The Audit, Compliance and Governance Committee of Cheltenham Borough Council met on Wednesday 15 July 2026 to review internal audit reports, approve updated policies, and discuss the council's governance and risk management frameworks. Key decisions included the approval of revised Proceeds of Crime and Anti-Money Laundering, and Counter Fraud and Anti-Corruption policies, alongside the draft Annual Governance Statement and the Local Code of Corporate Governance for 2026.

Internal Audit Opinion and Monitoring Report

The committee received the Internal Audit Opinion and Monitoring Report for 2025-26, presented by Lucy Cater, Assistant Director of South West Audit Partnership (SWAP). The report provided an overall Reasonable Assurance opinion on the council's governance, risk management, and internal control environment. While several audits, including those on Accounts Payable, Disaster Recovery, and Bank Reconciliations, achieved Substantial Assurance, significant risks were identified in the review of Recharging Mechanisms and Section 20 processes. The report detailed that progress is being made on implementing agreed actions, with some previously open actions now closed. The committee noted a typo in the report regarding the year for agreed actions and discussed the ongoing work on recharging mechanisms and voids, with assurances that further progress is being made.

Approval of the Proceeds of Crime and Anti-Money Laundering Policy

Adele Taylor, Interim Director of Finance and Operations (s.151 Officer), presented the reviewed and updated Proceeds of Crime and Anti-Money Laundering Policy for approval. The policy has been revised to reflect current legislation and the council's procedures, with operational details now contained within a supporting internal procedure document. A flowchart has been added as a quick reference guide for staff. The committee welcomed the updated policy and flowchart. In response to questions, Ms Taylor clarified the council's regulations regarding cash transactions and the council's role in identifying suspicious activity, noting that the council is not the primary body for licensing jurisdiction but focuses on protecting vulnerable people and alerting relevant authorities. The committee voted to approve and adopt the policy, delegating authority for minor future amendments to the Interim Director of Finance and Operations in consultation with relevant parties.

Approval of the Counter Fraud and Anti-Corruption Policy

Emma Cathcart, Assistant Director of the Counter Fraud and Enforcement Unit (CFEU), presented the reviewed and updated Counter Fraud and Anti-Corruption Policy. Amendments include a section on the Economic Crime and Corporate Transparency Act 2023, which introduced a failure to prevent fraud offence, and updated information on cybercrime. The policy also references the council's commitment to tackling fraud and corruption, outlining responsibilities and the approach to prevention, detection, and investigation. Members had no questions or comments, and voted to approve the policy, with similar delegation for minor amendments as with the anti-money laundering policy.

Standards Report

Claire Hughes, Director of Governance, Housing and Communities (Monitoring Officer), presented the Standards Report, summarising code of conduct complaints received between April 2025 and March 2026. The council has a statutory duty to promote high standards of conduct among its members. During the reporting period, two complaints were received regarding members of Cheltenham Borough Council. One complaint was partially upheld, resulting in a letter of apology, while the other was dismissed with no further action. There were no outstanding complaints at the time of the meeting. An independent member reminded councillors to avoid discussing potential complaints with colleagues to maintain impartiality. The report was noted by the committee.

Information Requests

Margaret Anderson, Interim Governance Risk and Assurance Officer, presented the Information Request Annual Report for 2025-26. The council received 1,029 requests, including 867 Freedom of Information (FOI) requests, 91 Environmental Information Regulations (EIR) requests, and 71 Data Subject Access Requests (DSARs). The council maintained a strong compliance rate, with 96.2% of FOIs, 92.2% of EIRs, and 100% of DSARs responded to within statutory timeframes. The report highlighted achievements such as the launch of a new case management system for FOIs and ongoing work to integrate EIR and DSAR management. The committee noted the report, with a suggestion to include historical comparisons of request numbers in future discussions. Officers confirmed that requests are handled appropriately even if misdirected, and that measures are in place to address potentially fraudulent requests, including collaboration with legal teams and external networks.

Annual Governance Statement and Local Code Report

Adele Taylor presented the draft Annual Governance Statement for 2025-26 and the Local Code of Corporate Governance for 2026. These documents are essential for good governance and demonstrate the council's commitment to the principles outlined in the CIPFA/SOLACE framework. The draft Annual Governance Statement assesses the council's performance against its Local Code of Corporate Governance and identifies five key areas for focus in the upcoming financial year: Local Government Reorganisation, Finance Capacity, Financial Savings, Competency and Conduct Standard, and Procurement. These areas will be monitored by the Corporate Governance Group and reported to the committee. The committee voted unanimously to approve the draft Annual Governance Statement and, by a show of hands, to approve the 2026 Local Code of Corporate Governance.

Corporate Risk Register Update

Margaret Anderson presented the update on the Corporate Risk Register, which currently lists 42 active risks. She highlighted one new risk: the Building Safety Levy, which becomes a requirement from October 2026. Seven risks had reduced in score, and four had increased. Notable increases included risks related to property legislation compliance, particularly concerning the Town Centre East car park and ongoing trespassing issues, and difficulties in recruitment. The report detailed the highest risks on the register, including those related to Leisure and Culture Venues, compliance with property legislation, prioritisation of capital resources, and cyber security. The committee noted the contents of the update.

Work Programme

The committee noted the work programme, with no further items added.

Exempt Information

The committee resolved to exclude the public from the meeting for the remaining agenda items in accordance with Section 100A(4) of the Local Government Act 1972, due to the likely disclosure of exempt information relating to financial or business affairs.

Exempt Minutes and Confidential Risk Register Update

The committee approved the draft exempt minutes from the meeting held on 22 April 2026. Members also discussed and noted the confidential Risk Register update.