DEVONPORT HIGH SCHOOL FOR BOYS ACADEMY TRUST FINANCIAL PROCEDURES MANUAL and RISK REGISTER May 2014 To be reviewed triennially or before if required Next scheduled review date May 2017 Page No Financial Conduct, Roles and Responsibilities 3 School Governance – Guiding Principles 4-5 Financial Conduct – Proper and regular use of public funds 6-8 Financial organisation and overview of roles and responsibilities 9 -10 Financial Planning, The Development Plan, The Annual Budget and Financial reporting 11 Financial controls – principles 11 - 15 Financial Delegation and authorities and Expenditure Procedures 14 - 15 Payroll 16 – 18 Business Continuity including Inventory, Asset Register, Finance Staffing, Insurance 19 Non Public Funds 20 Appd. 1 Duties of cheque signatories 21 Appd. 2 Bank Accounts for Public and Non Public Funds 22 Appd. 3 Financial Procedures and Responsibilities for Budget holders 23 Appd. 4 Accounting System description 24 Appd. 5 Credit / Debit / Purchase / Store Cards 25 Appd. 6 Role of responsible officer 26 -27 Appd. 7 Financial Risks 28 - 31 Appd. 8 Strategic and reputational risks 32 - 35 Appd. 9 Operational Risks 36 - 38 Appd. 10 Compliance Risks 2 School Governance The Governing Body (under delegated authority from the Trustees) is collectively responsible for the overall direction of the school and its strategic management and has a responsibility, not only to be effective, but seen to be effective. Therefore, the School will manage and administer its affairs in accordance with the seven principles of public life which are as follows: Openness – an approach to all interested parties in the disclosure of information, that lends itself to necessary scrutiny. Integrity – this is best described as both straightforward dealing and completeness. Accountability – the process whereby individuals are responsible for their actions and decisions. Selflessness – Governors should act solely in the public interest and not in a way that is likely to confer financial benefits, preferential treatment or other advantage, on others. Objectivity– In carrying out public business, including making public appointments, awarding contracts, or recommending individuals for rewards or benefits, decisions will be made on merit. Honesty – Governing Bodies have a duty to uphold the law, and to act on all occasions in accordance with the trust placed in them. Leadership – those in leadership should promote and support the above principles by leadership and example, always acting in such a way to preserve public confidence in the Governing Body. The Governing Body is responsible for ensuring that high standards of corporate governance are maintained and exercises a strategic role in addressing such matters as : policy development and strategic planning geared towards continuous school improvement ensuring sound management and administration and ensuring managers are equipped with relevant skills and guidance ensuring compliance with legal requirements establishing and maintaining a transparent system of prudent and effective internal controls. management of financial, human and other resources. monitoring performance and the achievement of objectives ensuring accountability through consultation and reporting and responding to the needs of parents and the community. setting standards of conduct and values assessing and managing risk. The Governing Body’s responsibilities include: Ultimate responsibility for the proper stewardship of funds, ensuring value for money and compliance with the Funding Agency, the Articles of Association and the Academies Financial Handbook. Approval of the Annual Budget Approval of the annual report and accounts The Governors and School Management will comply with or have regard to: Standards of financial management and propriety recommended or prescribed in the Academies Financial Handbook Advice and guidance relating to the financial performance of schools arising from the work of the EFA, OFSTED, Audit and any other relevant third party. 3 Financial Conduct – Proper and regular use of public funds The Academies Financial Handbook sets out the requirements of the school to put in place procedures to ensure regularity and propriety in the use of public funds. To comply the school must: Establish controls to ensure that spending has been for the purpose intended (Section3). Maintain a register of trustees’ business interests – see below. Establish controls to ensure no payments are made to Governors or other related parties unless permitted. Ensure payments made to senior employees comply with the DFE’s directions re avoidance of tax. Ensure a competitive tendering policy is in place and applied. Assets are not disposed of without appropriate consent. Register of Business Interests The Governing Body and school staff have a responsibility to avoid any conflict between their business and personal interests and affairs and interests of the school. A register of business interest will be maintained for both Governors and staff with an influence over spending decisions, and be freely available for inspection by governors, staff and parents. The register will include all business interests such as directorships, share holdings and other appointments of influence within a business or other organisation, which may have dealings with the school. The disclosures should also include business interests of relatives and other individuals who may exert influence. The school will ensure that the register is up to date and complete, includes all governors and relevant staff and in this regard is signed and dated. Financial Malpractice including the reporting of suspected theft and fraud This school believes that staff should be able to properly raise concerns, in confidence and without prejudice to their personal position. Where appropriate this will include an opportunity to raise concerns outside the line management structure, and an indication of the proper way in which concerns may be raised outside the organisation if necessary. The following person has been nominated as a contact point for queries of a confidential nature arising from the financial work of the school. Designated person: Chair of Governors In the event that the concerns are such that it would be inappropriate to raise concerns either with the Headteacher or Chair of Governors, the member of staff must contact the Education Funding Agency. Goods and Services for Private Use including the receipts of gifts and hospitality The school will avoid practices such as obtaining goods and services that may include an element of private use for governors or staff. Governors and staff will also avoid accepting excessive hospitality, entertainment, or other services from existing or prospective suppliers. A register should be maintained to record hospitality and gifts received to include the donor, the date and the approximate value. The Prevention of Corruption Act places the burden of proof on the recipient of favours. Payments to Governors, employees or other related parties Unless an individual has provided clear evidence of self employed status all payments to individuals will be processed only through the payroll system. Payment for employment will not be made to staff or visiting lecturers etc. through any other mechanism. It is illegal for Governors to receive any remuneration for 4 their work as trustees other than payment of reasonable out of pocket travel, accommodation or other expenses incurred in connection with their attendance at meetings acting in the capacity of governor of the academy. Abnormal transactions and delegated authorities The Academies Financial Handbook identifies the following non routine transactions and provides guidance in sections 2.4 and 2.6 which must be followed: Overpayments Unrecoverable debts Guarantees, letters of comfort and indemnities Losses of stock and other assets. Gifts or hospitality received or given Gifts of surplus assets Staff severance payments and compensation Asset sales, leases and tenancy agreements For all of the transactions above and any other transaction which falls outside the usual planned range of activities, the school will obtain relevant professional advice where appropriate; ensure decisions reflect value for money; agree internal delegation levels; and disclose the aggregate of such transactions in the annual accounts, detailing each transaction greater than £5,000. All abnormal transactions will be reported to the Governing Body, regardless of the internal approved delegated authorities. Other Matters Fees and charges Fees for chargeable services should normally be set at full cost, but a higher amount may be used when in a commercial environment. Borrowing EFA approval is rquired for borrowing and certain other similar liabilites (leases, tenancies, indemnities). In the event that the school considers entering into any such transaction, full Governing Body approval is required. Credit Cards Where a credit card is used, credit card limits will be set at appropriate levels and any balance will be repaid monthly in full, to avoid any borrowing risk. Further information is given in Appendix 6. 5 Financial Organisation and overview of roles and responsibilities The academy has defined the responsibilities of each person involved in the administration of academy finances to avoid the duplication or omission of functions and to provide a framework of accountability for governors and staff. The financial structure is illustrated below: The Governing Body The Governing Body (under delegated authority from the Trustees) has overall responsibility for the administration of the academy’s finances. The main responsibilities of the governing body are prescribed in the Funding Agreement between the academy and the DFE and in the academy’s scheme of government. The main responsibilities include: • ensuring that grant from the DFE is used only for the purposes intended; • ensuring that funds from sponsors are received according to the academy’s Funding Agreement, and are used only for the purposes intended; • approval of the annual budget; • appointment of the Headteacher and • appointment of the Business Manager / Finance Director, in conjunction with the Headteacher. authority to approve expenditure at any level with due regard to the available funds The Enterprise Committee The Enterprise Committee is a committee of the governing body and meets at least once a term but more frequent meetings can be arranged if necessary. The main responsibilities are detailed in written terms of reference which have been authorised by the governing body and include: • the initial review and authorisation of the annual budget; • the regular monitoring of actual expenditure and income against budget; • ensuring the annual accounts are produced in accordance with the requirements of the Companies Act and the DFE guidance issued to academies; • authorising the award of contracts over £7,500 • authorising changes to the academy personnel establishment and • reviewing the reports of the Responsible Officer on the effectiveness of the financial procedures and controls. These reports must also be reported to the full governing body. authority to approve disposal of assets between the values of £1,001 and £6,000 at any one time authority to approve capital expenditure provided it can be contained within the annual capital budget or approved capital programme The Headteacher (Accounting Officer) Within the framework of the academy development plan as approved by the governing body the Headteacher has overall executive responsibility for the academy’s activities including financial activities. Much of the financial responsibility has been delegated to the Business Manager but the Headteacher still retains responsibility for: • approving new staff appointments within the authorised establishment, except for any senior staff posts which the governing body have agreed should be approved by them; • authorising contracts between £1,000 and £7,500 in conjunction with the Business Manager authority to approve disposal of assets with a residual value up to £1,000 at any one time, within an annual amount of £10,000 • signing cheques in conjunction with the Business Manager or other authorised signatory. 6 The Business Manager (Principal Finance Officer) The Business Manager works in close collaboration with the Headteacher through whom he or she is responsible to the governors. The Business Manager also has direct access to the governors via the Finance Committee. The main responsibilities of the Business Manager are: • the day to day management of financial issues including the establishment and operation of a suitable accounting system; • the management of the academy financial position at a strategic and operational level within the framework for financial control determined by the governing body; • the maintenance of effective systems of internal control; • ensuring that the annual accounts are properly presented and adequately supported by the underlying books and records of the academy; • the preparation of monthly management accounts; • authorising orders below £1,000 in conjunction with budget holders • signing cheques in conjunction with the Headteacher or other authorised signatory and • ensuring forms and returns are sent to the DFE in line with the timetable in the DFE guidance. The Responsible Officer (see also Appendix 6) The Responsible Officer (RO) is appointed by the governing body and provides governors with an independent oversight of the academy’s financial affairs. The main duties of the RO are to provide the governing body with independent assurance that: • the financial responsibilities of the governing body are being properly discharged; • resources are being managed in an efficient, economical and effective manner; • sound systems of internal financial control are being maintained and • financial considerations are fully taken into account in reaching decisions. The Responsible Officer will undertake a quarterly programme of reviews to ensure that financial transactions have been properly processed and that controls are operating as laid down by the governing body. A report of the findings from each visit will be presented to the Finance Committee. Other Staff Other members of staff, primarily the Bursary Staff and budget holders will have financial responsibilities and these are detailed below. All staff are responsible for the security of academy property, for avoiding loss or damage, for ensuring economy and efficiency in the use of resources and for conformity with the requirements of the academy’s financial procedures. Bursary Staff Have delegated authority and responsibilities from the Governing Body: keep the Petty Cash account and money, advise budget holders on sources of supply, in order to obtain value for money authorised to receive cash and issue school receipts and keep cash in school up to insured cash limits Raise Orders in PSF in accordance with DHSB Order Forms signed by Authorised Cost Centre Managers. Maintain custody of all paper work associated with the public accounts. To be kept for six years. Resources Cashier Has delegated authority and responsibilities from the Governing Body: authorised to receipt monies paid in for public and private funds and to hold up to £500 cash overnight in the Resources safe Departmental budget holders Have delegated authority and responsibilities from the Finance Committee: 7 to spend their allocations wisely and by obtaining value for money in accord with the School Development Plan and the needs of the agreed curriculum. Heads of Department/Faculty may vire funds between their cost centres except those funds allocated for Curriculum Development which can only be vired with the Headteacher's agreement. to confirm goods received and that the invoice may be paid. to keep a running account of their cost centre balances, so that expenditure is planned and allocations not exceeded. The Estate Manager Has delegated authority and responsibilities from the Governing Body: to keep the Asset Register and initiate the annual muster of Departmental Inventories each June. to review the Insurance cover, propose any necessary changes to the Headteacher and co-ordinate any insurance claims 8 Financial Planning, The Development Plan, The Annual Budget and Financial reporting 1. The School Development Plan for educational objectives is drafted by the LG after consideration of Departmental Plans and is approved by the Governing Body. 2. The Annual Budget is drafted by the Headteacher and Business Manager, agreed by the Finance Committee and approved by the Governing Body. The Budget Holder is the Headteacher. The Budget Manager is the Business Manager. A final budget must be submitted to the EFE by 31 July for the forthcoming academic year. The budgeting process will include Forecasts of likely pupil numbers and the latest estimate of GAG receivable Latest estimates of other EFA / LA funding based on expected levels Estimates for other income, based on prior years and known variations Use of accumulated surpluses (GAG and unrestricted funds) Review of past expenditure performance against budgets, identification of efficiency savings and cnsideration of known changes (pay increases, inflation) The pay budget to be supported by a list of known and planned staff, fully costed A statement of principal assumptions, highlighting areas of vulnerability and outlining possible remedial actions should a shortfall arise if the assumptions do not hold. Setting the Budget - outline Autumn Term - The LG will discuss outline priorities for budget allocations, which relate to the School Development Plan. The Headteacher will seek endorsement of an outline plan by the Governing Body. Spring Term - If not already accepted by the Governing Body, the outline budget will be agreed. Summer Term - The Business Manager agrees the full draft budget with the Headteacher. This is to include the outline plan agreed by the Governing Body and projections based on historical spending and forecast capitation. This budget will be presented to the Governing Body for agreement and forwarded to the EFA. Internal Financial Monitoring Monthly reports will be prepared by the PFO, detailing actual expenditure and income against budget for review by the Headteacher and the Enterprise Committee External Financial Reporting Reports to the EFA are initiated by the Business Manager and submitted for signature by the Headteacher (Accounting Officer). At the time of writing the requirement for external reporting is as follows:By 31st July– Agreed Budget for forthcoming academic year reported to EFA using EFA budget forecast spreadsheet By 31st December (4 months after the end of the accounting year) full audited statutory accounts lodged with the EFA and with the Companies Registrar by 30 June of the following year (10 months after the end of the accounting year) 9 By 31st January – Accounts return consolidation exercise using EFA spreadsheet template and signed off by external auditor. Reports to the Governing Body, via the Enterprise Committee are to be initiated by the Business Manager, discussed with the Headteacher and presented to the Governing Body by the chairman of the Enterprise Committee. The cycle of meetings allows at least termly reports. Cash Management The PFO must prepare periodic cash flow forecasts to help ensure that the bank account is not overdrawn and the school abides by its contractual obligations to pay on time. Any such forecast produced should reflect: Known opening balances Known receipts from the EFA, LA and other grants Estimates of pay costsincluding NIC and pension contributions Estimates of routine non pay expenditure Known / expected non routine expenditure Receipts and payments re Capital schemes VAT Forecast closing balances for the following 12 month ends In the event that these forecastsidentify any potential cash shortfalls, the PFO must notify the Principal and report to the Enterprise Committee. Capital Schemes Capital schemes expose rhe school to substantial risks. Where the expertise required to oversee such schemes is not be available from within the school the Enterprise Committee must decide whether to engage external specialists to manage the prioject on behalf of the school. If external mangers are not appointed, the PFO, in consultation with the Head and Estates Manager must establishproject management procedures, in writing, for approval by the Enterprise Committee. Any such procedures should include the following: Plans and planning consents VAT recovery Contractor selection and contract structure Project timetable with milestones Monitoring construction progress / quality assessment Payment profile and cash flow management (inc. VAT) Final sign 10 Financial Controls The following control principles will be encouraged and observed to ensure that transactions are properly processed and errors detected promptly. Segregation of Duties The checking of one person's work by another provides a good safeguard against error or manipulation. Effective separation of those duties which would, if combined, enable one individual to record and process a complete transaction. In particular there is a need to separate the key functions of authorisation, execution, custody, recording and the development and operation of systems. Effective segregation reduces the risk of error or intentional manipulation. Documentation of Systems All operating procedures should be documented. Documentation helps to ensure a degree of formality, consistency and structure, which is essential in financial management procedures. It can aid considerably with continuity in the absence of key staff or during changes of staff. It will also reduce the chance of error, assist in proper and timely accounting and reporting and ensure transactions are accounted for correctly. • job descriptions, setting out clearly the key responsibilities of the job; • desk instructions, giving step by step instructions on the execution of individual tasks and • system procedures, giving step by step instructions on the operation of complete systems. Authorisation and Supervision Authorisation controls to certify that a transaction or event is acceptable for further processing. All systems of control should include supervision by responsible officials of the day to day processing of transactions. Supervisory controls should also include regular review of bank reconciliations and income and expenditure trends against budget and previous periods. Physical Security All data, records and assets should be kept in a physically secure environment. This should cover safe keeping of finance records such as official order forms and cheque books and bank details. In addition, any petty cash should be kept securely. Financial data and other records should also be protected in the form of back up procedures. All work should be regularly backed up and copy records stored securely off site. Risk Management The Governing Body must agree the main financial risks that the school faces and assess the likelihood of occurrence and materiality of each risk. The risk register at Appendix 8 outines many of the financial risks associated with delegated budgetary control and the school’s response to those risks. Financial Authorities and Expenditure Procedures Authorisation limits for financial transactions: Purchases over £1,000. Budget holder’s authority; prices are to be obtained from three suppliers and evidence attached to the order for the Bursary. Purchases over £7,500. Budget holders are to obtain three written quotations which are to be attached to the Order. The Enterprise Committee should minute approval of tender selection. The reason for not tendering a purchase in excess of £10,000 must be minuted by the Enterprise Committee. The use of divisible contracts is expressly prohibited. This instruction includes both Capital and Revenue Expenditure. Capital items are defined at paragraph 6 of this Annex. For each academic year the school will have an agreed Capital Budget and agreed Revenue Budget. 11 1. Authority to approve Revenue Expenditure (Goods and Services but excluding the engagement and employment of teaching and support staff, staff training, travel and subsistence, which are dealt with in paragraphs 3, 4 and 5 below) a. The Governing Body According to the EFA b. The Chairman of the Enterprise Up to £10,000 provided it can be contained within overall Committee together with the Headteacher annual budget c. Headteacher Up to £7,500 provided it can be contained within the overall budget d. Business Manager Up to £5,000 provided it can be contained within the overall budget e. Authorised budget holders Up to £5,000 provided it can be contained within 80% of the cost centre revenue budget Notes 1. Only the authorised budget holders may authorise a DHSB order form. 2. Petty cash is a sub account of the school budget and may be used as authorised by the Bursar for minor purchases. 3. Items should only be ordered from approved suppliers, as advised by the bursary. The basis of approval should be value for money including reliability of supply and delivery. 4. Items should be ordered via a requisition and generally the only non order invoices received should be for utilities and other periodic billings on the cost centres managed by the Bursar and the Estates Manager. Non order invoices are to be certifed by the authorised cost centre manager before payment. 2. Authority to Vire - *the transfer of monies between previously agreed budget headings a. Headteacher and Governing Body Unlimited except for development budgets b. Enterprise Committee Up to £6,000 within the budget as set c. Authorised budget holders Unlimited between the budgets they manage, except for developmental budgets. 3. Authority for the Engagement and Payment of Staff (Teaching and Non Teaching) a. Governing Body Unlimited b. Headteacher together with the Chairms of Enterprise and Standards Committees Unlimited within the agreed annual payroll budget All changes to the salaries of the Headteacher and Deputy Headteachers must be authorised by the Chairman of the Governors. 4. Authority for Staff Training The Asssitant Headteacher Expenditure within the agreed staff development budget 5. Authority to certify Travelling and Subsistence claims Travelling expenses will be paid at the Inland Revenue approved rate of 40p per mile and approved and authorised as follows:Claimant Headteacher Authoriser Chair of Govs or Deputy Head or Business Manager 12 Deputy Heads All other staff Headteacher / Business Manager Deputy Heads and Business Manager 6. Authority to approve Capital Expenditure a. The Governing Body Unlimited b. The Enterprise Committee Unlimited provided it can be contained within the annual capital budget or approved capital programme Items within the annual capital budget or approved capital programme Individual items up to £500, provided the amount can be contained within the budget holder’s agreed capital programme c. The Headteacher d. Other budget holders Definition of Capital Expenditure: Expenditure on, or in connection with: a. The acquisition, reclamation, improvement or laying out of any land b. The acquisition, construction, enlargement, improvement, repair or demolition of any building, wall, fence or other structure, or any playground or other hard standing c. The laying out of playing fields and other facilities for social activities and physical recreation, or d. The provision of any furniture, plant, machinery, apparatus, vehicles and equipment, used or intended to be used for the purposes of the school. The authority for Capital Expenditure will be recorded by the Governing Body in the minutes of their meetings and by Cost Centre Managers on Order Forms. 7. Authority to Approve Disposal of Assets Asset Land Assets with residual value up to £6,000 Assets with a residual value in excess of £6,000 Authority Required All disposals of land will be made in accordance with the clauses 88 – 94 of the Funding agreement Enterprise Committee Governing Body Disposal authority is restricted to school assets. The authority of the Local Authority must be obtained to dispose of other assets vested in the school but subject to LA disposal authority by Acts of Parliament. Write-off of Losses: Including bad debts (any value) must be referred to the YPLA. Debtor Policy: A reminder is to be sent six weeks after the original invoice. A second reminder is to be sent after a further three weeks. Debtors outstanding over 10 weeks and £100 in value are to be reported to the Finance Committee. The school's solicitor will usually be consulted at this stage. 8. Authority to Certify Invoices for Payment Authorised budget holders Invoices related to orders and commitments previously certified by the budget holder. Cash Flow Policy: a. Payments to suppliers will be made to obtain any discounts offered and to derive full benefit from the supplier's credit period. b. Income due will be collected and banked as soon as possible. c. Goods will not be ordered earlier than they are needed. d. Cash kept in the safes or as Petty Cash should be minimal, so as not to lose interest. 9. Authority to Raise Cheques / BACS Payments a. The Business Manager 13 b. The Business Manager’s Assistant (in the absence of the Business Manager) Cheques are only to be raised against a certified invoice or Petty Cash requisition signed by an authorised budget holder or against a signed authority of the Headteacher. Custody: The Business Manager has custody of the cheque forms, which are to be kept in a secure storage. The Business Manager is to keep separately a record of the numerical sequence of the cheques supplied by the bank and the actual cancelled/spoilt cheques. The Business Manager is responsible for accounting and reconciliation of the bank accounts with the cash book (PSF). The Responsible Officer is to inspect and sign the bank reconciliation monthly or whenever practicable. The resulting documentation is to be filed. The order form to replenish cheques is to be kept by the Business Manager, who is to authorise re-ordering. 10. Authority to Sign Cheques Cheques / BACS payments are to be signed by two signatories, as follows Headteacher Deputy Headteacher Business Manager Kieran Earley David Adams Geoff Davis The Business Manager is authorised to make transfers of money between bank accounts approved by the Governing Body, to optimise cash flow. 11. Authority to Receive Cash a. The Bursary b. The Resources / Assessment Trips coordinator Co-ordinates the banking of all moneys received in the school. The school receipts are to be issued to all persons paying in any money, unless on a school trip form, class paying in form or completed bank credit form (from the Resources cashier) School receipts are to be issued for any money paid in for school trips, music tuition and from the teachers (against individual bills and class paying in lists) School Trips / Educational Visits: Should be run at cost price. The parents should be told if a significant profit results, so that refunds can be made. A record is to be kept by the organiser of amounts paid in and the date. A School Receipt should be obtained when money is handed over to one of the accounting staff detailed above. 12. Authority to Open and Vary the approved Bank Accounts The Governing Body. The bank accounts approved by the Governing Body for Public and Non Public funds are at Appendix 3. The Business Manager is to ensure that the bank accounts are not overdrawn. The appointment of auditors for all funds is to be approved by the Governing Body. The Non Public fund accounts are to be closed annually for audit to date 31 August. The reports are presented to the Finance Committee by the auditors during the Autumn Term. 13. Authority to Borrow Governors must seek DFE / EFA approval for both short term borrowing (including overdraft facilities) and medium/longer term loans from the private sector (including finance leases), where such borrowing is to be 14 paid from DFE / EFA grant or secured on assets funded from DFE grants. However DFE / EFA’s normal policy is that academies should not be granted permission for medium and long term borrowing. Specific DFE / EFA approval is required for: Any guarantees, indemnities and letters of comfort entered into Write off of debts or liabilities owed to the academy over a specified value as set out in the annual funding letter issued by the DFE Any ex-gratia payments Any freehold sales or purchases The grant or take up of any leasehold or tenancy agreement for more than 3 years. 14. Tendering – overview and limits The Governing Body will follow the detailed guidance within the Academies Financial Handbook as they relate to tendering and form of tender. All goods/services with a value over £10,000, or for a series of contracts which in total exceed £10,000 must be subject to formal tendering procedures, including, where appropriate, advertising in the Official Journal of the European Union for supplies that may fall under EU procurement rules. Payroll - overview 1. The payroll is prepared by the Cornwall County Council under contract renewable on an annual basis. The service includes advice on tax, National Insurance, superannuation and redundancy. The Business Manager manages the payroll and is authorised to make detailed payroll changes consequent to decisions by the relevant Committee and confirmed by the Headteacher in writing. All staff are to be paid through the payroll. There are to be no cash payments. Monthly payments are to be reconciled against personnel records by the Business Manager. The monthly payroll summary is to be signed by the Headteacher and the Business Manager. 2. Individual pay is decided by the relevant Committee. The Business Manager drafts the contracts. The Headteacher authorises all contract changes. The Governing Body is responsible for the appointment and remuneration of the Headteacher and Deputy Head teachers. 3. All staff will be paid on the 25th of the month or on the last working day before that date. Amendments to the Payroll have to be with the contractor 13 working days before pay day. Payments are made by BACS and all those paid receive a pay slip from the contractor detailing the composition of monthly pay, deductions and net pay. Payroll administration The academy payroll is administered on the Cornwall County Council. All staff are paid monthly and a master file is created for each employee which records: salary; bank account details; taxation status; personal details and any deductions or allowances payable. Data is exchanged via a monthly spreadsheet which records Temporary Input and any permanent changes to the payroll including new starters. The spreadsheet is prepared by the Bursary Team, reviewed by the Business Manager and signed off by the Headteacher. Each section head / line manager must complete a monthly staff return which provides details for all staff in the section of sickness and other absences during the month and any new appointments or terminations. The staff return must be authorised by the nominated budget holder. Authorised staff returns should be sent to the Bursary Staff who then file the documents for payroll processing. 15 Payments After the payroll has been processed but before payments are dispatched a print of salary payments by individual and showing the amount payable in total should be obtained from the system. The print must be reviewed and authorised together with authority to release payment by the Business Manager and the Headteacher. Bursary Staff should prepare a reconciliation between the current month’s and the previous month’s gross salary payments showing adjustments made for new appointments, resignations, pay increases etc. This reconciliation should be reviewed and signed by the Business Manager. The payroll system automatically calculates the deductions due from payroll to comply with current legislation. The major deductions are for tax, National Insurance contributions and pensions. The amounts payable are summarised on the gross to net pay print and cheques for these amounts should be prepared by the Bursary Staff and authorised for payment by the Business Manager and the Headteacher (or other authorised cheque signatory if one is unavailable) by the due date. The Business Manager should select one employee at random each month and check the calculation of gross to net pay to ensure that the payroll system is operating correctly. After the payroll has been processed the nominal ledger will be automatically updated. Postings will be made both to the payroll control account and to individual cost centres. The Business Manager should review the payroll control account each month to ensure the correct amount has been posted from the payroll system, individual cost centres have been correctly updated and to identify any amounts posted to the suspense account. On an annual basis the Business Manager must check for each member of staff that the gross pay per the payroll system agrees with the contract of employment held on the personnel file in the Headteacher’s office. Inventories The school’s inventory will: form an important part of the school's procedures for ensuring that staff take responsibility for the safe custody of assets. enable school management to undertake independent checks on the safe custody of assets, as a deterrent against theft or misuse. help the school to manage the effective utilisation of its assets and to plan for their replacement support insurance claims in the event of fire, theft or other losses. Discrepancies between the physical count and the amount recorded in the inventory will be investigated promptly and where significant, reported to the governing body The Estates Manager is to initiate an annual muster of recorded items with current worth of more than £100, by the holders, each June. Inventory custodians are responsible for updating their records to show new acquisitions and for having them marked with stencil/branding iron. Asset Register The register is to be kept by the Estate Manager. The purpose is to promote accountability of publicly funded assets. It is to include ground, buildings and other assets valued in excess of £1000. Information technology equipment, other equipment, furniture, library, text books and stationery stock are to be included, using block headings and average current value, to cope with replacement and short lived items. 16 When approving Orders, the Business Manager is to note acquisition of relevant items by departments. These are to be checked against the muster of inventories in June and brought forward to the Asset Register. Insurance The Governors have appointed Marsh as their insurance brokers. The Estate Manager is responsible for review of the cover and for initiating necessary changes to the Finance Committee and for the co-ordination of claims. Summary of insurance Cover Material Damage The Buildings and Contents are insured against All Risks of loss or damage, including Theft on the premises. This cover includes: All buildings of DHSB, including boundary walls and fences Contents of every description which belong to the school (included in Inventories) or for which individual members of staff have assumed responsibility during their duties in the school. Limit of £10,000 per article. There is a general excess of £500. Contents are covered away from the premises anywhere in the world. Sum insured £25,000 at any one time; limit of £1,500 for any one article. Note: Personal effects of staff and their property on the premises for tuition purposes are insured against All Risks up to £1,000 for any one item, with an excess of £30. Personal effects of visitors and pupils are not insured against Theft or All Risks. Loss of Money and Assault Loss of money belonging to the school or for which the school has accepted responsibility: Non negotiable instruments including crossed cheques, stamped National Insurance Cards, airline tickets, phone cards and unused credit on franking machines: £250,000 n Cash and negotiable instruments: In the course of transit or in a bank night safe On the premises during business hours (0800 - 2200) On the premises in MLS safe outside business hours (unspecified) In the Resources safe outside business hours In any other circumstance £1000 £1000 £1000 £500 £300 Annual Travel – arranged via Marsh Insurance Brokers Covers all school trips undertaken during the policy year. There is no restriction on activities undertaken within the UK, although certain activities are excluded eleswhere in the world. Skiing is included. Cover applies to all members of a party and staff accompanying them. There is an excess of £30. Medical and other expenses: Loss of baggage/personal effects Death/serious injury Permanent total disablement £2,000,000 £1,500 £5,000 £25,000 17 Staffing and training / development of the Finance Function The appointment of staff should be made with due regard to the qualifications and capabilities commensurate with their duties. Inevitably, the proper functioning of any system depends on the competence and integrity of those operating it. The qualifications, experience and personal qualities of those involved with financial arrangements are important features of a control system. Consequently, the governing body should establish procedures to ensure that: personnel are competent, suitably qualified and trained to perform at a level commensurate with their responsibilities. clear statements of criteria for personnel selection and formal job descriptions are maintained. the finance staffing levels are adequate. there are effective arrangements to deal with the absence of key financial personnel Training / development For those with financial responsibilities, the Governing Body should keep under review any training needs and opportunities. Training is available through a number of organisations both in relation to general financial principles and procedures and more specifically in relation to the accounting requirements of schools Cover Arrangements In the absence of a key member of staff arrangements will be made to ensure the effective operation of the finance function and to ensure that financial control is maintained. This will be achieved through a combination of: Work shadowing Documented financial procedures Specified cover responsibilities within job descriptions Computer Systems / Data Protection The Governors recognise the importance of protecting computerised financial management systems and the data held within them. The Headteacher will ensure that the school is registered with the ICO in accordance with the Data Protection Act and that effective backup procedures are in place and that all back-up disks or tapes are stored securely off-site or in a fire-proof location Access to school management computer systems will be limited to authorised staff. These staff will use passwords that should not be disclosed and should be changed regularly. Only authorised software will be used to prevent the import of computer viruses. Staff will only have access to those modules appropriate to their duties. Security of Stocks and Other Property Safes and similar storage facilities will be kept locked and keys removed to be held by the key holder who will be nominated by the Headteacher. Normally key holders will carry keys on their person and keys must not be left on the premises overnight except in another safe. A list of key holders will be maintained by the school and loss of any keys must be reported to the Headteacher. Retention of Records All paper work associated with the public accounts is to be retained for six years. 18 Non Public Restricted Funds Generally The Governing Body approve the operation of the Fund which will be administered in accordance with recommended guidelines under the auspices of the Academy Trust. The accounts are to be maintained within the constraints of the Fund’s objectives, which have been approved by the Governing Body. The Fund Auditors will be appointed annually by the Governing Body and it will be their responsibility to conduct the annual audit in accordance with the Fund Objectives. The timescale for the preparation and delivery of the audited report to the governing Body will be within six months of the Fund year end. Bank Accounts are to be maintained at HSBC, Plymouth Operational Policy Non Public funds will be administered in accordance with the following criteria: A minimum of two signatures is required on all fund cheques. A formalised monthly reconciliation statement to all the cleared bank balances is required with a copy presented for termly meeting of the Finance Committee. The Headteacher should sign the statement as correct. All income to be properly receipted. Expenditure must be supported by proper invoices and/or vouchers, which must be retained for a period of not less than 6 years. Wages, honoraria, loans or ex-gratia payments will not be made from Unofficial Funds Purpose of School Fund The School Fund will be used to administer income and expenditure in the following areas: i) Educational Visits/Visitors ii) Residential Experiences iii) Fund-raising iv) Charity donations and collections v) Educational equipment vi) Donations to the School vii) Professional Fees (Membership, school registrations) viii) Trading Account: Photographs, Sweatshirts etc. ix) Hospitality and gratuities 19 Appendix 1 Duties of Cheque Signatories 1. Each cheque should be accompanied by either: a. The DHSB Order or Cheque Requisition Form certified by the budget holder and the Business Manager or, b. The original invoice, certified correct for payment by the budget holder. 2. The signatories are to verify that: a. The cheque is supported by the certified documents b. The payee is the same as the invoice name (except for factoring accounts) . c. The amount agrees with the net total of the vouchers d. The cheque is correctly dated e. The payment is a correct charge to Public or Non Public funds, as appropriate f. Documents should be initialled by the first signatory to certify verification 3. The cheques are to be returned to the Bursary, who will note the paid invoices with the cheque number and date of payment. Cheques are then despatched and the documentation filed: Invoices in alphabetical order and cheque counterfoils in numerical order. 20 Appendix 2 Bank & Credit Card Accounts authorised at DHSB Custodian (Cheque Book) Authorised Bank Accounts Signatories Academy Current Account Business Manager (Bursary Staff) HSBC 40-23-64 90012475 Any two of: KJE, DA, GD Academy Donor Account Business Manager (Bursary Staff) HSBC 40-23-64 70009962 Any two of: KJE, DA, GD Academy Money Market Business Manager HSBC 40-02-90 00613282 N/A Ex DHSB Trust Business Manager (Bursary Staff) HSBC 40-36-22 32166070 Any two of: KJE, DA, GD Commercial Card Business Manager (Bursary Staff) HSBC 4864831147342575 KJE 21 Appendix 3 Financial Authority and Responsibilities for Budget holders Responsibilities 1. Authorised budget holders have delegated authority, from the Governing Body, to spend and monitor their budgets. They are responsible for authorising their Orders and certifying subsequent invoices. The Business Manager oversees the day to day budget processes, cheque payments against certified invoices and Petty Cash reimbursements. The Bursary maintains a list of recommended suppliers to obtain value for money. The Business Manager is responsible to the Headteacher for drafting the annual budget and subsequent monitoring and reporting of significant deviations from the plan. Also for the reports that are made to the to the YPLA, and general responsibility for audit and adherence to the framework set out in the school's financial procedures, to prevent fraud. Money collected from pupils 2. Large amounts of money are collected when preparing for school visits and collecting in school subs. Records should be kept on the appropriate forms, especially when payments are fragmented. Money must be kept securely and is the responsibility of the individual member of staff until a school receipt has been obtained from the Resources Cashier or the Bursary. Money should generally be paid in daily so that it can be kept in a safe. If cash or cheques are needed against Cost Centres or School Trip funds, a Petty Cash form should be completed. The Resources Cashier will run a School Trips Costing Sheet in conjunction with a member of staff organising any trip involving the collection of money from pupils. Orders 3. The Governing Body has issued instructions about incurring expenditure, which are to be observed by budget holders. They expect suppliers' prices to be compared. Prices are to be obtained from three suppliers for Orders over £1,000. The Governors wish to consider all proposals to spend in excess of £7,500, supported by three written quotes and to minute approval of purchases/contracts before expenditure is made. All Orders for goods or services should be made on a DHSB Order form. Orders must be signed by the Budget holder. The Bursary will generally print and despatch orders by the end of each week. Cheques are similarly printed in one run. It is therefore necessary to plan ahead and give Orders and Petty Cash requests to the Bursary by Tuesday. Orders are not to be made informally by telephone, fax, e-mail or letter. If it is urgent, an order form must be completed as soon as possible. Goods and Invoices should always be addressed to the school, for the attention of a Cost Centre, not to an individual. Delivery notes should be checked and signed "Correct". All paper work concerning Orders should be passed to the Bursary. Invoices 5. If the correct ordering procedure has been followed, these will be received by the Bursary. The budget holder will be asked to certify on the original or a photocopy of the invoice, that the goods or services have been received and that the charge is correct. Budget Monitoring 6. Budget holders will be told of budget allocations, additional allocations and carry forwards. They should keep a record of these and deduct the cost of Orders as they are made. Periodic print outs of cost centre transactions will be provided on request in addition to online access via the web portal to “live” budget reports. 22 Appendix 4 Accounting System Description 1. The accounting system, PSF, has been purchased to support the move to Academy Status and is hosted at school on a dedicated server which is backed up on a daily basis. 2. It is a full double entry book keeping system with a powerful reporting function tailored to the needs of the Academy. Access rights restrict who is able to work on the budget and accounts. When the budget has been agreed by the Governing Body, the Business Manager allocates it to the major cost centres, including Headteacher's capitation. 3. Some 80% of the budget is spent on pay. After the Governors agree salary scales, these are entered in the Personnel module, this process being necessary to form the pay budget and make the pay commitment in PSF. Cornwall Payroll Services are our payroll contractor and make BACS payments on our behalf. 4. Departmental budget holders spend the remainder of the budget and the business manager monitors the budget from month to month and makes reports to the Headteacher and the Governors. 5. When Orders are placed, invoices approved for payment and cheques printed, the transactions are reflected in all parts of the accounts: Cash Book, school budget, the cost centre budget and audit trail. 6. Periodic returns are made to the EFA. These are specially generated reports and based on cost code income and expenditure. 23 Appendix 5 Credit / Debit / Purchase Cards The following arrangements will apply in respect of the use of the school’s credit card. 1. The Governing Body will approve any application for a corporate credit card including who should use the card. 2. Credit cards should only be used by designated staff and must be kept securely in the safe at all times, and must be signed out if taken off site. 3. Credit cards must not be used for personal use or for withdrawing cash without the express approval the Headteacher or his nominated representative. 4. Statements must be received at the School and, to ensure effective separation of duties will be checked and reconciled by a member of staff other than the staff member issued with the card. Statements will be checked promptly to check if there are any signs of irregular activity. 5. Working securely on line – the following guidance should be observed Anti-virus - It is very important to keep your anti-virus product up to date with the latest signature files (this usually happens automatically in the background with most commercial antivirus products) and operating system updates from Microsoft. This reduces the likelihood of malicious code or key-logging software running on your PC without your knowledge, transmitting your details to fraudsters across the internet. Personal Firewall - Never go online without ensuring you have your personal firewall enabled. This personal firewall adds a layer of protection to the PC by stopping unknown connections to the PC. Passwords - Don't ever select the remember my password option when registering online as your passwords are then stored on the PC, often in plain text, and are the first thing that a fraudster will target. Spam - Never shop from sites that you arrive at from clicking links in unsolicited marketing emails (spam). Know your vendor - The golden rule of commerce is still the same as it ever was - if the offer looks too good to be true, it probably is! . 24 Appendix 6 Responsible Officer The governing body will need to consider how it monitors and checks the operation of the financial management arrangements that have been established and are operated by officers of the academy. To assist in this they should appoint a person who will have specific responsibility for overseeing the financial arrangements on their behalf. The RO post is intended to provide an independent oversight of the academy’s financial affairs. The main duties of the RO are to provide the governing body with on-going independent assurance that: the financial responsibilities of the governing body are being properly discharged; resources are being managed in an efficient, economical and effective manner; sound systems of internal financial control are being maintained; and financial considerations are fully taken into account in reaching decisions. The programme of checks to be performed should be agreed with the Governing Body or Enterprise Committee (as appropriate). After each checking session the RO should provide the governing body or the Finance Committee with a written report. The RO should not be a member of the Finance Committee, as he or she may find it necessary to criticise the workings of that Committee. Instead, the RO should report to the Finance Committee in an advisory capacity. The RO should be a governor (but not the chairman), or an appropriately qualified and experienced individual not on the academy staff, with the necessary financial interest and skills to be able to perform the role competently. A recognised professional qualification is not necessary. However, the person selected must be able to show that the responsibilities being undertaken are fully understood and the importance of the role is fully recognised. The RO should have sufficient understanding to recognise any irregularities which may arise and sufficient authority to ensure they are addressed. The governing body should consider carefully who would make the most appropriate RO and if they are unable to appoint an RO who complies with the above guidelines they should discuss the appointment with the Department. Alternatively, the governing body can engage a firm of auditors to aid the RO in this function. The RO function could be carried out by an individual or body associated with a governor – for example a business governor may arrange for his/her company’s internal auditors to carry out the reviews and provide him/her (on behalf of the governors) with reports. The RO will need to be sufficiently familiar with the finances of the academy to be able to provide the governing body, and hence indirectly the DFE, with the required assurance. The RO is not expected to do any detailed accountancy work, but will be required to check some transactions to ensure that the correct procedures have been followed and the general areas for review should cover the following: • Review that bank reconciliations have been carried out each month, including a review of validity of reconciling items; • Review of the monthly payroll to ensure that any changes have been appropriately authorised; • Check of a sample of orders to delivery notes and invoices to ensure that the documentation is complete and has been appropriately checked and authorised; • Check of a sample of payments back to invoices, orders and delivery notes to confirm they are bona fide purchases; • Review of a sample of expense claims to ensure there is appropriate documentation to support the claim and that the claim is appropriately authorised; • Review the returns to the DFE to ensure the information supplied is consistent with the underlying accounting records and internal management reports; • Carry out spot checks of petty cash balances and supporting vouchers and • Review all major contracts and ensure formal tendering procedures exist and are being adhered to. 25 Devonport High School for Boys – Financial Risk Register Risk No 1. Financial Risk Likelihood Significance H/M/L H/M/L L H 4. Overspend budget, caused by weak expenditure management Overspend budget, caused by poor budgeting Received less income than budgeted, caused by poor budgeting Overspend on capital schemes 5. Short term cash shortages L H 6. Long term cash shortages – insufficient reserves L H 7. Improper or irregular use of funds L H 2. 3. L H L H H H Appendix 7 Key controls Assessment of control quality / Action needed Annual budget / Regular financial reporting / Strong strategic plan of action Strong Project management plans prepared by experienced local company – good monitoring by EM School currently enjoys a strong surplus position and cash flow has not been an issue in recent times. Good level of reserves maintained based on strategic plan and known factors including diminishing Minimum Funding Guarantee Strong Scheme of delegation in place Strong Strong Internal controls subject to regular scrutiny by RO Expenditure authorisation process clear 8. Errors in accounts caused by inadequately skilled or experienced finance staff L L 9. Loss caused by lack of security over assets including cash M H AO / PFO familiar with AFH Good experienced Team in the Bursary – strong culture of accountability PFO reports to FC on annual inventory check 26 Strong Moderate Risk No 10. Financial Risk Fraudulent payments to suppliers 11. Fraudulent payments to staff 12. Insufficient insurance cover Likelihood Significance Key controls H/M/L H/M/L L H Annual review of effectiveness of internal controls Expenditure authorisation procedures Systems under constant review by RO and PFO L H Robust procedures for monthly payroll sign off Personnel establishment under regular review L H Annual review of insurance arrangements by EM 27 Assessment of control quality / Action needed Strong Strong Strong Strategic and reputational risks Risk Ref No 1 2 Sub Risk Description Failure of the school to recruit sufficient learners to make it viable Failure to ensure that the objectives of the school are met 3 Failure to monitor and react accordingly to the requirement of our stakeholders 4 Failure to monitor and react accordingly to the risks associated with competitor establishments Risk Consequences • Significant financial risk; • Risk that the confidence of beneficiaries is diminished; • Risk that the confidence of stakeholders is diminished • Risk that the school fails to operate within the strategic objectives agreed by the Governing Body • Risk that the school's strategic objectives become out of date or no longer appropriate; • Risk that the school receives an unfavourble OFSTED report; • Risk that the objectives of the school are seen as controversial • Risk that stakeholders & beneficiaries do not consider the school service to be valuable and of high quality • Risk that competitors make a more attrative offer to beneficiaries; • Risk that stakeholders fail to differentiate between the school and its competitors; • Risk of competition for the same share of the market Appendix 8 Risk H /M / L Existing Internal Controls and Evidence Admissions Policy; Parent and Carer Communication Policy; Marketing Strategy; Effective Networking Experienced SMT; Active and experienced Trustees and Governing Body; Stakeholders who take an active role in the operation of the school Low Assessment of control quality / Action needed Strong Strong Low Low Reports to the Trustees; Reports to the school Governing Body; Parent and Carer Communication Policy Marketing Strategy; Effective Networking; Designated Assistant Director with responsibility for Business and Community; Low 28 Strong Strong 5 Failure to assess and review the alliances and partnerships with other organisations 6 Failure to ensure that Information Technology in the school is maintained to the highest standard • Risk that an alliance or partnership is no longer appropriate; • Risk to the integrity of the school • IT security risk; • Risk to the corruption or loss of data; • Risk that IT equipment and services are outdated and no longer fit for purpose; • Financial risk; • Risk of litigation Low Networking; Visits to other schools; Head teacher meetings IT Support contract; IT strategy; Access to school IT staff and policies Part of the school insurance review process organised by the Finance Department; Regular meetings with insurance companies; Buildings insurance held by the school; Employee insurance held by the school as employer; Vehicles hired through the school; Fixtures, Fittings, Employer, Public Liability, Professional Indemnity held by the school Part of the school insurance review process organised by the Finance Department; Regular meetings with insurance companies; Buildings insurance held by the school; Fixtures, Fittings, Employer, Public Liability, Professional Indemnity held by the school Low Low 7 Failure to ensure that the school had adequate insurance cover 8 Failure to monitor the effect of risks over which the school has no or little control such as economic and natural disaster • Financial risk; • Risk of litigation; • Reputational risk Low • Financial risk; • Risk of litigation; • Reputational risk 29 Strong Strong Strong Strong 9 Failure of the school to recruit Governors who have the correct profile 10 Failure of the school to produce open and regular management accounts 11 Failure of the school to have financial management systems that prevent fraud 12 13 Failure of the school to comply with legislative requirements Failure of the Academy and the Governing Body to ensure that the school have a robust organisational approach in place to deliver governance of • Risk that a governor could attract negative publicity; • Risk that the stakeholders and beneficiaries view governors as merely an extension of the SMT; • Risk that stakeholders and beneficiaries lose confidence in the governing body • Management and admin costs are perceived as too high by the stakeholders; • SMT salaries are perceived as being too high; • School reserves are seen to be too high and not directed towards meeting the school objectives • Financial risk; • Risk of litigation; • Reputational risk; • Risk to the future of the school • Financial risk; • Reputational risk; • Risk of litigation; • Risk of poor morale affecting staff and beneficiaries; • Risk to the future of the school • Risk that committees fail to operate; • Risk that committee delegation is poor; • Risk that the Governing Body do not delegate or delegate too much to the Head or SMT; • Risk that terms of reference are inadequate and unfit for purpose Low Head and Deputy Head profile of skills required against those offered by potential governors; Independent Clerk to the Governing Body; Governor training and Induction Strong Low Low Monthly Management Accounts; Reports to LG and Governing Body; Budget Monitoring; Awareness of Financial regulations; Effective Internal and External Audit Monthly Management Accounts; Internal Controls; Regular and timely reconciliations; Robust Financial policies and procedures; Financial Regulations; Internal and External Audit Low Clear policies disseminated staff; Risk assessment process; Health and Safety Policy; Guidance from school LEA on Data Protection; Low Independent Clerk to the Governing Body; Governor training and induction; Register of Governor Interests; Internal audit; Minutes of Governing Body 30 Strong Strong Strong Strong the school 14 Failure of the Academy and the Governing Body to have procedures in place to cover the absence of the Head of the School or other members of SMT • Financial risk; • Reputational risk; • Risk of poor morale affecting staff and beneficiaries; • Risk to the day to day operation of the school Clear guidance of senior staff roles; Clear cover arrangements; Active Governing Body membership; Access to school management for guidance and support; Crisis Management Policy Low 31 Strong Operational Risks Risk Ref No 1 2 3 Sub Risk Description Failure to ensure that the quality of Management Information produced by the school is of a high quality Failure to ensure that the Management Information produced by the school is timely Failure to ensure that the quantity of Management Information produced by the school is good enough to aid decision making Appendix 9 Risk Consequences • Risk that financial and non-financial performance can't be managed or reviewed by SMT; • Risk that financial and non-financial performance can't be challenged or reviewed by the Trust or Governing Body; • Risk to the school of receiving poor audits and inspections • Risk that financial and non-financial performance can't be managed by SMT because it is out of date; • Risk that financial and non-financial performance can't be challenged by the Governing Body because it is out of date; • Risk to the school of receiving poor audits and inspections • Risk that the SMT can't make informed decision making; • Risk that the Governing Body can't make informed strategic decisions Risk H /M / L Existing Internal Controls and Evidence Low Regular reporting and review of performance against targets for recruitment; LG Review process; Trustee and Governing Body reports and minutes; Support from the school Student Records Department Low Regular reporting and review of performance against targets for recruitment; LG Review process; Trustee and Governing Body reports and minutes; Support from the school Student Records Department Low Regular reporting and review of performance against targets for recruitment; LG Review process; Trustee and Governing Body reports and minutes 32 Assessment of control quality / Action needed Strong Strong Strong 4 Failure to ensure that the Governors who are recruited to the Governing Body possess the skills and experience required to run the school 5 Failure to ensure that the Managers of the school possess the skills and experience required to manage the school • Risk of insufficient educational knowledge within the Governing Body; • Risk that the Governors do not have the required experience; • Risk that Governors fail to honour their obligations leading to poor availability and attendance at meetings; • Risk that too much emphasis is placed on entrepreneurial work and the strategic objectives of the school are then ignored; • Risk that Governors become too involved with management of the school; • Risk that Governors do not act solely in the interest of the school but for other interests eg business; • Risk that the Governing Body has no financial expertise; • Risk that Governors play a "passive" role on the Governing Body • Risk that members of SMT do not have the capability or experience within the sector; • Risk that SMT do not have the integrity required; • Risk that succession planning is ignored; • Risk that too much emphasis is placed on entrepreneurial work and the strategic objectives of the school are ignored Low Head & Deputy Head profile of skills required against those offered by potential Governors; Independent Clerk to the Governing Body; Governor training and induction; Register of Governing Body interests Low School Recruitment and Selection Policy and Procedures; Continuing professional development; Active Governing Body membership; Performance management; Staff development strategy 33 Strong Strong 6 Failure to ensure that staff recruited to the school have the required skills and expertise to meet the strategic objectives of the school 7 Failure to ensure that the income due to the school is collected in a timely and efficient manner and fully reconciled as per financial regulations • Risk to staff and beneficiaries of low morale; • Risk of poor recruitment of learners to the school; • Risk of poor retention and success rates; • Risk of recruiting unsuitable staff; • Risk of poor appraisal, CPD processes and the need to instigate costly disciplinary procedures, tribunals etc; • Risk that school procedures and processes are not undertaken in a satisfactory manner; • Risk that health and safety and safeguarding could be compromised amongst beneficiaries, staff and stakeholders; • Financial risk; • Risk of litigation; • Risk to the achievement of the school's strategic objectives • Financial risk; • Risk to the achievement of the school's strategic objectives; • Risk of competitors competing for donations and grants from the same providers; • Risk that grants may not be used for the purposes they were intended; • Risk of poor audit reports and the claw back of funding School Recruitment and Selection Policy and Procedures; Continuing professional development; Active Governing Body membership; Staff development strategy; Strong Low Low 34 Monthly Management Accounts; Effective use of the school Credit Control system; Performance Monitoring Reports Strong 8 Failure to ensure that Goods and Services are purchased in line with financial regulations and that suppliers are paid in a timely and efficient manner 9 Failure to ensure that a comprehensive up to date list of suppliers to the school is maintained 10 Failure to implement a risk management strategy • Financial risk; • Reputational risk; • Risk to the achievement of the school's strategic objectives; • Risk to the financial viability of suppliers; • Risk of breaking financial regulations; • Risk of poor audit reports; • Risk of breaking the Bribery Act leading to litigation • Risk that by using a key supplier, supplies may not always be available; • Risk that the quality of supplies could be compromised; • Risk that the availability of competitive prices will be compromised; •Risk to the achievement of the school's strategic objectives • Failure to optimise educational opportunities; • Non-compliance with school funding agency requirements; • Exposure of the school to unnecessary risk; • Increased costs e.g. insurance Low Monthly Creditor control Monthly reports from the school; Financial Regulations awareness; Internal controls operated by the school; BACs Payment system used by the school; Effective internal and external audit Low Financial Regulations awareness; Internal controls operated by the school Finance Department; Effective internal and external audit Low Risk strategy; Risk Register and Action Plans; Risk Management Group; Governing Body reporting mechanisms; 35 Strong Strong Strong Compliance Risks Risk Ref No 1 2 Sub Risk Description Failure to ensure that the school comply with employee legislation Failure to ensure that the school comply with environmental legislation Appendix 10 Risk Consequences • Risk that legislative requirements are not known or complied with; • Risk that Equal Opportunities legislation may not be complied with or discrimination in the work place may occur; • Risk that Data Protection legislation may not be complied with; Risk that Human Rights legislation will not be complied with; • Risk that employee contract legislation may not be complied with; Risk that employee Pension legislative requirements are not known or complied with; • Risk that Health and Safety legislative requirements are not known or complied with • Risk that UK legislative requirements are not known or complied with; • Risk that EU legislative requirements are not known or complied with Risk H /M / L Existing Internal Controls and Evidence Low Support of HR Advice and the associated policies and procedures; Support of school Data Protection Officer and supporting policy and procedure; Health and Safety Policy; First Aid Policy; Fire Safety Policy; Support from the school Health and Safety Officer Low Reporting to LG and Governing Body; Utilisation of school sustainability policies (as Landlord of building); Support of the school Estates Manager 36 Assessment of control quality / Action needed Strong Strong 3 4 5 6 Failure to ensure that the Financial Reporting requirements of the school are met Failure to ensure that up to date information regarding the legislation relating to charities is maintained and kept updated by senior management in the school Failure to ensure that the school comply with legislation regarding Tax Failure to ensure that the school ensures that Data Protection systems, procedures and processes are adequate • Risk that the legislative requirements relating to the production and reporting of the Statutory Accounts are not known or complied with; • Risk that the legislative requirements relating to Accounting Standards are not known or complied with; • Risk that the Charities Statement of Recommended Practice (SORP) legislative requirements are not known or complied with • Risk that legislative requirements are not known or complied with; • Financial risk; • Risk that the Governing Body are not aware of their legislative obligations • Risk that legislative requirements relating to VAT, PAYE, National Insurance etc is not known or complied with; • Financial risk; • Litigation risk • Risk that the legislative requirements relating to the protection of data are not known or complied with; • Financial risk; • Litigation risk Low Monthly Management Accounts; Reports to Enterprise Committee and the Governing Body; Budget monitoring; Awareness of Financial Regulations / AFH; Effective External Audit; 3 year financial forecasts Support from the Responsible Officer Low Independent Clerk to the Governing Body; Networking Groups; EFA Updates; School website Strong Low Support from school VAT consultant; Support of Payroll Supplier and the associated policies and procedures Low Support of school Data Protection Officer and supporting policy and procedure Strong 37 Strong Strong 7 Failure to ensure that the school is compliant in relation to Welfare issues 8 Failure to ensure that the school is compliant in respect of the requirements of the school sector • Risk that the legislative requirements relating to disability are not known or complied with; • Risk that the legislative requirements of the Child Protection Act are not known of complied with • Risk that the legislative requirements relating to the National Curriculum are not known or complied with; • Risk that the legislative requirements relating to mental health are not known or complied with 9 Failure to ensure that the school is compliant in respect of the requirements of the Government and other relevant Authorities • Risk that the terms and conditions relating to the payment of grant is not known of complied with; • Risk that the legislative requirements relating to licensing are not known or complied with Low Low Low 38 Support of HR Department and the associated policies and procedures; Parent and Carer Communication Policy; DBS Policy; Citizenship Policy; Personal, Social, Health and Economic Education Policy; Reporting mechanisms to the Governing Body Reporting mechanisms to the Governing Body Independent Clerk to the Governing Body; Reports to LG and the Governing Body; Ofsted Inspections; Internal and External Audit; Networking; Visits to other schools; Head teacher meetings Strong Strong Strong
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