Document

Corporate risk register

001 The Benefit Subsidy claim may be qualified and/or financial losses.

Risk Cause

The External Auditors audit the Horsham District Council Benefits Grant Subsidy return to the Department for Work and Pensions (DWP) on an annual basis to identify errors.

Risk Effects

Financial. Service Delivery. Compliance with regulation. Reputation.

Controls

Continuously monitor the level of quality control checking.
An earmarked reserve for subsidy provision is now in place that would cover the loss of subsidy in the event that the upper threshold in the subsidy claim is breached.

Quarterly update

Pressure has been building in the service since the outbreak of Covid-19. In 2022/23, a pre-audit 0.58% Local Authority error rate breached the upper threshold of 0.54%, resulting in a loss of £122,925. Post-audit, the final subsidy loss was £191,235 after extrapolations. As part of a commitment to continued service improvement, including staff development, 2024/25 has seen an increased amount of quality assurance measures in year. These increased measures have also been a result of the issues previously identified, as well as areas for improvement identified in some of the quality review deep dives. A DWP support review was also undertaken in 2024 to help improve processes, procedures and approaches. The outturn LA error for 2023/24 was for a pre-audit figure of 0.24%, below the lower threshold of 0.48%, leaving some headroom. However, the audit identified some errors which, after extrapolation, has pushed the error rate over the lower threshold to 0.51% and a loss of £58,687 in subsidy. It ended below the upper threshold however. At month 9, the current error rate for 2024/25 is 0.38% following the identification of two large errors: a £15k error from 2016 (Census legacy) and one £11k error from 2021 (during Covid). As customers move to Universal Credit during 2024/25, this will reduce the expenditure population, further increasing the expected year-end error rate to a forecast of 0.44%. The forecast pre-audit year-end error rate position will therefore be only £8,865 beneath the lower threshold limit, with very little headroom to the lower and upper threshold limits for extrapolated audit errors. Therefore a loss of subsidy is again anticipated in 2024/25.

Target Risk

High (16) (Threat; High; Major)

Current Risks

High (20) (Threat; High; Critical)

Responsible Officer

Director of Resources

Action Officer

Director of Resources

002 Recruitment and Retention.

Risk Cause

Linked to national shortage of labour in some sectors as well as experienced professionals leaving the public sector for retirement or better pay in the private sector. Capacity problems increase turnover and absence and adversely affect wellbeing and productivity levels.

Risk Effects

Adverse effect on morale. Financial. Failure to achieve agreed business objectives. Compliance with regulations. Complaints / claims / litigation. Stress and absenteeism.

Controls

Workforce planning, training, development, growing your own, leadership and management programmes, apprenticeships, coaching, supporting skills and qualifications are all activities undertaken.
Efficient, effective recruitment processes tailored to jobs, enhancing the employer brand, recruitment benefits, such as relocation package, flexible and hybrid working, market supplements, recruitment & retention payments, review of pay point spinal column or a HDC weighting allowance.
Ongoing workforce planning and review of recruitment and retention effectiveness; staff surveys and action plans progression; sponsorships for professional development; career grades.

Quarterly update

Recruitment and retention in key services such as Building Control, Planning and Technology Services has resulted in locums and vacancies, resulting in delays in delivering workloads. Senior posts are currently all filled. Legally trained support staff are in place and lawyer posts have been filled recently, reducing the need for legal locums. Building Control has three trainee posts filled. Four employees have left for career progression and the associated greater pay, following their registration as Inspectors. Some activity has slowed down and we are considering the options for future service provisions. Other services have been able to recruit, but also retained their staff well, against a background of the recruitment market slowing down and fewer jobs being available for people to move to. With the announcement of Local Government Reorganisation, this risk will be closely monitored as there is a concern this will impact both recruitment and retention of staff, however, we are yet to see the impact of this.

Target Risk

Medium (12) (Threat; Medium; Major)

Current Risks

Medium (12) (Threat; Medium; Major)

Responsible Officer

Director of Resources

Action Officer

Head of HR and OD

003 Rapidly rising costs and lower income making balancing the budget more difficult.

Risk Cause

Uncertainty in the UK and World economy. Higher levels of salary and non-salary costs from inflation. Impact on the financial markets and the pound in the wake of war in other countries and the energy crisis. Likelihood of a deeper depression and slowdown in the property and financial markets. Loss of income because of changes in spending habits due to cost of living and impacts from government due to changes in benefits processing.

Risk Effects

Financial. Service Delivery. Compliance with Regulations.

Controls

Monitor the external environment.
Monitor internal indicators, particularly costs from inflation, income generation and respond appropriately to adverse trends.

Quarterly update

At month 9 the Council is forecasting an operational surplus of £0.3m. Parking income in the town centre car parks is lower than budgeted by £0.13m, and in Strategic planning difficulties in recruiting to the vacant land drainage post and additional spend on local plan consultancy create a total £0.20m forecast overspend. Income from the pantomime performance at the Capitol and the reduced cost of HVO fuel have offset some of these additional costs and loss of income. There are also significant pressures on homelessness and benefits cases, partly offset by an increase in government funding for homelessness. Spending our reserves for social and wellbeing gain, without achieving a revenue return will increase the pressure over the medium term. Budget shortfalls of around £2m a year are forecast once we introduce p.a. a 1,2,3 food waste collection and the Capitol Theatre refurbishment.

Target Risk

High (15) (Threat; Medium; Critical)

Current Risks

High (15) (Threat; Medium; Critical)

Responsible Officer

Director of Resources

Action Officer

Head of Finance and Performance

004 Funding from Government is less than assumed in the Medium Term Financial Strategy (MTFS) from 2026.

Risk Cause

The Council is reliant on Central Controlled Government funding (e.g. Business Rates).

Risk Effects

Reductions in funding. Adverse effect on morale. Financial. Failure to achieve agreed objectives.

Controls

Continue to keep a watching brief.
Revisit the MTFS and if necessary 2024/25 budget in year.
Evaluate and discuss with Members possible future actions to mitigate loss of income. e.g. Corporate Restructure, cuts to quality and / or non-statutory services, investment and infrastructure projects that generate income.

Quarterly update

For 2024/25 The Council has thoroughly reviewed income and expenditure and set a balanced budget, albeit using £0.6m of the Funding Guarantee grant from Government. For 2025/26 offers have proposed a balanced budget using £0.6m of the Floor Funding grant from Government. £0.9m savings were identified throughout 2025/26 and these have been actioned during budget setting. The Government decision to increase the National Insurance rate increases the budget expenditure by £0.5m. Government have said that funding for this will be announced in the final settlement announcement in February 2025. The Council will only receive funding of £154k creating a £346k gap which will be met by using additional Floor Funding grant. Government included this NI funding with the Council's core spending power so it is at risk of being reduced further in future years. A £3.6m budget deficit is forecast at the end of the MTFS, if we implement food waste before the statutory deadline March 2026 and / or spend our reserves without achieving a revenue return such as on the Capitol Theatre refurbishment. The gap will only get larger if the funding cuts are sharper than anticipated.

Target Risk

High (16) (Threat; High; Major)

Current Risks

High (16) (Threat; High; Major)

Responsible Officer

Director of Resources

Action Officer

Head of Finance and Performance

005 Funding from Business Rates is less than assumed in the Medium Term Financial Strategy (MTFS) from 2026.

Risk Cause

The Council is reliant on Central Controlled Government funding Business Rates. Government re-baselines less favourably, or businesses start to fail and the Rateable Value falls below the baseline.

Risk Effects

Reductions in funding. Financial. Adverse effect on morale. Failure to achieve agreed objectives.

Controls

Continue to keep a watching brief.
Revisit the MTFS & if necessary 2024/25 budget in year.
Evaluate and discuss with Members possible future actions to mitigate loss of income. e.g. Corporate Restructure, cuts to non-statutory services, investment and infrastructure projects that generate income.

Quarterly update

The Rateable Value listing remains higher than it started, which retains a greater share of the business rates funding in the Sussex Pool area.

Target Risk

Medium (12) (Threat; Medium; Major)

Current Risks

Medium (12) (Threat; Medium; Major)

Responsible Officer

Director of Resources

Action Officer

Head of Finance and Performance

006 Non-compliance with control procedures.

Risk Cause

Governance: Managers are responsible for ensuring that controls to mitigate risks are consistently applied.

Risk Effects

Failure of business objectives. Health & Safety. Financial. Service Delivery. Compliance with Regulations. Personal Privacy Infringement. Reputation damage.

Controls

Officer training
All Service Managers required to sign an Assurance Statement. (By 30th June Annually) (Cyclical)
Internal Audits identify service based issues and help managers to resolve these.
Programme of training and information to ensure all managers understand their roles.

Quarterly update

The Annual Governance Statement (AGS) actions in the 2023/24 action plan were implemented. The internal audit opinions issued in 2023/24 were either Substantial or Reasonable. The Chief Internal Auditor issued a Reasonable opinion. Minor breaches in controls have been reported in the AGS and actions are being addressed. These are not considered significant. There has been one partial assurance opinion issued in 2024/25 but no significant issues or risks to report in the year to date.

Target Risk

Low (8) (Threat; Low; Major)

Current Risks

Medium (12) (Threat; Medium; Major)

Responsible Officer

Director of Resources

Action Officer

Director of Resources

007 A health & safety failure occurs.

Risk Cause

Physical. The Council is responsible for the health & safety (H&S) of its clients, staff and other stakeholders, owns and maintains significant assets, and also has responsibility for H&S in some partner organisations where it does not have operational control.

Risk Effects

People come to harm. Complaints/claims/ litigation. Financial losses. Censure by audit / inspection. Reputation damage. Adverse effect on morale. Stress and absenteeism.

Controls

H&S Management Forum reviews corporate inspection strategy and all other H&S issues quarterly. An audit programme is in place to provide assurances on varying aspects of managing H&S. A Personal Safety of Staff and Lone Working audit completed last year gave Reasonable Assurance.
Training programme includes annual refreshers on a rolling programme. All mandatory H&S training must be completed as part of probation. Compliance is monitored centrally by the HR service and non-compliance escalated to Heads of Service initially and thereafter to SLT.
Risk assessments undertaken and reviewed as required.
H&S Officer regularly reviews high risk areas personally.

Quarterly update

Risk assessments are being undertaken, reviewed, and updated. Refresher training on Fire Safety for all staff has been completed in March 2024. All other control actions are ongoing. In light of recent incidents in our refuse service, we have reviewed our H&S procedures, which were found to be robust.

Target Risk

Medium (10) (Threat; Low; Critical)

Current Risks

Medium (10) (Threat; Low; Critical)

Responsible Officer

Chief Executive

Action Officer

Head of HR and OD

008 Key Contractor Failure.

Risk Cause

Uncertainty in the UK and World economy. Instability and high-profile failures.

Risk Effects

Financial.

Controls

Regularly check accounts of key suppliers.
Check public liability insurance of key suppliers.
Ask for key suppliers’ business continuity plans.
Consider whether the failure of a key supplier needs to go in service business continuity plan.

Quarterly update

The impact of the world shortage of building supplies remains uncertain. Risk of inflation (now falling), interest rates, and recession are being monitored. Government announcement to increase in employer national Insurance contributions will add further pressure from 1 April 2025. Some suppliers are starting to come forward to increase prices outside of the contract, which is being resisted. The Council terminated two contracts in 2023/24; one by mutual agreement with the supplier resulting in a termination payment to the Council, the other because of poor supplier performance. Both are being re-procured during 2024/25 and interim measures are in place. Key contracts are reviewed as part of the ongoing contact management arrangements and officers have been reminded to check the financial health of key suppliers and be ready to implement alternative arrangements.

Target Risk

Medium (10) (Threat; Low; Critical)

Current Risks

Medium (10) (Threat; Low; Critical)

Responsible Officer

Director of Resources

Action Officer

Director of Resources

009 Adopting an up to date Local Plan by end of 2025.

Risk Cause

Requirement to adopt an up-to-date Local Plan by end 2025 in accordance with government requirements.

Risk Effects

Economic and environmental damage to district as a result of limits to development which can take place. Council loses control over SNOWs prioritisation. Significant risk of speculative development prior to adoption of local plan, with impact on Local Plan trajectory and how this may be defended at the Local Plan examination.

Controls

Joint working with partners to develop water neutrality mitigation strategy.
Keep watching brief on government messaging on planning reforms.
Sufficient staff and budgetary resourcing to support progression through regulatory stages of consultation, evidence base preparation and examination.
Officers seeking KC advice and support prior to submission and to support through the examinations process.
Respond to Inspector in a timely way to any MIQs, questions and queries throughout the examination process

Quarterly update

Local Plan Examination Hearings commenced as programmed on 10.12.24. Without warning that the Inspector had identified concerns with the Plan in advance, the Local Plan Inspector has subsequently cancelled all further hearings. He has indicated that he has significant concerns about the Plan, and he has informed the Council via the Programme Officer that he will write to the Council setting out his views on next steps 'in the new year'. He has identified a number of Action Points for for the Council to complete. At the time of drafting this Quarterly Update, this work is still ongoing. Whilst all risks within the Council's direct control (set out above) have been managed effectively, no action by the Council can account for the particular views of an individual inspector. Next steps and risks will need to be reviewed following receipt of the response from the Inspector. Once we have more information, the risk rating will be adapted to reflect the emerging situation.

Target Risk

Medium (5) (Threat; Very Low; Critical)

Current Risks

High (15) (Threat; Medium; Critical)

Responsible Officer

Director of Place

Action Officer

Head of Strategic Planning

010 Data security.

Risk Cause

Managerial / Professional. The Council has a legal obligation to protect personal data. The Information Commissioners powers are much more far reaching since changes in May 2018.

Risk Effects

People and businesses come to harm and suffer loss that might not otherwise have occurred. Complaints / claims / litigation. Resources consumed in defending claims. Financial losses. Fines from regulators. Adverse publicity. Reputation damage.

Controls

Develop appropriate processes & procedures which underpin the IT Security Policy.
Provide a programme of Induction and at least annual training on Information Security to all staff.
Annual Public Services Network (PSN) Accreditation.
Representatives from each department meet every other month to maintain compliance, updates and training.

Quarterly update

The situation is being monitored and training for phishing attacks has been rolled out to members, as well as staff. A policy on the use of AI has been issued for staff and members and the Information Security Policy has been updated.

Target Risk

Low (8) (Threat; Low; Major)

Current Risks

Medium (12) (Threat; Medium; Major)

Responsible Officer

Director of Resources

Action Officer

Head of Customer and Digital Services

011 Cyber security and business continuity.

Risk Cause

Technological. Council services are increasingly reliant on IT systems at a time when there are greater opportunities for malicious attackers to exploit security weaknesses.

Risk Effects

Loss of key systems-disruption to Council services. Cost of investigation and recovery of systems. Fraud/theft. Loss of the integrity of Council Records. Penalties from the Information Commissioner's Office (ICO.) Adverse media coverage.

Controls

Awareness of current threats.
An effective ICT Service delivery team.
Effective patching and updates to mitigate known vulnerabilities.
Compliance with expected security standards. (PSN, PCI-DSS).
Effective policies in place which outline security requirements for users of ICT.
Effective back-up and recovery processes in place for Council ICT systems.
Plan developed, approved internally and being carried out.
Plan developed, approved internally and being carried out.

Quarterly update

Cyber awareness training is ongoing, as part of induction for new staff/ Members, and refreshed periodically. We have rolled out Phishing training to members, as well as staff. We are following government advice re heightened Cyber Security Threats. PSN Accreditation for 2024 has been achieved.. Backups have been reviewed and improved. A test scenario has been completed with relevant Heads of Service, to test Silver and Bronze liaison and operational continuity in a simulated cyber attack. No major issues were identifed.

Target Risk

Medium (12) (Threat; Medium; Major)

Current Risks

Medium (12) (Threat; Medium; Major)

Responsible Officer

Director of Resources

Action Officer

Head of Customer and Digital Services

012 Civil emergency.

Risk Cause

Legal. The Civil Contingencies Act places a legal obligation upon the Council, with partners, to assess the risk of, plan, and exercise for emergencies, as well as undertaking emergency and business continuity management. The Council is also responsible for warning and informing the public in relation to emergencies, and for advising local businesses.

Risk Effects

Controls

Update corporate business continuity plan and regular review.
Test effectiveness annually through case scenarios at Gold, Silver or Bronze levels.
Bitesize workshops to address new procedures and processes.

Quarterly update

All business continuity plans are being reviewed in Q4 2024/25. All Neighbourhood Wardens have been trained as Rest Centre Managers and some are earmarked for Incident Liaison Officer training later in the year. A small group of Heads of Service has been established to manage emergencies out-of-hours at 'bronze level', with training by the Police undertaken in Q3. Training on Resilience Direct was delivered in the last quarter. Hybrid bitesize workshops are being offered for: Response, Business Continuity, Recovery, Rest Centre operations. A recent fire in Horsham showed that the response was quick and a rest centre was setup during the night.

Target Risk

Low (8) (Threat; Low; Major)

Current Risks

Medium (10) (Threat; Low; Critical)

Responsible Officer

Director of Resources

Action Officer

Head of HR and OD

014 Climate Change.

Risk Cause

Human driven emissions of carbon dioxide and other greenhouse gases through the burning of fossil fuels, as well as intensive agriculture and habitat destruction have altered the global atmosphere.

Risk Effects

Increase in water logging and surface water. River flooding and surface water flooding. Extreme heat. Wildfires.

Controls

Evaluate feasibility of climate adaptation through on-site site design and infrastructure changes, such as sustainable urban drainage, and discuss with Members.
Review Emergency planning approach to extreme weather events.
Officer training to keep abreast of evolving climate adaptation approaches.

Quarterly update

Carbon Literacy training for staff continues, therefore, increasing understanding of climate change. The team are looking at further targeted training to increase understanding of potential adaption to more extreme weather events. Drainage Officer now appointed and sits within the Sustainability and Greenspaces team. This role will give advice on sustainable urban drainage in minor planning applications as well as natural flood management solutions.

Target Risk

Low (8) (Threat; High; Minor)

Current Risks

Medium (10) (Threat; Very High; Minor)

Responsible Officer

Director of Communities

Action Officer

Head of Sustainability and Greenspaces

015 Office move.

Risk Cause

Relocation of council offices.

Risk Effects

Financial losses. Reputational Damage to the Council. Disruption to services.

Controls

Continued monitoring of project progression via weekly sub meetings and project team update meetings.
Weekly onsite progress meetings to be held when works have commenced.

Quarterly update

Project completion for the office fit-out is on schedule for 17 January 2025. Weekly project meetings have taken place to ensure that any risks or issues that have been identified have been mitigated accordingly. Phase moves for members of staff are programmed in February and supporting documentation such as the staff handbook has been created. Staff newsletters have been emailed out regularly to keep officers and Councillors updated and informed about the office move. The finance tracker has been updated and monitored throughout the project to manage any budget constraints. Further tours have been arranged for Members and Move Champions ahead of phased moves and opening on 3 March. Fire Safety training has been completed, Counter Terrorism visit and report has been produced, post/suspect packaging handling training has been scheduled.

Target Risk

Low (9) (Threat; Medium; Moderate)

Current Risks

Medium (12) (Threat; High; Moderate)

Responsible Officer

Director of Place

Action Officer

Office Move Project Manager

016 Domestic Food Waste Collection.

Risk Cause

Failure of delivery of caddies and food waste vehicles. Recruitment issues. Competing with neighbouring authorities for the same goods and services. Distribution. Storage and extra space needs.

Risk Effects

Failure to meet the deadline. Reputational damage. Lack of buy in from residents. Failure to meet national recycling targets.

Controls

Fortnightly project meetings with key members of staff and monthly project board meetings.
External meetings with West Sussex Waste Partnership to share ideas, information and updates.
Working with a delivery company to manage production and delivery of caddies, and securing early procurement.
Recruitment plan being developed with HR.
Audit on project has taken place with a reasonable assurance outcome.
Vehicles ordered with delivery date late 2025 to ensure they arrive on time.

Quarterly update

Caddies and vehicles have now been ordered, however delays to delivery remain outside of the control of the Council as this is dependent on the supply chain. The Council ensured early procurement of vehicles and caddies to reduce the risk of delays impacting service delivery. Temporary storage for bins and caddies secured. Pre application completed for Park and Ride to store bins and planning application to be submitted in March. Rounds are being driven to establish where changes need to take place. Recruitment timescales are on the project plan and a meeting with HR is in the diary to put together a recruitment strategy. An internal audit carried out during Q3 concluded an opinion of Reasonable Assurance regarding the governance arrangements of the Domestic Food Waste project.

Target Risk

Low (9) (Threat; Medium; Moderate)

Current Risks

Medium (12) (Threat; High; Moderate)

Responsible Officer

Director of Communities

Action Officer

Head of Recycling and Waste

018 The Capitol Refurbishment project.

Risk Cause

Financial - lack of financial management and oversight, increasing material costs and inflation. Timescales - lack of project management, slow decision making and availability of materials. Reputational - lack of project management and poor political decision making. Environmental - lack of project management. Cultural - lack of ability to programme cultural offer with confidence.

Risk Effects

Financial - negative impact on the Council's financial reserves beyond agreed figures. Timescales - negative impact on reserves and revenue (and further programme income. Reputational - negative public perception on the Council both politically and organisationally and its ability to manage projects and finances in the future. Environmental - unable to hit the Council's net zero ambition by 2030. Cultural - unable to provide cultural offer to residents of the district for an extended period.

Controls

The Council's Project Board meet weekly to discuss all relevant information and steer the project. The project is planned across RIBA stages with a freeze implemented at the end of every stage where consideration is given to how to proceed. All necessary project documents are in place.
The Project Design Team (contractors) meet regularly with the Council's representation. All relevant decisions and issues presented at fortnightly Project Team Board meetings for discussion.
Members are kept up-to-date with progress and changes to project regularly - frequency is dependent on stage and across 2025 cabinet reports will be generated April,. July and October. Additional Member breifings will be organised as necessary

Quarterly update

Due to the fast moving nature of the changes to this project, the risk remains high. Members are consulted regularly as changes to the scope of the project occur along with formal updates on progress. Delivery of the Panto in 2025 and 2026 remain a priority, This risk is lower for 2025 due to the scaled down work and timeframes for this work. Construction is anticipated to take place from January 2026, the re-launch of the Theatre is programmed for 30 September 2026 with the 2026 Panto scheduled to start in late November 2026 but with a period needed prior to this for set build and rehearsals.. The cast for the 2026 panto will be secured in January 2026. This creates a greater risk of any delays impacting the 2026 panto season. Closure of the Theatre in 2026 also create a risk to the retention of permanent and temporary staff and the loyalty of voluntary staff, which could impact the effective running of the Capitol.

Target Risk

High (15) (Threat; Medium; Critical)

Current Risks

High (20) (Threat; High; Critical)

Responsible Officer

Director of Communities

Action Officer

Head of Leisure and Culture