Enhancing conduct risks and controls
We identified and assessed conduct risks and controls for an insurance business to enable consistent delivery of fair outcomes to customers
We enhanced the process and control environment whilst co-ordinating a number of process and control centred programmes with common dependencies
The challenge
Our client, a leading UK building society, identified opportunities to enhance it’s Enterprise Risk Management Framework including enhancing its control environment and better co-ordinating a number of process and control centred programmes with common dependencies.
Specifically our client wanted to design and implement Control Declarations, a framework to support Accountable Executives in fulfilling their responsibilities under the Senior Managers Regime by confirming the effectiveness of their controls. Previous attempts had failed to get the concept off the ground, an audit committee update was imminent and other programmes were also dependent upon it’s implementation.
Our approach
The starting point for us was to mobilise a programme team, initially to validate the declaration methodology and build consensus for it’s roll out amongst a wide range of stakeholders. This involved securing Executive engagement and sponsorship as well as working with representatives in every function of the business to identify Accountable Executives and assess their controls.
At the same time we established a new governance body – the Process & Controls SteerCo (PACS) to co-ordinate dependencies with other programmes.
A robust plan was developed to implement the framework that would meet the commitments made to both internal and external stakeholders.
The outcome
The Control Declarations Programme successfully delivered a first round of process and control declarations for c.70 Accountable Executives on plan.
The approach taken for control declarations is a significant start to a multi-phase, ongoing approach to maturing their risk and control environment and resulted in a number of deliverables which strengthen the control environment (e.g. single taxonomy for controls, upskilling of staff and clarity of process ownership) as well as enabling the identification of further opportunities to enhance the society’s control environment. As part of the programme closure the framework was embedded into BAU ownership and delivery.
