Risk Management Policy Paper Number: P1415-887 Document author Risk Administrator Policy to be reviewed Every 2 years Date of next review September 2017 Amendment & Approval History Version Date 1.0 23/03/2015 Approved by Change Council New policy Purpose of this document This risk management policy (the policy) forms part of the University’s internal control and governance arrangements. The purpose of the policy is to explain the University’s underlying approach to risk management and to document the roles and responsibilities of Council and its sub-committees, the Senior Management Team (SMT) and other key parties. It also outlines key aspects of the risk management process and identifies the main reporting procedures. It describes the process the Council will use to evaluate the effectiveness of the University’s internal control procedures. The policy has been written in accordance with HEFCE risk management guidance. Policy Statement The University considers risk management to be fundamental to good management practice and a significant aspect of corporate governance. Effective management of risk will provide an essential contribution towards the achievement of the University’s strategic and operational objectives and goals. Risk management must be an integral part of the University’s decision making and routine management, and must be incorporated within the strategic and operational planning processes at all levels across the University. Risk assessments must be conducted on new ventures and activities, including projects, processes, systems and commercial activities to ensure that these are aligned with the University’s objectives and goals. Any risks or opportunities arising from these assessments will be identified, analysed and reported to the appropriate management level. The University will maintain a corporate risk register. All Colleges, Professional Service departments, subsidiary companies, major projects and institutes will maintain risk registers. The University is committed to ensuring that all staff, particularly Heads of Colleges and Professional Service Directors are provided with adequate guidance and training on the principles of risk management and their responsibilities to implement risk management effectively. The University will regularly review and monitor the implementation and effectiveness of the risk management process, including the development of an appropriate risk management culture across the University. Risk Definitions Risk can be defined as the combination of the probability of an event and its consequence 1. In all types of University undertaking, there is the potential for events and consequences that constitute opportunities for benefit or threats to success. In the safety field it is recognised that consequences are only negative and therefore the management of safety risk is focussed on prevention and mitigation of harm. Risk management is the process whereby the University methodically address the risks attaching to University activities with the goal of achieving sustained benefit within each activity and across the portfolio of activities. Its objective is to add maximum sustainable value to all the activities of the organisation2. Related documentation: University policies in relation to Health & Safety Risk Assessments for staff, students, contractors and visitors arising from the University’s undertaking University insurance policies in relation to staff or students involved in University business University Incident Management Plans University Business Continuity Plans 1 2 International Organisation for Standardization – ISO/IEC Guide 73 Risk Management Institute of Risk Management (IRM) – A Risk Management Standard: 2002 Risk Management Policy v1.0 Page 2 of 12 Approach to Risk Management The following key principles outline the University’s approach to risk management: Council has ultimate responsibility for risk management at the University and is therefore responsible for the approval and review of the Risk Management Policy and for ensuring that it is appropriately managed The risk appetite of the University will emanate from the University’s Strategic Plan which is considered and approved by the Council The Audit Committee is responsible for providing the Annual Assurance to Council on the adequacy of risk management. The Audit Committee will receive assurance statements yearly via the University Risk Administrator there should be an open and receptive approach to mitigating risk the Vice-Chancellor and SMT supports, advises and implements policies approved by Council SMT will lead and provide direction on the major strategic and operational risks facing the University A corporate risk register, built around the key strategic themes and enablers (as identified in the University’s Strategic Plan) will be created and maintained and will be subject to quarterly reviews by SMT and the Audit Committee the University makes conservative and prudent recognition and disclosure of the financial and non-financial implications of risks all Colleges, Professional Service departments, subsidiary companies, major projects and institutes will use a consistent and transparent approach to risk, ensuring an agreed and widely understood method and language Heads of Colleges and Professional Service Directors are responsible for management of all risks within their areas of control, including ensuring appropriate systems are created to identify, assess, manage and review risks in line with the University Risk Management process Each College and Professional Service department is required to review and maintain its own risk register using the University Risk Register tool All new significant initiatives or projects will undergo a risk assessment, which will generate an initial risk register for the project Early warning mechanisms will be put in place and monitored to alert the University so that remedial action can be taken to manage any potential hazards Risk Management Policy v1.0 Page 3 of 12 Risk Identification Risk identification sets out to identify the University’s exposure to uncertainty. IMPACT The University uses a nine-point (3X3) scale risk rating mechanism to assess the impact and probability of risk, with a scoring of A1 denoting the highest risk on the scale as high impact and high probability. A A3 A2 A1 B B3 B2 B1 C C3 C2 C1 3 2 1 A1=high impact, high probability A2=high impact, medium probability A3=high impact, low probability B1=medium impact, high probability B2=medium impact, medium probability B3=medium impact, low probability C1=low impact, high probability C2=low impact, medium probability C3=low impact, low probability PROBABILITY Classifications of high, medium and low probability and impact are: Probability Description High (probable) Medium (possible) Chance of occurrence greater than 60% Chance of occurrence between 20% and 60% Low (remote) Change of occurrence less than 20% Risk Management Policy v1.0 Page 4 of 12 Impact Area Description High Finances Financial impact on the University is likely to be greater than £500K A critical event which would require mobilisation of a special project team Management time Health & Safety Medium Reputation Regulatory & Legal Action Staff Impact Finances Management time Low Major incident with serious casualties or which causes operations to be stopped Sustained negative national media coverage Disruption to courses / research activity over an extended period of time Significant adverse impact with Trade Unions in conflict mode Financial impact on the University is likely to be between £50K and £500K An event which would require management activity but which can be handled under normal circumstances Health & Safety Reputation Regulatory & Legal Action Staff Impact Finances Management time Moderate incident with some casualties or disruption to operations Extended negative local/sector media coverage Penalties applied but no disruption to courses / research activity Health & Safety Reputation Regulatory & Legal Action Staff Impact Minor incident with no sickness absence and no lasting impact Minor articles in local press Minor breaches with no penalties applied General discontent evident across multiple groups of staff Financial impact on the University is likely to be less than £50K An event which can be absorbed through normal activity Minor staff complaints A variety of risk identification techniques are to be used – Brainstorming Risk questionnaires Business Plan reviews Industry benchmarking Scenario analysis Incident investigation Auditing and inspection For all externally funded proposals which are greater than £100K in value the pre-risk assessment checklist process is to be followed. For major projects or initiatives the University Risk Administrator will facilitate a risk assessment review process to ensure that impacts of new proposals are assessed, reviewed and authorised by SMT. For major projects or initiatives which are greater than £10 million in value to the University, then a member of the Finance Committee will be invited to attend the risk assessment review. The Finance Risk Management Policy v1.0 Page 5 of 12 Committee is required to ratify all risk assessment reviews which are greater than £10 million in value at the next scheduled Committee meeting. For existing projects or initiatives the University Risk Administrator will facilitate a risk workshop, when required, supported by the relevant SMT owner of the activity and all related stakeholders. A range of techniques can be used to analyse risks including – Market surveys Impact analysis SWOT (strengths, weaknesses, opportunities, threats) analysis Event tree analysis Business continuity planning Threat analysis PESTLE (political economic social technical legal environmental) analysis Cause and effect diagrams (Ishikawa diagram) Risk Description The objective of risk description is to display the identified risks in a structured format. The following risk register format is used for the University Risk Register Criteria Detail Risk Identifier RAG Provides the risk with a unique identifier Traffic light status – RED – highest priority risks AMBER – medium priority risks GREEN – lowest priority risks Assigns ownership of risk to a member of SMT A detailed description of the risk and the impact if the event occurs (related reference to the University’s Strategic Plan) Owner Description & Impact (Strategic Reference) Probability Impact Trend Indicators Controls/Actions Action by Action Due Qualification of probability – high/medium/low(before controls applied) Qualification of impact – high/medium/low (before controls applied) Description of risk severity status – increasing/no change/decreasing Description of the evidence to be analysed in order to provide early warning of the occurrence of event triggering risk Identifies actions to be implemented in order to mitigate the risk (when actions are completed they are recorded in the University Risk Register Revision Update and removed from the Risk Register). Assigns ownership of the planned actions to a member of the University Management Board Due date for implementation of planned actions The University Risk Register is reviewed in a quarterly cycle and controls/actions will always show proposed or incomplete activity to further mitigate the risk. Controls and actions which have been completed are noted as completed in the University Risk Register Revision document accompanying the risk register. Risk Management Policy v1.0 Page 6 of 12 For local risk registers (College, Professional Service department, major project, institutes or subsidiary companies) the following format of risk register will be used – Criteria Detail Risk Identifier RAG Provides the risk with a unique identifier Traffic light status – RED – existing controls/actions are not working or are inadequate – escalation for higher level management attention required AMBER – existing controls/actions are in danger of failing GREEN – controls/actions in place are working Owner Assigns ownership of risk to a member of staff reporting to the owner of the risk register A detailed description of the risk and the impact if the event occurs Qualification of probability – high/medium/low(before controls applied) Qualification of impact – high/medium/low (before controls applied) Description of risk severity status – increasing/no change/decreasing Description of the evidence to be analysed in order to provide early warning of the occurrence of event triggering risk Description & Impact Probability Impact Trend Indicators Controls/Actions Action by Action Due Identifies actions to be implemented in order to mitigate the risk (when actions are completed they are recorded in the Minutes of the relevant management meeting which reviewed the risk register and removed from the Risk Register). Assigns ownership of the planned actions to a member of staff Due date for implementation of planned actions Controls/actions will always show proposed or incomplete activity to further mitigate the risk. Controls and actions which have been completed are noted as completed in the minutes of the management meeting where the risk register has been reviewed. Risk Management Policy v1.0 Page 7 of 12 Risk Appetite In pursuit of achieving the University’s strategic aims and academic mission, the University will therefore accept a degree of risk commensurate with the potential reward. The risk that the University is willing to take is within defined tolerances for risk appetite agreed by Council for each of the key strategic themes and enablers. The following risk appetite thresholds have been defined in the evaluation of risk in projects/activities within the designated strategic themes or enablers. Appetite Threshold Low Risk Appetite (risk averse) Description Avoidance of risk and uncertainty is a key University objective. There is a preference for business delivery options that have a low degree of inherent risk and only a potential for limited reward. The University is willing to proceed with a portfolio of activities providing that the exposure is not greater than all of the following: Finances 0%-1% of turnover as an investment or liability Staff Resources Estate Medium Risk Appetite (risk neutral) No more than 10 days of senior staff time (grade 9 and above) over and above everyday business Consider change of use for existing infrastructure but not new development Reputation Potential to have some negative local or regional damage to reputation Preference is for safe delivery options that have a low degree of residual risk and may only have limited potential for reward. The University is willing to proceed with a portfolio of activities in pursuit of achieving strategic aims providing that the exposure is not greater than all of the following: Finances 1%-5% of turnover as an investment or liability Staff No more than 25 days of senior staff time (grade 9 and Resources above) over and above everyday business Estate High Risk Appetite (risk seeking) Consider change of use for existing infrastructure and limited new development on areas of the estate where it is permitted Reputation Potential to have significant negative local or regional damage and some national damage to reputation Eager to be innovative and to choose options offering potentially higher business rewards despite the greater inherent risk. Willing to consider all potential delivery options and choose the one that is most likely to result in successful delivery. The University is willing to proceed with a portfolio of activities in pursuit of achieving strategic aims providing that the exposure is not greater than all of the following: Finances 5%-10% of turnover as an investment or liability Staff No more than 45 days of senior staff time (grade 9 and Resources above) over and above everyday business Estate Consider change of use for existing infrastructure and significant new development Reputation Risk Management Policy v1.0 Potential to have significant negative regional or national damage to reputation Page 8 of 12 The table below provides an overview of the risk appetite threshold assigned to each of the key strategic themes and enablers as defined in the Swansea University Strategic Plan 2012-17. In cases where an activity straddles more than one key theme or enabler, and the appetite in these areas is different, judgement will be required to balance the relative proportion of risk for each key area with the differing appetites. Key Strategic Risk Rationale for Risk Appetite Theme or Enabler Appetite Threshold Research Medium/High University is unlikely to take risks that have a direct and adverse impact on research income. Excellence However, the University is aggressive in growth targets for research and is prepared to take risks to achieve these rewards. The spread of activity across the University means the risk is spread and the potential impact of any higher risk projects can be balanced. University is unlikely to take risks that have a direct and adverse Student Medium/High impact on income from student fees. Experience Operating in a competitive marketplace means that the University is prepared to take risks in developing strategies that result in higher volumes of student and higher levels of student satisfaction. University is unlikely to take risks that have a direct and adverse Knowledge-led Medium impact on income from Knowledge Economy projects. Economy and The University is prepared to be innovative with industry to achieve Society breakthroughs for the wider economic benefit. Internationalisation Medium Working with Others Low/Medium Building Common Purpose Low/Medium Effective & Efficient Use of Resources Low Estate & Facilities Low/Medium Risk Management Policy v1.0 Balanced view of risk is taken to ensure that project commitments are delivered. University is unlikely to take risks that have a direct and adverse impact on income from student fees. Operating in a competitive marketplace means that the University is prepared to take risks in developing strategies that result in to achieve higher volumes of overseas students and higher levels of student satisfaction. Uncertainty of operations in some countries means that the University will be cautious in establishing new relationships. University’s mission in terms of the local region means some risk should be taken for the greater public good. Volatility of local partnership organisations and structures means that some caution should be taken to limit risk exposure A competitive marketplace means that the University is prepared to take risks to enter new strategic partnerships to achieve University growth targets. University’s performance relies on staff and some risks will be taken to improve staff performance and strengthen the University community. University will not take risks which damage the operational performance or league table positions by making radical changes to internal processes without detailed and thorough assessment of the risks University will take prudent action to safeguard the financial targets and enable re-investment into the estate University will be cautious in any diversification of income initiatives University will be cautious in providing safe and attractive working environments for staff, students and the wider community. University will take managed risks to achieve breakthroughs in the design of environments to increase attractiveness to students and other users of the estate. Page 9 of 12 Risk Management Responsibilities Council Council has a significant role to play in the management of risk. Council’s role is to – set the tone and influence the culture of risk management within the University. This includes: o determining whether the University is ‘risk taking’ or ‘risk averse’ as a whole or on any relevant individual issue o determining what types of risk are acceptable and which are not o setting the standards and expectations of staff with respect to conduct and probity determine the appropriate risk appetite or level of exposure for the University approve major decisions affecting the University’s risk profile or exposure monitor the management of significant risks satisfy itself that the less significant risks are being actively managed with appropriate and effective controls in place review annually the University’s approach to risk management and approve changes or improvements to key elements of its processes and procedures. Audit Committee The Audit Committee is required to keep under review the effectiveness of the risk management, control and governance arrangements on behalf of Council. The Audit Committee will monitor the management of corporate and local risks and authorise remedial action where necessary. It is also required to report to Council on an internal controls and alert members to any emerging issues. Senior Management Team (SMT) Led by the Vice-Chancellor, the Senior Management Team (SMT) role in relation to risk is to: Implement policies on risk management and internal control Identify and evaluate the significant risks faced by the University in the University Risk Register for consideration by Council and its Audit Committee Provide adequate information in a timely manner to Council and its Committees on the status of risks and controls Provide direction and guidance to all members of the University Management Board to ensure appropriate action is taken to mitigate the key risks of the University. Where risks cannot be managed within a specific College or Professional Service department, SMT will provide direction as to the University’s approach to responding to the risk. Undertake an annual review of effectiveness of the system of internal control and provide a report to Council Risk Management Policy v1.0 Page 10 of 12 Risk Administrator The Risk Administrator is responsible for development and communication of University risk management processes and tools, involving training of staff in risk management. The Risk Administrator is also responsible for administration of the University Risk Register on behalf of the Vice-Chancellor. An annual report on risk management is produced for review and approval of SMT, Audit Committee and Council. Heads of Colleges and Professional Service Directors The Heads of College and Professional Service Directors are responsible for actions to manage all risks within their areas and are responsible for implementing appropriate procedures to manage and monitor these risks, and for ensuring that all changes in key risks are reflected in the College/PS Department risk register. Where a risk is identified in RED status, then it should be raised in discussion with the Registrar/Chief Operating Officer (COO). There will be a standing agenda item for risk on all College management committee meetings. There will be a standing agenda item for risk on all Management Board meetings. Escalations On a quarterly basis the Risk Administrator will conduct a review with the Registrar/COO. At this review, all College and PS department risk registers are reviewed. Risks identified in RED status are reviewed and consideration is made by the Registrar/COO regarding possible amendments to the University Risk Register to reflect these RED risks. Level of management activity against each College and PS department risk register is also reviewed and the Registrar/COO will take follow-up action with relevant Head of College or PS Director as required. Individual members of staff Effective risk management depends on the commitment and co-operation of all staff. Individual members of staff within a College or Professional Service department are responsible for ensuring that individual risks are controlled and monitored appropriately with changes escalated where appropriate. Joint Internal Audit Unit (JIAU) Internal audit is an important part of the internal control process for risk. The JIAU use a risk-based methodology which is informed by the risks in the University Risk Register. Reviews of the University’s approach to risk management are undertaken on a regular basis on behalf of the Audit Committee. External Audit External audit provides feedback to the Audit Committee on the operation of the internal financial controls reviewed as part of the annual audit Risk Management Policy v1.0 Page 11 of 12 Contacts The key post holders for risk management are: College Code Register Owner Risk Coordinator Arts & Humanities AAH Prof John Spurr Heidi Waddington Business & Economics (School of Management) MGT Prof Nigel Piercy Garry Astley Engineering ENG Prof Javier Bonet Steve Davies Health & Human Sciences HHS Prof Ceri Phillips Stephen Herrieven Law LAW Prof Andrew Beale Sarah Holtom Medicine MED Prof Keith Lloyd Paul Roberts Science SEC Prof Matt Jones Steve Walmsley PS Department Code Register Owner Risk Coordinator Academic Registry ACR Adrian Novis Adrian Novis DRI DRI Ceri Jones Ceri Jones Estates & Facilities EST Craig Nowell Craig Nowell Finance FIN Rob Brelsford-Smith Rob Brelsford-Smith HR HRA David Williams John Cox ISS ISS Kevin Daniel Tony Ollier Marketing MKT Catherine Mullin Liz Shouaib PSPU PSP Pat Price Louisa Parry Student Services STS Kevin Childs Kevin Childs VC’s Office VCO Martin Lewis Martin Lewis University UNI Vice-Chancellor Ciaran Whyte Risk Management Policy v1.0 Page 12 of 12