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Nick Ralphs – NJR Procurement
Third Party Risk Management In A Start Up
£270m spend p.a. approx 1000 contracts
300 branches and 5000 staff
£20bn loans
William
s and Glyn
Context
£1.8bn spend. 2000 contracts
Influence over £1bn cash
20m policies
Direct Line G
roup
Large Start Ups
What Are The Risks ?
Non - Compliance to external legislation and regulation plus W&G internal policy framework
Inappropriate Supplier Selection
Poor In Contract Performance
Fraud
Keeping it simple
End to End Purchasing and Contract Management Approach
Data Gather & Analyse
Iden@fy Opportuni@es
Define Selec@on Approach
Conduct Supplier Selec@on
Finalise Supplier Selec@on
Governance Implementa@on Supplier & Contract
Management Iden@fy & Tier Requirements
Supplier Deployment
Category Strategy
Mandatory Ac0vity
Core RFP using Esourcing pla;orm
Mandatory Documents
Sourcing Plan
Mandatory Documents
Supplier Selec@on / Due Diligence Output
Mandatory Documents
1. Contract Checklist Form 2. BCAP 3. Contract
Mandatory Document **
Tier Services
Category Strategy
** = only when applicable
Carry out 1st LOD Assurance Ac0vity
Mandatory Documents
Contract Control Sheet
Governance Select Supply Base Define Sourcing Plan Define Business Need
Mandatory Ac0vity
**
Mandatory Ac0vity
Tiering
5
• The supply of an outsource services of such importance that weakness, or failure, of the services would cast serious doubt upon the firm’s con@nuing sa@sfac@on of the FCA threshold condi@ons or compliance with the FCA Principles
Material Outsource
• The failure or poor performance of the supplier would have a direct and immediate impact on the customer experience and the impact would be significant or major as defined within W&G Impact Assessment Criteria; or • The supplier will be represen@ng W&G directly with our customers
Customer Cri@cal
• The supplier handles/hosts secret/classified W&G informa@on; or • The supplier will be handling confiden@al customer or any other personal data; or • The supplier has staff accessing W&G systems or staff with unaccompanied access to W&G sites
Informa@on Security
• The suppliers opera@ons based outside the UK or Europe Offshore
Tiering will influence legal agreement, sourcing requirements and on-going contract management
Where Purchasing are engaged the Strategic Purchasing Approach (SPA) is followed. The SPA follows a risk based approach and sets out minimum standards to be employed on the activities below :
Purchasing Approach - Controls
Sourcing Plan
Due Diligence
Selec0on Outcomes
Financial Governance
Contract / Contract Checklist
Contract Management Activities - Overview
• Understand the contract
• Contract Management
Control Document
• Risks and Issues
• Due diligence, * Policy compliance * Contract change
control
• Performance reviews
• Purchase To Pay
• Con@ngency plans, * Exit plans
• Supplier BC plans in place
Contract Start Contract End Contract Performance
8
Policy Assurance
Adequacy
Process Review
Control Environment Assessments
Excep@ons To Policy
Issues
Effec@veness Results
Best Prac@ce
Biannual Cross Business Forums
Effec@veness
FLOD Reviews
Mandatory and Non Mandatory Ac@vi@es
Contract Control Documents
Key Lessons
Resource for Design and Implementation
Judgement Requires Strong Performers
Simplicity And Clarity Drive Compliance
Specialist Contract Managers
Collaboration, Testing and Testing