6.1. The council holds significant levels invested funds, representing income received in
advance of expenditure plus balances and reserves held. Cash, cash equivalents and
investments held on 31 December 2023 are summarised in the table below.
Table, Cash and Treasury Investments (as at 31 December 2023)
n/a |
Balance £m |
Cash and Cash Equivalents |
26.2 |
Treasury Investments |
n/a |
Corporate bond funds |
12.9 |
Equity income funds |
33.0 |
Property funds |
19.6 |
Multi asset income funds |
5.1 |
Total Treasury Investments |
70.5 |
Total Cash and Investments |
96.7 |
6.2. The CIPFA Code requires the council to invest its treasury funds prudently, and to
have regard to the security and liquidity of its investments before seeking the highest
rate of return, or yield.
The council’s objective when investing money is to strike an appropriate balance between risk and return, minimising the risk of incurring losses from defaults and the risk of receiving unsuitably low investment income.
Where balances are expected to be invested for more than one year, the council will aim to
achieve a total return that is equal or higher than the prevailing rate of inflation, in order
to maintain the spending power of the sum invested.
The council aims to be a responsible investor and will endeavour to consider environmental, social and governance (ESG) issues when making investment decisions.
6.3. As demonstrated by the liability benchmark above, the council expects to be a long-term borrower and new treasury investments will therefore be made primarily to
manage day-to-day cash flows using short-term low risk instruments.
6.4. The council has investments of approximately £70m in externally managed strategic
pooled investment vehicles (bond, equity, multi-asset and property funds) where short-term
security and liquidity are lesser considerations, and the objectives instead are regular revenue income and long-term price stability.
6.5. Under the IFRS 9 standard, the accounting for certain investments depends on the
council’s “business model” for managing them.
The council aims to achieve value from its treasury investments by a business model of collecting the contractual cash flows and therefore, where other criteria are also met, these investments will continue to be accounted for at amortised cost.
6.6. The CIPFA Code does not permit local authorities to both borrow and invest long-term
for cash flow management.
But the council may make long-term investments for treasury risk management purposes, including to manage interest rate risk by investing sums borrowed in advance for the capital programme for up to three years; to manage inflation risk by investing usable reserves in instruments whose value rises with inflation; and to manage price risk by adding diversification to the strategic pooled fund portfolio.
6.7. Environmental, social and governance (ESG) considerations are increasingly a factor in global investors’ decision making, but the framework for evaluating investment opportunities is still developing and therefore it is not currently feasible to consistently and reliably formally consider ESG scoring or other real-time ESG criteria at an individual investment level.
When investing in banks and funds, the council will prioritise banks that are signatories to the UN Principles for Responsible Banking and funds operated by managers that are signatories to the UN Principles for Responsible Investment, the Net Zero Asset Managers Alliance and/or the UK Stewardship Code.
6.8. The council may invest its surplus funds with any of the counterparty types in table 5 below, subject to the limits shown.
Table, Treasury investment counterparties and limits
Sector |
Time limit |
Counterparty limit |
Sector limit |
The UK Government |
50 years |
Unlimited |
n/a |
Local authorities & other government entities |
25 years |
£30m |
Unlimited |
Secured investments |
25 years |
£30m |
Unlimited |
Banks (unsecured) |
13 months |
£15m |
Unlimited |
Building societies (unsecured) |
13 months |
£15m |
£30m |
Registered providers (unsecured) |
5 years |
£15m |
£30m |
Money market funds |
n/a |
£30m |
Unlimited |
Strategic pooled funds |
n/a |
£20m |
£150m |
Real estate investment trusts |
n/a |
£20m |
£100m |
Other investments |
5 years |
£15m |
£30m |
The above table must be read in conjunction with the notes below, the notes give a more detailed explanation of some of the various sectors and limits.
6.9. *Minimum credit rating: Treasury investments in the sectors marked with an asterisk will only be made with entities whose lowest published long-term credit rating is no lower than A-. Where available, the credit rating relevant to the specific investment or class of investment is used, otherwise the counterparty credit rating is used.
However, investment decisions are never made solely based on credit ratings, and all other relevant factors including external advice will be taken into account. For entities without published credit ratings, investments may be made where external advice indicates the entity to be of similar credit quality.
6.10. Government: Loans to, and bonds and bills issued or guaranteed by, national governments, regional and local authorities and multilateral development banks.
These investments are not subject to bail-in, and there is generally a lower risk of insolvency, although they are not zero risk. Investments with the UK Government are deemed to be zero credit risk due to its ability to create additional currency and therefore may be made in unlimited amounts for up to 50 years.
6.11. Secured investments: Investments secured on the borrower’s assets, which limits the potential losses in the event of insolvency.
The amount and quality of the security will be a key factor in the investment decision. Covered bonds and reverse repurchase agreements with banks and building societies are exempt from bail-in.
Where there is no investment specific credit rating, but the collateral upon which the investment is secured has a credit rating, the higher of the collateral credit rating and the counterparty credit rating will be used.
The combined secured and unsecured investments with any one counterparty will not exceed the cash limit for secured investments.
6.12. Banks and building societies (unsecured): Accounts, deposits, certificates of deposit and senior unsecured bonds with banks and building societies, other than multilateral development banks. These investments are subject to the risk of credit loss via a bail-in should the regulator determine that the bank is failing or likely to fail. See below for arrangements relating to operational bank accounts.
6.13. Registered providers (unsecured): Loans to, and bonds issued or guaranteed by, registered providers of social housing or registered social landlords, formerly known as housing associations.
These bodies are regulated by the Regulator of Social Housing (in England), the Scottish Housing Regulator, the Welsh Government and the Department for Communities (in Northern Ireland).
As providers of public services, they retain the likelihood of receiving government support if needed.
6.14. Money market funds: Pooled funds that offer same-day or short notice liquidity and very low or no price volatility by investing in short-term money markets.
They have the advantage over bank accounts of providing wide diversification of investment risks, coupled with the services of a professional fund manager in return for a small fee.
Although no sector limit applies to money market funds, the council will take care to diversify its liquid investments over a variety of providers to ensure access to cash at all times.
6.15. Strategic pooled funds: Bond, equity and property funds that offer enhanced returns over the longer term but are more volatile in the short term.
These allow the council to diversify into asset classes other than cash without the need to own and manage the underlying investments.
Because these funds have no defined maturity date, but are available for withdrawal after a notice period, their performance and continued suitability in meeting the council’s investment objectives will be monitored regularly.
6.16. Real estate investment trusts: Shares in companies that invest mainly in real estate and pay the majority of their rental income to investors in a similar manner to pooled property funds.
As with property funds, REITs offer enhanced returns over the longer term, but are more volatile especially as the share price reflects changing demand for the shares as well as changes in the value of the underlying properties.
6.17. Other investments: This category covers treasury investments not listed above, for example unsecured corporate bonds and company loans.
Non-bank companies cannot be bailed-in but can become insolvent placing the council’s investment at risk.
6.18. Operational bank accounts: The council may incur operational exposures, for example though current accounts, collection accounts and merchant acquiring services, to any UK bank with credit ratings no lower than BBB- and with assets greater than £25 billion.
These are not classed as investments but are still subject to the risk of a bank bail-in, and balances will therefore be kept below £10m per bank.
The Bank of England has stated that in the event of failure, banks with assets greater than £25 billion are more likely to be bailed-in than made insolvent, increasing the chance of the council maintaining operational continuity.
6.19. Risk assessment and credit ratings: Credit ratings are obtained and monitored by the council’s treasury advisers, who will notify changes in ratings as they occur.
The credit rating agencies in current use are listed in the Treasury Management Practices document.
Where an entity has its credit rating downgraded so that it fails to meet the approved investment criteria then:
- no new investments will be made
- any existing investments that can be recalled or sold at no cost will be, and
- full consideration will be given to the recall or sale of all other existing investments with the affected counterparty
6.20. Where a credit rating agency announces that a credit rating is on review for possible downgrade (also known as “negative watch”) so that it may fall below the approved rating criteria, then only investments that can be withdrawn on the next working day will be made with that organisation until the outcome of the review is announced.
This policy will not apply to negative outlooks, which indicate a long-term direction of travel rather than an imminent change of rating.
6.21. Other information on the security of investments: The council understands that credit ratings are good, but not perfect, predictors of investment default.
Full regard will therefore be given to other available information on the credit quality of the organisations in which it invests, including credit default swap prices, financial statements, information on potential government support, reports in the quality financial press and analysis and advice from the council’s treasury management adviser.
No investments will be made with an organisation if there are substantive doubts about its credit quality, even though it may otherwise meet the above criteria.
6.22. Reputational aspects: The council is aware that investment with certain counterparties, while considered secure from a purely financial perspective, may leave it open to criticism, valid or otherwise, that may affect its public reputation, and this risk will therefore be considered when making investment decisions.
6.23. Market conditions: When deteriorating financial market conditions affect the creditworthiness of all organisations, as happened in 2008, 2020 and 2022, this is not generally reflected in credit ratings, but can be seen in other market measures.
In these circumstances, the council will restrict its investments to those organisations of higher credit quality and reduce the maximum duration of its investments to maintain the required level of security.
The extent of these restrictions will be in line with prevailing financial market conditions. If these restrictions mean that insufficient commercial organisations of high credit quality are available to invest the council’s cash balances, then the surplus will be deposited with the UK Government, or with other local authorities.
This will cause investment returns to fall but will protect the principal sum invested.
6.24. Investment limits: the maximum that will be lent to any one organisation (other than the UK Government) will be £30 million.
A group of entities under the same ownership will be treated as a single organisation for limit purposes.
Credit risk exposures arising from non-treasury investments, financial derivatives and balances greater than £10 million in operational bank accounts count against the relevant investment limits.
6.25. Limits are also placed on fund managers, investments in brokers’ nominee accounts and foreign countries and industry sectors as below.
Investments in pooled funds and multilateral development banks do not count against the limit for any single foreign country, since the risk is diversified over many countries.
Table, Additional investment limits
Investment |
Cash limit |
Any group of pooled funds under the same management |
£50m per manager |
Negotiable instruments held in a broker’s nominee account |
£50m per broker |
Foreign countries |
£25m per country |
6.26. Liquidity management: The council monitors its cash flow forecasting on a daily basis to determine the maximum period for which funds may prudently be committed.
The forecast is compiled on a prudent basis to minimise the risk of the council being forced to borrow on unfavourable terms to meet its financial commitments.
Limits on long-term investments are set by reference to the council’s medium-term financial plan and cash flow forecast.
The council will spread its liquid cash over at least three providers (e.g. bank accounts and money market funds) to ensure that access to cash is maintained in the event of operational difficulties at any one provider.