This meeting of the Royal Borough of Greenwich's Audit and Risk Management Panel included discussion about the Royal Borough of Greenwich’s Strategic Risk Register, and a performance report from the Internal Audit and Anti-Fraud team. The meeting also included discussion of the draft Annual Governance Statement 2023/24.

The Royal Borough of Greenwich's Strategic Risk Register

The Strategic Risk Register is a document that contains a list of the risks that the Greenwich Management Team has identified to the delivery of the Royal Borough of Greenwich's corporate plans and strategies. For each risk in the register, it includes a summary of the controls and mitigating actions that are in place to manage the risk.

The strategic risks that were scheduled to be discussed at the meeting included:

• The Medium Term Financial Strategy – in which the Royal Borough of Greenwich could be unable to balance its budget and would be required to issue a S114 notice¹. This was assessed as being a risk that had a ‘significant’ impact and a ‘likely’ likelihood, giving it an overall rating of 20/25.

• The demand for School Places – in particular the demand for specialist SEN school places, including residential places. This was assessed as being a risk that had a ‘significant’ impact and a ‘possible’ likelihood, giving it an overall rating of 16/25.

• Cyber Security & Data Breaches – in which the Council could suffer an attack that affects the security or availability of its network or associated systems. This was assessed as being a risk that had a ‘significant’ impact and a ‘possible’ likelihood, giving it an overall rating of 15/25.

• Achieving Carbon Neutral by 2030 – in which the Council could fail to achieve Carbon Neutrality by 2030. This was assessed as being a risk that had a ‘significant’ impact and a ‘moderate’ likelihood, giving it an overall rating of 15/25.

• Business Continuity, Emergency Planning – in which the Royal Borough of Greenwich’s business continuity plans could be unsuitable for allowing the local authority to provide support to emergency services in the response phase, lead on the recovery phase, maintain critical services, and protect vehicles and equipment from loss, for example through flooding. This was assessed as being a risk that had a ‘significant’ impact and a ‘minor’ likelihood, giving it an overall rating of 15/25.

• Health & Safety, Compliance and Wellbeing Procedures – in which a serious incident could occur as a result of non-compliance with Health and Safety standards. This was assessed as being a risk that had a ‘moderate’ impact and a ‘likely’ likelihood, giving it an overall rating of 15/25.

• Key Strategic Partnerships and Supply Chain Security – in which the failure of key services or construction projects could occur because of the failure of key strategic partners or suppliers. This was assessed as being a risk that had a ‘moderate’ impact and a ‘likely’ likelihood, giving it an overall rating of 15/25.

• Loss of Life and/or Injury Through Lack of Corporate Estate Building Safety – in which a lack of, or poor building maintenance of the corporate estate could result in loss of life or injury to occupiers, residents, visitors, employees or contractors. This was assessed as being a risk that had a ‘moderate’ impact and a ‘possible’ likelihood, giving it an overall rating of 12/25.

• Loss of Life and injury through lack of residential building safety – in which poor residential building maintenance could result in loss of life or injury to residents, visitors, employees or contractors. This was assessed as being a risk that had a ‘moderate’ impact and a ‘possible’ likelihood, giving it an overall rating of 12/25.

• Serious Injury or Death of a Vulnerable Adult – in which an adult known to Royal Borough of Greenwich’s services could die or suffer serious injury. This was assessed as being a risk that had a ‘moderate’ impact and a ‘possible’ likelihood, giving it an overall rating of 12/25.

• Compliance with New Procurement Legislation – in which the Royal Borough of Greenwich could suffer challenges from unsuccessful bidders, government audit and challenge, or litigation by unsuccessful bidders, because of its compliance with new procurement legislation. This was assessed as being a risk that had a ‘minor’ impact and a ‘high’ likelihood, giving it an overall rating of 15/25.

• Government Welfare Legislation – impact on service delivery – in which changes in government welfare legislation could drive up demand for directorate services. This was assessed as being a risk that had a ‘minor’ impact and a ‘high’ likelihood, giving it an overall rating of 16/25.

• Preventable Incident to the Wellbeing of a Child – in which a child or adult known to Royal Borough of Greenwich’s services could die or suffer serious injury. This was assessed as being a risk that had a ‘moderate’ impact and a ‘likely’ likelihood, giving it an overall rating of 9/25.

• Capacity-Workforce Planning – in which ineffective systems and processes for managing the Council’s workforce could impact its ability to deliver services. This was assessed as being a risk that had a ‘minor’ impact and a ‘likely’ likelihood, giving it an overall rating of 8/25.

• Government Welfare Legislation – impact on income collection – in which changes in government welfare legislation could drive up demand for directorate services, potentially affecting the Royal Borough’s income collection. This was assessed as being a risk that had a ‘minor’ impact and a ‘moderate’ likelihood, giving it an overall rating of 9/25.

Internal Audit and Anti-Fraud Performance

The Internal Audit and Anti-Fraud team provided a report that outlined the work that had been undertaken by the team between April and June 2024.

During that time, Internal Audit had been notified of 26 allegations of housing benefit fraud, and 4 allegations of tenancy and housing-related fraud. Internal Audit investigations and proactive activity relating to these allegations resulted in the recovery of 3 council tenancies during the quarter. One prosecution relating to a recovered tenancy is outstanding.

Internal Audit also received 15 allegations of blue badge misuse. During the quarter one case was successfully prosecuted, and a warning letter was issued. At the end of June 2024, there were 21 blue badge misuse cases referred to legal services with a view to prosecution.

Internal Audit also raised investigations into 28 allegations of corporate fraud, one of which involved an allegation against a Royal Borough employee.

Annual Governance Statement 2023/24

The draft Annual Governance Statement 2023/24 was scheduled to be discussed.

The Annual Governance Statement is a document that is prepared by local authorities each year to report publicly on the extent to which they comply with their own code of governance.

The draft statement identifies two areas for improvement:

• No Recourse to Public Funds (NRPF)² – in which the influx of EU nationals who do not meet the threshold for receiving benefits and who are unable to work (for reasons such as being elderly or having young children), together with refugees from recent war-torn areas and unforeseen conflict zones, are placing a strain on the Council's resources for supporting them. The statement noted that NRPF work would benefit from:

“increased funding of an immigration advisor at the Lewisham Refugee and Migrant Centre to support long supported clients who are unable to regularise their status due to inability to access legal aid.”

It also noted that:

“Discussions are taking place with Housing in relation to procurement and management of appropriate housing for NRPF cases, as identified in the recent Internal Audit of NRPFT”

and that:

“Procurement of a generic Resettlement Support provider will enable faster response of new migrant groups identified for Resettlement – currently there are separate contractual arrangements for Syrian, Afghan and Ukrainian resettlement, funded through Resettlement grants.”

• The Medium Term Financial Strategy – in which the Council’s revised strategy, approved in February 2023, identified the need to reduce the Council’s budget gap of £21.5 million by 2026/27, which represents a 32.5 million shortfall. The statement noted:

“The Council continues to have uncertainty about its future funding position and therefore the resources available to deliver services.”

The statement also identified several additional matters that have been identified for focus in 2024/25:

• The Medium Term Financial Strategy – the Statement noted:

“The MTFS³, which is one of the largest risks in the Council’s Strategic Risk Register, has further significant budget gaps in the medium term.” “The use of the risk reserves held by the Council to underwrite significant risks aligns to the message contained within the Government’s “Local Government Finance Policy Statement 2023/24 to 2024/25” released in December 2022 and updated in December 2023 for which the Government stated “we encourage local authorities to consider how they can use their reserves to maintain services in the face pressures, taking account, of course, of the need to maintain appropriate levels of reserves to support councils’ financial sustainability and future investment”.”

“2023/24 will utilise a proportion of the councils risk reserves, as reported to Cabinet in the revenue monitor. This report plans to replenish much of the sum utilised this year, from the Council Tax surplus.”

• No Recourse to Public Funds (NRPF) – the statement noted:

“The Council has a stable, fully staffed NRPF team with all work overseen by the GRAM which monitors global events that may have an impact on demand. Whilst the Council ensures full participation in all government schemes relating to specific groups affected, the following additional actions will be undertaken in 2024/24:

• A revision of the strategy for Borough of Sanctuary • Continued monitoring of global events • Participation in all relevant LA Network groups to plan responses to changes in demand.”