Risk Management Policy (MPF1194)
- Category: Governance and Management
- Review due by: December 3, 2021
- Version: 8
- Policy Steward: Executive Director, Legal & Risk and General Counsel
- Approved on: July 5, 2022
- Supporting Processes: Governance and Management Processes
- Effective date: July 8, 2022
- Policy Approver: Council
- Status: Published
11. Objectives
The objectives of this policy are to:
(a) outline the University’s approach to risk management;
(b) align the University with best practice AS/NZS ISO 31000:2009 Risk management – Principles and guidelines;
(c) establish the roles and responsibilities of staff in risk management; and
(d) affirm the University’s commitment to developing a compliance management framework in line with AS ISO 19600:2015 Compliance management systems – Guidelines, incorporating a risk based approach to compliance that:
i. facilitates compliance with legislation and regulation (University’s Regulatory Framework);
ii. continuously improves attention to compliance obligations within the Regulatory Framework; and
iii. stimulates the identification, reporting and rectification of non-compliance.
22. Scope
This policy applies to all staff and honorary appointees of the University, and to people authorised to undertake University business.
33. Authority
This policy is made under the University of Melbourne Act 2009 (Vic) and Council Regulation, and supports management of risk according to applicable legislative and regulatory standards and codes to which the University is subject.
44. Policy
4.1. Council, through Council’s Audit and Risk Committee (ARC), is responsible for overseeing and monitoring the assessment and management of risk and compliance.
4.2. Risk is managed in accordance with the University’s Risk Management Framework developed by Legal and Risk. The Risk Management Framework is approved by the ARC on behalf of Council and informed by the advice from the Risk Management Advisory Group.
4.3. The management of risk aligns with the University’s risk appetite, as approved by Council.
4.4. The Vice-President (Strategy & Culture) oversees the development of the risk appetite statement and advises the University Executive Committee on risk as it relates to strategy and objective setting.
4.5. The Vice-President (Administration & Finance) and Chief Operating Officer oversees the University wide implementation of the:
(a) Risk Management Framework that is consistent with AS/NZS ISO 31000:2018 Risk management – Principles and guidelines;
(b) Compliance Management Framework that is consistent with AS ISO 19600:2015 Compliance management systems – Guidelines and supports the University’s Regulatory Framework;
(c) Critical Incident Management that is consistent with Australian Inter-service Incident Management System;
(d) Business Continuity Program that is consistent with ISO 22301:2012 Societal security – Business continuity management systems – Requirements.
4.6. Risk management and compliance obligations are formally integrated into planning processes and management activities, and incorporated into ongoing ‘business as usual’ practices by those with management responsibilities.
4.7. The head of division is responsible for ensuring compliance breaches are monitored and reported.
4.8. In the event of a critical incident, the University's response will prioritise:
(a) human life, safety and wellbeing;
(b) animal life, safety and wellbeing;
(c) environmental protection; and
(d) the protection of property interests,
taking into account the nature of the incident and all relevant circumstances.
55. Procedural principles
5.1. Legal and Risk maintains the:
(a) University Risk Register; and
(b) University Compliance Obligations Register.
5.2. Legal and Risk:
(a) provides risk management advice and training;
(b) provides compliance training; and
(c) documents process in support of risk management.
5.3. Legal and Risk is responsible for internal audits, taking into account any recommendations made by RMAG in relation to the conduct of risk-related audits.
5.4. The Vice-President (Administration & Finance) and Chief Operating Officer is responsible for:
(a) developing and implementing a University-wide critical incident management program;
(b) developing processes to align with the Australian Inter-service Incident Management System; and
(c) coordinating the University's response to any critical incident that may occur, in accordance with the critical incident management program described in section 5.4(a) and all relevant University policies and processes.
5.5. Risks are identified and managed to ensure that:
(a) activities on behalf of the University are performed in an informed manner; and
(b) areas of risk or potential risk undertaken in day-to-day activities are the responsibility of all staff, including persons authorised to undertake University business and/or activities (eg service providers and contractors).
5.6. All staff and people authorised to undertake University business and/or activities (eg service providers and contractors) have a responsibility to comply with legislative and regulatory compliance obligations, specifically to ensure that:
(a) activities on behalf of the University comply with applicable laws and related University policies, and are performed in an ethical, lawful and safe manner; and
(b) they are aware of areas of legislation/regulation that affect their day-to-day work.
5.7. A breach of the University’s compliance obligations may result in disciplinary and/or legal action.
66. Roles and responsibilities
| Role/Decision/Action | Responsibility | Conditions and limitations |
| Oversee and monitor the assessment and management of risk and compliance | Council | Through Council’s Audit and Risk Committee |
| Oversee development of the University’s Risk Register | Vice-President (Administration & Finance) and Chief Operating Officer | In collaboration with Strategy, Planning and Performance. Taking into account any recommendations by RMAG. To be approved by Council through the Council’s Audit and Risk Committee. |
| Oversee development of the risk appetite statement | Vice-President (Strategy & Culture) | In collaboration with Legal and Risk Taking into account any recommendations by RMAG To be approved by Council through the Council’s Audit and Risk Committee |
| Develop the University's Risk Management Framework | Legal and Risk | In collaboration with Strategy, Planning and Performance Taking into account any recommendations by RMAG To be approved by Council through the Council’s Audit and Risk Committee |
| Develop the University's risk management process for assessing, evaluating and treating risk | Legal and Risk | To be approved by the Vice-President (Administration & Finance) and Chief Operating Officer |
| Incorporate risk management, including compliance obligations and business continuity management, into business practices | Management | |
| Provide risk advice to the University Executive Committee | Vice-President (Strategy & Culture) Vice-President (Administration & Finance) and Chief Operating Officer | Taking into account any recommendations by RMAG |
| Maintain University Risk Register | Legal and Risk | |
| Support the development of any divisional, project / operational risk registers | Legal and Risk | |
| Maintain and administer Enterprise Risk Management System (ERMS) | Legal and Risk | |
| Provide advice, training and documentation of process to support management of risk | Legal and Risk | |
| Conduct internal audits to support the management of risk and compliance obligations | Legal and Risk | Taking into account recommendations from RMAG and ARC in relation to risk-related audits |
| Develop and implement a University-wide critical incident management program | Health and Safety | Program to be reviewed and approved annually by the Vice-President (Administration & Finance) and Chief Operating Officer, informed by advice from RMAG |
| Coordinate the University's response to any critical incident that may occur | Incident Coordinator | Supported by the University’s Incident Management Team |
| Develop and implement the Business Continuity Program | Legal and Risk | Program to be approved by the Vice-President (Administration & Finance) and Chief Operating Officer, informed by advice from RMAG |
| Identify and manage risk - perform day to day activities in an informed manner adhering to relevant compliance obligations | All staff including persons authorised to undertake University business and/or activities (e.g. service providers and contractors) | Identification of risk and non-compliance to be raised/reported to the next most senior person for assessment |
| Administer this policy, including informing and assisting staff on compliance issues and consider complaints of compliance breaches | Risk and Compliance Manager, Legal and Risk | |
| Maintain University-wide Compliance Obligations Register | Legal and Risk | |
| Develop and implement Compliance Management Framework | Legal and Risk | |
| Compliance with relevant compliance obligations | All staff, students, contractors and service providers | |
| Identify and mitigate compliance risks | Obligation owner | |
| Deliver specific compliance training | Legal and Risk | As identified by the compliance owner in conjunction with Legal and Risk |
| Manage and report non-compliance | Obligation owner | Reporting of non-compliance to Legal and Risk and / or Regulators as required |
77. Definitions
Business continuity management means a management process that identifies potential threats to an organisation and the impacts to business operations; and provides a systematic approach for building organisational resilience.
Compliance means meeting all of the University’s compliance obligations.
Compliance obligations has the same meaning as in the Compliance Management Framework.
Compliance obligations register means a comprehensive list of the compliance obligations of all University functions and activities.
Critical incident means an event that may adversely affect the university and requires an immediate response. It is likely to cause significant personal illness or injury, substantial impact to operations and commercial prospects, a degradation of reputation, or lead to an impact on the wider community.
Risk means the effect of uncertainty on objectives.
Risk management means the coordinated activities of identifying, assessing and controlling threats or risks to the University and its activities.
Risk register means the comprehensive list that describes the type of risk and related characteristics, including risk owners; inherent and residual risk ratings; controls in place and control effectiveness; and treatment plans.
University Risk Register means a detailed record of risks that could impact the ability of the University to achieve its strategy/long term ambitions. These risks in the register require oversight at the institutional level.
8POLICY APPROVER
Council
9POLICY STEWARD
Executive Director, Legal & Risk and General Counsel
10REVIEW
This policy will be reviewed by 3 December 2021.
11VERSION HISTORY
| Version | Approved By | Approval Date | Effective Date | Sections Modified |
| 1 | Council | 8 July 2013 | 8 July 2013 | N/A |
| 2 | Governance and Nominations Committee authorised by Council | 23 June 2016 | 21 July 2016 | New version arising from the Policy Consolidation Project, incorporating the Risk Management Policy (MPF1194), Risk Management Procedure (MPF1097) and Compliance Policy (MPF1100). |
| 3 | Council | 24 August 2017 | 28 August 2017 | Roles and responsibilities updated to improve clarity. |
| 4 | University Secretary | 24 May 2019 | 31 May 2019 | Amended titles in Sections 4 and 6. |
| 5 | Vice-Chancellor on behalf of Council under Section 5(5) Vice-Chancellor Regulation | 31 July 2019 | 1 August 2019 | Amended titles in Section 5 and 6. |
| 6 | Council | 3 December 2019 | 12 December 2019 | Roles and responsibilities updated. Clarification of approach to compliance, critical incident and business continuity management. |
| 7 | Policy Officer | 5 October 2020 | 5 October 2020 | Corrected all references to 'University Executive' to 'University Executive Committee'. |
| 8 | Executive Director, Legal & Risk and General Counsel | 5 July 2022 | 8 July 2022 | 5.6. changed from 'including people' to 'and people'. |