Governance Ireland Process Steps
Process Flow for a Governance Ireland Service on CP 86 – Organisational Effectiveness Review
The GI proposition is designed to enhance the Board’s own oversight and effective review of the organisation. Such a review need not be completely outsourced through a material outsource contract with an external agent. There may be a more advantageous approach in meeting the CBI requirements under CP 86. GI sees this as an opportunity to enhance and affirm the Boards own expertise and stewardship in overseeing the effectiveness of the organisation. The independent nature of the review will provide an excellent control function framework when viewed under the PRISM review system currently adopted by the CBI.
9 Process Steps
- Engage Board Chairperson and INED, or just the Chairperson if this position is independent.
- Agree the terms of reference for a GI remit in supporting the development and stress testing of key data flows to enable an independent review of the effectiveness of the mandated designated functions within the company. Currently these functions include the following. – See appendix 1. From June 2016 these functions will include the following – See appendix 2.
- Review the organisation chart and key functions as noted in the Business Plan/ Programme of Activities.
- Agree with the Board the level and key focus of the GI engagement and prepare a Project Plan. This will make clear that the purpose and action points are aimed at supporting the Board to enhance its own effectiveness and control in conducting a critical assessment of the CP 86 requirements. Standard templates may be useful. However, each fund or management company board will have different challenges and different skill sets available within the board and within the wider organisation, so a more tailored approach may be appropriate.
- Review and develop an auditable archive of the required documents and data from each designated function (appendix 1&2) A key consideration at this point is to note that the GI proposal does not involve an exporting of key data outside of the company’s own IT environment. Thus a key data protection risk is mitigated.
- GI will review the documentation and data streams for each designated function with the INED. The purpose of the review is to assess if they offer a substantial basis for verifying the effective working of each relevant part of the organisation. Some areas of the review may require more support than others depending on the experience base of the INED. GI will provide appropriate support in ‘sense checking’ the adequacy of thedocument and data archive. In the area of Investment Performance and related performance GI will utilise strategic partners (Clarus Investment Solutions) to provide specific expertise.
- The data archive developed within the organisation should be capable of ensuring restricted access only to the INED and designed agents approved by the Board to support the Organisation Effectiveness Review.
- GI will assist, if necessary, the INED with the task of framing the report to the Board. The key consideration here is the role of GI in supporting the INED in the completion of the review process. The author of the report to the Board must be the INED.
- GI will, if required, prepare a report with recommendations on follow-up action points for the next review period.