FOI Request - Governance and Whistleblowing in ALEOs
Request 101003900010
I request the following information relating to the council’s use of Arms Length External Organisations (ALEOs) and associated governance arrangements:
1. ALEO Landscape
• The number of ALEOs currently operating under the council’s remit.
• A list of ALEOs, including their legal form (company, trust, charity, CIC, etc.).
2. Board Composition
• The number of volunteer trustees or non executive directors serving on ALEO boards.
• The number of councillors appointed to ALEO boards, including any instances where councillors have served as Chair or Vice Chair.
3. Whistleblowing Disclosures
a) Records of any disclosures made to ALEO board members, by the Council or any of its representatives, at the point of appointment regarding whistleblowing protections or exclusions.
b) Copies of template appointment letters or induction packs issued to ALEO board members since 2015.
c) Confirmation of whether ALEO board members are covered by the council’s whistleblowing policy.
4. Policy and Review Records
• Records/minutes of any governance committee discussions relating to whistleblowing policy updates since 2015.
5. Training and Awareness
• Attendance records or certificates of completion for whistleblowing training sessions arranged by the Council or its representatives.
6. Governance Oversight
a) Records of conflicts of interest declared by councillors serving on ALEO boards since 2015.
b) Records of any disputes, complaints, or investigations involving ALEOs since 2015, including whistleblowing related matters.
c) Correspondence with Audit Scotland, OSCR, or the Standards Commission regarding ALEO governance.
7. External Auditors’ Role
a) Records of any issues raised by the council’s external auditors (Audit Scotland or appointed firms) regarding whistleblowing policies, governance of ALEOs, or protections for trustees/non executive directors since 2015.
b) Copies of external audit management letters, reports, or recommendations relating to ALEO governance or whistleblowing.
c) Confirmation of whether external auditors have ever raised concerns about the council’s whistleblowing policy or its application to ALEO board members.
Response 13-01-2026
1. There is no clear definition of the term ALEO. A reasonable interpretation would be separate bodies in which the council has a major ownership stake. We have based our response on this and have not included bodes which the council control through funding/contract.
Limited companies:
Moray leisure limited - https://find-and-update.company-information.service.gov.uk/company/SC145750 - 3 Councillors appointed as directors out of 7.
Statutory boards:
Grampian valuation joint board - https://www.grampian-vjb.gov.uk/ - 3 Councillors appointed. Chair held by Moray Councillor.
Moray integration joint board - http://www.moray.gov.uk/moray_standard/page_100266.html - 4 Councillors appointed as members. Chair shared with Grampian NHS on a shared basis
Trust funds:
Microsoft Word - Connected Charities Trust Fund Trustees Report and Financial Statements 24-25 AUDITED – http://www.moray.gov.uk/downloads/file164019.pdf - membership varies – can be area councillors, can be whole council.
2. Please see above
3. a) None held. Information that is not held falls under Section 17 of the Freedom of Information (Scotland) Act 2002 - Information not held.
b) No templates/induction packs held. Training is offered for some positions. Information that is not held falls under Section 17 of the Freedom of Information (Scotland) Act 2002 - Information not held.
c) The whistleblowing policy just applies to officers
4. Not applicable
5. Not applicable
6. a) We do not hold a list but councillors do declare from time to time at committee meetings. The details can be found in council minutes which are searchable here: http://www.moray.gov.uk/moray_standard/page_40962.html
Councillors register of interests can be found here: https://moray.cmis.uk.com/moray/CouncilandGovernance/Councillors.aspx
b) None held. Exempt under S.17 FOISA
c) None held. We have had internal audit request that an appropriate SLA is put in place for Moray Leisure Limited. Report here:
https://moray.cmis.uk.com/Moray/Document.ashx?czJKcaeAi5tUFL1DTL2UE4zNRBcoShgo=7dpR4%2bI%2b8sBbkhAbnET2aR1NdzFipMoqUalHFlYng2PvKCpNgII6DQ%3d%3d&rUzwRPf%2bZ3zd4E7Ikn8Lyw%3d%3d=pwRE6AGJFLDNlh225F5QMaQWCtPHwdhUfCZ%2fLUQzgA2uL5jNRG4jdQ%3d%3d&mCTIbCubSFfXsDGW9IXnlg%3d%3d=hFflUdN3100%3d&kCx1AnS9%2fpWZQ40DXFvdEw%3d%3d=hFflUdN3100%3d&uJovDxwdjMPoYv%2bAJvYtyA%3d%3d=ctNJFf55vVA%3d&FgPlIEJYlotS%2bYGoBi5olA%3d%3d=NHdURQburHA%3d&d9Qjj0ag1Pd993jsyOJqFvmyB7X0CSQK=ctNJFf55vVA%3d&WGewmoAfeNR9xqBux0r1Q8Za60lavYmz=ctNJFf55vVA%3d&WGewmoAfeNQ16B2MHuCpMRKZMwaG1PaO=ctNJFf55vVA%3d
7. a) None that we are aware of. Annual audit reports are available on the committee site.
b) Not applicable
c) None