RISK MANAGEMENT POLICY Adopted 18 March 2013 Incorporating Annual Review (2014) Incorporating Annual Review (2015) RISK MANAGEMENT POLICY 2013 Contents of Risk Management Policy Contents 1.0 INTRODUCTION 2.0 CONTEXT 3.0 POLICY STATEMENT 4.0 OBJECTIVES 5.0 DEFINITIONS 6.0 APPLICATION 6.1 Council 6.2 The Audit Committee 6.3 Chief Executive Officer 6.4 The Executive Management Team (EMT) 6.6 Managers 6.7 Coordinators 6.8 Risk Management Unit 6.9 Employees and Temporary Staff 6.10 Contractors 7.0 REFERENCES and SOURCE 8.0 THE RISK MANAGEMENT PROCESS 8.1 The Continuum of Assessment and Review 8.2 Communication and Consultation 8.3 Establishing the Context 8.4 Identification of Risks 8.5 Assessment 8.6 Risk Appetite 8.7 Treatment 8.8 Implementation 8.9 Performance Measuring 8.10 Monitoring and Review 8.11 Records 9.0 REVIEW 10.0 ATTACHMENTS Attachment 1 – Risk Consequence Criteria Attachment 2 – Risk Controls Criteria Attachment 3 – Risk Likelihood Criteria Attachment 4 – Risk Matrix Attachment 5 – Risk Rating Definitions Attachment 6 – Definition of Risk Status Adopted by Council on 18 March 2013 3 3 4 4 5 7 7 7 7 8 8 9 9 10 11 11 12 12 14 14 14 15 16 17 18 18 19 20 20 20 21 22 23 24 25 26 2|Page RISK MANAGEMENT POLICY 2013 1.0 INTRODUCTION The management of risk is recognised as an integral part of good management practice. Effective risk management supports informed decision making and encourages the identification of opportunities for continuous improvement. Risk Management is no longer accepted as only a process of good operating standards but rather, as a critical element of sound governance across an organisation. Council, through its management accountability systems, internal audit programs, Audit Committee, risk assessment processes, occupational health & safety systems and various other policies and procedures, has a strong commitment towards the principles of risk identification, risk assessment and risk removal/minimisation or elimination. This Policy and procedure formalises and details Council’s approach to organisational risk management and provides a framework for the ongoing conduct of risk identification, assessment and minimisation practices across the organisation. The principles supporting this Policy are based on the International Standard for Risk Management, ISO AS/NZS 31000 - 2009 Risk Management – Principles and Guidelines. 2.0 CONTEXT The context within which this Policy is written is one of ongoing strong governance and leadership. Since its formation in 1994, the City of Stonnington has continuously delivered to its ratepayers and residents, stability in government, excellence in service/facilities within a backdrop of growing prosperity. The City of Stonnington is a Council within the meaning of the Local Government Act 1989 and has been given the authority and guidance to raise revenue from rates and charges, adopt it own budget independent of other governments or agencies and to adopt its own local laws to uniquely regulate its district. The determinations and considerations made in this Policy have been based on the legislated framework within which the Council exists and operates. It is based on this context that the risk appetite of Council has been declared. Stonnington has achieved a significant place within Local Government in Victoria as a stable and high performing Council. It guards its reputation conscientiously and invests significant resources to maintain and improve it. This achievement is to be seen against the backdrop of a business which is performing and delivering scores of diverse functions any of which have the potential to impact negatively on this reputation with its residents, visitors and the State Government. As a consequence, Council’s Risk Appetite is variable and commensurate with the risk being assessed. However, Council’s appetite to risks that encompasses corruption, fraud, theft or personal harm or injury is zero. To accommodate this, Council has established a program of continuous development and review of Policies, procedures, organisational structures and systems that are all designed to mitigate the likelihood and consequence of risk. Adopted by Council on 18 March 2013 3|Page RISK MANAGEMENT POLICY 2013 3.0 POLICY STATEMENT CITY OF STONNINGTON RISK MANAGEMENT POLICY STATEMENT The City of Stonnington is actively committed to the management of risk and reducing its exposure in all facets of its business. It endeavours to ensure that all necessary practices and procedures are effective and fully implemented to control any risks and thereby providing employees and the community with services, facilities and an environment which are sound, safe and inviting. By this commitment to Risk Management, the City of Stonnington aims to:a) Provide safe, quality facilities and environment for all stakeholders; b) Ensure there is an open and objective rationale for managing risk; c) Ensure that risk forms an integral part of all decision-making; d) Maintain appropriate budgetary levels to enable the effective management of risks related to Council’s physical assets; e) Provide appropriate training and information to all employees and contractors on risk management and risk reduction techniques; f) Ensure all employees are accountable for their actions including compliance with policies and procedures; and g) Work in partnership with the community, employees and contractors to identify, minimize, or eliminate potential and future risks. Warren Roberts Chief Executive Officer 4.0 OBJECTIVES The objectives of the Risk Management Policy are to: define risk in the context of Council; articulate Council’s commitment to risk management; provide broad guidance to Council’s General Managers, Managers and Coordinators, to enable them to fulfil their Risk Management responsibilities; introduce the fundamental principles and measures of risk; promote and support risk management and hazard identification practices throughout the organisation; recognise that successful risk management relies on input from all employees; and protect Council’s corporate image. Adopted by Council on 18 March 2013 4|Page RISK MANAGEMENT POLICY 2013 5.0 DEFINITIONS For the purpose of this Policy, the following definitions will apply. Commercial Risk Risk such as a failed contract or business relationship. Compliance Risk Risk of failing to meet statutory obligations. Consequence The impact on an organisation should an event occur. For details refer Attachment 1. Contractor An independent entity that agrees to furnish a certain number or quantity of goods, material, equipment, personnel, and/or services that meet or exceed stated requirements or specifications, at a mutually agreed upon price and within a specified timeframe. Co-ordinators All fourth level managers. Usually in charge of a Service Unit. Employee Includes all permanent and temporary employees of Council within the meaning of the Industrial Relations Act 1996 and includes the Chief Executive Officer. Executive Management Team Comprises the Chief Executive Officer and General Managers Financial & Systems Risk Risk posed to Council’s financial systems and controls such as fraud. General Manager All second level managers. Usually in charge of a Division. Hazard A source of potential harm or a situation with a potential to cause injury, damage or loss. Likelihood The probability of an event occurring. Attachment 3. Managers All third level managers. Usually in charge of a Department. Monitor To check, supervise, observe critically, or record the progress of an activity, action or system on a regular basis in order to identify change. Operational Risk Risk which occurs in, hampers or effects an individual Division, Department, Service Unit or area of an organisation. Risk The chance of an event occurring that will have an adverse effect on business objectives. It is measured in terms of consequences and likelihood. The consequent liability is usually measure in financial terms, but may involve bodily injury, financial loss or property damage. Adopted by Council on 18 March 2013 For details refer 5|Page RISK MANAGEMENT POLICY 2013 Risk Analysis A systematic use of available information to determine how often specified events may occur and the magnitude of their consequences. Risk Appetite The amount and type of risk that an organisation is willing to take in order to meet its strategic objectives. Risk Appetite is best described as an organisation’s pursuit of risk or its willingness to take risks as opposed to avoiding them. Risk Assessment The overall process of risk analysis and risk evaluation. Risk Control That part of risk treatment which involves the implementation of policies, standards, procedures and physical changes to a thing, work process or system of work to eliminate or minimise the impact of the risk. Risk Evaluation The process used to determine risk management priorities by comparing the level of risk against predetermined standards, target risk levels or other criteria. Risk Identification The process of determining what can happen, why and how. Risk Management The culture, processes and structures that are directed towards the effective management of potential opportunities and adverse effects. Risk Management process The systematic application of management policies, procedures and practices to the tasks of establishing the context, identifying, analysing, evaluating, treating, monitoring and communicating risk. Risk Minimisation A selective application of appropriate control measures, techniques and management principles to reduce either likelihood of an occurrence or its consequences, or both. Risk Rating The level of severity applied to a risk based upon its impact to the organisation. Refer Attachment 5. Risk Tolerance The level of risk that Council is prepared to accept, before action is deemed necessary to reduce it and represents a balance between the potential benefits of calculated risk and the threats that it inevitably brings. Risk to Public Those risks that are created by the activities, actions or inactions of Council in the delivery of services or works in the public space that may result in bodily harm or damage to property. Strategic Risk Risk which will effect or hamper across the organisation its ability to operate or deliver its policy, strategy or services. Technical Risk Risk such as failed equipment and managing assets. Adopted by Council on 18 March 2013 6|Page RISK MANAGEMENT POLICY 2013 6.0 APPLICATION This Policy applies equally to all employees and contractors. Employees and contractors all have joint responsibility for ensuring risk management is a key part of their approach to the delivery of the Council’s functions, operations and services. 6.1 Council will provide: Guidance and governance to support significant and/or high profile elements of the risk management spectrum; and The support and basis upon which the Risk Management framework can be established and developed including listing Risk Management as an element of the Council Plan. 6.2 The Audit Committee will provide: Guidance and quality advice on existing Council processes and alternatives to managing risks; and Advice and guidance on effective industry standards for managing risks associated with Council business. 6.3 Chief Executive Officer is responsible for: Providing direction and advice on the management of risks within Council and ensuring that appropriate treatment measures are in place to mitigate Council’s exposure; Promoting a culture of risk management and ensuring that a strategic, comprehensive and systematic risk management program operates throughout Council; Ensuring that the Council’s organisational vision and values (relative to risk) are aligned and synchronised with its strategic direction and culture; Making the case to the elected Council for budgetary consideration of additional risk initiatives; Ensuring that the risk management program is intrinsic to everything Council undertakes and is incorporated in the messages given to the organisation; Ensuring that Council’s commitments support the risk management program; Discussing and supporting the risk management program with Councillors; and Considering the information and implications contained in the regular report provided to the Executive on matters of risk that have been either reported to Council or are considered to be strategic risks for Council including insurance claim management. Adopted by Council on 18 March 2013 7|Page RISK MANAGEMENT POLICY 2013 6.4 The Executive Management Team (EMT) will provide: Comment and feedback regarding the elements of risk as they apply to their specific areas of responsibility; Provide quality advice to the CEO on the elements of risk they may consider to be an exposure to Council business. 6.5 General Managers are responsible within their Divisions for: Management of strategic risks that are directly related to their Division; Maintaining the overall responsibility for the effective management of all types of risks related to this Policy within their Division; Ensuring that Council’s assets and operations, together with liability risks and hazards, are adequately protected through appropriate risk budgeting, internal audit processes, loss control programs and the development and application of complementary practices and procedures; Developing and fostering working relationships with other agencies with whom Council has a shared risk; Ensuring that assistance is provided to support the provision of requested information in relation to an insurance claim or a risk management issue, in a timely manner; Advising of any risk management matter that should be referred for consideration for incorporation into forthcoming budgets; Ensuring that employees within their Division are adequately trained in the identification, assessment and procedures available for the minimisation of risk; Ensuring that performance measures are determined, to track progress in implementing risk treatment plans; and Acknowledging that the management of risk is an integral part of service delivery. 6.6 Managers are responsible within their Departments for: Management of risks that are directly related to their Department; Ensuring that Council’s assets and operations, together with liability risks and hazards within their areas of responsibility, are adequately protected through appropriate risk budgeting, loss control programs and measures, and adherence to Council’s various complementary practices and procedures; Managing relationships with other agencies on shared risk issues; Arranging for advice and assistance to be provided including the provision of requested information, in relation to an insurance claim or a risk management issue, in a timely manner; Ensuring that Council responds immediately to the investigation of any report of a hazard or incident received from a resident, employee, contractor or visitor; Adopted by Council on 18 March 2013 8|Page RISK MANAGEMENT POLICY 2013 Implementing risk control measures to mitigate exposure; Advising their Divisional Manager of any risk management matter that should be considered for incorporation into forthcoming budgets. Ensuring that their employees and contractors within their Department are trained, updated and undertake their duties in accordance with Council’s risk management and other related policies and procedures; Ensuring Council’s Risk Management Unit is advised immediately of any potential insurance claims and ensure appropriate incident investigation has taken place; Reporting to their Divisional Manager on a regular basis on risk management issues including budget, programs, measures and incidents; and Acknowledging that the management of risk is an integral part of service delivery. 6.7 Coordinators are responsible within their Service Unit or area of responsibility for: Management of risks that are directly related to their Unit; Ensuring that Council’s assets and operations, together with liability risks and hazards, are adequately protected through appropriate risk budgeting, loss control programs and measures, and adherence to Council’s various complementary policies and procedures; Ensuring that their employees and contractors within their Unit are trained, updated and undertake their duties in accordance with Council’s risk management and other related policies and procedures; Providing and arranging assistance and requested information in relation to an insurance claim or a risk management issue, in a timely manner; Ensuring that Council responds immediately to the investigation of any report of a hazard or incident received from a resident, employee, contractor or visitor; Implementing risk control measures to mitigate exposure; Advising their Departmental Manager of any risk management matter that should be considered for incorporation into forthcoming budgets; Ensuring Council’s Risk Management Unit is advised immediately of any potential insurance claims; and Acknowledge that the management of risk is an integral part of service delivery. 6.8 Risk Management Unit is responsible for supporting all Council Business Units in properly managing risk within their units, and monitoring compliance with the risk management policy and processes. The Risk Management Unit shall support the corporate risk initiatives by: Ensure that Council’s assets and operations, together with liability risks and hazards to the public, are adequately protected through appropriate risk budgeting, loss control programs and measures, and adherence to Council’s various complementary policies and procedures; Reporting on high and extreme risks with existing control measures and recommendations for further mitigation; Adopted by Council on 18 March 2013 9|Page RISK MANAGEMENT POLICY 2013 Documenting the Council risk management program through the compilation and regular update of the Council risk management strategy; Providing a platform to host Council’s Operational Risk Register which provides for the recording and management of these risks by Divisions, Department and Service Units; Providing a platform to host and record Council’s Strategic Risks; Ensuring that risk management platforms are functional and provide advice and guidance to users; Assisting in the planning, monitoring, and review of risk assessments for Council assets and activities; Ensuring that complementary policies and practices are implemented, periodically reviewed and where required, updated; Providing regular reporting through the Manager Risk Management and Contracts Compliance to the Executive, the Audit Committee, and Council on risk management issues, statistics and strategies including insurance claim management; Providing advice and educational material on industry trends and legal developments; and Placing and managing of Council’s insurance portfolio, ensuring that adequate insurance coverage exists for all classes of insurable risk. The Risk Management Unit provides guidance and advice on risk exposure issues as required by all Council Divisions and service areas. The risk owners (General Managers, Managers and Coordinators) are responsible for managing the risks of their areas and should seek assistance from the Risk Management Unit as soon as an exposure or an emerging risk becomes known or suspected. 6.9 Employees and Temporary Staff are responsible for: Reporting any risk, potential risk or incident immediately it is brought to their attention, to their Team Leader/Coordinator; Ensuring that they conduct their daily duties in a manner that does not expose Council to loss or risk, and that these duties are conducted in accordance with the relevant policies, procedures and legislative requirements; Assisting in the investigation of any incident that may have occurred and for which they were involved or have knowledge of, as a result of a risk or hazard; Acting in a pro-active manner to control and prevent risk, injury or harm to the Council or any person; Reporting either through a corporate recording system or to their Supervisor, any notification of a hazard or incident received from a resident, employee or visitor, in order to allow Council to respond immediately; Managing risk (including OHS risk) and, participate in risk management and OHS processes by encouraging all individuals to take responsibility for managing risks associated with their official duties. This is to be achieved through the observance of Council Policy, following lawful direction of their Supervisors and ensuring they Adopted by Council on 18 March 2013 10 | P a g e RISK MANAGEMENT POLICY 2013 carry out their tasks properly and safely, utilising the correct equipment for the task; and Acknowledging that they all have a part to play in managing risk. 6.10 Contractors are responsible for: Ensuring that Council’s assets and operations, together with liability risks and hazards to the public, are adequately protected through appropriate loss control programs and measures, and adherence to Council’s various complementary policies and procedures; Responding immediately to the investigation of any report of a hazard or incident received from an employee, resident or visitor; Maintaining appropriate and adequate insurances as required under their contract; and Ensuring that they conduct their daily duties in a manner that does not expose Council to loss or risk and that these duties are performed in accordance with the relevant policies, procedures and legislative requirements. 7.0 REFERENCES and SOURCE The references and sources for the content of this Policy have been derived from the following documents; 1. International Standard – ISO AS/NZS 31000 – 2009 Risk Management 2. Council’s Occupational Health & Safety Policy and Manual 3. Occupational Health and Safety Act (Vic) 2004 4. Managing Risk Cross the Public Sector 2004 5. Implementation of Government Risk Control Framework 2013; 6. Delivering Assurance on Risk Management ISO 31000 - 2009 (HB158/2010) 7. Risk Assessment Techniques (HB89/2012) 8. Fraud Prevention Strategies in Local Government 2012 Adopted by Council on 18 March 2013 11 | P a g e RISK MANAGEMENT POLICY 2013 8.0 THE RISK MANAGEMENT PROCESS 8.1 The Continuum of Assessment and Review For the Risk be: Management process to be successful and effective within Council, it must an integral part of management; embedded in the culture and practices; and tailored to the processes of the organisation. The process comprises a number of logical and distinct steps which are necessary to not only establish the specifics of the risk but to also engage it into the continuum of control and review. The steps are detailed in the flow chart below. ANALYSE RISKS EVALUATE RISKS COMMUNICATE AND CONSULT IDENTIFY RISKS RISK ASSESSMENT MONITOR AND REVIEW ESTABLISH THE CONTEXT TREAT RISKS * Source ISO AS/NZS 31000 - 2009 Risk Management - Principles and Guidelines Adopted by Council on 18 March 2013 12 | P a g e RISK MANAGEMENT POLICY 2013 To apply the assessment and review continuum into a City of Stonnington context, the following flowchart details the process. KEY Cycle Commences Identifying Risk Analysis & Treatment Monitor & Review Regular Departmental Managers/ Coordinators meetings to discuss operational risks Regular Divisional Managers/ Departmental Managers meet to discuss operational risks Divisions advise Risk Management of exposure. RM analyse, evaluate, provide treatment advice and record in Risk Register. All risks are monitored, reviewed and reassessed as required (special focus on High and Extreme risks) Risk Management Unit operates ongoing training and awareness workshops. Monthly Risk Management reports to the Executive regarding High and Extreme Risks. Adopted by Council on 18 March 2013 Training & Awareness Reporting Quarterly the Risk Management Coordinator revises the Risk Management Strategy, Action Plan and Strategic Audit Plan. Quarterly the Audit Committee reviews the Risk Management issues presented in the Risk Management report. Half yearly, Council review Risk Management issues presented in a Risk Management Report. Annually, the Risk Management Policy is reviewed and updated. Cycle Recommences 13 | P a g e RISK MANAGEMENT POLICY 2013 8.2 Communication and Consultation Communication and consultation with internal and external stakeholders should take place during all stages of the risk management process. Risk ownership is integral to its successful management and therefore, all risk creations and reviews are to involve the areas or key individuals who will effectively manage and control the risk exposure to Council throughout its life cycle. Relevant people will be involved in the consultation process and contribution into the various aspects of the process will be encouraged and acknowledged. 8.3 Establishing the Context The establishment of the context (or parameter of reference) is an integral element within the process of risk management as it establishes and defines the various environments in which risk is to be considered, assessed and managed. The level of contextual relevance should be considered on; External context – the external environment in which the organisation seeks to achieve its objectives; Internal context – the internal environment in which the organisation seeks to achieve its objectives; Context of the risk management process – the objectives, strategies, scope and parameters of the organisation should be established; and Defining the risk criteria – the organisation should define criteria to be used to evaluate the significance of risk. 8.4 Identification of Risks The effective identification of risk exposures to which Council may be subjected, is a foundation element of establishing the basis of effective mitigation, control and review. As various levels of assumptions are made during this process, it is essential to remain grounded in establishing the likelihood, consequence and realism of such a risk occurring. Unrealistically assessed events, impacts or consequences undermine the validly and credibility of the risk management process and its relevance to the organisation’s business rapidly becomes irrelevant as people disengage from the process. The primary questions must be based on; The current environment in which the activity is undertaken (political, financial etc); The past history or experience of the organisation; Any known or suspected threats; Recent experience of other like industries; or Other relevant knowledge, local or otherwise, to risk exposures that may also impact on Council. Adopted by Council on 18 March 2013 14 | P a g e RISK MANAGEMENT POLICY 2013 The key elements of Council’s risk identification processes are: The cyclical ‘whole-of-organisation’ risk assessments undertaken by Council’s internal auditors; Risk assessments undertaken within individual Divisions, Departments and Units by key personnel on a regular basis that are both supported by the Risk Management Unit and form part of Council’s Risk Registers (Strategic and Operational); The annual liability risk assessment undertaken by Council’s Public Liability insurer; and Key industry information derived from various sources. In managing organisational risk, Council will focus on the following major areas of risk exposure: Human Resources; Occupational Health & Safety; Legislative Compliance; Internal Controls; Contract Management; Insurance Liability; Corporate Governance; Information Technology; Asset Management; Security; Professional Advice; Records Management; Systems – Efficiency and Effectiveness; Financial Management; Reputational exposure; and Management Reporting. This list is not exhaustive and will be complemented through the normal risk review processes undertaken by General Managers and Managers as part of Council’s annual budget development, as well as the service reviews undertaken as part of Council’s Best Value program. Identified risks will be recorded on the Strategic and Operational Risk Registers, managed by the Risk Management and OHS Units. Employees and members of the public are also to be encouraged to report potential risk exposures. 8.5 Assessment A full, accurate and objective assessment of any identified risk must be undertaken to: Evaluate existing controls; Determine the likelihood of an incident; Determine the consequences of the risk; Establish the risk rating; Adopted by Council on 18 March 2013 15 | P a g e RISK MANAGEMENT POLICY 2013 Identify any physical hazards; and Develop remedial actions. These assessments may be undertaken by Council’s Risk Management Unit, Council’s Internal Auditors, Council Managers and Coordinators, Designated Workgroups or by external consultants. Risk assessments will be undertaken by using the assessment criteria and matrix shown in Attachment 1. An assessment of risks should be carried out three times during the life of the risk: Stage 1 - Inherent risk (Absolute) – the risk exposure prior to management controls being put in place; Stage 2 - Managed risk – the risk exposure with the current level of management controls; and Stage 3 - Residual risk – when no further controls are required and the level of residual risk is tolerable. 8.6 Risk Appetite The City of Stonnington determines its risk appetite across four distinct areas of its operations and performance namely Cultural, Outcome, Expectation and Liability. 8.6.1 Cultural Our cultural risk appetite defines our behaviour and the principles to be applied across Council but is not necessarily measurable or actionable. The Cultural Risk Appetite is: a) Council has a very low tolerance for reputational risk exposure that negatively impacts on its standing or image. Steps to minimize the likelihood of adverse reputational impact should always be taken; b) Council will promptly take action to address ratepayer/customer complaints and regulatory concerns; c) Council will not engage in any activity that will put its long-term values or reputation at risk. The Council will meet the ratepayers’/customers’ expectations of providing efficient, considerate and cost-effective services; and d) Council is an equal opportunity employer that employs skilled and experienced employees in positions with clearly defined roles and responsibilities. 8.6.2 Outcome Our outcome risk appetite specifies the limits or maximum impact/outcome within Council which is considered to be reasonable and acceptable where such risk is measurable. The Outcome Risk Appetite is defined by compliance to: a) Council’s Business and Strategic Plan; b) Council’s annual budget; and c) defined Divisional, Departmental and Unit Business Plans. Adopted by Council on 18 March 2013 16 | P a g e RISK MANAGEMENT POLICY 2013 8.6.3 Expectation Council’s expectation risk appetite defines its tolerance for strategic and operational actions. These risks, specific to activities or known risks, are measurable and supported by mitigation controls and actions. The Expectation Risk Appetite is: a) Council has a low tolerance for Strategic Risks. These risks are to be mitigated and controlled as far as practicable down to a low or medium risk rating. b) Council has zero tolerance for harm or injury to its employees or visitors and these harms will be mitigated and controlled down to a low risk; c) Council has zero tolerance for internal/external fraud or deception activities; d) Council has a low tolerance for operational risk. These risks will be mitigated and controlled to where the cost of control is equal to the marginal cost of the risk; e) Council has a low tolerance for information technology outages. There is no tolerance for outages that exceed one week. 8.6.4 Liability Council’s liability risk appetite defines the level of liability for which it is prepared to accept using internal mitigations or management processes before it seeks external support or remedies to resolve matters. Such risks are measurable and reportable. The Liability Risk Appetite is restricted to the deductible excess as stated on each of the insurance policies as issued by each insurer and may be adjusted as required from time to time against Council’s tolerance for risk exposure. 8.7 Treatment To control a risk, there is a need for it to be correctly and realistically evaluated to determine the best option for risk removal or minimisation, with plans prepared and implemented to rectify or mitigate any problem areas. Risk control options (which are not necessarily mutually exclusive or appropriate in all circumstances) include the following: Risk Avoidance – avoid the identified risk by deciding not to proceed with the activity likely to generate risk (where this is practicable); Risk Transfer – reducing exposure by transferring the risk to another party e.g. contracting to a business that has the requisite qualifications and skills; Reduce the likelihood of occurrence through measures such as audit compliance programs, contract conditions, preventative maintenance, engineering controls, inspections, process policies and procedures; and Reduce the consequences through measures such as contingency planning, disaster recovery plans, contractual arrangements, financial management controls and risk exposure minimisation plans. Adopted by Council on 18 March 2013 17 | P a g e RISK MANAGEMENT POLICY 2013 8.8 Implementation Risk Management across the Council will be implemented and managed through effective governance controls including: Monitoring of adherence to internal controls; Conducting risk assessments of Council assets and activities; Applying a corporate risk management strategy; Promoting adherence to this Policy and related Policies by all employees and contractors; Providing employee training opportunities on relevant risk issues; Providing induction training and ongoing workshop sessions; Instructional information available to employees upon request; Providing adequate funding for risk reduction initiatives in Council’s budget; and Undertaking an annual review of identified risks. The Risk Management Unit is part of the Risk Management and Contract Compliance Department and is available for advice and guidance on risk and insurance matters. 8.9 Performance Measuring Performance measures to track progress in implementing risk treatment plans within Divisions, Departments and Business Units should be established and reviewed by the relevant area Managers and reported to the Risk Management Unit annually. The tracking process should include; The inherent risks; The existing control measures; Actions to be undertaken; Due date of the actions; Outcomes to be achieved; Responsible officer; and Acceptance of the residual risk. A risk profile for each Department will be established and implemented as a live working document that will provide a clear snapshot of the actual risk position and of the possible or likely future risks. The progress of implementing the treatment plans will form part of the reporting structure of the Risk Management Unit on an exception basis via the process listed in 8.10 of this Policy. Adopted by Council on 18 March 2013 18 | P a g e RISK MANAGEMENT POLICY 2013 8.10 Monitoring and Review Monitoring of risk is the responsibility of the respective General Manager, Manager and Coordinator, as an element of their overall responsibilities. Monitoring of risk, with the support of the Risk Management Unit, will include, but not be limited to: the analysis of insurance claims; on-going risk assessment and risk minimisation as part of standard management practice; advice and input into contract specifications and documentation; advice and input into risk assessments of new Council programs; on-going review of existing Council programs and facilities, as required; reviewing documentation of inventories, hall or facility hire agreements, Committees of Management Deeds of Delegation; compliance with all complementary Council Policies and Procedures; and periodic review of Council’s complementary Policies and Procedures. The Risk Management Unit via the Risk Management & Contracts Compliance Department will report as follows: Reporting To Items of Report Frequency Executive Statistics regarding incidents, activities, training and Monthly insurance claims and advice and analysis of risk trends. Executive Report on High and Extreme risks with existing Quarterly control measures and recommendations for further mitigation. Audit Committee Statistics regarding incidents, activities, training, Quarterly insurance claims, analysis of risks trends. Report on High and Extreme risks with existing control measures and recommendations for further mitigation. Status Report of internal audit recommendations. Council Statement of position regarding the Council’s Risk Bi Annual Management program and management of High and Extreme Risks. Significant risk issues will be brought to the attention of the Chief Executive Officer and the relevant General Manager and, where required, Council. Risk reviews formally undertaken by Council’s internal auditors, will be reported to Council’s Audit Committee as part of its charter. Adopted by Council on 18 March 2013 19 | P a g e RISK MANAGEMENT POLICY 2013 8.11 Records Reference to the records relating to the management of Risks will be maintained in; the Division, Department or Unit where the risk resides; Council’s Records Management System; Council’s relevant Risk Register; and Council’s insurance portfolio where relevant. 9.0 REVIEW This document is to be reviewed by the Risk Management Coordinator every year from date of adoption by Council, with each review to be approved via the CEO Notice Paper. 10.0 ATTACHMENTS This Policy is supported by detailed attachments that further define graphically the methods and process of risk management. The attachments are; Attachment 1. Attachment 2. Attachment 3. Attachment 4. Attachment 5. Attachment 6. Risk Consequence Criteria Risk Controls Criteria Risk Likelihood Criteria Risk Matrix Risk Ratings Definitions Definition of Risk Status Adopted by Council on 18 March 2013 20 | P a g e RISK MANAGEMENT POLICY 2013 Attachment 1 – Risk Consequence Criteria City of Stonnington - RISK CONSEQUENCE CRITERIA CONSEQUENCE CONSEQUENCE RATING Description Safety Financial Environmental Outrage & Media Regulatory Business Continuity INSIGNIFICANT • Effect is minimal No Treatment Applied • Up to $10k financial loss (.007% of Budget) • No detrimental environmental effect • Issue raised by residents and/or local press • Activity does not follow established industry standards • Business disruption, but no loss of service delivery MINOR • Event requiring moderate levels of resources and input • First-Aid Treatment Only • >$10 k - $50k financial loss (.037% of Budget) • Environmental discharge controlled, and of a minor nature • Resident and/or media concern/local media coverage • Activity does not follow "Best Practice" • Brief service loss • Significant event with long reaching effect Medical treatment, Ambulance, or admission to hospital of less than 2 days • >$50 k - $500k financial loss (.37% of Budget) • Localised environmental impact, causing community annoyance, and requiring remedial action • Embarrassment for Council, including adverse media coverage • Activity does not meet all of the requirements of the relevant Australian Standards • Productivity loss for up to 5 days • >$500 k - $5 m financial loss (3.75% of Budget) • Long-term detrimental environmental or social impact • Reputation of Council severely affected in the long-term. • Activity does not meet all of the requirements of relevant legislation • Critical service loss for up to 1 month • >$5 m financial loss (>3.75% of Budget) • Long-term environmental or social impact on community • Government intervention required • Activity does not meet any of the requirements of relevant legislation and Regulations • Loss of service for a critical period of time MODERATE MAJOR • Critical event Hospitalisation of more than 2 days, or long term injury or disability CATASTROPHIC • Disaster with potential to lead to collapse or to have a profound effect • Single or multiple fatalities 1. Consider the consequence for each category i.e.; Safety, Financial, Environmental, outrage and Media, Regulatory and Business Continuity. 2. Determine the CONSEQUENCE RATING based on overriding definition i.e.; “worst” (or highest) category. Adopted by Council on 18 March 2013 21 | P a g e RISK MANAGEMENT POLICY 2013 Attachment 2 – Risk Controls Criteria City of Stonnington - RISK CRITERIA Measuring Risk: CONTROLS CONTROL RATING DESCRIPTION SYSTEM CONTROL/DESIGN CONTINGENCY PLAN INFORMATION SYSTEM Effectiveness of existing control measures Affects frequency of occurrence Reduces severity of consequence of an event Supports the action and capability for monitoring Significant control over the risk. Total confidence. Excellent system with total implementation. No variance in control quality. Total confidence in an effective plan. Fully tested and documented. Well proven data base, robust system, very user friendly. VERY EFFECTIVE Substantial reduction in risk. Improvements are possible. Very confident. Full system with effective implementation. Little or no variance in control quality. Very confident. Fully tested and documented. Mainly as above but improvements are possible. EFFECTIVE Satisfactory risk reduction. Improvements are possible. Quite confident. Satisfactorily implemented. Some variance in control quality. Just effective - open to some weaknesses. Not fully tested, quite good documentation. Mostly good but not yet robust. Some flaws in supporting effective risk action. Marginal risk reduction. Improvements should be considered. Moderately confident. Fair implementation only. Quite a degree of variance in performance. Not really effective plan. Not tested – open to substantial problems. Fair to poor database / performance in risk reduction. Not very user friendly. Minimal risk reduction, if any. Improvements required. Not confident. Only partly introduced or no attempt. Substantial variance. No plan at all or very inadequate preparation. Very poor / inadequate / nonexistent. TOTALLY EFFECTIVE PARTIALLY EFFECTIVE INEFFECTIVE Process Consider the effectiveness of current controls when determining the three levels of risk. The rating given should be based on the lowest of control ratings applied. Adopted by Council on 18 March 2013 22 | P a g e RISK MANAGEMENT POLICY 2013 Attachment 3 – Risk Likelihood Criteria Measuring Risk : LIKELIHOOD LIKELIHOOD RATING CRITERIA RARE Event MAY occur only in EXCEPTIONAL circumstances. There is LITTLE opportunity for the event to recur. Chance of risk occurring is 0-10% UNLIKELY Event COULD occur at SOME time. There is a REASONABLE opportunity for the event to recur. POSSIBLE Event SHOULD occur at SOME time. There is SOME opportunity for the event to recur. Chance of risk occurring is 11-40% Chance of risk occurring is 41-60% LIKELY Event will PROBABLY occur in MOST circumstances. There is CONSIDERABLE opportunity for the event to recur. Chance of risk occurring is 61-90% ALMOST CERTAIN Event is EXPECTED to occur in MOST circumstances. There is a STRONG likelihood of the event recurring. Chance of risk occurring is 91-100% Process 1. Determine the LIKELIHOOD RATING based on the overriding criteria definition Adopted by Council on 18 March 2013 23 | P a g e RISK MANAGEMENT POLICY 2013 Attachment 4 – Risk Matrix Consequence for Organisation Likelihood Insignificant Minor Moderate Major Catastrophic Almost Certain Moderate 11.00 High 16.00 High 20.00 Extreme 23.00 Extreme 25.00 Likely Moderate 7.00 Moderate 13.00 High 17.00 High 22.00 Extreme 24.00 Possible Low 4.00 Moderate 8.00 Moderate 15.00 High 19.00 High 21.00 Unlikely Low 2.00 Low 5.00 Moderate 9.00 Moderate 14.00 High 18.00 Rare Low 1.00 Low 3.00 Low 6.00 Moderate 10.00 Moderate 12.00 Process: Plot the rating box for each of Absolute, Managed and Residual risk. Adopted by Council on 18 March 2013 24 | P a g e RISK MANAGEMENT POLICY 2013 Attachment 5 – Risk Rating Definitions RISK CATEGORY LOW Descriptor Manage by routine procedures and be mindful of changes to nature of risks. implementation of any cost effective internal controls. Consider the MODERATE Management to ensure that the control environment, consequence and likelihood do not substantially change. Consider the implementation of any additional cost effective controls. HIGH Executive attention required to assess the acceptability of remaining net risk or required/planned mitigation measures. Management to ensure that necessary mitigation actions are carried out and the risk does not increase by actively monitoring any changes to the control environment, consequence and likelihood. EXTREME Extreme risk is generally unacceptable. Comprehensive consideration by the Executive is required to ensure that the net risk remaining is consistent with Council’s objectives and acceptance of risk. If not, detailed research and planning is required to mitigate risk. Process 1. Choose appropriate CONSEQUENCE RATING 2. Determine appropriate CONTROL RATING 3. Choose appropriate LIKELIHOOD RATING Ascertain risk category Adopted by Council on 18 March 2013 25 | P a g e RISK MANAGEMENT POLICY 2013 Attachment 6 – Definition of Risk Status Definition of Risk Status Operational Strategic Commercial Technical Risk which occurs in, hampers, or impacts upon an individual Division, Department, Service Unit or area of an organisation. Risk which will impact upon or hamper across the organisation its ability to operate or deliver its policy, strategy or services. Risk such as a failed contract or business relationship. Risk such as failed equipment and managing assets. Financial & Systems Risk posed to Council’s financial systems and controls such as fraud. Compliance Risks to meeting regulatory obligations. Source: Managing Risk Across the Public Sector - Good Practice Guide – Auditor General Vic 2004 Adopted by Council on 18 March 2013 26 | P a g e RISK MANAGEMENT POLICY 2013 Document Control Version: 3.0 Date: 17 November 2015 Author: Manager, Risk Management & Contracts Compliance Risk, Coordinator Risk Management and Contracts Compliance Department QA: Business Support Officer Review Period: Annual Owner: Revision Details Date Update Details 18 March 2013 Adoption of Policy 23 September 2014 Annual administrative review of document and insertion of Internal Audit recommendations regarding Risk Tolerance and the roles of the Audit Committee and EMT. Annual administrative review. 17 November 2015 Adopted by Council on 18 March 2013 Reviewed QA Approved Risk Manager, Coordinator Risk Management & Contracts Compliance Risk Manager, Coordinator Risk Management & Contracts Compliance Council Risk Manager, Coordinator Risk Management & Contracts Compliance Chief Executive Officer Chief Executive Officer 27 | P a g e
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