Owner: Ben Aston and Sarah Wartnaby, Compliance Managers SCL Compliance team Accountable Exec: Kate Lou Version: 1.0 Date: 07/09/2023 Approved by Board: 07/09/2023
CONTENTS
1. Introduction 2. Achieving Compliance Excellence 3. Building a Culture of Compliance: 4. Robust Compliance Monitoring and Reporting 5. Enhancing Stakeholder Confidence
6. Continuous Improvement 7. Audit Policy and Procedure o Audit process overview o
Funding Assurance Audits (Internal and External) o Regular Audit Schedule o Risk Reduction and error rating o Audit Findings Reporting o Compliance errors and risk responsibility
8. Responsibility: 9. Review and Revision 10. Conclusion
1. Introduction
The compliance strategy for SCL Education Group aims to ensure that the organisation operates in full adherence to all relevant laws, regulations, and industry standards. The purpose of this strategy is twofold: firstly, to establish a culture of compliance within the organisation, ensuring that all employees understand and follow the necessary rules and guidelines; and secondly, to mitigate funding risks by demonstrating to stakeholders, including funding bodies, that SCL Education Group operates with integrity, transparency, and accountability.
2. Achieving Compliance Excellence
The primary objective of the compliance strategy is to achieve compliance excellence by implementing robust systems and processes. This involves establishing clear policies, procedures, and controls that align with applicable legal and regulatory requirements, as well as industry best practices. Compliance training and awareness programs will be developed and conducted to educate all employees about their responsibilities and the importance of compliance in their day-to-day activities.
3. Building a Culture of Compliance:
To ensure long-term compliance, it is crucial to foster a culture of compliance within SCL Education Group. This requires the active participation and commitment of senior management, who will set the tone from the top by demonstrating their own dedication to compliance. Regular communication and training sessions will be conducted to reinforce the importance of compliance and to provide employees with the necessary tools and knowledge to fulfil their compliance obligations.
4. Robust Compliance Monitoring and Reporting
SCL Education Group will establish a comprehensive compliance monitoring and reporting framework to proactively identify and address compliance risks. This will involve regular internal audits, risk assessments, and periodic reviews of policies and procedures to ensure their ongoing effectiveness. Compliance reporting mechanisms will be established to enable employees to report potential compliance issues or violations confidentially and without fear of retaliation. The information gathered through these processes will be used to continuously improve and strengthen the compliance program.
5. Enhancing Stakeholder Confidence
A key aspect of the compliance strategy is to enhance stakeholder confidence, particularly among funding bodies. By demonstrating a commitment to compliance, SCL Education Group aims to reduce funding risks and maintain positive relationships with funding providers. This will involve transparent reporting of compliance activities, maintaining accurate records, and conducting external audits or reviews as required by funding agreements or regulatory bodies. By providing evidence of compliance, SCL Education Group will instil trust and confidence in its operations, reducing the likelihood of funding-related issues.
6. Continuous Improvement
Compliance is an ongoing process, and SCL Education Group is committed to continuously improving its compliance program. Regular assessments and evaluations will be conducted to identify areas for improvement and to address any emerging compliance risks. Feedback from employees, regulators, and other stakeholders will be actively sought and incorporated into the compliance strategy to ensure its effectiveness and relevance over time.
7. Audit Policy and Procedure
This Audit Policy and Procedure is established to ensure the effective and transparent management of audits and compliance within SCL Education Group. The Policy outlines the framework for conducting regular audits and reporting of findings promptly for resolution by each provision. Scope: This Policy applies to all employees, subcontractors, and relevant stakeholders engaged in activities within our funded provisions. Compliance is an integral aspect of our culture within SCL Education Group, and it is the collective responsibility of everyone to oversee and uphold.
Audit process overview
• Funding Assurance Audits (Internal and External)
SCL internal Auditing templates have been aligned with ESFA funding assurance requirements and guidelines, ensuring we align with external audits with the regulatory body. Where the ESFA have not released working papers for us to utilise, a temporary audit template will be created utilising the evidence requirements within the relevant contract year funding rules. Internal audits will be completed by the SCL internal Compliance team, under the directive of Kate Lou (Director of Quality & Curriculum). The compliance team are not responsible nor accountable for any risk or errors found, whilst the team can be consulted, they are to remain outside of handling of learner data for any error resolution. SCL Education Group will engage external auditors biannually to conduct audits in accordance with ESFA funding assurance. This external review will encompass assessments of our provisions, enhancing the robustness of our audit policy and incorporating external perspectives. Each provision is to assist in the collection of learner evidence for auditors and resolving any errors or risks found.
The remainder of the audit process review section relates to internal audits only.
Regular Audit Schedule A rolling 6 weekly audit schedule has been established that covers all our funded provisions, including subcontracted areas, to maintain compliance integrity and identify potential risks promptly. The audit will cover the below volume per provision:
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Regular reviews will be conducted with the Compliance team management to assess the need for additional resources as the number of provisions learners continues to increase throughout the contract year. Risk Reduction and error rating The aim of internal audits is to identify, assess, and mitigate risks within compliance across all funding streams and ensure compliance with funding regulations. Where risk has been identified, all funding for the learner will be placed at risk and an error rating will be provided for each provision after each 6 weekly audit period.
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The error rating has been designed in-line with Ofsted Grading and shown below:
o Outstanding: 0 – 0.49% error rating An Audit grade of "Outstanding" confirms that the sample audited
demonstrates compliance with funding rules and regulations, with no / little errors and risk to SCL found. The provision showcases their commitment to compliance, which aligns with ESFA funding rules and regulations, ensuring transparency, accountability, and the best use of resources. Good: 0.5 – 3% error rating An Audit grade of "Good" confirms that the sample audited demonstrates compliance with funding rules and regulations, with small number of errors and risk to SCL found. While they may have minor areas for improvement, their commitment to funding compliance helps maintain a stable and reliable foundation within their provision.
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o Requires Improvement: 3.0 – 4.99%
An Audit grade of "Requires improvements" confirms that the sample audited demonstrates aspects of compliance with funding rules and regulations, medium amount of errors have been found and poses a high risk to SCL Education Group. Requires Improvement runs the risk of moving into inadequate, whilst the audit identifies aspect of compliance with funding regulations, addressing errors and risks is a priority to ensure fully compliant with regulations. Inadequate: 5% or higher An Audit grade of "inadequate" confirms that the sample audited demonstrates failure to meet essential requirements outlined by ESFA, putting SCL Education Group at significant risk. Immediate and comprehensive actions are necessary to rectify compliance deficiencies, ensuring the provisions meets compliance regulations, resolves any errors, and reduces risk.
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As the audit schedule runs every 6 weeks, provisions may fluctuate between ratings, each provisions aim is to achieve Outstanding in compliance having no errors and risk to SCL Education Group. Where any rating received is below outstanding, all provisions must work on improvements to reach outstanding and remain a “outstanding” rating consistently throughout the contract year. Audit Findings Reporting At the end of each 6-week period or at request from executive / board members, an audit report will be created and released to key shareholders and provisions heads of. The audit report will summarise the findings of learner’s audit against each provision within the audit period, the financial risk and error rating.
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Sample below:
Each report will also encompass a recommendation for each provision to contemplate, along with a summary of outstanding areas from any prior audits, highlighting any emerging trends. A comprehensive audit report summarising all completed and outstanding audits up to the time of the report's drafting will also be presented at the subsequent crucial meetings within SCL.:
o Quarterly Performance and Quality governance board o Subcontractor monthly monitoring meetings
• Compliance errors and risk responsibility
Compliance with funding rules and regulations is the responsibility of every employee, subcontractor, and stakeholder within SCL Education Group. Upon receipt of the error report, each provision head is responsible and accountable for their provisions error rating and for managing any findings, for fixtures and improvements. Any effort to rectify compliance errors must adhere to regulatory requirements, accurately reflect the situation, and avoid any unethical or questionable practices.
Deadlines: Upon receipt of the audit report, all provisions must work to resolve any errors within a 4-week period.
Audit Procedure overview
1. Audit Schedule: Compliance Hub link - Here
The team have organised each audit period to fall in line with monthly provision meetings to talk over any findings so far and to understand any internal processes that may impact or be a detriment to the compliance learner journey. 2. Audit Conduct: The audit schedule lays out the team’s availability for audits over the current contract year period. The team will remain impartial to any findings and will ensure a robust audit of each learner is carried out. 3. Audit report and findings: will be documented in a comprehensive report, including recommendations, and corrective actions required. The report will be released to Kate Lou for full review and distribution to key stakeholders. Audit reports will be submitted within a reasonable timeframe after the audit's conclusion. 4. Risk Mitigation: Audit findings that identify risks will be recorded on a risk register, which will be monitored and managed by relevant provisions in collaboration with the compliance team.
8. Responsibility
The compliance team is not tasked with responsibility or accountability for any identified risks or errors. While they can provide consultation, they are not involved in the management of learner data for error resolution. Provision and area heads bear the responsibility and accountability for upholding compliance standards within their respective areas, ensuring that their staff adhere to compliance requirements. In cases where identified errors or risks extend beyond their team's scope, each head is expected to collaborate with other departments to rectify any issues and enhance processes for the benefit of future learners.
Consistent Non-compliance and / non-resolution of errors will be escalated for intervention and potential performance plans.
9. Review and Revision
This Audit Policy and Procedure will be reviewed and revised as necessary to ensure its effectiveness and compliance with changing regulations or organisational needs. Any revisions will be communicated to all relevant parties.
10. Conclusion
In summary, the compliance strategy for SCL Education Group aims to get compliance right by establishing a culture of compliance, implementing robust systems and controls, and actively mitigating funding risks. By doing so, the organisation seeks to instil confidence in its stakeholders, maintain positive relationships with funding bodies, and ensure the long-term success and sustainability of its educational initiatives.
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