Equality Duty Action Plan

1. Introduction

The Independent Living Fund Scotland (ILF Scotland) believes that no-one should be denied opportunities because of their race or ethnicity, a disability, their gender, or sexual orientation, their marital or civil partnership status, their age or religion, or due to any of the protected characteristics detailed in the Equality Act.

ILF Scotland will treat Recipients, applicants and ILF Scotland staff equally and fairly. For staff, this commitment also extends to maternity status, working pattern, employment status, caring responsibility, and trade union membership.

ILF Scotland must comply with the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 and the specific duties designed to help Scottish public authorities meet the general duty. Regulation 4 of the specific equality duties requires that we base our Equality Outcomes on evidence, and involvement of equality groups.

The Public Sector Equality Duty regulates performance against equalities duties. From April 2020, ILF Scotland is required to report on the areas outlined below, every two years, apart from the Statement on Equal Pay, which is every four years. We also have a duty to publish diversity information about our board members. This report meets our general and specific duties under the Equality Act 2010 and outlines:

1.1 Background

The public sector equality duty came into force on 05 April 2011. The purpose of the duty is to ensure that public authorities consider how they positively contribute to a more equal society. It requires authorities to consider equality in all their functions, including decision-making, design, and delivery of services.

From 1 October 2012, the scope of the Act was extended to ban age discrimination, though this does not presently cover people under the age of 18.

The Equality Duty Action Plan sets out how ILF Scotland will meet its statutory equality duties, promote equality of opportunity, eliminate discrimination and foster good relations. It also provides a framework for monitoring progress and ensuring equality considerations are embedded in service delivery and employment practices.

1.2 The General Equality Duty

Under the Equality Act 2010, public authorities are required to have due regard to the need to:

  1. Eliminate unlawful discrimination, harassment and victimisation and other prohibited conduct.
  2. Advance equality of opportunity between people who share a relevant protected characteristic and those who do not.
  3. Foster good relations between people who share a protected characteristic and those who do not.

This duty is often referred to as the three needs. To comply with the duty, a public authority must have due regard to all three of these needs.

The Act explains that to meet the second need (advancing equality of opportunity), a public authority must consider the need to:

The Act also sets out that:

1.3 Who should be aware of the General Duty in ILF Scotland?

Board Members

Set strategic direction, review performance, and ensure good governance of the organisation. The Depute Director, Scottish Government, Health & Social Care, appraises the Chair of the Board against a Diversity Objective.

Senior Managers

Oversee the design, delivery, quality, and effectiveness of the organisation’s functions.

Equality and Diversity Staff

Lead, promote and support equality, diversity and inclusion across the organisation, building awareness, capability and compliance with the Public Sector Equality Duty.

Communications Staff

Help ensure relevant equality information is available and accessible.

Frontline Staff

Need to be aware of how they can help to meet the needs of people with special characteristics.

Procurement

Need to be aware of how to build equality considerations into the organisation’s supply chain. In ILF Scotland, anyone tendering a contract should be aware of the Equalities Obligation and what we expect of organisations that we contract with.

Line Managers

Line managers are responsible for applying equality, diversity and inclusion principles in day-to-day management practice and ensuring fair, consistent and inclusive treatment of all employees.

2. Key ILF Scotland Documents

The primary function of ILF Scotland is to operate discretionary funds providing financial awards to over 4,000 disabled people in Scotland and Northern Ireland to help them live independently. ILF Scotland adheres to a suite of key policy documents to support our Recipients, applicants, and staff. The policy suite is updated on an ongoing basis to support the Scottish Government’s strategic priorities.

The key references are:

2.1 ILF Scotland Policies

ILF Scotland recognises the need to consider whether and how the outcome and delivery of any proposed new or amended policy might impact on people, specifically, what relevance the policy might have to people with protected characteristics.

The policy development lead will carry out a screening exercise to help determine if any proposed or amended policy / practice will directly or indirectly affect people. They should then complete either an Equality Impact Assessment (EQIA) or the No EQIA required declaration.

The policy lead must carry out the EQIA early, and as an embedded part of the policy development process, so that the assessment can shape, inform, and influence the policy proposals, and they should continue to revisit this assessment throughout the lifecycle of the policy.

2.2 ILF Scotland Strategy 2025 to 2028

The vision set out in the ILF Scotland Strategic Plan 2025 to 2028 identifies the integral part played by ILF Scotland in supporting independent living for disabled people across Scotland and Northern Ireland, and how ILF Scotland can support individuals through its funding role.

2.3 ILF Scotland Business Plan 2026 to 2028

As stated in the Business Plan 2026 to 2028, ILF Scotland will improve its evidence base by gathering information from Recipients, applicants, and staff through the various use of equality monitoring forms, and where applicable, will use surveys, to strengthen its understanding of the needs and requirements of the disabled people the organisation supports.

This improved data will be reflected in enhanced information displayed in the Annual Corporate Report and online. Stronger management information will enable ILF Scotland to consider how it can better meet the general equality duty, its specific duty under the Act, and improve its service delivery.

3. What We Do To Promote Equality

Customer Facing Actions (CFA)

CFA Reference: CFA01

Action
Engage opportunities to encourage diversity of our Board membership and create dialogue with under-represented groups (specifically disabled people).

General Equality Duty:
Advance Equality of Opportunity

Owner:
Chair of the Board

Review:
Ongoing through specific engagement opportunities and in partnership with the Public Appointments Team during periods of Board recruitment.

CFA Reference: CFA02

Action:
Ensure that all our staff follow SSSC and NISCC Codes of Practice. The Code is part of our Induction Pack for all staff. Refresher and updates are delivered as required.

General Equality Duty:
Eliminate Discrimination
Advance Equality of Opportunity
Foster Good Relations

Owner:
Director of Independent Living

Review:
Completed and ongoing.
Scottish Social Services Council Codes of Practice
NISCC Standards for Conduct and Practice for Social Care Practitioners

CFA Reference: CFA03

Action:
Continue to amend our website to create clear visual communication, making appropriate use of audio / video and social media platforms, to increase accessibility and reduce barriers for disabled people.

Follow good practice guidance on design for our website and all publications and provide documents in alternative languages and formats on request.

General Equality Duty:
Eliminate Discrimination
Foster Good Relations

Owner:
Director of Policy

Review:
New improved website with greater emphasis on accessibility, live June 2022.
Achieved new UK Government Standards on Accessibility.
Diversified and extended use of social media platforms.
Improvements made to Fund literature in the Transition Fund application process.
Accessibility internal working group established to review key material.
Focus on making all key public documents accessible.

CFA Reference: CFA04

Action:
EQIA published for all new and revised external policies, the framework of this is determined by Scottish Government Ministers.
EQIAs to be completed for internal policies.
EQIAs to be completed for other key business decisions.
Repeat training exercise for Managers on completing EQIAs.

General Equality Duty:

Owner:
Director of Policy
Director of HR & Business Services
All Heads of Departments
HR & Policy

Review:
Completed
Completed
Ongoing
Completed - EQIA Training for Management Team – May 2025. Refresher training will take place during Q3 2026 to 2027.

CFA Reference: CFA05

Action:
Improvements to application forms and guidance, all designed to be clear and accessible. Including access to Gaelic Language forms.

General Equality Duty:
Advance Equality of Opportunity
Foster Good Relations

Owner:
Director of Policy

Review:
In progress and ongoing – Gaelic Language forms not yet developed. No legislative requirement as yet.

CFA Reference: CFA06

Action:
All roadshows and events undertaken in accessible venues, with as wide a geographic spread as possible, bi-lingual advertising in Gaelic-speaking communities.

General Equality Duty:
Advance Equality of Opportunity
Foster Good Relations

Owner:
Director of Policy

Review:
Ensured all engagement events for the Independent Living Fund re-opening were held in accessible venues and that all related communication was produced in Plain Language and Easy Read. No events were held in Gaelic Language speaking localities.

CFA Reference: CFA07

Action:
Equality check carried out on Board papers and all publications / key documents to ensure written communication is gender neutral.

General Equality Duty:
Eliminate Discrimination

Owner:
All Heads of Department

Review:
Ongoing

CFA Reference: CFA08

Action:
Equality clauses added to all contracts as part of tendering / procurement process and submissions measured against equality criteria.

General Equality Duty:
Advance Equality of Opportunity
Eliminate Discrimination

Owner:
Head of Finance

Review:
Ongoing

CFA Reference: CFA09

Action:
Denholm House is an accessible building with an induction loop. ILF Scotland promotes such provision through its service level agreement with the Scottish Government.

General Equality Duty:
Foster Good Relations

Owner:
Chief Operating Officer

CFA Reference: CFA10

Action:
Through our Corporate Parenting Plan, we will further develop our communications strategy to target care experienced young people and those that support them to ensure they are aware of ILF Scotland Transition and Re-opened Funds.
We will ensure ILF Scotland staff and Board Members are aware of the principles of Corporate Parenting through training courses and induction programmes.

General Equality Duty
Advance Equality of Opportunity

Owner:
Director of Policy

Review:
Communications Strategy updated.
Completed - Training delivery September / October 2024

CFA Reference: CFA11

Action:
Facilitate meetings of the Co-Production Working Group regularly.
Report regularly on learning from receiving applications to the re-opened fund and work together with the group and others as required to further develop policies around the key issues raised by disabled people and others at the re-opening engagement events.
Arrange further co-production opportunities with our Recipients and others as part of our strategic planning consultations.

General Equality Duty:
Advance Equality of Opportunity
Foster Good Relations

Owner:
CEO
Director of Policy
SLT

Review:
Ongoing – from 2026 to 2027 the group meets on an as required basis.
Complete for policy realignment, carers component. Ongoing, DPO pilot and Threshold Sum.
Series of engagement events delivered for 2025 to 2028 strategy and Advisory Groups input to Business Plan

Staff Actions (SA)

SA Ref: SA01

Action:
Offer employment opportunities for volunteer / student placements for young people with a disability that places them at a significant disadvantage in the job market.
Offer social work student placements to promote the Social Model of Disability within statutory social work.

General Equality Duty:
Advance equality of opportunity

Owner:
CEO
Director of Independent Living

Review:
Ongoing

SA Ref: SA02

Action:
Continue induction training for Board Directors and staff on Diversity and Equality.

General Equality Duty:
Eliminate discrimination

Owner:
Director of Business Services

Review:
Ongoing - DET Training for all staff and Board Directors during induction.

SA Ref: SA03

Action:
Gaelic Language Plan, with responsibility held at Senior Management level, helping to raise awareness and culture of relevance to ILF Scotland’s staff and Recipients.

General Equality Duty:
Advance equality of opportunity
Foster good relations

Owner:
Director of Policy

Review:
Awareness training delivered across the organisation – Feb 2022. On hold since then due to other completing priorities and no requirement currently for legislative compliance. Will pick up in next Strategic Plan.

SA Ref: SA04

Action:
Information on Equality and Diversity is included in the Staff Handbook / HR Policies and forms part of the Induction for new staff.

General Equality Duty:
Advance equality of opportunity
Eliminate discrimination
Foster good relations

Owner:
Director of Business Services

Review:
Complete and ongoing for new staff. Refresher sessions for current staff.
New Equality and Diversity Policy published June 2025.

SA Ref: SA05

Action:
ILF Scotland continues to promote best practice in making sure the office space is suitable for people with differing needs, for instance with an induction loop and disabled access to the building.

General Equality Duty:
Foster good relations
Eliminate discrimination

Owner:
Finance and Business Services

Review:
MOTO and Shared Service Agreement with the Scottish Government.

SA Ref: SA06

Action:
Adhere to ILF Scotland HR policies on equality and diversity in the workplace, including work-life balance, development, promotion, work opportunities and recruitment.

General Equality Duty:
Advance equality of opportunity

Owner:
Director of Business Services

Review:
Completed for all staff and on-going refreshers.

SA Ref: SA07

Action:
Regular conversations between staff and managers include wellbeing, development and inclusion, ensuring concerns are identified and addressed at an early stage.

General Equality Duty:
Foster good relations
Eliminate discrimination

Owner:
Director of Business Services

Review:
Ongoing regularly through 1-2-1s and training.

SA Ref: SA08

Action:
Continue to increase awareness of mental health issues as an equality issue.

General Equality Duty:
Advance equality of opportunity
Eliminate discrimination
Foster good relations

Owner:
Director of Business Services

Review:
6 x Mental Health First Aiders.
Mental Health and Personal Resilience training offered regularly to all staff and Board Directors.

SA Ref: SA09

Action:
Continue to increase equality for disabled people living in poverty

General Equality Duty:
Socio-economic duty

Owner:
Director of Independent Living
Director of Policy

Review:
Ongoing: Provide regular welfare rights and income maximisation training to all operational staff.
Provide an in-house welfare rights service for staff to respond to ILF Recipients.
For 2027: Target areas of highest SIMDs for the Transition Fund.
Poverty included in EQIAs.

SA Ref: SA10

Action:
ILF Scotland adheres to the SG (Scottish Government) Fairness at Work policy, which covers equality and diversity.

General Equality Duty:
Foster good relations
Eliminate discrimination

Owner:
Director of Business Services

Review:
Work with recognised union - PCS to ensure ILF Scotland works to the Fairness at Work principles.

SA Ref: SA11

Action:
Raise awareness of neurodiversity and provide staff training to cover this area specifically as part of our equality and diversity training. Provide more detailed training to front line staff working in both Funds so that they can provide better informed customer service to those applications and Recipients who are neurodivergent.

General Equality Duty:
Advance equality of opportunity

Owner:
Director of Business Services

Review:
Awareness workshops delivered Q3 2025 to 2026 with further workshops planned for Q3 2026 to 2027. Established the NeuroMinds Working Group to promote understanding of neurodiversity, gather staff insights, and support the development of a more inclusive workplace for neurodivergent colleagues.

4. ILF Scotland HR Policies on Equality, Diversity & Inclusion

ILF Scotland has designed its induction procedures to ensure diversity issues are included and staff are aware of a range of advice, guidance and support provided by ILF Scotland policies and HR team.

4.1 Equal Opportunities Policy Statement

ILF Scotland will treat all staff equally irrespective of their sex, marital / civil partnership status, maternity status, age, race, ethnic origin, sexual orientation, disability, religion, or belief, working pattern, employment status, gender identity, caring responsibility, or trade union membership.

4.2 Diversity Policy Statement

ILF Scotland is committed to advancing equality, fostering good relations and creating an inclusive workplace where diversity is valued and everyone can thrive.

We will ensure that all employees and job applicants are treated fairly and with respect, regardless of their background, identity or circumstances. We are committed to providing equitable access to employment, learning, development and progression opportunities.

We recognise that a diverse workforce brings a wider range of skills, experiences and perspectives that strengthen our organisation and enhance the support we provide. We will actively promote an inclusive culture where differences are recognised as a source of strength, and where every individual feels valued, listened to and empowered to contribute.

We will monitor our progress, challenge discrimination and remove barriers wherever possible, supporting our commitment to equality, diversity and inclusion across all areas of our work.

4.3 Resources Available on Diversity and Equality

5. Forward Planning

Active consideration of equality will help ILF Scotland to identify ways in which to improve evidence gathering and engagement, to help improve the quality of services it provides, making them more responsive to customer and staff needs, leading to better outcomes.

Senior Managers and Board Directors have a vital role in demonstrating visible leadership and accountability for equality, diversity and inclusion. Through ongoing engagement, training and performance monitoring, ILF Scotland will continue to embed equality considerations across all areas of its work.

5.1 Annex A: Protected Characteristics

Protected Characteristics

* The socio-economic duty is contained in Section 1 of the Equality Act 2010 although it has never been enacted. The duty would require public authorities to actively consider the way in which their decisions increase or decrease the inequalities that result from socio-economic disadvantage. ILF Scotland is committed to supporting disabled people living in poverty.

6. Equality, Diversity & Inclusion Plan – Action Plan (AP)

AP Ref: AP01

Action:
Staff satisfaction survey – use to provide data on bullying and harassment, wellbeing, and opportunities. Compare data in-year. Use staff feedback to identify opportunities to improve equality, diversity, inclusion and employee wellbeing, and monitor progress over time.

General Equality Duty:
Advance equality of opportunity
Eliminate discrimination
Foster good relations

Owner:
Director of Business Services

Update:
Working group formed annually to consider survey and improve offering

Review:
2025 to 2026 Staff Survey completed.

AP Ref: AP02

Action:
The TF online application process reduces access barriers to Recipients as they do not need to phone or write to us to access information and do not need to complete a written application form.

General Equality Duty:
Foster good relations

Owner:
Director of Policy

Update:
Online application process improvements implemented 2020 to 2021.

Review:
Keep opportunities for further improvements under review.
All TF policies reviews for accessibility and fit for purpose.
TF Evaluation may highlight opportunities for further improvement.
Ongoing

AP Ref: AP03

Action:
Equality, Diversity & Inclusion given high profile in induction training for Board Directors

General Equality Duty:
Advance equality of opportunity
Foster good relations

Owner:
Director of Business Services

Update:
New Board Directors 2023 onwards

Review:
New Board Directors attend Disability Equality Training. Board Directors attend Neurodiversity workshop sessions 2024 to 2026.

AP Ref: AP04

Action:
Increase awareness of cultural importance of Gaelic and promote learning by providing training and BnG presentation to Board.

General Equality Duty:
Foster good relations

Owner:
Director of Policy / Director of Business Services

Update:
Progress started on a voluntary basis at present well in advance of requirement to produce Plan in full.

Review:
On hold – not yet a legislative requirement for ILF Scotland.

AP Ref: AP05

Action:
Ensure all venues for roadshows are accessible and bi-lingual advertising in Gaelic-speaking areas.

General Equality Duty:
Eliminate discrimination
Foster good relations

Owner:
Director of Policy

Update:
No public events held in Gaelic-speaking areas.

Review:
Can be accommodated if required.

AP Ref: AP06

Action:
Actions to promote increased awareness of Mental Health in the Workplace

General Equality Duty:
Advance equality of opportunity
Eliminate discrimination
Foster good relations

Owner:
Director of Business Services

Update:
6 x Mental Health First Aiders trained and in post.

Review:
Continue Mental Health & Resilience workshops and raising awareness annually. (ongoing – next Q3 2026 to 2027).

UNCRC Report 2026 to 2029

Commitment Statement

We are pleased to introduce our first UNCRC Report and action plan, which sets out the actions we will take during the 2026 to 2029 reporting period.

This document provides information about ILF Scotland and the work we do. It focuses on how we support, engage with and listen to young people. It sets out our commitment to the UNCRC (Incorporation) (Scotland) Act 2024, the work that we have already done to promote children’s rights prior to 2026 and what we are doing now.

We aim to review our progress and planning relating to the UNCRC regularly and will formally appraise our progress in achieving our objectives on an annual basis and publish this on our website.

Human rights and equality are at the heart of what we do as an organisation and they run through all our everyday activities, thoughts, behaviours and plans. Our core principle is that disabled people have the same rights, freedoms, and abilities to lead the fullest lives they can, free from discrimination and on an equal basis as others. We strive to continuously improve on our commitment to human rights and children’s rights across the organisation.

We developed this report using the national UNCRC Implementation Framework to guide our self-evaluation. We have also published a child friendly version of the report on our website that is appropriate to the age range and accessibility requirements of the Recipients of ILF Scotland.

Our Board members and our staff are committed to ensuring the policies we work to, the services we provide, the decisions we make and the way in which we communicate with young people are as appropriate as they possibly can be. We will review this on an ongoing basis and include  the young people we are involved with in this process.

Anne Marie Monaghan
ILF Scotland Chair of Board

Peter Scott OBE
ILF Scotland CEO

Introduction to ILF Scotland

ILF Scotland is a Non-Departmental Public Body (NDPB), governed by a Board of Directors appointed by, and accountable to, Scottish Ministers. We provide discretionary funding to disabled people in Scotland and Northern Ireland to help them live independently with choice, control and dignity in their own homes and communities.

Our Strategy 2025 to 2028: Realising Ambition - Re-Opening and Beyond is focused on enabling more disabled people to access our funds, supporting cultural change and capability across the sector, and delivering a high-quality, inclusive and sustainable service. ILF Scotland is aligned with Article 19 of the UN Convention on the Rights of Persons with Disabilities and operates in line with the PANEL principles of Participation, Accountability, Non-Discrimination, Empowerment and Legality. We also seek to embed the principles of Co-operation, Dignity, Informed Choice, Involvement and Participation in the delivery of our services.

ILF Scotland is also a Corporate Parent. You can find more information on our website. Corporate Parenting Plan - 2024 to 2027.

UNCRC - Children's Rights

ILF Scotland became a listed authority under the UNCRC (Incorporation) (Scotland) Act 2024 in June 2024. We have been working with the Scottish Government and other colleagues since then to understand our commitments under the Act and prepare for the development of our first active plan from 2026 to 2029.

ILF Scotland must consider how its policies, decisions and services affect children and young people's rights. This includes gathering evidence on impact, involving children and young people in a meaningful and inclusive way, publishing a Children's Rights Report and a child-friendly version of that report, and ensuring that Board members, senior leaders and staff understand and fulfil their responsibilities in relation to children's rights.

For ILF Scotland, this means considering the rights and experiences of disabled children and young people wherever they may be affected by our funding, policies, services, communications and decision-making, and reporting on the actions we have taken and plan to take to advance children's rights.

UNCRC

The United Nations Convention on the Rights of the Child (UNCRC) is an international human rights treaty that sets out the rights of all children and young people and explains how governments and adults should work together to ensure children can enjoy those rights.

The Convention, signed by 196 countries, is the most widely ratified international human rights treaty in history. It contains 54 articles that cover all aspects of a child’s life and set out their civil, political, economic, social and cultural rights. The convention is universal – these rights apply to every child, and the convention entitles every child to claim them. It also explains how adults and governments must work together to make sure all children can enjoy all their rights.

The UNCRC (Incorporation) (Scotland) Bill was passed unanimously by the Scottish Parliament in December 2023 and came into effect on 16 July 2024. The Scottish Government affirmed that the UNCRC is at the heart of the Scottish Government’s commitment to ensuring that all children and young people have the best possible start in life, regardless of their circumstances.

Under the UNCRC, a child means “every human being below the age of 18”. A child has all the rights in the UNCRC until they are 18 years old.

The UNCRC Act followed over a decade of legislation and policy that protects and promotes children’s rights, including the Human Rights Act 1998, Getting It Right for Every Child (GIRFEC), the Children and Young People (Scotland) Act 2014, and the Children (Scotland) Act 2020. Children’s rights, within the broader context of human rights, are also embedded in Scotland’s National Performance Framework (NPF).

ILF Scotland’s Duties under UNCRC

As a listed authority under section 18 of Part 3 of the Act, ILF Scotland must report on actions we have taken and intend to take for the purpose of ensuring compliance with the UNCRC requirements under section 6(1) of the Act.

We must also report on actions we take and intend to take to secure better or further effect of the rights of children – referred to as Children’s Right’s Reports.

We have used a Children’s Rights Based approach to develop our implementation plan. This approach, developed by the Children’s Commissioner for Wales, provides a practical framework for working with children, grounded in the UNCRC. It ensures that children’s human rights are at the core of every aspect of decision making, policy and practice. It breaks this down into five key areas:

Each of the rights enshrined within the Convention is interlinked and no right is more important than another. Notwithstanding this, those UNCRC requirements most relevant to our work and where we can make the most impact include:

Article 2:   Non-Discrimination

Article 3:   Best Interests of the Child

Article 23: Children with Disabilities

ILF Scotland and Young People

Transition Fund

The Transition Fund was opened in December 2017 to provide one-off grants to young disabled people in Scotland aged 16 to 21 to help them increase their independence and participate in their communities. The upper age limit was increased to 25 in November 2019.

The primary aims of the Fund are to help young people:

Since the Transition Fund opened, we have provided grants of over £29 million to over 14,500 young disabled people. Of these Recipients, 6,425 were aged 18 and under.

Find out more about the Transition Fund on our website.

Independent Living Fund

The Independent Living Fund re-opened in April 2024 to new applications in Scotland. This Fund enables disabled people in Scotland with the most complex needs to access the support they need and deserve. Awards are paid on an ongoing, long-term basis.

Since re-opening, we have received over 1,500 applications and provided funding of around £16 million enabling many more disabled people to live independent lives within their chosen communities.

The re-opened Fund is available to people aged 16 and over and since April 2024, we have received more than 50 applications on behalf of Recipients aged under 18.

Find out more about the Independent Living Fund on our website.

Career Ready

As well as our Fund Recipients, ILF Scotland has supported young people through the Career Ready Scotland intern programme. Over the past three years, a number of interns aged 16 to 17 from local high schools have spent 4 weeks immersed within ILF Scotland, working with their allocated mentors in a variety of departments to experience the workplace, before delivering a presentation of their experiences to ILF Scotland staff, Career Ready representatives, teachers and their family members.

As well as being a learning opportunity for the interns, ILF Scotland members of staff have found the experience to be valuable and have received positive and helpful feedback from the young people.

We are delighted that one of the previous interns is now a full-time employee at ILF Scotland as a Modern Apprentice, having been successful after applying for an externally advertised post.

“I did my Career Ready internship at ILF Scotland when I was still at school. A year later, when I saw a Modern Apprentice position advertised, I immediately applied and was delighted to get the job, they are a really supportive employer and I am looking forward to progressing my career here.”                                               Mark

ILF Scotland’s Work and Children’s Rights

ILF Scotland is committed to equality, as outlined in our Mainstreaming and Equality Outcomes Report - 2026 to 2028.

“Equality is at the heart of what we do as an organisation and runs through all our everyday activities, thoughts, behaviours and plans. We strive to continuously improve on our commitment to mainstreaming equality across the organisation.”

As well as embedding equality within our culture, ILF Scotland must comply with the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 and the specific duties designed to help Scottish public authorities meet the general duty. Regulation 4 of the specific equality duties requires that we base our Equality Outcomes on evidence and involvement of equality groups.

Our Board and staff group are diverse with regards to their own lived experience, and they are also well-informed about equality, diversity and inclusion more broadly. More specifically, we ensure that a programme of training and awareness is in place so that our staff have a high level of knowledge about the needs of young disabled people. Our employees are well qualified in health and social care and we regularly provide updated training.

Since July 2024, our work in this area has included:

How We Ensure Participation with Young People

Engagement and Young Ambassadors

ILF Scotland has a programme of engagement activity, with a focus on increasing awareness of the Transition Fund among priority groups. This helps in strengthening relationships with partner organisations, and providing direct support to young people, their families and professionals involved in supporting young people through transition from children’s to adult services.

In our engagement activity, we have tried to place particular focus on:

Through this engagement we have provided practical application support to increase access to funding.

Activity has included attendance at:

ILF Scotland has a group of young Transition Fund Recipients who are Young Ambassadors. These young Recipients aged 16 to 25 meet a few times each year to discuss common issues and provide feedback on their experiences with the Transition Fund.

The Young Ambassadors have previously discussed and provided feedback on publications and initiatives relevant to young people including:

The Young Ambassadors have had opportunities to attend events and engagement activities. This included a presentation by one of our Young Ambassadors at the ILF Scotland 10th Anniversary Celebration in June 2025, to an audience of over 100 guests, where they shared their experience of the Transition Fund and what it had enabled them to achieve.

As previously mentioned, ILF Scotland is a Corporate Parent and our plan can be found on our website. Corporate Parenting Plan - 2024 to 2027.

As part our Corporate Parenting role, ILF Scotland works collaboratively with partner agencies including the Centre for Excellence for Looked after Children in Scotland (CELCIS), the Office of the Children’s Commissioner for Scotland and Who Cares? Scotland.

A key area of our Corporate Parenting plan is to ensure that all ILF Scotland staff receive training in adult and child protection. All ILF Scotland staff are considered to have a safeguarding role with a duty to report any concerns of harm. We will continue to provide regular training on an ongoing basis.

What We’ve Done

Since July 2024, we have:

Action Plan for 2026 to 2029

Monitoring and Reporting

In addition to our action plan, we anticipate there will be additional areas identified through our ongoing improvement work and policy reviews that we will add to our UNCRC planning process.

We will monitor the progress of this plan and action points on a regular basis and report to our Senior Leadership Team. We will also provide updates to our Board and our Advisory and Ambassador Groups to provide members with assurance on our approach to meeting our UNCRC duties.

In addition, we will publish a report on progress on our website on an annual basis.

Complaints Handling Procedure

ILF Scotland is committed to providing high-quality customer services.

We value complaints and use information from them to help us improve our services

If something goes wrong or you are dissatisfied with our services, please tell us.  This leaflet describes our complaints procedure and how to make a complaint.  It also tells you about how we will handle your complaint and what you can expect from us.

What is a complaint?

We regard a complaint as any expression of dissatisfaction about our action or lack of action, or about the standard of service provided by us or on our behalf.

What can I complain about?

You can complain about things like:

Your complaint may involve more than one ILF Scotland service or be about someone working on our behalf.

What can’t I complain about?

There are some things we can’t deal with through our complaints handling procedure.  These include:

If other procedures or rights of appeal can help you resolve your concerns, we will give information and advice to help you.

Who can complain?

Anyone who receives, requests or is directly affected by our services can make a complaint to us. This includes the representative of someone who is dissatisfied with our service (for example, a relative, friend, advocate or adviser). If you are making a complaint on someone else’s behalf, you will normally need their written consent. Please also read the section on Getting help to make your complaint below.

Child Friendly Complaints

As outlined in Who can complain? above, anyone who receives, requests or is directly affected by our services can make a complaint.

On occasion this may refer to a young person who is aged under 18 and therefore defined as a child.

If ILF Scotland receives a complaint from a person aged under 18, or a person complaining on their behalf, we will ensure that we handle any such complaint affecting any child in a way that meets all of their rights under UNCRC (United Nations Convention on the Rights of the Child).

ILF will keep the best interests of the child as a top priority in all decisions and actions that affect them (UNCRC Article 3).

The SPSO has created guidance for Child Friendly Complaints that ILF Scotland will refer to when handling complaints from any individual under 18 years. Further information on this guidance can be found at:

Watch the Scottish Public Services Ombudsman’s Child Friendly Complaints Handling Principles in British Sign Language (BSL).

Or read more about Child Friendly Complaints on the Scottish Public Services Ombudsman’s Website

How do I complain?

You can complain in person at our offices, by phone, in writing or by email using the contact details below.

It is easier for us to address complaints if you make them quickly and directly to the service concerned. So please talk to a member of our staff at the service you are complaining about. Then they can try to resolve the issue.

When complaining, please tell us:

Our contact details

Our contact details are:

Email: complaints@ILF.scot

Phone: 0300 200 2022

Address: ILF Scotland, Ground Floor, Denholm House, Almondvale Business Park, Almondvale Way, Livingston, EH54 6GA

Website: www.ilf.scot

How long do I have to make a complaint?

Normally, you must make your complaint within six months of the event you want to complain about or finding out that you have a reason to complain.

In exceptional circumstances, we may be able to accept a complaint after the time limit.  If you feel that the time limit should not apply to your complaint, please tell us why.

What happens when I have complained?

We will always tell you who is dealing with your complaint. Our complaints procedure has two stages.

Stage one: Frontline response

We aim to respond to complaints quickly (where possible, when you first tell us about the issue). This could mean an on-the-spot apology and explanation if something has clearly gone wrong, or immediate action to resolve the problem.

We will give you our decision at stage one in five working days or less, unless there are exceptional circumstances.

If you are not satisfied with the response we give at this stage, we will tell you what you can do next. If you choose to, you can take your complaint to stage two. You must normally ask us to consider your complaint at stage two either:

In exceptional circumstances, we may be able to accept a stage two complaint after the time limit. If you feel that the time limit should not apply to your complaint, please tell us why.

Stage two: investigation

Stage two deals with two types of complaint: where the customer remains dissatisfied after stage one and those that clearly require investigation, and so are handled directly at this stage. If you do not wish your complaint to be handled at stage one, you can ask us to handle it at stage two instead.

When using stage two:

If our investigation will take longer than 20 working days, we will tell you.  We will tell you our revised time limits and keep you updated on progress.

What if I’m still dissatisfied?

After we have given you our final decision, if you are still dissatisfied with our decision or the way we dealt with your complaint, you can ask the Scottish Public Services Ombudsman (SPSO) / Northern Ireland Public Services Ombudsman (NIPSO) to look at it.

The SPSO / NIPSO are independent organisations that investigate complaints. You can ask the SPSO / NIPSO to look at your complaint if:

The SPSO / NIPSO will ask you to complete a complaint form and provide a copy of our final response to your complaint.  You can do this online at www.spso.org.uk/complain/form or https://www.nipso.org.uk/nipso/making-a-complaint/online-complaints-form/ or call them on the freephone numbers below.

The SPSO’s contact details are:

SPSO, Bridgeside House, 99 McDonald Road, Edinburgh, EH7 4NS (if you would like to visit in person, you must make an appointment first).

Their freepost address is: FREEPOST SPSO

Freephone: 0800 377 7330
Online contact www.spso.org.uk/contact-us
Website: www.spso.org.uk

The NIPSO’s contact details are:

Northern Ireland Public Services Ombudsman, Progressive House,
33 Wellington Place, Belfast. BT1 6HN

Their freepost address is: FREEPOST NIPSO

Freephone: 0800 34 34 24
Website: www.nipso.org.uk
Email: nipso@nipso.org.uk

Getting help to make your complaint

We understand that you may be unable or reluctant to make a complaint yourself. We accept complaints from the representative of a person who is dissatisfied with our service. We can take complaints from a friend, relative, or an advocate, if you have given them your consent to complain for you.

You may wish to get independent support or advocacy to help you progress your complaint. You can find out about advocates in your area by contacting the Scottish Independent Advocacy Alliance, tel: 0131 510 9410, website: www.siaa.org.uk.

You can find out about advisers in your area through Citizens Advice Scotland, website: www.cas.org.uk or check your phone book for your local citizens advice bureau.

We are committed to making our service easy to use for all members of the community. In line with our statutory equalities’ duties, we will always ensure that reasonable adjustments are made to help you access and use our services. If you have trouble putting your complaint in writing, or want this information in another language or format, such as large font, or Braille, please tell us in person, contact us on 0300 200 2022 or email us on enquiries@ilf.scot.

Quick guide to our complaints procedure

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Address: ILF Scotland, Denholm House, Almondvale Business Park, Almondvale Way, Livingston, EH54 6GA  Tel: 0300 200 2022 Email: enquiries@ilf.scot  Web: www.ilf.scot

ILF Scotland is a company limited by guarantee, registered in Scotland, Company Number: SC500075. Registered office: Denholm House, Almondvale Business Park, Almondvale Way, Livingston, EH54 6GA

Charter for Involvement - Progress against Action Plan 2025 to 2026

1. Background

The Charter for Involvement was developed by the National Involvement Network, supported by ARC Scotland. The Charter establishes how disabled people who use support services want to be involved and to have a say about the services they receive, the organisations that provide their services, and their wider communities.

2. Introduction

ILF Scotland signed up to the Charter for Involvement in 2018 and we worked with the Advisory Groups to tailor the Charter Statements so that they were meaningful to our recipients. We co-produced the Charter and Action Plan and published this in April 2021.

This report provides an update to the Board on the progress made during 2025 to 2026. This update was shared and agreed by the Advisory Group members and by our Senior Management Team at its meeting of 26 May 2026 and published on our website on that date.

3. Key Progress

Three joint Scotland and NI Advisory Group meetings were held during the last financial year to enable the Group to review progress to date and identify Charter priorities for ILF Scotland to action. These are highlighted below along with progress made during 2025 and 2026.

Raising the Profile of Independent Living

Group members stressed the importance of raising the profile of Independent Living to a wide range of Stakeholders.

Response: ILF Scotland celebrated its 10th birthday by holding events for our Recipients and their representatives and supporters in Scotland and Northern Ireland in June and July 2025. Attendees included our Advisory Group members, Recipients, carers, PAs, and partners from across government, public sector and third sector organisations. Speeches were delivered from advocates of disability and human rights, and people shared inspiring stories about how ILF Scotland helped them live with choice, dignity, and independence. Our website provides further information, including videos and photographs about the event: https://ilf.scot/news-post/celebrating-10-years-of-ilf-scotland/

Both events were a success and feedback from attendees demonstrated how impactful attendees felt the events were and provided helpful information on accessibility needs, the difference the funding makes in people’s lives, and suggestions for improvements at future events.

PA Recruitment and Retention – Support for Employers

Group members raised the significant difficulties people are experiencing in relation to the recruitment and retention of Personal Assistants (PAs) and asked for ILF Scotland to help promote the role.

Response: 13 November 2025, was celebrated as National PA Day across the UK to recognise PAs in social care who support independent living. Led by ILF Scotland, an inaugural PA week took place week commencing 24 November until 28 November 2025 to highlight the benefits of employing PAs and to highlight the need for PAs for disabled people.

Over the week, ILF Scotland launched our own dedicated content on a daily basis across our social media channels and our website, which included videos, blogs, news articles and graphics from Advisory Group members. We also created a dedicated page on our website for signposting information about employing PAs and we shared some other important resources from key partners / stakeholders, such as the PA Network.

The content was well received and we would like to dedicate the same week again this financial year, but with a lengthier lead in time. This will allow us more time to work with Group members on the content that they would like to see and for our colleagues in our Communications team to promote the content to a wider audience through additional media channels.

Support for Employers: We invited representatives from one of the insurance companies to deliver information sessions for Group members. This covered the support this particular company can provide to employers and the legal requirements of the employer role. The sessions were well attended and a future session has been agreed with an alternative insurance company commonly used by PA employers.

Managing ILF Scotland Awards

Members highlighted the need for further information, advice and guidance for Award Managers, particularly given the number of new Award Manager roles emerging as a result of the re-opening of ILF in Scotland. Members would like this to include, as a minimum, employer commitment, PA recruitment and retention, and independent advocacy.

Response: We have established an internal working group of Independent Living Assessors and Caseworkers to focus on Award Management. They have explored issues from their perspective as they are presented to them by existing and new Award Managers. They will report initial findings and these will be discussed with Advisory Group members with a view to incorporating their input and co-producing identified improvements. We plan to update our Employer Support Information Note and our Your Responsibilities Guide in 2025 to 2026 in consultation with Group members.

ILF Scotland Recipient Reviews

Group members highlighted the importance of continuously improving information, communication, and processes at all stages of reviews and that we continue to make sure that recipient choice is central to review discussions and outcomes.

Response: At least one colleague from our Independent Living Team, which includes all of our Assessors, attends meetings with the Advisory Groups to discuss Charter work and to ensure that they can participate in discussions with Group members and take suggestions on board in planning and conducting reviews and in relation to staff training.

Engagement and Involvement

Group members value the opportunity to influence policy and practice as it affects recipients and to co-produce key documents and initiatives.

Response: All ILF Scotland potential policy changes are discussed with the Group to obtain the views of the Group members as part of the policy development process. The Scotland Advisory Group met with the Minister for Social Care and Mental Wellbeing in January 2026 and the Northern Ireland Advisory Group met with the Minister of Health in February 2026, highlighting important wider policy issues. Group members participated in the co-production events to develop ILF Scotland’s Strategy: Re-Opening and Beyond. Members have been involved in the co-production of our new Feedback Strategy and Service Charter. During the year, the Chairpersons of both Advisory Groups attended ILF Scotland Board meetings and members of the Board also attended the Group’s meetings. Group members co-produced and delivered presentations at ILF Scotland’s 10th Birthday celebratory events in Scotland and Northern Ireland, mentioned above.

Written Communication

Group members stressed the importance of clear communication by ILF Scotland that is as accessible as possible.

Response: Members were consulted in the review and publication of external communications such as our website, newsletters, and letters to recipients, with a focus on both content and accessibility. Members were jointly involved in external consultations that ILF Scotland responded to in 2025 and 2026. ILF Scotland is focusing on the accessibility of its published documents and its correspondence and delivered accessibility training to all staff in 2025 to 2026. It is about to reinstate a working group to take this forward and will invite representation from the Groups.

Re-Opening of ILF in Scotland

The Scotland Advisory Group was highly instrumental in advocating, along with others, for the re-opening of ILF to new applicants in Scotland. The fund opened in April 2024 and since re-opening, has received applications from an additional 1,400 disabled people. Feedback from recipients so far has been very positive with in relation to the difference the funding has made to their lives and there has been strong praise for the overall process.

The Chairperson of the Scotland Advisory Group is a member of the ongoing Co-Production Working Group. This Group made recommendations to the Minister on the policy framework for the re-opened fund and have been engaging with senior ILF Scotland staff since to further inform the development of the policy framework relating to the re-opened fund.

4. Conclusion

We have made significant progress against the Charter Action Plan during 2025 to 2026. It is important that this improvement work is ongoing and we will continue to work with the Advisory Groups in 2025 to 2026 to make further progress towards achieving the Charter Standards.

The Charter provides a valuable opportunity to bring recipients, via the Advisory Groups, closer together and helps facilitate greater collaboration in the organisation’s strategy, policies and delivery of services. We are grateful to Group members for their valuable ongoing commitment to improving our services to disabled people in Scotland and Northern Ireland.

Mainstreaming and Equality Outcomes Report - 2026 to 2028

Foreword

We are pleased to introduce our fourth Mainstreaming and Equality Outcomes Report. This document highlights the progress we have made in delivering our 2024 to 2026 equality outcomes and sets out our equality outcomes for 2026 to 2028 and the actions we will take to achieve them.

We aim to review our progress and planning relating to equality regularly and, as a minimum, to conduct a formal appraisal of our activities including our progress in achieving our mainstreaming equality objectives, on an annual basis.

We introduce this report after successfully operating the re-opened Independent Living Fund in Scotland for two years. Since April 2024, we have received over 1,400 applications and provided funding of £9.7 million, enabling many more disabled people with the most complex needs to access the support they need to live independent lives within their chosen communities.

ILF Scotland Strategy - 2025 to 2028, its associated Delivery Plan, our suite of ILF Scotland Policies and actions flowing from our Charter for Involvement Action Plan and our Equality Committee meetings, demonstrate our overall commitment to promoting equality.

Equality is at the heart of what we do as an organisation and runs through all our everyday activities, thoughts, behaviours and plans. We strive to continuously improve on our commitment to mainstreaming equality across the organisation.

Our Board and staff group are diverse with regards to their own lived experience and they are also well-informed about equality, diversity and inclusion more broadly. We continue to listen to and learn from disabled people and strive to provide better-informed services relating to equality, diversity and inclusion to our Recipients, our staff and our other key stakeholders. The organisation does not operate in isolation and we continue to seek out best practice, obtain feedback on our services, consider reporting tools and be involved in partnership working.

Our key focus on addressing inequality is in relation to protected characteristics but we are also considerate of broader definitions of diversity that focus on additional areas. This last year, for example, we have had a greater focus on neurodiversity, cognitive diversity, social mobility and socio-economic diversity. We realise the importance of considering the intersectionality and the impact of how a combination or more than one protected characteristic can perpetuate different forms of discrimination or inclusion challenges.

Our plans are informed by a consideration of the existing context, as well as anticipated future impacts, such as the increase in the use of AI technologies, increased regulatory interest in identifying meaningful diversity metrics, the Scottish Government’s revisions to the National Performance Framework, and the introduction of the Human Rights Bill. We also look to incorporate best practice and guidance such as the UK Government’s Disability Action Plan.

Anne-Marie Monaghan

Anne-Marie Monaghan
ILF Scotland Board Chair

A picture of Peter Scott, a man with dark hair, at sunset on a beach.

Peter Scott, OBE
ILF Scotland CEO

A signature that reads Peter Scott

Introduction

About Us

ILF Scotland is a Non-Departmental Public Body (NDPB), governed by a Board of Directors, appointed by and accountable to Scottish Ministers. See a brief history and context of ILF Scotland.

We operate a discretionary fund providing ongoing awards to just under 4,000 disabled people in Scotland and Northern Ireland to help them live independently with choice, control and dignity in their own homes and within their local communities.

In addition, we provide one-off grants via our Transition Fund for young disabled people in Scotland aged 16 to 25 to help them increase their independence and participate in their communities. Between 2024 and 2026 we provided grants to just under 5,000 young disabled people.

Our Staff

ILF Scotland employs 80 people – 3 on temporary contracts. Of those, 3 members of staff are based in Northern Ireland and 77 work across Scotland. 53 of these are support staff based in the Livingston office and 27 are home-based assessors. We actively recruit colleagues who are disabled and who have long-term health conditions. We are a close team and we regularly listen to what staff have to say both informally and using regular survey tools. On our website there are two case studies from members of our staff to hear from them directly.

Legal Framework

The Equality Act 2010 sets out the general equality duty for all public authorities to have due regard to the need to:

The Equality Act 2010 lists nine protected characteristics:

and defines direct and indirect discrimination as:

“Where someone is treated less favourably according to a protected characteristic or could be disadvantaged compared to someone who does not share that protected characteristic.”

All people are entitled to equal treatment and the way in which people are treated shapes their lives and lived experiences. We recognise and understand how unequal treatment under each characteristic impacts people, particularly those who are living with more than one or multiple protected characteristics.

ILF Scotland must comply with the Equality Act 2010 (Specific Duties) (Scotland) Regulations 2012 and the specific duties designed to help Scottish public authorities meet the general duty. Regulation 4 of the specific equality duties requires that we base our Equality Outcomes on evidence and involvement of equality groups.

ILF Scotland is required to report on the areas outlined below every two years, apart from the Statement on Equal Pay, which is every four years. We also have a duty to publish diversity information about our board members. This report meets our general and specific duties under the Equality Act 2010 and outlines:

Introduction

As a fair work organisation working with disabled people, we regularly review our working practices to ensure that equality, diversity and inclusion are at the centre of our decision-making. We also seek to adopt recommended practices for mainstreaming as outlined in the Equality Human Rights Commission - Mainstreaming the Public Sector Equality Duty - A guide for public authorities in Scotland.

Mainstreaming equality is a long-term, strategic approach to ensure that equality, diversity and inclusion is truly integrated and sits at the heart of organisational culture, strategic planning and operational delivery.

This ambition is evolving and ongoing and we have the commitment, encouragement and support of our Board and our Senior Leadership Team (SLT) to deliver on this. We aim to make sure that every member of our staff team understands, accepts and embraces equality across every part of our organisation and in the services we deliver to our Recipients. We believe that mainstreaming equality has many benefits including helping us to:

We strongly embrace the principles of equality and are proud of the journey we have taken so far.

We became a Non-Departmental Public Body (NDPB) in 2018 and since then there have been changes to the wider equality context in which we work. These include legislative changes, the impact of major events and societal changes bringing certain inequalities into the foreground. Key recent examples to note include:

Legislation Milestones:

Key Events and Societal Changes

All of the above informs our thinking and our statutory responsibility under the Public Sector Equality Duty. These societal issues highlight the importance of us mainstreaming equality outcomes across policy development, decision making, service delivery, and review and this reports provides us with a vehicle to demonstrate progress in advancing equality and reducing unequal outcomes where we can.

Graphic showing a gold 2 balloon reading 2 years since the Independent Living Fund re-opened in Scotland.

Our Recipients

The Recipients of our funds are disabled people. We have two funds, the Independent Living Fund, which re-opened to applicants in April 2024, and the Transition Fund.

Our funding helps our Recipients to access the same opportunities as others and achieve their personal independent living outcomes. We continuously review our strategies, plans, policies and practice to provide the best service we can.

Here you can find out more about our work from some of our Recipients:

As part of ILF Scotland’s ethos and aim to work in co-production with our Recipients, we meet regularly with members of the ILF Scotland and Northern Ireland Advisory Groups.

The purpose of these Groups is to support the improvement and development of ILF Scotland for Recipients living in Scotland and Northern Ireland, by advising on all matters relating to the operation of the fund, including:

The Advisory Groups report to the ILF Scotland SLT, who in turn report learning and outcomes from the Group to the Board and the Scottish Government, as required.

The Groups meet quarterly on an individual basis and meet jointly three times each year with additional occasions meetings with the Minister of Social Care and Wellbeing in Scotland, the Minister for Health in Northern Ireland and with ILF Scotland’s Board members and staff.

The minutes from the Group meetings are available on our website.

We engage with our Recipients in a variety of other ways:

Graphic with text that reads since opening in December 2017, the Transition Fund has made nearly 13,000 awards to young people totalling more than £25 million, making a positive difference to the lives of thousands of young disabled people.

Equality Impact Assessment

We carry out Equality Impact Assessments (EQIAs) when we develop our external policies and publish these on our website. In addition, we conduct screening exercises for all internal policies and produce EQIAs where required. We have incorporated early consideration of Equality Impact Assessments as part of our internal project planning tools and continue to work to extend EQIAs across all our service delivery areas to cover all relevant decision making that affects people with protected characteristics.

We have incorporated Care Experienced young people in our Equality Impact screening and EQIAs, and in the next financial year, we intend to include poverty and rurality as well, because of the effect of these conditions on disabled people.

ILF Scotland is a public authority required to comply with the Consumer Duty, the guidance on which includes a template incorporating the Consumer Duty Assessment with the Equality Impact Assessment and other statutory impact assessments. ILF Scotland staff members are currently considering the best way to incorporate everything we need in the one assessment process, where possible with a view to implementing this after appropriate training in 2026 to 2027.

We believe in the many advantages of conducting EQIAs, in addition to adhering to our statutory duty to do so, including:

We raised awareness and provided training across the organisation of our Equality Impact Assessment tool and screening assessment plan, taking staff through relevant worked examples of EQIAs on live work-related topics during 2024 to 2025 and 2025 to 2026. We will repeat this training in 2026 to 2027 along with additional worked examples to embed this area further in future, which will enable us to apply good equality practice across the organisation.

Our published policy Equality Impact Assessments can be accessed on our website.

A young lady smiles as she puts together a jigsaw puzzle.

Our Partners

Key partners in our approach to equality include the Scottish Government and the Non-Departmental Public Body Human Resources network and forum where core Scottish Government and other Public Bodies share best practice on equality and diversity policy and practice.

In addition, we have developed ongoing positive working relationships with ARC Scotland, Who Cares? Scotland. This ensures that we keep equality at the heart of any decisions we make regarding the services we provide to young disabled people through our Transition Fund. We also signpost disabled people to other sources of support, such as the Scottish Welfare Fund and other charities, benefits agencies / advisory organisations as appropriate.

We also actively seek opportunities to engage with partners across the sector to support the mainstreaming of equalities, sharing learning and contributing to wider improvements in equality outcomes through our continued participation in events and stakeholder meetings.

We value the important input and feedback of our Advisory Group members in Scotland and Northern Ireland on equality when we work with them to develop the Charter for Involvement and through co-production on our strategies and policies.

We aim to adopt a human rights approach to all that we do and the Charter fits with human rights legislation, specifically the United Nations Convention on the Rights of Disabled Persons, supporting the realisation of Article 19 of the United Nations Convention on the Rights of Persons with Disabilities – “living independently and being included in the community”.

Implementing the Charter actions, co-produced by the Advisory Groups, helps ensure that we listen to our disabled Recipients and their representatives so that they remain at the heart of our decision-making.

We continue to embrace ways to work in partnership to improve our services and approach.

The Northern Ireland Advisory Group pictured in front of the steps at Stormont.

We set ourselves ambitious equality outcomes and these will be considered in the next section of this report.

Some of our Key Equality Achievements:

A lady in a blue top talks to someone at a table. Lots of people sit at tables in the background.
Picture - Chris Watt Photography

Our Equality Objectives were integrated into our business plan as Specific, Measurable, Achievable, Realistic and Timebound (SMART).

Outcome 1: Integrated Equality Impact Assessments

Integrated Impact Assessments are consistently applied across the organisation with a commitment to have our staff members appropriately trained and our board members fully aware of this.

Action: Further embed the use of Equality Impact Screening and Assessment practices across all business functions by providing additional awareness and practice training to Managers by the end of 2024 to 2025.

Update: We provided additional training to staff and managers in 2024 to 2025 and in 2025 to 2026. We have extended the automatic equality impact screening from our public policies to all of our internal policies and have incorporated this process into our project planning framework. During the next plan, we will continue to work to ensure all decisions about service development or changes to service delivery automatically incorporate equality impact screening and assessment where required.

Outcome 2: Promote Neuro-Inclusion

To start the neuro-inclusion journey within ILF Scotland focused on developing a neuro-inclusive culture with the aim of creating even greater comfort and belonging for our diverse staff group.

Action: We provided neurodiversity training to all staff in 2026 through The Donaldson Trust, raising awareness along with specialist training for our front-line staff so they can provide informed customer service to our Recipients who are neurodivergent, plus Leadership training for managers and Senior Leadership Team.

In 2025, we also created Neuro Minds, our staff neurodiversity group with the aim to create a workplace where everyone feels valued, fairly treated, supported and able to thrive. We celebrate the strengths and talents of neurodivergent people and work together to promote understanding, acceptance and meaningful inclusion.

Outcome 3: Corporate Parenting

More young disabled people who are Care Experienced are aware of the Transition Fund and how to apply, and our staff and Board members are aware of the Transition Fund and how it might positively impact Care Experienced young people.

Action: Through our Corporate Parenting Plan, we will further develop our communications strategy to target Care Experienced young people and those that support them to ensure they are aware of the Transition Fund. We will ensure ILF Scotland staff and Board Members are aware of the principles of Corporate Parenting through training courses and induction programmes.

Update: We updated our communication strategy to target Care Experienced young people and provided a series of Corporate Parenting awareness session for staff and Board members. We continue to progress improvement initiatives outlined in our published Corporate Parenting Action Plan. Corporate Parenting Plan - 2024 to 2027 and Corporate Parenting Plan - 2024 to 2027 - Progress Report at April 2026.

As part of our commitment to advancing equality and supporting diverse family structures, ILF Scotland introduced a Kinship Care Policy in 2025. This policy mirrors the principles of our Maternity and Adoption policies by providing equitable support to employees who take on the primary care of a child through kinship arrangements. It recognises the vital role that family members and close connections play in providing stable, loving care, and ensures that kinship carers have access to protected leave, enhanced pay and flexible working options during this important time. The introduction of this policy reflects our ongoing commitment to fair work, inclusion and ensuring that all forms of caregiving are valued and supported within our organisation.

In 2025, we introduced a positive action recruitment measure to support applicants who are Care Experienced, aligned in approach to the principles of the Disability Confident scheme. When an applicant identifies as being Care Experience and meets all essential criteria outlined in the job description, they are guaranteed progression to the next stage of the recruitment process.

We are proud to collaborate with them to recognise, value and support kinship carers, relatives and friends who step up to raise a child when their parents are unable to. We have ensured all our Family Friendly policies include kinship carers: providing our managers with guidance to help them support kinship carers with flexibility and kindness and raising awareness of kinship care to our staff. We are also proud to be introducing kinship care leave on par with adoption leave.

In 2025 we were recognised by the leading national charity Kinship as Gold Standard Kinship Friendly Employer and the first employer In Scotland to achieve the accreditation.

Outcome 4: ILF Re-Opening

Following an announcement by the First Minister in September 2023, the Independent Living Fund, closed to new applications since 2010, re-opened to new applicants in April 2024. This enabled up to 1,000 additional disabled people with the most complex needs to access the support they need to live independent lives.

A Co-Production Working Group was established in October 2023, consisting of disabled people, carers, disabled people's organisations (DPOs) and representatives of ILF Scotland, the Scottish Government and health and social care statutory partners. A range of engagement events were held to seek views on the policy framework for the re-opened fund. A commitment was given to continue to develop policy in 2024 to 2025.

Action: Facilitate meetings of the Co-Production Working Group every two months in 2024 to 2025, with the first meeting to be scheduled for June 2024. Report on learning from the first two months of receiving applications to the re-opened fund and work together with the group and others as required to further develop policies around the key issues raised by disabled people and others at the re-opening engagement events. Arrange further co-production opportunities with our Recipients and others as part of our strategic planning consultations in the latter part of 2024 to 2025.

Update: The Co-Production Working Group continued to meet regularly during 2024 to 2025 with the first of these meetings held in June 2024. Meetings continued during 2025 to 2026. ILF Scotland senior staff have worked closely with the Group to report on the operation of the re-opened fund, including the number of places allocated and taken up, challenges, learning and feedback. We received positive feedback and reported this back to the Group.

The Group recommended a policy change to include a Care Component. This would allow disabled people who did not currently meet the £800 local authority funding threshold for the re-opened fund, but who would have if account were to be taken of the significant amount of support provided to them by an unpaid carer residing with them. The Minister accepted this recommendation and ILF Scotland implemented a Carer Component in January 2025, which resulted in an additional 218 applications to the re-opened Fund.

During 2025 to 2026 we worked with the Group to develop a DPO supported pilot to test an alternative route to local authority applications, which will provide learning relevant to the consideration of a potential citizen led application route to the re-opened ILF. The pilot will last for 12 months from 2 April 2026 to 31 March 2027 and will be funded as part of the Scottish Government’s Disability Equality Plan. We ran a series of online and in-person events during 2024 to 2025 to co-produce our Strategic Plan 2025 to 2028 with our disabled Recipients and their supporters. They directly influenced our direction of travel through the articulation of aims and objectives important to the achievement of independent living outcomes.

Summary

We made strong progress in achieving the actions set out in our plan as part of our Mainstreaming and Equality Outcomes Report for 2024 to 2026.

We were unable, as planned, to undertake further work on our forms and systems to provide better equality data on protected characteristics across both funds to improve our monitoring and reporting practices in line with good practice. We will therefore carry this action forward to the next plan.

ILF Scotland remains committed to embedding equality outcomes and will pursue further expansion and improvement on our approach to working in partnership with others to promote equality in Scotland.

Three people pose for the camera alongside the Tom Arthur MSP.

The Gender Representation on Public Boards (Scotland) Act 2018 sets an objective that public boards should have 50% of their non-executive members who are women.

ILF Scotland has worked proactively with the Scottish Government over a number of years to strengthen the diversity and gender balance of our Board. We have maintained more than 50% female representation on our non-executive Board since 2015 and have sustained this position through to 2024, with women making up 75% of Board members.

We regularly review the diversity and representativeness of our Board to ensure it reflects the communities we serve, and we recognise that people from ethnic minority backgrounds remain underrepresented. We have 9 Board members, 4 of whom identify as disabled. We will continue to take proactive steps to improve representation, working closely with the Public Appointments Team during future Board recruitment processes to promote wider participation and encourage applications from underrepresented groups. ILF Scotland also follows the Equality and Human Rights Commission’s good practice guidance How to Improve Board Diversity: Six Step Guide to support fair, transparent and inclusive appointment processes.

In 2023 there were 4 women and 3 men.
In 2024 there were 6 women and 2 men.
In 2025 there were 6 women and 1 man.

2023 20242025
Women466
Men321
A pie chart showing 77.5% in blue which corresponds to female employees. And 22.5% in orange which corresponds to male employees.

Staff (Female / Male)

Female Employees: 77.58%
Male Employees: 22.5%

A pie chart. The biggest piece is blue at 51.25% for female, full time employees. The next biggest piece is orange, 18.75% for male full-time employees. Then we have 26.25% in grey for female part-time employees. Finally there's 3.75% in yellow for male, part-time employees.

Full and Part Time Female / Male

Female Full Time: 51.25%
Male Full Time: 18.75%
Female Part Time: 26.25%
Male Part Time: 3.754%

Part time working patterns remain predominate toward women.

During 2024 to 2026, 100% of staff worked within our hybrid working offering, with employee choice and control over whether they were working in the office or at home.

We used data capture and analysis to measure the representativeness of our workforce profile and use this information to identify improvement measures such as targeted recruitment.

The accuracy of our equality profile data is important as it can assist our Board and SLT in planning the workforce of the future and provides for the potential justification of allowable positive action to make improvements, leading to a workforce that reflects the population and geographical locations we work in.

Our workforce monitoring data indicates that there is room for improvement in the representation of people from ethnic minority groups and LGBTQI+ colleagues within our workplace. Our organisational demography by the end of Q4 2025 to 2026 was 80 staff and 9 Directors.

Women are well represented in the general workforce and at managerial level: 77.5%:22.5% female: male. At Director and Senior Leadership Team level, however, women remain comparatively underrepresented (25%:75% female: male).

Through our Workforce Plan, we have taken active steps to strengthen gender representation at senior levels. As part of this work, seven women have recently been appointed as Leads across the organisation, broadening the leadership pipeline and increasing opportunities for women to progress into more senior decision-making roles.

We plan to continue addressing this through a sustained focus on leadership and management development, succession planning and strategic recruitment.

We have a good representation of disabled people with 30% self-identifying as disabled. As a comparison, in September 2025, the Scottish Government reported 14.2% of staff were disabled.

We have some representation of people from ethnic minority groups at 3.75%, an increase from our previous representation of 2.6%. In September 2025, for comparison, the Scottish Government reported a figure of 4.0%.

The information we have on sexual orientation and gender reassignment is that 1.25% of staff identify as LGBTQI+. In September 2025, the Scottish Government reported a figure of 8.1%.

Data on the current ILF Scotland workforce is robust in relation to age and sex. However, information on other protected characteristics – including ethnicity, disability, religion or belief, sexual orientation and gender reassignment – remains limited. This is largely due to non-completion of questions within staff surveys or individuals choosing the prefer not to answer option.

We continue to raise awareness across the organisation about the importance and benefits of sharing protected characteristic data, emphasising that all information is held in strict confidence and used solely to support equality monitoring and improvement.

As a positive action measure in recruitment, we actively encourage applications from individuals with protected characteristics to help broaden representation across our workforce. Like many public bodies, we recognise the ongoing challenge of achieving a workforce that fully reflects the diversity of the communities we serve, and this will remain a key area of focus in the years ahead.

The findings from our 2025 employee engagement surveys indicate (84% response rate):

A picture of the ILF Scotland staff taken in 2026.
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These are the new Outcomes for 2026 to 2028. We have consulted with ILF Scotland staff and Advisory and Young Ambassadors Group members. Our Equality Committee and our SLT have recommended them to the Board, who have approved them. We will integrate these as SMART objectives in our business plan.

Outcome 1: Making inclusivity central to how we work and lead, strengthening our commitment to having a workplace where everyone belongs

Action: Over the next two years, we will embed inclusivity as a visible, measurable and shared responsibility across our organisation. We will continue to equip our staff with the skills to foster belonging, ensuring transparent policies and processes, as well our ongoing commitment to actively listen, engage and respond to diverse perspectives. Clear goals and accountability will track our progress and celebrate milestones in doing so, making inclusivity a core part of how we lead, collaborate and continue succeed together.

Outcome 2: Ensure our Equality Impact Assessment is inclusive of all of our relevant public body duties

Action: By the end of 2025 to 2026, review and update our Equality Impact Assessment Screening Toolkit and EQIA template to incorporate all other relevant impact assessments introduced by other legislation where we have a public body duty including the UNCRC, the Consumer Duty and the impending Human Rights Bill.

Outcome 3: Provide improved data on protected characteristics to improve the inclusivity of our services and to demonstrate alignment with Scottish Government equality priorities

Action: Develop our application forms, our online portals, our review process paperwork and processes and our digital systems to systematically request information relating to protected characteristics for applicants to and Recipients of both the Independent Living Fund and the Transition Fund. Monitor and analyse this data and report appropriately in line with good practice on data relating to protected characteristics to our SLT, Board, Equality Committee, Scottish Government and publicly as required.

Outcome 4: Increase our partnership working to improve equality outcomes for people living in Scotland and Northern Ireland

Action: Contribute to working parties, briefing papers, meetings, conferences, information sharing, etc. with the aim of driving improvements generally in equality and diversity. Attend meetings with relevant partner organisations to carry out benchmarking with other public bodies to improve the equality outcomes across the organisation as we continue on our Mainstreaming journey.

These equality outcomes will guide our progress and direction, which will be monitored by our Equality Committee. We will develop action plans and monitor and review these annually to ensure we remain on track and will publish and update our progress annually as well as updating plans with any relevant information due to unplanned and / or unforeseen national and international events.

We continue to set equality outcomes with the intention that we truly embed equality, diversity and inclusion into our strategic and annual delivery plans and our daily activities. We are pleased to report that we have achieved the majority of what we set out to do in the period of this plan. Some actions are ongoing and we have incorporated them in our actions for 2026 to 2028, as we continue to identify opportunities for improvement and as part of our ongoing commitment to our equality mainstreaming journey.

We agreed the actions we need to take to achieve our equality outcomes through engagement with and listening to the views of our Advisory Groups and staff. We discuss these with our Equalities Committee and with our Senior Leadership Team (SLT) and our Board formally approves them. Board members provide the necessary scrutiny to ensure that we meet our duties and that we consider potential equality impacts as part of our corporate decision-making.

Our SLT is responsible for promoting and embedding equality in our plans, projects and operational processes.

Each employee also has an individual responsibility for considering equality issues in all areas of the work we do and in working with others to continually enhance our processes and our contact with our applicants, Recipients and others.

We will continue to identify and implement innovative ways to understand the needs of our Recipients, listening and working hard, to learn and improve what we do.

We will use the employee equality metrics in this report, together with developing best practice, to support and inform our recruitment and employment practices, to improve our workforce equality and diversity and to promote the organisation as an employer of choice.

As a Non-Departmental Public Body, we ultimately aspire to continue to work in partnership with the Scottish Government and other Public Bodies, to be an inclusive employer and to continue to enhance the access to our services and the support provided to disabled people in Scotland and Northern Ireland.

Two young ladies sitting beside each other. One looks at the camera and the other looks at her.

We report our pay gaps using a single measure, comparing the average full-time equivalent earnings of men and women at March 2026. This includes both the mean and median hourly pay, excluding overtime. It is important to recognise that a gender pay gap reflects the difference in average earnings between men and women across the organisation as a whole and does not indicate unequal pay for comparable roles or work of equal value.

Gender Pay Gap by Grade

Grade A3
Female pay as a percentage of male pay: 105.74%
Median Pay Gap: -5.76%
Mean Pay Gap: -5.76%

Grade A4
No staff at A4

Grade B1
Female pay as a percentage of male pay: 103.61%
Median Pay Gap: -3.61%
Mean Pay Gap: -8.46%

Grade B2
Female pay as a percentage of male pay: 98.09%
Median Pay Gap: -0.82%
Mean Pay Gap: 0%

Grade B3
Female pay as a percentage of male pay: 111.65%
Median Pay Gap: -11.62%
Mean Pay Gap: -11.28%

Grade C1
Female pay as a percentage of male pay: 94.27%
Median Pay Gap: 5.75%
Mean Pay Gap: 0%

Grade C2
Female pay as a percentage of male pay: 93.32%
Median Pay Gap: 6.67%
Mean Pay Gap: 6.670%

Grade C3
Female pay as a percentage of male pay: not applicable
Median Pay Gap: 0%
Mean Pay Gap: 0%

CEO
Grade SCS 1
Female pay as a percentage of male pay: not applicable
Median Pay Gap: 0%
Mean Pay Gap: 0%

All comparable jobs or work of equal value are paid on the same scale. The pay gap in 2025 to 2026 is entirely due to spinal placement on the grade and will even out as employees reach the top of their scale.

This is set out in table form below.

Gender Pay Gap by Grade

 Job TypeGradeFemale pay as a
percentage of male pay
Median Pay GapMean Pay Gap
AdministrationA3105.73%-5.76%-5.76%
AdministrationA4n/an/an/a
Specialist Professional and TechnicalB1103.61%-3.61%-8.46%
Specialist Professional and TechnicalB2100.82%0.82%0%
Specialist Professional and TechnicalB3-111.65%-11.62%-11.28%
Senior LeadersC194.32%5.75%0%
Senior LeadersC293.32%6.67%6.67%
Senior LeadersC3n/a0%0%
CEOSCS 1n/a0%0%

Where men and women are undertaking work of equal value, they are paid a similar hourly rate and consequently the gender pay gap is low.

Appendix II: Equal Pay Statement

Equal Pay Statement

ILF Scotland is committed to the principle of equal opportunities in employment and to ensuring that all staff are treated fairly, consistently and without discrimination.

We believe that employees should receive equal pay for the same or broadly similar work, for work rated as equivalent, and for work of equal value, regardless of:

To achieve this, we operate pay and progression systems that are transparent, objective and free from unlawful bias. Our approach is underpinned by job evaluation, clear pay structures and regular monitoring to ensure equity is maintained and any emerging issues are addressed promptly.

Where a gender pay gap exists, this is primarily due to employees being placed at different spinal points within the grade, based on their time in post. Our pay structure is designed to ensure that staff progress through spinal points in a consistent and transparent way. As colleagues move through the scale, we anticipate that any current differences in average pay will narrow and even out over time.

As part of our commitment to fairness, dignity and equality at work, we are proud to be a Living Wage Employer. We ensure that all directly employed staff, as well as regular third-party contractors, are paid at least the real Living Wage as defined annually by the Living Wage Foundation.

This commitment reflects our belief that fair pay is a core component of promoting equality and reducing socio-economic disadvantage.

We will continue to monitor our pay practices and contractor arrangements to ensure ongoing compliance with Living Wage standards and alignment with our equality objectives.

ILF Scotland will continue to review its policies, practices and pay data to ensure that equal pay is embedded in all aspects of employment and that our workforce is supported to thrive in an inclusive and fair working environment.

Corporate Parenting Plan - 2024 to 2027 - Progress Report at April 2026

Annual review of progress against our Corporate Parenting Actions.

Commitment 1

We will continue to develop existing relationships with other Corporate Parents to make sure that ILF Scotland remains alert to the needs of care experienced young people to inform our policy and practice.

Actions:

Progress:

Commitment 2

We will assess the requirements of care experienced young people to ensure we meet their needs.

Actions:

Progress

Commitment 3

We will develop staff awareness of corporate parenting across our organisation.

Actions:

Progress:

Commitment 4

We will ensure access to our services for care experienced young people.

Actions:

Progress:

Commitment 5

We will consider where we could improve our services and processes for care experienced young people.

Actions:

Progress:

Service Charter

Service Charter

ILF Scotland is a public body that administers social care funding for disabled people in Scotland and Northern Ireland. It has two funds – the Independent Living Fund and the Transition Fund.

The Independent Living Fund

Through its Independent Living Fund, ILF Scotland provides an ongoing weekly financial award, paid monthly, to disabled people in Scotland and Northern Ireland. This funding enables people to purchase additional social care support, normally complimentary to statutory support, so they can live independently in their communities. Visit What is it? to find out more about the fund.

Transition Fund

ILF Scotland provides one-off, discretionary, grants of up to £4,000 for one year, through its Transition Fund to young disabled people aged 16 to 25, living in Scotland. These grants help young disabled people to become more engaged and active in their community. Visit Transition Fund to find out more about the fund.

As part of the ILF Scotland Feedback Strategy, we have developed an ILF Scotland Service Charter that outlines the minimum levels of service that we commit to provide to Recipients, Award Managers, and others.

The Charter sets out the service standards others can expect from us, and it explains how they will receive services from us, the expected timeframe for delivering those services, and the process people can follow if their expectations are not met.

Ongoing feedback about our services, both positive and negative, is central to ongoing review and development of our Service Charter.

Service Charter Statements

As an organisation we will:

In the delivery of our services, we will:

To develop our services, we will:

  1. encourage you to give us feedback using the methods set out in this feedback strategy
  2. put you at the centre when we are designing or developing our services and co-produce new policies and services with you whenever possible
  3. publish our performance to show you how we are doing

To help us, we would like you to:

Review and Update of Our Charter

We will review and update our Service Charter regularly. The review process will include consideration of any changes to service delivery, policy amendments, wider policy issues and relevant emerging research / literature, feedback projects, complaints, equality impact assessments, and recent / pending improvements.

We will ensure that our charter is accessible, visible, flexible, and current. In line with our organisational principle of co-production, we will involve our key stakeholders in future development of the Charter.

Feedback Strategy and Service Charter

Updated 31 March 2026

Contents

  1. Introduction
  2. Service Charter
  3. Existing Feedback Mechanisms
  4. Completed Feedback Projects Pre 2025
  5. Feedback Gathered During 2025 to 2026
  6. Future Feedback Mechanisms

Appendix 1

1. Introduction

Independent Living is, and always will be, at the centre of everything ILF Scotland does. To provide the best service we can, we must engage with Recipients and others who use our services to listen to their feedback, understand their experiences, and use this information to improve what we do and help address some of the challenges and barriers disabled people face.

Using a range of practical, co-designed mechanisms, we will continue to seek and encourage feedback from Recipients and our other stakeholders as appropriate. We will involve Recipients, particularly the members of our Advisory Groups in Scotland and Northern Ireland to help shape what we do and the way we do it.

We will use the data we gather to evidence how successfully we deliver our services. We will continue to evaluate our services, their effectiveness, and the outcomes they generate, so we can best understand the needs of those we deliver services to and continue to grow and evolve these services.

We will analyse the feedback we receive to identify any trends and continue to share our findings with ILF Scotland’s Board, with Scottish Government, the Northern Ireland Executive and with other key stakeholders where appropriate to support the wider policy landscape and influence improvements in social care in both countries to help disabled people achieve the independent living outcomes important to them.

Strategy Framework

The Feedback Strategy sits within ILF Scotland’s Strategic priorities 2025 to 2028 in which we are committed to:

The Feedback Strategy sets out the framework for feedback opportunities from Recipients and applicants who interact with our services. Initially we will focus on the feedback priorities for the 2025 to 2026 financial year as determined by the co-production events (see below) and then review at the end of the year to determine progress and to review completed projects and their effectiveness in providing us with useful data. This is a live document and will be reviewed on a regular basis to complement our annual Business Plans.

2. Service Charter

This section is also available as a stand-alone document.

ILF Scotland is a public body that administers social care funding for disabled people in Scotland and Northern Ireland. It has two funds – the Independent Living Fund and the Transition Fund.

The Independent Living Fund

Through its Independent Living Fund, ILF Scotland provides an ongoing weekly financial award, paid monthly, to disabled people in Scotland and Northern Ireland. This funding enables people to purchase additional social care support, normally complimentary to statutory support, so they can live independently in their communities. Visit What is it? to find out more about the fund.

Transition Fund

ILF Scotland provides one-off, discretionary, grants of up to £4,000 for one year, through its Transition Fund to young disabled people aged 16 to 25, living in Scotland. These grants help young disabled people to become more engaged and active in their community. Visit Transition Fund to find out more about the fund.

As part of the ILF Scotland Feedback Strategy, we have developed an ILF Scotland Service Charter that outlines the minimum levels of service that we commit to provide to Recipients, Award Managers, and others.

The Charter sets out the service standards others can expect from us, and it explains how they will receive services from us, the expected timeframe for delivering those services, and the process people can follow if their expectations are not met.

Ongoing feedback about our services, both positive and negative, is central to ongoing review and development of our Service Charter.

Service Charter Statements

As an organisation we will:

In the delivery of our services, we will:

To develop our services, we will:

  1. encourage you to give us feedback using the methods set out in this feedback strategy
  2. put you at the centre when we are designing or developing our services and co-produce new policies and services with you whenever possible
  3. publish our performance to show you how we are doing

To help us, we would like you to:

Review and Update of Our Charter

We will review and update our Service Charter regularly. The review process will include consideration of any changes to service delivery, policy amendments, wider policy issues and relevant emerging research / literature, feedback projects, complaints, equality impact assessments, and recent / pending improvements.

We will ensure that our charter is accessible, visible, flexible, and current. In line with our organisational principle of co-production, we will involve our key stakeholders in future development of the Charter.

3. Existing Feedback Mechanisms

Existing feedback mechanisms in place include:

4. Completed Feedback Projects Pre 2025

To date, we have completed the following feedback specific projects:

5. Feedback Gathered During 2025 to 2026

During the current financial year 2025 to 2026, we sought feedback for the following projects:

We have produced a comprehensive report incorporating all feedback elements from the above to our Board and our other key stakeholders and will publish this on our website shortly.

6. Future Feedback Mechanisms

The next stage of our Feedback Strategy is to consider and co-produce potential feedback mechanisms for the next financial year 2026 to 2027.

To keep our Recipients and other stakeholders informed, we will implement a feedback loop by publishing feedback received from our surveys, at least annually in the format of ‘We asked, you said, we did.’

This feedback strategy will be reviewed to coincide with ILF Scotland’s next strategic plan 2028 to 2031.

Appendix 1:

Statutory Obligations / Public Body Reporting Requirements

Voluntary Reporting

Mainstreaming and Equality Outcomes Report Update on Progress at April 2025

Equality Outcomes 2024 to 2026

These are the Outcomes for 2024 to 2026. ILF Scotland staff and Advisory and Young Ambassadors Group members have been consulted on these. They were submitted to the ILF Scotland Equality Committee and ILF Scotland’s Senior Management Team for sign off and then to the Remuneration Committee and the Board for information. They have been integrated as SMART objectives into our business plan.

Outcome 1 - Integrated Equality Impact Assessments

Integrated Impact Assessments are consistently applied across the organisation with a commitment to have our staff members appropriately trained and our board members fully aware of this.

Action: Further embed the use of Equality Impact Screening and Assessment practices across all business functions by providing additional awareness and practice training to Managers by the end of 2024 to 2025.

Progress: Equality Impact Assessments (EQIAs) have been revised to include “care experienced” as part of the assessment process. As part of the implementation of UNCRC (Incorporation) (Scotland) Act 2024, EQIAs are being reviewed to incorporate Child Rights and Wellbeing Impact Assessments (CRWIA).  Training and awareness sessions were provided to staff in 2024 and a further session is planned in quarter one of 2025. We also intend to more formally incorporate poverty considerations as part of our EQIA screening and will develop or thinking and practice around this during 2025 to 2026.

Outcome 2 - Promote Neuro Inclusion

To start the neuro inclusion journey within ILF Scotland, focused on developing a neuro inclusive culture with the aim of creating even greater comfort and belonging for our diverse staff group.

Action: Raise awareness of neurodiversity and provide staff training to cover this area specifically as part of our equality and diversity training. Provide more detailed training to front line staff so that they can provide an informed customer service to young people who are neurodivergent.

Progress: We have been discussing the training needs of our staff to raise awareness and to help deliver a neuro inclusive culture in the longer term and are consulting with them to identify gaps in knowledge. We plan to deliver a full training programme beginning in quarter three of 2025 to 2026.

Outcome 3 - Corporate Parenting

More young disabled people who are care experienced are aware of our funds and how to access them. Our staff and Board members are also aware of how our funding might positively impact care experienced young people.

Action: Through our Corporate Parenting Plan, we will further develop our communications strategy to target care experienced young people and those who support them to ensure they are aware of our funds. We will ensure ILF Scotland staff and Board Members are aware of the principles of Corporate Parenting through training courses and induction programmes.

Progress: All ILF Staff and Board Members have received training and awareness of Corporate Parenting in the last year. We continue to review our communication strategies to ensure that young people are aware of both the Transition Fund and the re-opened Independent Living Fund as this is also accessible to 16 to 18 year olds.

Outcome 4 - ILF Re-Opening

Following an announcement by the First Minister in September 2023, the Independent Living Fund, closed to new applications since 2010, re-opened to new applicants in April 2024 with the aim of enabling up to 1,000 additional disabled people with the most complex needs to access the support they need and deserve to live independent lives.

A Co-Production Working Group was established in October 2023, consisting of disabled people, carers, disabled people's organisations (DPOs) and representatives of ILF Scotland, the Scottish Government and health and social care statutory partners. A range of engagement events were held to seek views on the policy framework for the re-opened fund. A commitment was given to continue to develop policy in 2024 to 2025.

Action: Facilitate meetings of the Co-production Working Group every two months in 2024 to 2025, with the first meeting to be scheduled for June 2024. Report on learning from the first two months of receiving applications to the re-opened fund and work together with the group and others as required to further develop policies around the key issues raised by disabled people and others at the re-opening engagement events. Arrange further co-production opportunities with our recipients and others as part of our strategic planning consultations in the latter part of 2024 to 2025.

Progress: The Co-Production Working Group continues to meet every two months, reviewing the progress of applications to the re-opened Fund. During the past year,  a recommendation to introduce an element of Unpaid Care into the calculation of the Threshold Sum has been implemented, which allows additional applications from disabled people who receive a significant amount of unpaid care from someone living with them.  The group will continue to meet in 2025 to 2026 to further develop ILF Scotland policies. We held a further six engagement events to discuss strategy and policy with our recipients and other stakeholders and fed views into the development of our new strategic plan, 2025 to 2028.

Conclusion

These equality outcomes guide our progress and direction. We have developed action plans to implement our stated outcomes and we monitor and review these annually to ensure we remain on track. We will publish an update of progress annually. Progress is monitored by our Equality Committee, which meets regularly and has oversight of all relevant action plans and reports.

We set equality outcomes with the intention to truly embed equality, diversity and inclusion into our strategic and annual delivery plans and our daily activities. While we have not been able to achieve everything we set out to do, we have progressed well and we remain committed to continue our equality journey.

Our Equality outcomes are co-produced through the work we do to engage with and listen to our recipients. We will continue to instigate and implement innovative ways to understand the needs of our recipients, listening and working hard, to learn and improve what we do.

Board members provide the necessary scrutiny to ensure that we meet our duties and consider potential equality impacts as part of our corporate decision-making. Our senior management team shares responsibility for promoting and embedding equality in our plans, projects and operational processes and our Equality Committee oversees this work.

Each employee also has an individual responsibility for considering equality issues in all areas of the work we do and in working with others to continually enhance our processes. We consult with and listen to our staff members to help mainstream equalities across the organisation.

We will continue to develop best practice to support and inform our recruitment and employment practices, to improve our workforce equality and diversity targets and to promote the organisation as an employer of choice.

As a Non-Departmental Public Body, we ultimately aspire to continue to work in partnership with the Scottish Government and other Public Bodies, to be an inclusive employer and to continue to enhance the access to our services and the support provided to disabled people in Scotland and Northern Ireland.

Framework: Scottish Government and ILF Scotland - 2025

Approved: 22 April 2025
Version: 2025.1
Next Review: April 2028
Signed by: Peter Scott, for ILF Scotland following approval by the Board of ILF Scotland
Steven Hanlon, for Scottish Government following approval by Minister for Social Care, Mental Wellbeing and Sport

Contents

Introduction
Purpose
Governance and Accountability
The Board
The Chief Executive
The Accountable Officer
The Scottish Ministers
SG Portfolio Accountable Officer
Relationship between Scottish Government and ILF Scotland
NDPB staff management responsibilities
Broad responsibilities for NDPB staff
Pay and conditions of service
Pensions, redundancy and compensation
Corporate and business plans
Annual report and accounts
External audit
Internal audit
Budget management and delegated authority
Governance and Risk
Risk management
Internal control
Budget and finance
Remuneration
Banking and cash management
Annex A: Specific Delegated Financial Authorities

Introduction

1. This framework document is agreed between Independent Living Fund Scotland (ILF Scotland)and the Scottish Ministers. It summarises how ILF Scotland and Scottish Government (SG) will work together, and the key roles and responsibilities of:

While this document does not confer any legal powers or responsibilities, it forms a key part of the accountability and governance framework and as a live document it should be reviewed by SG and ILF Scotland regularly, and at least every 2-3 years. Any significant changes will be agreed between the Board and the Scottish Ministers.

2. Any question regarding the interpretation of the document will be determined by the SG after consultation with ILF Scotland. Legislative provisions take precedence over any part of the document.

3. ILF Scotland is not permitted to establish any subsidiaries or enter into joint ventures without express approval from Scottish Ministers.

Copies of the document will be published on the ILF Scotland website.

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Purpose

5. ILF Scotland is a Scottish registered company limited by guarantee and having company number SC500075. The constitution of ILF Scotland is set out in the Articles of Association. The basis upon which ILF Scotland carries out the administration and distribution of the ILF is agreed within the Service Level Agreement between the Scottish Ministers and ILF Scotland signed and dated on 24 June 2019. ILF Scotland does not carry out its functions on behalf of the Crown.

6. ILF Scotland’s purpose is to:

7. ILF Scotland’s duties, as agreed by the Scottish Ministers, are to:

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Governance and Accountability

This section summarises the specific responsibilities and accountabilities of the key people involved in governance of ILF Scotland.

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The Board

9. Members of the Board of ILF Scotland, including the Chair, are non-executives appointed by the Scottish Ministers in line with the Code of Practice for Ministerial Public Appointments in Scotland. The Chair and Board Members are accountable to the Scottish Ministers and also to the Scottish Parliament and may be required to give evidence to Parliamentary Committees.

10. The Board has overall responsibility for the delivery of the functions of ILF Scotland, as set out at paragraphs 5 to 7 above, in accordance with the aims, policies and priorities of the Scottish Ministers. It [the Board] has corporate responsibility, under the leadership of the Chair, to:

11. The Chair will:

12. Specific guidance on how the Chair and Board Members should discharge their duties will be provided in their appointment letters and in On Board – A Guide for Members of Statutory Boards. Guidance on governance good practice is available in the Scottish Public Finance Manual and from the sponsor team, who may consult the SG Governance and Risk Team. A list of key aspects of governance to consider is included in the section on Governance and Risk below.

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The Chief Executive

13. The Chief Executive is employed and appointed by the Board with the approval of the Scottish Ministers and is the principal adviser to the Board on the discharge of its functions and is accountable to the Board. The Chief Executive role is to provide operational leadership to staff working for ILF Scotland and to ensure that its aims and objectives are met, its functions are delivered, and its targets are met through effective and properly controlled executive action.

14. The specific duties of the Chief Executive will be set out in a job description, and annual objectives will be agreed with the Chair and used in appraisal of the Chief Executive’s performance.

15. In addition to any other specific duties, the Chief Executive will:

16. In advising the Board, the Chief Executive will ensure that the key governance issues highlighted in the section on Governance and Risk below are addressed.

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The Accountable Officer

17. The Principal Accountable Officer for the Scottish Administration will designate a senior official in ILF Scotland, usually this will be the Chief Executive unless there are specific reasons not to, as the Accountable Officer of ILF Scotland. The Accountable Officer is personally responsible for the propriety and regularity of the public finances of ILF Scotland and ensuring that its resources are used economically, efficiently and effectively, as required by section 15 of the Public Finance and Accountability (Scotland) Act 2000 and may be called to give evidence to the Public Audit Committee of the Scottish Parliament. The responsibilities of the Accountable Officer of ILF Scotland are set out in full in the Memorandum to Accountable Officers for Other Public Bodies in the Scottish Public Finance Manual. The Accountable Officer for ILF Scotland and the Board must both sign the annual report and accounts.

18. It is important for the Chair and Board members to recognise that one aspect of these duties is the requirement under section 15(8) of the Public Finance and Accountability (Scotland) Act 2000, where the Accountable Officer of ILF Scotland considers that any action they are required to take is not consistent with their Accountable Officer responsibilities, they must obtain written authority from the Board and send a copy of the written authority to the Auditor General for Scotland as soon as possible and send to the Clerk of the Public Audit Committee. The Accountable Officer of ILF Scotland should consult the Portfolio Accountable Officer before seeking written authority from the Board in these circumstances and should always notify the Portfolio Accountable Officer when such a written authority has been issued.

19. Where the duties of the Accountable Officer of ILF Scotland and the Chief Executive are not combined in one person, the Accountable Officer will work closely with the Chief Executive on governance, and in particular to ensure that the key governance issues highlighted in the section on Governance and Risk below are addressed.

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The Scottish Ministers

The Scottish Ministers appoint the Chair and Board Members and hold the Board to account for the performance of ILF Scotland and its use of resources. Ministers are ultimately accountable to the Scottish Parliament for ensuring that the Board is discharging its duties effectively, although the Parliament will scrutinise the performance of ILF Scotland directly as it does with all public sector bodies. The Scottish Ministers are not directly responsible for the operation of ILF Scotland.

21. The Scottish Ministers will:

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SG Portfolio Accountable Officer

22. The Principal Accountable Officer for the Scottish Administration (the Permanent Secretary of the SG) has designated the Director General for Health and Social Care as the Portfolio Accountable Officer (AO) for the SG portfolio budget which will provide funding for the ILF Scotland.

23. The Portfolio AO’s duties are to establish a framework for the relationship between SG and a public body, oversee the operation of that framework, ensure the public appointments to the body are made appropriately and ensure that appropriate assurance is provided on the performance and governance of the body. These activities are known collectively as ‘sponsorship’. In practice, the Portfolio AO is likely to delegate some or all sponsorship duties to a Director or Deputy Director as Senior Sponsor and/or to other SG officials in a ‘Sponsor Team’. The responsibilities of a Portfolio Accountable Officer are set out in detail in the Memorandum to Accountable Officers for Parts of the Scottish Administration.

24. The Portfolio AO will:

a. make sure the framework document is agreed between the Scottish Ministers and the Board of ILF Scotland, reviewed regularly and oversee the operation of the roles and responsibilities set out;

b. ensure that financial and other management controls being applied by ILF Scotland are appropriate and sufficient to safeguard public funds and conform to the requirements both of propriety and of good financial management;

c. in line with Code of Practice for Ministerial Appointments, ensure that public appointments are made in good time and secure appropriate skills, experience and diversity amongst Board members, working with the Chair on succession planning; that there is effective induction for new appointees; and ensure that there is regular review and a formal annual appraisal of the performance of the Chair;

d. support regular (normally at least once per year) and effective engagement between ILF Scotland and the relevant Scottish Minister(s); and

e. make sure there is clear, documented delegation of responsibilities to a Senior Sponsor and/or Sponsor Team and that the Board and senior officials of ILF Scotland are aware of these delegated responsibilities.

25. The Portfolio AO remains personally answerable to the Scottish Parliament for the effectiveness of sponsorship activity.

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Relationship between Scottish Government and ILF Scotland

26. Strategic engagement between the SG and ILF Scotland is essential in order that they work together as effectively as possible to maintain and improve public services and deliver improved outcomes. Specific governance and accountability roles are described in the section above, but more generally, both the SG and ILF Scotland will take all necessary steps to ensure that their relationship is developed and supported in line with the jointly agreed principles set out in the statement on ‘Strategic Engagement between the Scottish Government and Scotland’s NDPBs’. This emphasises the need for cooperation and good communication, and particularly early warning from either side about any emerging risk or issue with significant implications for the operation or governance of ILF Scotland.

27. The Sponsor Team’s primary function is to carry out the responsibilities delegated to it by the Portfolio AO, directly or via the Senior Sponsor, as described above. In addition to ensuring that the arrangements in this framework document operate effectively, managing public appointments and providing assurance to the Portfolio AO, the Sponsor Team will usually be the first point of contact for the body on any issue with SG. As part of the assurance they provide to the Portfolio AO, they must ensure that key actions and decisions agreed are documented and implemented. This includes ensuring that SG teams implement any agreed actions.

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NDPB staff management responsibilities

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Broad responsibilities for NDPB staff

28. The Chief Executive, challenged and supported by the Board, has responsibility for the recruitment, retention and motivation of its staff. The broad responsibilities toward staff are to ensure that:

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Pay and conditions of service

29. ILF Scotland will comply with SG Pay Policy in relation to staff and the Chief Executive. The Chief Executive will ensure that a pay remit, in line with the guidance for analogue bodies in the SG Pay Policy for Staff Pay Remits, is submitted to the SG for approval in line with the timetable notified and ensure that the pay settlement implemented is within the terms of the approved remit. This should normally be done annually, unless a multi-year deal has been agreed. Payment of salaries should also comply with the Tax Planning and Tax Avoidance section of the SPFM. Proposals on non-salary rewards will comply with the guidance in the Non-Salary Rewards section of the SPFM.

30. ILF Scotland will also seek appropriate approval under the SG Pay Policy for Senior Appointments for the chief executive’s remuneration package prior to appointment, annually or when a new appointment or change to the remuneration package is being proposed.

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Pensions, redundancy and compensation

31. Superannuation arrangements for staff are subject to the approval of the Scottish Ministers. ILF Scotland staff will normally be eligible for a pension provided by PCSPS. Staff may opt out of the occupational pension scheme provided, but the employers’ contribution to any personal pension arrangement, including stakeholder pension, will normally be limited to the national insurance rebate level.

32. Any proposal by ILF Scotland to move from existing pension arrangements, or to pay any redundancy or compensation for loss of office, requires the prior approval of the Scottish Ministers. Proposals on compensation payments will comply with the Settlement Agreements, Severance, Early Retirement and Redundancy Terms section of the SPFM. This includes referral to the Scottish Ministers of any proposed severance scheme (for example, a scheme for voluntary exit), business case for a settlement agreement being considered for an individual, or proposal to make any other compensation payment. In all instances, a body should engage with the Sponsor Team prior to proceeding with proposed severance options, and prior to making any offer either orally or in writing.

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Corporate and business plans

33. ILF Scotland will co-produce, with disabled people and other key stakeholders, a corporate plan, normally every 3 years, setting out its aims, objectives and targets over that period for consideration by the Scottish Ministers. When a new plan is to be prepared, the Chief Executive or their delegate will liaise with the Sponsor Team to agree the key points to be addressed and the timetable for preparation and review. The final, agreed version of the strategic or corporate plan will be published by ILF Scotland on its website.

34. The corporate plan will include ILF Scotland’s:

35. The corporate plan will inform the development of a separate annual business plan which ILF Scotland will prepare for each financial year, and which will include key targets and milestones for the year immediately ahead, aligned to the NPF, and be linked to budgeting information so that, where possible, resources allocated to achieve specific objectives can be identified. A copy of the business plan will be provided to the sponsor unit prior to the start of the relevant financial year.

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Annual report and accounts

36. ILF Scotland will publish an annual report of its activities together with its audited accounts after the end of each financial year. The annual report and accounts will cover the activities of any corporate, subsidiary or joint ventures under the control of ILF Scotland. It will comply with the Government Financial Reporting Manual (FReM) and outline the NDPB’s main activities and performance against agreed objectives and targets for the previous financial year. The accounts must be signed by a director on behalf of the board, and by the Chief Executive, as Accountable Officer.

37. The accounts will be prepared in accordance with relevant statutes and the specific accounts direction and other relevant guidance issued by the Scottish Ministers. Any financial objectives or targets set by the Scottish Ministers should be reported on in the accounts and will therefore be within the scope of the audit.

38. The SG Sponsor Team should receive a copy of the annual report for comment, and a copy of the draft accounts for information, by the end of September each year. ILF Scotland is responsible for the publication of the annual report and accounts after they have been laid by the Scottish Ministers. Whilst the statutory deadline for laying and publishing accounts audited by the AGS is 31 December after the end of the relevant financial year, the Scottish Ministers expect that accounts will be laid before the Scottish Parliament and published as early as possible.

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External audit

39. The Auditor General for Scotland (AGS) audits, or appoints auditors to audit, ILF Scotland’s annual accounts and passes them to the Scottish Ministers who then lay them before the Scottish Parliament, together with the auditor’s report and any report prepared by the AGS. The AGS, or examiners appointed by the AGS, may also carry out examinations into the economy, efficiency and effectiveness with which the body has used its resources in discharging its functions and/or carry out examinations into the arrangements made by ILF Scotland to secure Best Value.

40. The AGS, or the AGS’s appointed auditors or examiners, have a statutory right of access to documents and information held by relevant persons, including any contractors to or recipients of grants from ILF Scotland. ILF Scotland will ensure that this right of access to documents and information is made clear in the terms of any contracts issued or conditions of any grants awarded and will also use its best endeavours to secure access to any other information or documents required which are held by other bodies.

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Internal audit

41. ILF Scotland will:

42. The SG’s Internal Audit and Assurance Directorate has an expectation of cooperation and access to relevant material when required, the parameters for which would be set out in an engagement document before information was shared. ILF Scotland should make it clear on their own Privacy Notice that material may be shared with SG’s Internal Audit and Assurance Directorate in certain circumstances.

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Budget management and delegated authority

43. Each year the Sponsor Team will send the Board a Budget Allocation and Monitoring letter, notifying ILF Scotland of the budget provision, any related matters and details of the budget monitoring information required. ILF Scotland will comply with the format and timing of the monitoring information requested and with any requests for further information.

44. The statement of budgetary provision will set out the budget within the classifications of resource Departmental Expenditure Limits (RDEL), capital DEL (CDEL) and Ring-fenced (non-cash) (RfDEL) – and, where applicable, Annually Managed Expenditure (AME). These categories are explained in Annual Budget Processing in the SPFM, and ILF Scotland will not transfer budgetary provision between the categories without the prior approval of the SG Health and Social Care Finance, Digital and Governance Directorate (‘Health Finance’), which should be sought via the Sponsor Team. Transfers within the categories are at the discretion of the Board or, subject to delegated authority, the Chief Executive or relevant senior manager, if these do not breach any other constraints, for instance the approved pay remit.

Where budgetary provision includes projected income, including any income from disposal of non-current assets, the Chief Executive will ensure that Health Finance and the Sponsor Team are made aware promptly of any forecast changes in income – usually via the monthly budget monitoring statement. The Scottish Ministers expectation is that any shortfall in income will be offset by a matching reduction in gross expenditure, and prior approval Health Finance and the Sponsor Team must be sought for any alternative arrangement. Similarly, if income is higher than originally projected, this may only be used for additional spending or to meet pressures with the prior approval of the SG Finance Directorate and Sponsor Team. Failure to obtain prior approval for the use of excess income to fund additional expenditure may result in corresponding reductions in budgets for the following financial year. The only exception is where the income is from gifts, bequests and donations but this must be spent within the same financial year as the receipt.

45. ILF Scotland’s specific delegated financial authorities - as agreed in consultation between the Board and the Scottish Ministers - are set out in Annex A. The Board will obtain the prior written approval from sponsors and Health Finance before entering into any undertaking to incur any expenditure that falls outside these delegations, and before incurring expenditure for any purpose that is or might be considered novel, contentious or repercussive or which has or could have significant future cost implications.

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Governance and Risk

46. Guidance on governance requirements is available in several documents referred to earlier in this framework document:

47. If in any doubt about a governance issue, the Chair or Chief Executive should consult the Senior Sponsor or Sponsor Team in the first instance, and sponsors may in turn consult the SG Public Bodies Unit, the SG Governance and Risk Branch and / or other teams with relevant expertise.

48. The Board and Chief Executive are advised to pay particular attention to guidance on the following issues.

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Risk management

49. ILF Scotland must develop an approach to risk management consistent with the Risk Management section of the Scottish Public Finance Manual and establish reporting and escalation arrangements with the Portfolio AO or Senior Sponsor.

50. The Board should have a clear understanding of the key risks, threats and hazards it may face in the personnel, accommodation and cyber domains, and take action to ensure appropriate organisational resilience, in line with the guidance in: Having and Promoting Business Resilience (part of the Preparing Scotland suite of guidance) and the Public Sector Cyber Resilience Framework.

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Internal control

51. The Board should establish clear internal delegated authorities with the Chief Executive, who may in turn delegate responsibilities to other members of staff and establish an assurance framework consistent with the internal control framework in the SPFM.

52. Counter-fraud policies and practices should be adopted to safeguard against fraud and theft - see the Fraud section of the SPFM.

53. Any major investment programmes or projects undertaken should be subject to the guidance in the Major Investment Projects section of the SPFM and in line with delegated authorities. The Sponsor Team must be kept informed of progress on such programmes and projects and Ministers must be alerted to any developments that could undermine their viability. ICT investment plans must be reported to the SG’s Office of the Chief Information Officer.

54. ILF Scotland must comply with the requirements of the Freedom of Information (Scotland) Act 2002 and ensure that information is provided to members of the public in a spirit of openness and transparency. ILF Scotland must also register with Information Commissioners Office and ensure that it complies with the Data Protection Act 2018 and the General Data Protection Regulations, commonly known as GDPR.

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Budget and finance

55. Unless covered by a specific delegated authority, financial investments are not permitted without the prior approval of sponsors and SG Finance. This includes equity shares in ventures which further a body’s objectives. Public bodies should not invest in any venture of a speculative nature.

56. Non-standard tax management arrangements should always be regarded as novel and/or contentious and must therefore be approved in advance by the Portfolio AO and SG Finance. Relevant guidance is provided in the Tax Planning and Tax Avoidance section of the SPFM. ILF Scotland must comply with all relevant rules on taxation, including VAT, recover input tax where it is entitled to do so.

57. Optimising income (not including grant-in-aid) from all sources should be a priority, and sponsors should be kept informed about any significant projected changes in income. Novel or contentious proposals for new sources of income or methods of fundraising must be approved by sponsors and SG Finance. Fees or charges for any services supplied must be determined in accordance with the Fees & Charges section of the SPFM.

58. Gifts, bequests or donations received score as income and should be provided for in the agreed resource DEL and capital DEL budgets, but should not fund activities or assets normally covered by SG grant-in-aid, trading or fee income, and conflicts of interest must be considered – see the principles in the Gifts section of the SPFM. Note that this relates to gifts to the body - gifts to individuals are covered in the Model Code of Conduct.

59. Borrowing cannot be used to increase ILF Scotland’s spending power. All borrowing - excluding agreed overdrafts - must be from the Scottish Ministers in accordance with guidance in the Borrowing, Lending & Investment section of the SPFM.

60. Any lending must be in line with the guidance in the Borrowing, Lending & Investment section of the SPFM on undertaking due diligence and seeking to establish a security. Unless covered by a specific delegated limit ILF Scotland must not lend money, charge any asset, give any guarantee or indemnity or letter of comfort, or incur any other contingent liability (as defined in the Contingent Liabilities section of the SPFM), whether or not in a legally binding form, without the prior approval of sponsors and SG Finance. Guarantees, indemnities and letters of comfort of a standard type given in the normal course of business are excluded from this requirement.

61. An accurate and up-to-date record of current and non-current assets should be maintained, consistent with the Property: Acquisition, Disposal & Management section of the SPFM. ILF Scotland is also subject to the SG Asset Management Policy, including the requirement for acquisition of a new lease, continuation of an existing lease, decision not to exercise a break option in a lease or purchase of property for accommodation / operational purposes, to be approved in advance by Scottish Ministers. The Property Controls Team should be consulted as early as possible in this process.

62. Assets should be recorded on the balance sheet at the appropriate valuation basis in accordance with the FReM. When an asset (including any investment) suffers impairment, when there is significant movement in existing provisions and/or where a new provision needs to be created, this should be communicated to sponsors and SG Finance as soon as possible to determine the implications for the NDPB’s budget.

63. Any funding for expenditure on assets by a third party should be subject to appropriate arrangements to ensure that they are not disposed of without prior consent and that a due share of the proceeds can be secured on disposal or when they cease to be used by the third party for the intended purpose, in line with the Clawback guidance in the SPFM.

64. Unless covered by a specific delegated authority, prior approval from sponsors and SG Finance is required before making gifts or special payments or writing off losses. Special payments and losses are subject the guidance in the Losses and Special Payments section of the SPFM. Gifts by management to staff are subject to the guidance in the Non-Salary Rewards section of the SPFM.

65. Unless covered by a specific delegated authority ILF Scotland must not enter into any finance, property or accommodation related lease arrangement – including the extension of an existing lease or the non-exercise of a tenant’s lease break - without prior approval from sponsors. Before entering/ continuing such arrangements the NDPB must be able to demonstrate that the lease offers better value for money than purchase and that all options of sharing existing public sector space have been explored.

Non-property / accommodation related operating leases are subject to a specific delegated authority. There must be capital DEL provision in the budget allocation for finance leases and other transactions which are in substance borrowing.

66. Procurement policies should reflect relevant guidance in the Procurement section of the SPFM and any other relevant guidance issued by the SG’s Procurement and Property Directorate. The SG’s directory of SG Framework Agreements, is available to support organisations but they should check the Framework Agreement’s ‘buyer’s guide’ before proceeding to ensure they are eligible to use the Framework.

67. All matured and properly authorised invoices relating to transactions with suppliers should be paid in accordance with the Expenditure and Payments section of the SPFM wherever possible and appropriate within Scottish Ministers’ target of payment within 10 working days of their receipt.

68. ILF Scotland is subject to the SG policy of self-insurance. Commercial insurance must however be taken out where there is a legal requirement to do so and may also be taken out in the circumstances described in the Insurance section of the SPFM - where required with the prior approval of sponsors and their finance business partner subject to the level of inherent financial risk. In the event of uninsured losses being incurred the SG shall consider, on a case by case basis, whether or not it should make any additional resources available to the NDPB. The relevant sponsor team will provide a Certificate of Exemption for Employer's Liability Insurance.

69. Unless covered by a specific delegated authority ILF Scotland must not provide grant funding to a third party without prior agreement from sponsors and SG Finance. Guidance on a framework for the control of third party grants is provided as an annex to the Grant & Grant in Aid section of the SPFM. Subsidy control requirements for any such funding are discussed below.

70. The EU State aid regime was effectively revoked from UK law from 1 January 2021. Following this, subsidy control provisions were covered by the UK-EU Trade and Cooperation Agreement (TCA) and the UK’s international obligations, including various Free Trade Agreements and those arising as a consequence of World Trade Organisation membership. However, a new UK subsidy control regime came into force on 4 January 2023 as a result of UK Government’s Subsidy Control Act 2022. Currently, any activity that a public body undertakes itself, or funds other bodies to undertake, that can be offered on a commercial market for goods and services, is subject to the regulations set out in the Subsidy Control Act 2022. A full assessment is required prior to disbursing any funding, subject to the guidance in the subsidy control section of the SPFM.

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Remuneration

71. Remuneration, allowances and any expenses paid to the Chair and Board Members must comply with the latest SG Pay Policy for Senior Appointments and any specific guidance on such matters issued by the Scottish Ministers.

72. Staff pay, pensions and any severance payments must be in line with the requirements of Public Sector Pay Policy and the responsibilities described in the section on NDPB Staff Management Responsibilities.

73. All individuals who would qualify as employees for tax purposes should be paid through the payroll system with tax deducted at source.

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Banking and cash management

74. Banking arrangements must comply with the Banking section of the SPFM.

75. Cash management arrangements need to be addressed as well as overall budget management. Any grant in aid (i.e. the cash provided to ILF Scotland by the SG to support the allocated budget) for the year in question will be authorised by the Scottish Parliament in the annual Budget Act. ILF Scotland will normally receive monthly instalments based on updated profiles and information on unrestricted cash reserves and will not seek any payment in advance of need. ILF Scotland will keep its unrestricted cash reserves held during the year to the minimum level needed for efficient operation and any relevant liabilities which have to be met at the year-end. Grant in aid not drawn down by the end of the financial year will lapse. ILF Scotland will not pay Grant-in-Aid into any restricted reserve it holds.

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Helpful information

76. The Public Bodies Support Unit has produced a register of reporting requirements for devolved public bodies which will help in regard to compliance with certain legislative asks. Copies of the register can be obtained from the PBSU mailbox.

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Annex A: Specific Delegated Financial Authorities

Commit expenditure and authorise payments in the ordinary course of business
Delegated Limit: Up to the budgets provided for in ILF Scotland’s annual Budget Allocation and Monitoring Letter.

Operating leases – other than property / accommodation related leases
Delegated Limit: £25,000 per year

Gifts
Delegated Limit: £5,000 per year, individual transactions up to £200

Special payments
Delegated Limit: £30,000 per year

Claimed waived or abandoned
Delegated Limit: £10,000 per year

Write-off of bad debt and / or losses
Delegated Limit: £10,000 per year

Grants
Delegated Limit: As provided for in the policies agreed by Scottish Ministers

Major investment programmes / projects
Delegated Limit: Total projected value up to £100,000

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