REG - LSL Property ServPLC - PRELIMINARY ANNOUNCEMENT <Origin Href="QuoteRef">LSL.L</Origin> - Part 2
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determination of risk appetite and management or mitigation of risks in
line with risk appetite tolerances;
c. assessment of prospects and viability;
d. review of effectiveness of the risk management and internal control
systems; and
e. going concern confirmation (for LSL's going concern disclosure see the
Report of the Directors).
During the year, the Directors carried out a robust assessment of the
principal risks facing the Group, including those that threaten the business
model, future performance, solvency or liquidity. The Directors believe that
the assessment which has been completed is appropriate to the complexity, size
and circumstances of the Group, which is a matter of judgmentof the Board and
has been supported by the Management Teams.
The Directors also carried out a risk appetite assessment exercise which
involved the evaluation of continually evolving aspects of risk management.
During 2016, this included the capturing of anticipated impacts following the
EU referendum on the residential housing market and the articulation of
established 'conduct risk' routines used to support the delivery of
appropriate customer outcomes. These aspects are included in the principal
risks and uncertainties summarised in this Report.
The identified risks may change over time due to changes in business models,
performance, strategy, operational processes and the stage of development of
the Group in its business cycle as well as with changes in the external
environment. This robust assessment is focused on the principal risks and it
differs from the review of the effectiveness of the systems of risk management
and internal controls.
In accordance with the requirements of the Code this Report includes
descriptions of principal risks together with a high level explanation of how
they are being managed or mitigated. This includes clear descriptions of the
risks together with an evaluation of the likelihood of a typical risk event
crystallising and its possible impact. Mitigating steps and any significant
changes to specific areas of risk are also referred to within the tabular
summary.
As noted above, this robust analysis of principal risks has also contributed
to the Group's viability statement which is set included the Report of the
Directors. The Directors have also considered the impact if risks coincide,
namely a combination of non-principal risks could potentially represent a
single compound principal risk.
The Group also faces other risks which, although important and subject to
regular review, have been assessed as less significant and are not listed in
this statement. This may include some risks which are not currently known to
the Group or that LSL currently deems as immaterial, or were included in
previous Annual Report and Accounts and through changes in external factors
and careful management, are no longer deemed to be as material to the Group as
a whole.
However, these risks may individually or cumulatively also have a material
adverse effect together with other risk factors which are beyond the direct
control of LSL, and may have a material adverse impact on LSL's business,
results of operations and/or financial condition. The risk management
framework and procedures in place can only provide reasonable but not absolute
assurance that the principal risks and uncertainties are managed to an
acceptable level.
Further information relating to how LSL managed these risks and uncertainties
during 2016 is set out in the Audit Committee Report (Internal Controls).
Principal Risk and Uncertainties
Risk Description Mitigation
Strategic:
1 UK housing market Groupperformanceisintrinsicallylinkedtothe overallperformanceoftheUKhousingmarket (includingsubsets - e.g. primeCentralLondon). The market is also impacted by changes in the global political and economic environments (e.g. EU Referendum outcome). • Daily, weekly andmonthlymonitoringof tradingandmarket performancedata.•
Marketshare,productmixandsegmentationinitiatives.• Development of counter-cyclical
income and recurring revenue streams.• Responsive investment and cost control
measures during the housing market cycle.• Investment in teams to delivery strategic
projects.• BalancedUK-widegeographicalspread.• Monitoringofwidermacro-economic and
political developments.
2 New UK housing market entrants Traditionalbusinessmodelsforproperty servicesareexposedincreasinglytonew businessmodelsandtechnological advancements(e.g.online/hybrid estate agents,AutomatedValuationModels and automated financial services operating models). • Competitor and industrybenchmarking.• Development of strategies in response to
market disrupters.• Externalconsultativesupportasnecessary.• Monitoring of
potential acquisitions and joint venture opportunities.•
Servicedeliveryenhancementsandexperimentation.• Infrastructure investment, upgrading
and consolidation of core operating systems.• Marketinginitiatives.•
Staffincentiveschemes.
3 Acquisitions and growth initiatives Realisingappropriatetargetsforacquisitionand majorprojectinitiatives,includingdeliveryof appraisals,duediligenceand integration/implementationrequirements. • Definedpreand post-acquisition reportingto theBoard and Audit Committee.•
Structuredauthoritylevels.• Responsive flexing of risk appetite during the housing
market cycle.• Flexible resource pool to support acquisition and integration
activities teams.• Externalconsultativesupportasnecessary.•
Establishedintegrationplanningmethodology.• Post-acquisitionandpost-implementation
reviews.• RiskandInternal Auditengagements.
Sales/distribution:
4 Professional services Exposureto major PI claimsarising from any lapsesinsurveyingandvaluation practices. • Robustframeworkandmonitoringroutinestomaintain valuationaccuracy.•
Dedicatedsurveyingriskteam.• Timelydatacaptureofallclaimsandassociatedtrends.•
Utilisationoftechnologytomonitorvaluationtrendsand triggeralerts.• RiskandInternal
Auditreviews.• Experiencedclaimshandlingpersonnelsupportedbylegal experts.•
Culturepromotingeffectivesalesconductandopenlinesof communicationwithclients.• Board
-levelauthoritiesforPIclaimssettlementpayments
andgovernanceofunderlyingclaimshandlingand accountingprocesses.
5 Client Contracts Theperformanceofthe Estate Agency and Surveyingbusinessesare dependent on securingandretainingkeycontracts (e.g. lenders, portfolio landlords and house builders). • Customeroutcomefocusedforumsandinitiatives.•
Designatedseniormembersofstaffwithresponsibilityfor relationshipmanagement.• Ongoing
investment in resources, technology and service standardsto ensure LSL has the
capacitytomeetserviceleveldemands.• Targetedmarketing and training events.•
Monitoring of client dependency and compliance with contractual requirements.•
Robust control framework supporting the risk profiling of prospective clients,
contract renewals and the quality of professional services.• Dedicatedin-houseLegal
Services and Claims Management teams• Risk&InternalAudit reviews.
Operations:
6. Information technology infrastructure TheGrouphasvariedoperationswhichrequire arobustITinfrastructure.TheITenvironment needstoremainadaptabletosupportgrowth initiatives,harnesstechnologicaladvancements andcounterbusinesscontinuitythreats, includingmaliciousandcyberrelatedattacks. • BoardlevelIT governance,policiesandinitiatives.• Focus on innovation within the
Group's strategy.• Dedicatedin-houseITteams.•
Maintenanceofinfrastructuretomaintaineffectiveservice delivery.• On
-goingITinvestment and development programme.• Implementable business continuity
and disaster recovery solutions.• Monitoring of compliance with relevant
contractual and regulatoryrequirements.• Inter-GroupITforums.•
Externalconsultativesupportasnecessary.• RiskandInternal Auditreviews.
7. Information security Groupoperationsinvolvetheprocessingofhigh volumesofpersonaldata,withpotentialfor unintended data lossand exposureto increasing levelsofexternalcyber-crime. • LSLInformationSecurity and Governance Group and Group IT Director in place. •
DedicatedLSLInformationSecuritypersonnel.• Groupdata protectionpolicies in
place andtraining delivered.• Advice obtained from In house legal and external
advisers as appropriate.• Trackingofdataassets/datasharing,inlinewithauthority
levels.• Penetrationtestingprogramme.• Benchmarking versus best practice
standards - e.g. ISO27001.• Implementation of regulatory changes - e.g. General
Data Protection Regulation.• Secondandthird-linerisk-basedreviews.
8. Regulatory and compliance Relationshipswithregulatorsandcompliance withlegalandregulatoryrequirements. Any compliance breaches could result in sanctions and reputational damage (e.g. prosecutions or fines). Regulatory and compliance risk extends to oversightofstandardsadoptedby businesspartners (e.g.franchises, appointed representatives,joint ventures and minority investments). The market and business operations are also impacted by regulatory reforms (e.g. Housing White Paper) which may have an effect on Group revenue and expenditures. Regulatory costs, fees and charges continue to grow due to the rising funding requirements of the Financial Services Compensation Scheme. • Top-down culture focused on fairness, transparency and
successfulcustomeroutcomes.• Opendialoguewithregulatorsandmonitoringofemerging
developments and regulatory reforms.• Groupriskframeworkpolicyincorporatinga'three
-linesof defence'model totrackcompliancewithregulations.• Grouppolicies including
ethics (e.g.whistleblowingstructuresand anti-fraud and anti-bribery policies) and
employee welfare.• Group-wide health and safety arrangements to ensure the welfare
of employees and visitors to Group premises.• Group-levelforumswithregulatoryfocus
and oversight (e.g. FSMC, FSRC and Information Security and Governance Group).•
Dedicated compliance teams in higher risk/regulated functions.• EvolutionofIT
systemsto strengthenoversightroutines.•
Responsivecomplaintstrackingofanyemergingthemes.• In-house Legal Services team,
with external consultativesupportwhenneeded.• GroupRiskandInternal Auditreviews.
People:
9. Employees Securingandretainingkeystrategicpopulation and controlling attrition in key business critical areas, ensuringtheeffectivemanagementof personnelstandardsacrossvariedGroup businesses. • OversightbyLSLRemunerationandNominations Committees.•
Groupremunerationpoliciesandincentiveschemesto retainkeystrategicpopulation.• Regular
benchmarkingandappraisalsof senior management.• Successionplanningreviews and
targeted reviews in some areas.• Dedicatedin-houserecruitmentteam.• Targeted
retention and recruitment initiatives.• StaffsurveysandGroupHRinitiativesto focus on
attrition,improvestaff morale,relieveareasofpressureandimproveoperational
efficiencies.• Group-wideHRITsystems.•
Monitoringofstatutoryrequirementsanddevelopments.• Employee policies and monitoring
framework (e.g. health and safety).• Cultureoftransparency,clearGrouppoliciesand
whistleblowingproceduresto enable staffto confidentiallyraiseconcerns.
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