Risk Management Policy

This risk management policy is designed to help RCG comply with the conditions for recognition set out by Ofqual (the Office of Qualifications and Examinations Regulation) in the UK. The policy sets out the procedures for identifying, assessing, and managing risks associated with RCG's operations. RCG is responsible for ensuring that the qualifications and assessments it offers and conducts are fair, valid, reliable, and secure, and that the results accurately reflect the achievements of the learners and apprentices.

This policy seeks to mitigate any potential adverse effect and reflect RCG’s management of risks. 

Risk Definition

A Risk is a combination of the probability of an event and its consequence. Risk management includes identifying the risk, preventing incidents, mitigating or eliminating their effect and contingency planning where the possibility of an Adverse Effect occurring has been identified. 

Adverse Effect

An ‘Adverse Effect’ is defined as: An act, omission, event, incident or circumstance has an ‘adverse effect’ if it gives rise to prejudice to learners, apprentices or potential apprentices, or adversely effects the development, delivery or award of Qualifications which relate, but are not limited to: 

• Published apprenticeship standards. 

• Public confidence in the Qualification. 

• The delivery of an assessment that threatens Assessors’ ability to differentiate accurately and consistently between the levels of attainment demonstrated by learners and apprentices. 

• Being able to meet a published date for the issue of results. 

• Issuing incorrect results or certificates. 

• An incident of malpractice or maladministration that could invalidate the award of a qualification. 

• Increase in costs that result in stopping a learner or an apprentice completing and obtaining certification. 

• A criminal or civil proceeding or is subjected to a regulatory investigation or sanction by any regulatory or government body. 

• Misleading apprentices through statements, advertisements or promotions resulting in learners and  apprentices being disadvantaged and not achieving a recognised qualification. 

• Apprentices made redundant before assessment is complete. 

• Lead training provider ceases trading. 

• Confidentiality of assessments. 

Role and responsibilities

The Governing Body

• Oversees risk management within RCG.  

• Defines the strategic risks and the risk appetite as the Business Objectives are formulated.  

• Develops and implements policies on risk management for internal and external control.  

• Identifies and evaluates the strategic risks faced by RCG when considering the annual Business Plan.  

• Provides adequate information in a timely manner to the Governance Committee on the status of risks and controls.  

• Identifies and monitors risks monthly and leads the mid and end year reviews of progress against plan.  

• Undertakes an annual review of effectiveness of the system of internal control which forms part of self-evaluation and provides a report to the Governance Committee.  

The Governance Committee

• Provide an independent opinion to the Governing Body on the adequacy of risk management.  

• Commenting on proposals for implementation of risk management and expressing an opinion on their overall adequacy.  

• Reporting annually on the effectiveness of risk management activity in the organisation on the basis of audit/self-evaluation reports received and the internal audit annual report.  

Managers

• Ensuring that risk management processes within their area are effective and that their staff/contractors are aware of the risks within their working environment.  

• Ensuring that all necessary risk assessments are carried out within their area.  

• Implementing and monitoring any identified risk within their area of responsibility.  

• Identifying, assessing, addressing and reviewing and reporting risks.  

• Ensuring that risks and mitigation plans have been completed, if appropriate, included in the risk register.  

All employees/contractors

• To report incidents/accidents via the appropriate manager.  

• To be aware of their duty to take reasonable care for their own safety and others.  

• To report to their managers on newly identified or potential risks in their working environment.  

• To comply with the RCG Risk Management Policy and procedures  

Procedure

Persons/organisations must inform Railway Competence Group of any adverse effects at the earliest opportunity and include information relating to: 

• The nature and cause of the incident. 

• The number of apprentices affected (where applicable). 

• The possible or actual impact on apprentices (where applicable). 

• How the incident came to light. 

• Whether other awarding organisations are aware of the incident. 

• Action plan detailing causes and effects, and to mitigate adverse effects. 

Where an adverse effect is reported, Railway Competence Group Board will: 

• Add the incident to the Railway Competence Group risk register. 

• Acknowledge receipt of the notification. 

• Confirm the timelines for investigation. 

• Obtain evidence relevant to investigation, management of risk. 

• Confirm the facts, establish any relevant factors/circumstances. 

• Ensure all necessary mitigating actions to protect the interests of apprentices have been taken. 

• Identify whether the incident is an isolated occurrence or has wider implications for other Qualifications and is a consistent issue. 

• Identify any patterns or trends and implement strategies to mitigate any risks associated with said patterns/trends. 

• Identify any appropriate changes to policy or procedures and ensure their implementation. 

• Ensure confidentiality throughout all processes. 

• Report to the regulators where appropriate. 

• Retain and store evidence/records appropriately and in line with all necessary policies and procedures/legal requirements such as data retention policy/GDPR requirements. 

• Communicate the lessons learned to all relevant team members and third parties. 

Process for raising an adverse effect concern

An adverse effect should be raised with the compliance manager who will liaise with Railway Competence Group Board of Directors. The concern raised must cite the following information: 

• Date and time of incident 

• Persons involved 

• Nature of incident(s) 

Railway Competence Board of Directors will then undertake the following process: 

• Acknowledge notification of adverse effect in writing. 

• Add adverse effect claim details to the risk register. 

• Board of Directors reviews risk and appropriate mitigations. 

• Board of Directors mitigate risk as required, i.e implement change of policy or procedures. 

• Railway Competence Group will promptly notify Ofqual when it has cause to believe that an event has occurred or is likely to occur which could have an Adverse Effect.  

Annual risk assessment

We will conduct an annual risk assessment and take appropriate action based on the combined score as outlined below. The higher the score, the higher the risk priority and importance of robust management: 

• Red combined score - take immediate steps to mitigate risk and monitor/review monthly. 

• Amber combined score - Mitigate risk and monitor/review quarterly. 

• Green combined score - No action necessary but monitor quarterly. 

A review of incidents that have taken place will be on the agenda for Director Board Meetings. 

Railway Competence Group Board of Directors will investigate incidents and determine appropriate mitigations to prevent any further occurrences.