Risk Management Policy

See Purpose.

To clarify Data Migrators’ policy on Risk Management, and the processes that support that policy.

This Policy applies to all Company officers, employees, partners, and contractors to facilities and systems controlled by the Company. The policy extends to all current and future activities, and new opportunities.

Where necessary, more detailed risk management policies and procedures will be developed to cover specific areas of the Company’s operations, such as financial management and business management.

Data Migrators recognises the need for risk management to feature as a consideration in strategic and operational planning, day-to-day management and decision making at all levels in the organisation.

Data Migrators is committed to managing and minimising risk by identifying, analysing, evaluating and treating exposures that may impact on the Company achieving its objectives and/or the continued efficiency and effectiveness of its operations. Data Migrators will incorporate risk management into its organisational planning and decision-making processes. Risk management must also be included as a consideration in sectional and operational planning as a delegated line management responsibility. Data Migrators staff must implement risk management according to relevant legislative requirements and appropriate risk management standards.

Data Migrators is committed to ensuring that all staff, particularly those with management, advisory, and decision making responsibilities, obtain a sound understanding of the principles of risk management and the requisite skills to implement risk management effectively.

Data Migrators will regularly monitor and review the progress being made in developing an appropriate culture of risk management and the effective implementation of risk management strategies throughout the organisation as a basis for continuous improvement.

Risk must first and foremost be managed at the corporate level as part of the Company’s good governance and corporate management processes. Risk management is considered an integral part of all management and decision-making functions within Data Migrators. The responsibility for the identification of risk and the implementation of control strategies and follow up remains a delegated line management responsibility. All stakeholders have a significant role in the management of risk. This role may range from initially identifying and reporting risks associated with their own jobs to participation in the risk management process. Data Migrators Directors will facilitate the introduction and monitoring of risk management into key areas of Data Migrators’ activities

Risk must first and foremost be managed at the corporate level as part of Data Migrators’ good governance and corporate management processes. This process, coordinated and facilitated by Data Migrators Directors, will involve the following key steps:

Risk management is a delegated line management responsibility. It is the responsibility of all line managers to continually monitor their areas of responsibility to ensure that risks are identified and managed. Line managers should ensure that a contribution is made to the whole-of-Company risk management process, on behalf of their areas of responsibility, that identifies risks at all levels.

The sharing of documented responses to risks and knowledge of risk management principles and procedures will be fostered between line managers to ensure consistency across the Company.

On an annual basis, line managers should review all activities to ensure that any unacceptable risk exposures are identified and managed at an appropriate level. All operational sections will be required to report on risk management as part of the institution’s annual operational and resource management process.

Each employee or other stakeholder throughout the Company has a role in the risk management process and is responsible for actively participating in the risk management process as appropriate to their position within the Company.

In addition to the risks that already exist, the Company is continually exposed to new risks particularly from the introduction of new activities. The new risks should be incorporated into the initial planning and assessment processes conducted prior to undertaking the activity and, subsequently, into the annual risk management assessment at the appropriate level(s) of activity and management.

The principles of risk management shall be applied to all areas of risk exposure, insurable and non-insurable, and shall include, but not be limited to the following areas:

Data Migrators Directors will regularly monitor and review the progress being made in developing an appropriate culture of risk management and the effective implementation of risk management strategies throughout the organisation.

Through its monitoring, review and reporting functions, Data Migrators’ Directors will ensure that the Company maintains a consistent approach to its assessment of acceptable risk.

Each stage of the risk management process shall be appropriately documented. The extent of documentation required is dependent on the nature of the risk. Documentation will be controlled so as to inform part of an auditable quality management process.

A representation and compliance statement should be provided by each project manager as formal acknowledgement of their responsibility to comply with risk management policies and procedures. Each employee should have included in their Position Description a responsibility for risk management, and Annual Performance Appraisals should include an appropriate assessment thereof.

Management shall ensure that staff have available to them appropriate information and training opportunities in risk management as appropriate to their position and role within Data Migrators.

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