Swancommunitybank.org.uk



Swan Credit Union

Business Plan

October 2017 – September 2020

CONTENTS

Executive Summary 2

The Plan: 2

Who we are: 3

Our purpose: 3

Our values: 3

Our vision: 4

Our goals: 4

Key achievements in the last 3 years: 7

Financial Projections: 8

Annex 1: Profile of our Communities 9

Annex 2 Member Survey Results 11

Annex 3: Implementation Plan 13

Annex 4: Financial Projections 15

Annex 5: 2017 Review of Risks 17

Executive Summary:

Swan Credit Union is in a transitional phase, emerging from a local organisation in Milton Keynes using volunteers and handling cash transactions into a professionally-run online operation covering large areas of Buckinghamshire and Oxfordshire. We are decreasingly reliant on grant income to survive, and we will continue to cover the funding of our operational costs from revenue.

Growth over the last four years has been rapid and substantial; however, we are mindful of economic uncertainty ahead and therefore will be appropriately cautious with our forecasting.

Nevertheless, it is our firm intention to build on the progress to date, to further control our costs and mitigate operational risks. Whether this is by mergers and acquisitions or by organic growth, the Board will continue to ensure that our culture of good business practice is maintained.

With over 1500 members, £500K of loans generating nearly £100K of revenue, and assets of £1 million, Swan Credit Union is developing into a substantial not-for-profit business, and looking after our members better than ever.

Key objectives for the three years to 2020 are:

• Continue to grow our membership and activities with assets reaching £1.6 million

• Fund all our operating costs from income as well as one of the two development and expansion officer posts.

• Continue to pay members a dividend on their savings (subject to adequate levels of reserves);

• Continue to offer affordable and ethical loans to our members, saving them money on interest payments compared to high street and internet lenders.

• Continue to provide an excellent and friendly service to all our members

The Plan:

As required by the regulators and in line with best business practice, Swan Credit Union maintains a rolling Business Plan, which is updated and agreed by the Board every year.

The Business Plan is founded on and must be consistent with the agreed aims and objectives of the Credit Union as set out in our Rules and our Policy and Procedures manual.

The Business Plan is underpinned by detailed financial projections for each of the next three years. These projections are built up on the basis of the Assumptions. A summary of the projections is included in this document. The full set of projections and assumptions have been made available to the Board.

The regulators also require the Credit Union to regularly review the risks it faces in conducting its business. We have chosen to make this an integral part of our business plan. The outcome of this years’ review of risks is shown at Annex 5.

The overall business aims over the next three years are: to continue to grow our membership; to become financially self-sufficient; to be able to pay dividends to our members, while continuing to provide safe savings and affordable credit.

This Plan addresses our regulatory obligations, and speaks both to our existing members and to the public at large.

Who we are:

Swan Credit Union trades as a group of local community banks. It is member-owned and run, providing ethical and affordable savings and loans in North Buckinghamshire, Milton Keynes and South Oxfordshire. The four community banks: Milton Keynes, Aylesbury Vale, Thame and Didcot are branches of Swan Credit Union, which offers saving and loan services to our members that are a real alternative to High Street banks and to internet and doorstep lenders. Background information about our areas of operation can be found in Annex 1.

In company law, credit unions are financial cooperatives, which operate on a not-for-profit basis and are authorised by the Prudential Regulation Authority (PRA) and regulated by the Financial Conduct Authority and the PRA (FRN417717). Our common bond consists of the areas covered by Milton Keynes Council, Aylesbury Vale District Council and Oxfordshire County Council.

Our purpose:

We exist to provide caring, community banking, offering safe savings and ethical loans.

What this means is:

Caring: We are an organisation that recognises that you have good and hard times. We are an organisation for all our members, and there are no barriers or fees to join us. We provide safe, reliable and affordable savings and loans to all, and in hard times such as loss of a job or income we can provide more affordable loans than most other financial organisations to help you get by without incurring high levels of debt. We are there to help you, help with maybe a deposit account to help you save, a loan to help you secure accommodation or to buy something you need, or advice to help you manage your money more effectively.

We will do this in a way that recognises who you are and treats you as an individual.

Community: We are run by our members, people who live or work in the areas we serve, for the benefit of you and all our members and the neighbourhoods where you and we live. We want you to feel that you genuinely belong and can talk to us.

Banking: Our business is your money. Looking after it carefully, and making it work hard for you and all our members.

Our values:

These values are foundational principles which underpin everything we do, and which are a reference for everything we aspire to do. They lead our vision and guide our strategy. These are:

Openness

Trust

Fairness

Mutuality

Openness We will be totally transparent with you in what we do. We’ll tell you our running costs, what we are doing with your savings, why we have made the decisions we have, what the regulators think of us, and more. Obviously we can’t tell you about another member, nor would we tell anyone about you, but if you want to know anything else – just ask.

Trust We will do four things to help build the trust between us:

We will say what we mean and mean what we say;

We will do what we say we are going to do;

We will ensure we know what we are doing, and if we aren’t sure we will find out and learn: and

We will care for you as individuals and work with you to build a sustainable and successful Community Bank.

Fairness Different people mean different things by fairness; some believe it means treating everybody the same and others think it means treating people according to their particular personal circumstances.

We will do both. We will give everyone the opportunity to talk to us about their personal needs and will seek to come up with a solution that balances your needs and the needs of all our members and the communities we serve.

Mutuality Swan and our Community Banks are run by members for the benefit of the members. There is no them. We are you.

Our vision:

Looking ahead, it is essential to have a picture in mind of what we want to be in five or ten years’ time. This helps us to imagine a future reality we can work towards. Our vision is this:

“By 2020 we want to be known in the communities we serve to be financially viable, and to be seen as a genuine alternative to commercial lenders.”

For years, Swan and other credit unions have been sustained by grant funding, principally from local Councils and some other community support agencies. With the squeeze on the public finances certain to last for some years, and as a matter of principle as well, it is vital for us to become self-sufficient. Essentially this means that we will cover all our normal operational costs from our own funds. We will therefore set our own goals and strategies that will increase our membership and extend the services we offer, while controlling our costs.

Our goals:

To be meaningful, goals must be SMART. This ensures we set objectives that are: Specific, Measurable, Achievable, Realistic and Timelined.

These goals are:

A: Increase our resources

B: Become better known

C: Create communities

D: Develop profitable products & services

E: Operate efficiently

For each one of these goals, we have a strategy to achieve it, and the detailed actions are shown in our Implementation Plan at Annex 3 which collectively forms the nuts and bolts of our Business Plan for at least the next three years.

A: Increase our resources

Challenges:

• We need more Board members and volunteers to avoid doubling-up of roles

• We would like more of a physical presence in Aylesbury and MK

• We need more payroll deduction business to fund planned growth

• We will add to our existing Expansion & Development staff

At its most basic level, we need to bring in more income from our business in order to fund the growth we want to see, and to cover the costs of ever-increasing regulatory requirements. Currently we are still reliant on grant funding to help us grow, and welcome though this is, we cannot, and do not wish to, assume this source of income will continue indefinitely.

This means we must both increase our number of members, but more particularly to increase the revenue from offering them financial products and services they want from us.

We have recently extended our Bond Area to include Oxfordshire so that we can support members in and around Didcot who fall outside the South Oxfordshire District Council area. We remain open to seeking opportunities for relevant collaboration (including mergers) with neighbouring Credit Unions, provided there would be a clear benefit to our members.

Alongside this financial need, we also must increase our resource of people. Alongside our Expansion & Development Officers, this will be made up of volunteers – whether as telephone canvassers, Community Bank Information Point staff, Community Bank Management Team members, Board members or in an internal governance role on our Supervisory Committee, for example.

B: Become better known

Challenges:

• While using both internet and telephone services to support members, we need to be more visible in our local communities

• Our marketing communications need some improvement, and we need to be better represented on social media

• We have a potential confusion of brands between the Community Banks and the Credit Union, and need to increase public awareness of CU’s

• We need a clearer understanding of our members’ requirements from us

We need to become better known both in the localities where we have a Community Bank, and within a competitive financial sector. For Swan Credit Union to succeed, it is important to have differentiated product ranges for it to stand out amongst the well-known corporate banks and building societies.

While a relatively low budget is a challenge for Swan Credit Union, it is prudent to make the most of low cost resources which can ultimately lead to the wide spread of the brand in the communities that we serve. Low cost examples that may benefit Swan Credit Union include:

• Take more advantage of free editorial and advertising in local communities, such as in business directories and local media

• Presence at high profile community events

• Increase visibility on highly populated social media sites

C: Create Communities

Challenges:

 

• We are not well-enough known in our local communities, and want to be recognised as part of an interconnected network of service providers.

• We need to continue building a greater understanding of what our members want from us.

• We need to create a sense of belonging among our local communities.

D: Develop profitable products & services

Challenges:

• We are operating in an economic climate where credit unions have never been more needed, and so must be able to respond promptly

• We need to develop our mission to be a successful and sustainable not-for-profit business

• We need to continually review our products and services that our members want, and generate sufficient income to meet our financial objectives.

E: Operate efficiently

Challenges:

• Control costs and maximize income

• Manage business risks effectively

• Meeting regulatory requirements

• Maintaining and developing our skills

• Surplus funds (from member savings) do not generate sufficient income to be profitable.

Financial viability requires us to generate enough from our services to cover the costs of those services and generate a surplus that means we can continue to grow the Credit Union, pay members a dividend, and maintain our capital ratios. Failure to do this would mean the Union would ultimately cease to function.

Key to this is careful risk management, principally with our lending and our bad debt levels, which have reduced significantly as a result of CUS’s good work in making affordable loans available and are within regulatory tolerance limits. That said, it is nevertheless important that we can meet our social aims as well as maintain low bad debt levels.

We need to manage our surplus funds more efficiently in terms of maximising investment income and possibly managing (reducing) the share balances of some of our ethical savers.

CUS, along with our marketing and business development activities, are also our largest cost. Their fees are calculated based on how successful we are and the proportion of CUS costs for which we are responsible. 2018-20 will see further increases in our costs as a result of our continuing growth trend.

As part of our operating review we have undertaken a detailed risk review and agreed strategies to accept, manage or mitigate the risks we have identified (see Annex 5).

Critically we will also ensure that throughout all of this we remain compliant and within all regulatory ratios and processes requirements. The Board is supported by an independent Supervisory Committee, which undertakes internal audit functions and to whom the Board is accountable.

We are also engaged in an ongoing training process for Board members and specific volunteers, and will continue to ensure we are appropriately skilled for the roles we undertake on your behalf.

Key achievements in the last 3 years:

Swan Credit Union has undergone a period of sustained and accelerating growth over the last three years, and has been working towards our target of self-sufficiency arising from business generation. We have been fortunate to have received a number of grants, which have enabled us to transition to an online operation and thereby gaining the benefit of significant increase in efficiency through our partners at Credit Union Solutions.

We have extended our Bond Area to include the county of Oxfordshire, but with a clear purpose to serve the parts of South Oxfordshire covered by the South Oxfordshire and Vale of White Horse District Councils.

We are benefitting from the activity of an Expansion & Development Officer covering our Buckinghamshire territory, initially funded from grants and now from revenue generation; we are in the process of recruiting for a similar role in South Oxon with grant funding committed for 3 years.

To support this strong growth performance, we have been extremely fortunate to have recruited a highly professional and experienced Board of Directors and Supervisory Committee. Within these teams are represented years of service in the financial sector, with many in or having held very senior positions. We are also constantly looking for ways to improve our skills and where needed to look for new talent.

Review of last 4yrs performance:

|Indicator |Y/E Sep 14 |Y/E Sep 15 |Y/E Sep 16 |Y/E Sep 17 |1Yr up % |

|Resident population |248,821 |174,137 |134,257 |557,215 |63,182,178 |

|Women (%) |50.5 |50.5 |50.8 |50.6 |50.9 |

|Median age |35 |40 |42 |39 |39 |

|Aged 60 and over (%) |16.4 |21.2 |24.6 |19.8 |22.4 |

|Non-white (%) |20.0 |10.4 |4.0 |13.2 |12.9 |

|Rented housing (households %) |35.3 |26.2 |24.7 |29.9 |34.5 |

|Limited by health or disability (%) |13.9 |13.6 |13.8 |13.7 |18.1 |

|Unpaid carers (%) |8.8 |9.5 |9.9 |9.3 |10.3 |

|No car or van, (households %) |18.9 |13.3 |11.6 |15.4 |26.0 |

Source: Population Census 2011: Summary Tables by Local Authority areas: Office for National Statistics

Milton Keynes has one of the youngest and fastest growing populations in the country, and it is the adult population under 60 who are the main users and beneficiaries of credit unions. In contrast South Oxfordshire has an older population, but this is likely to change with the planned expansion of Didcot to become the major town in the area.

MK has a greater percentage of its population from non- white and mixed race categories than the UK average. Our other two areas, especially South Oxfordshire, have lower percentages. A similar pattern emerges on housing tenure with a higher percentage of households in MK renting and lower percentages in our other two areas.

Probably due to its younger age range, MK has a smaller percentage than the UK with health or disabilities. Our other two areas are also low on this indicator possibly due to higher average incomes. A similar picture emerges for those providing unpaid care for family or friends and the percentages without access to a car or van.

Indices of Deprivation

|Category |Milton Keynes |Aylesbury Vale |South Oxfordshire |

|Local authority rank (out of 325) |164 |277 |309 |

|Local neighbourhoods in the worst 10% nationally |194 |0 |0 |

|Rank of above (out of 200) |129 |200 |200 |

|Population living in local neighbourhoods, among the worst 30% nationally |32,000 |4,000 |0 |

|Income level: local authority rank (1 = lowest) |129 |279 |315 |

|Local neighbourhoods with incomes in the worst 10% nationally |216 |0 |0 |

Source: English indices of deprivation 2015, Department for Communities and Local Government.

Milton Keynes has average deprivation scores when measured as a whole area, however it has many local neighbourhoods which feature in the worst 10% of local neighbourhoods throughout England. Our other two areas of operation do not score on these indicators. While no part of Buckinghamshire falls into the most deprived decile in England on the index of multiple deprivation, three LLSOAs in Aylesbury Vale fall into the second most deprived decile, ranking in the 19th and 20th percentiles.

Employment Statistics

|Category |Milton Keynes |Aylesbury Vale |South Oxfordshire |All Swan areas |

|Total employment (2015) - thousands |168.0 |75.2 |60.8 |304.0 |

| Public |23.5 |13.5 |7.4 |44.4 |

| Private |144.5 |61.7 |53.4 |259.6 |

|Number of jobs paying less than the living wage (2014) - |23 |10 |9 |42 |

|thousands | | | | |

|Local Employment units (2015) - number |6,730 |6,740 |5,955 |19,425 |

| Over 250 employees |60 |20 |20 |100 |

| From 50 to 250 |165 |80 |70 |315 |

| Less than 50 employees |6,405 |6,640 |5,865 |18,910 |

Sources: Business Register and Employment Survey 2015: Table 6, and Annual Hours and Earnings Survey 2014, Office for National Statistics

Our area has over 19,000 local employment units based on those responsible for VAT or PAYE returns. One hundred of these have over 250 employees and a further 315 have between 50 and 250 employees. These are the units we intend to target for recruitment to provide payroll deduction services to their staff.

Annex 2 Member Survey Results

The following charts are based on our last two member surveys in 2015 and 2016. The samples of about 100, are based on those who chose to reply and are therefore not necessarily fully representative of all our members. Nevertheless the age, sex and location of the samples are consistent with our full membership.

The main findings were:

1 More ethnic minority responses in 2016, possibly reflecting an increase in membership.

2 Big increase in those joining via the internet and in those contacting our back office by e-mail.

3 Big increase in those joining in order to take out a loan.

4 Continuing high levels of satisfaction with the service from our back office (80%+)

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Annex 3: Implementation Plan

Part 1: Previous goals achieved

Note: Column 2 refers to Strategic Goals reference A-E.

|Plan date |Ref |SMART Goal |Comment |

|Oct 2015 |E |Have set out new budget for 2015-18 and draft budgets for the |Achieved |

| | |following 2 yrs | |

|Oct 2015 |E |Have reviewed our service and its cost from CUS |Periodically reviewed, also done |

| | | |for 2016/17 |

|Mar 2016 |A |Recruit 3 more Board Members, incl one for Marketing & 1 SupCom member|Achieved |

|Mar 2016 |B |Have conducted email & phone surveys to gather member perceptions of |Sample of members phoned in 2016 |

| | |Swan & CB’s |& 2 web surveys conducted in 2017|

| | | |(see Annex 2). |

|May 2016 |B |Have a clear marketing plan, linking with CUS |Partial progress |

|Sep 2016 |D |Use survey data to review products & services |Done |

|Oct 2016 |D |Have researched similar CU’s to see what products they are offering |Partial progress |

| | |which might help us | |

|Dec 2016 |E |Have reviewed cost/benefit of services and explored cost savings |Ongoing. New joint audit of CUS |

| | |within CUS group |group will assist in this. |

|Oct 2017 |D |Be able to offer members a current account/debit card |Engage Card now in use |

Part 2: Implementation Plan 2018

|Plan date |Ref |SMART Goal |Action |

|Jan 2018 |A |Recruit full-time Expansion & Development Officer for S Oxfordshire |Chair |

|Mar 2018 |A |Recruit at least one new Board member |Chair |

|May 2018 |B |Have a clear marketing plan, linking with CUS |Marketing Director |

|May 2018 |D |Explore business and secured loans |TBA |

|June 2018 |A |Have volunteer-staffed Information Points in all areas |Aylesbury IP to be set up by lead|

| | | |Director |

|July 2018 |C |Member survey |Marketing Director |

|Jul 2018 |A |All CBMT’s to have local marketing strategies & budgets |CB Lead Directors |

|Sep 2018 |E |Explore higher return-on-investment opportunities for some of Swan’s |Treasurer |

| | |cash reserves. | |

|Sep 2018 |D |Have engaged with min 1 community scheme for other products & services|Board |

| | |(eg bulk energy) | |

|Sep 2018 |D |Further review of loan policy, products & services including those |Credit Committee |

| | |offered by other CU’s | |

|Sep 2018 |A |Active member target: 1346 (+8% on 2017) |Board |

|Sep 2018 |A |Gross asset net of bad debt provision: £1.3M (+34% on 2017) |Board |

|Sep 2018 |A |Have functioning CB Management Teams in all areas |Lead CB Directors |

|Sep 2018 |A |Consider merging Didcot & Thame CB structures |S Ox Directors |

|Sep 2018 |C |Swan to have an active online community, with provision for local CB |Marketing Director |

| | |presence | |

|Sep 2018 |E |Have reviewed cost/benefit of services and explored cost savings |3 SMR’s |

| | |within CUS group | |

|Sep 2018 |A |Have a functioning smartphone app |IT Director |

|Sep 2018 |B |CBMT’s to be meeting regularly with at least 2 community leaders or |CB Lead Directors |

| | |stakeholders per quarter | |

|Sep 2018 |A |All Swan regular operational costs (with the exception of the |Treasurer |

| | |grant-funded EDO) to be covered from loan income | |

|Sep 2020 |A |S Oxfordshire to have reached 200 members and have £60K on loan |S Ox Directors |

| |

Annex 4: Financial Projections 2017-2020

|STANDARD PROJECTION | | | | |12 month growth rates |

|  |Outturn |Projection |Projection |Projection |2017-18 |

| |2016-17 |2017-18 |2018-19 |2019-20 | |

|Dividends due (£000) |6.1 |0.0 |0.0 |0.0 | |

|  |Base Year |Projection |Projection |Projection 2019-20 |2017-18 |

| |2016-17 |2017-18 |2018-19 | | |

|Strategic Risks |

|Failure to find sufficient Board and |4 |2 |8 |A realistic implementation plan will be required, taking account of |Chair to include a revised implementation plan with the |

|volunteer resources to implement the | | | |limited resources. The impact is scored low on the assumption that we |Business plan by end December 2017. |

|strategic objectives of the Business Plan | | | |would continue to expand, if more slowly than hoped for. | |

|Failure to meet our financial targets in the|3 |3 |9 |Risk tolerance and risk appetite levels will be included in the 2017 |Board, monthly |

|business plan, such as growth of loans, | | | |risk review The figures are reviewed monthly as part of the Management | |

|financial surplus and capital adequacy | | | |Information (MI) and actions taken when necessary. We are continuing to | |

|ratios. | | | |make our Business Plan more rigorous and realistic with specific actions| |

| | | | |and accountabilities. | |

|Poor loan decisions, and poor management of |2 |4 |8 |Risk tolerance and appetite levels will be included in the 2017 Risk |The Credit Committee (designated Board member) to obtain |

|bad debts. | | | |Review. We have agreed procedures but we lack an overall strategy that |more information on lending decisions to assist evaluation|

| | | | |ensures control of bad debts, without compromising our lending targets. |(e.g. refusal rates). |

| | | | |CUS independent internal audit report on their lending activities was |He should develop a bad debt strategy, taking account of |

| | | | |positive with no new risks identified. |the internal audit report. |

|Over complex range of loan products |2 |2 |4 |The recently introduced and revised product range is relatively simple. |Product range to be kept under review by the Credit |

| | | | |and are in any case changed as circumstances and opportunities change |Committee. |

|Financial Risks |

|Fraud and/or theft of funds from Swan by |1 |5 |5 |Two signatures are now required for all BACS payments. |Treasurer to keep procedures and controls under review. |

|staff, volunteers and/or members. | | | | | |

|Excessive and poorly managed expenditure - |2 |2 |4 |Management Information, including expenditure, is presented monthly and |Monthly MI to continue to be improved by CUS/Treasurer |

|above budget. | | | |subject to Board scrutiny. The format of the MI has improved in recent | |

| | | | |months | |

|Use of Swan for money laundering purposes. |3 |2 |6 |There are documented manual and automated processes in place which are |MLRO needs to review large transactions more often than |

| | | | |subject to audit. First line of responsibility rests with CUS and the |once per year |

| | | | |designated Board member for money laundering (MLRO). | |

|Erroneous payment out of funds due to |3 |2 |6 |This has happened in the past. External payment of funds is subject to a|Treasurer to keep controls and safeguards under review |

|clerical errors | | | |two person process - input and authorisation apart from BACS payments. | |

|Grant income falls below business plan |1 |2 |2 |The Business Plan does not include any grant income not already promised|Grant Officer to monitor and report to Board. |

|expectations | | | |by grant providers, so this risk is minimal. | |

|Regulatory Risks |

|Changes in regulatory requirements |4 |3 |12 |This is happening more frequently e.g. New requirements for Politically |The three Board members designated as “Senior Managers” |

| | | | |Exposed Persons (PEPs) from 2017. We must maintain awareness of |take lead responsibility and should alert the Board |

| | | | |potential and actual changes, and attend ABCUL and regulatory briefings.|whenever necessary. |

|Failure to meet existing regulatory |3 |4 |12 |As these become more complex and multi layered, the chances of a |The Secretary, Treasurer and the SupCom must all be |

|requirements, leading to potential censure | | | |significant breach are increasing. |responsible for alerting the Board to actual and potential|

|and or fines. | | | |The new series of independent internal audit reports on CUS are already |breaches. |

| | | | |helping to ensure that requirements are met. |Chair to ensure that the internal audit programme covers |

| | | | | |all essential regulatory areas. |

|Inadequate administration of DPA/GDPR |3 |4 |12 |Swan to audit CUS’s policies, procedures and IT processes, and |Secretary, Senior Information Risk Officer (SIRO) and |

|protocols leading to erroneous retention, | | | |incorporate this requirement in a revised contract and Service Level |Supervisory Committee |

|error or loss of a person’s Personal | | | |Agreement. | |

|Identifiable Information | | | | | |

|External Risks | | | | | |

|Other Credit Unions start operating in our |4 |2 |8 |Northampton and Berkshire have recently extended their common bonds to |Board to work cooperatively with all neighbouring credit |

|Common Bond Area | | | |cover parts of our area, but there is no evidence that they are actively|unions. |

| | | | |recruiting and competing with us. Focus on what we do best. | |

|National or local level rumours about |1 |5 |5 |We have a policy in place to permit us to hold back on withdrawals for |Secretary to be prepared to put out a press release |

|financial/bank stability lead to an | | | |up to 60 days. Half of our 12 month investments roll over every 6 |reassuring members about security of funds. |

|excessive level of withdrawals. | | | |months. This should give us time to liquidate funds to meet demand, but | |

| | | | |we are considering changing this to a 4 month rolling period. | |

| | | | | | |

|Operational Risks |

|Failure of CUS to maintain operations and |4 |2 |8 |Frequent departures from SLA by CUS, although mostly on issues of lower |Senior Management Team to hold occasional bilaterals with |

|records to agreed standards in Service Level| | | |priority. Planned expansion and more training of CUS staff should help. |CUS to review performance and changes to requirements |

|Agreement | | | |We need to encourage a more professional and business-like approach to |Chair to invite CUS to attend Board meetings at least |

| | | | |their clients by CUS. |every 3 months and to ensure that the Client Group |

| | | | | |meetings are also held quarterly. |

|Poor customer service from our back office |3 |3 |9 |The CUS telephone service and difficulties of getting through have been | |

|service provider CUS. | | | |seen as a problem by the Board. The CUS telephone computer system says |New (third) member survey to be conducted in 2018 |

| | | | |that only 5% of calls fail to get though to their staff. | |

| | | | |The independent internal audit report did not find any major problems | |

| | | | |with customer records and processing. The 2016 member survey shows 80% | |

| | | | |of members are happy. The third survey is underway. We have a documented| |

| | | | |complaints procedure and only two recent cases. | |

|Inadequate supervision of staff by the Board|2 |3 |6 |Clear job descriptions and lines of management have been put in place. |Monthly line management meetings to continue to be held |

| | | | | |with each member of staff. |

| | | | | |Local Community Bank management teams to meet quarterly |

| | | | | |with all volunteers |

|Inadequate supervision of volunteers by the|3 |3 |9 |Clear job descriptions and lines of management have been put in place. |Designated Board member or Staff member to meet face to |

|Board | | | | |face with each volunteer at least every quarter. |

| | | | | |Local Community Bank management teams to meet with |

| | | | | |volunteers at least once a year. |

|Inadequate financial or operational |3 |4 |12 |CUS has been very reliant on its CEO, but a deputy CEO has recently been|Chair to discuss at bilateral meetings with CUS and at |

|stability of CUS as a company, due to poor | | | |appointed. Swan needs to ensure its back office provision going forward |quarterly Client Group meetings |

|management or inadequate resources. | | | |is robust. | |

| | | | |CUS reserves are negligible and should be increased. | |

|Reputational Risks |

|Criminal or unethical behaviour by |2 |3 |6 |Policy of letting potential Board members work as volunteers for a |Secretary to ensure agreed procedures and checks are |

|individual Board members or staff. | | | |period helps to ensure their commitment and suitability. |followed |

| | | | |The new regulatory vetting procedure for Board members also helps. | |

|Complaints entering the public domain |4 |2 |8 |Negative public comment on social media has already happened, though |Complaints Officer to ensure regulatory requirements are |

|leading to negative publicity and an adverse| | | |with no noticeable effect as yet. We have a complaints officer and as |met including a quick response to complaints. |

|impact on our reputation. | | | |documented complaints process, which has an appeals / review system. | |

|Commercial links to an organisation not |2 |2 |4 |Suppliers of services and formal partnership agreements are all subject |Treasurer, Secretary and Board |

|considered as consistent with our ethical | | | |to Board approval. | |

|policies. | | | |All board members must declare conflicts of interest | |

|Abuse/misuse of our social media sites by |3 |2 |6 |The Board member with responsibility for social media operates a |Board member with Social Media responsibilities to keep |

|members or the public (Facebook and twitter)| | | |“policing” policy to ensure any abusive, unethical, or otherwise |under review |

| | | | |undesirable posts are removed. This policy has been added to our manual.| |

|IT risks |

|Software supplier (Kesho), goes out of |2 |4 |8 |Keep alternative software providers such as ‘Progress’ under review. |Board member with IT responsibilities to keep up-to-date |

|business or loses key staff. | | | |‘Curtains’ would continue to function for a period of time even without |with options and continue to press Kesho when service |

| | | | |Kesho. However our members area and on-line joining procedure are |levels fall below our contract level (e.g. members’ |

| | | | |totally reliant on Kesho. |website downtime). |

|Inadequate cyber or data security leading to|4 |3 |12 |There was a virus attack (ransomware) in 2016 and remote access to the |Board member with IT responsibilities to keep CUS IT |

|breaches of the Data Protection Act or GDPR | | | |server has been discontinued. CUS have also put in place encryption to |systems and controls under review. Also investigate a safe|

|regulations, or virus infections. | | | |avoid hacking or leaks of e-mails with confidential member details. |way of permitting Board members to access the Curtains |

| | | | | |database. |

|Inadequate IT systems leading to excessive |2 |3 |6 |Kesho contract and service standards but these have not been very |Board member with IT responsibilities to CUS and IT |

|downtime and inefficiencies in admin | | | |effective so far. |officer We need to press Kesho for a more robust upgrade |

|procedures. | | | | |of the Curtains software and its implementation at CUS. |

| | | | | |Ditto for the website and Customer services from Kesho. |

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Ethnic status

Source of information on joining

Main reason for joining

Main method of contact

Quality of Service

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