Annual report to the Board on the Association’s system of internal controls for Kingston and Wimbledon YMCA For the period ending 31st March 2007 As reviewed by the Audit Committee at their meeting on 23rd July 2007 ___________________________________________________________________ Introduction This report is intended to help the Board review the effectiveness of the Association’s system of internal control. Although the Association is not required (due to the number of housing units) by regulation to undertake such a review it has determined that, as a matter of good practice, an annual statement should continue to be prepared and presented to the Board for their consideration. Housing Corporation circular R2 – 25/01 requires the Board to a) maintain a sound system of internal control which focuses on the significant risks, and provides reasonable assurance of the safeguarding of assets b) conduct an annual review of the effectiveness of the Association’s system of internal control. The Chief Executive or senior team are required to present an annual report on the effectiveness of the system to assist the Board with this. c) include a statement on internal controls in the audited financial statements which refers to the board’s annual review. This report is The Chief Executive’s report referred to under (b) above and has been prepared jointly with the Finance Director. Internal Controls – Annual Report July 2007 1 Identification of Risks Risk management is central to any system of internal controls. The Board has put in place a system to identify and control risks. The main elements are; A schedule of the key risks faced by the Association including a schedule of actions required in order to minimise these risks. This has been reviewed during the course of the past twelve months utilising a computer package to assist in the management of these risks. Specific responsibility to oversee the management of risks has been delegated to a member of the senior staff team. Updating this by consideration of risks in new pieces of work. The senior team report on key risks regularly to the Board. All Board reports include a paragraph on risk management. A procedure for Incident Reporting has been introduced, including assessing whether the risk register needs updating following a particular incident. Staff are issued with risk identification forms and have been provided with an overview of the key risks faced by the Association. Departmental Plans have been approved to include the identification of departmental risks and action required to minimise these. An internal audit review has been undertaken in respect of risk identification and risk management utilising interviews with a broad range of staff– this has assessed the system as providing substantial assurance. The Chief Executive and senior team implement the risk management decisions of the Board. The Chief Executive has retained responsibility for the implementation of the Association’s Risk Strategy whilst delegating responsibility for managing risk awareness to the Director of Corporate Services. The Board has reviewed the schedule of risks and these are included in the Association’s Risk Map. A more detailed review, reducing the number of key risks faced by the Association has recently been carried out which included a seminar on risk awareness. The control environment There is a relatively strong culture of commitment to internal control. In particular; The organisation works within its Vision, Values, Ethos and Mission. These are clearly communicated to staff, volunteers and partner organisations and key stakeholders. They set the tone of the organisational culture. The Values include relationships built on integrity and trust, development of all people in body, mind and spirit, and being forward looking and progressive. The Board demonstrates a lead in internal control by requiring regular reports on risks, on the controls or actions in place to mitigate risks, and on key performance indicators. The Board also demonstrates a lead in the values of the Association. A balance scorecard approach to Internal Controls – Annual Report July 2007 2 the measurement of KPIs was approved by the Board in February 2007 for introduction in the financial year 2007/08. The Chief Executive and senior staff team are responsible for making the values live within the organisation and thereby for creating a culture in which there is a commitment to internal control. In particular the senior staff team are responsible for specific key areas of control and for the management of other staff with responsibilities for developing and/or operating internal controls. Disregard of control procedures is treated seriously. Our system of internal controls The key internal controls within Kingston and Wimbledon YMCA are; Governance Memorandum and Articles of Association; Operational Risk management process: Financial Financial Standing Orders; Board Members’ Handbook; An annual budget and operating plan agreed before the start of the financial year; Monthly income statements and management accounts; Board member and staff codes of conduct; A more rigorous code of conduct for the Chief Executive and Senior Staff Team; Oversight and scrutiny by the Audit Committee; The approval and review of a range of strategic policies and procedures; Delegation of approval of non-strategic policies to the SST determined upon a risked based A strategic five year plan; Five year financial projections; A five year business plan; Daily review of bank balances; Written policies and procedures that are regularly reviewed and disseminated to staff and volunteers; Procedures for the authorisation of expenditure; The issuing of key policies and procedures to staff with payslips and the availability of policies on the shared server; Staff induction; A Capital Panel in order to oversee capital expenditure; External The process of internal audit; External audit reports. Compliance External compliance and regulation from external bodies:- The Housing Corporation - The Charity Commissioners - OFSTED - The Commission for Social Care Inspection. - Partner Local Authorities - Supporting People Commissioning Bodies; - Funders Procedures for the control of cash; Procedures for the authorisation of credit card transactions. Job descriptions Internal Controls – Annual Report July 2007 3 approach; A twelve months forward plan for the Board; Regular skills assessment for Board membership; Procedures for the identification and reduction of fraud. and person specifications; Staff recruitment, line management and regular work review processes; Staff training and development; A child protection officer accountable directly to the Board; ICT back up procedures and disaster recovery plans; Site specific emergency procedures manuals; A programme of internal audit undertaken on the basis of risk assessment. Review of the effectiveness of controls The Board and the senior team receive assurances that controls are operating as planned from the following sources; Board overview of the risk management process Management assurances: reports from managers providing financial and operational information. Regular planned reviews of key operational areas – catering services, child care and PR and Marketing; Internal Controls – Annual Report July 2007 4 Key Performance Indicators: reports on operational or financial areas identified as significant to achieving the business objectives utilising a balanced scorecard approach; External audit management letter. Reports from other regulators and key stakeholders. The implementation of the YMCA National Standards. Housing Corporation compliance reports and reports from CSCI in relation to the Care Homes. An assurance statement from Internal Audit. An assurance statement from the Audit Committee. The external auditors, the Housing Corporation and other external bodies do not have any specific responsibility to identify shortcomings in the system of internal control, so the main source of independent assurance is internal audit. The following internal audits have been undertaken in the past twelve months with the following levels of assurance provided:- Corporate Governance/Risk Building Maintenance Human Resources Investment Management VAT and PAYE Follow up report Substantial Adequate Adequate Adequate Adequate Adequate The Internal Audit Reports have been reviewed by the Audit Committee and key recommendations have been discussed and implementation followed through. Kingston and Wimbledon YMCA is compliant with the Housing Corporation requirements to combat fraud. The Board has established policies that set out the organisation’s commitment to the highest ethical standards. These are combined with codes of conduct for both employees and Board members, which set out detailed policies. A fraud register has been established to maintain details of all actual or attempted fraud. Any entries on the register wil are reviewed by the Audit Committee. All cases in excess of £5000, or which involve a member of the Board or senior team, will be reported to the Housing Corporation. There are procedures in place if fraud or attempted fraud is discovered. One cases of suspected fraud investigated during the course of the year well below the £5,000 reporting threshold. Whilst the Association has reviewed the internal controls and believe them to be adequate, it is appreciated that further improvement will always be required. Recommendations for improvements will be made to the Board as and when required. Conclusion: There is sufficient evidence to confirm that adequate systems of control existed and operated throughout the year to manage the main risks faced by Kingston and Wimbledon YMCA and in order to achieve the charitable and operational objectives of the Association. Internal Controls – Annual Report July 2007 5 Kingston and Wimbledon YMCA Board’s annual report on internal controls The Board must make an annual statement on internal control for publication with the accounts. The statement must include; An acknowledgement by the Board that it is responsible for the Association’s system of internal control and for reviewing its effectiveness; An explanation that the system of internal control is designed to manage rather than eliminate the risk of failure to achieve business objectives, and can only provide reasonable, and not absolute assurance against material misstatement or loss; An explanation that the process for identifying, evaluating and managing the significant risks faced by the Association is ongoing, has been in place throughout the year under review and up to the date of approval of the report and accounts, and is regularly reviewed by the Board; A summary of the process the Board has adopted in reviewing the effectiveness of the system of internal controls; A summary of the main policies which the Board has established and which are designed to provide effective internal control; and Information on the process the Board has adopted in addressing material internal control aspects of any significant problems disclosed in the annual report and accounts. Reference to regulatory concerns should also be considered if the Housing Corporation has intervened. A suggested draft report is attached for the Board’s consideration once it has undertaken its review of controls. Internal Controls – Annual Report July 2007 6 Kingston and Wimbledon YMCA DRAFT report on internal controls The Board of Management has overall responsibility for establishing and maintaining the Association’s system of internal control and for reviewing its effectiveness. The Board recognises that no system of internal control can provide absolute assurance against financial misstatement or loss or eliminate all risk. The system of internal controls is designed to manage key risks and to provide reasonable assurance that planned business objectives and outcomes are achieved. It also exists to give reasonable assurance about the preparation and reliability of financial and operational information and the safeguarding of the Association’s assets and interests. The Board confirms that there is an ongoing process for identifying, evaluating and managing the significant risks faced by the Association. This approach has operated throughout the year under review up to and including the date of approval of the annual report and accounts. The process adopted by the Board to review the effectiveness of the system of internal control, together with some of the key elements of the control framework that the Board has established includes: Identification and evaluation of key risks: Risk Management is included as an item on all reports considered by the Board. The Board has reviewed the risk register in the course of the past twelve months. Training on risk management for the Board and Senior Staff Team; The adoption of a Strategic and Business Plan setting out strategic and operational objectives for the period 2006 - 2010; The continuation of a Strategic Building Review in order to ascertain the best use of the Association’s property assets in order to meet the changing needs of our client group; The adoption of an annual operating plan and specific departmental plans, with progress being reviewed during the course of the year; The operation of a comprehensive budgeting system and the regular review of financial performance by management and by the Board; The regular review of key performance indicators by management and the Board; The formal appraisal by the Board of the business case for new opportunities; The appointment of new members of the Board of Management with a range of skills to assist in meeting the Association’s key objectives; A scheme of delegation (reviewed during the course of the year) between the Board of Management, the Chief Executive and Senior Staff Team; A detailed staff training plan based upon the outcomes of Regular Work Reviews and regulatory and operational requirements; Internal Controls – Annual Report July 2007 7 The development of a detailed values statements for the Senior Staff Team establishing the culture in which the Association will be managed and extending this to the respective departmental managers. The appointment of a child protection officer with direct access to the Board of Management and statutory authorities. A framework of policies and procedures with which employees must comply. The Board has adopted, amongst others, policies covering financial and accounting procedures, authorisation of transactions, health and safety, protection of children and vulnerable adults, equalities and diversity and various employment polices and procedures, as well as a Code of Conduct for employees. A separate, more detailed Code of Conduct has been introduced for the Chief Executive and Senior Staff Team. Detailed reviews of these polices are carried out at regular intervals. The delegation of operational polices to the Senior Staff Team assessed based upon risk; Up-to-date Criminal Record Bureau Checks for staff and Board members. A robust process of internal audit, undertaken on the basis of risk. The Internal Audit opinion for 2006/07 states:- “..for the twelve months ended 31st March 2007 Kingston and Wimbledon YMCA has adequate and effective risk management, control and governance processes to manage the achievement of the organisation’s objectives.” The Board confirms that there have been no regulatory concerns which have led the Housing Corporation or other regulatory bodies to intervene, nor any significant failures of internal controls which require disclosure in the financial statements. Internal Controls – Annual Report July 2007 8 Review of risk management and control environment This section does not form part of the main report. It is part of the evidence of the review of controls and is used to draw the conclusions in the report. It also draws attention to areas where improvements can be made for future years. This section has been prepared using the Charity Commission Internal Financial Controls self-assessment checklist, the NGO Finance Charities Internal Audit checklist, the Housing Corporation Guidance Notes on Internal Controls Assurance and the Beever and Struthers Corporate Governance Review for Registered Social Landlords (February 2003) to identify questions we should ask ourselves about our internal controls. Risk management Does your Association have a policy on risk management and associated procedures? The Association has a Risk Management Strategy. The main elements of the Risk management process within the Association are: The existence of a risk register that is regularly reviewed and updated. The completion of a risk analysis for all new areas of work. The reporting of risks and controls to the Board of Management. Risk issues included on all Board papers. A full programme of internal audit based upon key risks. An assessment of the Association’s Risk Appetite. Training on risk awareness for the Board and SST. Details of key incidents within the Association to the audit Committee and whether these require the Risk Register to be updated. The Reporting of failures in controls to the Audit Committee for review. A review of the Association’s Risk Strategy is currently outstanding. It has been agreed that this will be carried out once Board training has been Action: continue review of the Risk Map and risk Register. Bring forward the Review of the Risk Strategy to the September meeting of the Audit Committee Have the main risks faced by the association been identified? Yes. There is a risk register that has identified the key risks facing the Association. This has recently been reviewed by the Board and SST and the number of key risks substantially reduced. Departmental Registers are updated for new pieces of work. Details of mitigating factors and responsibilities for the implementation of controls have been identified and are considered by the Senior Staff Team at regular intervals. Are the primary means of controlling these risks documented on the risk register? Yes. –again utilising the “Just Assured” IT system. Are the controls working and have you obtained assurance they are working? Internal Controls – Annual Report July 2007 9 This is achieved through management reporting to the board. It is of course impossible to say whether all the controls are working, and some will be more effective than others. However no major unidentified risks or control failures have come to light in the past year. Failures in controls are reported to the Audit Committee. No failures in controls have been reported for the period in question. Assurance is primarily through management assurances and review of financial and other performance indicators by the Board. Internal Audit has now become a key tool in the provision of assurance – during the course of the last financial year a review was undertaken to assess the awareness of risk management at all levels within the Association – this resulted in substantial assurance being provided to the Board. Are the persons/committees responsible for monitoring controls clearly identified and do they actually carry out the monitoring process? In general the senior team members are responsible for monitoring. This is itself checked by the requirement to report to the Audit Committee and Board. Responsibility for the implementation of controls are clearly identified within the Risk Register. Regular reviews are carried out by the Senior Staff Team with responsibility for co-ordinating action delegated to the Director of Corporate Services. Is the risk register regularly reviewed and updated during the year? The full risk register was reviewed during the course of the past twelve months , utilising the “Just Assured” IT based system. The Board and Senior Staff Team have recently undertaken a substantial review – this will be considered at the July and September Audit Committee meetings. Does the board play an active part in ensuring it is aware of all main risks and how they are managed? Yes. The Board receives and considers risk reports. The Board also regularly receives copies of publications and briefings on risk management and assurance. The Audit Committee monitors the Risk register and the appropriateness of controls. The Board have recently participated in a training seminar on Risk Management. Conclusion: There is an ongoing process for identifying and managing the significant risks faced by Kingston and Wimbledon YMCA, which is regularly reviewed by the Board. The risk management process is effective in identifying the main risks and the controls in place to manage them, and in monitoring whether the controls work. Internal Controls – Annual Report July 2007 10 Control environment Does the Association’s culture, code of conduct, human resource policies and performance reward systems support the business objectives and risk management and internal control systems? Yes. The culture is based on The Association’s Vision, Values, Ethos and Mission. These are clearly communicated to staff through a variety of means, including monthly newsletters and staff meetings. HR policies are under revision to more closely support the business objectives. Staff manuals, procedures and instructions support the risk management and control systems. Significant progress has been made in the past twelve months in order to ensure that all policies and procedures are up to date and fit for purpose. Risk management is starting to become embedded into the management culture – for example regular discussions at SST meetings and Managers’ Conferences. All staff have been encouraged to engage in the identification and management of key risks. Key policies and procedures are issued to all members of staff, along with a staff handbook. The Staff Information and Consultation Group receives reports on key developments within the life of the Association including the management or risk and the opportunities provided for new developments. Action: Continued updating of policies and procedures on a regular basis. Does senior management demonstrate, through its actions as well as its policies, the necessary commitment to competence, integrity and fostering a climate of trust within the Association? Again broadly Yes. The Chief Executive takes a strong lead in fostering a climate of competence, integrity and trust and the SST and indeed staff at all levels support this. In particular the level of integrity and trust expected based upon the Association’s ethos is high. Senior management are expected to be part of the Christian centre of the Association. Senior management in finance and human resources are particularly responsible for ensuring that some key internal control procedures are followed in practice. Staffing levels in both Finance and HR are considered to be appropriate. Are authority, responsibility and accountability defined clearly such that decisions are made and actions taken by the appropriate people? Does the Association communicate to staff what is expected of them and their freedom to act? A scheme of delegation between the Board and the Chief Executive is in place. This also includes responsibilities delegated by the Board to the Chair or in his absence one of the Vice Chairs. Within the senior staff team, each job description contains full details of what is expected of the post holder and their discretion to act, and this is reinforced through line management. Notes of line management meetings are kept and progress in meeting key objectives reviewed at least every other month. Policies and Procedures are communicated to all staff through the regular monthly newsletter and additional staff input and training. Internal Controls – Annual Report July 2007 11 Do staff have the knowledge, skills and tools to support the achievement of the association’s objectives? Broadly, Yes. This is achieved through recruitment, training and line management of staff. Recruitment is carried out through a recruitment procedure which is designed to, and does, ensure that staff with the right competencies are recruited to particular roles. A reasonably generous training budget is set aside to develop staff. The Regular Work Review process has commenced and needs to become more embedded into the lifecycle of the Association. A training and development plan has been developed, and this needs to be embedded further into the management of the Association. Staff induction for new staff takes place regularly with the Chief Executive attending part of every induction programme. All Line Managers are required to successfully complete the nine-day Line Managers Training Programme. All but two line-managers have participated on this programme and they have been scheduled to attend in the next few months. Action: Full implementation of the RWR process Conclusion: The control environment is adequate. There is a culture of relationships based on integrity and trust. Disregard of control procedures are treated seriously. Information and communication Do management and the Board receive timely, relevant & reliable reports on progress against business objectives and the related risks that provide them with the information for decision making? Relevant financial reports are prepared and presented to the Board at every meeting. Cashflow projections are still outstanding but will be produced from September onwards. The Board receives information in a consistent format and this has just been updated to improve its relevance and consistency. Key Performance Indicators are now produced utilising the Balance Score Card Method and based upon targets set by the Board at the start of the financial year. Action: - Cash-flow forecasts to be included in the management accounts on a monthly basis. Are the periodic reporting procedures, including annual reporting, effective in communicating a balanced and understandable account of the association’s position and prospects? Yes – the Board have indicated that Board Reports are clear and consistent and that appropriate reporting mechanisms are in place. Are there established channels of communication for individuals to report suspected breaches of laws or regulations or other improprieties? Yes – within the Whistleblowing Policy and Staff Handbook. Internal Controls – Annual Report July 2007 12 Monitoring Are there ongoing processes embedded within the business operations, which monitor the effective application of the policies and procedures related to internal control and risk management? In some areas, for example controls over expenditure, there is clear and effective monitoring. Internal Audit provides assurance in relation to the operation of key polices and procedures. The Finance Director will undertake a co-ordinating role to ensure that compliance is maintained. Conclusion: information and monitoring controls exist and are adequate but can be improved upon in the future. 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