FPOL17 Treasury Management by Provide Community

Treasury Management

Version: V5

Ratified by: Finance & Risk Committee

Date ratified: 01/02/2021

Name of author: Assistant Director of Finance

Reviewed by Committee or Expert Group Finance & Risk Committee

Equality Impact Assessed by:

1. Introduction

The day to day arrangements for Treasury Management of Provide CIC are undertaken through NHS SBS and their procedures clearly set out the arrangements for monitoring of bank balances and bank account transactions. Treasury Management for subsidiaries is undertaken by the CIC finance team.

2. Definitions

Fraud is where any person who dishonestly makes a false representation to make a gain for himself or another or dishonestly fails to disclose to another person, information which he is under a legal duty to disclose, or commits fraud by abuse of position, including any offence as defined in the Fraud Act 2006.

Bribery is the giving or receiving a financial or other advantage in connection with the ‘improper performance’ of trust or a function that is expected to be performed impartially or in good faith. Where the Provide Group is engaged in commercial activity it could be considered guilty of a corporate bribery offence if an employee, agent, subsidiary or any other person acting on its behalf bribes another person intending to obtain or retain business or an advantage in the conduct of business for the Provide Group and it cannot demonstrate that it has adequate procedures in place to prevent such. The adequate procedures that the Provide Group is required to have in place to prevent bribery being committed on their behalf are performed by six principles – proportionate procedures, toplevel commitment, risk assessment, communication (including training), monitoring and review. The Provide Group does not tolerate any bribery on its behalf, even if this might result in a loss of business for it. Criminal liability must be prevented at all times.

3. Counter Fraud

If any member of staff has good reason to suspect a colleague, patient or other person of fraud, bribery and / or corruption, involving the Provide Group, they should report their genuine concerns to the LCFS or Executive Finance Director immediately. The LCFS will then decide on the next course of action and advise the member of staff accordingly. All calls are dealt with in the strictest of confidence and callers may remain anonymous.

Suspicions of fraud, bribery or corruption should be reported to the Local Counter Fraud Specialists on telephone 0845 300 3333, Provide’s Group Chief Executive or NHS Counter Fraud Authority (NHSCFA) via an online reporting form: https://cfa.nhs.uk/reportfraud: or NHSCFA Freephone: 0800 028 4060. Further details including email addresses for those responsible can be found on Provide’s Intranet.

Individuals suspected of committing an offence of fraud, bribery or corruption may be subject to criminal and/or disciplinary investigation, which could result in criminal and/or disciplinary action being taken, including prosecution and/or dismissal. For more information, please refer to the Local Anti-Fraud, Bribery and Corruption Policy or to Provide’s Counter Fraud intranet pages https://intranet.provide.org.uk/project/counterfraud/

4. Bank Account

The CIC and its subsidiaries operate all bank transactions through current accounts held with various High Street banks.

5. Authorised Signatories

Details of authorised signatories are recorded on the appropriate forms and master lists are held by the Finance Department.

The finance team are responsible for the administration of amendments to authorised signatories.

6. Responsibilities

All members of the Finance Team have a responsibility to review the income and payments within the Group that fall within their area of responsibility and to advise the Assistant Director of Finance to assist with managing the cash flow as appropriate.

Budget managers should also consider the effect any actions taken within their area of responsibility may have on the cash flow and advise their Finance Business Partner accordingly.

A Cash Flow report and forecast will be reported on a monthly basis to the Finance & Risk Committee.

EQUALITY IMPACT ASSESSMENT

TEMPLATE: Stage One: ‘Screening’

Name of project/policy/strategy (hereafter referred to as “initiative”):

Treasury Management

Provide a brief summary (bullet points) of the aims of the initiative and main activities: Provides guidance on treasury management procedures

Project/Policy Manager:

Date:

This stage establishes whether a proposed initiative will have an impact from an equality perspective on any particular group of people or community – i.e. on the grounds of race (incl. religion/faith), gender (incl. sexual orientation), age, disability, or whether it is “equality neutral” (i.e. have no effect either positive or negative). In the case of gender, consider whether men and women are affected differently.

Q1. Who will benefit from this initiative? Is there likely to be a positive impact on specific groups/communities (whether or not they are the intended beneficiaries), and if so, how? Or is it clear at this stage that it will be equality “neutral”? i.e. will have no particular effect on any group.

Neutral

Q2. Is there likely to be an adverse impact on one or more minority/under-represented or community groups as a result of this initiative? If so, who may be affected and why? Or is it clear at this stage that it will be equality “neutral”?

Neutral

Q3. Is the impact of the initiative – whether positive or negative - significant enough to warrant a more detailed assessment (Stage 2 – see guidance)? If not, will there be monitoring and review to assess the impact over a period time? Briefly (bullet points) give reasons for your answer and any steps you are taking to address particular issues, including any consultation with staff or external groups/agencies.

Guidelines: Things to consider

• Equality impact assessments at Provide take account of relevant equality legislation and include age, (i.e. young and old,); race and ethnicity, gender, disability, religion and faith, and sexual orientation.

• The initiative may have a positive, negative or neutral impact, i.e. have no particular effect on the group/community.

• Where a negative (i.e. adverse) impact is identified, it may be appropriate to make a more detailed EIA (see Stage 2), or, as important, take early action to redress this – e.g. by abandoning or modifying the initiative. NB: If the initiative contravenes equality legislation, it must be abandoned or modified.

• Where an initiative has a positive impact on groups/community relations, the EIA should make this explicit, to enable the outcomes to be monitored over its lifespan.

• Where there is a positive impact on particular groups does this mean there could be an adverse impact on others, and if so can this be justified? - e.g. are there other existing or planned initiatives which redress this?

• It may not be possible to provide detailed answers to some of these questions at the start of the initiative. The EIA may identify a lack of relevant data, and that data-gathering is a specific action required to inform the initiative as it develops, and also to form part of a continuing evaluation and review process.

• It is envisaged that it will be relatively rare for full impact assessments to be carried out at Provide. Usually, where there are particular problems identified in the screening stage, it is envisaged that the approach will be amended at this stage, and/or setting up a monitoring/evaluation system to review a policy’s impact over time.