WEST DEVON BOROUGH COUNCIL – LETTER OF REPRESENTATION

Our Ref

Date: 30th September 2008

Grant Thornton UK LLPHartwell House

55-61 Victoria Street

Bristol BS1 6FT

Dear Sirs

Financial Statements for the Year Ended 31 March 2008

We confirm to the best of our knowledge and belief that the following representations are made on the basisof appropriate enquiries of other officers, management and staff, with relevant knowledge and experience(and, where appropriate, of inspection of supporting documentation) sufficient to satisfy ourselves that wecan properly make each of the following representations to you in respect of your audit of the above financialstatements.

i we acknowledge our responsibilities for preparing financial statements which present fairly the financialposition of this council and for making accurate representations to you.

ii As far as we are aware:- there is no relevant audit information of which you are unaware; and- we have taken all steps that we ought to have taken to make ourselves aware of any relevant audit

information and to establish that you are aware of that information.

iii All the accounting records of the council have been made available to you for the purpose of your auditand all the transactions undertaken by the council have been properly recorded in the accountingrecords and reflected in the financial statements.

iv All other records and related information, including minutes of all council and committee meetings,have been made available to you.

v The financial statements are free of material misstatements, including omissions.

vi We acknowledge our responsibility for the design and implementation of internal control to prevent anddetect error and fraud.

vii We have disclosed to you the results of our assessment of the risk that the financial statements may bematerially misstated as a result of fraud.

viii We have disclosed to you our knowledge of fraud or suspected fraud affecting the entity involving:- management;- employees who have significant roles in internal control; or

- others where the fraud could have a material effect on the financial statements.

ix We have disclosed to you our knowledge of any allegations of fraud, or suspected fraud, affecting thecouncil's financial statements communicated by employees, former employees, analysts, regulators orothers.

x Except as stated in the accounts:- there are no unrecorded liabilities, actual or contingent;- none of the assets of the council has been assigned, pledged or mortgaged; and- there are no material prior year charges or credits, nor exceptional or non-recurring items requiring

separate disclosure.

xi All related parties have been identified to you and there were no transactions with related parties nordetails of controlling interests which should be disclosed in the financial statements.

xii There are no claims, legal proceedings or other matters which may lead to a loss falling on the council orwhich could result in the creation of an unrecorded asset, that should be disclosed in the financialstatements.

xiii The council has complied with all aspects of contractual agreements that could have a material effect onthe financial statements in the event of non-compliance. There has been no non-compliance withrequirements of regulatory authorities that could have a material effect on the financial statements in theevent of non-compliance.

xiv We are not aware of any instances of actual or possible non-compliance with laws and regulations whichmight affect the view given by the financial statements .

xv We have no plans or intentions that may materially alter the carrying value or classification of assets andliabilities reflected in the financial statements.

xvi No significant events having an effect on the financial position of the council have taken place since thebalance sheet date which necessitate revision of the figures included in the financial statements orinclusion of a note thereto, other than the disclosure in note 32.

xvii We have not adjusted the misstatements brought to our attention on the audit differences andadjustments summary, attached to the ISA 260 report, for the following reasons:-

· The benefit of adjusting the accounts for £41K on a reserve of £8.547 million is consideredimmaterial to adjust, as the adjustment is less than 0.5% of the disclosed balance, which isalready based on actuarial estimates anyway.

· There are also time constraints and costs involved in requesting a supplementary FRS17 reportfrom the actuaries to disclose in the financial statements.

· The benefit of adjusting the accounts does not outweigh the cost of requesting a supplementaryactuarial statement from the actuaries.

The financial statements have been fully explained to and discussed with us.

Approval

The approval of this letter of representation was minuted by the Council at its meeting on 30 September2008.

Signed on behalf of West Devon Borough Council

Name Name

DAVID INCOLL pp JOHN FOXWORTHY

Position Chief Executive Position Head of Finance

Date 30 September 2008 Date 30 September 2008