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Turnbull: Meeting the guidance
Risk Management (UK)
Executive Summary
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Effective business risk management is fundamental to delivering
the modernising government agenda. This is a bold statement and
in this paper we explain the benefits to the public sector of improved
business risk management and argue that it can be applied effectively
to a much wider range of public sector activity.
HM Treasury has asked Principal Finance Officers to comment on
their proposal to implement the Turnbull Working Party's guidance
on Internal Control in central government departments. Their desire
is to secure real benefit through implementing effective risk management
in departments rather than simply playing lip service to the guidance.
A draft implementation timetable is due to be issued soon.
Work done in some departments has brought about significant improvements
in performance by taking control of risk. We describe a more dynamic
view of risk than that normally applied, set out the key principles
that should underpin its management in the public sector and describe
how risk management can be implemented effectively to improve delivery
of the modernising government agenda as well as provide better corporate
governance.
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This paper answers the following questions:
So what is risk management? It is a combination of avoiding hazards,
dealing effectively with uncertainty and knowing when to take the
right risk.
Where can risk management make a difference in the public sector?
Quite apart from meeting the Turnbull guidance on Internal Control,
it can help identify the main departmental risks, their relative
priority, the tolerance to each risk and the responsibilities for
managing them. Unnecessary duplication of efforts or assignment
of resources can then be identified. What follows is better capital
efficiency because the information identified can help inform adjustments
in expenditures from a risk-based perspective.
Is risk a dilemma for the Civil Service? Some in Whitehall are
encouraging more risk taking, yet at lower levels 'fear of failure'
makes many Civil Servants risk averse. What principles underpin
effective public sector risk management? Quite simply, a system
that allows effective visibility at the appropriate levels, with
appropriate control measures and a suitable mechanism to sanction
and monitor investment.
The steps to implementing effective business risk management. Effective
risk management needs to be tied into the business at every level
through a framework of risk management strategies, informed by an
overall policy and managed with an effective process. For this to
succeed in the public sector a culture shift will be required.
Effective business risk management is fundamental to delivering
the modernising government agenda. This is a bold statement and
in this paper we explain the benefits to the public sector of improved
business risk management and argue that it can be applied effectively
to a much wider range of public sector activity.
HM Treasury, following the established principle that the government
will follow private sector best practice in respect of accounting,
reporting and audit (unless there is good reason for not doing so),
asked Principal Finance Officers to comment on their proposal to
implement the Turnbull Working Party's guidance on Internal Control1.
Their desire is to secure real benefit through implementing more
effective risk management in departments rather than simply playing
lip service to the guidance. A draft implementation timetable is
due to be issued soon.
Work done by PA Consulting Group illustrates how some Government
Departments have brought about significant improvements in performance
by taking control of risk. We describe a more dynamic view of risk
than that normally applied, set out the key principles that should
underpin its management in the public sector and describe how risk
management can be implemented effectively to improve delivery of
the modernising government agenda and provide better corporate governance.
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So what is risk?
Traditionally, risk management has been regarded by civil servants
as hazard avoidance, for example avoiding anything that may reflect
poorly on the decision-maker and, ultimately, upwards to ministerial
level. However, potential hazards are many and efforts to chart
a course around each can simply result in a loss of momentum.
We have come across examples where a policy initiative has been
worked up with great thoroughness and wide consultation. The final
blue print is impressive but has been achieved at a cost as the
time for implementation is severely truncated by the additional
planning time. The net effect is that the total risk of implementation
failure – e.g. that results fail to materialise inside the
required time horizon – has been increased.
We believe ‘risk’ is more dynamic than mere hazard
avoidance and should be viewed as a combination of:
- Hazards or threats (what happens if things go wrong). This
is the traditional view of risk.
- Uncertainty resulting from the effects of changes in key
variables (e.g. delivery time or cost fluctuation), affecting
an operation or project and relates to the variance between
anticipated and actual outcomes.
- And the potential Benefits of taking calculated risks or
seizing opportunities, sometimes referred to as the balance
of risk and reward. This concept may appear alien, but is common
in the private sector where profit is, in part, the reward for
successful risk taking in business. It is focused on investment
and action to achieve positive gain, where a decision to take
a risk would be driven by a desire for the investment to achieve
better value for money. At a corporate level, taking this type
of risk is implicit in many departments’ ongoing modernisation
programmes, especially where initiatives are developed internally
rather being imposed by ministers.
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Where can risk management make a difference in the
public sector?
Risk management is not new; any department with formal project
management processes or one that uses methodologies like PRINCE
will be well aware of risk analysis as they will be if, as one hopes
they should, use the Treasury Green Book in their investment appraisals.
However we question whether sufficient real value is derived from
this at present. Risk management has yet to become the fundamental
part of corporate governance that it has in the private sector,
where pressure on the bottom line and the requirements of stock
markets have encouraged companies to develop comprehensive risk
management procedures:
"…recognising that business decisions
require the incurrence of risk, [companies must] achieve a proper
balance between the risks incurred and the potential returns…"
(Toronto Stock Exchange Company Manual)
The Turnbull Working Party’s recent report on Internal Control
will place visibility of corporate risks firmly on the Board's agenda.
In the public sector, the treasury is likely to expect departments
to comply with Turnbull-style conditions too, so placing business
risk management responsibility firmly with the Accounting Officer².
But can the evolving principles of business risk management be
applied to help achieve better value (in terms of outputs and outcomes)
for public money whilst achieving the demands of effective internal
control? The answer is ‘yes’ – we believe that
these two requirements are completely interrelated.
Effective business risk management can bring significant benefits.
It can help identify the main Departmental risks, their relative
priority, the tolerance to each risk and the responsibilities for
managing them. Unnecessary duplication of efforts or assignment
of resources can then be identified. The next step is better capital
efficiency because the information identified can help inform adjustments
in expenditures from a risk-based perspective.
We acknowledge that all departments are striving for incremental
increases in the efficiency of their routine operations and the
application of a formal risk management structure would not always
be appropriate. Yet where the public sector seeks to increase value
from investment in a venture such as:
- major projects (a new system, a new delivery method or the
establishment of a new organisation, etc)
- mergers of previously separate divisions or agencies
- corporate transformation initiatives
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Risk management can play a crucial role in ensuring successful
delivery and is vital in helping the Permanent Secretary, as Accounting
Officer, to understand the risks to which the department's investment
is exposed.
For example, there are a series of initiatives underway aimed at
transforming the delivery of a very high profile public service
through new systems, processes and organisation structures. The
failure of these will have potentially serious operational, financial
and political implications. Yet we have found numerous examples
where the approach to identifying and managing risks has been rudimentary
and where a more structured approach could help.
We would go further and argue that risk management could help departments
to manage the broader combination of programmes and initiatives
which are intended to deliver their Public Service Agreements. Turnbull
implies a portfolio approach where a risk management framework might
be used to inform the level of resources that are invested in specific
initiatives. This may not be appropriate in the public sector, as
an aggregated risk threshold is hard to quantify. However the approach
can be applied to identifying when continued investments in specific
projects should be capped or withdrawn; something which is still
rare in both the public and private sectors.
Risk management is not a panacea, but it can make an important
contribution to enabling a department or agency to deliver its broader
objectives.
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Is risk a dilemma for the Civil Service?
Some senior figures in Downing Street and Whitehall
have argued strongly that civil servants should be encouraged to
take more risks – recognising that without doing so the transformation
in management techniques needed to modernise Government is unlikely
to be secured.
The Chairman of the Public Accounts Committee (PAC) has been quoted
as saying that he would like to see departments demonstrate that,
following careful analysis, they had actually taken risks in order
to secure benefit, even if they didn’t necessarily achieve
them. However, a realist might suggest that this argument would
not be credible if presented to the PAC in mitigation of poor performance.
On the other hand, high profile implementation problems periodically
remind ministers that failure also has political as well as practical
consequences. Combined with the need to satisfy the National Audit
Office, this leads some to argue that many civil servants should
be encouraged to take less risk and not more – and that the
public sector should concentrate on grinding out incremental improvements.
We recognise that because of the nature of the public sector, rapid
change is not always possible, or desirable, but these apparently
conflicting pressures appear a recipe for management schizophrenia.
However, that these points of view are often regarded as conflicting,
reflects a widespread misunderstanding of the nature of risk. Both
perspectives can be reconciled by the sensible application of risk
management techniques.
The key principle underlying effective risk control is accountability.
It is now widely accepted that risk management should be undertaken
at all levels; business units/projects are responsible for risk
management and managers should be responsible for implementing policies
for control and risk in their area. Further they should create a
risk aware culture, where employees have the collective knowledge,
skills, information and authority to establish and maintain the
system of control and understand their responsibility for managing
risk. This will be difficult in the blame culture that exists in
parts of the civil service.
We have seen this work very effectively in a number of departments,
especially those that have a reasonable Project Culture, where the
execution of projects has helped develop an acceptance that things
do go wrong. An effective approach, building on this acceptance,
might include specific risk management obligations and performance
measures to focus line management and functional specialists on
the risk management strategy and objectives.
Internal audit also has an important role to play in 'new style'
public risk management. However, business risk management is not
simply a job for internal audit, it is a management issue. That
said, the traditional role of internal audit is shifting from control
to risk based auditing and some government departments are already
adopting an approach that involves internal audit in business unit
and project decision making to help the business avoid hazards and
manage uncertainty more effectively.
The theory's great, how do you implement it?
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Conclusion
The need for effective business risk management in the public sector
is becoming ever more important. We pointed out how at the same
time civil servants were being accused of taking too few risks and
too many. In fact both points of view are valid but can be addressed
through a systematic and comprehensive approach to risk management.
This will include a strategy that makes risks visible and grades
them in terms of seriousness – a requirement of Turnbull.
The cost of risk should be factored into new and continuing expenditure
decisions. There should also be clear criteria for escalating issues
upward within the Department if specific trigger points are reached.
The overall strategy needs to include plans to mitigate risks or
deal with them should they arise.
Whilst such an approach will impose a greater degree of rigour
in the management of risks to the business, it must also make clear
the freedom of managers and the scope to which limited failure is
permitted. Only by appraising and monitoring risks in a controlled
way will public sector managers have the confidence to take them
and their superiors the confidence to permit them to do so.
Effective business risk management in the public sector will allow
government departments to ensure better value for money from their
ventures and improved service levels through the effective control
of risk. We are aware that some public sector managers will question
the value of risk management. However, whilst it is by no means
a universal panacea, it has an important role to play in delivering
significant transformation of public service delivery and providing
better internal controls.
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