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#1 Posted : 01 December 2005 09:39:00(UTC)
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Posted By Robert K Lewis Neil's commments were for me well put. The speech by Gordon Brown including the Operations and Financial Reporting(OFR) typifies the innate superiority complex held by the financial lobby that only money in reality matters at the end of the day. Many of us in this profession have struggled to get organisations to recognise that the Internal Auditing and certification requirements concerning risks to investment in the Turnbull code actually should include ALL risks to their investment. Yes I know Turnbull is only mandatory for plcs but it must be good practice for all other organisations. Perhaps it also shows that, as with the pensions debate, government departments do not have the same hymn sheet and we will have to await many other tragedies before it can be recognised and accepted that organisations must review and publicise their safety performance in some recognised and uniform manner. I would hate however to see the bland affirmations and certifications that are made on financial statements. This is perhaps an area where we can make a difference with genuine and searching review and reporting of business risks related to health and safety. Neil, when you do have the opportunity to read this I for one would be pleased to see IOSH promote a working party on this matter to produce a code of practice within HSE control. Bob
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#2 Posted : 01 December 2005 10:34:00(UTC)
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Posted By Mark Talbot I thought Turbull was guidance - not compulsory even for PLC's. Did I miss that bit?
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#3 Posted : 01 December 2005 10:49:00(UTC)
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Posted By Jonathan Sandler Turbull is only guidane, what about the Cadbury report that preceeded the Turnbull report or 93. Did Turnbull base his guidance on HSG 65? The only reason why a person has to work is for money. You have to be competent to be a bricky not not to be a director!
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#4 Posted : 01 December 2005 12:03:00(UTC)
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Posted By Robert K Lewis Mark If you don't comply with Turnbull try and see how long your stock exchange listing lasts. JS The Turnbull guide is about managing the company and not safety per se therefore HSG65 has no specific relevance. The intention was to ensure that there was adequate transparency concerning the risks to which a company is exposed and ensure that stakeholders were protected against the risks or were at least informed of their existence such that directors could be held to account. On a more general note - Many major companies do now follow the reporting elements of the Internal Audit and reporting sections with respect to environment and occassionally safety but the Chancellor has for me released pressure on companies to report by only emphasising the fiscal aspects. The other very real risks were ignored. Bob
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#5 Posted : 01 December 2005 12:41:00(UTC)
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Posted By Jonathan Sandler Agreed, re Turnbull not safety, but Turnbull took the basis of HSG 65 and made Corp Gov out of it. Accountability, proof, audit trail, etc.
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#6 Posted : 01 December 2005 13:06:00(UTC)
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Posted By Robert K Lewis The problem, though, is that the report has been passed through financial channels and the accountants are the "police" for its application and so concentrate on financial risk. Yes Turnbull recognised the requirements elsewhere but the money issue became "Monarch" of the empire. I would have wished the Chancellor to make the connections rather than emphasise only the fiscal but that is too close to joined up government for comfort in Whitehall. No one has yet responded to the idea of promoting a code based around Turnbull etc specifically for H&S - perhaps it could be incorporated into the much needed CoP for Directors Duties that has been mooted. If this is the case then the Institution could provide significant assistance. Bob
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#7 Posted : 01 December 2005 13:43:00(UTC)
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Posted By Jonathan Sandler Where is IOSH's Corp Governace Procedure to be found please.
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#8 Posted : 01 December 2005 13:57:00(UTC)
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Posted By Robert K Lewis I don't think there is a specific one but the following link provides some associated documents around the point http://www.iosh.co.uk/in...echnical.resources&cid=3 Bob
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#9 Posted : 01 December 2005 14:09:00(UTC)
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Posted By Jonathan Sandler Thanks for that. FYI IOSH do NOT have a COrp Gov policy!!!
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#10 Posted : 01 December 2005 14:27:00(UTC)
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Posted By bigwhistle I understand MPs get a full pension after 20 years was that brought up?
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#11 Posted : 01 December 2005 15:33:00(UTC)
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Posted By Robert K Lewis Out of interest these are some quotes from the Times concerning the speech The main thrust of the speech saw the Chancellor promising to abandon plans to force companies to report on their social and environmental strategies in operating and financial reviews…………… The Chancellor said these moves were part of a new risk-based approach to regulation that would be based on "trust in the responsible company". He said there should be "no inspection without justification, no form filling without justification and no information requirements without justification". He said: "In the new legislation we will publish before Christmas we will make this risk-based approach a statutory duty of the regulators." The last one is an interesting take but I am unsure what he means, but am I any different to anyone else on this? The emphasis seems to be away from specific requirements but I wonder if the DWP are with him. Bob
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#12 Posted : 01 December 2005 16:49:00(UTC)
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Posted By Ian Waldram To answer Jonathan: For some time IOSH has had an Audit Committee reporting to Council. In recent years that Committee has used guidance from Charities Commission about how to identify risks and associated controls holisticly, and has closely monitored and reviewed how the senior management team at HQ do that, and the results. A summary report of key business risks has been discussed annually at Council. You can see that whole process summarised under the heading "Risk exposure and assessment" within the Trustees' report on p19 of the current IOSH Annual Report. The role of that Committee was strengthened as part of the Corporate Governance revision which came into effect at the November AGM, it is now titled the "Risk management and Audit Committee" and reports to the new Board of Trustees who are ultimately accountable for all that happens within IOSH. We try hard to model internally all the good practices that we advocate for other organisations, including listening to stakeholders and finding ways to further improve. So I do believe Neil was speaking from a position of comparative strength.
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#13 Posted : 01 December 2005 16:57:00(UTC)
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Posted By Jonathan Sandler Ian, Thank you for your reply but how was this board elected, is there any conflict of interest with this board? how is the boards accountablity demonstrated. I accept IOSH is NOT a plc but could we not have a Corp Gov policy with the amount of funds we (IOSH) have? Regards
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#14 Posted : 02 December 2005 09:13:00(UTC)
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Posted By Robert K Lewis Sometimes it is strange how issues lead back to IOSH governance - which was not my intention in the thread. However Jonathan there are transparent procedures for nomination to the various committees and access to them is available via the normal nomination and selection procedures. Picking up on Ian's comments I think we could "beef" up the section in the annual report to a degree and no doubt this will happen. More importantly I think there is a point at which IOSH could make a positive contribution by producing and publishing a document in this area. I have made an offer to Neil to assist and there are no doubt those such as Lawrence B et al who could drive this to a successful conclusion. My view is that we need a major issue to focus on this next year to make a significant impact and Directors' Duties would seem to be a very live issue for us to make a start! Bob
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#15 Posted : 02 December 2005 13:46:00(UTC)
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Posted By Richard Jones Bob, I’m not sure what sort of code of practice you are advocating here…it may well be that there is something already out there. For information, the subject of OFR was an unusual and interesting one for us to get involved in as part of our consultation process…not our normal sphere of activity. The original consultation was to do with OFR and Materiality…the latter bit catching our attention. It was about the board identifying what was ‘material’ to the long-term viability of the company, so we responded arguing that people have to be ‘material’ to any business, therefore their health and safety must also be ‘material’. It worked…and the second consultation document had three mentions of health and safety (see http://www.iosh.co.uk/fi...riality%20pdf%2015%2Epdf). We responded to the second consultation in a similar vein and this response can be viewed at: http://www.iosh.co.uk/fi...se/pdf%2050%20OFR2%2Epdf The result of all this consultation was the passing of new legislation: The Companies Act 1985 (Operating and Financial Review and Directors’ Report) Regulations 2004, which came fully into force in April of this year. We were disappointed that ‘health and safety’ wasn’t specifically mentioned in the statutory instrument, but were greatly heartened when the Accounting Standards Board issued their guidelines on ‘how to do’ OFR and it was there (4 times), see: http://www.frc.org.uk/im...ded/documents/ACF345.pdf I think this may well cover the 'code of practice' you referred to! So from April this year, it was mandatory for all GB listed companies to complete an OFR, the Chancellor seems to have reversed this in his speech to the CBI…it will be interesting to see how that can be done, particularly in the face of the apparent backlash that has occurred. Richard
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#16 Posted : 02 December 2005 14:02:00(UTC)
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Posted By Robert K Lewis Richard I am thinking that we have the ability in our members to bring forward some form of code which would include the Turnbull ideas on governance. If you remember the London consultation on directors duties that we attended it seemed to stutter a bit and looks like it may produce something but not to the extent I think may be necessary. Could there be scope for us to produce a guidance document somewhere in the epicentre of this situation. I cannot finalise my thoughts as yet but I think there are skills in IOSH members to identify and create a relevant code on Operational Risk reporting etc. Would welcome a decent brainstorm on where this could head for. Bob
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#17 Posted : 05 December 2005 10:39:00(UTC)
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Posted By Jonathan Breeze Bob, An interesting proposal, which, for what it's worth, I would like to second. It may be, as Richard suggests, that the information is out there, but if it is, it needs to be brought to the attention of H&S practitioners like myself. If it's not, then we will have made a novel and useful contribution to to the debate.
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#18 Posted : 05 December 2005 11:43:00(UTC)
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Posted By Robert K Lewis For me the problem with Richard's response is that ALL INFORMATION is out there somewhere but needs to be brought together to create a coherent whole. In all honesty how much of what we do is actually new. We constantly adapt and re-adapt material to suite the specific need. Hence my free floating thought to bring together some people to brainstorm the issue and drive a document forward. We need, as I said previously, a high profile issue for the year and there seems to me to be something here that could be done and create national awareness of IOSH at the same time. Bob
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