Sunday, 15 September 2024

They cannot both be correct

By Andrew Rowson

 

Under the Nolan Principles, among other things, public servants are required to be honest and accountable:

“Holders of public office are accountable to the public for their decisions and actions and must submit themselves to the scrutiny necessary to ensure this.”

Accountability is apparently not a requirement at Cambridgeshire County Council (CCC), at least not among some senior officers and elected members.

In a recent post on this site, the authority’s Head of Human Resources, Janet Atkin, was asked to comment on documents she prepared in October 2018 for audit firm BDO.  Those documents contain entirely false information that demonstrably contradicts the public record of real events and other public documents.  In the three weeks since then, there has been no response.

That post centred around a meeting of the Staffing and Appeals Committee held on 8th September 2016.  As chance would have it, CCC’s current leader, Cllr Lucy Nethsingha, attended that meeting as a substitute. 

The official minutes do not record whether the vote was unanimous, but Cllr Nethsingha was among the members who resolved to appoint Mr Chris Malyon to the post of Deputy Chief Executive, adding that title to his Chief Finance Officer role.

The leader too was contacted on 27th August this year and asked for her recollection of the meeting.  It is important because the approved minutes - the council’s official record of the meeting - make no mention of an interview.  Ms Atkin twice referred to an interview in her documents.  Instead, the minutes only mention a report, which was not made public.  The minutes do not mention a “£10,000 special responsibility allowance”, though Ms Atkin mentions it twice in her documents.  No allowance or any other additional remunerative benefit for Mr Malyon (on top of the amount in the annual pay policy statement) was ever put to the full council for its approval, either in 2016/17 or in any other year.  The council’s own pay policy requires full council approval for any amendment to senior officer pay.  The council thus breached its own written pay policy, and Ms Atkin tried to cover that up with the confidential documents she prepared for BDO, presumably on the instructions of then CEO, Gillian Beasley (see previous post).

The Director of HR's documents and the minutes of that September 2016 committee meeting are irreconcilable.  Both accounts cannot be correct.  If Ms Atkin lied and misled the auditors with incorrect information they later relied on (however stupidly) when considering an objection to the accounts, why is she still in her post?  Alternatively, if the official minutes of that meeting were materially incorrect because they omitted key details about a senior officer's unlawful pay increase, why has that not been investigated?  Like Ms Atkin, the council leader has failed to respond, even to say that it was a long time ago and she cannot recall what took place.  By failing to respond, Cllr Nethsingha has also declined to be accountable,  That makes her party to the cover-up.  Even that is no longer surprising at CCC, since the CEO, Dr Stephen Moir, has written to some elected members, instructing them not to engage with certain members of the public, including, in one case, one of their own constituents.

According to the Director of Human Resources, as the earlier post explained, the secret £10,000 "allowance" was just one component of Mr Malyon’s unapproved £38,000 pay rise and £7,000 additional pension contribution from CCC in 2017/18.  The other component, an implausible, undocumented, unconstitutional, and unapproved CFO regrade, (applied retrospectively), was also set out in Ms Atkin’s CM.docx document that was given to BDO in September 2018.  It was never given to the full council or any committee, and does not exist as a public document.  According to Ms Atkin, it was those two components that explained Mr Malyon’s overall £45,000 remuneration increase in 2017/18.  £45,000 was the exact sum of the non-executive directorship fee (NED) for Mr Malyon’s services at Cambridge and Counties Bank (CCB) in the same year.  The £40,000 fee for his services the previous year (2016/17) at the same 50% owned subsidiary of CCC was the figure BDO auditor Lisa Blake referred to (and later admitted to) in her July 2018 comment about the omission of remunerative benefits required for inclusion.  


It is not difficult to see how Mr Malyon managed to pocket those NED fees without declaring them for up to five years.  CCB is 50% owned by CCC, but that ownership is delegated to its Pension Fund.  The Pension Fund’s draft accounts for 2023/24 state:

“The Fund is joint owner, along with Trinity Hall, Cambridge, of Cambridge and Counties Bank (CCB). The Fund has no controlling interest in the Bank and it is included within the Fund’s financial statements as a minority interest. Each shareholder is entitled to appoint one shareholder Non-Executive Director to the Board of CCB. The Fund is represented by an external party to the Pension Fund.”

The external party does not seem to be concerned with governance or scrutiny.

For the 17th July 2024 meeting of CCC’s Assets and Procurement Committee, the Monitoring Officer, Emma Duncan, presented a report on the governance of council owned companies where the council’s holding is 25% or above.  The table of five companies meeting that criterion did not include Cambridge and Counties Bank.  On 6th August I wrote to the Monitoring Officer asking why CCB was missing from the list and how CCC manages the governance and scrutiny functions of its 50% holding.  Ms Duncan has not responded.

Returning to Mr Mason’s objection and the demonstrably false information in the Head of HR’s documents, in the five and a half years it took BDO to consider Mr Mason’s 2018 objection, BDO audit partner Lisa Blake had to use her professional judgement and professional scepticism.  She had to assess the incontrovertible, fully referenced documentary evidence presented in Mr Mason's objection and in the October 2018 revised Document F on the one hand, and on the other, Ms Atkin’s transparent lies in her CM.docx and embedded documents, that were wholly unsupported by any public document.  True to form, BDO dismissed Mr Mason’s evidence, and swallowed the lies.  That is because BDO’s Lisa Blake was complicit in the cover-up from 2017/18, and because BDO plainly did not want to do the right thing and acknowledge that its client’s CEO and CFO were involved in alleged abuse of position fraud.  Similar wilful blindness is not unheard of in the audit industry.

After five and a half years, and two days before Lisa Blake stepped down from BDO altogether, this is what the replacement partner, Mr Ciaran MacLaughlin wrote in the January 2024 statement of reasons, a document which, according to BDO’s Head of Audit and Assurance, Mr Scott Knight, spent well over a year being reviewed not only by BDO’s lawyers, but also by Public Sector Audit Appointments Ltd, the company  that appointed BDO and EY to be CCC’s external auditors:

As Document F from 2018 and last month’s letter to the Head of HR show only too clearly, BDO was 100% wrong, and complicit in the cover-up since:

·      There was no due process, and there were no lawful mid-year salary increases in 2016/17 for the Deputy CEO role, or in 2017/18 for Mr Malyon’s CFO role.  There was only Ms Atkin’s dishonest CM.docx document, produced on Mrs Beasley’s instructions, which BDO accepted uncritically.

·       The £45,000 overall increase in Mr Malyon’s remuneration in 2017/18 (£38k + £7k) was the laundered £45,000 NED fee from Cambridge and Counties Bank, as Lisa Blake herself later admitted to me, and as she had already mentioned in her comments about the senior officer’s omitted remunerative benefits.  There is no other documentation to explain that £38k+£7k rise because the March 2017 pay policy statement left Mr Malyon’s pay band unchanged at £95-£100k, and there was no subsequent pay policy statement amendment during 2017/18.

 

The charge sheet

“The simplest way to combat misinformation is with the truth.”

Taylor Swift

Mr Mason and I have been spelling out these truths for the last six years, but the political establishment has gone to extreme lengths to lie, deny the truth, and work against the public interest, evidently because it is embarrassing,  and because all the parties involved appear to be corrupt.  It is time to go public with these accusations.  They are not new and have been made publicly at CCC and to the auditors, and to the Deputy Prime Minister.  It is time to make them more public still.  If I am wrong, then I would expect to receive letters threatening legal action from the parties below.  There have been none to date.  If after this post, there is still no response from the lawyers, then readers will be able to draw their own conclusions.

 

CCC

The two protagonists: Mr Malyon and former CEO Gillian Beasley both retired on generous taxpayer-funded pensions two years before BDO produced its statements of reasons earlier this year.  The charges remain that Mr Malyon stole five-figure, or more likely six-figure taxpayers’ money in total over several years in the form of NED fees from CCB, which should have gone to CCC.  When she discovered this, or when she decided she needed to do something, the CEO laundered the 2017/18 NED fee (£45k) into an unlawful pay rise for her CFO.  Just before the start of the following financial year, in March 2018 Mrs Beasley tried to cover her tracks by dishonestly raising Mr Malyon’s 2017/18 “current salary range” by £30,000 in order to make his effective 33% pay policy statement increase for 2018/19 look more reasonable (see Janet Atkin letter).

CCC’s current CEO, Dr Stephen Moir, the council leader, Cllr Lucy Nethsingha, the deputy leader, Cllr Elisa Meschini, and the Chair of the Audit and Accounts Committee, Cllr Graham Wilson, are all well aware of the facts surrounding Mr Malyon’s unlawful pay rise and other matters, since they were all given briefings by me and/or Mr Mason in 2021 and 2022.  Cllr Nethsingha’s current silence over her recollection of Mr Malyon’s unlawful pay rise is unacceptable conduct in a council leader.

“Honesty, no matter how difficult, is a vital part of maintaining high standards in public life and the confidence of the public.  Holders of public office acting in the public’s name must live up to this important principle in the day-to-day operation of their duties, and own up when things go wrong.”

Jane Ramsey – Committee on Standards in Public Life

 

BDO

Even if BDO’s lawyers were unaware of Mr Malyon’s undeclared NED fees over at least two years, and possibly up to five years (which seems unlikely), they could not have been unaware of the unlawfulness of Mr Malyon’s £38k+£7k pay rise.  That is because of the high profile, analogous case in 2022 of Northumberland CC’s former CEO DaljitLally’s unapproved, and therefore unlawful “international expenses” of £40,000/yr over several years, which resulted in that authority’s Section 151 officer taking advice from Counsel, and issuing a s114 notice  (unlawful expenditure – s114 and s114A, Local Government Finance Act 1988).  I allege that BDO’s lawyers knew the facts, but did nothing.  If they did not know, they were lied to and misled by Lisa Blake.

In February 2023, Mr Scott Knight, BDO’s Head of Audit and Assurance, publicly took ownership for completing BDO’s much delayed investigations into Mr Mason’s two objections from 2017 and 2018, which included Mr Malyon’s undisclosed NED fees and unlawful pay rise, and the nine figure false accounting of City Deal grants.  He promised the statements of reasons in “a matter of a few weeks, rather than anything longer than that”.  In the end, it took a further 51 weeks before Mr Mason received his two statements of reasons, a delay twice as long as the Code of Audit Practice recommends for local auditors to consider an objection from the start.  I submit that it is not remotely credible that Mr Knight was unaware of the true facts.  He too did nothing to stop the cover-up of the facts relating to Mr Malyon’s undisclosed NED fees and unlawful £38k pay rise - or indeed of BDO's insistence that the false accounting of City Deal grant revenue complied with the CIPFA Code.

  

Public Sector Audit Appointments (PSAA)

The PSAA is a wholly-owned subsidiary of the Local Government Association (LGA) – a declared political organisation.  PSAA had no excuse for not knowing, or for dismissing the fact that Mr Malyon’s unauthorised 36% mid-year pay rise in 2017/18 was unlawful.  It should not have approved BDO’s statements of reasons.  As with Mr Knight, if the PSAA was unaware of Mr Malyon’s undisclosed benefits from NED fees in the years up to and including 2017/18, it was lied to and misled by BDO and CCC.

When Mr Knight appeared before CCC’s Audit and Accounts Committee in February 2023, the LGA’s Chief Executive was Mr Mark Lloyd.  Before moving to the LGA in 2015, Mr Lloyd was the CEO and Head of Paid Service at Cambridgeshire County Council.  He was the authority’s CEO in 2013 when Mr Malyon was appointed CFO, notwithstanding the latter’ well-known track record for dishonesty at Barnet Council just two years earlier.

I have no evidence to suggest that Mr Lloyd’s unexpected and sudden resignation from the LGA last October, with immediate effect, which produced a five-month vacuum at the top, had anything to do with Mr Malyon’s NED fees, his unlawful cover-up pay rise, or the serial false accounting of City Deal government grants instigated by Mr Malyon and BDO’s Lisa Blake in 2017.


Conclusion

This post began with a reference to the Nolan Principles, introduced by the Committee on Standards in Public Life in 1995.

Nearly thirty years later, in March this year, the same Committee announced an open consultation on accountability within public bodies, which it has noticed sometimes falls short of what the public deserves:

“In recent years we have seen several examples of major failures within public institutions, where it seems that opportunities were missed to address issues before they escalated. We are asking, when things go wrong in public bodies, why does it take so long for problems to be recognised and the leadership to respond appropriately and, most importantly, what needs to change?”

The Committee is expected to publish its findings in the spring of 2025.

Cambridgeshire County Council and the agencies it works with provide a clear case study illustrating one way in which problems are brushed aside for extended periods, and where leadership fails to respond appropriately.

The mechanism for unaccountability at CCC vis-à-vis the Malyon issue is quite straightforward.  Former CEO Gillian Beasley presumably discovered that Mr Malyon had been benefitting from the CCB NED fees and not disclosing them in the accounts at some stage in 2017/18, before Mr Malyon prepared that year’s draft financial statements.  Instead of disciplining her CFO, she covered it up.  She allowed him to prepare the draft accounts in which that year’s £45,000 NED fee from CCB was presented as a bona fide salary increase.  As head of paid service, she was responsible for that.  In fact, Mr Malyon’s footnote 4 to the senior officer’s remuneration table in those accounts presented the entire £38k pay rise plus £7k pension contribution as a consequence of his Deputy CEO appointment the previous year, from which  the records show no additional financial benefit was due.

4. The Deputy Chief Executive and Chief Finance Officer postholder undertakes non-executive directorships at The Cambridge and Counties Bank and This Land Limited, for which CCC received fixed contributions of £45k and £20k respectively (2016/17 £40k and £0). The full remuneration cost for 2017-18 is shown above, along with the cost to CCC for its share. The Chief Finance Officer became Deputy Chief Executive, for which an additional salary amount was payable during 2016-17.

It was only after Mr Mason’s and my first meeting with Lisa Blake on 11th October 2018, and Mr Mason sending copies of the revised Document F to the auditor, the CEO and all members of the Audit & Accounts Committee, that Mrs Beasley instructed her Head of HR, Janet Atkin, to produce the false narrative in CM.docx and send it to BDO on the afternoon of 19th October 2018, just a few days later.  She probably knew that Lisa Blake would do her bidding and collude with the cover-up over Mr Malyon’s dishonesty, which ultimately cost local taxpayers many hundreds of thousands of pounds.

As noted on multiple occasions in last month’s letter to Janet Atkin and elsewhere, BDO duly ignored the irrefutable documentary evidence Mr Mason provided that comprehensively disproves CCC’s multiple false and contradictory narratives.  The so-called independent auditor showed no independence or professional integrity, and no professional scepticism.  Instead, the firm dragged out the objection for five and a half years, until well after Mrs Beasley and Mr Malyon had safely retired, before producing two wholly dishonest statements of reasons, from which CCC’s lies about Mr Malyon’s salary rise are reproduced above.

Thereafter, at the 6th February meeting of the Audit & Accounts Committee this year, CCC’s current CEO, Dr Stephen Moir, who was well aware of the true facts, publicly defended his dishonest and corrupt officers with these disgraceful words:

“What I do want to place on record is, mindful of the individual officers who have had this particular series of issues hanging over them for some considerable time, is to place on record my thanks to them for their resilience, professionalism and tenacity in the face of what has been an unacceptably long period  of concern, challenge and frankly, as we have heard, unjustifiable criticism.”

Thus a corrupt council and its corrupt auditor, backed by lawyers and the PSAA, even today, are working dishonestly and against the public interest to cover up chronic and serious failures at one public institution that is entrusted with spending well over a billion pounds of public money annually.

Mr Knight has yet to reply to my two letters to him regarding his firm’s conduct on the City Deal false accounting and Mr Malyon’s unlawful pay rise.  I am still awaiting replies from Ms Atkin and Cllr Nethsingha about their respective roles in the Malyon scandal and cover-up.  As for the three statutory officers at CCC: the CEO, the s151 Officer, (Mr Michael Hudson) and Monitoring Officer (Ms Emma Duncan), several letters to them in recent weeks have all gone unanswered.  Cambridgeshire County Council has become an accountability-free zone.

“If you are a public office holder, you are expected to lead by example, and also to call out poor ethical behaviour wherever you find it.  If a leader lives up to the principles, promotes and prioritises high standards of ethical behaviour, the institution will follow.” 

  Monisha Shar – Committee on Standards in Public Life

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