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16 October 2023
jerseyauditoffice.je R.153/2023
Contents
Introduction 3 Key Findings 4 Conclusions 5
Objectives and scope of the review 6
Timeliness of publication of annual reports 11
Overall Good Practice Principles 18
Setting requirements for annual reporting 21 Appendix One – Annual reports and accounts reviewed 31 Appendix Two – Scoring methodology for 2022 annual reports 36 Appendix Three – Summary of Recommendations 46
- An annual report is a key means by which an entity tells the story of its year. Public annual reporting, done well, enables stakeholders to understand – with trust and confidence – an entity's strategy and the risks it faces, how much money has been spent and on what, and what has been achieved as a result. It enables stakeholders to hold the entity to account effectively.
- In each year since 2020 I have published a report on Annual Reporting accompanied in each year by a Good Practice Guide. I have also sought to encourage and to share best practice through delivery of workshops, the publication of Frequently Asked Questions (FAQs) and the publication of Annual Report Self-Assessment Tools.
- Consistent with my 2020, 2021 and 2022 reviews, for this 2023 report I have reviewed the annual reports and, where available publicly, the annual accounts produced by the States of Jersey and by Jersey entities that are either:
• identified by the States of Jersey in their annual report as controlled by the States; or
• established by the States Assembly and required to prepare an annual report and/or accounts.
- I have reviewed 38 annual reports for 2022 that were published by 31 July 2023. The full list of annual reports I have considered since 2020 is set out in Appendix One. I have considered the content of all the annual reports and accounts reviewed against a set of criteria that encompassed:
• minimum content that I consider to be best practice for accountability to public stakeholders
• essential elements of a good annual report; and
• over-arching principles for good public reporting.
- The scoring methodology for assessing 2022 annual reports is set out in Appendix Two.
- To assist entities in improving their performance I am also publishing a third Good Practice Guide updated for 2023 that draws out examples from the better performing entities.
- In each of the last three years I have reported that annual reports of States controlled and States established entities have been getting better. This trend has continued for a fourth year. For 65% of 2022 annual reports I have reviewed I have noted improvements. As a result, in overall terms:
• 76% of 2022 annual reports now have good or fair content compared to best practice (66% for 2021); and
• 82% of 2022 annual reports are good or fair compared to best practice principles (79% for 2021).
- The States of Jersey are making progress in implementing the wider recommendations from my 2022 report. However further work is still required to:
• set out minimum annual reporting requirements for States controlled and States established entities; and
• implement sustainability reporting.
- Larger entities are able to devote greater resources to preparing their annual reports and they tend to be glossier and more attractive to read. Typically, they include more best practice content than I have found in those of smaller entities. However:
• this is sometimes in addition to existing content and can make annual reports overly long and complex; and
• some smaller entities succeed in providing best practice content whilst keeping their annual reports relatively brief.
- Performance reports are generally stronger than accountability reports within annual reports. The key area for improvement in accountability reports concerns staffing issues, particularly remuneration of board members and of senior staff at smaller entities.
- There has been little change in the timeliness of the publication of annual reports. Where reporting deadlines are set, 77% of entities met their deadline (75% for 2021 reports).
- The States of Jersey have made improvements to their own annual report. I assessed the 2022 annual report as good. However, I note two important areas of inconsistency that need to be addressed:
• as in previous years, the States of Jersey are not required by the Jersey Financial Reporting Manual (JFReM) to consolidate all of their subsidiaries into their Group financial statements. The JFReM requirements are not compliant with International Financial Reporting Standards. The States of Jersey are aware of this and are working towards compliance in future years. Out of seven subsidiaries that are material to the States of Jersey Group, only three are consolidated; and
• there is an opportunity to enhance further the public financial reporting by Government departments.
- I am pleased to see year-on-year improvements in the annual reports of States controlled and States established entities that I have reviewed. I encourage these entities to consider how to address the matters raised in this report and to use my updated Good Practice Guide to make further improvements.
- I am also pleased to see progress made by the States of Jersey in improving their own annual report and in implementing some of my wider recommendations from 2022. Appendix Three consolidates recommendations from my previous reviews with those arising from issues identified in this report. I will continue to monitor the progress being made to address these recommendations.
Objectives and scope of the review
- The review has evaluated the 2022 annual reports of the States of Jersey, States controlled entities and entities established by the States, against updated criteria encompassing:
• minimum content that I consider to be best practice for accountability to public stakeholders
• essential elements of a good annual report; and
• over-arching principles for good public reporting.
- These criteria and the scoring methodology are set out in Appendix Two.
- The review sought to identify the progress being made by entities in improving their annual reporting. It also sought to identify and share good practice through the publication of an updated Good Practice Guide.
- Exhibit 1 summarises the key elements I consider to be good practice in the single annual report.
Exhibit 1: Good practice single annual reports
Single Annual Report
Supporting accountability Transparent
Accessibility Understandable
Accountability Report |
Directors' or |
equivalent report |
|
A statement of |
responsibilities |
|
A governance report |
|
A remuneration and |
staff report |
|
Performance Report Financial Statements
Strategy
Prepared under a suitable framework
Risks
Suitably assured
Operations
Performance analysis
Financial performance
Source: Jersey Audit Office
- Entities need to adapt good practice to their circumstances. For example:
• where entities are not required to prepare financial statements, I would expect annual reports to present other relevant financial information
• exceptionally, where an entity has no income and expenditure, for example because costs are incurred by a third party, I would expect this to be explained; and
• where an entity does not engage any staff, for example because services are contracted out, I would expect the annual report to set out the arrangements that are in place.
- Of the annual reports reviewed for 2022, 79% included information on performance, accountability and (where relevant) finances. This represents a significant improvement compared to 2019 and 2020 and is a further improvement compared to 2021 annual reports (see Exhibit 2).
Exhibit 2: 2022 annual reports including information on performance, accountability and (where relevant) finances
100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0%
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2019 2020 2021 2022
All relevant elements reported One or more relevant elements missing
Source: Jersey Audit Office analysis of annual reports
- In each of the last three years I have reported that annual reports of States controlled and States established entities have been getting better. This trend has continued for a fourth year:
• 65% of entities improved the content of their 2022 annual reports compared to 2021, with 21% making significant improvements; and
• 76% of entities now produce an annual report with content I judge as fair or good compared to best practice (see Exhibit 3).
Exhibit 3: Overall assessment of the content of annual reports 2019 to 2022
100% 90% 80% 70% 60%
50% 40% 30% 20% 10% 0%
2019 2020 2021 2022
Good Fair Poor Very poor
Source: Jersey Audit Office analysis of annual reports
- As for 2020 and 2021 annual reports, entities generally made improvements to their 2022 annual reports by retaining the same structure and style as in previous years and seeking compliance with good practice by including additional content.
- While including additional content typically provides more complete and useful information, entities also need to ensure that they consider the needs of their stakeholders:
• larger entities, especially those with glossy and detailed annual reports, may need to review how they tell the story of the year. For example, could the key issues be presented more effectively and succinctly?
• smaller entities may need to pay particular attention to proportionality when applying best practice. For example, if an entity's governance arrangements are straightforward, it may be sufficient to describe these more simply, and in less detail, than larger entities with more complex arrangements
• many reports would benefit from better signposting, especially the larger and more complex annual reports. For example, few annual reports provide an overview of key sections to explain their purpose and summarise key messages; and
• few performance and accountability reports are signed and dated by the chief executive, accountable officer or equivalent.
- Exhibit 4 sets out how three entities made significant improvements to their 2022 annual reports.
Exhibit 4: Entities making significant improvements
Entity Areas of improvement
Jersey Sport The Jersey Sport annual report has, for many years, been attractively
presented, easy to read and informative.
The 2022 annual report builds on this strong base by setting out more clearly key information such as Jersey Sport's strategy, key objectives, risks and performance.
As a result, it is easier to understand what Jersey Sport is trying to achieve and the progress it has made during the year.
JT Until 2021, JT produced two public reports: one was focussed
primarily on the financial statements, the other on performance and corporate governance issues.
For 2022, these were brought together in a single report that provides an overview covering all three areas. As a result, it is easier for stakeholders to gain an understanding of JT's story for the year.
Jersey Legal The 2021 JLIB annual report comprised the audited accounts and a Information single narrative commentary covering aspects relating to performance Board (JLIB) and accountability.
For the most part, the 2022 annual report retains a similar narrative style but makes significant improvements by structuring its contents around good practice and providing additional information in line with my Good Practice Checklist. For a small entity, the accountability section is particularly impressive, especially the clear remuneration and staff report.
Source: Jersey Audit Office analysis of 2021 and 2022 annual reports
Timeliness of publication of annual reports
- There was little change in respect of timeliness of publication of annual reports for 2022.
- For 2022, one half of entities reported in the same month as for 2021, one quarter reported in an earlier month and one quarter in a later month (see Exhibit 5).
Exhibit 5: Reporting dates for 2022 annual reports compared to 2021 annual reports
Reported in a later Reported in an month earlier month
25% 25%
Reported in the same month 50%
Source: Jersey Audit Office analysis of 2021 and 2022 annual reports
- For those entities with annual reporting deadlines,there was a slight improvement in the percentage of entities that met their deadline (see Exhibit 6).
Exhibit 6: Annual reports published within deadlines
100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0%
2019 2020 2021 2022
Deadline met Deadline missed
Source: Jersey Audit Office analysis of 2019 to 2022 annual reports
Performance reports
- Performance reports should be:
• balanced, fair and understandable; and
• tell the full story of an entity, including both positive and negative aspects of performance.
- For 2021, I assessed 66% of performance reports as good or fair which was a marked improvement from previous years. For 2022 annual reports, I updated my methodology for assessing performance reports. This means that the results are not directly comparable to prior years. However, it is clear that performance reports have continued to improve. Using the updated methodology:
• 84% of performance reports are good or fair compared to the minimum content I would expect to be reported (see Exhibit 7); and
• 71% of performance reports are good or fair when compared to best practice (see Exhibit 8).
Exhibit 7: 2022 performance reports compared to minimum standards
Very poor 3%
Poor 13%
Good 55%
Fair 29%
Source: Jersey Audit Office analysis of 2022 annual reports
Exhibit 8: 2022 performance reports compared to best practice
Very poor 16%
Good 37%
Poor 13%
Fair 34%
Source: Jersey Audit Office analysis of 2022 annual reports
- The main areas that improved during 2022 annual reporting
• clearer descriptions of organisational priorities
• fuller discussion of risks facing the entity; and
• more explicit analyses of performance against priorities.
are similar to 2021:
- These remain the key areas to address for those entities I assess as having poor and very poor performance reports.
- There is also scope for further improvements to performance reports, including for those assessed as fair or good. The key areas are:
• quantifying performance measures and risks and showing how they align with the entity's strategy and priorities
• being clearer as to whether or not performance is satisfactory and what action is being taken to address poor performance; and
• discussion of the entity's operating model and how it achieves value for money.
- Accountability reports should be signed and dated by the chief executive, accountable officer or equivalent. They should contain at least two sections:
• a corporate governance report, which as a minimum should include:
o the directors' or equivalent report
o a statement of responsibilities; and
o a governance statement; and
• a remuneration and staff report.
- Entities should provide at least a short overview of these sections and explain how they contribute to the entity's accountability and practice in the context of corporate governance norms and codes.
- For 2021 annual reports, I assessed 58% of accountability reports as good or fair which represented an improvement from previous years. For 2022, I updated my methodology for assessing accountability reports which means the results are not directly comparable to prior years. However, there were undoubtedly further improvements made by entities in accountability reporting in 2022 annual reports. The results from my assessments using the revised methodology are:
• 81% of 2022 accountability reports are good or fair compared to the minimum content I would expect to be reported (see Exhibit 9); and
• 63% of 2022 accountability reports are good or fair when compared to best practice (see Exhibit 10).
Exhibit 9: 2022 accountability reports compared to minimum standards
Very poor 8%
Poor 11%
Good 60%
Fair 21%
Source: Jersey Audit Office review of 2022 annual reports
Exhibit 10: 2022 accountability reports compared to best practice
Very poor
16%
Good 24%
Poor 21%
Fair 39%
Source: Jersey Audit Office review of 2022 annual reports
- The rate of improvement for accountability reports is slower than for other elements of the annual report. 19% of 2022 accountability reports are still poor or very poor compared to minimum standards and 37% are poor or very poor compared to best practice.
- The key areas where accountability reports fall short of best practice are:
• staff reporting and disclosure of remuneration of board members and of senior officers
• disclosure of potential conflicts of interest of board members and senior officers (this is in addition to the process for managing conflicts which is often well described); and
• highlights of the board and committee reports, an assessment of the board's performance and the actions being taken to make improvements.
- Overall, there was an improvement in the information provided on staff and remuneration. However, in my view this continues to be the most important area for improvement, particularly for smaller entities. I repeat the comments I made in my 2022 report:
• staff and remuneration reporting is fundamental to ensuring transparency and accountability of public entities
• balancing transparency with protecting information relating to individuals is challenging and this is an important area for the States of Jersey to consider in setting any minimum requirements; and
• until the States of Jersey set out their minimum requirements for staff and remuneration reporting, improvements in accountability reports may remain limited.
Overall Good Practice Principles
- There are, in my view, four overall principles for good practice in annual reports, as shown in Exhibit 11.
Exhibit 11: Overall principles for good practice annual reporting
Supporting Accountability Transparency
• telling the story of the • frank and honest analysis organisation in a fair and
• consideration of the challenges
balanced way
an organisation is facing
• compliance with relevant • appropriate use of data; and reporting requirements; and
• quantification of risks and
• clear action points to take performance measures. forward.
Accessibility
• highlights key trends in the financial statements
• concise summaries of key points; and
• consideration of how the organisation engages with key stakeholders and meets their needs.
Understandable Use of:
• plain English to explain difficult concepts
• infographics and diagrams to communicate important messages; and
• clearly integrated structure to help users navigate it effectively.
Source: National Audit Office Good Practice in Annual Reporting January 2022
- These principles should be evident across the sections of the annual report.
- The proportion of annual reports demonstrating fair or good compliance with best practice principles now stands at 82%. Compliance has improved markedly over the first three years of my review, with a further improvement for 2022 annual reports (see Exhibit 12).
Exhibit 12: 2019 to 2022 annual reports compared to best practice principles
100% 90% 80% 70% 60% 50%
40% 30% 20% 10% 0%
2019 2020 2021 2022
Good Fair Poor Very poor
Source: Jersey Audit Office review of 2019 to 2022 annual reports
Supporting Accountability
- As reported in previous years:
• most annual reports tend to emphasise positive aspects of performance and would tell a more balanced story by discussing areas where performance has been disappointing
• some entities, particularly those with regulatory roles, report on their findings or observations of other bodies, but provide limited information about their own organisation; and
• most annual reports included actions for future years but these were sometimes not easy to identify or not clearly set out.
Transparency
- Many annual reports provide a significant amount of information and discuss what entities have done, their challenges and the risks they face. However, it is not always clear whether entities have achieved what they set out to achieve,
performed well or managed their risks successfully. Transparent annual reports focus on communicating these messages effectively by, for example:
• providing a clear line of sight to show how activities, performance measures, challenges and risks are derived from strategic objectives
• quantifying performance measures and risks
• being clear about whether performance is satisfactory and risks have been addressed; and
• providing short but insightful narrative to help stakeholders understand the context of the information provided.
Accessibility
- The best annual reports have clearly been designed with stakeholders in mind by, for example, providing short summaries to highlight important messages.
- An increasing percentage of the annual reports reviewed provide a commentary on finances in addition to audited accounts or other financial statements. However, for 2022 annual reports reviewed I was unable to locate any meaningful financial information (whether published as part of the annual report or elsewhere) for five entities.
Understandable
- As in previous years, reports were generally well written in plain English. More reports are using tables, graphs and infographics to enhance understandability. As I reported last year however, there is scope for more entities to adopt this approach.
- Also as reported in previous years, there is scope for entities to improve signposting within their annual reports. This is particularly relevant for annual reports that rely primarily on text to communicate messages and as entities seek to include more information to meet best practice.
Setting requirements for annual reporting
- In 2022 I consolidated the recommendations from all of my previous reports into five recommendations. The current status of the implementation of these recommendations is summarised in Exhibit 13.
Exhibit 13: Current status of previous consolidated C&AG recommendations
Recommendation Current status Evaluation
R1 Finalise and set out Recommendation accepted with Progress is being minimum requirements for target implementation date of 31 made.
annual reports and accounts March 2024.
for States established and The States are currently in the
States controlled entities. In process of determining which
doing so, consider: entities meet the definition of
• setting out different States established and States
requirements depending controlled.
on the nature and size of Further work is then required to:
entities
• identify the Accountable
• specifying minimum Officer holding lead
requirements for responsibility
reporting on performance,
accountability and include States established and
finances States controlled entities in the
Accountable Officer
• requiring specific appointment letters issued by
disclosures of the Principal Accounting
remuneration of directors Officer; and
and staff
• introduce requirements into
• for entities required to the Public Finances Manual for
publish financial Accountable Officers to take
statements: steps to ensure that the States
- specifying the controlled and States
accounting framework; established entities for which
and they are responsible meet
- specifying the degree minimum annual reporting
of independent standards.
assurance that should Officers have reported that this
be provided over the further work is on track.
financial statements;
and
• for all entities, setting out the requirements for making the annual report and accounts public.
R2 Introduce a requirement Recommendation accepted with a Progress is being for Statistics Jersey to target date of December 2024. made.
produce an annual report. Legislation is required to effect
this change and is planned as part
of wider changes designed to
preserve the independence of
Statistics Jersey.
Reported by officers as being on track.
R3 Set out a public ambition The States of Jersey annual Good progress is and timetable for the sustainability report is currently being made. production of a States of published as an appendix to the Further work
Jersey annual sustainability States of Jersey Annual Report required to realise report. In doing so, consider: and Accounts. the States'
• the Jersey Performance The 2022 sustainability report was ambitions over Framework and the significantly improved from the next two Taskforce on Climate- previous years and sets out the years.
Related Financial States of Jersey's ambition for
Disclosures (TCFD) further improvements for
recommended disclosures sustainability reporting over the
• whether the sustainability next two years'.
report should form part of
the States of Jersey
Annual Report and
Accounts or be a separate
report
• publishing targets alongside actual performance and comparative data with other jurisdictions where this is available; and
• the degree of independent assurance that should be provided over the data contained within the sustainability report.
R4 Set out minimum Recommendation accepted with a Limited progress requirements for sustainability target date of December 2023. has been made. reporting by States Limited progress is reported by
established and States officers.
controlled entities. In doing
so, consider how to apply the
Jersey Performance
Framework and the TCFD
recommended disclosures.
For all entities:
R5 Continue to improve Good progress is annual reporting. In doing so, Ytheear oentitn yeiesar im reviepwroeved ments across being made.
consider: demonstrated as set out
• any minimum throughout this report. Implementation of requirements set out by recommendations the States of Jersey R1 to R4 will support further
• how to improve reporting improvements in on performance, 2023 annual accountability (including reporting and director and staff onwards. remuneration) and
finances
• how to use an appropriate framework to improve sustainability reporting; and
• other good practice identified in this report and my Good Practice Guide.
Source: Jersey Audit Office analysis
Reporting by the States of Jersey Group
- The 2022 States of Jersey Group annual report was improved from 2021 and I assessed it as good in each of the areas I reviewed:
• overall content
• performance reporting
• accountability reporting; and
• best practice principles.
51. The improvement in performance reporting was particularly strong:
• all minimum performance reporting items were disclosed
• it was far easier to understand how the Common Strategic Policy drives activity; and
• information on performance targets and risk was more comprehensive.
- I was also pleased to note that:
• the annual report was easier to navigate, for example through improved signposting of its content and publishing (and providing a link to) a separate document setting out Government department annual reports
• there was improved presentation of sustainability issues and extended sustainability reporting to include social issues; and
• the States of Jersey carried out a self-assessment of their 2022 annual report to identify areas for improvement in future years.
- However, there are opportunities to improve further the financial reporting:
• at the States of Jersey Group level; and
• for Government departments, States controlled entities and States established entities.
- As in previous years, and in line with the JFReM, the States of Jersey Group 2022 accounts consolidated three of their material subsidiaries, but not the States' four largest subsidiaries. Instead, the Group accounts include these subsidiaries at fair value. The States are aware that the current approach does not comply with International Financial Reporting Standards and intend to move to fully consolidated accounts on a staged basis from 2024.
- Full consolidated accounts prepared on a consistent basis would provide better financial information to support policymakers and enhance scrutiny and accountability. Full consolidated accounts would also provide additional information to external users such as credit rating agencies.
- The States have not yet prepared a project plan or a clear timetable to support their ambitions.
- There is a lack of consistency in the financial reporting requirements of Government departments, States controlled entities and States established entities:
• the Statement of Outturn Against Approvals contained in the States of Jersey annual report shows how each department has performed against its budget. However the States do not set minimum requirements for more granular financial reporting in Government department annual reports. Such minimum requirements could, for example, set out requirements to report expenditure against budget at sub-head level; and
• as reported in my July 2023 Thinkpiece Mid-Term Reflections, there is a lack of consistency in the financial information that individual States established and States controlled entities are required to publish. For example:
- some entities, such as limited companies, are required to publish audited accounts that follow relevant accounting practice; and
- others are not required to prepare accounts or have no audit requirement.
- In my view, all Government departments, States established and States controlled entities should disclose or publish relevant financial information to assist stakeholders in assessing the performance of the entity. Where financial transactions of an entity are included within the States of Jersey Accounts, the relevant financial information could be disclosed either within the States of Jersey Accounts or within the entity's own annual report, or both.
Recommendations for the States of Jersey
R1 Set out a project plan and timetable for the preparation and publication of full
consolidated States of Jersey Group accounts.
R2 Set out minimum requirements for more granular financial reporting in
Government department annual reports.
Developments in sustainability reporting
- The purpose of sustainability reporting is to encourage organisations to take positive action to address environmental, social and governance (ESG) issues by:
• setting out the organisation's ESG ambitions; and
• reporting the progress it is making in achieving these ambitions.
- Sustainability reporting includes, but is wider than, reporting on climate change (see Exhibit 14).
Exhibit 14: Potential areas of sustainability reporting
Area Potential reporting issues
Environment Climate change
• Use of natural resources
• Polluting discharges
• Waste
• Biodiversity and ecosystem conservation
People Employees and workforce
• Social matters
Human rights Reporting criteria used
• Supply chains
• High risk areas for civil and political rights
• Impacts on indigenous and local communities
• Conflict-affected areas
• Data protection
Anti-corruption Commitment to fight against corruption
• Whistleblowing channels
General positive Impact of products/services impacts Opportunities
Source: Jersey Audit Office Annual Reporting Workshop 2022
- There is a range of international frameworks in place and being developed. These include:
• Task force on Climate-related Financial Disclosures (TCFD) – created by the Financial Stability Board to improve and increase reporting of climate-related financial information
• International Sustainability Standards Board (ISSB) – established by the trustees of the International Financial Reporting Standard (IFRS) Foundation to develop reporting standards that will result in a high-quality, comprehensive global baseline of sustainability disclosures focussed on the needs of investors and the financial markets
• International Public Sector Accounting Standards Board (IPSASB) - develops accounting standards and guidance for use by public sector entities. IPSASB is currently researching and scoping public sector specific sustainability projects
• UN Sustainable Development Goals (SDGs) – in 2015 the UN published 17 SDGs in an urgent call for action by all countries in a global partnership. The SDGs recognise that ending poverty and other deprivations must go hand-in- hand with strategies that improve health and education, reduce inequality and spur economic growth – all while tackling climate change and working to preserve our oceans and forests; and
• Global Reporting Initiative (GRI) – the GRI publishes standards for sustainability reporting that are designed to be used by any organisation regardless of size or sector.
- The States of Jersey have developed their own Performance Framework (Exhibit
15). This comprises a set of measurements by which the Island's progress towards sustainable wellbeing goals can be judged. The Framework consists of two parts:
• Island outcome indicators; and
• service performance measures.
Exhibit 15: Jersey Performance Framework (Island Outcomes and Sustainable Wellbeing)
Source: Government of Jersey
- The States of Jersey have not set out minimum reporting requirements for entities in respect of sustainability. However, 23 out of the 38 annual reports reviewed for 2022 refer to climate change or sustainability issues. This compares to 21 out of 38 for 2021 (see Exhibit 16).
Exhibit 16: Annual reports referring to climate change/sustainability issues and relevant reporting frameworks
25 20 15 10 5 0
Climate Jersey Performance TCFD UN SDGs change/sustainability Framework
2022 2021
Source: Jersey Audit Office analysis of 2021 and 2022 annual reports
- Although this increase is modest, I also noted that the quality of the climate and sustainability reports was generally higher in 2022, with eight annual reports referring to the Jersey Performance Framework compared to just one in 2021 annual reports. Some entities noted that they were looking to develop and improve reporting on climate and sustainability in future years.
- In the absence of minimum sustainability reporting requirements, it is pleasing to see improvements by some entities on a voluntary basis. In my view, however, unless minimum sustainability reporting requirements are established by the States of Jersey there is a risk that entities may not implement improvements to reporting at an appropriate pace.
Annual reports and accounts reviewed
The reviews for each year encompassed a desk-based evaluation of the latest published annual reports and financial statements of the following entities available at the time of the fieldwork. For the 2022 annual reports, I reviewed annual reports available at 31 July 2023. The criteria used are set out in Appendix Two.
Years reviewed Documents
Entity
reviewed
2019 2020 2021 2022 Andium Homes Annual Report
Bureau des Iles
Not available in Anglo -
any year Normandes
Care Annual Report Commission
Channel Islands Not available in
Brussels Office any year
Charity Annual Report Commissioner
Charity Tribunal Annual Report Children's Performance For 2018
Commissioner Report to 2019
Complaints Not available in Panel any year
Criminal Injuries
Three year For 2016 Compensation
report to 2018 Board
Jersey Office of
Data Protection the Information Authority Commissioner
Annual Report
Annual report
Digital Jersey and financial
statements
Director of Civil the States Aviation
Assembly
Financial
Services Annual Report Commission
Financial
Services Annual Report Ombudsman
Gambling Annual Report Commission and Accounts
Government of
Jersey London Financial
Statements
Office
Independent
Prison Annual Report Monitoring
Board
Jersey Advisory
and Conciliation Annual Report Service
Jersey
Appointments Annual Report Commission
Jersey Bank Annual Report For year For year For year For year Depositors and Audited to 31 to 31 to 31 to 31 Compensation Financial January January January January Scheme Statements 2019 2021 2022 2023
Jersey Business Annual Report
and Accounts
Jersey
Competition Annual Report Regulatory and Accounts
Authority
Jersey
Consumer Annual Report For 2018
Council
Jersey Electricity Annual Report
and Accounts
Jersey
Employment
and Annual Report Discrimination
Tribunal
Jersey Finance Annual Report
Jersey Heritage Annual Report and the Archivist
Jersey Law Not available in Commission any year
Jersey Legal Annual Report
Information and Financial Board Statements
Jersey Overseas Annual Report For 2018 Aid Commission
Jersey Post
International Business Review For 2018 Limited
Jersey
Probation and Aanndn Straual Repotegic rt After-Care
Priorities
Service
Jersey
Resolution Annual Report Authority
Jersey Sport Annual Report For 2018 Jersey Teachers'
Superannuation Annual Report Fund
Annual Report
and
JT consolidated
financial
statements
For year
Jersey Water Aanndn Fualin Repoancialrt to 30
September
Statements
2019
Mental Health Not available in Tribunal any year
Multi-Agency
Public Annual Report
Protection
Arrangements
Office of the
Comptroller and Annual Report
and Accounts
Auditor General
Police
Complaints Annual Report Authority
Ports of Jersey Annual Report Prison Service Annual Report
Public
Employees' Annual Report Pension Fund
Public Lotteries Report
Safety Council Financial
Statements
States Assembly Annual Report
States
Employment Annual Report Board
States of Jersey Annual Report
and Accounts
Annual Report
States of Jersey and
Development Consolidated Company Financial
Statements
States of Jersey Annual Report For 2018
Police
Not required to Statistics Jersey produce an
Annual Report
Tenancy Not available in Deposit Scheme any year
Annual Report
Visit Jersey and financial
statements
Scoring methodology for 2022 annual reports
Throughout this report I have categorised annual reports as Good', Fair', Poor' or Very Poor'. The categorisation is based on the following boundaries:
• Good = 75% or more of the relevant score available
• Fair = 50% to 74% of the relevant score available
• Poor = 25% to 49% of the relevant score available; and
• Very poor = less than 25% of the relevant score available.
The scoring methodology for individual 2022 annual reports is set out in the following tables.
Overall Content
Criteria Mark Guidance notes
available
- The annual report and accounts Good practice annual reports typically include: set out three distinct sections.
• a performance report However, provided all three areas are covered and are easily identifiable,
• an accountability report; and alternative structures may be
• the financial statements. appropriate.
Where entities are not required to
2 to 3
publish audited financial statements, other relevant financial information should be provided (for example an income and expenditure statement).
Exceptionally, where the entity has no income or expenditure, this section should be marked out of two.
Total for overall content 2 to 3
Performance Report - minimum
Criteria Mark Guidance notes
available
- Performance reporting is fair,
1
balanced and understandable.
- The performance report tells the This should include both positive andfull story of the entity. negative aspects of how the entity
has performed across the year, so
1 that users can have confidence in any
judgements and so that it is clear that reporting is trustworthy and transparent.
- The annual report demonstrates This is typically achieved by the most that the Accountable Officer, senior executive officer signing and Chief Executive, or equivalent dating:
1
has taken ownership of the a distinct performance report; or reporting of performance.
• the annual report as a whole.
- The performance report A going concern statement is only contains: required where there are reasons for
• a statement of purpose going concern to be called into doubt. This means that for most
• a statement from the lead entities this section should be Minister, Chief Executive or marked out of seven.
equivalent setting out their
Exceptionally, where an entity has no perspective on how the entity
income or expenditure, a financial has performed
review may also not be required. In
• the key issues and risks that such cases this section should be could affect the entity in marked out of six.
delivering its objectives
• a performance analysis
showing performance 6 to 8 against priorities (and any
other organisational strategic
objectives and goals)
• information on environmental matters
• other non-financial information such as social responsibility, respect for human rights, anti-corruption and anti-bribery matters and diversity
• a financial review; and
available
• where relevant, an explanation of the adoption of the going concern basis.
Total for Performance Report
9 to 11 minimum
Performance Report – best practice
| Criteria | Mark available | Guidance notes | ||
6. |
| Strategy: • clarity around purpose, strategic objectives and key programmes/projects • balanced view of progress against objectives • details of plans to implement priorities; and • strategy clearly linked to performance measures and risks. |
| 4 |
|
7. |
| Risks: • clear articulation of the entity's risk management process • risks reflect the external environment and implications for the entity • clear links between risks, strategic objectives and the annual report narrative • quantified risks and realistic planned and implemented mitigations; and • discussion about how the dynamic of the risk profile has changed over time, including developments in relation to specific risks disclosed. |
| 5 |
|
Criteria Mark Guidance notes
available
- Operations: Discussion of the delivery model
• discussion of the entity's should describe how the entity
delivers its activities (for example in - delivery model
house teams, contractors). It may also
• narrative around how include discussion of:
business operations support
wider Government (or other) the reason for using the entity's
delivery model
objectives
• for significant contracted-out how it achieves value for money; and
services, discussion of how 2 to 4
these contracts are awarded different delivery models.
and how the entity manages Where there are no significant
the ongoing contract; and contracted out services, the mark
• consideration of capital available for this section should be investment and how it reduced by one.
achieves value for money. Where there is no capital investment
(or any capital investment is not material) the mark awarded for this section should be reduced by one.
- Measures of success:
• quantified key performance indicators (KPIs) aligned to strategic objectives
• balanced assessment of 3 goals achieved and
performance against targets;
and
• graphics used to illustrate performance.
- Financial performance: Exceptionally, where the entity has no
• an understandable and fair income or expenditure, this section is reflection of financial not marked.
performance which is
consistent with the
underlying financial 0 to 2
statements; and
• discussion of actual performance against expected/budgeted performance.
Criteria Mark Guidance notes
available
- External factors: External drivers might include the
• an annual report that cost of living crisis, the UK's EU exit and the continuing impact of the
considers the external
COVID-19 pandemic.
drivers that influence and
impact on current objectives; 2
and
• innovative reporting on sustainability and climate change.
Total for Performance Report -
16 to 20 best practice
Accountability Report – minimum
Criteria Mark Guidance notes
available
- The annual report demonstrates This is typically achieved by the most that the Accountable Officer, senior executive officer signing and Chief Executive, or equivalent dating:
1
has taken ownership of a distinct accountability report; or accountability reporting.
• the annual report as a whole.
- The accountability report Good practice annual reports includes information on: typically set out this information in
• the governance structure two distinct reports on:
• the board's (or equivalent) corporate governance; and commitment to high remuneration/staffing
standards of governance However, provided all issues are how the board (or 4 to 5 covered and are easily identifiable, equivalent) works effectively alternative structures may be
to govern the entity appropriate.
• remuneration of board Where an entity has no staff or members (or equivalent) and equivalent, this section should be other senior staff; and marked out of four.
• staffing or equivalent (such as a contracted-out workforce).
Total for Accountability Report
5 to 6
- minimum
Accountability Report – best practice
| Criteria | Mark available | Guidance notes | ||
14. |
| Information provided on corporate governance includes a directors' report that sets out: • the names of the Chair and Chief Executive (or equivalent) • the composition of the management board (or equivalent). • details of entity directorships and other significant interests held by members of the management board (or equivalent) which may conflict with their management responsibilities; and • information on personal data related incidents where these have been formally reported to the Jersey Office of the Information Commissioner or confirmation that no incidents have been reported. |
| 4 | This information is typically provided as a directors' report (or equivalent). Alternative structures may be appropriate. The management board (or equivalent) may include advisory and/or non-executive members. It comprises those who have had authority or responsibility for directing or controlling the major activities of the entity during the year. This means those who influence the decisions of the entity as a whole, rather than the decisions of individual directorates. Entities may prefer to provide a link to an online register of interests instead of detailed disclosures in the annual report. |
15. |
| Information provided on corporate governance includes a statement of responsibilities of the Accountable Officer (or equivalent) comprising: • an explanation of responsibilities of the Accountable Officer • a statement to confirm that, as far as they are aware, there is no relevant audit information of which the entity's auditors are unaware, and that the Accountable Officer has taken all the steps that they ought to have taken |
| 1 to 3 | For entities that are not required to publish audited financial statements, the second and third bullet points are not required, and this section should be scored out of one. |
| Criteria | Mark available | Guidance notes | ||
|
| to make themselves aware of any relevant audit information and to establish that the entity's auditors are aware of that information; and a statement from the Accountable Officer to confirm that the annual report and accounts document as a whole is fair, balanced and understandable and that they take personal responsibility for the annual report and accounts document and the judgements required for determining that it is fair, balanced and understandable. |
|
|
|
16. |
| Information on corporate governance includes statements on: • the governance framework of the entity, including information about the board's (or equivalent) committee structure, its attendance records and the coverage of its work • the board's (or equivalent) performance, including its assessment of its own effectiveness • highlights of board committee (or equivalent) reports, notably by the audit and nomination committees; and • an account of corporate governance including (where relevant) an assessment of compliance with any adopted corporate governance codes. |
| 4 | Not all entities are required to comply with a specific corporate governance code. Where an entity is required, or choses, to comply with a specific corporate governance code, the account of corporate governance should include the board's (or equivalent) assessment of its compliance with explanations of any departures. |
| Criteria | Mark available | Guidance notes | ||
17. |
| Information on the remuneration of board members (or equivalent) includes: • the policy on the remuneration of directors (or equivalent) for the current and future years • components and the overall single total remuneration figure for each director (or equivalent); and • fair pay data such as:
|
| 2 to 3 | Components of the total remuneration figure may include: • salary and allowances • performance pay or bonuses payable • non-cash benefits • accrued pension benefits; and • compensation for loss of office and other severance payments. This information may be set out in any part of the annual report. For example, some entities may wish to rely on remuneration disclosures included in the financial statements. Where no staff are employed, the fair pay data is not required and this section should be marked out of two. |
18. |
| The staff report includes the following information: • number of senior staff (or equivalent) by band • staff numbers and costs • staff composition including (where available) a gender analysis of directors, senior officers and employees • sickness absence data • staff policies applied during the year, for example in respect of disabled persons, diversity and equal opportunities • other employee matters such as employee consultation and/or participation, health |
| 0 to 7 | Entities that do not employ any staff should not complete this section and complete section 19 instead. Entities that do employ staff will need to define senior staff and the pay reporting bands. For example, English local authorities report in bands of £5,000 the number of: • staff earning more than £50,000 a year who are statutory officers or report directly to the head of the paid service; and • all staff earning more than £150,000 a year. Entities with small workforces will need to be sensitive to disclosing personal information, particularly for non-senior staff. Where entities have such concerns, they may instead |
Criteria Mark Guidance notes
available
and safety at work, trade prefer to provide a commentary on union relationships and key issues such as gender balance. human capital management
(for example career
management and
employability, pay policy);
and
• exit packages – summary data on the use of exit packages agreed in year.
19. For entities that do not employ This section applies only to entities any staff the annual report sets that do not employ any staff. out clearly:
• that it does not employ any staff; and
• how the entity carries out its
activities (for example all 0 to 2 activities delivered by board
members, staff provided by
the Government of Jersey,
appointment of
contractors/affiliates, use of
volunteers)
Total for Accountability Report
13 to 21
- best practice
Best Practice Principles
| Criteria |
| Mark | Guidance notes | ||
|
|
| available |
| ||
20. |
| Accountability: |
|
|
|
|
|
| telling the story of the entity in a fair and balanced way |
|
|
|
|
|
| compliance with the relevant reporting requirements; and |
|
| 3 |
|
|
| clear action points to take forward. |
|
|
|
|
21. |
| Transparency: |
|
|
|
|
|
| frank and honest analysis |
|
|
|
|
|
| consideration of the challenges the entity is facing |
|
| 4 |
|
|
| appropriate use of data; and |
|
|
|
|
|
| quantification of risks and performance measures. |
|
|
|
|
22. |
| Accessibility: |
|
|
|
|
|
| highlights key financial statement trends within the |
|
|
|
|
|
| narrative |
|
|
|
|
|
| concise summaries of key points; and |
|
| 3 |
|
|
| consideration of how the entity engages with key |
|
|
|
|
|
| stakeholders and meets their |
|
|
|
|
|
| needs. |
|
|
|
|
23. |
| Understandable: |
|
|
|
|
|
| plain English to explain difficult concepts |
|
|
|
|
|
| infographics and diagrams to communicate important |
|
| 3 |
|
|
| messages; and |
|
|
|
|
|
| clearly integrated report structure to help users |
|
|
|
|
|
| navigate it effectively. |
|
|
|
|
|
| Total for Best Practice Principles |
|
| 13 |
|
Summary of Recommendations
I have made two recommendations for the States of Jersey in this report:
R1 Set out a project plan and timetable for the preparation and publication of full
consolidated States of Jersey Group accounts.
R2 Set out minimum requirements for more granular financial reporting in
Government department annual reports.
In 2022, I consolidated my recommendations from all of my previous reports on annual reporting into five recommendations. These recommendations remain relevant, and their current status is set out below.
Recommendation Current status Evaluation
R1 Finalise and set out Recommendation accepted with Progress is being minimum requirements for target implementation date of 31 made.
annual reports and accounts March 2024.
for States established and The States are currently in the
States controlled entities. In process of determining which
doing so, consider: entities meet the definition of
• setting out different States established and States
requirements depending controlled.
on the nature and size of Further work is then required to:
entities
• identify the Accountable
• specifying minimum Officer holding lead
requirements for responsibility
reporting on
performance, include States established and
accountability and States controlled entities in the
finances Accountable Officer
appointment letters issued by
• requiring specific the Principal Accounting
disclosures of Officer; and
remuneration of directors
and staff introduce requirements into
the Public Finances Manual for
• for entities required to Accountable Officers to take
publish financial steps to ensure that the States
statements: controlled and States
- specifying the established entities for which
accounting they are responsible meet
framework; and minimum annual reporting
- specifying the degree standards.
of independent
assurance that should
be provided over the Officers have reported that this financial statements; further work is on track.
and
• for all entities, setting out the requirements for making the annual report and accounts public.
R2 Introduce a requirement Recommendation accepted with a Progress is being for Statistics Jersey to target date of December 2024. made.
produce an annual report. Legislation is required to effect this
change and is planned as part of
wider changes designed to
preserve the independence of
Statistics Jersey.
Reported by officers as being on track.
R3 Set out a public ambition The States of Jersey annual Good progress is and timetable for the sustainability report is currently being made. production of a States of published as an appendix to the Further work Jersey annual sustainability States of Jersey Annual Report and required to realise report. In doing so, Accounts. the States'
consider: The 2022 sustainability report was ambitions over
• the Jersey Performance significantly improved from the next two Framework and the previous years and sets out the years.
Taskforce on Climate- States of Jersey's ambition for
Related Financial further improvements for
Disclosures (TCFD) sustainability reporting over the
recommended next two years'.
disclosures
• whether the sustainability report should form part of the States of Jersey Annual Report and Accounts or be a separate report
• publishing targets alongside actual performance and comparative data with other jurisdictions where this is available; and
• the degree of independent assurance that should be provided over the data contained within the sustainability report.
R4 Set out minimum Recommendation accepted with a Limited progress requirements for target date of December 2023. has been made. sustainability reporting by
States established and States Limitofficeerds. progress reported by
controlled entities. In doing
so, consider how to apply the
Jersey Performance
Framework and the TCFD
recommended disclosures.
For all entities:
R5 Continue to improve Year on year improvements across Good progress is annual reporting. In doing the entities reviewed being made.
so, consider: demonstrated as set out Implementation of
• any minimum throughout this report. recommendations requirements set out by R1 to R4 will the States of Jersey support further
• how to improve reporting improvements in 2023 annual
on performance,
reports and accountability (including
onwards. director and staff
remuneration) and
finances
• how to use an appropriate framework to improve sustainability reporting; and
• other good practice identified in this report and my Good Practice Guide.
49 | Annual Reporting