credit card holder will match to goods received. The invoice or receipt total will then be agreed to the credit card statement then the line manager authorises the payment. Once matched, no further action is required as automatic electronic payment will be made by the Company’s bank. If the company is not already set up for VAT in the Company system then an adjustment for VAT must be made by the Finance Team.

13.5. If an invoice is due for payment, the invoice will be processed for payment in a timely manner in accordance with the terms and conditions agreed with the supplier.

13.6. Payments will be made as detailed in Section 4 (Banking Arrangements).

13.7. Where the sum invoiced by a supplier is incorrect the supplier will be contacted and asked to issue a new invoice or a credit note. This will be processed through the payments system.

14.1. Payroll

14.1.1. The Company will comply with all HMRC regulations in force relating to payroll processing, including obtaining prior approval for salary sacrifice schemes. At present the company’s payroll is operated by a 3rd party payroll service provider.

14.1.2. HR will maintain records and information in regard to employee’s salaries and other emoluments as the payroll service provider may require, and will be responsible for the accuracy and authenticity of such information.

14.1.3. Appointments and terminations of employment will be approved by the Senior Leadership Team or Chief Executive.

An exception will be the appointment or termination of employment for the position of Chief Executive, as this will be approved by the Board of Trustees.

14.1.4. A signed statement of particulars will be obtained for all employees of the Company, binding the employee and employer to its terms and conditions.

14.1.5. Any changes in employee remuneration will be authorised by the Line Manager and agreed with the employee. Documentation of the change, other than annual inflationary increases in salary, will be passed to HR who will inform the payroll service provider of the change required on the payroll system.

14.1.6. HR will inform the payroll service provider of all matters affecting the employee emoluments, and in particular:

- appointments, including temporary and casual appointments, resignations, dismissals, suspensions, secondments and transfers;

- long term unpaid or reduced pay absences from duty for sickness or other reason, apart from approved annual / flexi leave;

- changes in remuneration, approved overtime and expenses; and

- any information necessary to maintain records of service for superannuation, income tax, national insurance and any other payroll deductions necessary.

14.1.7. Any overtime must be authorised in advance by completing the standard form and will be passed to the payroll provider for payment

14.1.8. Time Off in Lieu (TOIL) can be accrued up to a limit of 2 days. Any use of TOIL must be pre-approved by Line Managers

14.1.9. The payment of all salaries and other emoluments to employees will be made by the payroll service provider under arrangements approved by the Chief Executive.

14.2. Travel & Subsistence

14.2.1. All expense claims will be completed on standard forms by employees and authorised by the Line Manager or a member of the Management Team.

14.2.2. Receipts must be provided to support expense claims. The receipts must be originals, unaltered, reasonable and be a valid tax receipt where VAT applies.

14.2.3. All authorised claims for expenses will be paid through payroll services. In exceptional circumstances expense claims may be paid out with the payroll services system through petty cash if approved by the Director of Governance or Chief Executive.

15.1. As part of the Service Agreement with Stirling Council, the Company is required to present information on the performance of their services to the Board of Trustees at their regular meetings.

15.2. The Chief Executive will be responsible for providing performance information, as required by the Board and Stirling Council.

15.3. In order to prepare the performance indicators, each member of the Senior Leadership Team will:

- establish systems and procedures to ensure that the required information is gathered;

- ensure that all working papers and relevant documents are retained;

- gather information which is as far as possible, accurate and complete; and

- report the performance to the Board of Trustees at each meeting.

16.1. Petty Cash

16.1.1. A petty cash float will be maintained in safes at Company locations, only accessible by the designated petty cash holder. All petty cash holders and amounts will be approved and a record held by the Finance Team.

16.1.2. Employees will be personally responsible for petty cash which they hold and will provide backup documentation to support any amounts taken from the petty cash float to the petty cash holder.

16.1.3. Petty cash will be reconciled on a regular basis by the holder, or daily if there are a large amount of petty cash transactions within the period. The reconciliation will be checked and agreed by a second member of staff at the relevant site.

16.2. Company credit cards

16.2.1. Company credit cards will only be issued to employees as authorised by the Chief Executive or Director of Governance.

16.2.2. Use of company credit cards is restricted to emergency transactions or where the supplier will not normally take payment by other means. Employees are aware that transactions that could go through Central Purchasing should not go through credit cards. Finance staff processing credit card transactions are instructed to review statements thoroughly and draw the attention of the Director of Governance to transactions that are out with that criteria.

16.2.3. Company credit cards should never be used to pay for items of a personal nature and employers who mistakenly use the wrong card are required to immediately reimburse the Company.

16.2.4. Company credit cards will only be used for purchases by those employees who have completed application forms with the Company’s bankers, in line with the existing mandate.

16.2.5. The current list of authorised personnel for credit card use, and their purchase limits is held by the Finance Team.

16.2.6. Monthly credit card statements will be reconciled to supporting purchase receipts by the credit card holder. The reconciliation will then be checked by their line manager/ the Finance Team.

16.2.7. Payment of monthly credit card statements will be made from the Company’s bank account by Direct Debit.

17.1. Documents will be retained in accordance with statutory guidelines and GDPR.

17.2. HM Revenue and Customs requires all Company records to be kept for a minimum period of six years (unless a dispensation has been awarded). These records include:

orders and delivery notes;

purchase orders for creditors and copy supply invoices to debtors;

any debit or credit notes issued or received;

cash records and till rolls;

bank statements and paying-in slips;

creditors, debtors and cash income ledger control accounts;

VAT account;

payroll records;

corporation tax documentation;

annual accounts;

import and export documents; and

relevant business correspondence.

17.3. HM Revenue and Customs allows organisations to retain records electronically, provided that copies can be produced over the full six year period (i.e. the storage mediums are robust) and there are adequate facilities for Revenue and Customs employees to view these when required. Any decision by the Company to rely solely on electronic records will be pre-agreed with HMRC to minimise any risk.

17.4. A number of documents must be retained for external auditors to verify the final accounts of the Company. Other documents required by external audit which do not have to be retained for a longer period because of statutory or other reasons need only be retained until the audit has been completed.

17.5. Annual Accounts and any associated working files will be retained permanently.

17.6. All current and historical financial documents must be retained securely.

17.7. Financial files will be labelled clearly detailing:

- the origin and contents;

- the period they relate to;

- the person or section responsible for them; and

- their retention information (generally a “Not to be Disposed of Before” date).

17.8. Time-expired financial records which include any personal information must be treated as confidential waste and will be shredded or incinerated under supervision or forwarded to a specialist contractor (for confidential destruction). Financial records not including personal information can be disposed of through ordinary waste paper collection agents but must not be placed in open skips, left out in bin sacks or be exposed to casual retrieval.

18.1. The Director of Governance will ensure that an inventory of all assets held by the Company, is maintained as detailed in Section 7 (Fixed Assets).

18.2. The Company’s assets or stock will not be removed from the premises otherwise than in accordance with the ordinary course of business or used otherwise than for the Company’s purposes.

18.3. Entry to Head Office will be restricted by locked doors at all times. Employees will gain access to the building through electronic passes. All other visitors to Head Office will gain admission by use of the Door Entry system at the Visitors entrance. There may be rare exceptions to this procedure e.g. where volunteers are working closely with coaching staff and, by arrangement, will be admitted by the staff entrance.

18.4. Entry by non-staff members to the Company’s other sites will be restricted by staffed reception areas during opening hours and locked doors when closed. In addition, members will be provided with electronic keys for restricted access to relevant areas of the building.

18.5. Employees who work at the Company’s other sites will be issued with electronic keys with unrestricted access to all areas of the building.

18.6. Members will not be allowed access after site closing time.

18.7. Electronic passes or keys giving access to the building must not be distributed to third parties, unless there is a sound reason. Casual or infrequent visitors and members of the public should never be given electronic passes or keys. Frequent visitors who may be working closely with staff may, subject to appropriate controls and supervision, be allowed an electronic key to allow access to Head office.

18.8. Line managers will be responsible for the security, custody and control of all documents within their area, in line with GDPR policy and guidance. The retention period for all financially related books, forms and records will be determined by the Director of Governance in consultation with legal advisers and documented in the GDPR Policy.

18.9. Company cheque books, Bankline passes and keys will be kept in a locked safe or drawer, accessible only by duly authorised persons.

18.10. Cash receipts and till floats will be kept in a locked safe when the office is closed and banked regularly, dependant on insurance levels and amounts involved.

18.11. The Director of Governance, through the Head of Systems and IT, will ensure that there are efficient arrangements for the security of Information Systems (IS), Information Technology (IT) and associated data, software and services. They will also ensure that all users of the Company’s IS, IT and associated data, software and services are clear about what is acceptable and unacceptable usage.

18.12. Key IS and IT systems will be protected by unique employee passwords and restricted access rights. It is crucial that passwords are not disclosed to unauthorised personnel under any circumstances. These passwords will be changed regularly and at least quarterly.

18.13. The Company requires to have appropriate cyber insurance cover in place reviewed regularly (at least annually) in the light of market conditions and sector experience. If appropriate, independent advice may be taken on the required level of cover.

18.14. A backup of the Company’s accounting system will be taken on a daily basis by the Company’s IT provider ( currently 2e-Volve), in accordance with their system backup and recovery policy and stored in a location out with the Company’s head office.

19.1. The care, custody and level of stock will be the responsibility of local site managers, who will ensure that:

- adequate arrangements have been made for the proper and secure storage of all stock and these arrangements have taken account of good risk management practices;

- stock levels are maintained at the minimum level sufficient to meet the operational requirements of the Company;

- all stock received, issued or otherwise disposed of are accounted for in the manner prescribed by the Director of Governance;

- stocks are checked regularly by employees involved in the day to day administration of those stocks and inventories and at least annually by persons independent of those stocks and inventories; and

- any surpluses or deficiencies found on stocktaking or at any other time are investigated and reported to the Finance manager.

19.2. The Company’s stock will not be removed from the premises otherwise than in accordance with the ordinary course of business or used otherwise than for the Company’s purposes.

19.3. Stock and inventories will be reviewed regularly for damage or obsolescence and as a result may be written-off or disposed by the Director of Governance, to a value of £1k for individual stock items. Any write-off above this level will be authorised by the Chief Executive.

19.4. Local site managers will provide the Financial Controller with appropriate records of stock held as at each month end, or any other date as determined by the Director of Governance, by the date required to meet the Management Accounts deadlines.

20.1. The Company can be inspected by Her Majesty’s Revenue and Customs (HMRC) at any time. These inspections may result in the imposition of penalties for non-compliance with tax law. It is therefore essential that the Director of Governance and Chief Executive ensure that employees are aware of any relevant taxation matters and that where necessary, guidance is obtained from the Company’s tax and legal advisers.

20.2. A review of the tax advisory service provider will be carried out by the Board of Trustees regularly on a ‘value for money’ basis. In practice the tax advisory service is provided by the external auditors

20.3. The Chief Executive and Director of Governance, though discussions with the Company’s tax advisor, will the responsible for the following:

- ensuring that transactions comply with relevant statutory requirements and authorities;

- minimising the Company’s tax liability; and

- ensuring that all relevant returns are submitted to HMRC by the due date and statutory obligations discharged.

20.4. In carrying out such responsibilities the Chief Executive and Director of Governance will ensure that:

- duties in relation to taxation and tax management are defined and allocated;

- financial control systems operate effectively, produce the necessary information and minimise the risk of error;

- appropriate guidance is provided to employees involved in processing tax related transactions;

- assistance is provided for any investigations undertaken by any Government Agency, and that justification for assessments made resulting from investigations is properly reviewed;

- arrangements are put in place to monitor the execution of these responsibilities; and

- any significant changes to the Company’s tax affairs are reported to the Board of Trustees.

20.5. Where transactions of a new or unusual nature are being considered, the Director of Governance will consult with the Company’s tax advisor on the tax implications before committing the Company.

20.6. Payment of tax to HMRC will be made as per the procedures for payment noted in Section 4 (Banking Facilities).

21. Vat

21.1. VAT on Supplies by the Company

21.1.1. VAT may be due on charges made or income received which has to be paid over to HM Revenue and Customs (HMRC). In cases of doubt advice will be obtained from the Company’s tax advisor.

21.1.2. The Company’s financial system enables VAT to be identified when debtor accounts are issued and income banked. As the penalties for not identifying VAT on income can be severe, it is essential that all relevant income is correctly identified.

21.1.3. Invoices rendered by the Company for goods and services provided will conform to HMRC requirements and will be agreed with the Company’s tax advisor.

21.1.4. The VAT liability for goods and services supplied by the Company must be identified correctly. The Director of Governance will ensure that the VAT classifications for all new charges raised are confirmed by the Chief Executive and the Company’s tax adviser, who will also provide detailed guidance on the VAT classifications applicable for all service charges and supplies.

21.2. VAT on Supplies to the Company

21.2.1. To reclaim VAT, the Company must obtain a valid tax invoice from a registered trader and be able to produce it on request. If input tax is claimed and not supported by a valid invoice the Company may be liable for penalties for misdeclaration of tax. In practice, HMRC have reviewed and relaxed the criteria for smaller value invoices.

21.2.2. Invoices for services or supplies to the Company must meet HMRC requirements.

SCHEME OF DELEGATION – DELEGATED AUTHORITY