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Annual Report and Accounts 2024 - 2025 Accountability report

This information is also available in the Annual Report and Accounts 2024/25 document (PDF, 9.5 MB). 

Corporate governance report

Directors’ report

Agency Board

At the end of March 2025, the Agency Board (the Board) comprised of 10 non-executive members including the Chair, L Tennant, and one executive member, the Chief Executive, N Paterson. Appointments are made by Scottish Ministers and are regulated by the Commissioner for Public Appointments in Scotland. Appointments are normally for a three or four-year term with the possibility of a further term, subject to evidence of effective performance and satisfying the skills, knowledge and personal qualities required of the Board at the time of re-appointment. 

Register of interests

Board members are asked to complete a registration of interest which is published on our website alongside their biographies.

Data breaches

During 2024/25, we did not report any data breaches to the Information Commissioner’s Office (ICO). 

Auditors

Under Section 46 of the Environment Act 1995, our accounts must be audited by an auditor appointed by the Secretary of State. Under the Public Finance and Accountability (Scotland) Act 2000, our independent auditors are appointed for the Auditor General by Audit Scotland. Audit Scotland is our independent external auditor for the five-year period starting in financial year 2022/23. The fee paid to Audit Scotland in respect of the independent statutory audit for the financial year 2024/25 is £78,500. All relevant audit information has been made available to our auditors and the Accountable Officer has taken steps to ensure that the auditors are aware of any relevant audit information.

The result of the external audit and improvement actions are reported to the Audit, Risk and Assurance Committee (ARAC) and Board. Audit Scotland attend ARAC meetings throughout the year and submit regular reports to the ARAC, including a progress report on improvement actions and ensure action is taken on any matters arising. Further information about the role of the ARAC is contained in the Board operation section below.

Statement of Accountable Officer’s responsibilities

Under Section 45(2) of the Environment Act 1995, we are required to prepare annual accounts for each financial year in the form of and on the basis determined by Scottish Ministers.

The accounts are prepared on an accruals basis and must give a true and fair view of our financial affairs and of its income and expenditure, statement of financial position, and cash flows for the financial year.

In preparing the accounts, I am required to comply with the requirements of the Government Financial Reporting Manual and in particular to: 

  • Observe the Accounts Direction issued by Scottish Ministers, including the relevant accounting and disclosure requirements, and apply suitable accounting policies on a consistent basis.
  • Make judgements and estimates on a reasonable basis.
  • State whether applicable accounting standards as set out in the Government Financial Reporting Manual have been followed and disclose and explain any material departures in the accounts.
  • Prepare the accounts on a going concern basis.
  • Confirm that the Annual Report and Accounts as a whole are fair, balanced and understandable.
  • Take personal responsibility for the Annual Report and Accounts and the judgements required for determining that it is fair, balanced and understandable.

The Principal Accountable Officer of the Scottish Government has appointed me, the Chief Executive, as Accountable Officer of SEPA. My responsibilities as Accountable Officer, including responsibility for the propriety and regularity of the public finances for which I am answerable, for keeping proper records and for safeguarding SEPA’s assets, are set out in the Framework Document approved by the Scottish Government and in Managing Public Money published by the HM Treasury. As the Accountable Officer, I have taken all the steps that I ought to have taken to make myself aware of any relevant audit information and to establish that SEPA’s auditors are aware of that information. So far as I am aware, there is no relevant audit information of which the auditors are unaware.

Governance statement

Governance framework

We are a non-departmental public body. The broad framework in which we operate is set out in the Framework document, which also defines key roles and responsibilities which underpin the relationship between SEPA and the Scottish Government. While this document does not confer any legal powers or responsibilities, it forms a key part of our accountability and governance framework. 

Non-departmental public bodies are directed by Scottish Ministers to comply with the Scottish Public Finance Manual. Our Corporate Office is Angus Smith Building, Unit 6, 4 Parklands Avenue, Holytown, Motherwell, ML1 4WQ.

Our governance framework is a set of processes and controls which are designed to set the organisation up to deliver our statutory purpose, plans and objectives, and to identify and manage risks and issues effectively. Our framework, which is described on the following pages, has been in place for the year ended 31 March 2025 and up to the date of approval of the Annual Report and Accounts. We can provide assurance that the processes have been running effectively during that period. We are constantly improving our processes and learning from best practice, so at any time we can provide assurance of its effectiveness.

Board operation

The main functions, powers and duties of the Board are set out in the Environment Act 1995 and the Framework Document. Regulation and conduct of Board meetings are set out in the standing orders. Board members attend a range of meetings including formal Board and committee meetings, ad-hoc meetings, working groups and meetings with SEPA employees to discuss key strategic issues. They also attend seminars and events run by us or other organisations. 

Sustainable development considerations are embedded in the Board’s governance arrangements and principles are set out in our three-year Corporate Plan. The Board nominated a sustainability champion to support officers in consideration of strategic sustainability issues. This will be superseded by the revised terms of reference for the People and Resources Committee approved by the Board on 30 September 2025, which include reference to sustainability. 

We publish the public papers and public minutes of Board meetings on our website. 

The Board has appointed an Audit, Risk and Assurance Committee (ARAC) to monitor and review risk, internal control, audit activity and corporate governance. This committee was formerly known as the Audit and Risk Committee until 26 November 2024 when the Board approved a revised remit and change of name. N Gordon currently chairs this Committee. The Board appoints members to the Committee, and it is governed by its Terms of Reference and Remit.

The ARAC receives reports from internal and external auditors and our employees. The internal and external auditors may attend all Committee meetings, and they can contact the Chair of the Committee at any time to express specific concerns identified during audit work. Four meetings of the ARAC were held in 2024/25 and four further meetings were held during the year: an extra Finance meeting, two special meetings on the Annual Report and Accounts 2023/24, and the annual Committee workshop.

The People and Resources Committee (PRC), formerly the People and Remuneration Committee (to 26 November 2024), provides assurance to the Board that SEPA meets its obligations as an employer in relation to a range of people and remuneration related matters. The revised remit of the Committee, approved by the Board on 26 November 2024, and a further revision on 25 February 2025, includes the effective scrutiny of transformational business cases, sustainability and resources. The Board appoints members to the Committee, and it is governed by its Terms of Reference and Remit. The Board Chair, L Tennant, was Chair of the PRC until 25 February 2025. D Hunter was appointed as Chair on 26 March 2025. Three meetings of the PRC were held in 2024/25. 

Members’ attendance at Board and Committee meetings is set out in table 13. Note: Board members who are not official members of Committees, for example the Chief Executive, can attend as observers or as terms of reference require for specific items (these are highlighted in the footnotes of table 13). 

Table 13: Attendance at ordinary meetings by Board members 2024/25

Board member

Role and term

Board

Audit, Risk & Assurance Committee
(ARAC)

ARAC extra meetings

People & Resources Committee (PRC)

Total number of meetings in year

 

6

4

4

3

L Tennant

Chair. Chair of PRC to 25 February 2025.

4 of 6

4[3]

4

2 of 3

N Paterson

Chief Executive.

6 of 6

3[3]

4

2[4]

H Kohli

Deputy Chair. Member of ARAC.

5 of 6

4 of 4

4 of 4

1[4]

N Gordon

Board member and Chair of ARAC.

5 of 6

4 of 4

4 of 4

N/A

D Hunter

Board member. Member of PRC; Chair of PRC from 26 March 2025.

6 of 6

N/A

N/A

3 of 3

C Hume

Board member. Member of PRC.

5 of 6

N/A

N/A

3 of 3

C Evans

Board member. Member of ARAC.

6 of 6

4 of 4

4 of 4

N/A

L MacDonald

Board member. Member of ARAC.

5 of 6

4 of 4

4 of 4

N/A

L McMillan

Board member. Member of PRC.

6 of 6

N/A

N/A

3 of 3

S Paterson

Board member. Member of PRC from 25 February 2025.

5 of 6

N/A

N/A

0 of 0

K Rosser

Board member. Member of PRC.

4 of 6

N/A

N/A

3 of 3


[3] Not a member of the ARAC but attended meetings as noted.

[4] Attended PRC as an observer


Corporate Leadership Team

The Corporate Leadership Team is responsible for SEPA’s services and their delivery. Its purpose is to implement the high-level strategy of the organisation, as set by the Board, and lead the agency to ensure that our statutory purposes, operational and organisational requirements are met. The Corporate Leadership Team reports directly to the Chief Executive who is held accountable by the Board.

During 2024/25, the Corporate Leadership Team was comprised of the Chief Executive and five Chief Officer roles:

  • Chief Executive and Accountable Officer – N Paterson.
  • Chief Officer Finance, Modernisation and Digital – A Milloy.
  • Chief Officer People, Workspaces and Development – K Paterson.
  • Chief Officer Governance, Performance and Engagement – K L Campbell.
  • Chief Operating Officer (Data, Evidence and Innovation) – A Flucker.
  • Chief Operating Officer (Regulation, Business and Environment) – L Bunten (to 31 July 2025).
  • Chief Operating Officer (Regulation, Business and Environment) (acting) – D Harley (from March 2025).

A strategic assessment of environmental impacts is included in Board and Corporate Leadership Team papers requiring a decision and a Climate Change Impact Assessment tool is being introduced in 2025/26 for use across strategic leadership decisions and new regulated procurements.

Anti-bribery and corruption

We have zero tolerance towards fraud, bribery, and corruption. We have an employee code of conduct, whistle-blowing policy, along with appropriate and effective governance and oversight of gifts and hospitality, both given and received. We actively encourage colleagues to be aware of appropriate behaviours with both customers and suppliers and we maintain a gifts and hospitality register. 

During the 2024/25 financial year, there were six cases of suspected fraud considered by our Fraud Response Group with investigations undertaken as appropriate. All six were subsequently closed with appropriate action taken, recommendations made and/or lessons learnt captured. There were no material financial losses as a result.

The Chief Officer Governance, Performance and Engagement chairs our Risk Management Group and our Fraud Response Group. Risk and fraud issues are escalated through these groups to the Corporate Leadership Team. The Audit, Risk and Assurance Committee and the Chair of the Board are made aware of significant issues by the Chief Executive or the Clerk to the Board. The Clerk to the Board, as Head of Corporate Legal and Leadership Support, is also the Corporate Solicitor, Standards Officer, and a member of the Fraud Response Group.

Planning and performance reporting

Our Corporate Plan 2024-2027, published this year, sets out our strategy and is supported by our Annual Operating Plan. We worked during 2024/25 to strengthen our Performance Measurement Framework and reporting mechanisms by agreeing a suite of Key Performance Indicators (KPIs) and linking measures to both plans.  

We produce corporate quarterly performance reports and our Chief Executive’s Report to the Agency Board which highlights areas of performance and delivery across periods during 2024/25. Both of these reports are published on our website. Our end-of-year performance and analysis for 2024/25 is summarised in the performance report section of this report.

Looking ahead to 2025/26, we have developed Objectives and Key Results (OKRs), aligned to our Corporate Plan priorities and the key deliverables in our Annual Operating Plan, and further strengthened our KPIs to ensure our new Performance Framework is robust.

Our strengthened Performance Measurement Framework will more effectively enable us to monitor and report on delivery against our strategic priorities and our impact on the environment in Scotland. We will use our strengthened framework to continue to refresh and improve our reporting as we move into 2025/26.  

Budgeting and financial management

We have a comprehensive budgeting and financial reporting system, in line with the Scottish Public Finance Manual, which compares actual results to the budgets approved by our Board. We produce management accounting reports to each portfolio and the Corporate Leadership Team monthly and to the Board quarterly. Significant variances from budget are thoroughly investigated.

Budget holders have online access to up to date spend, commitments and forecasts at cost centre level using Enterprise Resource Planning accounting software. Cash flow and other financial forecasts are prepared monthly to ensure that we have sufficient cash to meet our operational needs. On a monthly basis we submit a budget monitoring return, including forecasts and a cash report, to the Scottish Government.

Internal audit and internal control

As Accountable Officer, I have responsibility for maintaining sound systems of internal control. These support the achievement of our policies, duties and objectives. They also safeguard the public funds and assets for which I am personally responsible. 

The Public Sector Internal Audit Standards state that:

“The Chief Audit Executive must deliver an annual internal audit opinion and a report that can be used by the organisation to inform its Governance Statement. The annual internal audit opinion must conclude on the overall adequacy and effectiveness of the organisation’s framework of governance, risk management, and control.”

In the Internal Audit Annual Report 2024/25, produced by our internal auditors, BDO, the Chief Audit Executive concluded that:

“In our view, based on the reviews undertaken during the period, and in the context of materiality, the risk management activities and controls in the areas which we examined, were found to be suitably designed to achieve the specific risk management, control and governance arrangements. 

"Based on our verification reviews and sample testing, the risk management, control and governance arrangements were operating with sufficient effectiveness to provide reasonable, but not absolute assurance that the related risk management, control and governance objectives were achieved for the period under review in most areas.

"We note that the Staff Development and Succession Planning, and Estates Management reviews had an assurance rating of ‘limited’ for the operational effectiveness of the controls in place. It was evident in the review and through discussion with management that process changes were actively being addressed during the time of the audit.”

The internal audit standards were revised in January 2024 and will be adopted by public bodies from April 2025. The new Global Internal Audit Standards (GIAS), supersedes the previous Public Sector Internal Audit Standards (PSIAS). 

This year we asked BDO (our internal auditors) to undertake several audits to provide assurance that we are managing key risks well and achieving value for money. The audits were:

  • Our approach to the handling of complaints.
  • Our approach to providing flood planning advice.
  • A review of our corporate governance arrangements.
  • A review of our colleague development and succession planning processes.
  • Estates management.
  • Our approach to fixed and variable monetary penalties. 

The results of all completed internal audits in 2024/25, including findings and resulting improvement actions, were accepted and approved by the Corporate Leadership Team and the Audit, Risk and Assurance Committee. Improvement actions from all audits are monitored and completion of actions is verified independently by our internal auditors annually. At the end of 2024/25, there were no overdue management actions.

Risk management and resilience

We have a risk management framework in place where we have clearly set out the responsibilities of the Board, Audit, Risk and Assurance Committee, Corporate Leadership Team, management and colleagues. We seek to: (i) understand threats; (ii) identify and prioritise risks; (iii) put in place controls to reduce or mitigate risks and (iv) monitor risks. We assess risks in terms of the likelihood of them occurring and the impact they would have if they did occur.

Our principal risk register is scrutinised quarterly by our Corporate Leadership Team and Audit, Risk and Assurance Committee. We also provide an Annual Review of Risk report to the Board. Risk is regularly discussed at Corporate Leadership Team and Board meetings and informs our internal audit programme. We routinely review external analysis of key risks impacting UK organisations and consider potential risks raised by our people or Board members to ensure risks are being managed across the organisation. Bespoke risk management training is available to all colleagues, either on a one-to-one basis, or via team workshops. We also have a range of tools available to colleagues to help them identify and manage risks. We have outlined our key risks and challenges in the performance section of this report.

Our risk management arrangements comply with the five main principles and several of the supporting principles of risk management that are set out in The Orange Book[5].  We continue to review and improve our risk management process to incorporate more of the supporting principles. In 2024/2025, we carried out a strategic review of our risk management practices, which included the creation of a new principal risk register with associated risk appetite, a set of guiding principles for risk management in SEPA and a complete refresh of our operational risk registers. 

As a Category 1 responder under the Civil Contingencies Act 2004, we work with multi-agency resilience partnerships to plan, respond to, and recover from emergencies where there is an actual or potential environmental or business continuity impact. We also ensure that we have our own emergency and business continuity plans in place. We regularly hold resilience exercises with our Corporate Leadership Team, where we simulate multiple emergency scenarios as well as training and exercising events for our strategic, tactical and operational responders.


[5] ‘The Orange Book: Management of Risk - Principles and Concepts’ provides guidance to government organisations on the development and implementation of risk management processes.


Information governance

During 2024/25, we made significant progress to strengthen our Information Governance framework. A major milestone was the formal approval of SEPA’s updated Records Management Plan, accepted by the Keeper of the Records for Scotland, reflecting our commitment to robust information stewardship and compliance with statutory obligations. This was complemented by the lifting of the intervention from the Office of the Scottish Information Commissioner (OSIC), and performance returning to pre-pandemic levels, marking a return to full regulatory confidence in our information handling practices.

Throughout the reporting period, we maintained a strong record of compliance, with no reportable personal data breaches to the Information Commissioner’s Office (ICO). This outcome highlights the effectiveness of the Agency’s risk-based approach to information security and its continued investment in cyber resilience and data protection. The Agency’s assurance reporting also highlighted the integration of information governance into broader organisational risk frameworks, including the development of a new assurance map and the embedding of information governance within the three lines of assurance model.

Looking ahead, SEPA’s Information Governance maturity assessment and implementation actions remain a priority. These efforts are designed to ensure that SEPA remains agile, compliant and resilient in the face of evolving digital and regulatory landscapes.

Written authorities provided to the Accountable Officer

The Permanent Secretary to the Scottish Government designated the Chief Executive, N Paterson, as the Accountable Officer for SEPA with effect from 7 November 2022. 

Review of effectiveness

As Accountable Officer, I have responsibility for reviewing the effectiveness of the systems of internal control. Our internal control systems include delegation and accountability; a code of conduct all colleagues must follow; procedures, standing financial instructions, guidance and training; internal checks and balances; regular reviews of management information, including financial, performance and risk information; peer reviews; external accreditation; and internal and external audit. My review of the effectiveness of these systems is informed by:

  • The views of the Audit, Risk and Assurance Committee on the assurance arrangements in place.
  • The work of the internal auditors and the opinion of the Chief Audit Executive.
  • Reviews of the corporate risk register and risk management processes by the Risk Management Group, the Corporate Leadership Team and the Audit, Risk and Assurance Committee.
  • Reviews of regular performance and financial reports by the Corporate Leadership Team and the Board.
  • Feedback from Senior Leaders about delivery of our duties and objectives, response to risks, budget management and use of resources.
  • Comments made by the external auditors in their management letter and other reports.
  • Completion of an annual certificates of assurance exercise with written assurance from Chief Officers that internal measures are operating sufficiently within their portfolios.

Based on the above, I am satisfied that the corporate governance arrangements in place are appropriate and that there are no significant issues.

Approved by the Board on 25 November 2025 and signed on behalf of the Board on 10 December 2025.

N Paterson, Chief Executive and Accountable Officer

Remuneration and staff report

Remuneration report

Remuneration policy

The Board, Chief Executive, Executive Directors, and Chief Officers’ remuneration packages are agreed within the parameters set by the Scottish Government’s pay policy. The Scottish Government approves the daily fee to be paid to the Chair and Board members, as well as approving the Chief Executive’s remuneration package.

There were no significant decisions taken on Executive Directors’ remuneration in year. No performance payments were made in 2024/25 in accordance with the Scottish Government pay policy.

Chair and Board members

All appointments to the Board are on a non-pensionable part-time basis. Board members contribute at least two days per month in support of our activities. The Chair devotes, at a minimum, 12 days per month in support of our activities, and the Deputy Chair and Audit and Risk Chair devote three days per month.

The Board members did not receive any benefits in kind in 2024/25. Table 14 is subject to audit and provides details of the remuneration of Board members.

Table 14: Board remuneration

Name

Post and term

2024/25

£’000

2023/24

£’000

B Downes

Chair to 31 December 2023 when term in office ended

0

35 to 40

L Tennant

Chair from 1 January 2024

50 to 55

10 to 15

F Van Dijk

Deputy Chair to 31 December 2023 when term in office ended

0

5 to 10

H Kohli

Deputy Chair from 1 January 2024

10 to 15

5 to 10

M Hill

Board member to 31 December 2023 when term in office ended

0

5 to 10

N Gordon

Board member and Chair of Audit and Risk Committee

10 to 15

10 to 15

C Hume

Board member

5 to 10

5 to 10

J Hutchison

Board member to 31 March 2024 following resignation

0 to 5

5 to 10

P Matthews

Board member to 31 December 2023 when term in office ended

0

5 to 10

N Chambers

Board member to 25 July 2023 following resignation

0

0 to 5

C Evans

Board member from 15 January 2024

5 to 10

0 to 5

D Hunter

Board member and Chair of People and Resources Committee from 15 January 2024

5 to 10

0 to 5

L MacDonald

Board member from 15 January 2024

5 to 10

0 to 5

L McMillan

Board member from 15 January 2024

5 to 10

0 to 5

S Paterson

Board member from 15 January 2024

5 to 10

0 to 5

K Rosser

Board member from 15 January 2024

5 to 10

0 to 5

Corporate Leadership Team pensions and salary benefits

In 2024/25, Corporate Leadership Team (CLT) members received no benefits in kind. Changes included D Pirie's resignation in June 2024, A Flucker's appointment in April 2024, and D Harley's interim appointment in March 2025. Table 15, subject to audit, details CLT remuneration and pension benefits.

Table 15: Corporate Leadership Team pension and salary benefits 2024/25 and 2023/24

Name

Post

Full time equivalent 2024/25 £’000 Remuneration 2024/25
£’000

Pension benefits
2024/25 £’000[6]

Total
2024/25
£’000

Remuneration

2023/24

£’000

Pension benefits
2023/24

£’000

Total

2023/24

 

 £’000

N Paterson

Chief Executive

130-135

130-135

74

200-205

120 to 125

54

175 to 180

D Pirie

Executive Director

120-125

30-35

Less than 0

25-30

115 to 120

37

155 to 160

A Milloy

Chief Officer

100-105

100-105

36

135-140

90 to 95

25

115 to 120

J Kenny

Chief Officer

N/A

N/A

N/A

N/A

40 to 45

73

115 to 120

I Buchanan

Chief Officer

N/A

N/A

N/A

N/A

95 to 100

48

140 to 145

J Russell

Acting Chief Officer

N/A

N/A

N/A

N/A

30 to 35

7

35 to 40

D Harley

Acting Chief Officer

95-100

0 to 5

42

45 to 50

90 to 95

43

130 to 135

L Bunten

Chief Officer

95-100

90-95

48

140-145

90 to 95

 

32

120 to 125

B Marshall

Acting Chief Officer

N/A

N/A

N/A

N/A

80 to 85

36

115 to 120

K Paterson

Chief Officer

100-105

100-105

33

135-140

60 to 65

N/A

60 to 65

K L Campbell[7]

Chief Officer

100-105

100-105

58

 165-170

15 to 20

N/A

15 to 20

A Flucker[8]

Chief Officer

100-105

90-95

29

115-120

N/A

N/A

N/A


[6] The value of pension benefits accrued during the year is calculated as the real increase in pensions and applying the HMRC methodology multiplier of 20 plus the real increase in any lump sum. The real increases exclude increases due to inflation and are net of contributions made by the individual. If the figure is negative a nil change is recorded.

[7] There was an inter-fund transfer received on 18 November 2024. The transferred final salary service, CARE pot and CETV has been removed from the calculations to show a more accurate figure for the increase in this member’s pension, lump sum and CETV to 31 March 2025.

[8] Joined the LGPS on 1 May 2024. As such, there is no comparative figures against prior years.


Table 16: Pension entitlements of Chief Executive, Executive Director and Chief Officers’ 2024/25 (audited) [9]

 

 

 

Name

Accrued pension March 2025

£’000

Accrued lump sum March 2025

£’000

Real increase in pension

£’000

Real increase in lump sum

£’000

CETV

March 2025[10]

£’000

CETV

March 2024

£’000

Real increase in CETV

£’000

N Paterson

55 to 60

55 to 60

2.5 to 5

0 to 2.5

956

854

60

D Pirie

65 to 70

85 to 90

0 to 2.5

Less than 0

1,452

1,318

86

A Milloy

5 to 10

0 to 5

0 to 2.5

0 to 2.5

140

100

27

J Kenny

N/A

N/A

N/A

N/A

N/A

992

N/A

I Buchanan

N/A

N/A

N/A

N/A

N/A

1,046

N/A

J Russell

N/A

N/A

N/A

N/A

N/A

458

N/A

D Harley

45 to 50

65 to 70

0 to 2.5

 Less than 0

               949

893

25

L Bunten

40 to 45

35 to 40

2.5 to 5

0 to 2.5

735

658

46

B Marshall

N/A

N/A

N/A

N/A

N/A

672

N/A

K Paterson

0 to 5

0 to 5

0 to 2.5

0 to 2.5

38

14

14

K L Campbell[11]

35 to 40

30 to 35

2.5 to 5

0 to 2.5

670

5

84

A Flucker

0 to 5

0 to 5

0 to 2.5

0 to 2.5

23

0

14


[9]The increase shown is the difference between the CETV calculated at 31 March 2025 and that provided in the 31 March 2024 disclosure (report dated September 2024), allowing for inflation and member contributions. We have assumed, as in previous years’ disclosures, that each director’s own contribution should be deducted.

[10] A cash equivalent transfer (CETV) is the actuarially assessed capitalised value of the pension scheme benefits accrued by a member at a point in time. The benefits valued are the member’s accrued benefits and any contingent spouse’s pension payable from the scheme. A CETV is a payment made by a pension scheme or arrangement to secure pension benefits in another pension scheme or arrangement when the member leaves a scheme and chooses to transfer the benefits accrued in their former scheme. The pension figures shown relate to the benefits that the individual has accrued because of their total membership of the scheme including any benefit transferred from another scheme and not just their service in a senior capacity to which the disclosure applies. The real increase in CETV reflects the increase in CETV effectively funded by the employer. It does not include the increase in accrued pension benefits due to inflation, contributions paid by the employee and uses common market valuation factors for the start and end of the period.

[11] There was an inter-fund transfer received on 18 November 2024. The transferred final salary service, CARE pot and CETV has been removed from the calculations to show a more accurate figure for the increase in this member’s pension, lump sum and CETV to 31 March 2024.


Compensation payments (subject to audit)

D Pirie accepted voluntary severance in March 2024 and departed in June 2024; he received a compensation payment of £68,229 and the cost of buying out the actuarial reduction in his pension was £191,006. In line with accountancy standards, these costs were accounted for in 2023/24.

Fair pay disclosure (subject to audit)

We are required to disclose pay information in relation to the highest paid member of the management team and how it compares to remuneration paid to staff and agency workers at the 25th, 50th and 75th percentile. These have been calculated on the annualised salaries; the calculation excludes employer pension contributions and cash equivalent transfer values. 

The annual pay awards and remuneration are guided by the Scottish Government’s Public Sector Pay Policy. Any pay proposal is subject to Scottish Government approval to ensure compliance with the fair pay requirements of the Public Sector Pay Policy and are underpinned by an Equality Impact Assessment. A formal offer is subject to collective bargaining with our recognised trade union, UNISON. This process applies to all SEPA pay grades, with the exception of, Chief Executive pay, which is subject to separate Scottish Government guidance.
 
SEPA agreed a two year pay offer, effective from 1 April 2023 to cover financial year (FY) 2023/24 and 2024/25. In line with Scottish Government Pay Policy, we prioritised a progressive approach so that the lower pay bands were provided with the greatest pay increase. We also removed base pay steps from some of our pay bands to help reduce the progression journey time within a pay band in line with good practice recommendations.
 
The Chief Executive pay covered FY 2024/25 only and increased by 5%. 
 
The changes in pay ratios between FY 2023/24 and FY 2024/25 are attributable to the application of these pay increases and measures for our main cohort of pay grades over the two-year period compared to the increased percentage applied to the Chief Executive pay band. The median pay ratio is consistent for the pay policies applied and represents a similar outcome across both this and last financial years.

Table 17: Fair pay disclosure (subject to audit)

 

2024/25

2023/24

Remuneration band highest paid individual

£130,000-£135,000

£125,000-£130,000

Percentage change from previous financial year

5%

1.19%

Average percentage ratio change from previous financial year

5.6%

7.7%

25th quartile remuneration

£36,906

£34,674

25th quartile ratio

3.59

3.68

50th quartile remuneration

£42,913

£41,132

50th quartile ratio

3.09

3.10

75th quartile remuneration

£50,120

£48,267

75th quartile ratio

2.64

2.64

Remuneration range

£24,573-£140,881

£22,134-£134,172

People report

Employee relations and well-being

As the environment around us changes, we must review how we collectively work together to tackle the climate emergency and deliver on our commitments to the people of Scotland.

With a focus on purpose, people and continuous improvement, we have created our People Strategy, which will bring clarity to employees and managers, building a framework to actively build on performance, capability and well-being. This Strategy supports our Corporate Plan and ensures our people have what they need to deliver our Corporate Priorities. 

The aim of our People Strategy is to create a safe, welcoming and high performing environment, where SEPA employees belong and feel valued. By delivering on our commitments in the People Strategy, we will support our teams to deliver on their outcomes and make a difference to the future of our environment.

Our values of Purposeful, Professional and Passionate underpin all people related activity, and help to create common understanding around expectation and performance. To support this, we have a behaviours framework with self-assessment tools to embed the values and behaviours. Within our People Strategy we have identified four ‘pillars’ where we will focus on improvements:

  • How we work: We will provide the tools to deliver our statutory purpose in flexible ways which sustain flooding and regulatory services response and support our goal to be a net zero organisation. This includes workspaces, fleet and travel, hybrid working and facilities management.
  • People and Organisational Development: We will support the organisation, leaders and individuals to fulfill the potential and create opportunities for progression and innovation. This includes career and succession planning, continuous learning, performance management and talent acquisition.
  • Employee support: Provide the tools, support and guidance required to enable safe, productive, capable and efficient teams. This includes health, safety and well-being, reward and recognition, equality, diversity and inclusion.
  • Engaging and empowering teams: Empower teams and individuals to bring the visions and values of SEPA to life. This includes values, behaviours, employer brand and employee engagement. 

As we continue to deliver an organisation-wide transformation programme taking full advantage of public sector reform opportunities and efficiencies, our People Strategy will be at the core of this work, prioritising effective engagement with our people and our recognised Trade Union to help us understand the issues which matter most and support us to identify and develop actions and improvements. 

We continue to look for new, innovative ways to support, develop and engage with our people and develop a positive working environment for all.

Equality and diversity

Equality, diversity and inclusion is integral to all our work, our service provision and our interactions with communities and businesses, as well as our colleagues. We published our Equality Mainstreaming and Outcomes Report in April 2023. We will report on the work we have undertaken towards our equality outcomes for 2022-2026 in our next mainstreaming report, due in 2026. 

Table 18 represents the gender split within SEPA as at 31 March 2025 - this table is not subject to audit.

Table 18: SEPA staff headcount and gender split including Board (not subject to audit)

 

2024/25

2023/24

SEPA staff headcount [12]

1,248

1,195

SEPA staff full time equivalent (FTE)

1,195

1,137

SEPA staff gender split-female

58%

58%

SEPA staff gender split–male

42%

42%

Board-female [13]

55%

58%

Board-male

45%

42%

Corporate Leadership Team-female

71%

56%

Corporate Leadership Team-male

29%

44%


[12] Total excludes Board but includes the Corporate Leadership Team

[13] Includes the Chief Executive


Health and safety

The agency remains firmly committed to maintaining a safe, healthy and supportive working environment for all employees. This commitment aligns with our broader organisational reset, reinforcing expected behaviours and leadership standards. Health and safety continues to be a strategic priority, and we are actively strengthening our systems and practices to ensure consistent application of high standards across all teams and work settings, underpinned by a risk-based approach.

Our internal health and safety governance and delivery groups provide oversight and direction, helping to shape a positive culture that supports prevention, learning, and continuous improvement. We are actively developing more tailored and practical support, recognising the varied nature of our operational activities and the specific risks some employees encounter in their roles. 

This year, we placed a renewed focus on behavioural safety and a health and safety reset, led from the Corporate Leadership Team and taken forward by the Health and Safety Team within the People, Workspaces and Development Portfolio. All our employees are encouraged to take ownership of their own health and safety, and that of others by following processes and procedures, staying alert to potential hazards/near misses, and reporting incidents when they occur. These actions have been key to improving the culture when used in conjunction with the wider continually developing health and safety framework including new and revised policies, guidance and support, which are essential for helping us learn and improve our systems and ways of working. 

Our Health and Safety Team continues to lead on maintaining robust reporting processes and ensuring that all employees have access to the training and support they need to work safely. This includes specific health and safety training and online learning resources, working collaboratively with the SEPA Portfolio teams, Organisational Development and Learning and Development teams. 

Health and safety incident reporting summary 2024/25

  • 252 incidents reported in 2024/25 (compared to 90 incidents in 2023/24).
  • 67 hazards spotted in 2024/25 (compared to 13 in 2023/24). Please note that the number of hazards reported are also included in the total number of health and safety incidents reported above.
  • 0 incidents reported to Health and Safety Executive under Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR) in 2024/25 (compared to zero in 2023/24).

We have seen an increase in the number of health and safety incidents being reported across the agency. Importantly, none of these required reporting under RIDDOR.

This trend reflects a more open and proactive reporting culture, where employees feel confident reporting hazards spotted, near misses and other incidents. This is a positive sign that health and safety awareness is improving, allowing us to address issues early and continue to prevent more serious incidents from occurring. 

This is being helped with continual incremental improvements of the incident reporting system and supporting processes, to make it easier for employees to access and report incidents, allowing quicker responsive support and investigation tracking from the Health and Safety Team, this continues.  

SEPA remains committed to building a safer and healthier workplace for all, and will continue to review, develop and improve its approach as part of the wider agency responsibilities.

Trade Union relationship

[14]

UNISON is our recognised trade union. Our Joint Negotiation and Consultation Committee (JNCC) comprising representatives from our management and UNISON meet regularly to discuss information and conduct meaningful consultation and/or negotiation between management representatives and UNISON.

UNISON supports us in our initiatives to ensure working conditions and an overall remuneration package that our people value. We negotiate our people’s pay, terms, and working conditions with UNISON. The parameters of pay terms and conditions that we can offer are contained within Scottish Government’s public sector pay policy. A two-year pay offer for the period 1 April 2023 to 31 March 2025 was accepted by UNISON in January 2024. 

In accordance with our statutory responsibility under Trade Union (Facility Time Publication Requirements) Regulations 2017, the schedule below provides the required data relating to our trade union representatives for the period 2024/25.

Trade union facilities time 2024/25 (not subject to audit)

[15]

Table 19: Relevant union officials

Number of employees who were relevant union officials

Full-time equivalent employee number

31

29.7

Table 20: Percentage of time spent on facility time [16]. Percentage of time spent on facilities time as a percentage of total working hours for each union representative.

Percentage of time

Number of employees

Less than 1%

4

1-50%

27

51-99%

0

100%

0

Table 21: Percentage of pay bill spent on facility time [17]

Total cost of facility time

£89,832

Total pay bill

£70.5m

Percentage of total pay bill on facility time

0.13%

Table 22: Paid trade union activities [18]

Time spent on paid trade union activities as a percentage of total paid facility time (hours)

71.6%


[14] Industrial relations are not subject to audit

[15] All footnotes on trade union facilities time refer to information taken from HM Government Supporting Guidance for the Trade Union (Facility Time Publication Requirements) Regulations 2017.

[16] Trade union activities - means time taken off under section 170(1) (b) of the 1992 Act. TULR(C) A section 170. There is no statutory entitlement to paid time off to undertake trade union activities. However, trade union representatives are entitled to be granted reasonable unpaid time off to participate in trade union activities.

[17] Total paid facility time hours - total number of hours spent on facility time by trade union representatives during relevant period. Does not include hours attributable to time taken off under section 170(1) (b) of the 1992 Act in respect of which a trade union representative does not receive wages.

[18] Paid trade union activities - time taken off for trade union activities under section 170 (1) (b) of the 1992 Act in respect of which a trade union representative receives wages from the relevant public sector employer. There is no statutory entitlement to paid time off to undertake activities.


Pension scheme

We contribute to the Falkirk Council Pension Fund. This is a Local Government Pension Scheme (LGPS), which is a defined benefit scheme and is administered by Falkirk Council. All staff are eligible to enter the Falkirk Pension Scheme, the Local Government Superannuation Scheme managed by Falkirk Council. Employee contributions, based on salary, are fixed by statute currently on a scale of 5.5% - 11.2%.

Hymans Roberston completed the last formal fund valuation on 31 March 2023. The results are used to set employer contribution rates to ensure the fund can pay members' benefits. SEPA's contribution rate has been set at 17% for the period from 1 April 2024, a reduction of 3.5% from the 2023/24 rate of 20.5%. The next formal valuation will be on 31 March 2026.

Staff costs (subject to audit)

In the year 2024/25, the agency's staff costs amounted to £70m, compared to £68m in 2023/24, in relation to staff who have an employment contract with the agency. Of this, £67m was for permanent staff contracts and £3m was for fixed-term contracts. The average full-time equivalent (FTE) employed during the year was 1,178, with 1,128 on permanent contracts and 50 on fixed-term contracts. In comparison, the previous year's average FTE was 1,122, with 1,096 on permanent contracts and 26 on fixed-term contracts. 

The staff turnover rate was 8% in 2024/25 compared to 7.89% in 2023/24.  

The staff absence rate was 1.94% in 2024/25, compared to 3.09% in 2023/24. This indicates a decrease in the absence rate. The organisation continues to support employees through progressive flexible working and hybrid working policies and introduced a paid well-being and communities day as part of the 2023-2025 pay award.

Other staff-related costs of £2.7m include recruitment, training, agency staff, year-end pension and provision adjustments. We spent £0.46m on agency staff to cover vacancies. 

Table 23 excludes £0.21m on consultancy and £0.42m on professional services both of which are included in other operating costs (see note 5).

Table 23: Staff costs during the year to March 2025 (subject to audit)
 

Permanent staff

£’000

Fixed term staff

£’000

Year to 31 March 2025

£’000

Year to 31 March 2024

£’000

Wages and salaries

52,238

2,329

54,567

50,631

Social security costs

5,398

241

5,639

5,217

Apprenticeship levy

237

11

248

230

Pension costs

9,586

427

10,013

11,680

Subtotal of payroll costs

67,459

3,008

70,467

67,758

Other staff related costs

 

 

1,087

1,061

IAS 19 pension charge (note 17)

 

 

1,296

137

Life assurance provision (note 14)

 

 

234

206

Unfunded IAS 19 pension charge (note 14)

 

 

28

55

 

 

 

73,112

69,217

Exit packages (subject to audit)

As part of the 2023-2025 pay award we agreed a commitment to avoid compulsory redundancy, in accordance with Scottish Government Public Sector Pay Policy.

In 2024/25 we conducted a voluntary severance exercise which resulted in 10 members of staff receiving an exit package. The total cost of the package includes payments made to the Falkirk Pension Fund to meet the costs of staff entitled to early access to pension as part of the voluntary severance agreement.

Table 24: Exit packages (subject to audit) per cost band

Exit package cost band

Number of exit packages

2024/25

Number of exit packages 2023/24

£0-£10,000

1

0

£10,000 - £25,000

2

4

£25,000 - £50,000

0

4

£50,000 - £100,000

2

6

£100,000 - £150,000

2

4

£150,000 - £200,000

2

2

£200,000 - £250,000

1

1

£250,000 - £300,000

0

1

£300,000 - £350,000

0

1

Total number of packages

10

23

Total costs disclosed in the financial statements £’000

£1,040

£2,356

Parliamentary accountability report (subject to audit)

Fees and charges

The financial statements provide a breakdown of our £55.4m income from contracts (see note 2 on page 126) of which £53m relates to charging scheme fees and charges. Our fees and charges have been set to comply with the cost allocation and charging requirements set out by Scottish Public Finance Manual, HM Treasury, and the Office of Public Sector Information guidance on trading funds and commercial services. 

Table 25 provides the detail of our income, expenditure and cost recovery levels for charging schemes. The financial objective for charging schemes is full cost recovery taking one year with another, based on all costs including current cost depreciation and a rate of return on relevant assets.

Table 25: Trading accounts cost recovery year to 31 March 2025
  ERS[19] £’000 PRW[20]£’000 RSA nuclear[21] £’000 Other[22]£’000 Total £’000
Income 48,171 1,635 2,717 443 52,966
Expenditure 49,415 1,302 2,654 572 53,943
(Under)/over recovery (1,244) 333 63 (129) (977)
% cost recovery 97% 126% 102% 77% 98%

[19] Environmental Regulation (Scotland)

[20] Producer Responsibility Waste Packaging

[21] Radioactive Substances Act

[22] Total of charging schemes which generate income of less than £1m


Consolidated fund receipts

We collect penalties for EU Emissions Trading Scheme (EU ETS) and environmental offences. During 2024/25, penalty notices of £3.6m (2023/24 - £4.8m) were raised and payments of £3.5m were received and remitted to Scottish Government. As at 31 March 2025, there was an outstanding balance of £2.7m in our current assets and liabilities. As we are acting as an agent on behalf of Scottish Government these balances are not reflected in the accounts.

Value for money

As with all governmental bodies, we are required to deliver optimal value and achieve efficiency savings of a minimum of 3% annually. To balance the 2024/25 budget, we included £2.9 million in savings from staff turnover, equating to a 4% reduction. The actual savings made were £6.2m, equating to 8.2%, which were mainly achieved through management of staff turnover.

Contingent liabilities

We occupy several leased properties, which have dilapidation clauses in the leases. We maintain these properties in excellent order. Some properties have a potential liability at the end of the lease to reinstate the internal layout of the building to their original floor plan. A provision is in place for properties where the estimated costs are considered to be significant.

Most of our gauging stations are on leased sites. When we no longer require these facilities, they must be decommissioned, removing the plant, buildings and restoring the site. The level of these potential future liabilities will be subject to negotiation with individual landlords.

As at end of March 2025, we were involved in one ongoing litigation and one statutory appeal in relation to regulatory matters, which may result in claims for legal fees and expenses. In addition, we received one civil claim and notification of a second potential claim. One of these claims is being disclosed as remote contingent liability and one as a contingent liability. 

Losses and special payments

There were no losses or special payments exceeding £300k in the financial year to 31 March 2025.

Gifts

There were no gifts exceeding £250k in the financial year to 31 March 2025.

Approved by the Board on 25 November 2025 and signed on behalf of the Board on 4 December 2025.

N Paterson, Chief Executive and Accountable Officer

Independent auditor’s report to the members of the Scottish Environment Protection Agency, the Auditor General for Scotland and the Scottish Parliament

Reporting on the audit of the financial statements

Opinion on financial statements

I have audited the financial statements in the annual report and accounts of the Scottish Environment Protection Agency for the year ended 31 March 2025 under Section 46 of the Environment Act 1995. The financial statements comprise the statement of comprehensive net expenditure, the statement of financial position, the statement of cash flows, the statement of changes in taxpayers’ equity and notes to the financial statements, including material accounting policy information. The financial reporting framework that has been applied in their preparation is applicable law and UK adopted international accounting standards, as interpreted and adapted by the 2024/25 Government Financial Reporting Manual (the 2024/25 FReM).

In my opinion the accompanying financial statements:

  • give a true and fair view of the state of the body’s affairs as at 31 March 2025 and of its net expenditure for the year then ended;
  • have been properly prepared in accordance with UK adopted international accounting standards, as interpreted and adapted by the 2024/25 FReM; and
  • have been prepared in accordance with the requirements of Section 45(2) of the Environment Act 1995 and directions made thereunder by the Scottish Ministers. 

Basis for opinion

I conducted my audit in accordance with applicable law and International Standards on Auditing (UK) (ISAs (UK)), as required by the Code of Audit Practice approved by the Auditor General for Scotland. My responsibilities under those standards are further described in the auditor’s responsibilities for the audit of the financial statements section of my report. I was appointed by the Auditor General on 5 June 2023. My period of appointment is five years, covering 2022/23 to 2026/27. I am independent of the body in accordance with the ethical requirements that are relevant to my audit of the financial statements in the UK including the Financial Reporting Council’s Ethical Standard, and I have fulfilled my other ethical responsibilities in accordance with these requirements. Non-audit services prohibited by the Ethical Standard were not provided to the body. I believe that the audit evidence I have obtained is sufficient and appropriate to provide a basis for my opinion.

Conclusions relating to going concern basis of accounting

I have concluded that the use of the going concern basis of accounting in the preparation of the financial statements is appropriate.

Based on the work I have performed, I have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the body’s ability to continue to adopt the going concern basis of accounting for a period of at least twelve months from when the financial statements are authorised for issue.

These conclusions are not intended to, nor do they, provide assurance on the body’s current or future financial sustainability. However, I report on the body’s arrangements for financial sustainability in a separate Annual Audit Report available from the Audit Scotland website

Risks of material misstatement

I report in my separate Annual Audit Report the most significant assessed risks of material misstatement that I identified and my judgements thereon.

Responsibilities of the Accountable Officer for the financial statements

As explained more fully in the Statement of Accountable Officer's Responsibilities, the Accountable Officer is responsible for the preparation of financial statements that give a true and fair view in accordance with the financial reporting framework, and for such internal control as the Accountable Officer determines is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, the Accountable Officer is responsible for assessing the body’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless there is an intention to discontinue the body’s operations.

Auditor’s responsibilities for the audit of the financial statements

My objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes my opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the decisions of users taken on the basis of these financial statements.

Irregularities, including fraud, are instances of non-compliance with laws and regulations. I design procedures in line with my responsibilities outlined above to detect material misstatements in respect of irregularities, including fraud. Procedures include:

  • using my understanding of the central government sector to identify that Section 45(2) of the Environment Act 1995 and directions made thereunder by the Scottish Ministers are significant in the context of the body;
  • inquiring of the Accountable Officer as to other laws or regulations that may be expected to have a fundamental effect on the operations of the body;
  • inquiring of the Accountable Officer concerning the body’s policies and procedures regarding compliance with the applicable legal and regulatory framework;
  • discussions among my audit team on the susceptibility of the financial statements to material misstatement, including how fraud might occur; and
  • considering whether the audit team collectively has the appropriate competence and capabilities to identify or recognise non-compliance with laws and regulations.

The extent to which my procedures are capable of detecting irregularities, including fraud, is affected by the inherent difficulty in detecting irregularities, the effectiveness of the body’s controls, and the nature, timing and extent of the audit procedures performed.

Irregularities that result from fraud are inherently more difficult to detect than irregularities that result from error as fraud may involve collusion, intentional omissions, misrepresentations, or the override of internal control. The capability of the audit to detect fraud and other irregularities depends on factors such as the skilfulness of the perpetrator, the frequency and extent of manipulation, the degree of collusion involved, the relative size of individual amounts manipulated, and the seniority of those individuals involved.

A further description of the auditor’s responsibilities for the audit of the financial statements is located on the Financial Reporting Council's website. This description forms part of my auditor’s report.

Reporting on regularity of expenditure and income

Opinion on regularity

In my opinion in all material respects the expenditure and income in the financial statements were incurred or applied in accordance with any applicable enactments and guidance issued by the Scottish Ministers.

Responsibilities for regularity

The Accountable Officer is responsible for ensuring the regularity of expenditure and income. In addition to my responsibilities in respect of irregularities explained in the audit of the financial statements section of my report, I am responsible for expressing an opinion on the regularity of expenditure and income in accordance with the Public Finance and Accountability (Scotland) Act 2000.

Reporting on other requirements

Opinion prescribed by the Auditor General for Scotland on audited parts of the Remuneration and Staff Report

I have audited the parts of the Remuneration and Staff Report described as audited. In my opinion, the audited parts of the Remuneration and Staff Report have been properly prepared in accordance with Section 45(2) of the Environment Act 1995 and directions made thereunder by the Scottish Ministers.

Other information

The Accountable Officer is responsible for the other information in the annual report and accounts. The other information comprises the Performance Report and the Accountability Report excluding the audited parts of the Remuneration and Staff Report. 

My responsibility is to read all the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or my knowledge obtained in the course of the audit or otherwise appears to be materially misstated. If I identify such material inconsistencies or apparent material misstatements, I am required to determine whether this gives rise to a material misstatement in the financial statements themselves. If, based on the work I have performed, I conclude that there is a material misstatement of this other information, I am required to report that fact. I have nothing to report in this regard.

My opinion on the financial statements does not cover the other information and I do not express any form of assurance conclusion thereon except on the Performance Report and Governance Statement to the extent explicitly stated in the following opinions prescribed by the Auditor General for Scotland.

Opinions prescribed by the Auditor General for Scotland on Performance Report and Governance Statement

In my opinion, based on the work undertaken in the course of the audit:

  • the information given in the Performance Report for the financial year for which the financial statements are prepared is consistent with the financial statements and that report has been prepared in accordance with Section 45(2) of the Environment Act 1995 and directions made thereunder by the Scottish Ministers; and
  • the information given in the Governance Statement for the financial year for which the financial statements are prepared is consistent with the financial statements and that report has been prepared in accordance with Section 45(2) of the Environment Act 1995 and directions made thereunder by the Scottish Ministers.

Matters on which I am required to report by exception

I am required by the Auditor General for Scotland to report to you if, in my opinion:

  • adequate accounting records have not been kept; or
  • the financial statements and the audited parts of the Remuneration and Staff Report are not in agreement with the accounting records; or
  • I have not received all the information and explanations I require for my audit.

I have nothing to report in respect of these matters.

Conclusions on wider scope responsibilities

In addition to my responsibilities for the annual report and accounts, my conclusions on the wider scope responsibilities specified in the Code of Audit Practice are set out in my Annual Audit Report.

Use of my report

This report is made solely to the parties to whom it is addressed in accordance with the Public Finance and Accountability (Scotland) Act 2000 and for no other purpose. In accordance with paragraph 108 of the Code of Audit Practice, I do not undertake to have responsibilities to members or officers, in their individual capacities, or to third parties.

Liz Maconachie, CPFA
Senior Audit Manager
Audit Scotland, 4th Floor, 8 Nelson Mandela Place,
Glasgow
G2 1BT

10 December 2025


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