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Home > Government
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> Arm's length body sponsorship code of good practice
Cabinet Office
Contents
Ministerial foreword
Introduction
Why sponsorship is essential
What effective sponsorship entails
How to deliver good practice in ALB sponsorship
Bibliography
Glossary of terms
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sponsorship-code-of-good-practice/arms-length-body-sponsorship-code-of-good-practice
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Ministerial foreword
Public bodies form an important means of providing services on behalf of Her
Majesty’s Government. They cover a wide range of areas, from health to
education, justice to defence and beyond. Arm’s Length Bodies (ALBs) spend
over £220 billion a year and employ the equivalent of over 300,000 people on a
full-time basis.
Sponsorship is the activity that promotes and maintains an effective working
relationship between departments and public bodies, in turn facilitating
accountable, efficient and effective services to the public.
The National Audit Office (NAO) and the Public Accounts Committee (PAC)
have both recommended improvements in the Government's oversight of ALBs.
This followed from a number of high-profile failures which illuminated concerns
around sponsorship 222221),
For this reason, HM Government decided to improve departmental sponsorship
through action 24 of the Declaration on Government Reformieeinete 2), I am,
therefore, pleased to launch the Sponsorship Code of Good Practice which will
fulfil that commitment.
As with all State activities, the relationship with Parliament is fundamental.
ALBs must prioritise their obligations to Members of Parliament to whom they
are accountable and by whom they are paid on behalf of voters. This is of
particular importance when MPs seek “redress of grievance” for their
constituents.
This code sets out why sponsorship is essential, what effective sponsorship
entails, and how it can be undertaken. The Code requires departments to:
1. Strive to deliver best practice in six key sponsorship capabilities; and
2. Progress through three levels of maturity - ‘emerging, maturing and
advanced’.
This approach recognises the variety of public bodies so HM Government
Departments should be confident in complying with the Code, or explaining why
compliance is not necessary or appropriate.
These measures will promote a more effective relationship between HM
Government Departments and ALBs, providing better services to the British
public.
Rt Hon Jacob Rees-Mogg MP
Minister for Brexit Opportunities and Government Efficiency
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Introduction
What is sponsorship?
Sponsorship is the activity that delivers effective relationships between
departments and their ALBs. Effective relationships help departments and their
ALBs to operate as outcome delivery systems, delivering the efficient and
effective public outcomes that Parliament and the public expect.
Sponsorship has a long history. The Next Steps Report (1988) recommended
the establishment of Next Steps Agencies: central government public bodies
focused on the delivery of policies developed by ministerial departments! a
I
}
To deliver these principles, senior sponsors and their supporting sponsorship
teams were introduced to act as the golden thread between departments and
public bodies.
In its 2021 report, ‘Central oversight of arm’s length bodies’ ,/22!2'¢ 4! the
National Audit Office (NAO) recommended that:
“ The Cabinet Office should set out common standards for what good
departmental sponsorship arrangements look like, and work with
departments to ensure sponsorship teams have the right capability and
sufficient capacity. It should monitor how this is adopted by departments
during its regular review of framework agreements.”
In its 2021 report, ‘Government's delivery through arm’s length bodies’, /22!o'e
5] the Public Accounts Committee (PAC) subsequently recommended that:
“ [The Cabinet Office should] assure itself that the guidance it sets is being
followed and that assurance and framework documents are regularly
updated; support departments and ALBs so that they can better
benchmark their performance; and improve sponsorship skills across
government and how it will measure the success of this.”
The government committed in the June 2021, Declaration on Government
Reform (“DoGR’) to “increase the effectiveness of departmental sponsorship,
underpinned by clear performance metrics and rigorous new governance and
sponsorship standards.” [2292 SThe government reiterated that commitment
to support and monitor the delivery of more consistently high-quality
sponsorship arrangements across government in its response to the PAC and
NAO’s recommendations. f22tete 7)
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Government has a number of sponsorship functions for its ALBs, each with a
distinct role and responsibilities.
How is sponsorship delivered?
Sponsorship requires a whole department effort. There should be a focus on
forging strong and trusting relationships between the relevant individuals at all
levels of the ALB and the department. This will help to ensure both that ALBs
feel supported and that departments are assured of their delivery. Working
together to create trust and a culture of no surprises is the foundation of good
sponsorship.
Sponsorship is delivered by several actors, listed below. Section [5] provides
more detail on how departments might structure themselves to deliver
sponsorship in practice.
1. The Secretary of State is accountable to Parliament for the performance of
each Public Body for which their department is responsible#22!"2!2-8!, They
may delegate responsibility to a junior minister.
2. The board of an ALB provides leadership, strategic direction, advocacy and
independent scrutiny to both the ALB and the department. It acts in
accordance with the requirements of Managing Public Money and is key to
promoting an effective relationship between the sponsoring department and
the ALB. The role of the board varies according to the classification of the
ALB. Whereas some boards are advisory, others (usually boards of
government-owned companies) also have fiduciary responsibilities [see
Annex C -The Role of the Arm’s Length Body (ALB) board for further
information].
3. The Principal Accounting Officer (PAO) - normally the department’s
Permanent Secretary - is accountable to Parliament for the management of
public money.
4. ie PAO should appoint a delegated Accounting Officer (AO) to each of their
s. lf .
5. Routine oversight of each ALB within the departmental group should be led
by a senior sponsor, normally appointed by and acting on behalf of the PAO.
6. Senior sponsors are normally supported by a team, or by an equivalent group
such as a secretariat. The potential structures of the sponsorship team are
described in section 5.
7. The senior sponsors accountable for managing an ALB should engage with
the department's functional leads, and work with them to ensure that the
department's ALBs have the right information, tools and capacity to adopt
relevant functional standards. !!22@9te 7)
8. These sponsors typically oversee the strategic engagement between the
department and its ALBs, working closely with the department's functional
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experts and are able to call on specialist expertise as needed.
Figure 2: Table illustrating the differences between the categories of ALBs
dependent on their comparable characteristics, defining roles and
responsibilities
Category
to Minister
Executive Yes
Agency
Non Yes
Departmental
Public Body
(Advisory)
Non Yes
Departmental
Public Body
(Non-
Advisory)
Non- Yes**
Ministerial
Department
policy
oversight
Yes
Yes*
Yes*
No
Accountable Department Accounting
Officer
Yes
No
Yes
Yes
Income Ma
sourced
from
department
estimate
Yes CE:
Exe
Yes Ind:
Cor
Yes CE:
Exe
No CE
Exe
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Category Accountable Department Accounting Income Ma
to Minister policy Officer sourced
oversight from
department
estimate
*Department sets a strategic framework. **Minister usually reported to, but
‘constitutional bodies’ report directly to Parliament in exceptional circumstances.
What is the scope of this Code?
This Code is for Executive Agencies or Non-Departmental Public BodiesIetsote
‘1 and may be applicable to Non Ministerial Departments. The code accounts
for all forms and functions of ALBs (i.e. regulators, granting organisations).
Departments must exercise their discretion when determining the correct
application of this document to ALBs of differing independent status under their
purview. A ‘comply or explain’ approach must be adopted to facilitate this.
Departments are encouraged to apply this Code to central government public
bodies as appropriate. ff 2]
The Code supersedes pre-existing guidance; namely, the 2017 Sponsorship
Code, the 2014 Sponsorship Competency Framework, and the 2014
Sponsorship Induction pack.
The Code compliments any statutory requirements and those set out in
Managing Public Money. It is consistent with, and complementary to, the
Cabinet Office guidance on reviews of public bodies!{22!22'2.13! and sets the
standards for sponsorship. The Code is also issued in addition to other relevant
directives such as functional standards and Dear Accounting Officer letters.
Figure 3: The Sponsorship Code supports Accounting Officers to fulfil
their stewardship role for the public resources associated with the
direction and management of arm’s length bodies
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Public Money
Accounting Officer
Functional standards
and other requirements and
guinance
Sponsorship Code
Managing the relationship between
The Sponsorship Code manages the relationship between departments and
arm’s length bodies. It feeds into the functional standards and other
requirements and guidance, which supports Accounting Officers to fulfil their
role. Accounting Officers also need to consider the Managing Public Money
guidance.
The principles and the capabilities that underpin
sponsorship
The key principles of great sponsorship are:
e purpose: a mutual clear understanding of the purpose of the ALB
assurance: a proportionate approach to assurance
value: mutual sharing of skills and experience, and
engagement: open, honest and constructive relationships
Great sponsors apply these principles across six key capabilities:
relationship management
agreeing strategy and setting objectives
outcome assurance
financial oversight
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e risk management, and
e governance and accountability
Central assurance of departmental sponsorship
It is important that there is a consistent level of sponsorship across different
departments and their ALBs and that standards in sponsorship continue to
develop and respond to the changing environment.
The Cabinet Office will provide ministers and the Civil Service Board with
assurance that the effectiveness of departmental sponsorship is increased by:
e providing a tool to support departments in assuring their PAO that high
standards of sponsorship are being delivered in respect of the department's
ALBs footnote 14)
e the Cabinet Office 2022-23 Outcome Delivery Plan guidance includes two
sponsorship focused metrics that offer assurance in department adoption of
the Code
e number of department sponsor teams adopting the sponsorship ‘Code of
Good Practice’; and
e number of departments reporting they assess their sponsorship capability as
‘emerging, maturing, or advanced’.
e a proportionate annual assurance of departments to monitor continuous
improvement in ALB sponsorship capability and consistency across
governmentif2einete 15)
e sponsorship being an integral part of ALB reviews
How should departments use this Code?
Departments should strive for continuous improvement, delivering best practice
by progressing through the three maturity stages described in Box 1 below
according to the priorities departments determine for their sponsorship
development.
Figure 4: diagramatic illustration of the maturity model approach
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Advanced
Maturing
Peer Review: Continuous improvement and the Code
as a living document
improving Proficiency: Across all six sponsorship
capabilities
Assurance: Annual review of departmental >
sponsorship
The three maturity stages are emerging, maturing and advanced. They include:
e peer review: continuous improvement and the Code as a living document
e improving proficiency: across all six sponsorship capabilities
e assurance: annual review of departmental sponsorship
There is a diverse landscape of ALBs. Departments will be best placed to
consider proportionality in relation to the sponsorship of their bodies.
Departments should therefore look to apply the ‘comply or explain’ principle
against this Code.
There may be organisations that, for a variety of reasons, are unable to fully
implement the Code. A good faith attempt to apply with all aspects of the Code
should be made and evidenced through a ‘comply or explain’ principle
This section sets out what effective sponsorship entails across each of the six
sponsorship capabilities:
e relationship management
e agreeing strategy and setting objectives
¢ outcome assurance
e financial oversight
e risk management, and
® governance and accountability
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Box 1: sponsorship maturity
Relationship management
Emerging
1. Engagement between the department and the ALB is ad hoc and
unfocused.
2. Understanding of the ALB’s purpose within the department is limited to
those officials who engage routinely with the ALB.
3. Departmental officials over-identify with the ALB’s interests and are
unable to give the appropriate level of constructive challenge.
4. Trust is yet to be established between the sponsor team and the ALB and
constructive challenge is limited and lacks the appropriate sharing of views.
5. Risks are not surfaced early enough to be resolved quickly and efficiently,
leading to operational concerns and delays.
Maturing
6. The department and the ALB are engaging regularly, but not at an
appropriate degree of seniority to be effective.
7. The ALB’s purpose is well understood within the business units of the
department adjacent to the ALB’s policy area but not the wider department.
8. There is some leverage of the ALB’s expertise as part of the
department's policy development cycle.
9. Departmental officials are engaging routinely with the ALB, striking an
appropriate balance between advocating for the ALB within the department
and holding the ALB to account for meeting its objectives.
10. There is trust between the ALB and the department at some levels.
Constructive challenge is undertaken but is ad hoc and lacks detailed
understanding of ALB operations.
Advanced
11. Engagement between the department and the ALB is regular and
effective at all levels at the relevant points across the department.
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12. Engagement is strategic, delivering a shared understanding of risks,
opportunities, ministerial priorities, and the ALB’s operating context.
13. The ALB’s purpose is communicated and understood throughout the
sponsoring department at all levels of seniority and publicly.
14. Where appropriate and applicable, processes are in place to draw on
the ALB’s expertise in policy development by the department.
15. Trusting, mature relationships are well established. Challenge is
welcomed and is a norm in engagements.
16. Crisis management is characterised by a culture of collective
responsibility, early identification and mutual problem solving.
Agreeing strategy and setting objectives
Emerging
1. The responsible minister (or PAO, if delegated) does not communicate
priorities to the ALB, for example via an annual chair’s letter or direct
communication.
2. There is limited engagement between the department and ALB on what
success looks like, how it can be delivered and how it is measured.
3. The senior sponsor has limited engagement with the ALB in the
production of its annual business plan and multi-year corporate strategy
and is unable to influence its direction.
4. The ALB is insufficiently responsive to departmental priorities, to change
delivery through lack of awareness or inability to flex resources.
5. The ALB’s plans to deliver ministerial objectives are not clearly articulated
in an annual business plan and multi-year corporate strategy.
Maturing
6. The responsible minister (or PAO, if delegated) clearly articulates the
priorities for s for the ALB
7. Senior sponsor engagement on the business plan and corporate strategy
is limited to final review.
8. Avision of what success looks like, how it can be delivered and how it is
measured is clearly articulated by the department to the ALB, but may be
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over- or under-stretching and not properly reflect ministerial priorities and/or
the reality of the ALB’s operating context.
9. Priorities for the ALB from the department change frequently and can at
times be inconsistent with the longer-term strategic direction and/or any
statutory underpinning.
Advanced
10. The priorities for the ALB are set out in documents such as an annual
chair’s letter issued by the responsible minister (or PAO, if delegated) sets
SMART 22i22'.18] outputs or objectives for the ALB to deliver.
11. Outputs provide a stretching but realistic target that drives continuous
improvement in effectiveness and efficiency for the ALB.
12. The department and the ALB engage collaboratively on an annual
business plan that sets out how these SMART outputs will be delivered,
underpinned by key performance indicators that are informed by timely
management information. There is a constructive yet challenging dialogue
between individuals at all levels that underpins this work.
13. This document makes up the first year of a multi-year corporate strategy
that sets out how the ALB’s annual outputs contribute to the delivery of
longer-term impacts.
Outcome assurance
Emerging
1. There is a lack of understanding of what good delivery [operation] should
look like for the ALB throughout the department. The department has limited
discussions and opportunities to review and challenge the outcomes
delivered by the ALB.
2. The processes implemented by the department to ensure the outcomes
delivered by the ALB are not sufficiently effective or broad enough to
understand its operational delivery.
3. Management information (MI) provided to the department is limited
scrutiny is cursory and unsupported by relevant functional expertise, or
lacks timeliness.
4. The ALB’s MI is not available to the department, or it is not scrutinised
appropriately.
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5. Functional support is not sought and/or provided to help scrutinise
outcomes by the department and the application of functional standards is
limited and not considered appropriately.
6. The department makes frequent and/or unnecessary changes to the MI
that it requires from the ALB.
Maturing
7. There are discussions between the ALB and department at working level
and with the senior sponsor on performance. However, there is no ‘join up’
between the ALB’s outcomes and the department's wider governance and
delivery system.
8. MI is provided to the department in a timely manner, but assurance is
process driven and not undertaken collaboratively or in order to drive
continuous improvement at all levels.
9. The department and the ALB agree MI reporting arrangements at the
beginning of the year and minimise in-year changes to those requirements.
Advanced
10. Discussions take place at all levels, including active constructive
challenge on the outcomes the ALB has delivered. These outcomes flow
into the department’s wider governance, and are discussed by the
departmental board. The department facilitates the ALB discussing its
outcomes with bodies that constitute any wider delivery system they are
part of.
11. MI is widely used to inform decision making and to drive continuous
improvement at all levels. It is presented in an accessible manner and the
department and the ALB consider the same versions of the ALB’s MI.
12. Ml is considered at regular formal accountability meetings between the
responsible minister and the ALB’s chair and between the senior sponsor
and the ALB’s chief executive, as well as at working level.
13. The department and the ALB keep the effectiveness of reporting
arrangements under active and critical review, and agree changes in a spirit
of partnership where clear gains to the quality of the accountability and
feedback loop can be achieved.
Financial oversight
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Emerging
1. There is a limited relationship between the ALB and departmental finance
teams - interactions only take place through the minimum required
processes.
2. The PAO or relevant budget holder does not provide the ALB with a
delegated authority letter at an appropriate time, hampering the ALB’s
business planning.
3. The ALB goes beyond the delegated limits and budget allocations set out
in the delegated authority letter and there is limited discussion on
justification.
4. In-year assurance of the ALB’s financial position by the department is
inadequate, either through the absence of timely and accurate financial
data being provided by the ALB, or through the department not having
effectively scrutinised and acted upon that data.
5. An excess of controls and approval processes: the department adds
additional financial controls over the ALB, impacting on the ALB’s
operational freedom and effectiveness.
6. There is a lack of engagement or information on the ALB financial
position and therefore issues are not visible to the department.
Maturing
7. There are relationships at a working level between the ALB and
departmental finance teams - but this does not extend to senior or board
levels. Suspicion remains within the relationship about expenditure and/or
the sharing of relevant data, though there is a degree of in-year spending
assurance.
8. The delegated authority letter from the department to the ALB AO fails to
provide the ALB with an appropriate degree of operational autonomy or the
department with an appropriate degree of control.
9. The department (and Cabinet Office/ HM Treasury where applicable) sets
an appropriate spending approval framework, but does not consistently
deliver service standards, for example in relation to business case
turnaround times, hampering the ALB’s operational delivery.
Advanced
10. There is a well established and trusting but constructively critical
relationship between the ALB’s finance team and the department's finance
team at all levels. Both the ALB and the department act as ‘one team’ when
it comes to significant expenditure requests, or any proposals that need to
be submitted to the Centre.
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11. The PAO delivers a timely and comprehensive delegated authority letter
to the ALB’s AO, balancing the ALB’s need for operational autonomy with
the department's need for control.
12. Regular ‘open book’ engagement between the department and the ALB
provides both parties with assurance that the ALB’s expenditure is
affordable, sustainable, and within agreed limits and allocations.
13. The ALB has a good understanding of and operates in accordance with
Managing Public Money and with Cabinet Office spending controls.
Risk management
Emerging
1. The ALB has limited implementation of appropriate risk management
framework in accordance with the Orange Book.
2. The department does not discuss and provide clarity to the ALB as to the
risks that it is willing to take to achieve objectives - its risk appetite.
Alternatively, the ALB exceeds the department's position.
3. The department has limited processes and opportunities for the ALB to
routinely escalate risks to the department, or the ALB fails to employ these
processes appropriately.
4. The department and the ALB do not engage at appropriate frequency on
risk identification and management.
5. Risk management is largely viewed as a process-driven exercise in the
department, ALB, or both.
Maturing
6. The department provides a balance of opportunity and risk to the ALB
that is either too restrictive to operate delegated decision making or too lax
to discharge respective accountabilities and responsibilities
7. Although there are some processes in place to routinely escalate risk
from the ALB to the department, the department does not identify and
deliver cross-cutting risks and mitigation strategies within the departmental
family or to support ALBs in managing those risks by identifying and sharing
best practice
8. The value of an effective risk management framework, including
appropriate escalation, is generally understood and processes are largely
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proportionate.
Advanced
9. Aligned risk management processes are applied and within the
department and the ALB
10. The department provides a clear and balanced risk appetite to the ALB
that meets the needs of the department for control and of the ALB for
operational autonomy.
11. The department and the ALB have a mutual understanding of risk, both
within the ALB and of cross-cutting risks within the departmental family.
12. The department supports ALBs in managing risks by identifying and
sharing best practice in risk management and by delivering cross-cutting
interventions.
13. Effective risk management is seen as a key strategic tool at all levels,
and is approached by the department and the ALB in the spirit of
partnership and constructive challenge.
Governance and accountability
Emerging
1. Managing Public Money is not well understood nor applied by the ALB.
2. The PAO does not appoint a senior sponsor in respect of each ALB, or
appoints a single sponsor to oversee an excessive number of ALBs.
3. The PAO does not prioritise resources to ensure that the senior sponsor
is supported by a sponsor team, or equivalent, with appropriate capability
and capacity to deliver consistently high quality sponsorship.
4. The department has insufficient processes and oversight in place to
ensure good governance or accountability is in place within the ALB.
5. The department's engagement with the ALB frequently undermines the
ALB’s own governance structures and processes.
Maturing
6. The PAO appoints a senior sponsor, but they may have limited time to
build and maintain an effective relationship with the ALB.
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7. The senior sponsor is supported by a working-level sponsor team or
equivalent, but this team may lack the capacity and capability to provide
consistently high quality support to the senior sponsor.
8. The department monitors whether the ALB has met the requisite
standards of governance and accountability and highlights deficiencies to
the ALB’s senior leadership team at formal accountability meetings.
9. The department has named individuals in place for the departmental and
ALB accountabilities set out in GovS 001, Government functions
10. The PAO is assured that the ALB is meeting the mandatory elements
set out in Managing Public Money and relevant functional standards
Advanced
11. The PAO appoints a senior sponsor to each ALB and balances these
appointments with senior sponsors’ other responsibilities so that each ALB
receives an appropriate degree of oversight from the senior sponsor.
12. The senior sponsor is supported by a working-level sponsorship team,
or equivalent, with the capability and capacity to provide consistently high
quality support.
13. The PAO has confidence that the arm’s length body has a
comprehensive picture of improved delivery performance, including
evidence about how progress is being maintained.
Why sponsorship is essential
Effective relationships help departments and ALBs to operate as outcome
delivery systems that are worth more than the sum of their parts. Sponsorship
enables those effective relationships, supporting the efficient and effective
delivery of public outcomes.
Sponsorship plays a vital role in providing Principal Accounting Officers (PAOs)
with assurance that the ALBs for which they are accountable are operating
effectively, managing and escalating risks appropriately, and operating with a
high degree of probity.
Conversely, ineffective sponsorship can undermine the relationships between
departments and public bodies. This can in turn have a detrimental effect on the
delivery of effective public outcomes that offer value for money. For example, if
a public body does not have a clear set of agreed objectives for the year, it may
fail to meet the expectations of the department.
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Sponsors should be supported by the Government Functionsigetsie 17),
resourced appropriately, and provided with impactful learning and development
opportunities.
What effective sponsorship entails
In respect of the six capabilities, this section sets out the outcomes that
departments should strive for, the activities that facilitate those outcomes, and
the support that is available to facilitate those activities.
Figure 5: The interaction between the key components of effective
sponsorship and the six sponsorship capabilities as set out below
1, Relationship 2. 3. a 5. 6. Governance
Management Objectives Outcome Financial Risk &
& Strategy Assurances Management Management Accountability
ACTIVITIES:
BEHAVIOURS
SUPPORT
The outcomes are supported by 6 activities: relationship management,
objectives and strategy, outcome assurance, financial management, risk
management and governance and accountability. These are also supported by
two components: behaviours and support.
Relationship management
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At the heart of a successful partnership between the department and its ALBs
are relationships, which support the delivery of efficient and effective public
outcomes.
Outcomes
Departments should strive for relationships characterised by:
1. Trust;
2. Honesty and openness, and
3. Constructive challenge.
Case Study 1: 2019 collaboration between the Department for
Transport (DfT) and the Civil Aviation Authority (CAA) to deliver the
Thomas Cook passenger repatriation
In 2019 the DfT and the CAA - the UK’s specialist aviation regulator -
assisted by other organisations such as the Foreign, Commonwealth and
Development Office (FCDO), collaborated closely to repatriate passengers
following the financial collapse of travel group Thomas Cook.
The two organisations worked tirelessly between 23 September and 7
October 2019 to ensure that over 150,000 passengers were returned to the
UK on 746 flights across 54 destinations from 18 countries. This was
achieved with as little disruption as possible, and the vast majority on their
originally intended day of travel. This was a significant achievement given
the scale of the exercise and tight timeframe in which it was delivered.
The operation was characterised by a high level of trust between the two
organisations in each other’s capabilities and that decisions would be made
and put into practice in a timely manner. This is testament to the effective
DfT-CAA relationship prior to the Thomas Cook insolvency; constructive
and regular engagement took place at all levels, roles and accountabilities
were clear and decision-making processes were mutually understood.
The successful partnership was reinforced by thorough contingency
planning using their experience of the 2017 Monarch repatriation; by
attention to the recommendations of an Airline Insolvency Review; and by
flexibility in responding to the variety of challenges that came up during the
course of the repatriation.
The insolvency of Thomas Cook was a difficult and emotional event for
affected passengers and especially for staff who lost their jobs. However,
the efficient repatriation and other government initiatives meant that the
impact on passengers, employees and local communities was minimised.
The DfT’s second Permanent Secretary, Gareth Davies, noted that this was
“a great example of what government can do when it’s got a clear goal, a
real sense of purpose and mission and is able to work as one team.
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Case Study 2: Department of Work and Pensions (DWP) maintaining a
close working relationship with The Pensions Regulator (TPR) to
mitigate resource constraints
One of DWP’s major ALBs - The Pensions Regulator (TPR) - is largely
funded by a levy on the private pensions industry. Facing a situation where
the levy was in deficit, but the Regulator was required to implement new
powers arising from the Pension Schemes Act 2021. DWP and TPR agreed
that increased strategic engagement about priorities and budget allocation
was required.
This engagement was built on a relationship that had developed over a
number of years enabling the frank exchange of views and an
understanding of the challenges and pressures each party faced. In
addition to existing working level meetings and regular meetings between
the Chief Executive and the responsible minister, quarterly meetings were
introduced between the DWP Pensions and ALB Executive Leadership
Team and TPR Senior Leadership Team.
The meetings allowed full and open discussion about strategic priorities;
resource implications and where appropriate, the support that DWP
specialist functions, such as commercial and digital, could offer. As a result,
there was a clear and joint understanding of government priorities, and
DWP and TPR were in a good position to reach agreement on how
available resources should best be used to deliver those priorities over the
Spending Review period.
Behaviours
The following behaviours underpin these outcomes:
1. Both parties prioritise investing in the relationship and its maturity at all
levels, from the relationship between the responsible minister and the ALB’s
Chair to the working-level relationships between the department and the ALB.
This was particularly crucial as challenging circumstances arose.
2. A‘no surprises’ culture existed. This enabled trust and transparency to grow
between the department and the ALB. As trust grew the ALB was granted
further autonomy. The ALB engaged with the department on an ‘open book’
basis.
3. The department respected the expertise of the ALB and the ALB welcomed
constructive challenges from the department.
Activities that enable great outcomes and behaviours are set out below.
Activity 1
Clearly articulate accountability relationships within the departmental group,
including with ALBs, in an up-to-date Accounting Officer System Statement
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(AOSS), including relevant roles for functional leadership (see GovS 001,
Government functions)
Activity 2
Clearly articulate the nominated Accounting Officer, if applicable, and senior
sponsor of each of the department’s ALBs. It may be appropriate to do so within
the AOSS.
Activity 3
Publish a Framework Document that has been updated in the last three years
and is based on a template published within Managing Public Money.
Activity 4
Articulate where responsibility lies for each sponsorship function - policy and
corporate - of the department in relation to each of its ALBs, such as through a
Terms of Reference.
Activity 5
Encourage new senior executives and non-executives in the department and in
the ALB to be inducted appropriately, including by encouraging new ALB Non-
Executive Directors to attend a CO-led induction event.
Support
To support them in delivering effectively, sponsor teams should draw on
relevant training, in addition to the guidance referenced throughout this Code.
In particular, sponsors may benefit from undertaking the following Civil Service
Learning training:
1. Giving feedback - Giving and receiving feedback helps us to build authentic
and trusting relationships. {e!ste.18)
2. Communicating with customers Defining the four fundamental principles of
professional communication. [2etete.19)
3. Influencing skills - Effective influencing skills are critical if you want to build
successful relationships. Whether it's customers, colleagues or management,
find out how to adapt your influencing behaviours through an awareness of
their viewpoints. 22's 20)
4. Verbal communication - Develop skills such as crafting a compelling
message and building rapport, and consider how the inflection of your voice
can affect the outcome of a conversation. [stole 21)
5. Written communication - Learn how to write effectively. [otote 22)
6. Assertiveness - Investigate the impact of assertiveness on your day-to-day
working life, as well as the most typical barriers to being assertive. lfeeknote 23)
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Service Standards between both parties may help to strengthen this
relationship. Service standards may be appropriate where both the department
and the ALB believe an agreement is helpful.
A template for reaching this agreement is at Annex B. The Service Standard is
not contractual and should be used only on a ‘best endeavours’ basis. It may be
appropriate to monitor performance against an agreed Service Standard at
meetings between the senior sponsor and the ALB chief executive or as part of
an ALB review. losinete 24)
Agreeing strategy and setting objectives
ALBs form part of departmental outcome delivery systems. Agreeing the
strategy and setting objectives is a vital step in delivering outcomes.
Outcomes
Departments should strive for:
1. Aunified sense of purpose and a clear mutual understanding of how agreed
outcomes will be delivered;
2. ALBs that are established, and continue to exist, only when there is a clear
net benefit to doing so; and
3. Clear expectations and ownership of the outputs to be delivered by the ALB
with supporting management information, which - where possible - are
benchmarked against those delivered by similar organisations to provide
stretching but realistic targets that drive continuous improvement.
Case Study 3: Collaboration between the Ministry of Justice (MoJ) and
the Arm Length Body Partnership team, supporting a shared sense of
purpose
The fast-moving impacts of Covid-19 restrictions (from March 2020) meant
that sponsorship activity within the MoJ had to adapt to ensure changing
operational objectives remained aligned to the wider department and
government strategies and to actively prioritising informational support.
This opened up new opportunities to increase two-way communication with
ALBs. The department was conscientious in providing a shared sense of
purpose, providing practical support through data sharing and supporting
decisions being made around service priorities. One of the MoJ’s ALBs set
up a weekly gold command l22!2!¢.25! meeting to co-ordinate these
changes. By inviting the MoJ’s ALB partnership team, this created a unified
sense of purpose and a clear mutual understanding of how agreed
outcomes will be delivered.
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This gave the Mod a first-hand view of decisions being made on the ground,
as well as input into how the ALB targeted its resources to navigate
complex and fast-changing circumstances. Both parties actively prioritised
informational support, sharing information at all levels, providing
engagement and producing collaborative outputs.
Having the opportunity for regular strategic participation and collaboration
promoted active dialogue which helped the partnership team craft up-to-the-
minute advice to Ministers and the Permanent Secretary when required. In
some instances, in advance of waiting for events to play out. This regular
collaboration ensured departmental objectives were communicated in real
time and ensured alignment of strategies throughout the pandemic.
Case Study 4: Department for Digital, Culture, Media and Sport and UK
Anti-Doping - National Anti-Doping Policy
In 2019 DCMS started working with UK Anti-Doping (UKAD) to revise and
update the UK’s National Anti-Doping Policy.
The document, owned by the government, sets out the roles and
responsibilities around anti-doping activities in the UK. It aimed to meet the
requirements of the United Nations Educational, Scientific and Cultural
Organisation (UNESCO) Convention against Doping in Sport while ensuring
that the World Anti-Doping Code is implemented in the UK. However, the
policy had not changed since its introduction in 2009 when UKAD was
established. The UKk’s policy was in need of updating to reflect significant
developments in anti-doping, education and the latest World Anti-Doping
Code.
DCMS worked with UKAD to identify areas of the *policy requiring revision,
and launched a six week public consultation in late 2019 on how these
could be updated. The results of the consultation were analysed by both
organisations, and a process of iterative discussions took place to agree the
new policy. This involved further consultation with stakeholders from across
the sport sector, and close collaboration between DCMS and UKAD to
consider, agree and finalise changes.
The result was the publication in April 2021 of the updated UK National Anti-
Doping Policy. The most significant update was the introduction of a new
Assurance Framework through which sports can formally demonstrate their
compliance with the policy, reflecting the need for greater clarity over
responsibilities apparent through the consultation. Roles and
responsibilities of organisations involved in anti-doping were updated, and
additional organisations added to make the policy more comprehensive.
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The result was a policy that is helping sports organisations better
understand and meet their anti-doping responsibilities, and the UK is better
able to meet its international obligations.
Behaviours
The following behaviours underpin the outcomes:
1. Both parties were conscientious in providing a shared sense of purpose and
fostering a culture of support.
2. Both parties provided practical and informational support through sharing
data, providing engagement and producing collaborative outputs, defining
clear expectations and highlighting the ALB’s contribution to the department's
aims.
3. Both parties promoted active dialogue that is constructive yet challenging
thereby creating a respectful working environment.
Activities
Figure 6: The hierarchy of documentation that the department should employ in
agreeing the ALB’s strategy and setting its objectives
Accounting Officer
System Statement
Accountabiites
Framework
Document
impact .
evaiuation Corporate
; strategy
Chaiie’s letter
Business
Anal Mositoring of plan
Report and +——----. Management
Accounts inforenation:
Figure 6 provides an illustrative timeline for producing and agreeing this
documentation.
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Activity 1
Clearly articulate:
1. The ALB’s purpose and objectives in the Framework Document, consistent
with those agreed in the business case for the ALB’s establishment, where
applicable, and with any relevant enabling legislation.
2. The ALB’s purpose and objectives should be linked to departmental priorities,
including the ALB in the department’s Outcome Delivery Plan.
3. Short-term outcomes in a published multi-year corporate strategy, informed
by an annual Chair’s Letter, issued by the relevant Minister or Principal
Accounting Officer to the ALB Chair.
4. Immediate delivery outputs in a published annual business plan.
Key Performance Indicators (KPIs) to measure the ALBs performance against
the Specific, Measurable, Achievable, Relevant, and Time-bound (SMART)
outputs agreed between the department and the ALB.
Activity 2
Implement procedures or mechanisms to draw on the expertise of the ALB in
departmental policy-making.
Activity 3
Explore opportunities to cluster similar ALBs - within or outside of the
departmental group - and to benchmark their performance, setting realistic but
stretching targets that promote the efficient and effective delivery of public
outcomes.
Activity 4
Ensure an assessment is made about how well the department and its ALBs
are currently meeting functional standards, and their ambition for meeting them
more efficiently and effectively in the future; embed actions about continuous
improvement into business plans.
Activity 5
Sponsorship teams should triage proposals by policy teams to establish new
ALBs before engaging the Cabinet Office’s Public Bodies Team, in line with the
Public Bodies Handbook Part 2 - the Approval Process for New Arm’s Length
Bodies. [footnote 26)
Support
To support them in delivering effectively, sponsor teams should draw on
relevant training, in addition to the guidance referenced throughout this Code.
In particular, sponsors may benefit from undertaking the following Civil Service
Learning training:
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1. Collaboration across departments, government and Beyond - Supports civil
servants in building and maintaining relationships and maximising the value
of collaboration. festsete 271
2. Communicating and negotiating policy with influence - Supports civil servants
in influencing and negotiating with different stakeholder groups as part of
policy development and implementation. “sze!¢.28]
Sponsor teams should draw on expert support within their departments,
including from the private office of the responsible minister.
Outcome assurance
Departments should act as critical friends to ALBs, offering support and
challenge in the delivery of outcomes informed by timely Management
Information (MI).
Outcomes
Activities that enable great outcomes and behaviours are set out in the checklist
below.
Activity 1
Ashared understanding at all levels as to how well the ALB is meeting its KPIs.
Activity 2
1. Require ALBs to ensure that they undertake longer-term outcome and impact
evaluation.
2. Require ALBs to publish appropriate information on outturn delivery against
KPIs within the ALB’s Annual Report and Accounts.
3. Ensure that appropriate arrangements are in place to allow the findings of
impact evaluations to influence departmental policy decisions as part of the
policy development cycle. M22inete.29]
Shared outcomes across clusters of ALBs that operate within broad ‘outcome
delivery systems’; where joined up working helps minimise cost and increase
benefits for the user.
Activity 3
Acontinuous improvement culture where learning lessons is primary and
‘blame allocation’ is avoided.
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Case Study 5: The Ministry of Justice (MoJ) and their ALBs outcome
focussed approach to assurance.
Each year the MoJ makes an evidence-based assessment of the
“meaningful oversight” necessary for each of the ALBs. These are based on
the nature and level of risks faced in the year ahead and how these may
impact on delivery against the MoJ’s Outcome Delivery Plan (ODP).
To inform the assessment, engagement with ALBs is undertaken across all
levels and with a range of policy and functional colleagues. This ensures a
shared understanding as to whether the ALB is meeting the performance
that is expected of it, that KPI’s are being met, and that risks are being
effectively managed. Consideration of where and how the department can
best support ALB delivery of essential statutory functions is made and
determines the optimum, risk-based and proportionate oversight and
assurance arrangements for the year ahead.
The findings are reported to the MoJ’s Audit and Risk and Executive
Committees and outcomes from this exercise are used to put in place
bespoke oversight and support arrangements for each ALB, proportionately
targeting our higher risk ALBs. Enhanced oversight arrangements include
increased “holding to account” meetings, tailored engagement and delivery
of targeted risk-reducing initiatives. The risks, strategic themes and
prioritised projects identified through this process are reviewed throughout
the year at regular holding to account meetings.
Through this process we ensured effective oversight and assurance of ALB
delivery and risk management fostering a continuous improvement culture
where learning lessons is primary and ‘blame allocation’ is avoided. We act
as critical friends to our ALBs, holding them to account for delivering agreed
outcomes informed by timely Management Information.
Behaviours
The following behaviours underpin the outcomes:
1. Both parties prioritised an outcomes focussed approach; the ALB was open
with its management information (MI) and strived to provide it in a timely and
an accessible manner. The department was supportive of this approach and
appreciated the limitations of what the MI told it.
2. The department and the ALB fostered a culture of open communication;
communicating any problems and solutions, both through formal reviews, the
recommendations coming from them, and informally on an ongoing basis.
The department should also identify cross-cutting problems and support
ALBs in solving them.
3. When things went wrong both the ALB and department looked to problem
solve rather than apportion blame
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Activities that enable great outcomes and behaviours are set out in the checklist
below.
Activity 1
Hold ALBs to account for delivering their objectives through regular discussion
of timely Management Information (MI) linked to output KPIs.
Activity 2
Ensure that:
1. ALBs undertake longer-term outcome and impact evaluation.
2. ALBs publish appropriate information on outturn delivery against KPIs within
the ALB’s Annual Report and Accounts.
3. that appropriate arrangements are in place to allow the findings of impact
evaluations to influence departmental policy decisions as part of the policy
development cycle. {2#e!e 39)
Activity 3
In the Framework Document, agree a mechanism for sharing the ALB’s MI with
the department.
Activity 4
Support the delivery of ALB reviews in line with Cabinet Office guidance, and
the implementation of recommendations or actions coming from them. [e!ete
Support
To support them in delivering effectively, sponsor teams should draw on
relevant training, in addition to the guidance referenced throughout this Code.
In particular, sponsors may benefit from undertaking the following Civil Service
Learning training:
1. Performance indicators - Performance indicators help government
departments understand how well a policy, programme, project or service is
performing against expectations. This training covers the setting and use of
targets and the use of outcome-based indicators, benchmarking, and the
balanced scorecard approach. eot#ete $2]
Sponsor teams should draw on expert support within their departments,
including from their corporate governance teams, relevant functional leads, and
operational delivery teams.
Sponsor teams should draw on relevant functional expertise, and understand
the need to meet functional standards in a way that is proportionate and
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appropriate to the work being done by an Arm’s Length Body. Multiple
functional standards - for example, GovS 002, Project Delivery and GovS 008,
Commercial - support the successful, timely, and cost-effective delivery of
government policy objectives. !22!9'2 33 Any analysis to support decision
making should follow GovS 010, Analysis. tse 341
Financial Oversight
ALBs, like other public sector organisations, should follow the guidance on
handling public funds that is contained within Managing Public Money (MPM)
and augmented by ‘GovS 006, Finance’ where appropriate. This Code is
secondary to MPM.
The Principal Accounting Officer (PAO) is accountable to Parliament for the
stewardship of their organisation’s resources. They may delegate responsibility
for the operations of an ALB to an Accounting Officer (AO) within that body, but
their personal accountability remains unchanged.
An understanding of the breadth of legal responsibility of the board and the
ALB, including how such legal and financial responsibilities also affect and
relate to the Accounting Officer’s direct responsibility to Parliament for the ALB.
Outcomes
Departments should strive to:
1. Assure their PAOs that ALBs within the departmental system spend public
money with high levels of probity, delivering value for money.
2. There is a clear process with the ALB Board, department and the Accounting
Officer (AO) to ensure appropriate engagement in the budgeting process.
Case Study 6: The Ministry of Justice (MoJ) Assurance of Financial
Oversight
The MoJ Sponsorship team identified that one of its ALB had received a
number of negative audit opinions, therefore raising concerns about their
compliance with financial controls and functional standards.
Striving to assure the department's Principal Accounting Officer (PAO) that
the ALB spent public money in a manner that was delivering value for
money, the sponsorship team worked closely with the finance functional
leads to understand the rationale for the negative audit opinions and to
design a specific improvement plan to support.
Working as a partnership between the Sponsorship team and functional
leads, the department was able to articulate what good would look like and
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what steps the department could perform to help the ALB. This included
providing dedicated financial support and associated interim resourcing as
well as an enhanced offer of training on financial controls from functional
leads, and deeper and broader engagement on financial issues via more
focused partnership activities
This led to improved audit opinions and strengthened departmental
assurance of the ALB’s financial processes and governance arrangements.
This in turn provided the assurance that was required for both the
department's PAO and the ALB’s Accounting Officer (AO).
Case Study 7: The Home Office (HO) example of Financial Oversight
Function of an Arm’s Length Entity (ALE)
One of the HO Arm’s Length Entities (ALE’s) required assistance from the
department to provide an independent element in assessing quotations for
a research project which had been put out to tender.
In considering who in the department was best placed to fulfil this function,
the ALE identified the Home Office Sponsorship Unit (HOSU) as it
considered that it possessed the relevant skill sets. The relevant Team
Leader in the unit was approached and agreed to assist in the process.
The Team Leader, utilising their acquired knowledge and subject matter
specialism around sponsorship (e.g. finance, commercial), was able to
effectively support the ALE in assessing the quotations and contracts were
awarded accordingly.
The ALE was grateful for the input from HOSU and the expertise that the
Unit was able to bring to assess the quotations and award the contract.
Both parties were able to utilise the strong relationship which had been
established, with HOSU remaining respectful of the ALEs autonomy and
independence, while balancing the departments need for oversight of
Financial Oversight assurance.
Behaviours
The following behaviours underpin the outcomes:
1. Both parties prioritised an open, frank and conscientious relationship at all
levels, ensuring guidance on handling public funds that is contained within
Managing Public Money (MPM) and augmented by ‘GovS 006, Finance’ was
adhered to.
2. A culture of regular engagement was promoted; providing both parties
assurance that the ALB’s expenditure was affordable, sustainable, and within
agreed limits and allocations.
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3. Both parties were respectful of the ALBs operational autonomy in balance
with the department's need for oversight and assurance.
Activities that enable great outcomes and behaviours are set out in the checklist
below.
Activity 1
Implement proportionate oversight arrangements to assure the PAO that the
ALB has the systems and processes in place to reach high standards of probity
in handling public funds.
Activity 2
Ensure that the financial and operational freedoms provided to the ALB by the
department are clearly articulated in a delegated authority letter from the PAO
or relevant budget holder to the AO, which should also set out budget limits.
Activity 3
Support ALB business planning to assure the PAO that the ALB’s financial
plans are sustainable and affordable, in addition to delivering agreed outcomes.
Activity 4
Support ALB leaders to meet functional standards.
Support
To support them in delivering effectively, sponsor teams should draw on
relevant training, in addition to the guidance referenced throughout this Code.
In particular, sponsors may benefit from undertaking the following Civil Service
Learning training:
1. Awareness of finance in government - Learn about the processes used to
manage, monitor and report financial operations to deliver value for money to
the taxpayer.
Sponsor teams should draw on expert support within their departments,
including from their Corporate Governance or Financial Governance Teams or
equivalent and from their Internal Audit Team.
Where sponsor teams encounter ALB spending proposals that may be novel,
contentious, or repercussive, they should engage their Permanent Secretary’s
office and then consider whether it would be appropriate to engage the relevant
spending team or the Treasury Officer of Accounts at HM Treasury.
Sponsor teams should call upon the function leaders within the department, and
ensure that relevant functional standards are followed when functional work is
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involved. For example,
1. The Finance Functional Standard is likely to be relevant to the effective
management of public funds.
2. The Commercial Functional Standard is likely to be relevant when
undertaking procurement.
3. Sponsor teams should pay due regard to the Counter Fraud functional
standard in managing fraud, bribery, and corruption risk in government.
4. Sponsor teams should refer to the debt functional standard when managing
debt owed to the government.
5. Sponsor teams should likewise adhere to the grant functional standard to
support them in delivering effective and efficient grant-making.
Risk management
Sponsors play a vital role in overseeing the ALB’s management of risk. The
Orange Book: Management of Risk — Principles and Concepts sets out the
main principles underlying effective risk management in departments and Arm’s
Length Bodies. If20t%2'2 43! This Code is subordinate to the Orange Book.
Outcomes
The department should strive for:
1. Risks that are well understood, managed and appropriately escalated.
2. An appropriate assessment and management of opportunity and risk with
clarity over the risks that the ALB is exposed to and willing to take to achieve
its objectives - its risk appetite.
3. Confidence in the response to risks and transparency over the principal risks
faced and how these are managed balances the needs of the department for
oversight and of the ALB for operational autonomy.
Case Study 8: The Department of Work and Pensions (DWP) and a
shared understanding of risk management
The DWP wanted to ensure all its bodies had a shared understanding of
risk, a better understanding of the department's risk appetite and that the
impact on the department of ALB risks was clear.
To enable this, DWP instigated regular forums of the chairs of each body’s
Audit and Risk Assurance Committee (ARAC). These were attended by the
senior sponsor and the department's NEDs responsible for risk oversight
alongside members of the department's central risk team.
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These quarterly fora fostered a collaborative culture, enabling bodies to
share common risk themes, raise items of common interest and share the
outcomes of broader horizon scanning exercises looking at less likely but
high impact risks. Discussions have also been informed by Annual
Assurance.
Assessment and the regular reporting to departmental ARAC and have
supported a mutual understanding of this both within the individual ALBs
and of cross-cutting risks within the departmental family.
The fora have prioritised an appropriate risk appetite, building stronger links
within the audit and risk functions across the bodies and enhancing the
links with the central departmental teams. This has resulted in a better
understanding of the overall risk landscape.
Case Study 9: The Department for Education (DfE) and a shared
understanding of risk management
The DfE was keen to lead a collaborative approach to system risk
management working with its Arm’s Length Bodies (ALBs).
Supported by sponsor teams and allowing for greater collaboration on
areas of shared risk affecting multiple organisations, System Risk Reviews
were undertaken to enable cross-organisational discussion of system level
risks (including Devolution of Accountability, T Levels and Data Sharing and
Quality) with actions agreed. The department and ALBs were able to
identify, manage and mitigate system level risks and share risk information,
intelligence, professional expertise and best practice.
Creating an open and transparent approach to sharing risk information
between the department and its ALBs fostered a culture of collaboration in
which all parties were respectful of one another's risk appetite and able to
account for this within their own respective appetite.
Through DfE’s commitment to resource the work, including a dedicated
experienced System Risk Manager and team, the risks were well
understood, communicated and stakeholder engagement plans agreed with
actions monitored, evaluated, managed and appropriately escalated,
creating an appropriate risk appetite that balanced the needs across the
ALB landscape and those of the department.
The positive culture of collaboration within risk management resulted in the
establishment of the ALB Risk Leads Network in May 2021 where best
practice and risk expertise continue to be shared and provide a platform in
which all can seek advice and support.
Behaviours
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The following behaviours underpin the outcomes:
1. Both parties prioritised a mutual understanding of risk. Roles and
responsibilities for risk management were clear and supported effective
governance and decision making at each level, both within the ALB and of
cross-cutting risks within the departmental family.
2. The department fostered a collaborative culture; supporting ALBs in
identifying, managing and mitigating risks. They also looked to understand if
and how risks of an ALB may impact other ALBs both within their department
and the wider ALB landscape.
3. Both parties were respectful of one another’s responsibilities, delegations
and governance, accounting for these in their respective risk management
frameworks.
Activities that enable great outcomes and behaviours are set out in the checklist
below.
Activity 1
Implement a proportionate process for updating the department on the ALB’s
tisk assessments and risk management strategies.
Activity 2
Regularly and openly discuss the department's risk appetite with the ALB.
Activity 3
Implement an effective risk escalation structure. Escalation from the ALB’s Audit
and Risk Assurance Committee to the ALB’s board and then to the
department’s Audit and Risk Assurance Committee or other appropriate
committee is likely to be appropriate.
Activity 4
It may be appropriate for the ALB to invite departmental representatives to
attend the ALB’s Audit and Risk Assurance Committee or other risk
management structures as observers from time to time.
Activity 5
The ALB should avoid escalating an excessive number of risks to the
department. Doing so could undermine the clear lines of accountability that
exist between the Department and the ALB, within which it is the responsibility
of the ALB to manage its own risks. Likewise, the Department should avoid
intervening excessively in the ALB’s risk management structures.
Support
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To support effective delivery, sponsor teams should draw on relevant training,
alongside the guidance referenced in this Code. In particular, sponsors may
benefit from undertaking the following Civil Service Learning training:
1. Risk management - Identify and understand the types of risks you may
encounter, how they may be addressed and how managing them effectively
can lead to organisational improvement. {22t"2!¢ 441
2. Managing risks, issues and dependencies - Learn about what risk is (its
cause, effect and impact) as well as effective ways to manage it.feo!ole 45}
Sponsor teams should draw on expert support within their departments,
including from their Corporate Governance or Financial Governance Teams or
equivalent.
Sponsor teams should also draw on relevant functional expertise. The finance
functional standard is relevant to risk management and assurance. (22t2l2 461
Governance and accountability
As with central departments, Parliament expects ALBs to operate to the highest
of standards of professionalism and probity. Ministers are responsible for the
performance of their ALBs and PAOs for ALBs’ stewardship of public funds.
Ministers and PAOs should be provided with appropriate assurance in relation
to those points, including through the provision of appropriate scrutiny.
Outcomes
Departments should strive to:
1. Assure their PAOs that ALBs within the departmental family - operate
effectively and to a high standard of probity, meeting the requirements set out
in Managing Public Money.
Case Study 10: The Department for Work and Pensions flexible
approach to partnership working
The Department for Work and Pensions (DWP) sponsors three regulators,
money guidance and pensions bodies and advisory committees for which
sponsor arrangements are centralised.
Small Grade 7 led partnership teams support each of the department’s
public bodies, supporting the Head of the Division as senior sponsor. A
centralised Public Appointments Team within the Division is responsible for
administering the public appointments process on behalf of Ministers and
provides recruitment expertise. This structure creates a centre of expertise
with partners and the public appointments team supporting and learning
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from each other. Each partnership team has a relationship with the policy
leads for their public bodies which span DWP, HMT, BEIS, DEFRA, DLUHC
and MoD so it is essential that senior sponsors and partner teams build
effective working relationships across the whole system. As well as day to
day engagement, policy leads join the formal quarterly accountability review
meetings with each body. These meetings provide an opportunity for
strategic discussion on delivery against strategic objectives and business
plans, risk and Financial Oversight.
There are also relationships with the functional leads within the Department,
for example Finance, Commercial, People and Capability, Communications,
Security, Parliamentary, Digital, Legal, Analysis mapping onto the functional
standards. A Central Assurance Team deals with issues that apply across
all of DWP’s bodies, and also acts as the central focus point for
engagement with Cabinet Office.
This approach to prioritising a relationship that consistently delivers high
quality support creates a more flexible approach to partnership working,
tailored to suit the needs of each individual body, while ensuring
consistency across DWP’s bodies, assuring the Principal Accounting Officer
(PAO) that ALBs within the departmental family are operating effectively and
to a high standard of probity.
Behaviours
The following behaviours underpin the outcomes:
1. The department prioritised a relationship that consistently delivered high
quality support. The senior sponsor was supported by a sponsorship team or
equivalent with appropriate capability and capacity.
2. Aculture of active assurance is central to activity. The ALB supported early
conversations about governance and accountability activities.
3. Both parties were respectful of the assurance required by the PAO and AO.
Activities that enable great outcomes and behaviours are set out in the checklist
below.
Departments should note that the governance requirements for Executive
Agencies and for Non-Departmental Public Bodies vary. For example, some
Executive Agencies are not required to lay an Annual Report and Accounts
(ARA) before Parliament each year.
Activity 1
Ensure that the ALB challenges [or requires] the ALB to have:
1. Amanagement board or equivalent that meets at least four times annually
and that includes appropriate non-executive representation.
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2. A Terms of Reference for each board sub-committee, which should be
reviewed annually.
3. A Schedule of Delegation setting out the delegated responsibilities of each
sub-committee.
4. A published Annual Report and Accounts, if required, that is laid before
Parliament annually.
5. Aschedule of meetings and an attendance register for the board and each of
its sub-committees that is published in the governance statement of the
ALB’s Annual Report and Accounts, which should be laid before Parliament
annually.
6. Completed an annual board Effectiveness Review and, at least triennially, an
externally-led board effectiveness review. {22's 47)
7. Completed annual appraisals of non-executive members led by the Chair and
that the senior sponsor or an appropriately senior departmental official has
completed an annual appraisal of the Chair.
8. A Diversity Action Plan
9. Aboard Operating Framework or Terms of Reference, or equivalent in place,
which should be reviewed annually.
10. Aboard Operating Code in place, which should be published and reviewed
biennially.
11. Aclear conflicts of interest policy and a register of interest that captures the
interests of all board members. These documents should be published and
reviewed regularly.
12. Awhistleblowing policy in place that is consistent with the Public Interest
Disclosure Act 1998.
13. Integrated the management of functional work into its overall management
arrangements, to meet functional standards.
14. Abusiness continuity plan within the annual business plan.
Activity 2
Support early conversations between the Chair, your department's
appointments team and your ministers about succession planning for board
appointments, and the planning/running of individual appointment campaigns.
Activity 3
The department and ALB should provide mutual support in undertaking
Parliamentary and public engagement, including in responding to requests
made under the Freedom of Information Act, Parliamentary Questions, and
Ministerial Correspondence.
Support
To support them in delivering effectively, sponsor teams should draw on
relevant training, in addition to the guidance referenced throughout this Code.
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In particular, sponsors may benefit from undertaking the following training:
1. Governance, assurance and audit - Explores the issues involved in
governance, assurance and audit and how these interrelated subjects should
be handled to manage and mitigate risk both across government and in
ALBs. 2etsete 48)
2. Essential corporate governance - Looks in detail at the role of boards in
delivering good governance, the regulatory landscape and key
responsibilities for directors. 22!nete 491
Sponsor teams should draw on expert support within their departments,
including from their Corporate Governance Team'22!2!2.59! or equivalent.
How to deliver good practice in ALB
sponsorship
Leadership of the department’s sponsorship of its ALBs
PAOs should appoint a senior sponsor to oversee the department's relationship
with each of its ALBs. The PAO should consider how many ALBs it would be
appropriate for a single senior sponsor to oversee. This assessment should be
based on the budget, risk profile, or political significance of the ALB and on the
senior sponsor’s other responsibilities. The senior sponsor is responsible for
ensuring that activities across the six capabilities are met in respect of the ALBs
for which they are senior sponsor.
The overriding requirement is that the senior sponsor is able to dedicate the
necessary time to executing their responsibilities fully.
Senior sponsors may be supported in delivering this responsibility by a
sponsorship team, secretariat, or equivalent, in addition to the department's
functions e.g. its finance, HR and commercial teams. This section sets out how
departments may structure themselves to provide this support.
Sponsorship functions and models
Functions
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The government has a number of distinct sponsorship functions for its ALBs.
For ALBs of any complexity and/or scale there should be an articulation of the
relevant sponsorship functions. Each sponsor's role and responsibilities should
be set out in the framework document.
Asponsorship function should have sufficient and dedicated resource, and
effectively represent the government's interests relating to their role. It must
work closely with other functions to ensure a unified departmental approach.
Sponsorship functions may be divided into two broad areas: policy and
corporate sponsorship, (also characterised as the shareholder function for
certain ALBs).
1. Policy sponsor: this function relates to what ALBs deliver on behalf of the
government. It is responsible for agreeing ALB purpose and strategy, setting
policy outcomes aligned to ministerial and government priorities and assuring
delivery of those outcomes.
2. Corporate sponsor (also known as ‘shareholder’ for certain ALBs): this
function relates to how ALBs perform and deliver, including risk and financial
oversight, governance, and accountability. UK Government Investments
(UKGI) is the government's centre of excellence in corporate governance in
government, and performs the shareholder function for a number of complex
ALBs. As per MPM, departments should consider whether UKGI is best
placed to deliver this function for their ALBs or, if not, seek the advice and
use the expertise of UKGI during the life of such arm's length bodies.
Project sponsor (also known as client or customer) relates to what and how
ALBs deliver projects and programmes. It represents the department's interests
as the recipient of the ALB’s services or function. It specifies and holds the ALB
to account for delivery of the project. The Infrastructure and Projects Authority
(IPA) is the government's centre of expertise for sponsorship of major projects
and programmes.
Clarity of roles between policy and corporate sponsorship is important to
achieve success for ALBs of complexity or scale. Where this is not beneficial to
the performance and management of the ALB, departments should retain the
flexibility to deploy different operating models depending on their ALB and
departmental construct.
Models
No two departments structure their sponsorship teams in precisely the same
way, however, department approaches may be grouped into three broad
models based on how responsibility for delivering each function is apportioned.
They are as follows:
1. Centralised model: Where the policy and corporate sponsorship functions are
delivered by separate teams in separate business units.
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2. Hybrid model: Where policy and corporate sponsorship are delivered
separately but within the same business unit.
3. Decentralised sponsorship model: Where the same team discharges both the
policy and corporate sponsorship functions.
The model of the departmental sponsorship of the ALB should align with both
the objectives of the ALB and enable the department to provide support and
oversight. For example designing the ‘how’ of support around the ‘why’ of the
ALB. fegtnete 51)
Across each model functional experts either deliver on behalf of or support the
delivery of corporate sponsorship functions. Sponsorship should never seek to
be delivered in a vacuum - it requires engagement at appropriate levels to the
relationship across the department.
Co-sponsoring
Co-Sponsoring is an extraordinary process and is the act in which two (or more)
departments may wish to sponsor one ALB.
Where co-sponsorship is considered, clear lines of accountability should be
defined with a single department sponsoring each ALB. Memorandums of
Understanding (MoU) governing the relationships between the ALB and other
departments or ALBs should be in place.
The co-sponsorship relationship can support the delivery of departmental
objectives. (Including sharing learning with partners across the whole of the UK,
including devolved administrations, to deliver better outcomes for citizens).
Capability of the sponsor team
The nature of sponsorship of ALBs varies widely. Tables 1, 2, and 3 summarise
the support available to help new, experienced and senior sponsors,
respectively, to learn and develop in their roles.
The department should facilitate the exchange of knowledge and expertise
between departments, the department and the ALB, and between ALBs. It may
be appropriate to do so by facilitating staff loans, convening forums and
networks where best practice can be discussed and relevant information
disseminated, as well as undertaking/supporting ALB reviews and the
implementation of review recommendations.
Bibliography
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¢ Code of Conduct for Board Members of Public Bodies, 2019.
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Glossary of terms
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Accounting Officer
[See Principle Accounting Officer] This role is delegated to other Senior Civil
Servants as required.
Accounting Officer System Statement
This is a governance statement outlining their internal control system written by
the Chief Executive or Accounting Officer. It describes accountability for all
expenditure of public money, as well as management of shareholdings, assets
and investments under their responsibility.
Assurance
The process by which the Cabinet Office will provide ministers and the Civil
Service Board with evidence of consistency in sponsorship across government,
and proof that the trend is one of improvement.
Centralised Model
The departmental approach to sponsoring their arm’s length bodies through two
distinct teams to deliver policy and corporate affairs separately.
Chair’s letter
An annual directive written by the responsible minister or delegated PAO which
communicates priorities, expectations for the ALB and suitable metrics by which
this will be measured.
Co-sponsorship
The rare occurrence wherein two departments simultaneously sponsor a single
ALB with an overlapping remit to deliver better outcomes for citizens.
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Comply or Explain
This principle will underpin the Code assurance mechanism, allowing
departments to specify their own circumstances in relation to sponsorship.
Corporate Sponsor
1. Also known as ‘shareholder’ for certain ALBs: this function relates to how
ALBs deliver, including risk and financial oversight, governance, and
accountability. UK Government Investments (UKGI) is the government's
centre of excellence in shareholding and broader corporate governance as
per MPM.
Decentralised Model
Under this model, the same departmental team is responsible for both policy
and corporate functions.
Declaration of Government Reform (Action 24)
This wide-ranging document outlines how the government and Civil Service
reform government to deliver better for citizens. Action 24 specifically targets
sponsorship transformation.
Framework Document
Managing Public Money states that departments should set out a framework
document from their Accounting Officer to draw clear lines of accountability,
monitor and understand the specific circumstances surrounding their ALB.
Templates are available for each ALB classification.
Functional Standards
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A suite of management standards and associated documentation to guide
people working in and with the UK government.
Hybrid Model
Employed by some departments where both policy and corporate sponsorship
functions are delivered separately but within the same business unit.
Key Performance Indicators
Key performance indicators (KPIs) refer to a set of quantifiable measurements
used to gauge overall long-term performance. KPIs specifically help determine
strategic, financial, and operational achievements.
Management Information
The collection, storage, curation, dissemination, archiving and destruction of
documents, images, drawings and other sources of information.
Managing Public Money
The Treasury publication setting out guidance on how to handle public funds.
This Code is subordinate to MPM.
Memorandum of Understanding
A memorandum of understanding, or MOU, is a nonbinding agreement that
states each party’s intentions to take action, conduct a business transaction, or
form a new partnership. This type of agreement may also be referred to as a
letter of intent (LOI) or memorandum of agreement (MOA).
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Non-Executive Director
Anon-executive director is a member of a company’s board of directors who is
not part of the executive team. A non-executive director typically does not
engage in the day-to-day management of the organisation but is involved in
policy making and planning exercises.
Outcome Delivery Plan
Outcome Delivery Plans sets out how respective departments are working
towards the delivery of its priority outcomes. Outcome Delivery Plans place a
greater emphasis on joint working between departments, enabling departments
to plan together to deliver shared outcomes.
Policy Sponsor
This function relates to what ALBs deliver on behalf of the government. It is
responsible for agreeing ALB purpose and strategy, setting policy outcomes
aligned to ministerial and government priorities and assuring delivery of those
outcomes.
Principal Accounting Officer
The most senior official in each department - the Permanent Secretary, is
personally accountable to Parliament for the use of public money. They can be
asked to appear before the Public Accounts Committee to face scrutiny on
value for money.
Project Sponsor
Also referred to as the client/customer, the project sponsor represents
departmental interests as the recipient of the ALB’s services or function. It
specifies and holds the ALB to account for delivery of the project.
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Service Standards
Aservice standard specifies requirements that should be fulfilled by a service to
ensure it is fit for purpose. Typically it includes definitions or quantifiable levels
of acceptable delivery.
SMART Outputs
Methods of quantifying progress that are Specific, Measurable, Achievable,
Relevant and Time bound.
Terms of Reference
Also known as TORs, these define the purpose and scope for a project or task.
They usually also include a copy list of relevant stakeholders, setting out
regularity of meetings and procedures.
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accountable directly to Parliament and not via government ministers.
. The only exception to this is Non-ministerial Departments, where HM
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