Risk Management Policy and Risk Management Strategy
Section 1 - Scoping
Risk Management Policy and Risk Management Strategy
10/07/2025
Alanna Sloan – Assurance and Risk Manager
Kieron Gallagher – Head of Governance, Risk and Resilience
Yes, no other relevant impact assessments identified.
Section 2 - Screening
The aim of SEPA’s Risk Management Policy is to outline why we must manage risk at SEPA, and to set the standards and roles and responsibilities across the organisation in relation to the management of risk.
The aim of SEPA’s risk management strategy is to set out how we will effectively manage risk, either potential threats or missed opportunities, which may stand in the way of the organisation achieving its objectives.
The strategy articulates our vision, risk objectives, risk appetite approach and sets out a roadmap to demonstrate how we will introduce the components of our new risk management framework.
Both the Risk Management Policy and the Risk Management Strategy relate to equality and human rights because all colleagues in SEPA are expected to follow this policy and manage risk as per the methodology set out in the framework giving everyone the opportunity to raise potential risks they have identified regardless of job role.
SEPA’s Equality Outcomes 2022-2026
Outcome 1 – We have increased the number of people from currently underrepresented groups in our applicants, our staff and those who progress within the organisation.
Outcome 2 – People with lived experience of inequality, related to a protected characteristic or socioeconomic status, access and use SEPA’s services without barriers.
Outcome 3 – Staff with lived experience of inequality and barriers, and with a wide variety of needs, feel listened to and respected as SEPA meets those needs.
Outcome 4 – We have decreased our gender pay gap and occupational segregation related to gender, disability, and ethnicity.
Yes, it relates to Outcome 3. All SEPA colleagues need to be able to access this information in an accessible manner.
Yes. The Risk Management Policy sets out why SEPA should have good risk management in place. A positive risk culture will be an enabler for SEPA to achieve its strategic objectives, protect colleagues, business assets and reputation whilst ensuring financial sustainability. The Risk Management Strategy is the roadmap detailing how SEPA will achieve this.
The main stakeholders that will be impacted by the Risk Management Policy and Strategy are colleagues across SEPA. All colleagues will be subject to the Policy however the Strategy will mainly be used by risk champions, heads of functions, the Corporate Leadership Team and the Audit, Risk and Assurance Committee because it outlines the approach of risk management at SEPA.
We will engage with these main stakeholders via internal communications, training via teams, engagement sessions, papers to Corporate Leadership Team and Audit, Risk and Assurance Committee.
Not applicable, as risk management is an existing internal process applicable to all colleagues, the new policy and strategy documents are also applicable to all colleagues.
Amongst your group of stakeholders are there any people who belong to the protected characteristic groups listed below who may be impacted, either positively or negatively, or do you believe there is a neutral impact?
Consider the three needs of the general duty for each Protected Characteristic in turn.
Table 1 - Public Sector Equality Duty - Screening tool
| Eliminate discrimination, harassment and victimisation and other conduct prohibited under the Equality Act | Advance equal opportunities between people who have a protected characteristic and those who do not | Foster good relations between people who have a protected characteristic and those who do not |
|---|---|---|---|
Age | Neutral | Neutral | Neutral |
Disability | Negative | Neutral | Neutral |
Gender reassignment | Neutral | Neutral | Neutral |
Marriage / Civil partnership | Neutral | Neutral | Neutral |
Pregnancy / Maternity | Neutral | Neutral | Neutral |
Race | Neutral | Neutral | Neutral |
Religion / Belief | Neutral | Neutral | Neutral |
Sex | Neutral | Neutral | Neutral |
Sexual orientation | Neutral | Neutral | Neutral |
No
SEPA as a public authority is obliged to ensure that our decisions and actions align with the fundamental rights and freedoms enshrined in the European Convention of Human Rights.
Human Rights: Human Lives - A Guide to the Human Rights Act for Public Authorities
Table 2 - Human Rights consideration
Human Rights Act Article | Yes | No |
|---|---|---|
Article 2: Right to life |
| x |
Article 3: Prohibition of torture |
| x |
Article 4: Prohibition of slavery and forced labour |
| x |
Article 5: Right to liberty and security |
| x |
Article 6: Right to a fair trial |
| x |
Article 7: No punishment without law |
| x |
Article 8: Right to respect for private and family |
| x |
Article 9: Freedom of thought, conscience, and religion |
| x |
Article 10: Freedom of expression |
| x |
Article 11: Freedom of assembly and association |
| x |
Article 12: Right to marry |
| x |
Article 13: Right to an effective remedy |
| x |
Article 14: Prohibition of discrimination |
| x |
Protocol 1, Article 1: Protection of property |
| x |
Protocol 1, Article 2: Right to education |
| x |
Protocol 1, Article 3: Right to free elections |
| x |
Section 3 - Full Assessment
Eliminate unlawful conduct
Advance equality of opportunity
Foster good relations
It will have no impact on SEPA’s ability to comply with the three elements of the Public Sector Equality Duty.
It’s potentially relevant to all protected characteristic groups because it is relevant to all colleagues.
Once the policy and strategy are approved, it will be helpful to engage with SEPA’s Digital Lived Experience group to get feedback regarding its accessibility for those with the disabled protected characteristic.
Yes.
The implementation of the risk management policy and strategy will give colleagues a route for expressing their thoughts and knowledge on emerging threats and opportunities for SEPA depending on the type of work they do for the organisation.
There is the potential for negative impact on people with a disability if we do not create our documentation and training materials in an accessible format.
Accessibility – We will ensure that the Risk Management Policy and Strategy documents and any associated materials are created using the accessibility guidelines set out by SEPA communications team.
The Policy and Strategy is for all colleagues to access at SEPA. Once they have been approved, we can engage with the Digital Lived Experience group to ensure they are accessible for all colleagues and use the accessibility tool on Microsoft Word.
There will always be a member of the Assurance and Risk team available to answer any questions, provide training or address concerns.
Include any further evidence gathering and external engagement that is required to demonstrate that you are giving ‘due regard’ to the equality duty of eliminating discrimination, promoting equality of opportunity, and fostering good relations.
To make this decision I used the following information:
Dos and don’ts on designing for accessibility – Accessibility in government
Sepa internal guidance on digital document accessibility and equality & human rights
No further evidence gathering or external engagement required because this will be an internal document. If that changes, this impact assessment will be revisited.
Section 4 - Continuous monitoring and improvement
Having considered the actual and potential impacts, you can decide what needs to happen next. There are four options, select the one that is appropriate to your findings and provide any supporting information you have for that decision.
Option 2: Adjust the policy / practice
This involves taking steps to:
remove any barriers, to better advance equality or to foster good relations
minimise any restriction of Convention rights or freedoms
It may be possible to remove or change the aspect of the policy that creates any negative or unwanted impact. You should describe additional measures which could be taken to reduce or mitigate any potential negative impact.
We will ensure the policy and strategy is accessible to all colleagues. It will be available internally and once approved, we will engage with SEPA’s Digital Lived Experience group and use the accessibility tool on Microsoft Word to ensure any accessibility issues are identified and resolved.
15/09/2026
Section 5 - Sign off
30/07/2025
Yes