ENTERPRISE RISK MANAGEMENT IN THE DEPARTMENT OF EDUCATION GUIDELINES July 2015 COPYRIGHT © NSW Department of Education All rights reserved. No part of this work may be reproduced or copied in any form or by any means, electronic or mechanical, including photocopying without the written permission of the publisher. Published by the NSW Department of Education Direct all enquiries to the Enterprise Risk Management Unit - contact details as follows: Level 2, 35 Bridge Street SYDNEY NSW 2000 GPO Box 33 Sydney NSW 2001 Internet and intranet references www.dec.nsw.gov.au https://detwww.det.nsw.edu.au/lists/directoratesaz/erm/index.htm https://www.det.nsw.edu.au/policies/general_man/erm/implementation_1_PD20040036.shtml?level= Version no. 1.6 Enterprise Risk Management Guidelines Contents Introduction ..................................................................................................................... 3 1. Enterprise Risk Management Principles.................................................................... 5 2. The Enterprise Risk Management Framework .......................................................... 6 3. The Risk Management Process .................................................................................. 8 3.1 Communication and Consultation .................................................................................... 8 3.2 Establishing the context .................................................................................................... 9 3.2.1 Key Stakeholders ............................................................................................. 10 3.2.2 The Business Objective ................................................................................... 10 3.2.3 Key Phases and Key Processes ..................................................................... 11 3.3 Risk Assessment .............................................................................................................. 12 3.3.1 Risk Identification ............................................................................................ 12 3.3.2 Risk Analysis .................................................................................................... 14 3.3.3 Risk Evaluation ................................................................................................. 22 3.4 Risk Treatment .................................................................................................................. 23 3.4.1 General .............................................................................................................. 23 3.4.2 Selection of Risk Treatment Options ............................................................. 24 3.4.3 Preparing and Implementing Risk Treatment Plans ..................................... 26 3.5 Monitoring and Review .................................................................................................... 26 3.5.1. Scanning Risk Sources .................................................................................. 27 3.5.2 Executive Risk Monitoring and Reporting ..................................................... 27 3.5.3 Executive Meetings .......................................................................................... 28 3.5.4 Review of the Risk Profile ............................................................................... 28 3.5.5 Monitoring and Reviewing Risk Appetite ...................................................... 29 3.5.7 Communication with the ERM Group and the Business .............................. 30 3.5.8 Executive Risk Reporting ................................................................................ 30 3.5.9 Review of the Risk Management Framework ................................................ 31 3.5.10 Reporting to the Audit and Risk Committee ................................................ 31 3.5.11 Other Risk Management Monitoring and Reporting Mechanisms ............ 32 4. References ..................................................................................................................33 Appendix 1 - Risk Reporting Templates .......................................................................34 Appendix 2 – Sample - Risk Escalation Report Template ...........................................35 Appendix 3 – Risk Register ...........................................................................................36 Appendix 4 - Sample Risk Record Template ................................................................42 Appendix 5 - Sample Risk Assessment Worksheet......................................................43 Appendix 6 - Sample Risk Assessment Template ........................................................45 Appendix 7 - Aligning Risk Management to Strategic and Business Planning, Budgeting and Performance Management ...................................................................46 Appendix 8 – Definition of Terms ..................................................................................53 Appendix 9 - Executive Meeting Agenda Items ............................................................54 Appendix 10 – Roles and Responsibilities ...................................................................55 Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 2 of 55 Enterprise Risk Management Guidelines INTRODUCTION The Department of Education (the Department) is committed to a structured and systematic approach to the management of risk across the whole organisation in accordance with current industry standards and best practice. Enterprise Risk Management (ERM) involves the management of risks that impact (either positively or negatively) on the organisational strategies used to achieve corporate objectives. During our normal day to day activities we face internal and external factors and influences that make it uncertain whether, when and the extent to which we will achieve or exceed our objectives. The effect this uncertainty has on our objectives is “risk”. Each and every one of us has a responsibility for managing risk. All our activities involve risk. We manage risk by anticipating, understanding and deciding whether to modify it. Throughout this process we communicate and consult with stakeholders and monitor and review the risk and the controls that are modifying the risk. Risks will always continue to emerge due to the increasing complexity and scope of our operations, the changing nature of our environment and our relationships with stakeholders, and the increasing need for accountability. Risk Management is an integral part of good business practice and involves the implementation of cost effective strategies such as foreseeing opportunities and/or potentially damaging events, implementing risk treatment actions, and providing decision makers with information to effectively assess potential risks. ERM encapsulates the extension of risk management from a purely business unit focus to an organisational wide operational and strategic focus. This is designed to identify the whole range and relative priority of risks that have to be managed by the organisation as a whole and allow all reasonable steps including any necessary action at Executive level to help ensure these risks are adequately managed. When effectively implemented and maintained, the management of risk enables us to a) increase the likelihood of achieving objectives b) encourage proactive management c) be aware of the need to identify and treat risk throughout the Department d) improve the identification of opportunities and threats e) achieve compatible risk management practices between our own business units and between us and other organisations f) comply with relevant legal and regulatory requirements and good practice g) improve financial reporting h) improve governance i) improve stakeholder confidence and trust j) establish a reliable basis for decision making and planning k) improve controls Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 3 of 55 Enterprise Risk Management Guidelines l) m) n) o) p) q) r) effectively allocate and use resources for risk treatment improve operational effectiveness and efficiency enhance health and safety performance as well as environmental protection improve loss prevention and incident management minimise losses improve organisational learning improve organisational resilience. The intent of these guidelines is to facilitate the implementation of the ERM policy by providing a framework that integrates the process for managing risk into our overall governance, strategy and planning, management, reporting processes, policies, values and culture, in a manner that is holistic, inclusive and consistent. Risk Management is compulsory as part of the Enterprise Risk Management in the Department of Education policy. These guidelines are provided to assist in the implementation of this Policy. These guidelines and the policy are located on both the Department’s intranet and the Internet. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 4 of 55 Enterprise Risk Management Guidelines 1. ENTERPRISE RISK MANAGEMENT PRINCIPLES The following principles have been endorsed by the Executive for use throughout the Department. 1. The Executive is committed to a management culture that embeds enterprise risk management in all departmental processes. 2. The Executive and each division will manage risk consistent with the agreed set of ERM principles and the Department’s ERM guidelines. 3. ERM forms part of all policy and operational decision making. 4. ERM is integral to planning and budgetary processes and is reflected in performance management agreements of senior executive staff. 5. Executive and division level risks are monitored, reviewed and subject to regular reporting based on the best available information. 6. ERM addresses uncertainty and at the Executive level means ‘aim for no surprises’. 7. Stakeholder relations and engagement will be risk managed in relation to any change management activity1. 8. ERM processes and tools will focus on ‘ease of use’ and integration into existing activities The above principles are in addition to the eleven listed in Australian Standard AS/NZS ISO 31000:2009 Risk management - Principles and Guidelines. Risk Management creates and protects value is an integral part of all organizational processes is part of decision making explicitly addresses uncertainty is systematic, structured and timely is based on the best available information is tailored takes human and cultural factors into account is transparent and inclusive is dynamic, iterative and responsive to change facilitates continual improvement of the organization. 1 For assistance or support with managing stakeholder relations contact the Communication and Engagement Directorate on 9561 8088 Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 5 of 55 Enterprise Risk Management Guidelines 2. THE ENTERPRISE RISK MANAGEMENT FRAMEWORK The ERM Framework helps to ensure that risk is managed across the Department in a holistic manner, is integrated into our culture, business practices and business plans, is inclusive of all levels of staff and is applied in a consistent manner. ERM supports the needs of the Department at both the Executive level as well as the division level. A two-tier collaborative risk model is shown in Figure 1, which involves strengthening and enhancing risk governance and management practices at both Executive and division levels. The approach to governing the risks at the division level recognises the diverse nature of the divisions’ activities and risks and therefore, should be tailored to the division’s operations. A principles-based approach (see previous page) to managing risks within the divisions will provide the required flexibility at division level while still enabling us to achieve a minimum required consistency of risk management across the Department and enabling divisions to demonstrate effectiveness of risk management activities. Figure 1: Two Tier Collaborative Risk Model Risks are escalated to the Executive based on consideration of the Department-wide risk environment including stakeholder expectations, community concerns, government reputation, senior management interventions, and as identified by the Executive, the Audit and Risk Committee and the ERM Group. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 6 of 55 Enterprise Risk Management Guidelines The ERM framework has focus in the following areas: Strategic or Transient Risks – risks associated with: carrying out our business objectives as articulated in high level plans; major programs/initiatives; risks that are associated with strategies that are transient or relatively short term in nature. Operational or Business-As-Usual Risks – this relates to the management of risks associated with day to day business or operational activities. Although all risks are linked (either directly or indirectly) to one or more strategic objectives, operational risks could always be present regardless of changes to strategic objectives e.g. risks related to staff and student safety. Risks are identified, documented (usually in a risk register), and managed using structured processes at all business unit levels (Department-wide, division, directorates and other business units). Corporate reporting systems are used to report achievement of objectives and management of identified risks. For information and guidance on reporting templates and how to create a risk register refer to Appendix 1, 2, 3 and 4. To support both strategic and operational risk management, we have established specific policies, procedures and guidelines to help ensure effective management of risks which include but are not limited to: o business continuity o child protection o corruption prevention o emergency planning & response o work health & safety o school excursions o school safety and security o serious incidents o offsite activities, including work placement The ERM framework provides for consistent and ongoing processes for identifying, analysing, treating/responding to, monitoring and reporting on risk so that any changes in risk exposures or areas requiring immediate action are highlighted promptly so that appropriate improvement actions can be implemented. The framework provides for the identification and assignment of risk ownership to those who have the authority and responsibility to help ensure it is managed effectively. The following section illustrates the risk management process itself. For information and guidance on how to integrate risk management with strategic and business planning, budgeting and performance management refer to Appendix 7. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 7 of 55 Enterprise Risk Management Guidelines 3. THE RISK MANAGEMENT PROCESS ERM involves the management of risks that impact on the organisational strategies used to achieve corporate objectives. The process described in this section can be used as a methodology for conducting strategic or operational risk assessments. Details of all risks within a business unit or initiative should be recorded in a risk register. The ERM process that we use is based on Australian Standard AS/NZS ISO 31000:2009 Risk management - Principles and Guidelines. This Standard provides the steps of the risk management process as shown in the diagram below. Definition of Terms relating to risk management is contained in Appendix 8. The numbers in the diagram represent the sections in this document. Figure 2: Risk Management Process (Adapted from AS/NZS ISO 31000:2009 Risk management - Principles and Guidelines) 3.1 COMMUNICATION AND CONSULTATION Communication and consultation with internal and external stakeholders should take place during all stages of the risk management process. Therefore, plans for communication and consultation should be developed at an early stage. These should address issues relating to the risk itself, its causes, its consequences (if known), and the measures being taken to treat it. Effective internal and external communication and consultation should take place to help ensure that stakeholders and those accountable for implementing the risk management process understand the basis on which decisions are made, and the reasons why particular actions are required. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 8 of 55 Enterprise Risk Management Guidelines A consultative team approach may: help establish the context appropriately help ensure that the interests of stakeholders are understood and considered help ensure that risks are adequately identified and defined bring different areas of expertise together for analysing risks help ensure that different views are appropriately considered when defining risk criteria and in evaluating risks secure endorsement and support for a treatment plan enhance appropriate change management during the risk management process develop an appropriate external and internal communication and consultation plan. Communication and consultation with stakeholders is important as they make judgements about risk based on their perceptions of risk. These perceptions can vary due to differences in values, needs, assumptions, concepts and concerns of stakeholders. As their views can have a significant impact on the decisions made, the stakeholders' perceptions should be identified, recorded, and taken into account in the decision making process. Communication and consultation should facilitate truthful, relevant, accurate and understandable exchanges of information, taking into account confidential and personal integrity aspects. Communication and consultation in the Department includes business units: reporting untreated risks through existing corporate reporting frameworks communicating the results of the risk assessment to stakeholders. For assistance or support with managing stakeholder Communication and Engagement Directorate on 9561 8088. relations contact the 3.2 ESTABLISHING THE CONTEXT The purpose of this step is to define the context and scope for the risk assessment. This involves understanding the internal and external environment in which risks occur including strategic, operational, financial, competitive, stakeholder, social, cultural and legal aspects of your functions. This will provide the structure for the risk assessment tasks that follow. In this step you will need to identify the business objectives and the strategies or key processes developed to achieve the business objectives. Below are some possible environmental characteristics that may affect the risk context: 1. Short timeframe to achieve actual results 2. Untried technology Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 9 of 55 Enterprise Risk Management Guidelines 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. Dispersed across a large number of sites 2,000+ In-house capacity limits in resources and skills/expertise to undertake all aspects of project. Long gestation period for the major deliverables around retention rates and student levels of attainment. Interdependencies with other major initiatives. Cross division impacts Reliance on infrastructure capacity external to the organisation Impact of unforeseen circumstances on school communities Market trends and competition Economic factors Completion of capital works Environmental conditions or influences Sport and recreation centres and stadia impacts Community awareness and support. 3.2.1 Key Stakeholders Key stakeholders have a significant role in risk identification as they have a vested interest in the outcomes. They include but are not limited to the following: 1. Students 6. Community 11. Disabled 2. Teachers 7. Government 12. Indigenous 3. Parents 8. Unions 13. Aged 4. Youth 9. Associations 14. Sponsors 5. Veterans 10. Lobby Groups 15. Industry Partners 3.2.2 The Business Objective The risk process is a recognition that in striving for a specific goal or outcome there are often elements or risks associated with the achievement of those outcomes. If these risks are not considered or addressed at the time of developing business plans they can delay, frustrate or cause unexpected outcomes to arise affecting the achievement of the objectives, or there may be opportunities that are missed. The primary purpose of this step is to gain some assurance we will be focusing on the correct risks, barriers, and opportunities in achieving our stated business objectives. Part of the business objective step involves ensuring we are very clear about what we are trying to achieve through the program and involves ensuring the business objective addresses the following SMART criteria: Specific Measurable Achievable Relevant Timely Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 10 of 55 Enterprise Risk Management Guidelines 3.2.3 Key Phases and Key Processes The following key phases are essential for any initiative to be effective: Planning Implementation Monitoring and reporting Evaluation and Review. Planning – this represents any key process relied on to outline how an activity is intended to be carried out (e.g. policies, procedure manuals, guidelines, business cases that identify needs, business plans that set out targets, deliverables and key milestones, implementation plans etc.). Implementation – this phase represents those key processes relied on to implement the plans from the planning phase (e.g. application of a project management discipline, application of resource allocation criteria, training, variations and change management, accountabilities, recording of actions/decisions, meetings and actioning, matching of skills to tasks, succession planning. Monitoring and Reporting – this phase represents those key processes relied on to monitor performance and progress against business plans which include targets, deliverables at key milestones on the activity and some reporting on the same. This monitoring and reporting might be in terms of KPI’s and other performance criteria set. Evaluation and Review – this phase is sometimes more commonly understood as continuous improvement and relates to some form of improvement on past mistakes, what went well, or lessons learnt. It can relate to new and innovative methods and technologies being adopted to replace existing approaches. To help you identify the type of key processes that might fall under each of the four phases the table below shows some examples. EXAMPLES OF KEY PROCESSES Planning Implementation Monitoring & Reporting Review Governance structure Consultation on changes and decisions made Regular meetings with stakeholders key players Reviewing best practice Consultation with stakeholders Compliance with guidelines, Monitoring and reporting business rules requirements Adopting new methods, technologies Policies/guidelines available to staff Application of Project management discipline Capture and reporting performance against KPI’s Abandoning failed strategies Critical milestones/targets set Allocation and matching of resources and skills Prompt remedial action on poor performance, delays, and budgetary issues Criteria for budget allocations Roll out of training Reporting requirements followed up Responsibilities and accountability requirements assigned Recording of decisions, meetings, action records succession planning, accountability for outcomes Analysis of data conducted These phases can be used to help identify where there might be gaps in key processes for the initiative which can point to potential sources of risk to the activity under consideration. Once these have been worked through we can conduct a risk analysis and risk response for the initiative. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 11 of 55 Enterprise Risk Management Guidelines 3.3 RISK ASSESSMENT 3.3.1 Risk Identification Describing risks involves two elements namely an event (or cause) and an impact (or consequence). The context and key processes defined above will set the boundaries for which risks will be included. It is critical that all risks impacting on the achievement of the business objectives are identified, whether or not they are under the control of the Department. If risks are not identified they will be excluded from analysis from this point onwards. To identify risks for each of the key business processes identified above, ask the following questions: What can go wrong (event or cause)? or What opportunities are available – how can we achieve our objectives more easily (event or cause)? and What does this lead to (impact or consequence)? It is important that you consult with people who are knowledgeable about the activity being assessed. You can identify risks through individual staff interviews or by conducting focus group meetings and workshops. The latter is recommended if the activity is complex and involves staff in more than one area. In describing risks, you should always relate the event and impact to the business objective. It helps to use terms such as “resulting in” or “due to” which link the event to the impact. An example is “Failure to meet Commonwealth objective deadline, resulting in withdrawal of current funds, loss of future funds, damage to relationship with the Commonwealth, negative media, and damage to the Department’s reputation”. This example shows that there are a number of potential impacts due to one event. This could then lead to a number of possible risk treatment options. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 12 of 55 Enterprise Risk Management Guidelines 3.3.1.1 Risk Categories The following ten risk categories can be used to facilitate easy identification of risks. These categories are the sources of risk i.e. where the risk can arise (see also Section 3.5.1). Examples of risk themes that would be grouped in each category are also provided. Note: the list is not exhaustive, it is provided as a guide. Service delivery delivery, achievement, assessment & reporting of educational and services objectives & outcomes provision of quality learning environments Aboriginal community outcomes provision of information & communication technologies school leavers with School Certificate & or Higher School Certificate Corruption & Fraud theft misappropriation conflicts of interest bribery falsification of records academic fraud favouritism in recruitment misuse of resources including communication devices corporate governance business development outcomes marketing & promotion of core activities product development service delivery market share client needs equity Human Resources attracting & maintaining key staff staff skills & qualifications staff disputes Financial revenue expenditure assets & liabilities corporate credit cards Stakeholder changes in government community expectations legislative changes unions media staff associations & councils Legal & Legislative breaches of contract public liability professional liability legislative non-compliance industry partnerships Reputation product & or service delivery stakeholder, employer & customer perceptions and expectations brand protection Health & Safety child protection student welfare staff welfare work health & safety Business Continuity technological change natural disasters strikes computer breakdowns Security intellectual property privacy of information property & equipment data integrity Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 13 of 55 Enterprise Risk Management Guidelines 3.3.2 Risk Analysis 3.3.2.1 Assess Consequence and Likelihood The purpose of this step is to rank the identified risks so that resources to treat risks are allocated to those of greater priority. We will formally analyse and assess risks to our strategy, business plans, major organisational change, major projects and programs. All risks identified at the Department and division level will be assessed in the residual terms using the Department-wide risk consequence and likelihood criteria. To evaluate the risk level, you will need to first assess the risk consequence by identifying the potential consequences of a risk event occurring. The 'Department-wide consequence criteria’ is used to estimate a potential impact which a risk might have on the achievement of the Department/division objectives (both in terms of negative consequence (threats – see Tables 1 & 2) or positive consequence (opportunities – see Tables 3 & 4). Select the appropriate table. The risk consequence is either positive or negative – not both. The percentage of appropriate baseline amount as indicated in the ‘Financial’ consequence category should be applied to the Department budget or a division budget accordingly to facilitate an appropriate calibration of the risk consequence across the Department. The consequence is the impact or effect that the risk could have on the outputs or outcomes in the listed Risk Focus areas. The Risk Focus areas may be different than the Risk Categories used for identification of the risks (Section 3.3.1.1) because they are more to do with the results of the risk eventuating rather than the source of the risk. The risk likelihood will then be considered using the ‘Department-wide likelihood criteria’ by determining the probability of the risk occurring with the identified consequences. Existing or planned controls should be taken into consideration when determining the risk likelihood. The risk consequence and likelihood criteria are provided in the tables below. Additional risk consequence tables have been provided to facilitate an assessment of project/program specific risks. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 14 of 55 Enterprise Risk Management Guidelines Risk Focus Table 1 - Department-Wide Negative Consequence Criteria (Threats) (The potential negative impact on the objectives and resources) Service / Program delivery Insignificant (1) Minor (2) Moderate (3) Major (4) Critical (5) Virtually no change in operations Can be accommodated with existing resources Impact can be absorbed with treatment but will require additional resources to be allocated Delivery of academic or community/program outcomes compromised for identified groups Significant review/changes to programs required The Department/Business unit may not meet its objectives and will require considerable additional resources from other areas Outcome of a major program not achieved resulting in decline of academic/community outcomes Significant review of implementation of program required Interrupt the development of essential infrastructure Ministerial inquiry Loss, error or omission > 10% to 15% of the appropriate baseline amount, e.g.: o Program budget o Annual budget o Projected revenue The Department will not meet its objectives Academic or community/ Academic or community/ program outcome compromised Resolved by routine operations A Financial B Management Effort C Health & Safety Loss, error or omission up Loss, error or omission > 1% Loss, error or omission > 5% to to 1% of the appropriate baseline amount, e.g.: o Program budget o Annual budget o Projected revenue An event, the impact of which can be absorbed through business as usual activity First Aid treatment Graffiti, vandalism E Reputation / External relationships F to 5% of the appropriate baseline amount, e.g.: o Program budget o Annual budget o Projected revenue An event, the consequences D Legal / Compliance program outcome compromised Minor impact on efficiency or effectiveness, managed internally of which can be absorbed but management effort is required to minimise the impact Potential reallocation of resources within a division Significant but reversible disability requiring hospitalisation Situation requiring lockdown in school, or cessation of operations in offices 10% of the appropriate baseline amount, e.g.: o Program budget o Annual budget o Projected revenue Permanent disabling injury or Single fatality and/or irreversible disability to one or Series of fatalities or significant Pandemic effect in a few schools, between the divisions fine operations Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 public, limited / localised media interest, specific internal reporting Local industrial action Requiring Treasury approval An event so severe in nature it Additional resources required Significant management effort in a contingency mode under normal circumstances Little or no effect on stakeholder with no publicity, only routine internal reporting 15% of the appropriate baseline amount, e.g.: o Program budget o Annual budget o Projected revenue Additional resources required Potential reallocation of resources Local adverse publicity Visible dissatisfaction from Loss, error or omission is above An event, which with proper management can be Minor legal issues, non- Little or no publicity Attention from minor in significant decline in academic/community outcomes Significant damage to reputation of public education Ministerial inquiry An event that can be managed Minor compliance issues Offence punishable by compliances and breaches of regulation Offence possibly punishable by fine Effect managed at local level Not requiring Treasury approval Programs not delivered, resulting disabling illness to one or more persons Teaching/learning compromised Litigation Increasing incidence of injury Local increase in workers compensation costs Breach of regulation with investigation or report to authority with prosecution powers Offence punishable by fine Effect on the Department’s operations Litigation State wide adverse publicity Short term damage, public embarrassment of the Department, restricted negative publicity from local media, internal inquiry State-wide industrial action (e.g. bans) endured. May involve some changes in management more persons Pandemic effect in a school or corporate office Breach of school security/destruction of buildings Widespread increase in workers compensation costs Major breach of regulation Shutdown of service for non-compliance Offence punishable by imprisonment Ministerial inquiry could lead to a significant restructure of the business or its major parts or a change in the management structure irreversible disability offices, or centres Significant prosecution and fines Shutdown of multiple services for non-compliance Major consequences to a person, agency Parliamentary scrutiny Sustained state wide adverse publicity Mainstream media reports, new oversight required, Resignation and or removal of community dissatisfaction Ministerial inquiry Persistent questions in Parliament, external inquiry e.g. inquest Industrial action affecting statewide service delivery Minister and or the Department’s senior staff Broad public concern, media event, senior resignations/ removals, Parliamentary Inquiry July 2015 15 of 55 Enterprise Risk Management Guidelines Project / Program Threats Table 2 – Negative Consequence Criteria (Threats) – Projects / Programs Risk Focus (The potential negative impact on the objectives and resources) Insignificant (1) Minor (2) Moderate (3) Major (4) Critical (5) No change in projects Can be accommodated with existing resources Impact can be absorbed with treatment but will require additional resources to be allocated The program will require considerable additional resources from other areas The program may not be delivered Negligible quality issues with no effect on objective Quality Objective achieved but quality diminished slightly Objective achieved but quality diminished substantially Substantial part of objective not met for quality reasons Outputs/outcomes are not delivered G Time Quality issues lead to nonachievement of objectives Project/Program/Service delayed by up to 5% Project/Program/Service delayed > 5% to 10% Project/Program/Service delayed > 10% to 20% Project/Program/Service delayed > 20% to 30% Delay causes objective to not be achieved Up to 1% variance to budget > 1% to 5% variance to budget > 5% to 10% variance to budget > 10% to 15% variance to budget but not requiring Treasury approval Over 15% variance to budget or requiring Treasury approval Up to 5% not delivered > 5% to 20% not delivered > 20% to 30% not delivered > 30% to 50% not delivered > 50% not delivered H Cost I Benefits J Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 16 of 55 Enterprise Risk Management Guidelines Risk Focus Table 3 - Department-Wide Positive Consequence Criteria (Opportunities) (The potential positive impact on the objectives and resources) Service / Program delivery A Insignificant (1) Minor (2) Moderate (3) Major (4) Critical (5) Negligible improvement in ability for the Department/Business unit to meet its objectives Negligible improvement in academic or community/ program/service outcomes Changes implemented by routine operations Minor improvement in ability for the Department/Business unit to meet its objectives Moderate improvement in ability for the Department/Business unit to meet its objectives Major improvement in ability for the Department/Business unit to meet its objectives Significant improvement in ability for the Department to meet its objectives Minor improvement in academic or community/ program/service outcomes Minor improvement in efficiency or effectiveness Moderate improvement in delivery Financial D community/program/service outcomes Major improvement in ability to implement program Major improvement in the development of essential infrastructure Major improvement in utilisation of state assets Major improvement in community participation & access E Reputation / External relationships academic or community/program/service outcomes Significant improvement to reputation of public education Saving or benefit > 15% of the An event, the impact of An event, the impact of which results in a major An event, the impact of which which slightly reduces the management effort required of the appropriate baseline amount, e.g.: o Program budget o Annual budget o Projected revenue the appropriate baseline amount, e.g.: o Program budget o Annual budget o Projected revenue reduces the management effort required Potential to free up resources within a division results in a moderate reduction in the management effort required Potential to free up resources between the divisions An event, the impact of which An event, the impact of which baseline amount, e.g.: o Program budget o Annual budget o Projected revenue reduction in the management effort required Resources can be released for other functions appropriate baseline amount, e.g.: o Program budget o Annual budget o Projected revenue significantly reduces the management effort required Able to free up resources, reallocate responsibilities, and significantly realign functions Negligible effect on health Minor preventative measures Moderate improvements in and safety prevention and control Minor improvements in site Negligible effect on site security and controls Moderate improvements in site security security Minor improvement in Positive improvement in reputation Little effect on reputation reputation Major improvements in prevention and control Major improvements in site security Major improvement in reputation and community/ Negligible improvement in Minor improvement in Moderate improvement in Significant improvement in Major improvement in compliance ability Large change in behaviours Positive cultural change Proactive approach Sustained state wide positive publicity Mainstream media reports, community satisfaction Ministerial supportive comments Positive reinforcements in Parliament stakeholder interest and community interest Legal / Compliance Significant improvement in Saving or benefit > 10% to 15% of the appropriate of the appropriate baseline amount, e.g.: o Program budget o Annual budget o Projected revenue C Health & Safety Major improvement in academic or Saving or benefit up to 1% Saving or benefit > 1% to 5% Saving or benefit > 5% to 10% of B Management Effort of academic or community/ program/service outcomes for identified groups Moderate improvement in efficiency or effectiveness Moderate improvement in utilisation of state assets Moderate improvement in community participation & access compliance ability Little effort required Modest positive publicity Modest positive attention from minor stakeholders F Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 compliance ability Process improvements assist with a proactive approach Local positive publicity Visible satisfaction from public, limited / localised media interest compliance ability Positive cultural change Process improvements assist with a proactive approach State wide positive publicity Short term improvements, public interest in the Department, positive publicity from local media Significant improvements in prevention and control Significant improvements in site security Significant improvement in reputation and community/ stakeholder interest compliance ability with cultural change and a proactive approach Significant improvement in reputation and community / stakeholder interest Significant recognition leading to major improvement in community and stakeholder support Broad public interest, media event July 2015 17 of 55 Enterprise Risk Management Guidelines Project / Program Opportunities Table 4 - Positive Consequence Criteria (Opportunities) – Projects / Programs Risk Focus (The potential positive impact on the objectives and resources) Insignificant (1) Minor (2) Moderate (3) Major (4) Critical (5) Small change in projects Minor improvements in outcomes Moderate improvements in outcomes Major improvements in outcomes Significant improvements in outcomes Negligible effect on objective Quality Objective achieved Quality starting to exceed expectations G Objective achieved Moderate increase in outcomes Exceeding expectations Major increase in quality Greatly improved outcomes High level of stakeholder satisfaction Exceeding expectations Significant increase in quality Significantly improved outcomes High level of stakeholder satisfaction Greatly Exceeding expectations Time Project/Program/Service improved by up to 5% Project/Program/Service improved by > 5% up to 10% Project/Program/Service improved by >10% up to 20% Project/Program/Service improved by >20% up to 30% Project/Program/Service improved by > 30% Up to 1% below budget > 1% to 5% below budget > 5% to 10% below budget > 10% to 15% below budget >15% below budget Negligible increase in planned benefits Minor increase in benefits over those planned Moderate increase in benefits over those planned Major increase in benefits over those planned Significant increase in benefits over those planned H Cost I Benefits J Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 18 of 55 Enterprise Risk Management Guidelines Department-Wide Likelihood Criteria How likely is it that the Department will be exposed to this specific risk (looking at both the event (cause) and the impact (consequence)) considering factors such as: Anticipated frequency The external environment The procedures, tools, skills currently in place Staff commitment, morale, attitude History of previous events. The ‘Description’ column in the following table is to be used as a guide only. Not all initiatives will align to the time frames shown. Description of Likelihood Ratings Likelihood Rating Description Probability 5 Almost Is expected to occur in most circumstances > 95% to 100% Certain - frequently during the year 4 Likely Will probably occur > 70% to 95% - once during the year 3 Possible Might occur at some time > 30% to 70% – once every 3 years 2 Unlikely Could occur at some time > 5% to 30% – once every 5 years 1 Rare May only occur only in exceptional < 5% circumstances This event is known to have occurred elsewhere – once every 5+ years Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 19 of 55 Enterprise Risk Management Guidelines 3.3.2.2 Determine Risk Level Having assessed the consequence and likelihood of major risks, a risk level will be determined using the Department-wide risk matrix. Risks which may have a larger consequence and a higher likelihood on business operations will have a higher priority rating than those with a minor consequence and lower likelihood. Likelihood/consequences matrix L I K E L I H O O D Almost Certain 5 Extreme Risk Likely 4 High Risk Medium Risk Possible 3 Unlikely 2 Low Risk Rare 1 Insignificant 1 Minor 2 Moderate 3 Major 4 Critical 5 CONSEQUENCE Risk treatment and escalation/delegation guidelines: Risk Level Extreme High Medium Low Risk Treatment Guidelines Division Risk Escalation Guidelines Department-Wide Risk Delegation Guidelines Immediate action required to actively manage risk and limit exposure Escalate to the division head and the Executive The Executive responsibility and accountability Cost / benefit analysis required to assess extent to which risk should be treated - monitor to help ensure risk does not adversely change over time Escalate to the division head The Executive responsibility and accountability Constant / regular monitoring required to help ensure risk exposure is managed effectively, disruptions minimised and outcomes monitored Escalate to the General Manager, Executive Director, and Directors. Specify risk management responsibility and accountability Assign accountability to the General Manager, Executive Director, and Directors Effectively manage through routine procedures and appropriate internal controls Monitor and manage at the middle and operational management level Monitor and manage at the middle and operational management level Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 20 of 55 Enterprise Risk Management Guidelines 3.3.2.3 Cognitive Bias The effectiveness of risk management is dependent on sound risk assessments. Even if we have all the well-designed processes, methods and tools for risk management, risk assessment is ultimately an activity that requires subjective judgement. Although there may be other causes for faulty risk assessments, cognitive biases can be particularly pervasive. If unchecked, these biases can lead to systematic decision-making errors and faulty risk assessments. Cognitive biases include: Anchoring: relying too heavily, or ‘anchoring’, on one aspect or piece of information when making decisions Bandwagon (or herd) effect: doing (or believing) something because many other people do (or believe) the same Confirmation bias: looking for evidence to justify preconceived ideas Framing effect bias: arriving at conclusions based on how information is presented Optimism (or over-confidence): overestimating the likelihood of favourable outcomes. Recognising these biases is the first step in minimising their impact on your risk assessment. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 21 of 55 Enterprise Risk Management Guidelines 3.3.3 Risk Evaluation The purpose of this step is to develop a prioritised list of risks requiring attention. When the risk has been rated, the risk level needs to be compared with management’s acceptable level of risk (tolerance). If the level of a risk with a negative consequence (threat) is at or below management’s acceptable level then the risk is at an acceptable level and no additional risk treatment is required at this stage. This risk would be managed by ongoing monitoring and be subject to review in the next risk assessment. If the level of a risk with a negative consequence (threat) is above management’s acceptable level of risk then the risk is at an unacceptable level and additional risk treatments may be required to reduce the risk to management’s acceptable level. If the level of a risk with a positive consequence (opportunity) is low or medium but could be increased (improved) with reasonable steps (subject to cost/benefit analysis) then it is at an unacceptable level and additional risk treatments may be required. If the level of a risk with a positive consequence (opportunity) is high or extreme it may be at an acceptable level so no additional risk treatment may be required (subject to cost/benefit analysis) at this stage. This risk would be managed by ongoing monitoring and be subject to review in the next risk assessment. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 22 of 55 Enterprise Risk Management Guidelines 3.4 RISK TREATMENT 3.4.1 General The purpose of this step is to identify the most appropriate treatments for risks that are at an unacceptable level. Risk treatment involves selecting one or more options for modifying risks, and implementing those options. Once implemented, treatments provide or modify the controls. Risk treatment involves a cyclical process of: assessing a risk treatment deciding whether residual risk levels are tolerable if not tolerable, generating a new risk treatment assessing the effectiveness of that treatment. Risk treatment options are not necessarily mutually exclusive or appropriate in all circumstances. Select the best options in terms of feasibility and cost effectiveness. The options can include the following: Avoiding the risk by deciding not to start or continue with the activity that gives rise to the risk Taking or increasing the risk in order to pursue an opportunity Removing the risk source Changing the consequences Changing the likelihood Sharing the risk with another party or parties (including contracts, insurance, and risk financing) Retaining the risk by informed decision. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 23 of 55 Enterprise Risk Management Guidelines 3.4.2 Selection of Risk Treatment Options 3.4.2.1 Cost / Benefit Analysis Selecting the most appropriate risk treatment option involves balancing the costs and efforts of implementation against the benefits derived, with regard to legal, regulatory, and other requirements such as social responsibility and the protection of the natural environment. Decisions should also take into account risks which can warrant risk treatment that is not justifiable on economic grounds, e.g. severe (high negative consequence) but rare (low likelihood) risks. A number of treatment options can be considered and applied either individually or in combination. The organisation can normally benefit from the adoption of a combination of treatment options. 3.4.2.2 Stakeholder Analysis When selecting risk treatment options, the organisation should consider the values and perceptions of stakeholders2 and the most appropriate ways to communicate with them. Where risk treatment options can impact on risk elsewhere in the organisation or with stakeholders, these should be involved in the decision. Though equally effective, some risk treatments can be more acceptable to some stakeholders than to others. The treatment plan should clearly identify the priority order in which individual risk treatments should be implemented. 3.4.2.3 Control Effectiveness Risk treatment itself can introduce risks. A significant risk can be the failure or ineffectiveness of the risk treatment measures. Monitoring needs to be an integral part of the risk treatment plan to give assurance that the measures remain effective. Risk treatment can also introduce secondary risks that need to be assessed, treated, monitored and reviewed. These secondary risks should be incorporated into the same treatment plan as the original risk and not treated as a new risk. The link between the two risks should be identified and maintained. The purpose of a control or treatment is to provide reasonable assurances in terms of effective management of the risk in meeting the residual risk rating. At the beginning, and throughout the life of a risk, there will be a need to make judgements on whether or not existing controls are adequate. It may be useful to reflect on past experience and examine instances where there has been exposure to loss and why this has occurred. Alternatively, a simulation of the risk scenario may prove a useful exercise to test the effectiveness of current controls e.g. emergency fire drill. There may be a number of controls or treatments in place to manage a particular risk. The control effectiveness assessment would then apply to the set of controls for that risk. Control Effectiveness can be either a subjective assessment or an objective assessment of how effective the control or set of controls is in meeting the risk’s Residual Risk Rating. 2 For assistance or support with managing stakeholder relations contact the Communication and Engagement Directorate on 9561 8088. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 24 of 55 Enterprise Risk Management Guidelines Subjective Assessment A subjective assessment can be made by simply deciding, based on current knowledge of the situation, whether the control effectiveness is Excellent, Good, Fair, or Poor. Objective Assessment For a more objective, evidence-based method, perhaps on more critical risks, an assessment of the control effectiveness could be undertaken by using the Control Practices Matrix shown below in Table 5. This provides a simple way of objectively determining the adequacy of your existing controls (adapted from Tasmanian Critical Infrastructure Risk Management Guidance Manual). Table 5 - Control Practices Matrix Does the control address the risk effectively? Is the control officially documented and communicated? Is the control in operation and applied consistently? Yes 1 1 1 Partly 3 2 2 No 6 3 3 + Add Scores + = Total Score By comparing the total score from Table 5 with the score in the rating table (Table 6), a quick assessment of the effectiveness (not necessarily efficiency or economy) of controls may be ascertained. Table 6 - Control Effectiveness Rating Table Score Rating Description 3 Excellent Control addresses risk, is officially documented and in operation and applied consistently. 4 Good Control addresses risk, but documentation and/or operation of control could be improved. 5–6 Fair Control addresses risk, at least partly, but documentation and/or operation of control could be improved. 7 – 12 Poor At best, control addresses risk, but is not documented or in operation; at worst control does not address risk and is neither documented nor in operation. Ideally “Excellent” or “Good” ratings should be sought for all controls. Risks that are well controlled will have a lower consequence or likelihood depending on the control. The Control Effectiveness assessment is a tool for managing the risk. The results can be recorded in the Risk Record (see Appendix 4). Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 25 of 55 Enterprise Risk Management Guidelines 3.4.3 Preparing and Implementing Risk Treatment Plans The purpose of risk treatment plans is to document how the chosen treatment options will be implemented. The information provided in treatment plans should include: the reasons for selection of treatment options, including expected benefits to be gained those who are accountable for approving the plan and those responsible for implementing the plan proposed actions resource requirements including contingencies performance measures and constraints reporting and monitoring requirements timing and schedule. Treatment plans should be integrated with the management processes of the organisation and discussed with appropriate stakeholders. Decision makers and other stakeholders should be aware of the nature and extent of the residual risk after risk treatment. The residual risk should be documented and subjected to monitoring, review and, where appropriate, further treatment 3.5 MONITORING AND REVIEW Risk monitoring and review is an integral step in the risk management process. It enables us to proactively identify changes on the risk profile and adjust the organisational response as required. It also enables us to understand the effectiveness (impacts, benefits and costs) of implementing risk management strategies. Risk monitoring and review is a continuous process and is essential that our risk priorities and risk management plans remain relevant in the changing environment we operate in. Risk management is responsive to change. Continuous monitoring and review of the external and internal risk environment is required to help shape the context and understanding of our risk profile, change in the risk ratings, identification of new risks, or taking risks off the radar. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 26 of 55 Enterprise Risk Management Guidelines 3.5.1. Scanning Risk Sources Environmental scanning is an important part of the monitoring framework and involves analysis of multiple sources of risk information as depicted in Figure 3 below. Risk Profile Figure 3: Sources of risk information Environmental scanning by the Executive, senior division officers, and the ERM Group assists to identify new and emerging risks from external and internal environment through: Analysis of Political, Economic, Social, Technological, Environmental factors, Government policies and other regulatory environment Interviews or meetings with the Executive and Directors Interviews or meetings with staff and stakeholders External reports and papers from recognised subject matter experts Consideration of our operations, systemic issues arising from incidents analysis, audit results and other historical risk information. 3.5.2 Executive Risk Monitoring and Reporting The Executive monitors the risk profile and associated risk treatment strategies (as detailed in the Executive Risk Register) using the following approaches: Executive meetings Formal risk profile and risk appetite reviews ERM Group reports to the Executive Early escalation of emerging risks. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 27 of 55 Enterprise Risk Management Guidelines 3.5.3 Executive Meetings Executive meetings are important forums for tracking movements on the risk profile and the implementation of key risk treatment strategies. The Executive meets on a regular basis to monitor performance against the strategic initiatives and monitor the risks. The Executive considers risks at the following meetings: Monthly Executive meetings include discussion on performance matters, emerging threats and opportunities, and major ongoing concerns The Secretary/division head regular face-to-face meetings include discussion on major division risks Monitoring of strategy and major projects includes review of the risk profile and risk treatment activities quarterly by the Executive. A Risk Escalation Report and details of overdue/partially completed risk treatment activities in relation to high and extreme risks are reviewed as part of these meetings. Refer to Appendix 2 for a Risk Escalation Report example. Refer to Appendix 9 for the Executive risk meetings agendas. 3.5.4 Review of the Risk Profile The risk profile is an important source of risk information, represented by the Executive Risk Register, which contains the most significant risks faced by the Department as a whole and includes the following: Strategic and operational risks Major division risks escalated to the Executive via the ERM Group Risks representing strategic projects or major initiatives Escalated risks will procedurally progress to the Audit and Risk Committee. The profile is collaboratively reviewed by the Executive on a quarterly basis. A formal quarterly refresh of the risk profile includes revision of the risk ratings taking into account the progress against risk treatment activities. New and emerging risks are considered for the inclusion on the risk profile A comprehensive annual review of the risk profile and risk appetite is performed as part of the Executive Strategy Day. The profile monitoring is an integral part of monitoring business performance and is underpinned by the following: Prioritisation of the major strategic risks which may have impact on the Corporate Plan Prioritisation of the top division risks, including risks which may have impact across the divisions Identification and prioritisation of new or emerging risks which may have a significant impact Monitoring of key performance indicators of major projects and initiatives which constitute areas of significant risk. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 28 of 55 Enterprise Risk Management Guidelines To help ensure that the risk profile is relevant, up to date and effectively managed, the Executive risk review approach addresses the following: Alignment of the risks to strategic priorities Risk magnitude Key treatment strategies in place to manage the risk Effectiveness of the current risk treatment activities Movements in the risk ratings Initiatives to address risks which are above risk appetite or to strengthen risk management processes Accountabilities assigned to implement the risk treatment strategies and associated due dates Sufficiency of resourcing requirements to implement the risk treatment strategies. Where the risk rating increases or potential risks are identified, the Executive considers the adequacy of the current risk treatment activities. The following questions may be considered: Are the assumptions relating to the risk context (including environment, technology and resources) still relevant? Is the risk treatment activity effective in managing the risk? How it can be improved? Are there performance measures or indicators in place to measure key outcomes? Does the risk management activity comply with legal requirements, government and departmental policies? 3.5.5 Monitoring and Reviewing Risk Appetite The risk appetite is explicitly described in the risk management policy and accurately reflects the Department’s attitude to the amount of acceptable risk “The Department is committed to delivering long term sustainable academic and community outcomes by managing effectively and pursuing strategies which include the safety of students, staff and the community as the Department’s number one priority. In advancing those strategies, the Department takes due consideration of the protocols relating to risk identification, assessment and escalation (including consequence and likelihood determinations based on the risk matrix).” The risk appetite is reflected in the construct of the risk matrix (the more red, the more risk averse), and the risk consequence tables (e.g. what impact constitutes a critical consequence?). The risk consequence tables and risk appetite are reviewed annually by the Executive in conjunction with the changes in strategic priorities and budget. Risk tolerance is the variation of risk level that the organisation is prepared to accept around a specific objective. Risk tolerance is reflected in the risk consequence tables in conjunction with the escalation / delegation criteria. Risk tolerance is also reflected in the Executive and Division Risk Registers as the acceptable risk rating (residual or target) for each of the risks. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 29 of 55 Enterprise Risk Management Guidelines 3.5.6 Emerging Risk Identification All staff members are responsible for ensuring new and emerging risk areas are captured, monitored and escalated appropriately through existing communication channels. Monthly Executive meetings include discussion on emerging threats and opportunities. 3.5.7 Communication with the ERM Group and the Business The ERM Group supports the Executive risk monitoring activities by performing an environmental scan, coordinating management and monitoring of cross-division risks, and monitoring of the strategic risks. The Executive consults the ERM Group on practical risk treatment approaches. Where risks are escalated from the division risk profiles or where risks have a cross-division effect, the Executive agrees on the high level risk treatment strategies and consults the ERM Group to determine specific actions to implement identified risk treatment strategies and to monitor them. Top down communication from the Executive is performed formally to all appropriate levels of the business to help ensure that the business remains engaged and informed of the risk management approach. 3.5.8 Executive Risk Reporting Risk reporting supports the Executive discussion and decision-making on major risks and business priorities. Executive risk reports are prepared by the ERM Group quarterly. The reports are focussed on high and extreme risks and highlight “hot spots” on the Executive Risk Profile including: Risk description Reference to the strategy (target) Residual risk ratings Target risk ratings Movements in risk ratings Reference to a division (if applicable) Reference to a risk treatment strategy Accountability (risk ownership) Status of risk treatment strategies Assurance activities in place to assess the management of the risk High level overview of the significant risks/risk areas facing the Department (including emerging threats and opportunities). For major initiatives, dashboard reports are provided (similar in format to that shown in Appendix 2) which include details of overdue or partially implemented risk treatment strategies and the following information: Description Commentary Budget Accountability and Due date. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 30 of 55 Enterprise Risk Management Guidelines The dashboard report is supported by a commentary including highlights of the semiannual environmental scan and analysis of systemic issues and trends arising from historic information such as incidents and internal audit findings or resource implications for additional risk treatment activities. Progress on performance against expected outcomes for major projects by reviewing key risk performance indicators for major initiatives is reported as part of the business performance reporting. This information contributes to the monitoring of major risks associated with these projects. Full details of the roles and responsibilities of divisions, the Executive and the ERM Group are outlined in Appendix 10. 3.5.9 Review of the Risk Management Framework The risk management framework is subject to review to meet the requirements of the NSW Treasury Internal Audit and Risk Management Policy for the NSW Public Sector (TPP 15-03) and current risk management standards (AS/NZS ISO 31000:2009). The review includes the following: Annual review of the Department’s risk profile and division risk profiles in conjunction with the self-assessment of the achievement of strategic objectives and progress against the strategic initiatives Self-assessment of the ERM Group performance in accordance with the ERM Group Charter An independent review of the risk management function and process every two years A review of divisions’ alignment with the risk management principles. Significant changes to operations should prompt a review and update of the risk management framework to help ensure that it remains appropriate to support business needs. 3.5.10 Reporting to the Audit and Risk Committee The results of the risk management framework review are reported to the Audit and Risk Committee which will include recommendations for improvement. The Audit and Risk Committee also reviews an Assurance Plan for the upcoming financial year and helps to ensure linkage to the following areas: NSW Treasury Audit Office of NSW Internal audit External accreditation audits. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 31 of 55 Enterprise Risk Management Guidelines 3.5.11 Other Risk Management Monitoring and Reporting Mechanisms We have a number of mechanisms which assist in the ongoing management of risks. These include but are not limited to the following: A summary of the Executive Risk section of the Executive Risk Register is provided to the Minister on a quarterly basis. The latest versions of the Executive Risk Register (high and extreme risks only) and the Division Risk Register (all significant risks) are uploaded to the Executive Information System (EIS). These are then available at any time to each member of the Executive and each member of the ERM Group All risk policy, procedural, and guidelines documents and updates, in addition to copies of the Executive Risk Register and Escalation Reports are provided to the Audit and Risk Committee for their review Strategic priorities are monitored at weekly meetings of the Minister and the Secretary Quarterly reports on performance against plans provided to the Minister and NSW Treasury The Audit Directorate is responsible for performing reviews on key operational areas The Auditor Office of NSW acts as an external assurance provider. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 32 of 55 Enterprise Risk Management Guidelines 4. REFERENCES AS/NZS ISO 31000:2009 Risk management - Principles and Guidelines Standards Australia (and related standards and handbooks) HB 89-2012, Risk management - Guidelines on risk assessment techniques Standards Australia Enterprise-Wide Risk Management Better Practice Guide for the Public Sector, Certified Practising Accountants Australia, 2002 Risk Management Training Program, Queensland Government, February 2003 Risk Management in the Public Sector, Risk Management Workshop conducted by Business Excellence Australia – Standards Australia 06/02 01.03 Benchmarking Strategic Risk Management against Australian Government, Australian Public Service Commission’s publication titled: ‘Contemporary Government Challenges – Building Better Governance’ published 2007 Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 33 of 55 Enterprise Risk Management Guidelines APPENDIX 1 - RISK REPORTING TEMPLATES The following templates are suggested for use in monitoring, reporting, and managing risks. Each report carries different levels of detail appropriate for its own use. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 34 of 55 Enterprise Risk Management Guidelines APPENDIX 2 – SAMPLE - RISK ESCALATION REPORT TEMPLATE Summary: Key Comments: Risk Profile Health Governance Budget Stake Holder WH&S Child Welfare State Targets Business Continuity LMBR EIM Other This Report Last Report No major risks Major risks but treatment in place Major risks – ineffective or no treatment Governance Risk Triggers Impact Treatment Triggers Impact Treatment Triggers Impact Treatment Triggers Impact Treatment Budget Risk Stakeholder Risk Work Health & Safety Risk Student Welfare and Child Protection Risk Triggers Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 Impact Treatment July 2015 35 of 55 Enterprise Risk Management Guidelines APPENDIX 3 – RISK REGISTER (See also Recording Risk Information – Appendix 7 Section 8) The purpose of a risk register is to provide a central repository or focal point of identified risks that can be monitored and reviewed on a regular basis by both internal and external stakeholders. Risk information gained through conducting risk assessments should be documented and maintained in the register. The Executive Risk Register following is included as a guide only. The risk assessment will provide managers with information to assist them to manage risks remaining at an unacceptable risk level. The strategic and operational risk assessments should be updated at least annually and or at times when new and emerging risks may arise for example, the introduction of new business products, processes, systems and or services. The creation and application of a risk register leads to improved management decision making as it helps to: identify managed and unmanaged risks especially during the planning cycle evaluate the severity of any identified risk apply possible solutions to those risks through a systematic approach monitor and analyse the effectiveness of actions taken to treat the risks. When risks are effectively managed, the confidence level in achieving goals and objectives is increased. By creating and maintaining risk registers across the Department, stakeholder engagement will increase through communication and the accountability and escalation of risks. There is no standard list of components that should be included in the risk register. The Department’s Executive Risk Register (ERR) is being used here as a model. The format of the detailed ERR is shown below. Item no. Risk Type 1 1a. Corporate Strategic Services Threat C L Residua l Rating A4 3P High B4 C4 F4 Maj Division Target (Strategic Objective) Planned Action (to Risk achieve objective) No. New & Better Effective 66 Ways of Doing management of Business the implementation of the program. R Additional Target Treatments Risk Needed Rating Continue to High monitor. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 T Exec Owner KPI Identified Risk Existing Treatments ABCD Program does not deliver timely services or....... Development of program assurance... Continued Revision of strategic focus... Internal Audit Assurance DepSec Program delivery KPIs - Project CS - Successful introduction 9999 of ABC. Shared service risk - Development and assessment implementation.... / audit.... Program Mgt KPIs... - Project 8888 – Gap analysis... Other Internal Assurance External Assurance - DoE ABCD Audit & Risk SubCommittee oversight.... - CPMG has been engaged in.... - Audit Office of NSW conducted.... July 2015 36 of 55 Enterprise Risk Management Guidelines The Detailed Register is sorted in the following sequence – ‘Risk Type’ = Strategic Risk (threat or opportunity) first, listing the highest ‘Residual Rating’, then grouped by ‘Division’ in alphabetical order. Operational Risk follows, then Division Risk. The columns are described below: 1. Item no. – This number relates to the item number on the detailed Executive Risk Register. This number may change as risks are removed, added, escalated or de-escalated. 2. Risk Type – Strategic Threat or Opportunity, Operational Threat or Opportunity, and Division Threat or Opportunity. 3. Division – The Division responsible for the risk. 4. Target or Strategic Objective – A brief description of the target or strategic objective that the risk relates to. This may come directly from the State Plan, Corporate Plan, or other high level sources. Currently we have a list of 5 Strategic Objectives. Each risk should be aligned to one of these objectives. a. Fostering Opportunity and Partnership with Aboriginal People b. High Expectations, Closing the Gap c. New and Better Ways of Doing Business d. Quality Teaching and Leadership e. Safety & Welfare of our People 5. Planned Action – The action(s) required to achieve the target or strategic objective. This is a brief description of the planned actions or initiatives that are being undertaken to achieve the strategic objective. This is not the risk. However, it could be used to help identify a risk. For example, what could stop us from achieving our objective? What could prevent us from completing the planned action? 6. Risk No. – A unique number given to each individual risk. There may be more than one risk linked to each strategic objective. These numbers are not necessarily sequential in the listings as the risks may be removed, added, escalated or de-escalated as time progresses. 7. Identified Risk – In describing risks, you should always relate the event and impact to the business objective. It helps to think of an event “resulting in” an impact, or an impact “due to” an event. An example is “Failure to meet Commonwealth objective deadline, resulting in withdrawal of current funds, loss of future funds, damage to relationship with the Commonwealth, negative media, and damage to the Department’s reputation”. This example shows that there are a number of potential impacts due to one event. This could then lead to a number of possible risk treatment options. The previous example had the event first. You could also have the impact first, e.g. “Loss of funding due to failure to meet Commonwealth objective deadline”. The first example is better suited to multiple impacts. The description should relate to each of the consequences that are identified in the consequence rating column (Service/Program Delivery, Financial, Management Effort, Health & Safety, Legal/Compliance, Reputation/ External Relationships etc.). 8. Existing Treatments – Relates to current or existing treatments, strategies or controls either in-place or planned to achieve the Residual Risk rating. Each risk should include treatments for each of the consequences referred to in the consequence rating column (although one risk treatment may cater for more than one consequence). 9. C – Consequence Rating from the DEC Enterprise Risk Management Guidelines (see Legend on page 2). There can be multiple consequence ratings as a risk can affect multiple categories e.g. financial, reputation, compliance etc. Each of these consequences should be referred to in the ‘Identified Risk’ description, with treatments for each included in the ‘Existing Treatment’ column. 10. L – Likelihood (Rating) of the risk occurring with the predetermined Consequence Rating and with the risk treatments, strategies or controls either in-place or planned – from the DEC Enterprise Risk Management Guidelines (see Legend on page 2). 11. Residual Rating – The estimated risk rating based on the predetermined consequence and likelihood ratings with the current or existing treatments, strategies or controls (planned or inplace). Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 37 of 55 Enterprise Risk Management Guidelines 12. Additional Treatment Needed – If the Residual Rating is unacceptable, additional treatments, strategies or controls will need to be put in place to reduce the rating to an acceptable Target Risk Rating. Once these additional treatments are put in place, or included in approved plans, they become Existing Treatments/Strategies and the residual rating can be revised. 13. Target Risk Rating – If the Residual Rating is unacceptable, additional treatments or strategies will be put in place to reduce the rating to an acceptable Target Rating. 14. Executive Owner – The member of the Executive (one person) accountable for ensuring that the risk is managed as effectively as possible. 15. KPI – The Key Performance Indicators which are a measure of how well the risk is being or could be managed. 16. Internal Audit Assurance – Internal audit activity that the department’s Audit Directorate will undertake to assess the management of the risk. 17. Other Internal Assurance – Other internal mechanisms or departmental groups (steering committees etc.) who have oversight of the management of the risks or related objectives. 18. External Assurance – External bodies or organisations with a role in assuring the effective management of the risk (Audit & Risk Committee, Audit Office of NSW etc.). LEGEND for reading the Risk Register Key to Columns - C, L and Rating C (Consequence) L (Likelihood) A = Service/Program Delivery B = Financial C = Management Effort D = Health & Safety E = Legal / Compliance F = Reputation / External Relationships G = Project / Program Quality H = Project / Program Time (schedule) I = Project / Program Cost J = Project / Program Benefits 1 = Ins = Insignificant 2 = Min = Minor 3 = Mod = Moderate 4 = Maj = Major 5 = Crit = Critical 1 = R = Rare 2 = U = Unlikely 3 = P = Possible 4 = L = Likely 5 = AC = Almost Certain Residual or Target Risk Rating Low Medium (Med) High Extreme (Extr) How to Develop a Risk Register Risk registers are designed to capture risk information and is a primary tool for risk monitoring, reporting and follow up action. The steps taken to create a risk register are outlined in the following table and are in parallel to the risk register development process shown below. Steps in the Creation of a Risk Register Step Step Descriptor Comments 1 Risk register awareness and readiness Initial planning by business unit manager and key staff 2 Meet with business unit key stakeholders Building the contextual framework 3 Conduct business unit risk identification meetings (e.g. brainstorming) Take into consideration all points of view 4 Stakeholder engagement with teams develop the risk register (see next table) Populating the risk register 5 Development of risk register entries Coordination of risk evaluation and treatments 6 Sign off and assigning ownership of risks Agreement of budgets to control risks 7 Updating risk registers Reviewing and monitoring Escalation and/or deescalation process may need to be enacted Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 38 of 55 Enterprise Risk Management Guidelines Risk Register Development Process Step No. Process Component Key Questions to be Asked Linkages 1 Establishing the context Have the business objectives been taken into account? Has an environmental scan been conducted? Have the risk criteria been defined? Monitoring and review Communication and consultation 2 Risk identification What do you want to achieve, what will stop it being Monitoring and review achieved (threat), or what will help it being achieved Communication and (opportunity)? consultation What is the potential cost to time, money and performance? How likely is it to happen? What are the impacts of each risk? What is the source of the risk? What can be done to reduce/control the risk? 3 Risk analysis Are there any existing controls? Have the consequences of the risk been considered? Have the impacts been evaluated on a ‘gut feel’ or an evidence-based approach? Has the likelihood criteria been applied? Monitoring and review Communication and consultation 4 Risk evaluation Have the risk tolerance levels been considered in accordance with legal, regulatory and other requirements? Has a decision been made to treat the risks? If yes, go to Step 5. If no, continue to monitor and review the risks. Monitoring and review Communication and consultation 5 Risk treatment Have all treatment options been identified? Have all options been assessed? Have treatment plans been prepared and ready for implementation? Have residual risks been analysed and evaluated? Monitoring and review Communication and consultation 6 Monitoring and review Have the established procedures been followed? Is there is a requirement to escalate or de-escalate risks to the next level? Risk management plan, if held The risk register when complete should be brought to the attention of all staff working in the business unit in a clear and understandable manner taking into account their level of training, knowledge and experience as well as their responsibility of managing the risks. Continuous Improvement A risk register is a ‘living document’, and not a one-off process. Accordingly, it should be regularly updated and used actively during planning and related activities. To align with departmental requirements, industry standards and best practice, business units are required to regularly review their risk register for accuracy and currency. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 39 of 55 Enterprise Risk Management Guidelines Sample Template 1 - Risk Register (1) (2) Item Risk no. Type 1 (3) Division (4) Target (Strategic Objective) 1a. Corporate New & Better Strategic Services Ways of Threat Doing Business (5) (6) (7) Planned Action (to Risk Identified Risk achieve objective) No. Effective 66 management of the implementation of the program. (8) Existing Treatments (9) (10) C L (11) (12) (13) (14) Residual R Additional Target T Exec Rating Treatments Risk Owner Needed Rating ABCD Program Development A4 3P High does not deliver of program B4 timely services assurance... C4 or....... F4 Revision of Maj strategic focus... Escalate to Med Exec. ERM Unit meeting with ERM Group Members to support faster progress (15) KPI DepSec Program delivery CS KPIs Successful introduction of ABC. (16) (17) (18) Internal Other External Audit Internal Assurance Assurance Assurance - Project 9999 Shared service risk assessment / audit.... - Project 8888 – Gap Developme analysis... nt and implementa tion.... - DoE ABCD Audit & Risk SubCommittee oversight... . - CPMG has been engaged in.... - Audit Office of NSW conducted.... Program Mgt KPIs... Note: An explanation of each numbered column is shown earlier in this appendix. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 40 of 55 Enterprise Risk Management Guidelines Sample Template 2 – Risk Register Risk Risk Description No. Residual Management Additional Risk Management Target Responsibility Timetable for Implementation Reviewed Risk Action Strategies / Controls Risk for Implementation Update Date Rating Implementation Rating A Assets may be lost or Low No Major Concern No further strategies required Low n/a n/a High Active Management Branch Manager to check and Medium Branch Manager 15/X/YY damaged B Cash transactions are subject to theft, loss or authorise monthly reconciliations and misuse at remote locations ensure secure safe is installed Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 41 of 55 Enterprise Risk Management Guidelines APPENDIX 4 - SAMPLE RISK RECORD TEMPLATE Risk Number: Communication and Consultation Identify Key Stakeholders and who has been Target (Strategic Objective) involved in the consultation of the identification and assessment of the risk. Planned Action (to achieve objective) Division Context / Assumptions Identified Risk (risk description) Existing Treatments/Strategies Control Conseq- LikeliEffectiveuence hood ness Residual Exec Risk Completion Risk Budget Owner Manager Date Rating Risk Triggers (or indicators), Risk Sources, Introduced Risks / Residual Risks Additional Treatments Needed Control Conseq- LikeliEffectiveuence hood ness Target Risk Rating Executive Action Required Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 Funding Approved / Required Risk Treatment KPI's Due Date Status KPI's July 2015 42 of 55 Enterprise Risk Management Guidelines APPENDIX 5 - SAMPLE RISK ASSESSMENT WORKSHEET Division / Business Unit / Project 1. Communicate and Consult: Key Stakeholders: Which internal and external stakeholders have been consulted in developing the risk assessment? Deputy Secretary Finance Manager Branch staff 2. Operating Environment & Context: Identify the key internal and external factors influencing the operating environment: The function is new therefore no policies or procedures and no history of performance Budget allocation to be determined Staff in remote locations Contracted staff with no knowledge of corporate policies and procedures Specialist equipment to be purchased and installed 3. Risk Identification Risk No. and Identification Category: Risk Description: 1.Security 2.Legal & Legislative 3. Financial A. Assets such as computers, TV’s, specialist equipment and mobiles may be lost or damaged resulting in financial loss; specialist equipment difficult to replace; disruption to operations. B. Cash transactions will be conducted at the remote locations raising the risk of theft, loss or misuse by external or internal parties resulting in theft being reported to the Police; bad publicity for the Department; disruption to operations; financial loss; effect on staff morale. 4. Risk Assessment Triggers / Risk Sources: Identify those factors that might lead to the risk occurring A. poor asset records; no stocktakes; lack of security; mobiles have a history of being lost or damaged. Existing Controls: A. assets recorded in asset register; regular stocktakes; require security card to enter the work area; contract exists for ready supply of specialist equipment B. lack of security; no reconciliations; the nature of cash makes it very vulnerable B. no safe for securing cash; no reconciliations; but receipts are recorded and staff are aware of requirements of Treasurer’s Directions Control Effectiveness Rating: A. Good (4) Are the current controls B. Poor (8) effective? Are they being complied with? Consequence Rating: A. A2 (minor) B. E4 (major) Likelihood Rating: A. 2 (unlikely) B. 4 (likely) Residual Risk Rating: Consequence rating combined with Likelihood rating A. L ow B. High Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 43 of 55 Enterprise Risk Management Guidelines 5. Risk Treatment Management Action: As described in the Guidelines A. Monitor & manage at operational level B. Escalate to Executive Additional Risk Treatments Needed: Identify those strategies in addition to the existing controls that will be implemented to further manage this risk. A. No further strategies required B. Manager to check and authorise monthly reconciliations and ensure secure safe is installed New Control Rating: A. Good (4) B. Good (4) New Consequence: Rating: A. A 2 (minor) B. E 3 (moderate) New Likelihood Rating: A. 2 (unlikely) B. 3 (possible) Target Risk Rating: Consider the effect of the additional strategies / controls on the risk A. Low B. Medium Responsibility: The position supervising the implementation of this risk treatment strategy. A. n/a B. Manager Timetable: When will implementation of the strategies be completed? A. n/a B. 15/X/YY Risk Assessment Undertaken by: Risk Management Strategies Approved by: Date of Approval Date of Review Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 44 of 55 Enterprise Risk Management Guidelines APPENDIX 6 - SAMPLE RISK ASSESSMENT TEMPLATE Risk No. Risk Description (short version) A Assets may be lost or damaged B Cash transactions are subject to theft, loss or Residual Consequence Rating Residual Likelihood Rating Residual Risk Rating Target Consequence Rating Target Likelihood Rating Target Risk Rating A2 Minor 2 Unlikely Low A2 Minor 2 Unlikely E4 Major 4 Likely High E3 Moderate 3 Possible Medium Low Responsibility n/a Branch Manager misuse at remote locations Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 45 of 55 Enterprise Risk Management Guidelines APPENDIX 7 - ALIGNING RISK MANAGEMENT TO STRATEGIC AND BUSINESS PLANNING, BUDGETING AND PERFORMANCE MANAGEMENT 1. RISK MANAGEMENT AT THE STRATEGIC LEVEL Risk Management at the strategic level involves identifying circumstances and events that could have an impact (positive or negative) on the achievement of corporate objectives. Risk and strategy are linked and whenever there is a change in strategies, the risk assessment will also change. The risk process is a recognition that in striving for a specific goal or outcome there are often elements or risks associated with the achievement of those outcomes. If these risks are not considered or addressed at the time of developing strategic plans they can delay, frustrate or cause unexpected outcomes to arise affecting the achievement of the objectives, or there may be opportunities that are missed. Strategic plans and the risks impacting the outcomes in those plans are not likely to remain static due to changing priorities, new initiatives, government decisions, stakeholder issues, etc. and these risks along with the division strategies may need re-assessment at the time division plan progress is being monitored regularly throughout the year. There two distinct stages when risk needs to be considered at the strategic level: At the time strategic plans are first being developed and At the time progress is being monitored and reported on against the strategic plans. 2. STRATEGIC AND BUSINESS PLANNING Understanding how risks align with the planning processes enables us to effectively integrate risk management into our governance and management structures. Risks are addressed as part of any planning process including the Total Asset Management (TAM) Plan, Funding Plan submissions to the Treasury, the Corporate Plan, project and program plans, and any other strategic, business or operational plan. The integration of risk management into strategic and business planning processes is a key component of the Department’s risk governance and business improvement processes. Strategic risk management applies to the process of considering and managing the strategic risks on the Executive Risk Profile (risks included on the Executive Risk Register) which may impact the Department as a whole. However, this process can also be generally applied to all business unit levels. Strategic risks are those that may have a direct and significant impact on the organisation’s strategic objectives. The strategic risks are given formal consideration by the Executive collectively and the division heads individually. Business plan risk management applies to the process of considering and managing risks to the delivery of major projects and services. Business plan risks include strategic and operational risks. Major projects and initiatives risks generally relate to the delivery of infrastructure projects. The starting point for embedding risk management is to link the risk identification process to the corporate strategic and business plan objectives, using risk assessment as an input Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 46 of 55 Enterprise Risk Management Guidelines to the plans. Risk and performance are managed and monitored in an integrated manner to help achieve better overall governance. Effective risk management provides increased confidence that we can deliver the desired outcomes, manage threats to an acceptable degree and make informed decisions about opportunities. Alignment of risk management to strategic planning, budgeting and performance management can deliver a range of benefits by: a. Improving the quality of decision making (appropriate, fast, accurate, and effective) b. Effective execution of decisions (improved confidence, known quantity) c. Embedding risk management within the day-to-day operation of your organisation (part of business as usual, not additional task or process burden) d. Integrating risk management with business strategy (help ensure decisions are informed and based on sound judgment) e. Improving planning processes by enabling the key focus to remain on core business and helping ensure continuity of service delivery f. Reducing the likelihood of potentially costly ‘surprises’ g. Preparing for challenging events and improving overall resilience h. Prioritising budgeted resources i. Optimising performance through efficiencies in service delivery, major change and quality assurance initiatives and j. Contributing to the development of a positive organisational culture of improved governance, clear purpose, roles and accountabilities for all staff. 3. BUDGETING Risk information provides an input to the identification of the resourcing requirements and assists in the prioritisation of available resources as follows: Risk information and estimates of resource requirements for the treatment of major risks are included in program and project proposals and considered by senior management Risk management resource implications are included in the appropriate approved plans The budget prioritisation process takes into account the Department-wide and division risk profiles. The risk management framework allows escalation of risks throughout the year, with any financial considerations being subject to the Executive, Minister or Treasury decision as appropriate. However, the identification and assessment of risks will not necessarily be a trigger for additional funding. If additional funding is available, then this can be used to accommodate the additional risk treatment activities required to manage the risk. In most cases however, the reduction of the risk exposure in a particular area, will be accommodated by reprioritising the available activities, resources, funds or other investment in that area. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 47 of 55 Enterprise Risk Management Guidelines 4. THE ALIGNMENT PROCESS Risk management is integrated in strategic and business planning and budgeting activities as follows: Step 1 2 3 4 Action Review any current in-use planning policies, procedures and checklists to help ensure that content is aligned with these guidelines as well as any reference to the latest standards (e.g. risk matrix, consequence and likelihood tables). If inconsistencies exist, the appropriate action should be taken by either developing or updating risk related documentation/or references to risk terminology Clearly state the strategic objective (e.g. launch a new As you would product or service, new school, meet a corporate target, etc.) normally do in your Describe the planned actions to achieve the objective planning Clearly state all assumptions (e.g. market size, resources process 9 required, competition, safety, etc.) Identify the risks related to the objectives, planned actions, and the assumptions (are the assumptions correct? what if they’re not? what if the situation changes? etc.) Perform a high level assessment of the risks (consequence, likelihood, risk rating) Describe a high level treatment strategy for the higher rated risks (treatment options, cost/benefit analysis, decide whether to proceed) Undertake a detailed assessment and plan the management of the accepted risks as per Section 3 of these guidelines Monitor the risks and the situation for changes 10 Monitor the plan to address the changes. 5 6 7 8 Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 48 of 55 Enterprise Risk Management Guidelines 5. STEPS TO INTEGRATE (EXAMPLE) Integration of ERM into the Department’s strategic planning process (see Figure 4 below) Timeline Business / Strategic Planning Process (example) Risk Management Process Performance Management Process Management Planning Session to set broad strategy April Individual Business Plans May Management Strategy Development of Budget Requirements Approval of Funding Plan Priority Projects for Strategy Implementation Identify risks to achieving strategic and operational objectives Treatment Strategies Determine Budget Implications Detail Action Plans to Implement Treatment Strategy Major Risks Considered in Identification of Priority Projects Working Draft of Strategy Endorsed by Management June Management Meeting to Validate Strategy July Responsibility for Carriage of Objectives & Strategies Assigned Develop KPI’s to Measure Achievement of Objectives Responsibilities Assigned to Action Plans Develop High Level Risk Profile Management Performance Agreement Incorporate Risk Management Objectives Monitor, Review & Report Progress against the Plan Figure 4: Integration of ERM into the Department’s Strategic Planning Process (timeline is an example only) a. At the Management Planning Session in April the broad strategy is set, providing a strategic direction for preparation of individual business plans, the management plan, and the development of future years’ budget requirements b. Individual business streams begin drafting their business plans in May to inform the management meeting (held in July). The following business plan risk assessment actions are carried out by the business streams: i. Business streams articulate their objectives contributing to the overall strategy, describe the planned actions to achieve the objective, state the assumptions, and identify risks to achieving the business plan objectives ii. Risks are identified by the business stream in the context of the business as usual (service delivery) objectives, and major projects and initiatives iii. Risks are assessed by the business stream in accordance with the Enterprise Risk Management Guidelines Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 49 of 55 Enterprise Risk Management Guidelines iv. Treatment strategies required to manage the risks are developed v. Budget implications (high level) are estimated for each high and extreme risk vi. Risk treatment strategies and budget implications are documented in the risk records (refer to the Sample Risk Record template – Appendix 4) vii. Risk treatment strategies and the budget implications are then prioritised taking into account the risk ratings viii. Summary of high and extreme risks, treatment strategies and budget implications are documented in a prioritised order in the business plans ix. Upon approval of the funding plan the detail action plans to implement risk treatment strategies are developed taking into account the available budget and the risk priority x. Business plans are finalised to include detailed action plans for each risk including due dates xi. Responsibilities are assigned after the strategy is validated in July xii. Detailed action plans, due dates, associated costs and responsibilities are documented for each high and extreme risk (refer to the Sample Risk Record template – Appendix 4). c. The management strategy is set, reflective of the strategic direction d. Prioritised budget requirements in excess of available resources, are promoted to management for inclusion in the development of the next budget period e. Major risks on the risk profile are considered in the identification of priority projects before a working draft of the strategy is endorsed by management in June. The following risk related questions are considered during the strategy setting process: i. What are the major assumptions to each of the strategic objectives? ii. What are the strategic and operational risks inherent in the strategy, and are in accordance with our appetite to risk? iii. Can we meet the resources requirements of this strategy and associated risks, now and in the foreseeable future? iv. Will our values and ethics be compromised in any way by execution of this strategy? v. Priority projects for the strategy are refined in May taking into account the requirements to manage major risks on the risk profile vi. Existing structures, resources and risk appetite are aligned to the strategy and the risk profile. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 50 of 55 Enterprise Risk Management Guidelines 6. AN INTEGRATED FRAMEWORK Risk Management is an integral part of the strategic planning and budgeting processes. An integrated business planning and ERM framework should contain the following elements: a. Evidence of communication and consultation with key stakeholders in developing strategic plans b. Objectives should be set so that achievement of them can be measured. Tools such as “SMART” criteria (i.e. objectives should be Specific, Measurable, Achievable, Relevant and Timely) reflect good practice in this regard (see Section 3.2.2) c. Linking of operational plans back to higher level strategic plans to help ensure they are consistent with higher level vision/mission d. Evidence of identification and consideration of risks that impact on the achievement of strategic and operational objectives e. Evidence of strategies designed to achieve objectives and manage the risks that could affect the achievement of those objectives f. Evidence of responsibilities for carriage of objectives and strategies having been assigned to divisions/areas g. Development of Key Performance Indicators to measure achievement of objectives h. Evidence that operational plans include identification, appropriate costings and assignment of resources to undertake them i. Evidence of formal processes for identification of emerging risks and issues that impact plans and mechanisms for implementation of remedial action as appropriate j. Evidence of formal processes in place to monitor, review and report progress against plans k. Evidence that the annual report includes reporting in terms of key risks identified for the Department and management of those risks and legislative requirements l. Policy and guidelines to support the above processes. 7. RISK MANAGEMENT AND PERFORMANCE MANAGEMENT Risk management objectives are linked with performance management at all levels of the organisation. Appropriate risk culture is supported by ensuring that risk management objectives and overall performance objectives are aligned. This is supported in the following ways: Management’s individual Performance Agreements incorporate risk management objectives such as high and extreme risks, target (or acceptable) risk ratings, risk management strategies, KPIs and due dates Identification of the people component of major business risks: leadership, knowledge, capabilities, behaviour, staff turnover, succession planning, training and development, and culture. Relevant risk management strategies are developed to address root causes of these risks. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 51 of 55 Enterprise Risk Management Guidelines 8. RECORDING RISK INFORMATION For each individual risk, the risk information is documented on a risk record (see sample in Appendix 4) which incorporates links to the strategic management, budgeting and performance management as follows: Reference to a strategic area/objective Risk management accountability which indicates an overall responsibility for managing a particular risk Risk triggers - an event, activity or early warning signal or indicator likely to highlight or result in an emerging risk occurring Key performance indicators (KPIs) for future treatment strategies which are included in the individual performance agreements Budget required to implement the risk treatment strategies. See also the Risk Register – Appendix 3, Risk Assessment Worksheet – Appendix 5, and Risk Assessment Template – Appendix 6 Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 52 of 55 Enterprise Risk Management Guidelines APPENDIX 8 – DEFINITION OF TERMS Acceptable level of risk The acceptable level of risk reflects the decision by management to accept the likelihood and consequences of a risk. This is also known as risk tolerance. Consequence The outcome or impact associated with a risk occurring e.g. the loss, injury, disadvantage or gain. Control Any measure or action that changes the consequence or likelihood of a risk materialising. Likelihood The qualitative description of the probability or frequency of a risk occurring. Operational Risks Those risks that may have a direct and significant impact on the organisation’s business as usual activities, functions, roles and/or operations. Residual Risk Level The level of risk calculated using likelihood and consequence criteria after treatments have been put in place. Risk The effect of uncertainty on objectives. The chance of something happening that will have an impact (positive or negative) on achieving the organisation’s objectives. It is measured in terms of the magnitude of the consequences and the likelihood of occurrence. Risk Appetite The risk appetite (see Section 3.5.5) reflects the Department’s overall acceptable level of risk. This is articulated in the construct of the consequence tables and the risk matrix. The Department’s Enterprise Risk Management Policy also includes a Risk Appetite statement which describes the Department’s focus on acceptable risk. Risk Register The documented repository of risk information gained from risk assessments. Risk Level The risk rating calculated using likelihood and consequence criteria after considering the existing control environment. Risk Management Co-ordinated activities to direct and control an organisation with regard to risk. Stakeholders Those people and organisations who may affect, be affected by, or perceive themselves to be affected by, a decision or activity of the Department. Strategic Risks Those risks that may have a direct and significant impact on the organisation’s strategic objectives. Tolerance Tolerance is a management decision on whether the current level of risk is acceptable or not (decision to ‘tolerate’ the risk). Tolerance is also reflected in the Executive and Division Risk Registers as the acceptable risk rating (residual or target) for each of the risks. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 53 of 55 Enterprise Risk Management Guidelines APPENDIX 9 - EXECUTIVE MEETING AGENDA ITEMS Agenda Items Meeting focus: Annual risk profiling 1. Discuss summary of corporate plan objectives 2. Reassess the risk appetite in accordance with strategic priorities and budget 3. Review the draft risk profile prepared by the ERM Group and consider: The relevance of existing risks and their context Progress against key risk treatment activities, note potential movements in the risk ratings Results of the environmental scan performed by the ERM Group (external trends, systemic issues arising from incidents, risks to the major projects and initiatives, new and emerging risks) Confirm new or emerging risks Assess residual risks and prioritise the risks Highlight risks with a cross-division impact 4. Consider revisions to risk treatment initiatives: Improvements to the existing initiatives New treatment strategies required for current or new risks Consider strategies for the cross-division risks Reassess resourcing requirements to fulfil risk treatment initiatives Consider “what should we stop doing?” taking into account the prioritised risks Meeting focus: Annual review of the risk management framework 1. Review relevance of the Enterprise Risk Management Policy and Framework 2. Review NSW Treasury Policy attestation pack including: Internal Audit and Risk Management Survey Internal Audit and Risk Management Attestation Meeting focus: Quarterly review of the Department-wide risk profile Review each risk on the Executive Risk Register Relevance of existing risks and their context Progress against key risk treatment initiatives, note potential movements in the risks New or emerging risks Refresh residual risk ratings Amendments to current risk treatment activities Risk treatment initiatives for new and emerging risks Meeting focus: Monthly risk discussions at the Executive meetings New and emerging threats and opportunities Major concerns or other matters escalated early through the existing communication channels Potential impact of these matters and response to them Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 54 of 55 Enterprise Risk Management Guidelines APPENDIX 10 – ROLES AND RESPONSIBILITIES ROLE OF DIVISIONS Consistent with the Department’s Risk Management Principles, divisions will Identify, assess, develop and rate success indicators and treatment strategies for risks to be included in the Executive and Division Risk Registers Help ensure major risks align with policy, budgets, business plans and performance management arrangements Help ensure risks are escalated (on a needs basis) for Executive consideration when there is danger of a risk not being appropriately managed by existing strategies, treatments and resource allocation Provide recommendations for dealing with escalated risks (escalated risks rated high or extreme will procedurally progress to the Audit and Risk Committee). ROLE OF THE EXECUTIVE Help ensure ERM is embedded in the Department’s budget and planning processes and appropriately monitored Monthly discussions of emerging threats and opportunities Formal consideration of the risk profile and associated risk treatment strategies on the Executive Risk Register facilitated through quarterly Executive meetings Annual review of the risk management framework, the risk profile, and the risk appetite Risk Management is a standing item for Executive meetings as part of Issues Management Consideration given to Executive level risks of a cross-division nature and a risk owner designated (e.g. Executive governance, ERM, business continuity, procurement, etc.) The designated risk owner will help ensure that cross division risks are effectively managed consistent with division requirements. ROLE OF ERM GROUP Regular monitoring of the Enterprise Risk Register and escalation as appropriate to the Executive through the Deputy Secretary, Strategy and Evaluation Provide / coordinate support across divisions Executive support for ERM items at Audit and Risk Committee meetings and the Executive Work Program Work with all internal (and external) stakeholders to help ensure effective adoption of the ERM framework. ROLE OF THE MANAGER, ENTERPRISE RISK MANAGEMENT For the purposes of Treasury Policy TPP 15-03 the Manager, Enterprise Risk Management is nominated as the Department’s Chief Risk Officer. Enterprise Risk Management Guidelines Policy document reference; PD/2004/0036/V01 July 2015 55 of 55