Corporate report

Governance Statement

Published 9 June 2022

The Office of the Solicitor for the affairs of Her Majesty’s Treasury (the Treasury Solicitor) was incorporated as a corporation sole by the Treasury Solicitor Act 1876.

The Government Legal Department (GLD) is a non-ministerial department and was established as an Executive Agency on 1 April 1996. Ministerial oversight and accountability to Parliament lies with the Attorney General. HM Procurator General and Treasury Solicitor leads the department, in the roles of Permanent Secretary and Chief Executive.

The Treasury Solicitor is accountable to the Attorney General for the running of GLD; and as Chief Legal Adviser to Government, the Attorney has a close interest in the legal advice and legal services being provided to government by GLD and the wider Government Legal Profession. An interim Framework Agreement governs the relationship between GLD and the Law Officers and the Attorney General’s Office.

Ministers

The ministers who had responsibility for the department during the year were:

• The Rt Hon Suella Braverman QC, MP, Attorney General from 10 September 2021 (maternity leave from 26 February 2021 to 10 September 2021)
• The Rt Hon Michael Ellis QC, MP, Attorney General until 10 September 2021, and Solicitor General from 10 September 2021 to 15 September 2021
• The Rt Hon Lucy Frazer QC, MP, Solicitor General until 10 September 2021
• Alex Chalk QC, MP, Solicitor General from 16 September 2021

In 2021-22, a Ministerial Strategic Board was established, chaired by the Attorney General, which met in July 2021 and January 2022.

Board and Sub Committees

The Governance structure is set out below:

GLD Board

Chair: Susanna McGibbon

The Board focuses on strategic matters for the department. It supports the Treasury Solicitor in providing leadership of GLD. It sets GLD’s vision and strategic direction.

Shadow Board

Chair: Rotating Chair

The Shadow Board is an advisory staff forum, comprised of representatives from a range of divisions/groups, grades and professions, to scrutinise and contribute to strategic decisions in order to deliver GLD’s Strategy. Its specific focus is on ensuring that the GLD strategic outcomes are incorporated into the decisions being made by the Board. It meets every 2 months before each Board meeting to discuss and provide opinions on the same papers that the Board see.

Executive Committee

Chair: Susanna McGibbon

The Executive Committee reports to the Board and consists of Executive Board Members. It oversees the operational management of all aspects of the department. The Executive Committee has 3 sub committees which provide assurance, challenge and support to the strategic outcomes and key priorities for GLD:

Legal Delivery Committee

Chair: Elizabeth Hambley, Legal Director General, Commercial with Trade and International

The Legal Delivery Committee provides oversight and assurance in relation to the quality and efficiency of legal work undertaken by GLD and oversees client relationships. It also oversees arrangements for the delivery of external legal services and relationships with the legal professional bodies. It supports the development of strategic priorities for activities in these areas.

The Committee met bi-monthly during the financial year 2021-22, with additional meetings to refine and review the biannual reports provided to it. The Committee has fulfilled its oversight and assurance role through regular reporting and by specific discussion and scrutiny of areas, including:

• Legal Delivery Excellence: Reviewing the work of GLD’s Centres of Excellence for primary and secondary legislation. Overseeing progress on other key elements of GLD’s Knowledge, Capability and Innovation Strategy. Assuring the reprocurement of GLD’s largest law firm panels.
• Client Relationships: Reviewing the key outcomes of the client care initiatives achieved through the GLD Client Action Plan 2020-21 and the Client Services Forum. Approving the GLD Client Action Plan 2021-22. Reviewing future ways of working for the GLD Client Services Forum and agreeing its recommendations to take forward the development of an overarching client approach.

The Committee has provided a strategic steer on key elements of legal delivery within its terms of reference and supported the development of GLD’s strategic priorities in these areas, including:

• Legal Delivery Excellence: Endorsing proposals to develop a GLD legal learning framework and to review GLD’s use of third party legal information services. Steering GLD’s development of specialist roles including knowledge development lawyers. Reviewing recommendations on and progress to put in place an enhanced model and processes for legal quality assurance. Reviewing and refining GLD’s current approach to assuring the work of external panel counsel and law firms.
• Client Relationships: Commissioning and undertaking a review of how GLD reports and captures risks in relation to client relationships. Reviewing key findings from individual department ‘deep dives’ led by GLD’s Non-Executive Directors and guiding the development of an improved deep dive process.

Operations Committee

Chair: Jessica de Mounteney

Legal Director General, Litigation with Justice and Security (previously Stephen Braviner Roman, Legal Director General, Litigation with Justice and Security).

The Committee provides oversight and assurance in relation to the delivery of non-legal priorities, including Corporate Services and Bona Vacantia, by monitoring performance and supporting the development of strategic priorities within its remit, including the Accommodation and Location Strategy, the Digital and Technology Strategy, and the Management Information Strategy.

The Operations Committee met 5 times during 2021-22. It has also dealt with a large number of papers by correspondence throughout the year.

The Committee has endorsed recommendations to relocate staff in Bristol and Leeds to more suitable offices to accommodate increasing numbers. This is in line with the GLD Strategy of providing increased opportunities for the attraction, recruitment and retention of staff. The Committee has endorsed various ICT plans to ensure that GLD is transitioning to a converged and integrated IT system which contributes to the GLD strategic outcome of being more connected as well as aligning to contemporary standards across government.

The Committee has been considering proposals to reduce GLD’s footprint in 102 Petty France as part of GLD’s ambition to be a “location – neutral” employer.

The Committee endorsed 2 project closure reports, for the Time Recording System and the Digital Office Solutions, which are essential for GLD to be a modern legal organisation. It has continued its programme of deep dives into the corporate functions, covering elements of HR, Finance and the Business Management function, enhancing its capability to make more informed decisions.

During 2021-22, the Committee regularly reviewed the performance of Corporate Services through Operations Performance Reports, to provide assurance to the Board.

People Committee

Chair: Mel Nebhrajani CB

Legal Director General, Employment with Economic Recovery and UK Governance (previously Wendy Hardaker CB, Interim Legal Director General, Directorate B)

The People Committee exercises strategic oversight of the People Strategy and the underpinning strategies within its remit, including the Diversity and Inclusion Strategy. The Committee reviews GLD’s key workforce risks and the action being taken to address them, particularly around legal resourcing, capacity and capability and pay and reward. Members also have an assurance role ensuring that GLD promotes health and wellbeing activities; supports activities to build leadership amongst staff; actively reviews the skills and capabilities needed to deliver outstanding legal and corporate services; and drives improvements in response to the People Survey.

The People Committee met 7 times in the financial year 2021-22. Over the past year, the Committee has overseen an array of work including: work to improve recruitment and retention; the implementation of a new Performance Management Framework; the Annual People Survey results (commissioning work accordingly); the further development and implementation of ‘Leadership the GLD Way’ (with a focus on how we hold each other to account for our leadership behaviours); the development of early talent (including Paralegal Career Pathways) and additional routes to legal qualification; and the modification of GLD’s Overseas Working Policy and other workforce policies and processes in response to COVID-19. Members also considered the effectiveness of the ranges of GLD’s resourcing approaches, and progress of the pay business case, on a regular basis.

The People Committee considers the bi-annual Health and Wellbeing Report to monitor and identify any risks related to activities within the Committee’s remit.

Audit and Risk Assurance Committee

Chair: Mike Green

Non-Executive Director (previously Tom Taylor, Non-Executive Director and Erica Handling, Non-Executive Director)

The Audit and Risk Assurance Committee (ARAC) reports directly to the Board. It supports the Accounting Officer by monitoring and reviewing the department’s risk, control and governance processes, and the associated assurance processes, including external and internal audit. The membership of the Committee includes one Non-Executive Director, in addition to the Chair, and an additional independent member, Jenny Rowe, the former Chief Executive of the Supreme Court.

The ARAC met 5 times in 2021-22. It considered the Annual Report and Accounts for 2020-21, and the External Auditors’ opinion. The Committee was satisfied with the quality of the external auditors’ work and their approach to their responsibilities.

The Committee also considered the findings contained in management letters and reports prepared by the Head of Internal Audit based on an Internal Audit Plan agreed in advance by the Committee and monitored the implementation of internal audit recommendations.

The ARAC was satisfied that assurances provided by the various internal audit reports met the requirements of the Board and the Accounting Officer. The Committee also considered the GLD position on fraud, risk management and security.

Committee Membership

Membership of each Committee is drawn from GLD’s Strategic Leadership Group and each has one of the Non- Executive Directors as a member (Mike Green – Operations Committee, Catherine Berney – People Committee, and Erica Handling – Legal Delivery Committee).

Board Members

Membership of the Board as at 31 March 2022 was as follows:

Executive Members:

• Susanna McGibbon - Permanent Secretary and Chief Executive
• Jessica de Mounteney - Legal Director General, Litigation with Justice and Security
• Elizabeth Hambley - Legal Director General, Commercial with Trade and International
• Mel Nebhrajani CB - Legal Director General, Employment with Economic Recovery and UK Governance
• Damian Paterson - Strategy, People and Culture Director

Jon Fundrey joined the Board as Finance, Operations and Digital Director on 3 May 2022.

Ex-officio Member:

• Douglas Wilson OBE - Director General, AGO

Co-opted Board Member:

• Lee John-Charles CBE - Deputy Legal Director, Litigation Group

Non-Executive Members:

Catherine Berney took up her appointment as Strategy, People and Culture lead Non-Executive Director (NED) on 15 October 2018 and is Chair of both the SCS Pay and Talent and Succession Committees. Catherine is a qualified organisational psychologist and solicitor, with a background in private practice and international finance. She has held a previous NED role for Arts Inform, an organisation that seeks to build links between the creative and cultural industries and the London schools system, in addition to chairing a local community association. Catherine leads a consultancy firm and brings considerable experience to GLD in leadership, strategic direction, communications and talent development.

Erica Handling joined on 29 October 2018, as lead NED for Legal Quality. Erica brings experience and expertise to GLD having worked as head of large legal departments in private practice and in-house. Her previous roles have included General Counsel for Europe at BlackRock and Barclays Investment Bank and Head of Securities and Structured Finance at Ashurst LLP. Erica combines her role at GLD with working as an executive coach and being a non-executive director on the Board of Petershill Partners plc (a listed company investing in private equity partnerships, managed by Goldman Sachs) and a trustee and chair of charities with a focus on women and/or criminal justice, including Spark Inside, St Giles Trust and Working Chance.

Mike Green joined GLD in January 2022 and is Chair of the Audit and Risk Assurance Committee. Mike is a Fellow of the Institute of Chartered Accountants in England and Wales and a graduate of the London School of Economics. He qualified as a chartered accountant with what is now KPMG and spent 11 years with the audit practice before a 20-year career in commercial television. Currently Mike is a Director, Audit Committee Chair and a member of the Service Quality Committee at Anchor Hanover, a housing association specialising in older people’s housing and operating over 100 care homes. Mike also spent 10 years as a non-executive director at an NHS Foundation Trust.

Board attendance

The Board met 9 times between April 2021 and March 2022, with attendance as follows:

Executive Members	Eligible to attend	Attended (to end March)
Susanna McGibbon	9	9
Stephen Braviner Roman (to November 2021)	7	7
Jessica de Mounteney (from March 2022)	1	1
Elizabeth Hambley	9	9
Wendy Hardaker CB (to September 2021)	5	5
Mel Nebhrajani CB (from October 2021)	4	4
Anna Sanders (to June 2021)	3	3
Damian Paterson (from July 2021)	5	5
Nick Payne (to February 2022)	8	8
Ex-Officio Member - Douglas Wilson OBE (from July 2021)	7	6
Co-opted Member - *Lee John- Charles CBE	9	9

Non-Executive Members	Eligible to attend	Attended (to end March)
Catherine Berney	9	9
Erica Handling	9	9
Tom Taylor (to July 2021)	4	4
Mike Green (from February 2022)	2	2

These refer to when meetings Members were eligible to attend were held, rather than membership. For example, Tom Taylor was officially a Board member until 24 September 2021, but he attended meetings until July 2021 because that was when the last meeting he was eligible to attend was held. He had left GLD and the Board by the September 2021 Board meeting.

*Lee John-Charles CBE (Deputy Legal Director, Litigation Group) was co-opted onto the Board in response to the increased nationwide and global focus on issues around ethnic minority representation and social justice, occasioned by a number of significant newsworthy events during the course of 2020. His appointment to the Board is an interim measure, pending a final decision on the approach GLD will take to the issue of ethnic minority representation at the highest levels of the department.

The Board’s work covers the 5 main areas expected by the Corporate Governance in Central Government Departments: Code of Good Practice:

Strategy – setting the vision;

• Commercial focus – scrutinising the allocation of resources to achieve plans; ensuring controls are in place to manage risk;
• Talented people – the Board has a People Strategy to help ensure that GLD has the capability to deliver and to meet current and future needs;
• Results focus – the Board agrees the annual business plan and monitors and manages performance against the plan; and
• Management information – the Board receives a bi-monthly dashboard containing clear, consistent and comparable performance information.

The Board’s performance

GLD adheres to centrally set standards of good governance practice for government departmental boards and follows the Board Effectiveness Evaluation process, recommended in guidance produced by the Cabinet Office.

We have continued to review what kind of effectiveness evaluation would best suit the needs of GLD throughout 2021-22, given the significant changes at Board level. During this time, we recruited a new Non-Executive Director (carrying a vacancy between September 2021 and January 2022) and made 3 new appointments to our Board. Planning work has begun to conduct a comprehensive effectiveness review in 2022.

Compliance with the Corporate Governance in Central Government Departments: Code of Good Practice

The “Corporate Governance in Central Government Departments: Code of Good Practice” applies primarily to ministerial departments. This means that the key provisions relating to the composition of boards do not apply to GLD; specifically the involvement of ministers and the requirement to have roughly equal numbers of ministers, senior civil servants, and Non-Executive Directors.

Management of interests and Business Appointments

GLD has a policy, published in our Staff Handbook, on outside activities and employment. The general principles are that official time must not be spent on any outside activity without the approval of the Head of Division. Individuals must not engage in any outside activity, which would in any way tend to impair their effectiveness in their official duties or be inconsistent with their position as civil servants, or as members of GLD.

No member of staff may carry out private legal work except, and subject to permission of the Treasury Solicitor, in relation to non-contentious family matters, or pro bono work.

Individuals must seek permission from the Head of HR, via a senior manager in their business area to ensure there is no risk in respect of conflict of interest with, or potential damage to the credibility of, the Government Legal Department before:

• taking any job or position, which might affect their official work directly or indirectly; or
• undertaking any outside work involving official information; or
• undertaking any work involving payment by another government department or agency on their own account.

Where permission is granted the relevant documentation is filed in the individual’s personnel folder.

There are strict rules in place for those responsible for procurement or management of contracts and on an annual basis all Directors are asked to complete a Declaration of Related Party Interests.

We have a policy on business interests and shareholdings, also published in our Staff Handbook. This states that there is no objection to civil servants investing in shareholdings unless the nature of their work is such as to require constraints on this. Individuals must not be involved in any work, which could affect the value of their private investments, or the value of those on which they give advice to others; nor must staff use information acquired in the course of their work to advance their private financial interests or those of others.

Individuals must declare to the Finance, Operations and Digital Director any business interests or shareholdings (including directorships) which they or members of their immediate family (spouse/partner and children) hold - to the extent to which they are aware of them - which they would be able to further as a result of their official position.

They must comply with any subsequent instructions from the Finance, Operations and Digital Director regarding the retention, disposal or management of such holdings. In line with Cabinet Office guidance, GLD will ensure that:

• All senior civil servants declare any relevant interests to the Permanent Secretary on at least an annual basis. This will include providing a ‘nil return’ should they have no relevant outside interests.

• Senior civil servants continue to declare any outside interests on appointment, or if their circumstances change, in real time.

• Returns are scrutinised within GLD by the Audit and Risk Assurance Committee, with assurance of this process set out in the Annual Report and Accounts, and an annual return is provided to the Cabinet Office, providing assurance that all outside interests are being managed appropriately.

• As part of or alongside our Annual Report and Accounts we will publish a register of relevant interests for all Members of the Departmental Board, including senior civil servants.

• When a civil servant is appointed, as part of the recruitment process the hiring manager is satisfied they can comply with the requirements of the Civil Service Code. The individual must ensure that any interests they do have are compliant with their obligations as a civil servant. If their employer considers there is any real or perceived conflict from their outside interests, the individual must resolve that conflict - for example, by giving up any outside employment.

• After a civil servant is appointed, they declare relevant private interests in real time to their line manager and, if necessary, senior management. They will be required to comply with any instructions from GLD relating to those interests. They will also be required to seek permission before taking up any outside engagement which might affect their work.

Business Appointments

The Audit and Risk Assurance Committee monitor compliance with the Business Appointment Rules, receiving an Annual Report from Human Resources.

In compliance with Business Appointment Rules, the department is transparent in the advice given to individual applications for senior staff, including special advisers. A summary of advice given is published at: https://www. gov.uk/government/publications/ago-gld-and-hmcpsibusiness-appointment-rules

Risk management

Risk management is carried out in accordance with HM Treasury risk management guidance – “The Orange Book”. Our strategic risks are also aligned to the risk categories in the Orange Book.

The ARAC provides a challenge function to the department’s risk management arrangements, including deep dive reviews, internal audit reviews and the assurance of processes.

Risk management is embedded at every level in the department by encouraging empowerment and delegation so that risks can be managed proactively by those with the local knowledge and experience, and who are held accountable for the effective management of those risks.

The process is to identify and evaluate a risk, determine an appropriate response, and actively manage the response to ensure that GLD’s exposure is limited to an acceptable level.

Strategic risks are agreed by the GLD Board and monitored by the ARAC, and each key strategic risk is owned by a Board Member. The risks and actions to mitigate them are reported monthly to the Executive Committee, and bimonthly to the Board. The strategic risks and the actions to mitigate them are detailed in the GLD business plan.

Risk profile

For GLD, COVID-19 has continued to add major challenges in terms of meeting the intense demands for legal services related to the outbreak, whilst managing the impact of the virus on our workforce, as we adapted to hybrid working and the use of new technology, while supporting the health and wellbeing of our people. The potential impact of these challenges, which also impacted on GLD’s ability to deliver business as usual, were recognised in GLD’s key strategic risks and mitigating actions, which are:

Risk Category	Risk Description	Plans and Mitigations
Strategy	We do not have an optimised performance and assurance system to monitor the implementatioof our Strategy and supporting sub-strategies.	An overarching Strategic Plan is in place with updates provided to the Executive Committee on a monthly basis. Sub-strategies have been developed and responsibilities have been assigned for agreed actions. The Committees monitor progress on relevant sub-strategies and actions.
Strategy	We do not prepare for significant external events which have the potential to have an adverse impact on the delivery of legal services to our clients or achieving full cost recovery.	We have a highly developed Business Continuity Plan which includes plans for critical systems and operations at a local divisonal level. The plans include an ICT Disaster Recovery Plan and are supported by an Incident Management Team and our remote working capability. In addition we have succession plans for critical roles to ensure our legal service is maintained.
Reputation	We damage the confidence and trust of our clients and/or the judiciary, by not meeting their expectations or delivering on commitments given to them.	We use a multi-aspect approach to managing this risk by ensuring the capability of our staff through appropriate training programmes, the development of general and specialist legal skills, utilisation of legal technologies and have appropriate legal quality assurance processes. In addition we have worked closely with the Attorney General’s Office to update the approach to advising on legal risk in Government and we have an overall client approach supported by local client care plans to help build and maintain the trust and confidence of clients. To manage demand for our services we have procured external panel firms and panel counsel.
Financial	We do not generate sufficient income to achieve full cost recovery and/or we breach one of our HM Treasury Control Totals.	Each year we undertake a comprehensive planning and budgeting process to determine the fee rates we need to charge to clients. The income, expenditure and activity trends are monitored throughout the year and this enables prompt action to be taken to bring spending in line with HM Treasury Control Totals.
People	We do not attract, recruit and retain diverse and sufficient people to deliver the breadth and quality of legal services required by our clients.	We are working to enhance our workforce planning process including regular meetings with senior management to ensure effective deployment of staff. There is ongoing resourcing activity to improve our recruitment processes and the candidate experience, and we have commissioned an external review of our resourcing approach. We continue to explore the creation of alternative routes to legal qualification via apprenticeships. We are working on the following initiatives to enhance attraction and improve retention: explore ways to improve pay and conditions; leadership work to ensure that managers engage their employees so that they see GLD as a great place to work; ensuring that staff have access to a range of Learning and Development opportunities; and implementing our Diversity and Inclusion Delivery Plan, Health and Wellbeing Action Plan and our Talent and Succession Framework. We are continuing to ensure access to external expertise via external counsel and panel firms.
People	We have insufficient leadership capability to inspire and empower our people to deliver the required levels of service and/or our strategic aims.	Our Leadership Framework, supported by a programme of learning and development, sets out clear leadership expectations. All managers have leadership objectives and are held to account through the Performance Management Framework. Our recruitment and promotion processes have been reviewed and updated to ensure we create a diverse leadership cadre.
Technology	We do not make the most effective tools consistently available to our people across the whole department which are necessary to deliver the required standards of service to our clients.	We are developing a Digital and Technology Strategy and are implementing the findings of the Legal Work Activity Analysis, which has informed the technology aspects of our Legal Knowledge, Capability and Innovation Strategy. These strategies are being developed in conjunction with the technology strands of our Business Transformation Programme. We are strengthening our innovation capability and culture and will adhere to our business case approval process to ensure appropriate prioritisation and value for money.
Security	We do not keep pace with emerging threats, or there is a failure of compliance, which results in harm, or sanctions, or has an adverse impact on our ability to deliver legal services to our clients.	We comply with the requirements of our Information Security Management System and meet minimum government security standards. We ensure all staff are appropriately security cleared and communicate securely with counsel and other third parties. In addition all staff complete mandatory annual information security and related training, and assurance is obtained through maintaining various ICT related certifications and accreditations.

Security and business continuity

Client information security remains critical and is assured by GLD’s adherence to Cabinet Office Minimum Security Standards (GovS 007), maintaining ISO 27001 certification, and Cyber Essentials Plus certification. Cyber resilience is maintained through comprehensive penetration testing, vulnerability management and protective monitoring policies, with all of our IT services on, or connected to the GLD network being monitored by the Security Incident Event Management (SIEM) appliance.

GLD continues to contribute to work carried out by the Cabinet Office on the wider security transformation agenda and is actively contributing to the government-wide security governance reviews in relation to National Security Vetting and the Document Classification System. We are additionally working with the National Cyber Security Centre to improve cyber security resilience. All staff have completed mandatory Information Security and GDPR training courses to ensure that they are fully aware of their responsibility to keep information secure.

GLD enjoys a high level of client satisfaction and it is essential that it is able to maintain its high quality service in all circumstances. Business continuity is assured through the maintenance of an ISO22301 aligned business continuity management system and a comprehensive suite of recovery plans. Incident management exercises are carried out and GLD’s disaster recovery facilities are tested on a regular basis. The GLD disaster recovery site has significant remote access capacity, resilience and security, which reduces the risk of service disruption should the GLD head office be unavailable. A complementary plan, based on and tested against a flu pandemic, was reviewed and updated at the start of the year, to assist the department’s crisis response to and subsequent management of operations during the COVID-19 pandemic. This was supported by divisional staff succession plans, again reviewed and updated in early 2022, the aims of which are to ensure all critical posts are adequately covered during periods of excess staff absence.

Whistleblowing

Responsibility for the operation of an effective whistleblowing policy and process within GLD is vested at Board level in the Director of Strategy, People and Culture (SPC) Damian Paterson. He is supported in this role by 3 SCS Nominated Officers, who act as a point of contact for GLD staff, outside their line management chain, for raising concerns. They also offer impartial support and advice to anyone raising a whistleblowing concern.

Assurance of GLD’s whistleblowing policy and processes is provided by GLD’s ARAC who review whistleblowing cases, identifying the lessons to be learned from them. The ARAC has considered quarterly reports on whistleblowing throughout 2021-22, with the Board receiving a verbal report from the Director of SPC in March 2021. In 2021- 22 one case potentially covered by GLD’s whistleblowing policies and procedures was raised and is under investigation.

GLD is absolutely committed to nurturing an environment where staff are aware of how to raise concerns about something they see or experience at work. This includes ensuring they feel able and supported in expressing grievances through the channels available to them, including where an issue may be classed as whistleblowing. The 2021 People Survey scores show that inclusion rates have increased 2% to 85%. 77% of respondents stated that they feel encouraged to speak up in the event they have serious concerns at work, 72% able to challenge inappropriate behaviour and 76% were confident that concerns raised under the Civil Service Code would be investigated properly.

The department will continue to explore ways to improve these results as part of its wider investment in our leadership, culture and staff awareness, building on our activities as part of Civil Service ‘Speak Up’ week in September 2021. This saw blogs signpost colleagues to relevant whistleblowing information pages on GLD’s intranet and highlighted contacts for the department’s Nominated Officers. The routes to raise a concern have also been highlighted during other activities and engagement events, including since the publication of the Gray update.

Effectiveness of the risk management and governance framework

Assurance is obtained from a range of sources, including the work of the Internal Auditors. In their Annual Assurance Report, which offers an opinion on the adequacy and effectiveness of risk management, control and governance, the Head of Internal Audit gave a moderate level of assurance. In his opinion, some improvements are required to enhance the adequacy and effectiveness of the framework of governance, risk management and control; plans are in place to take these recommendations forward.

Assurance on information handling is provided by the Senior Information Risk Owner, Nick Price CBE, Operations Director and Senior Security Advisor, supported by the Security Team.

GLD Directors provide an annual end of year Assurance Report highlighting any risks that crystallised during the year. These assurances have been reviewed by the ARAC. As part of the business planning process, the Permanent Secretary/Chief Executive holds Panel Reviews with all Executive Team Members to challenge their bids for resources.

At the end of each quarter, GLD conducts a formal forecasting exercise. GLD Directors are asked to review their resourcing priorities and relevant income and expenditure against budget, and to forecast their year-end position. This information enables the Executive Committee and the Board to identify areas of concern and, if necessary, to review and consider the allocation of resources in meeting GLD objectives. From quarter 2, it also enables consideration of potential in-year fee reductions and rebates/refunds, where a surplus is forecast, or increases if a deficit is forecast.

External assurance of GLD’s litigation activities is provided by the Law Society against the Lexcel Standard, and GLD’s information systems are assured against the Lloyd’s Register Quality Assurance Ltd standard ISO27001. These processes highlighted no issues of significance to the corporate health or operations of GLD in 2021-22.