Appendix 6 Autism Bedfdshire Management Matrix Plan 2014 2015 Registered Charity and Company Limited by Guarantee Charity no: 1100722 Company no: 4632497
Contents A. Introduction... 6 B. Mission/objectives... 7 The Charity s aims/ objectives do not accd with the Constitution... 7 Activities and future developments restricted by objects... 7 The Charity lacks direction, strategy and fward planning... 8 C. Law and regulation... 8 Failure to operate within Charitable Objects... 8 Breach of statuty requirements (e.g., Health & Safety at Wk legislation, Charities Act, Companies Act, Trustees Act etc.)... 9 Adverse Charity Commission moniting visit... 9 Penalties restrictions imposed following control visits... 9 D. Governance and management... 10 Structure/membership of the Board of Trustees and managing committees is inappropriate... 10 Relationship between the Board of Trustees and seni staff is po... 11 Repting to the Trustees is inadequate... 12 Problems exist with seni management team (supervision, communication)... 13 Dominance of key individual(s) on the Board of Trustees... 14 Trustees are benefiting from the charity... 15 Conflict of interest... 16 Lack of strategic plan, poly implemented... 17 E. External facts... 18 Change in political regime/direction.... 18 Change in public perception of charities... 18 Acts of God, impact of adverse weather conditions... 19 Changes in charity taxation, including VAT rules... 19 2
Social and demographic changes... 19 F. Operational facts... 20 Reputation impact of event, fraud, accident, media coverage etc.... 20 Supplier dependency/ difficulties/ bargaining power... 21 Contract risk onerous terms, uncompetitive... 21 Safeguarding of assets (insurance, maintenance, etc.)... 22 Intellectual property inadequately protected... 22 Physical security abuse of staff... 23 Capacity and use of resources including tangible fixed assets... 23 Competition from other bodies... 23 Po security of office from/equipment unauthised usage... 24 Lack of control of third party users... 24 Lack of planning & control of offsite activities e.g., trips & expeditions... 24 Lack of written policies and procedures failure to keep them up-to-date... 25 Disaster recovery procedures in place... 25 Breach of regulations e.g. Data protection Act, Food Standards, Children s Act... 25 G. Human resources... 26 Loss of key members of staff i.e., lack of succession-planning... 27 Difficulties in recruiting/retaining staff... 27 Failures in staff-vetting procedures... 28 Po wking practices e.g. discrimination bullying... 28 Po staff male... 29 Po lack of terms and conditions... 29 Breaches of employment laws, e.g. wking time directive, stakeholder pensions... 29 Po staff training and development... 30 Inadequate supervision control of volunteers... 30 3
Dependence on a key individual... 30 Po recruitment procedures... 31 H. Environmental... 31 Difficulties with residential home planning applications and highway access clearance... 31 I. Technological... 32 Increased need to invest in new technology/ po use of IT... 33 Failure of key software/hardware... 33 Weak systems selection and implementation procedures... 33 Lack of disaster recovery planning, including backups... 34 J. Financial... 35 Weak ineffective financial controls and... 36 Inadequate financial planning and fecasting... 36 Po inaccurate financial repting and management accounts... 36 Income levels inadequate... 37 Po investment management and perfmance... 37 Qualified external audit rept... 37 Unplanned tax/vat liabilities... 38 Inadequate inappropriate insurance cover... 38 Capital expenditure plans not defined... 38 Lack of a reserves policy... 38 K. Funds and fundraising... 39 Sensitive cash flow situation resulting in pressures to meet financial commitments and adversely impacting operational activities... 40 Uncompetitive unrealistic charges... 40 Non-compliance with don / funder imposed restrictions... 40 Deteriation in relationship with funders... 41 Inappropriate terms and uncompetitive browing rates... 41 4
Guarantees to third parties... 41 Pension commitments are not being met... 42 Failure to meet fundraising targets... 42 Po control of fundraisers... 42 Lack of control of branches and suppt groups... 42 Breach of Inland Revenue rules on small scale trading... 43 Non-compliance with laws and regulations regarding fund raising activities, including use of professional fundraisers... 43 L. Fraud... 44 Lack of consideration of the potential f fraud... 44 Po employee education and understanding of the implications of fraud... 45 Response to fraud is inappropriate... 45 Po internal controls which impinge on ability to detect fraud... 46 5
A. Introduction Purpose of this document This document sets out the key risks as assessed by the Trustees, both financial and non-financial. The document recds the assessment made by the Organisation and is to be revisited on a regular basis. The relative imptance of each of the risks identified has been assessed through consideration of the likelihood of incidence and the potential impact on Autism Bedfdshire. The matrix uses a simple scing system as follows: (3) Likely (2) Possible Possible even chance of happening (1) Remote Extremely unlikely Expected me than even chance of happening (3) Critical (2) Maj (1) Manageable Will make a material difference Will make a difference deemed to be Remote Possible Likely -1-2 -3 Critical (3) M (3) H (6) H (9) H = High Maj (2) L (2) M (4) H (6) M = Medium L = Low Manageable (1) L (1) L (2) M (3) Controls in place which mitigate the risks identified have been recded along with the names of the individuals assigned responsibility f the operation and moniting of those controls. In cases where further action is required, the steps to be taken have been recded. 6
B. Mission/objectives Fact (1), maj (2) The Charity s aims/ objectives do not accd with the Constitution L(1) 1 1 Protocol f reviewing new projects to ensure consistency with objects, powers and terms of funding and consistency with Constitution AGM 2014 to present proposed changes, aligned with 3 Year Strategic Plan and as recommended by solicits Park Woodfine Heald Mellows LLP Trustee s. Fmal Review following AGM in November board meeting 2014. To be fmally reviewed annually by Trustee s. Set out a strategic plan which set out key aims, objectives and policy. Activities and future developments restricted by objects 2 2 Protocol f reviewing new projects to ensure consistency with objects, powers and terms of funding Authisation procedures, moniting and repting Trustee s. Included in Fmal annual review. Considered in Wking Group meetings relating to developments in activity. To be fmally reviewed annually by Trustee s and in Wking Group meetings. Financial systems to identify restricted funds and their application 7
Fact (1), maj (2) The Charity lacks direction, strategy and fward planning L(1) 1 1 Creation of a strategic plan which sets out the key aims, objectives and policies Creation of financial plans and budgets of financial and operational perfmance Trustee s. Monthly Board meeting to measure results against targets set in Strategic and Operational Plan and monit financial and operational perfmance. Ensure feedback is gathered from all stakeholder groups, including beneficiaries and funders. C. Law and regulation Fact (1), maj (2) Failure to operate within Charitable Objects 2 2 As above Trustee s. As above As above 8
Fact (1), maj (2) Breach of statuty requirements (e.g., Health & Safety at Wk legislation, Charities Act, Companies Act, Trustees Act etc.) 2 2 Policies and procedures documented and communicated to visits & staff as appropriate Trustee s Service Manager to ensure training is delivered. Monthly Board meeting to monit Health and Safety designated Trustee. Ensure Administrat is suppted to keep up to date. Ensure feedback is gathered from all stakeholder groups, including beneficiaries and funders. Recruit Trustees from HR/Legal background to strengthen moniting. Adverse Charity Commission moniting visit 1 1 As above As above As above As above L(1) Penalties restrictions imposed following control visits 2 2 Policies and procedures documented and communicated to visits & staff as appropriate As above As above As above 9
D. Governance and management Fact (1), maj (2) Structure/membership of the Board of Trustees and managing committees is inappropriate 2 2 Review of structure and constitutional change to ensure that the Board contains the necessary experience and skills Skills review Competence framewk and job descriptions Trustee s. Monthly Board meeting to monit recruitment process and probation of new Trustee s. Toolkit developed. Annually review and agree recruitment process. Training and Recruitment process Organisation chart and clear understanding of roles and responsibilities 10
Fact (1), maj (2) Relationship between the Board of Trustees and seni staff is po H(6) 2 3 Fmal and infmal lines of communication are clearly understood and documented, as appropriate Trustee s. Robust recruitment, training and probation period. Line manager of the board to bi monthly supervise. All board members to be accessible and perfmance management criteria to be followed. Team Build days to unite through common goals. 11
Fact (1), maj (2) Repting to the Trustees is inadequate 2 2 Proper strategic planning, objective setting and budgeting processes Timely and accurate project rept Timely and accurate financial rept Proper project assessment and authisation procedures Regular contact between Trustees and management Trustee s. Line Management perfmance management criteria followed. Clear measurable targets set out in the strategic goals to rept against. Agree infmation and fmat to be shared. Timely repting agreed, occurrence timed to include month end financial repting. Trustee s governance and repting training. Ensure adequate suppt and resource is in place. Perfmance management meetings arranged bi-monthly me frequently to address the concerns. Succession planning. Regular contact links between board and team, i.e. Trustee to attend team meetings adhoc. 12
Fact (1), maj (2) Problems exist with seni management team (supervision, communication) 2 2 Organisation chart and clear understanding of roles and responsibilities Competence framewk and role descriptions Delegation and moniting, which is documented and communicated, is consistent with good practice Trustee s. Line Management perfmance management criteria followed. Clear measurable targets set out in the strategic goals to rept against. Agree infmation and fmat to be shared. Timely repting agreed, occurrence timed to include month end financial repting. Trustee s governance and repting training. Ensure adequate suppt and resource is in place. Perfmance management meetings arranged bi-monthly me frequently to address the concerns. Succession planning. Regular contact links between board and team, i.e. Trustee to attend team meetings adhoc. 13
Fact (1), maj (2) Dominance of key individual(s) on the Board of Trustees 2 2 Consider the structure of the Board and their independence Mechanisms agreed to deal with potential conflicts of interest Recruitment and appointment processes and constitutional validity Procedural framewk f meetings and recding decisions Trustee s. Reviewed monthly at board meetings. Review of structure and constitutional change to ensure that the Board contains the necessary experience and skills Competence framewk and job descriptions Training Exit Strategies made clear in Trustee Recruitment Toolkit. Skills review and succession planning. Menting and counselling suppt to ensure that Trustees can debrief to an independent person. Peer suppt to be fmalised into the supervision that it provides. Recruitment process probations and supervisions Organisation chart and clear understanding of roles and responsibilities 14
Fact (1), maj (2) Trustees are benefiting from the charity 2 2 Ensure legal authity f payment benefit Terms and procedures to authise/approve expenses and payments Procedures and methods to establish fair payment, conducted separately from interested Trustee Trustee s. Monthly meetings. board Financial checks and counter signaties f all expenses are a member of the Finance Team and Trustee. Recruitment process and training on Volunteers and the Law made available to all Trustees and mandaty f new Trustee recruitment. Finance Direct to monit governance expenditure, along with Approved by the Board 15
Fact (1), maj (2) Conflict of interest L(2) 2 1 Understanding of trust law Protocol f disclosure of potential conflicts of interest Procedures f standing down on certain decisions Recruitment and selection processes Trustee s. AB adheres to the Nolan 7 principles which should be applied in public life. These are: selflessness, integrity, objectivity, accountability, openness, honesty and leadership. One imptant means by which Autism Bedfdshire may demonstrate that it is applying these principles is by maintaining a Register of Business Interests. Annual review of recruitment and selection process. Exit strategies included in recruitment process and toolkit. HR suppt available via HR contract with Bedfd Bough Council. 16
Fact (1), maj (2) Lack of strategic plan, poly implemented 2 2 Proper strategic planning, objectives setting and budgeting processes in place, requiring Trustee approval Trustee s. Monthly team meetings f areas within the ganisation to rept back on targets against Strategic and Operational Plan. Finalise 3 Year Strategic Plan and 1 Year Operational Plan, setting out; key aims, objectives and policies. Create financial plans and budgets. Monthly Board meetings to review and monit progress against targets against Strategic and Operational Plan Use job plans and targets. Monit financial and operational perfmance. Obtain regular feedback from beneficiaries and funders. 17
E. External facts Fact (1), maj (2) Change in political regime/direction. Change in public perception of charities 2 2 2 2 of proposed legal and regulaty changes Membership of umbrella bodies Communication with suppters and beneficiaries Quality financial, annual rept and review repting PR training/procedures Trustee s. Trustee s. Monthly meetings. Board Stakeholder relationship events (i.e. AGM). Monthly meetings. Board Stakeholder relationship events (i.e. AGM). Ensure profiled is raised to demonstrate need, high quality and best value. Stakeholder communications to be regular and effective Ensure profiled is raised to demonstrate need, high quality and best value. Stakeholder communications to be regular and effective. Devise Media, Marketing and Communications Plan. 18
Fact (1), maj (2) Acts of God, impact of adverse weather conditions L(2) 1 2 State of repair of buildings kept under review. Fmal facilities management arrangements. Repairs and maintenance budget Appropriate insurance in place Data Officer, Adult Services Manager and Administrat. Rept moniting to Trustee s. Data Officer to complete weekly & monthly checklists. Add all further actions required to checklist. Agree IT Recovery Plan. Implement data backup procedures and review security arrangements. Review insurance cover.. Changes in charity taxation, including VAT rules 2 2 Fmal moniting of the position to understand implications of changes Wking with specialists (appointed accountants) who provide appropriate advice Trustee s. Monthly Finance repts to include changes, impact and recommendations. SORP training f Key Finance Personnel Social and demographic changes L(2) 1 2 of changes and implications Trustee s. Equality and diversity monited in monthly repts and quarterly data submissions. Install Google Translate and partnership links with all groups. 19
F. Operational facts Fact likely (3) (1), maj (2) Reputation impact of event, fraud, accident, media coverage etc. H(6) 2 3 Financial control procedures Segregation of duties Authisation limits Security of assets Insurable risks Complaints procedures (both internal and external) Proper review procedures f complaints Trustee s all stakeholders to be aware. Rigous recruitment process, particularly with seni / finance related positions. Policies and procedures to reflect practice and with measures and safeguards to mitigate risks. Ensure successes, assets and achievements are celebrated through all our communications and press articles. Review the policies f Finance bi-annually and all policies minimum annually. Maintain good relations with all stakeholders. Designated management Trustee. risk Crisis management strategy f handling, consistency of key messages, nominated spokesperson etc 20
Fact likely (3) (1), maj (2) Supplier dependency/ difficulties/ bargaining power L(2) 2 1 Use of competitive tendering f larger contracts Procedures f obtaining quotations Authised suppliers listing Trustee s and Administrat. Monthly reviews of suppliers and Administrat to check price comparisons. Review and rept concerns ongoing. of quality/timeliness of provision Use of service level agreements Use of buying constia Contract risk onerous terms, uncompetitive 2 2 Cost/project appraisal procedures Authisation procedures Professional advice on terms and conditions Trustee s and Administrat. Monthly reviews of suppliers and Administrat to check price comparisons. Review and rept concerns ongoing. Perfmance arrangements moniting Insurable risks cover 21
Fact likely (3) (1), maj (2) Safeguarding assets (insurance, maintenance, etc.) L(1) of 1 1 Review of security Asset register and inspection programme Facility management arrangements Safe custody arrangements f title documents Trustee s and Administrat. Bi-annual reviews of suppliers and Administrat to check price comparisons. Review and rept concerns ongoing. Ensure that checklists are held up to date and any new contracts relating to office premises hire are screened by AB solicit. Management of patent and intellectual property Insurance reviews Intellectual property inadequately protected L(1) 1 1 Registration of trademarks and patents Security of electronically held data Trustee s and Administrat. Bi-annual reviews of suppliers and Administrat to check price comparisons. Review and rept concerns re transparency ongoing. 22
Fact likely (3) (1), maj (2) Physical security abuse of staff 2 2 Review of security Recruitment procedures including vetting of staff and volunteers Training and supervision procedures Trustee s, Child and Adult Service Managers. Bi-annual reviews of suppliers and Administrat to check price comparisons. Review and rept concerns ongoing. Ensure that all contact is risk assessed and staff and volunteers are adequately trained f their roles, including health and safety training. Capacity and use of resources including tangible fixed assets L(1) 1 1 Building and ganisation inspection programme Repair and maintenance programme Capital expenditure budgets Efficiency review Trustee s, Child and Adult Service Managers. Bi-annual reviews of suppliers and Administrat to check price comparisons. Review and rept concerns ongoing. Competition from other bodies 2 2 Public and authity awareness of the charity. Seni Funding Officer to ensure data and proposal kept up to date and repts issued timely. Trustee s, Child and Adult Service Managers. Keep good relations with key funders rept results against best quality and price. Attend local netwk meeting to gauge competits and threats. Ensure VFM is promoted. 23
Fact likely (3) (1), maj (2) Po security of office from/equipment unauthised usage Lack of control of third party users 2 2 Review of security 2 2 Review of security Authisation procedures f usage of charity property Training and supervision procedures, Assistant Development Officer and Facilities Manager., Assistant Development Officer and Facilities Manager. Keep checklist of all equipment, and ensure all items are cosigned in and out. Keep checklist of all equipment, and ensure all items are cosigned in and out. Establish system and also add to exit interview paperwk. Establish system and also add to exit interview paperwk. Lack of planning & control of offsite activities e.g., trips & expeditions 2 2 Review of security Review and communication of procedures Recruitment procedures including vetting of staff and volunteers Training and supervision procedures, Seni Finance Officer and Finance Direct Restrictions and petty cash control sheet. 100 limit f petty cash. No authised expenditure above 50 without s signed consent. Debit card policy and procedure and limited to as the card holder. 24
Fact likely (3) (1), maj (2) Lack of written policies and procedures failure to keep them up-to-date 2 2 Proper documentation of policies and procedures Audit and review of systems Trustee s. Annual review in May and June. HR BBC and AB solicits to suppt ensuring that they are kept up to date and audited annually. Disaster recovery procedures in place M(3) 1 3 Disaster recovery plan and procedures in place addressing operations in addition to IT Training, perfmance management and bi-monthly supervisions of Seni Team. Trustee s. Monit funding and perfmance monthly. Annual service scoping to establish der and cover of services to be cut depending on local provision and priities. Breach of regulations e.g. Data protection Act, Food Standards, Children s Act H(6) 2 3 Appropriate policies and procedures in place; documented and communicated to visits and staff as appropriate Trustee s. All staff and Volunteers. All staff and volunteers to follow a robust recruitment process. Inductions and training logged. Policies updated annually. 25
G. Human resources Fact (1), maj (2) 26
Fact (1), maj (2) Loss of key members of staff i.e., lack of succession-planning 2 2 Succession planning Documentation of systems, plans and projects Training programmes Board of Trustee s, and Seni Management Team. Monthly board repts and meetings; bimonthly supervisions; Appraisals. Perfmance Management, pay scales audits. Staff retention monited and repted annually. Notice periods and handovers Recruitment processes Difficulties in recruiting/retaining staff 2 2 Established recruitment process, subject to regular review Review of staff perfmance and salary levels Marketing and advertising activity Board of Trustee s, and Seni Management Team. Staff retention monited and repted annually. If 3 key staff resigns within 3 months, the board need to investigate. Target skills and experience required and all advertising avenues; social media, press, internally and targeted. 27
Fact (1), maj (2) Failures in staff-vetting procedures H(6) 2 3 Recruitment processes Reference and qualification checking procedures, job descriptions, contracts of employment, appraisals and feedback procedures and Seni Management Team and Assistant Development Officer. Recded bi annual sample quality control checks on staff and volunteer file. Annual HR checks against infmation requested. Job training and development Health and safety training and moniting Staff vetting and legal requirement checks Po wking practices e.g. discrimination bullying H(6) 2 3 Equal opptunities policies in place documented and communicated Where inappropriate behaviour identified appropriate action taken and Seni Management Team and Assistant Development Officer. Seni teams to monit and deliver supervision programs. Training and Induction documented and communicated 28
Fact (1), maj (2) Po staff male 2 2 Interview and assessment processes Fair and open competition appointment f key posts Job descriptions, perfmance appraisal and feedback Conduct exit interviews and Seni Management. Supervisions, Appraisals, team meetings, board meetings, team days and open do communication and suppt available. External suppt via ICT Counselling Suppt Service made available to all staff and volunteers. Consider rates of pay, training, wking conditions, job satisfaction Po lack of terms and conditions 2 2 Job descriptions, contracts of employment, appraisal and feedback processes in place and Seni Management Team. Seni teams to monit and deliver supervision programs. Training and Induction documented and communicated Breaches of employment laws, e.g. wking time directive, stakeholder pensions H(6) 2 3 Change in regulations monited and documented Contracts of employment amended fm new legislation as appropriate and Seni Management Team. Seni teams to monit and deliver supervision programs. Training and Induction documented and communicated 29
Fact (1), maj (2) Po staff training and development 2 2 Job descriptions and fmal appraisal process Training needs fmally identified and addressed and Seni Management Team and Assistant Development Officer. Seni teams to monit and deliver supervision programs and perfmance moniting appraisals. Training and Induction documented and communicated Inadequate supervision control of volunteers 2 2 Appropriate policy documented and communicated to staff and volunteers and assessment of supervision and Seni Management Team and Assistant Development Officer. Seni teams to monit and deliver supervision programs and contribution reviewed. Training and Induction documented and communicated Dependence on a key individual 2 2 Succession planning Documentation of systems, plans and projects Training programmes Board of Trustee s, and Seni Management Team. Monthly board repts and meetings; bimonthly supervisions; Appraisals. Perfmance Management, pay scales audits. Staff retention monited and repted annually. Notice periods and handovers Recruitment processes 30
Fact (1), maj (2) Po procedures recruitment 2 2 Procedures documented and reviewed Board of Trustee s, and Seni Management Team. Perfmance and retention monited and repted. Training and induction programmes recded and evaluated. H. Environmental Fact (1), maj (2) Difficulties with residential home planning applications and highway access clearance L(2) 2 1 Review of regulation Communication with planning and other bodies Residential Project Manager, Board of Trustees and Project Manager to rept to the Board of Trustees and Seni Manager. Ensure feasibility study is conducted and environmental facts scoped. 31
I. Technological Fact (1), maj (2) 32
Fact (1), maj (2) Increased need to invest in new technology/ po use of IT 2 2 Appraisal of systems needs and options IT Suppt Consultant and. Bi annual reviews of Service Level Agreement. Feasibility study conducted to validate proposed significant increases. Failure of key software/hardware H(6) 2 3 Security and authisation procedures and Implementation and development procedures Use of service and suppt contracts Disaster recovery procedures, Adult Services Manager and IT Suppt Consultant. Weekly backups remote drive. logged to hard SLA inclusive of maintenance checks. Internal additional backups of SAGE and ABShare, shared drive. Outsourcing and Insurable loss Weak systems selection and implementation procedures 2 2 Appraisal of systems needs and options, Adult Services Manager and IT Suppt Consultant. SLA inclusive of assessment of needs. Internal additional backups of SAGE and ABShare, shared drive Competitive quotes sought. 33
Fact (1), maj (2) Lack of disaster recovery planning, including backups H(6) 2 3 IT recovery plan and Insurance cover and Data backup procedures and precautions Disaster recovery plan f alternative accommodation, Adult Services Manager and IT Suppt Consultant. SLA inclusive of assessment of needs and detailed recovery plan. Internal additional backups of SAGE and ABShare, shared drive External hard drive updated weekly by Adult Services Manager 34
J. Financial Fact (1), maj (2) 35
Fact (1), maj (2) Weak ineffective financial controls and Inadequate financial planning and fecasting H(6) 2 3 Budgets linked to business planning and objectives Proper costing procedures f product service delivery Adequate skills base to produce and interpret budgetary and financial rept Procedures to review and action budget/cash flow variances Chair, Finance Direct, Board of Trustees and, Seni Finance and Funding Officer. Finance Wking Group Bi-annual meetings. Board meetings Finance Repts. Timely accurate moniting repting and and AB Accountant Garner Associates to meet bi-annually re fecasting, policies and procedures and year end audits. Po inaccurate financial repting and management accounts H(6) 2 3 As above Chair, Finance Direct, Board of Trustees and, Seni Finance and Funding Officer. Finance Wking Group Bi-annual meetings. Board meetings Finance Repts. AB Accountant Garner Associates to meet bi-annually re fecasting, policies and procedures and year end audits. 36
Fact (1), maj (2) Income inadequate H(6) levels Po investment management and perfmance 2 3 Policies and procedures f approval of charges and income levels (budgets) 2 2 Marketing strategy and capability Review and assessment of competit markets and strategies Investment policy Proper investment advice management Diversity, prudence and liquidity criteria Adequate reserves policy Chair, Finance Direct, Board of Trustees and, Seni Finance and Funding Officer. Chair, Finance Direct, Board of Trustees and, Seni Finance and Funding Officer. Finance Wking Group Bi-annual meetings. Board meetings Finance Repts. Finance Wking Group Bi-annual meetings. Board meetings Finance Repts. Re-establish priities. 1. Increasing revenue/income streams. 2. Cuts to services. Re-establish priities. 1. Increasing revenue/income streams. 2. Cuts to services. Qualified external audit rept Regular perfmance moniting 2 2 Policies and procedures documented Review procedures in place Chair, Finance Direct, Board of Trustees and, Seni Finance and Funding Officer. Finance Wking Group Bi-annual meetings. Board meetings Finance Repts. AB Accountant Garner Associates to meet bi-annually re fecasting, policies and procedures and year end audits. 37
Fact (1), maj (2) Unplanned liabilities tax/vat 2 2 of the position to ensure compliance Seni Finance Officer and. Real time tax paid monthly and VAT checked with HMRC. AB Accountant Garner Associates to meet bi-annually re fecasting, policies and procedures and year end audits. Inadequate inappropriate insurance cover 2 2 Review of insurance requirements Policies and procedures f negotiating insurance terms and claims Board of Trustee s, Administrat and Seni Manager. Annual checklist f Insurance Charity Commission submissions and quality control checks. Capital expenditure plans not defined 2 2 Appropriate budgeting processes requiring Trustee approval Regular moniting of perfmance and capital expenditure Board of Trustee s, Administrat and Seni Manager. Monthly Finance Repts and Finance Wking Groups. 3 Year and 1 Year Strategic Plans. All expenditure greater than 1000 co signed by Finance Direct and. Lack of a reserves policy 2 2 Appropriate reserves policy approved by the Trustees and communicated Reserves policy fully explained in the Annual Trustees rept Board of Trustee s and. Revised annually f the Annual Rept and Published Accounts. Reviewed in bi-annual Finance Wking Groups. 38
K. Funds and fundraising Fact (low, medium High) (low, medium High) 39
Fact (low, medium High) (low, medium High) Sensitive cash flow situation resulting in pressures to meet financial commitments and adversely impacting operational activities H(6) 2 3 Adequate cash flow projections (prudence of assumptions) Identification of maj sensitivities Adequate infmation flow from operational managers arrangements and repting, Finance Direct and Seni Funding and Finance Officers. Monthly rept on accounts and cash flow. Fecast reviews monthly board repts. Finance Wking Groups Agreement in principal with CAF Bank re: tempary overdraft facility and loan options. Uncompetitive unrealistic charges 2 2 Procedures to agree charges (budgets) Procedures f approval of variations to charges (budgets), Finance Direct and Seni Funding and Finance Officers. Child and Adult Wking Groups Stakeholder consultations and evaluations Annual review of fee s and comparisons to other voluntary ganisations. Non-compliance with don / funder imposed restrictions 2 2 Systems to identify restricted receipts Budget control, moniting and repting arrangements, and Seni Funding and Finance Officers. Monthly Funding and Finance meetings. Accounts nominal coding Variation agreements sought funding returned. 40
Fact (low, medium High) (low, medium High) Deteriation relationship funders H(6) in with 2 3 Regular contact and briefings to maj funders Project repting Meeting funders terms, conditions and requirements, Child and Adult Services Managers. Monthly repts Bi-annual quarterly repting. Board and Contracts clearly outlining expectations and output and outcomes to be repted on. Inappropriate terms and uncompetitive browing rates 2 2 Appraisal of future income streams Appraisal of terms (rates available, fixed, capped, variable etc.) Property advice procedures, Finance Direct and Seni Funding and Finance Officers. Project Management of all new projects with clearly identified funding streams and strategies, Finance Direct assess need against plans Guarantees to third parties L(1) 1 1 Approval and authity procedures Procedures to ensure consistency with objects, plans and priities Financial repting of contingency and amendment to reserves policy, Finance Direct and Seni Funding and Finance Officers. Monthly repts Bi-annual quarterly repting. Board and, Finance Direct assess need against plans 41
Fact Pension commitments are not being met (low, medium High) (low, medium High) 2 2 Review and approval of monthly payroll & Seni Finance Officers. Monthly and repting payroll pension and Finance Direct monthly co-sign. Failure to meet fundraising targets H(6) 2 3 of perfmance Appropriate reserves policy in place and Seni Funding Officer Monthly repting to the board. Monthly meetings funding Effective annual fecasting and moniting. Repeat grant funding secured. Po control of fundraisers 2 2 Fundraisers issued with fmal guidance booklet Fmal targets/budgets set and perfmance monited against targets and Seni Funding Officer Monthly repting to the board. Monthly meetings funding Lack of control of branches and suppt groups 2 2 Appropriate repting lines and infmation requirements established Fmal targets/budgets set and perfmance monited against targets Seni Funding Officer and Service Managers Sessional returns Restricted purchases and limited petty cash Training and Induction documented 42
Fact Breach of Inland Revenue rules on small scale trading (low, medium High) (low, medium High) 2 2 Appropriate moniting of trading activity Establishment of trading subsidiary other vehicle Seni Finance Officer and Seni Manager. Real time tax paid monthly and VAT checked with HMRC. AB Accountant Garner Associates to meet biannually re fecasting, policies and procedures and year end audits. Non-compliance with laws and regulations regarding fund raising activities, including use of professional fundraisers H(6) 2 3 Appraisal, budgeting and authisation procedures Review of regulaty compliance of the adequacy of financial returns achieved (benchmarking comparisons) Complaints review procedures Seni Funding Officer and Seni Manager. Monthly Funding meetings Monthly repting to the board AB Accountant Garner Associates to meet biannually re fecasting, policies and procedures and year end audits. AB adheres to charity Commission guidance: http://www.charitycommis sion.gov.uk/detailedguidance/money-andaccounts/internalfinancial-controls-fcharities-cc8 Recruitment, Induction and Training f all fundraisers. Superviosn, appraisal ad suppt programmes available 43
L. Fraud Fact (1), maj (2) Lack of consideration of the potential f fraud 2 2 Fraud is assessed as a risk The different types of fraud to which the charity is exposed have been identified and appropriate policies, procedures and responsibilities f managing the risk are in place Trustees Annual compliance checks of all policies and procedures. Funding and Finance training to be under taken by key staff in funding, finance and management. 44
Fact (1), maj (2) Po employee education and understanding of the implications of fraud 2 2 The charity has a fraud policy statement which is communicated to all employees The fraud policy statement is regularly reviewed f compliance and updated A fraud prevention education/training programme is in place Trustees Annual compliance checks of all policies and procedures. Funding and Finance training to be under taken by key staff in funding, finance and management. The charity has a clear whistleblowing policy Recruitment and ongoing personnel policies are in place, which address the risk of fraud Response to fraud is inappropriate H(6) 2 3 All instances of suspected fraud are investigated Where fraud is detected and proven appropriate action is taken to recover any loss and deter reoccurrence The board of Trustees and Financial Controls, Policies and Procedures A documented plan of action is in place to be followed in the event of a fraud being detected Through audit plans Restricted access to funds 45
Fact (1), maj (2) Po internal controls which impinge on ability to detect fraud 2 2 Policies, procedures and controls in place in respect of the transaction and accounting systems Controls in place over the security of assets/property, Seni Officers, Finance Direct Trustee s Rigous background checks recruitment f key staff and volunteers Seni team to carry out fraud risk assessment, including both prevention and detection methods Key staff to attend training to identify fraud Track cash donations Appropriate budgeting and management accounting and other repting in place to aid moniting of perfmance Whistle blowing policy communicated Fraud action plan to be created 46