Archived: Risk-based audit and evaluation plan: 2013-14 to 2017-18: chapter 7


Appendix C. Summary of Key Risks and Considerations

Context:

For planning purposes, AEB conducts an annual independent assessment of key risks and other planning considerations (e.g. priorities or events of significance, materiality of sensitivity) related to both program and environmental priorities and as well as operational and managerial objectives. The overall assessment approach and methodology is summarized in the report (section 3.2) and included consideration of various sources of information (e.g. MAF assessments, Corporate risk profile, RPP/DPR, prior audits/evaluations) and consultations with senior executives.

The following table presents AEB’s updated list of highest risks and considerations for 2013-14 planning purposes, in accordance with MAF elements. The table contains the following acronyms to identify, where appropriate, the principal sources of information:

  • CKM = Consultation and Knowledge Management
  • CRP = Corporate Risk Profile
  • MAF = Management Accountability Framework

Key Risks and Considerations

(by Key MAF Elements)

1.         Policy and Programs

Strategic Outcome 1: Canada’s natural environment is conserved and restored for present and future generations

1.1          EC is late developing some of the SARA recovery strategies/plans and must demonstrate effective due diligence in addressing the backlog (CKM). Refer also to CESD audits on biodiversity and species at risks.

Strategic Outcome 2: Canadians are equipped to make informed decision on changing weather, water and climate conditions

               Risks identified through the CRP were related to enabling/support services. No direct program risks

Strategic Outcome 3: Threats to Canadians and their environment from pollution are minimized

1.2          The increasing workload needed to develop regulations and also implement the world class regulator initiative have created capacity and planning challenges. Previous plans may not be met (CKM & CRP).

1.3          Recent changes to the Environmental Assessment Act may impact both the ability of EC to respond to increased workload requirements associated with number of larger development projects, and the roles and responsibilities in meeting these requirements (CKM & CRP).

1.4          The required consistency of Enforcement activities across regions and the effectiveness of operations management, including enforcement procedures and training (CKM). Refer also to previous CESD audit.

1.5          Assessing the toxicity of substances under Chemical Management Plan Phase 2 (CMP2) and identifying related remedial plans are likely to be more challenging and complex to coordinate/manage than under CMP1.  CMP 1 lessons learned could alleviate upcoming challenges (CKM).

1.6          The capacity to manage the necessary activities pertaining to numerous international agreements to which EC is a party, and to demonstrate that EC is complying with commitments and achieving results under international agreements. Also consideration of previous CESD audits (CKM).

1.7          Likely increasing challenges in coordinating interdependencies and priorities within EC such as to continue to ensure effective science support to programs (CKM, CRP). Considerations identified included:

  • Interactions / coordination in support of CMP;
  • Operational labs support to Enforcement;
  • Evolving role or demands for science to support enforcement priorities (e.g. training); and
  • Meteorological dependencies on water/hydrological science.

1.8          Restructuration of the environmental emergencies program (also highlighted in CESD audit).

2.         Citizen Focused Service

               No specific or significant risk identified (or presented under risk management / stewardship).

3.         Governance and Strategic Directions

3.1          The effectiveness of EC's new governance framework in coordinating priorities, activities and decisions across programs may not be fully understood or communicated, in context that the framework was recently updated. Governance audit/review also a requirement of the internal audit policy (CKM).

3.2          The effectiveness of integrated and operational planning (both corporately and within branches) has been challenging and different planning initiatives were introduced in recent years. Integrated planning is a government priority and some CESD reports have identified related issues (CKM).

4.         Risk Management

4.1          Ongoing challenges identified in fully incorporating risk with management processes (CKM).

4.2          The governance related to IT services and the coordination with Shared Services Canada is a concern for some managers, especially in ensuring the timeliness and continuity of program operations (CKM).

4.3          Increasing cyber-threats and related security risks (CKM).

5.         Results and Performance

5.1          Further opportunities and challenges identified with EC's performance indicators related to the FSDS, and possible need for better integration of various performance management approaches across EC (e.g. CESI, RPP/DPR, FSDS). Also previous CESD audits/reviews of FSDS (CKM).

6.         Stewardship

6.1          Combination of possible issues/risks related to the effectiveness of the overall financial management framework and financial information, including: 

  • Implementation of a new financial management framework and service delivery model (CKM);
  • Lack of information and forecasts in support of financial management (e.g. year-end lapses; CKM);
  • Potential changes to financial processes/controls from different initiatives and requirements; and
  • Review of core expenditure controls (TBS requirement).

6.2          Ability of EC to realign its priorities and resources and fully implement DRAP within the timeframe established. This risk was diminished following the CRP review and update (CRP).

6.3          Ensuring effective governance and project management to enable a successful implementation of the complex SAP financial system (e.g. involves major system and business processes changes, significant resources over multiple years, key external interdependencies). Notable efforts were invested in past similar initiatives with limited results. Also OCG previously noted issues with EC's DFMS plan (CKM, MAF).

6.4          OCG identified issues through the last MAF assessment related to EC's financial statements (compliance with standards and guidance) and with the Annex on Internal Controls over Financial Reporting (e.g. clarity, completeness and progress against plan).

6.5          Adequacy of IM and management of available data, in the context of loss of corporate knowledge (retirements). Also concerns regarding the effective implementation of IM and the "CGDocs" initiative (CKM).

6.6          Ongoing issues with the efficiency of the contracting/procurement processes impacting programs/operations (CKM). About 20% of EC expenses go through procurement, and significant changes are planned for the function (e.g. service standards, e-requisition, new delegation). Also planned OCG horizontal audit.

6.7          Effectiveness of capital assets management, maintenance and renewal, and asset life-cycle management have significant impact on program objectives (CKM).

6.8          Current rationalization of accommodation and real property may not generate all planned savings and could impact the delivery of programs (CKM).

6.9          Effective management / coordination of EC's consultations with external stakeholders to support the delivery of programs (CKM, CRP). Also refer to previous evaluation reports and findings.

6.10        Risks related to effective emergency management and business continuity planning to maintain critical services (CKM, CRP). In addition, the Strategic Emergency Management Plan was revised.

6.11        Risks related to the management of interdependencies and horizontal engagement between branches, including enablers, may negatively impact key programs or services (CKM, CRP).

7.         People

7.1          Efficiency of the staffing and classification processes may not provide the necessary timely support to programs and operations (CKM, CRP). Related considerations:

  • New EC service standards were put in place;
  • 2011 PSC audit found issues with staffing documentation, priority appointments and monitoring;
  • Staffing identified as opportunity for improvement in the MAF assessment (MAF).

7.2          Potential shortage of employees with specific skills, knowledge and experience required to deliver programs, and ability of programs to maintain adequate capacity with increasing departures (CKM & CRP).

7.3          Performance and Talent Management has been identified as an opportunity for improvement in the MAF assessment (MAF).

7.4          The Department Staffing Accountability Report (DSAR) was identified as an opportunity for improvement in the MAF assessment (MAF).

7.5          Recent challenges and issues related to the management and control of personal information were recently identified (CKM).

8.         Public Service Values

8.1          Evolving requirements for EC to be organized to properly prevent, coordinate and investigate/remediate potential fraud, or other related or similar incidents (CKM). TBS guidance and new internal audit professional standards related to fraud risk management/assessment.

9.         Accountability

               No specific or significant risk identified (other than those identified in other sections).

10.       Learning, Innovation and Change Management

               No specific or significant risk identified (other than those identified in other sections).

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