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Policy paper

Framework agreement between DHSC and the Human Fertilisation and Embryology Authority 2026 to 2029

Published 16 July 2026

© Crown copyright 2026

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This publication is available at https://www.gov.uk/government/publications/framework-agreement-between-dhsc-and-the-human-fertilisation-and-embryology-authority-2026-to-2029/framework-agreement-between-dhsc-and-the-human-fertilisation-and-embryology-authority-2026-to-2029

Introduction

This framework agreement has been agreed between the Department of Health and Social Care (DHSC) and the Human Fertilisation and Embryology Authority (HFEA) in accordance with HM Treasury’s (HMT) Managing public money (MPM) handbook (as updated from time to time) and has been approved by HMT.

The framework agreement sets out:

  • the broad governance framework within which HFEA and DHSC operate
  • HFEA’s core responsibilities
  • the governance and accountability framework that applies between the roles of DHSC and HFEA
  • how the day-to-day relationship works in practice, including in relation to governance and financial matters

The document does not convey any legal powers or responsibilities, but all parties agree to operate within its terms. 

References to HFEA include all its subsidiaries and joint ventures that are classified to the public sector and central government for national accounts purposes. If HFEA establishes a subsidiary or joint venture, there shall be a document setting out the arrangements between it and HFEA, agreed with DHSC.

Copies of the document and any subsequent amendments have been placed in the libraries of both Houses of Parliament and made available to members of the public on HFEA’s website and on GOV.UK.

This framework agreement should be reviewed and updated at least every 3 years unless there are exceptional reasons that render this inappropriate that have been agreed with HMT and the principal accounting officer of DHSC. The latest date for review and updating of this document is May 2029.

Objectives

DHSC and HFEA share the common objective of:

  • ensuring the delivery of safe, ethical and effective treatment to fertility patients
  • ensuring consistent outcomes and appropriate support for fertility patients
  • continuing to support improving standards through evidence

To achieve this, HFEA and DHSC will work together in recognition of each other’s roles and areas of expertise, providing an effective environment for HFEA to achieve its objectives through the promotion of partnership and trust and ensuring that HFEA also supports the strategic aims and objectives of DHSC and wider government as a whole.

Classification

HFEA has been classified as a central government organisation by the Office for National Statistics and HMT classifications team.

It has been administratively classified by Cabinet Office as a non-departmental public body (NDPB).

Purposes, powers and duties, and aims

Purposes

HFEA was established under the Human Fertilisation and Embryology Act 1990 (the HFE Act). Its purposes are set out in section 8 of that act.

Powers and duties

HFEA’s powers and duties stem from sections 8 and 8ZA of the HFE Act.

HFEA’s statutory duties and functions are to:

  • regulate the provision of certain fertility treatments, related services and the conduct of research involving the use of human embryos, as set out in the HFE Act
  • license and inspect establishments carrying out these activities
  • maintain a code of practice setting out guidance for the proper conduct of these activities
  • maintain a register of all treatment services provided by licensed establishments to named patients and their outcomes. The register also contains details of all gamete and embryo donors
  • discharge other statutory functions in relation to information and advice

Aims

HFEA’s strategic aims are set out in the HFEA strategy for 2025 to 2028. These are summarised across 2 themes:

  • theme 1 - regulating a changing environment:
    • to effectively regulate a changing fertility section
    • to continue to increase the availability and benefit of our data for patients, clinics and researchers
    • to ensure that HFEA responds well to issues related to donation
    • to make a difference on issues that matter to patients
  • theme 2 - supporting scientific and medical innovation:
    • to ensure the safe regulation of emerging new science and technology, under a clear ethical framework
    • to prepare for the ways in which artificial intelligence (AI) and its future potential is likely to impact on the sector and HFEA
    • to inform and advise government in relation to new developments and their regulation

Governance and accountability

HFEA shall operate corporate governance arrangements that, so far as is practicable and in the light of the other provisions of this framework agreement or as otherwise may be mutually agreed, accord with good corporate governance practice and applicable regulatory requirements and expectations.

In particular (but without limitation), HFEA will: 

  • comply with the principles and provisions of the Corporate governance code for central government departments (as amended and updated from time to time) to the extent appropriate and in line with their statutory duties or specify and explain any non-compliance in its annual report
  • comply with MPM
  • in line with MPM have regard to the relevant Functional standards as appropriate and in particular those concerning finance, commercial and counter fraud
  • take into account the codes of good practice and guidance set out in annex A of this framework agreement, as they apply to arm’s length bodies (ALBs)
  • in line with MPM annex 3.1, provide an account of corporate governance in its annual governance statement, including the board’s assessment of its compliance with the code with explanations of any material departures. To the extent that HFEA does intend to materially depart from the code, DHSC should be notified in advance and their agreement sought to this approach

Role of DHSC

The responsible minister

The Secretary of State for Health and Social Care will account for HFEA on all matters concerning HFEA in Parliament. This includes being accountable to Parliament in relation to the functions and performance of HFEA.

The Secretary of State’s statutory powers in respect of HFEA are set out in the HFE Act. These are:

  • to appoint the non-executive directors of the HFEA board (‘the Authority’), including the chair and the deputy chair
  • to set objectives for HFEA in line with statutory duties
  • to determine the funding and resourcing of HFEA
  • to hold HFEA to account

Through the exercise of these powers, the minister:

  • is responsible for the policy framework within which HFEA operates
  • provides guidance and direction to ensure the strategic aims and objectives of HFEA are consistent with those of DHSC and government
  • approves the HFEA corporate plan and business plan
  • has power of appointment in relation to all members of the Authority (including the chair and deputy chair) in line with the Governance Code on Public Appointments

Appointments to the Authority

The chief executive of HFEA is appointed by the Authority at the discretion of the chair and with the approval of the Secretary of State.

The minister shall have the following appointment and approval rights in relation to the Authority:

  • the chair, the deputy char and other members of the Authority are appointed by the Secretary of State under schedule 1, paragraph 4 of the HFE Act
  • all such appointments are subject to the Public Appointments Order in Council and as such must comply with the Governance Code on Public Appointments
  • all such appointments should have regard to the principle that appointments should reflect the diversity of the society in which we live, and appointments should be made taking account of the need to appoint boards which include a balance of skills and backgrounds

As set out in schedule 1, paragraph 4A of the HFE Act, the following persons are disqualified from being appointed as chair or deputy chair of the Authority:

  • any person who is, or has been, a medical practitioner registered under the Medical Act 1983 (whether fully, provisionally or with limited registration), or under any repealed enactment from which a provision of that act is derived
  • any person who is, or has been, concerned with keeping or using gametes or embryos outside the body
  • any person who is, or has been, directly concerned with commissioning or funding any research involving such keeping or use, or who has actively participated in any decision to do so

At least one-third but fewer than half of the other members of the Authority must meet one of the above criteria. At least one member must fall within each of the first 2 criteria above.

Other ministerial powers and responsibilities

The minister is also responsible for:

  • the policy framework within which HFEA operates
  • setting the performance framework within which HFEA operates
  • matters regarding spending approvals, acquisitions, disposals and joint ventures in line with delegations as set out in the delegation letter
  • such other matters as may be appropriate and proportionate

The principal accounting officer

The principal accounting officer (PAO) is the Permanent Secretary of DHSC.

The PAO of DHSC designates the chief executive as HFEA’s accounting officer (AO) and ensures they are fully aware of their responsibilities. The PAO issues a letter appointing the AO, setting out their responsibilities and delegated authorities.

The respective responsibilities of the PAO and AOs are set out in chapter 3 of MPM.

The PAO is accountable to Parliament for the issue of grant-in-aid to HFEA. The PAO, usually through the sponsor team, is also responsible for advising the Secretary of State on:

  • an appropriate framework of objectives and targets for HFEA in the light of DHSC’s wider strategic aims and priorities
  • an appropriate budget for HFEA in the light of DHSC’s overall public expenditure priorities
  • how well HFEA is achieving its strategic objectives and whether it is delivering value for money
  • the exercise of the ministers’ statutory responsibilities concerning HFEA

The PAO through the sponsor team is also responsible for ensuring arrangements are in place to:

  • monitor HFEA’s activities and performance
  • address significant problems in HFEA, making such interventions as are judged necessary
  • periodically, and at such frequency as is proportionate to the level of risk, carry out an assessment of the risks both to DHSC and HFEA’s objectives and activities in line with the wider departmental risk assessment process
  • inform HFEA of relevant government policy in a timely manner
  • bring ministerial or departmental concerns about the activities of HFEA to the full Authority and, as appropriate, to the DHSC board requiring explanations and assurances that appropriate action has been taken

The senior departmental sponsor

A director is appointed as the senior departmental sponsor who acts as HFEA’s designated, consistent point of contact within DHSC and manages their overall relationship with DHSC. The senior departmental sponsor acts as the link at executive level between HFEA and senior officials of DHSC, and with ministers. They are the main source of advice to the responsible minister on the discharge of their responsibilities in respect of HFEA. They also support the PAO on their responsibilities towards HFEA.

While the senior departmental sponsor role is facilitative and recognises the need for direct engagement between HFEA and other parts of DHSC and ministers, it also supports the responsible minister and the PAO in holding HFEA to account.

The senior departmental sponsor is also responsible for approving HFEA’s annual business plan and annual report and accounts and agreeing the objectives for and reviewing the contribution of the chair of HFEA.

The sponsor team

The HFEA sponsor team in DHSC (part of the health ethics branch) supports the senior departmental sponsor and is the primary contact for HFEA. The sponsor team liaises regularly with counterparts in HFEA to support effective corporate relationships and co-ordinate assurance and accountability functions.

Officials of the sponsor team will liaise regularly with HFEA officials to review:

  • performance against plans
  • achievement against targets
  • expenditure against its departmental expenditure limit and annual managed expenditure allocations

HFEA and the sponsor team will hold quarterly accountability meetings. The sponsor team will also take the opportunity to explain wider policy developments that might have an impact on HFEA.

HFEA will provide information to DHSC including:

  • quarterly business scorecards that show performance against agreed key performance indicators and monthly budgetary performance returns to finance
  • quarterly updates on the monthly strategic risk register
  • annual governance statement

The process in place to enable DHSC and HFEA to review performance include:

  • quarterly accountability meetings between HFEA and the sponsor team
  • attendance of officials from DHSC, as observers, of the full authority and HFEA Audit and Governance Committee

HFEA will also prepare an annual report of the 12 months ending on 31 March each year, setting out:

  • the Authority’s activities
  • how it has discharged its statutory duties
  • what progress it has made towards its objectives
  • activities HFEA proposes to undertake in the succeeding 12-month period

Resolution of disputes between HFEA and DHSC

Any disputes between DHSC and HFEA will be resolved in as timely a manner as possible. DHSC and HFEA will seek to resolve any disputes through an informal process in the first instance. If this is not possible, then a formal process, overseen by the senior sponsor, will be used to resolve the issue. Failing this, the senior sponsor will ask the relevant policy director general to oversee the dispute. They may then choose to ask the Permanent Secretary to nominate a non-executive member of DHSC’s board to review the dispute, mediate with both sides and reach an outcome, in consultation with the Secretary of State.

Freedom of Information requests

Where a request for information is received by either party under the Freedom of Information Act 2000, or the Data Protection Act 1998 or Data Protection Act 2018, the party receiving the request will consult with the other party prior to any disclosure of information that may affect the other party’s responsibilities.

HFEA shall provide a quarterly update to the sponsor on the existence of any active litigation and any threatened or reasonably anticipated litigation. The parties acknowledge the importance of ensuring that legal risks are communicated appropriately to the sponsor in a timely manner.

In respect of each substantial piece of litigation involving HFEA, the parties will agree a litigation protocol which will include specific provisions to ensure appropriate and timely reporting on the status of the litigation and the protection of legally privileged information transmitted to the sponsor to facilitate this. Until such time as a protocol is agreed, the parties will ensure that:

  • material developments in the litigation are communicated to the sponsor in an appropriate and timely manner
  • legally privileged documents and information are clearly marked as such
  • individual employees handling the legally privileged documents are familiar with principles to which they must adhere to protect legal privilege
  • circulation of privileged information within government occurs only as necessary

HFEA governance structure

Chief executive

Responsibilities as accounting officer 

The chief executive as AO is personally responsible for:

  • safeguarding the public funds for which they have charge
  • ensuring propriety, regularity, value for money and feasibility in the handling of those public funds
  • the day-to-day operations and management of HFEA

In addition, they should ensure that HFEA as a whole is run on the basis of the standards, in terms of governance, decision-making and financial management that are set out in box 3.1 of MPM. These responsibilities include the below and those that are set in the AO appointment letter issued by the PAO of DHSC.

Responsibilities for accounting to Parliament and the public 

The chief executive’s responsibilities to Parliament and the public include:

  • signing the accounts and ensuring that proper records are kept relating to the accounts and that the accounts are properly prepared and presented in accordance with any directions issued by the Secretary of State
  • preparing and signing a governance statement covering corporate governance, risk management and oversight of any local responsibilities, for inclusion in the annual report and accounts
  • ensuring that effective procedures for handling complaints about HFEA in accordance with Parliamentary and Health Service Ombudsman’s Principles of Good Complaint Handling are established and made widely known within HFEA and published on HFEA’s website
  • acting in accordance with the terms of MPM and other instructions and guidance issued from time to time by DHSC, HMT and Cabinet Office
  • ensuring that as part of the above compliance they are familiar with and act in accordance with:
    • any governing legislation
    • this framework agreement
    • any delegation letter issued to body
    • any elements of any settlement letter issued to DHSC that is relevant to the operation of HFEA
    • any separate settlement letter that is issued to HFEA from DHSC
  • ensuring they have appropriate internal mechanisms for the monitoring, governance and external reporting regarding compliance with any conditions arising from the above documents
  • giving evidence, normally with the PAO, when summoned before the Public Accounts Committee on HFEA’s stewardship of public funds

Responsibilities to DHSC

The chief executive’s responsibilities to DHSC include:

  • establishing, in agreement with DHSC, HFEA’s corporate and business plans in the light of DHSC’s wider strategic aims and agreed priorities
  • informing DHSC of progress in helping to achieve DHSC’s policy objectives and in demonstrating how resources are being used to achieve those objectives
  • ensuring that:
    • timely forecasts and monitoring information on performance and finance are provided to DHSC
    • DHSC is notified promptly if over or under spends are likely and that corrective action is taken
    • any significant problems, whether financial or otherwise, and whether detected by internal audit or by other means, are notified to DHSC in a timely fashion

Responsibilities to the Authority  

The chief executive is responsible for:  

  • advising the Authority on the discharge of the Authority’s responsibilities as set out in this document, in the founding legislation and in any other relevant instructions and guidance that may be issued from time to time
  • advising the Authority on HFEA’s performance compared with its aims and objectives
  • ensuring that financial considerations are taken fully into account by the Authority at all stages in reaching and executing its decisions, and that financial appraisal techniques are followed

Managing conflicts 

The chief executive should follow the advice and direction of the Authority, except in very exceptional circumstances with a clear cut and transparent rationale for not doing so. 

If the Authority, or its chair, is contemplating a course of action involving a transaction which the chief executive considers would infringe the requirements of propriety or regularity or does not represent prudent or economical administration, efficiency or effectiveness, is of questionable feasibility or is unethical, the chief executive in their role as AO should reject that course of action and ensure that the Authority has a full opportunity to discuss the rationale for that rejection.

Such conflicts should be brought to the attention of the PAO and the responsible minister as soon as possible.   

Furthermore, and if agreed with the responsible minister, the AO must write a letter of justification to the chair of the Authority setting out the rationale for not following the advice and recommendation of the Authority and copy that letter to the HMT officer of accounts. 

If the responsible minister agrees with the proposed course of action of the Authority, it may be appropriate for the minister to direct the AO in the manner as set out in MPM paragraph 3.6.6 onwards. 

HFEA authority

Composition of the Authority

HFEA will have a board, called the HFEA Authority, in line with good standards of corporate governance and as set out in its establishing statute and in guidance as set out in annex A. The role of the Authority shall be:

  • to run HFEA
  • to deliver:
    • its objectives, in accordance with the purposes as set out above
    • its statutory, regulatory and common law duties
    • its responsibilities under this framework agreement

The detailed responsibilities of the Authority shall be set out in the terms of reference. Remuneration of the Authority will be disclosed in line with the guidance in the government financial reporting manual (FReM). 

The Authority will consist of a chair and a deputy chair, and any such number of non-executive members that the Secretary of State appoints, as set out in section 5 of the HFE Act. The non-executive members will have a balance of skills and experience appropriate to directing HFEA’s business. The chair and chief executive decide the balance of skills across the Authority, which may include members who have experience of the fertility sector as medical practitioners, in operational delivery, lawyers, ethicists, patient advocates, clinical geneticist, biomedical scientists, financial services, communications and performance management. The Authority will include a member who is an appropriately qualified finance director as described in annex 4.1 of MPM. 

Authority committees

The Authority may set up such committees as necessary for it to fulfil its functions. As is detailed below, at a minimum, this should include an Audit and Risk Committee chaired by an independent and appropriately qualified non-executive member of the Authority.  

While the Authority may make use of committees to assist its consideration of appointments, succession, audit, risk and remuneration, it retains responsibility for, and endorses, final decisions in all of these areas. The chair should ensure that sufficient time is allowed at Authority meetings for committees to report on the nature and content of discussion, on recommendations and on actions to be taken. 

Where there is disagreement between the relevant committee and the Authority, adequate time should be made available for discussion of the issue with a view to resolving the disagreement. Where any such disagreement cannot be resolved, the committee concerned should have the right to report the issue to the sponsor team, PAO and responsible minister. They may also seek to ensure the disagreement or concern is reflected as part of the report on its activities in the annual report.

The chair should ensure Authority committees are properly structured with appropriate terms of reference. The terms of each committee should set out its responsibilities and the authority delegated to it by the Authority. The chair should ensure that committee membership is periodically refreshed and that individual independent non-executive directors are not over-burdened when deciding the chairs and membership of committees.

Authority duties

The Authority is specifically responsible for:

  • establishing and taking forward the strategic aims and objectives of HFEA consistent with its overall strategic direction and within the policy and resources framework determined by the Secretary of State
  • providing effective leadership of HFEA within a framework of prudent and effective controls which enables risk to be assessed and managed
  • ensuring the financial and human resources are in place for HFEA to meet its objectives
  • reviewing management performance
  • ensuring that the Authority receives and reviews regular financial and management information concerning the management of HFEA
  • ensuring that it is kept informed of any changes which are likely to impact on the strategic direction of HFEA or on the attainability of its targets, and determining the steps needed to deal with such changes and where appropriate bringing such matters to the attention of the responsible minister and PAO through the executive team, sponsorship team or directly
  • ensuring that:
    • any statutory or administrative requirements for the use of public funds are complied with
    • the Authority operates within the limits of its statutory authority and any delegated authority agreed with DHSC, and in accordance with any other conditions relating to the use of public funds
    • in reaching decisions, the Authority takes into account guidance issued by DHSC
  • ensuring that, as part of the above compliance, the Authority is familiar with:
    • this framework agreement
    • any delegation letter issued to HFEA
    • any elements of any settlement letter issued to DHSC that is relevant to the operation of HFEA
    • any separate settlement letter that is issued to HFEA from DHSC
    • appropriate internal mechanisms for the monitoring, governance and external reporting regarding any conditions arising from the above documents and ensuring that the chief executive and HFEA as a whole act in accordance with their obligations under the above documents
  • demonstrating high standards of corporate governance at all times, including by using the independent audit committee to help the Authority to address important financial and other risks
  • appointing, with the Secretary of State’s approval, a chief executive and, in consultation with DHSC, set performance objectives and remuneration terms linked to these objectives for the chief executive which give due weight to the proper management and use of public resources
  • determining all such other things which the authority considers ancillary or conducive to the attainment or fulfilment by HFEA of its objectives

The Authority should ensure that effective arrangements are in place to provide assurance on risk management, governance and internal control. 

The Authority should make a strategic choice about the style and shape of risk management and should lead the assessment and management of opportunity and risk. The Authority should ensure that effective arrangements are in place to provide assurance over the design and operation of risk management, governance and internal control in line with the Orange Book management of risk - principles and concepts. The Authority must set up an Audit and Risk Assurance Committee, chaired by an independent and appropriately qualified non-executive member, to:

  • provide independent advice
  • ensure that DHSC’s Audit and Risk Assurance Committee is provided with routine assurances with escalation of any significant limitations or concerns

The Authority is expected to assure itself of the adequacy and effectiveness of the risk management framework and the operation of internal control.

The chair’s role and responsibilities

The chair is responsible for leading the Authority in the delivery of its responsibilities. Such responsibility should be exercised in the light of their duties and responsibilities as set out in:

  • the chair’s contract of employment
  • the priorities in the chair’s letter issued to them by DHSC
  • the statutory authority governing HFEA
  • this document
  • the documents and guidance referred to within this document

Communications between HFEA and the responsible minister should normally be through the chair.

The chair is bound by the code of conduct for board members of public bodies, which covers conduct in the role and includes the Nolan principles of public life.

In addition, the chair is responsible for: 

  • ensuring, including by monitoring and engaging with appropriate governance arrangements, that HFEA’s affairs are conducted with probity
  • ensuring that policies and actions support the responsible minister’s and where relevant other ministers’ wider strategic policies, and where appropriate these policies and actions should be clearly communicated and disseminated throughout HFEA

The chair has the following leadership responsibilities: 

  • formulating the Authority’s strategy
  • ensuring that the Authority, in reaching decisions, takes proper account of guidance provided by the responsible minister or DHSC
  • promoting the efficient and effective use of staff and other resources
  • delivering high standards of regularity and propriety
  • representing the views of the Authority to the general public

The chair also has an obligation to ensure that: 

  • the work of the Authority and its members are reviewed and are working effectively, including ongoing assessment of the performance of individual Authority members with a formal annual evaluation and more in-depth assessments of the performance of individual Authority members when being considered for re-appointment
  • in conducting assessments, the views of relevant stakeholders including employees and the sponsor team are sought and considered
  • the Authority has a balance of skills appropriate to directing HFEA’s business, and that all directors including the chair, deputy chair and chief executive continually update their skills, knowledge and familiarity with HFEA to fulfil their role both on the Authority and committees. This will include, but not be limited to, skills and training in relation to financial management and reporting requirements, risk management and the requirements of board membership within the public sector
  • Authority members are fully briefed on terms of appointment, duties, rights and responsibilities
  • they, together with the other Authority members, receive appropriate training on financial management and reporting requirements and on any differences that may exist between private and public sector practice
  • the responsible minister is advised of HFEA’s needs when Authority vacancies arise
  • there is a board operating framework in place setting out the role and responsibilities of the Authority, consistent with the corporate governance code for central government departments
  • there is a code of practice for Authority members in place, consistent with the Cabinet Office code of conduct for board members of public bodies

Individual board member responsibilities

Individual Authority members shall:

  • comply at all times with the code of conduct for board members of public bodies, which covers conduct in the role and includes the Nolan principles of public life as well as rules relating to the use of public funds and to conflicts of interest
  • demonstrate adherence to the 12 principles of governance for all public body non-executive directors as appropriate
  • not misuse information gained in the course of their public service for personal gain or for political profit, nor seek to use the opportunity of public service to promote their private interests or those of connected persons or organisations
  • comply with the Authority’s rules on the acceptance of gifts and hospitality, and of business appointments
  • act in good faith and in the best interests of HFEA
  • ensure they are familiar with any applicable guidance on the role of public sector non-executive directors and boards that may be issued from time to time by Cabinet Office, HMT or wider government

Management and financial responsibilities and controls

Delegated authorities

HFEA’s delegated authorities are set out in DHSC’s schedule of delegations and delegation letter. This delegation letter may be updated and superseded by later versions which may be issued by DHSC in agreement with HMT.

In line with MPM annex 2.2, these delegations will be reviewed on an annual basis.

HFEA shall obtain DHSC’s and, where appropriate, HMT’s prior written approval before:

  • entering into any undertaking to incur any expenditure that falls outside the delegations or which is not provided for in HFEA’s annual budget as approved by DHSC
  • incurring expenditure for any purpose that is or might be considered novel or contentious, or which has or could have significant future cost implications
  • making any significant change in the scale of operation or funding of any initiative or particular scheme previously approved by DHSC, unless where required to do so by order of the court
  • making any significant change in the scale of operation or funding of any initiative or particular scheme previously approved by DHSC
  • making any change of policy or practice which has wider financial implications that might prove repercussive or which might significantly affect the future level of resources required
  • carrying out policies that go against the principles, rules, guidance and advice in MPM

Spending authorities

Once the budget has been approved by DHSC, HFEA shall have authority to incur expenditure approved in the budget without further reference to DHSC, on the following conditions:

  • HFEA shall comply with the delegations set out in the delegation letter. These delegations shall not be altered without the prior agreement of DHSC and as agreed by HMT and Cabinet Office as appropriate
  • HFEA shall comply with MPM regarding novel, contentious or repercussive proposals
  • inclusion of any planned and approved expenditure in the budget shall not remove the need to seek formal departmental approval where any proposed expenditure is outside the delegated limits or is for new schemes not previously agreed
  • HFEA shall provide DHSC with such information about its operations, performance, individual projects or other expenditure as DHSC may reasonably require

Banking and managing cash

HFEA must maximise the use of publicly procured banking services (accounts with central government commercial banks managed centrally by Government Banking).

HFEA should only hold money outside Government Banking service accounts where a good business case can made for doing so and HMT consent is required for each account to be established. Only commercial banks which are members of relevant UK clearing bodies may be considered for this purpose.

Commercial accounts where approved should be operated in line with the principles as set out in MPM.

The AO is responsible for ensuring that HFEA has a banking policy as set out in MPM and ensuring that the policy is complied with.

Procurement

HFEA shall ensure that its procurement policies are aligned and comply with UK and international procurement regulations such as the Procurement Act 2023.

HFEA shall establish its procurement policies and document these in a procurement policy and procedures manual.

In procurement cases where HFEA is likely to exceed its delegated authority limit, procurement strategy approval for the specific planned purchase must be sought from DHSC’s sponsor team.

Competition promotes economy, efficiency and effectiveness in public expenditure. Works, goods and services should be acquired through competition unless there are convincing reasons to the contrary. The form of competition chosen should be appropriate to the value and complexity of the goods or services to be acquired.

Contracts awarded without competition shall be limited and exceptional and a quarterly report explaining those exceptions should be sent to DHSC.

Procurement by HFEA of works, equipment, goods and services shall be based on an appraisal of options and value for money. That means securing the best mix of quality and effectiveness for the least outlay over the period of use.

HFEA shall:

  • engage fully with DHSC and government-wide procurement initiatives that seek to achieve value for money from collaborative projects
  • comply with all relevant procurement policy notes issued by Cabinet Office
  • co-operate fully with initiatives to improve the availability of procurement data to facilitate the achievement of value for money
  • ensure their commercial capability is developed in line with Government Commercial Function people standards

HFEA shall also comply with both:

These standards apply to the planning, delivery and management of government commercial activity, including management of grants in all departments and ALBs, regardless of commercial approach used and form part of a suite of functional standards that set expectations for management within government.

Risk management

HFEA shall ensure that the risks that it faces are dealt with in an appropriate manner, in accordance with relevant aspects of best practice in corporate governance, and develop a risk management strategy, in accordance with HMT guidance, the ‘Orange Book management of risk - principles and concepts’.

HFEA shall promptly notify DHSC of any operational and financial risks arising from its activities which may have a potentially significant impact on HFEA, DHSC, another health and care body or the wider system. These will be discussed in meetings HFEA has with the senior departmental sponsor and the sponsor team. Such risks shall also be notified by HFEA’s risk function or Authority to DHSC’s risk team and may be escalated to DHSC’s Audit and Risk Committee for consideration. The chair of HFEA’s Audit and Governance Committee shall also escalate any risk concerns to DHSC’s risk team and may be asked to attend DHSC’s Audit and Risk Committee to explain risks. It is the responsibility of HFEA and the sponsor team to keep each other informed of significant risks to, or arising from, the operations of HFEA within the wider system.

Counter fraud and theft

Commitment to counter fraud

HFEA acknowledges that fraud, bribery and corruption pose significant risks to public funds and the integrity of health services. Both HFEA and DHSC agree that preventing, detecting and responding to fraud is a shared responsibility and a priority under the government’s counter fraud standard.

Fraud reporting and co-operation

HFEA should:

  • adopt and implement policies and practices to safeguard itself against fraud and theft
  • take all reasonable steps to prevent and detect fraud within its operations
  • keep records of and prepare and forward to DHSC an annual report on fraud and theft suffered by HFEA and notify the DHSC Anti-Fraud Unit (AFU) and, where appropriate, the NHS Counter Fraud Authority (NHSCFA) of any unusual or major incidents as soon as possible
  • manage the prevention, detection and recovery of fraud losses in HFEA. Where trained resource is in place, this includes the investigation of fraud, bribery and corruption, working with law enforcement partners as appropriate
  • report detected loss from fraud, bribery, corruption and error, alongside associated recoveries and prevented losses, to the counter fraud centre of expertise in line with the agreed government definitions as set out in the counter fraud standard
  • co-operate fully with DHSC and NHSCFA in any investigation or assurance activity, including providing timely access to relevant information, staff and systems

Notification and escalation

Where fraud is identified or suspected, HFEA must notify DHSC without delay and follow agreed escalation protocols. Serious cases should be reported immediately to DHSC AFU at reportingfraud@dhsc.gov.uk.

Compliance and assurance

HFEA should act in line with guidance as issued by the Government Counter Fraud Function and in compliance with the procedures and considerations as set in in MPM annex 4.9 and the government’s counter fraud standard. This includes:

  • completing fraud risk assessments
  • implementing proportionate controls
  • participating in periodic reviews or audits as requested by DHSC
  • taking all reasonable steps to appraise the financial standing of any firm or other body with which it intends to enter a contract or to provide grant or grant-in-aid

HFEA will maintain effective counter-fraud arrangements aligned with DHSC’s counter-fraud strategy and MPM guidance.

Culture and training

HFEA will promote a culture of integrity and vigilance, ensuring staff are aware of fraud risks and know how to report concerns. Training and awareness activities should be embedded within governance and operational processes.

Staff

Broad responsibilities for staff

Within the arrangements approved by the Secretary of State and HMT, HFEA will have responsibility for the recruitment, retention and motivation of its staff. The broad responsibilities toward its staff are to ensure that:

  • the rules for recruitment and management of staff create an inclusive culture in which:
    • diversity is fully valued
    • appointment and advancement is based on merit
    • there is no discrimination against employees with protected characteristics under the Equality Act 2010
  • the level and structure of its staffing, including grading and staff numbers, are appropriate to its functions and the requirements of economy, efficiency and effectiveness
  • the performance of its staff at all levels is satisfactorily appraised and HFEA’s performance measurement systems are reviewed from time to time
  • staff are encouraged to acquire the appropriate professional, management and other expertise necessary to achieve HFEA’s objectives
  • proper consultation with staff takes place on important issues affecting them
  • adequate grievance and disciplinary procedures are in place
  • whistle-blowing procedures consistent with the Public Interest Disclosure Act 1998 are in place
  • a code of conduct for staff is in place based on Cabinet Office’s code of conduct for board members of public bodies

Staff costs

Subject to its delegated authorities, HFEA shall ensure that the creation of any additional posts does not incur forward commitments that will exceed its ability to pay for them.

Pay and conditions of service

HFEA’s staff are subject to levels of remuneration and terms and conditions of service (including pensions) within the general pay structure approved by DHSC and HMT. HFEA has no delegated power to amend these terms and conditions without the approval of the Secretary of State and HMT.

If Civil Service terms and conditions of service apply to the rates of pay and non-pay allowances paid to the staff and to any other party entitled to payment in respect of travel expenses or other allowances, payment shall be made in accordance with the Civil Service management code and the annual Civil Service pay remit guidance, except where prior approval has been given by DHSC to vary such rates.

Staff terms and conditions shall be set out on the HFEA intranet. Copies should be provided to DHSC together with subsequent amendments as required.

HFEA shall abide by public sector pay controls, including the relevant approvals process dependent on the organisations classification as detailed in the senior pay guidance and the public sector pay and terms guidance.

HFEA shall operate a performance-related pay scheme that shall form part of the annual aggregate pay budget approved by DHSC, where relevant with due regard to the senior pay guidance.

The travel expenses of authority members shall be tied to the rates allowed to senior staff of HFEA. Reasonable actual costs shall be reimbursed.

Pensions, redundancy and compensation

Compensation scheme rules and pension scheme rules shall reflect legislative and HMT guidance requirements regarding exit payments.

HFEA staff shall normally be eligible for a pension provided by the Principal Civil Service Pension Scheme (PCSPS). Staff may opt out of the occupational pension scheme provided by HFEA, but that employers’ contribution to any personal pension arrangement, including stakeholder pension, shall normally be limited to the national insurance rebate level.

Any proposal by HFEA to move from the existing pension arrangements, or to pay any redundancy or compensation for loss of office, requires the prior approval of DHSC. Proposals on severance must comply with the rules in chapter 4 of MPM.

HFEA shall seek approval from DHSC’s Remuneration Committee for recruiting to executive and senior managers posts or paying above the relevant ceilings in the executive and senior managers’ pay framework. All applications will need approval from the HFEA sponsor team before being considered by the committee.

Business plans, financial reporting and information management

Corporate and business plans

HFEA shall submit annually to DHSC a draft of the corporate plan (otherwise referred to as the HFEA strategy) covering 3 years ahead. The draft should be submitted by 31 March. HFEA shall agree with DHSC the issues to be addressed in the strategy and the timetable for its preparation. The strategy shall reflect HFEA’s statutory and/or other duties and, within those duties, the priorities set from time to time by the responsible minister (including decisions taken on policy and resources in the light of wider public expenditure decisions). The strategy shall demonstrate how HFEA contributes to the achievement of DHSC’s medium-term plan and priorities and aligned performance metrics and milestones. 

The first year of the 3-year strategy, amplified as necessary, shall form the business plan. The business plan shall be updated to include important targets and milestones for the year immediately ahead and shall be linked to budgeting information so that resources allocated to achieve specific objectives can readily be identified by DHSC. Subject to any commercial considerations, the corporate and business plans should be published by HFEA on its website and separately be made available to staff. 

The following matters should be included in the strategy and business plan: 

  • critical objectives and associated performance targets for the forward years, and the strategy for achieving those objectives
  • critical non-financial performance targets
  • a review of performance in the preceding financial year, together with comparable outturns for the previous 3 years, and an estimate of performance in the current year
  • alternative scenarios and an assessment of the risk factors that may significantly affect the execution of the plan but that cannot be accurately forecast
  • other matters as agreed between DHSC and HFEA

Budgeting procedures

Each year, in the light of decisions by DHSC on the updated draft corporate plan, DHSC will send to HFEA by an agreed date: 

  • a formal statement of the annual budgetary provision allocated by DHSC in the light of competing priorities across DHSC and of any forecast income approved by DHSC
  • a statement of any planned change in policies affecting HFEA

The approved annual business plan will take account both of approved funding provision and any forecast receipts, and will include a budget of estimated payments and receipts together with a profile of expected expenditure and of draw-down of any departmental funding and/or other income over the year. These elements form part of the approved business plan for the year in question.

Grant-in-aid and any ring-fenced grants

Any grant-in-aid provided by DHSC for the year in question will be voted in DHSC’s supply estimate and be subject to parliamentary control. 

The grant-in-aid will normally be paid in monthly instalments on the basis of written applications showing evidence of need. HFEA will comply with the general principle that there is no payment in advance of need. Cash balances accumulated during the course of the year from grant-in-aid or other Exchequer funds shall be kept to a minimum level consistent with the efficient operation of HFEA. Grant-in-aid not drawn down by the end of the financial year shall lapse. Subject to approval by Parliament of the relevant estimates provision, where grant-in-aid is delayed to avoid excess cash balances at the year-end, DHSC will make available in the next financial year any such grant-in-aid that is required to meet any liabilities at the year end, such as creditors.

In the event that DHSC provides HFEA separate grants for specific (ring-fenced) purposes, it would issue the grant as and when HFEA needed it on the basis of a written request. HFEA would provide evidence that the grant was used for the purposes authorised by DHSC. HFEA shall not have uncommitted grant funds in hand, nor carry grant funds over to another financial year.

Annual report and accounts

HFEA must publish an annual report of its activities together with its audited accounts after the end of each financial year. HFEA shall provide the finalised (audited) accounts in line with the agreed annual timetable established by DHSC for the accounts to be consolidated within DHSC’s accounts. A draft of the report shall be submitted to DHSC at least 2 weeks before the proposed publication date. The accounts should be prepared in accordance with the relevant statutes and specific accounts direction issued by DHSC, as well as with HMT’s FReM.

The annual report and accounts must: 

  • cover any corporate, subsidiary or joint ventures under HFEA’S control
  • comply with FReM and in particular have regard to the illustrative statements for a NDPB
  • outline main activities and performance during the previous financial year and set out in summary form forward plans

Information on performance against critical financial targets is within the scope of the audit and should be included as part of the financial performance described in the annual report. The report and accounts shall be laid in Parliament and made available on HFEA’s website, in accordance with the guidance in FReM.

Reporting performance to DHSC

HFEA shall operate management, information and accounting systems that enable it to review, in a timely and effective manner, its financial and non-financial performance against the budgets and targets set out in the corporate and business plans.

HFEA shall inform DHSC of any changes that make achievement of objectives more or less difficult. It shall report financial and non-financial performance, including performance in helping to implement ministers’ policies, and the achievement of critical objectives regularly through its quarterly meetings with DHSC.

HFEA’s performance shall be formally reviewed by DHSC 4 times a year.  

The responsible minister shall meet the chair and chief executive once a year.

Information sharing

DHSC has the right of access to HFEA records and personnel for any purpose including, for example, sponsorship audits and operational investigations. This will not apply to information held by the register of fertility treatment data.

HFEA shall provide DHSC with such information about its operations, performance, individual projects or other expenditure as DHSC may reasonably require.

DHSC and HMT may request the sharing of data held by HFEA in such a manner as set out in central guidance except insofar as it is prohibited by law. This may include requiring the appointment of a senior official to be responsible for the data sharing relationship.  

As a minimum, HFEA shall provide DHSC with information monthly that will enable DHSC satisfactorily to monitor: 

  • HFEA’s cash management
  • its draw-down of grant-in-aid
  • forecast outturn by resource headings
  • other data required for the Online System for Central Accounting and Reporting (OSCAR)
  • data as required in respect of its compliance with any Cabinet Office Controls pipelines or required to meet any condition as set out in any settlement letter

Audit

Internal audit

HFEA shall: 

  • ensure that DHSC’s internal audit team has complete access to all relevant records
  • ensure that any arrangements for internal audit are in accordance with the Global Internal Audit Standards
  • set up an audit committee of the Authority in accordance with the corporate governance code for central government departments and the Audit and Risk Assurance Committee handbook
  • forward the audit strategy, periodic audit plans and annual audit report, including HFEA’s head of internal audit opinion on risk management, control and governance, as soon as possible to DHSC
  • keep records of, and prepare and forward to DHSC an annual report on, fraud and theft suffered by HFEA and notify DHSC of any unusual or major incidents as soon as possible
  • share with DHSC information identified during the audit process and the annual audit opinion report (together with any other outputs) at the end of the audit, in particular on issues impacting on DHSC’s responsibilities in relation to financial systems within HFEA

External audit

The National Audit Office (NAO) audits HFEA’s annual accounts, which are then certified by the Comptroller and Auditor General (C&AG). The NAO lays the accounts before Parliament, together with the report.

In the event that HFEA has set up and controls subsidiary companies, HFEA shall, in the light of the provisions in the Companies Act 2006, ensure that C&AG has the option to be appointed auditor of those company subsidiaries that it controls and/or whose accounts are consolidated within its own accounts. HFEA shall discuss with DHSC the procedures for appointing C&AG as auditor of the companies.

The C&AG:

  • shall consult DHSC and HFEA on whom - the NAO or a commercial auditor - shall undertake the audits on C&AG’s behalf, though the final decision rests with C&AG
  • has a statutory right of access to relevant documents, including by virtue of section 25(8) of the Government Resources and Accounts Act 2000, held by another party in receipt of payments or grants from HFEA
  • shall share with DHSC information identified during the audit process and the audit report (together with any other outputs) at the end of the audit, in particular on issues impacting on DHSC’s responsibilities in relation to financial systems within HFEA
  • shall consider requests from departments and other relevant bodies to provide regulatory compliance reports and other similar reports at the commencement of the audit. Consistent with C&AG’s independent status, the provision of such reports is entirely at C&AG’s discretion

C&AG may carry out examinations into the economy, efficiency and effectiveness with which HFEA has used its resources in discharging its functions. For the purpose of these examinations, C&AG has statutory access to documents as provided for under section 8 of the National Audit Act 1983. In addition, HFEA shall provide, in conditions to grants and contracts, for C&AG to exercise such access to documents held by grant recipients and contractors and sub-contractors as may be required for these examinations. HFEA shall use its best endeavours to secure access for C&AG to any other documents required by C&AG which are held by other bodies.

Reviews and winding up arrangements

Review of HFEA’s status

HFEA will be reviewed as part of the wider Public Bodies Reviews Programme, at a time determined by DHSC’s ministers and their PAO.

Arrangements in the event that HFEA is wound up

DHSC shall put in place arrangements to ensure the orderly winding up of HFEA. In particular, it should ensure that the assets and liabilities of HFEA are passed to any successor organisation and accounted for properly. (In the event that there is no successor organisation, the assets and liabilities should revert to DHSC.) To this end, DHSC shall: 

  • have regard to Cabinet Office guidance on winding up ALBs
  • ensure that procedures are in place in HFEA to gain independent assurance on important transactions, financial commitments, cash flows and other information needed to handle the wind-up effectively and to maintain the momentum of work inherited by any residuary body
  • specify the basis for the valuation and accounting treatment of HFEA’s assets and liabilities
  • ensure that arrangements are in place to prepare closing accounts and pass to C&AG for external audit, and that, for non-crown bodies, funds are in place to pay for such audits. It shall be for C&AG to lay the final accounts in Parliament, together with C&AG’s report on the accounts
  • arrange for the most appropriate person to sign the closing accounts. In the event that another ALB takes on the role, responsibilities, assets and liabilities, the succeeding ALB AO should sign the closing accounts. In the event that DHSC inherits the role, responsibilities, assets and liabilities, DHSC’s PAO should sign

HFEA shall provide DHSC with full details of all agreements where HFEA or its successors have a right to share in the financial gains of developers. It should also pass to DHSC details of any other forms of claw-back due to HFEA.

Other matters

Partnership working

To support the development of their relationship, DHSC and HFEA have agreed to a set of shared principles:

  • working together with each other, and with DHSC’s other ALBs, for patients, people who use services and the public, demonstrating our commitment to the values of the NHS as set out in its constitution
  • respect for the importance of autonomy throughout the system, and the freedom of individual organisations to exercise their functions in the way they consider most appropriate
  • recognition that the Secretary of State is ultimately accountable to Parliament and the public for the system overall. HFEA will support DHSC in the discharge of its accountability duties, and DHSC will support HFEA in the same way
  • working together openly and positively - this will include working constructively and collaboratively with other organisations within and beyond the health and social care system

To support this, HFEA and DHSC will follow an ‘open book’ approach. In the case of issues with an impact on the development or implementation of policy, DHSC can expect to be kept informed by HFEA. In the same way, DHSC will seek to keep HFEA apprised of developments in policy and government. There are likely to be some issues where DHSC or HFEA will expect to be consulted by the other before DHSC or HFEA makes either a decision or a public statement on a matter. DHSC and HFEA will make clear which issues fall into this category in good time. The sponsor team will be responsible for ensuring that this works effectively.

To support the Secretary of State and the PAO in their accountability functions, HFEA must provide the Secretary of State with such information relating to the exercise of its functions as the Secretary of State may request. It is therefore expected that DHSC will, when required, have full access to HFEA’s files and information. If necessary, the senior departmental sponsor’s team will be responsible for prioritising these requests for information.

Communications between DHSC and HFEA

This section sets out the basic principles guiding co-operation and collaborative working between DHSC and HFEA, across all aspects of communication and marketing activities, to provide impactful and cost-effective communications in the context of our shared accountability to Parliament and the public.

The principles include regular collaboration and information sharing between DHSC and HFEA to ensure communications are aligned and to amplify their impact. All organisations commit to undertaking this collaboration and information sharing in a timely manner, of content being shared with the public, media or other stakeholders. This will ensure that, as a system, we are communicating with the public, workforce and our stakeholders in a co-ordinated manner so as to not confuse or undermine another part of the system.

To achieve this, the DHSC and HFEA communications teams will have regular check in points, including for the heads of communication and media and marketing teams, to agree communication plans. In particular, HFEA and DHSC will give each other sufficient advance notice of public facing communications to allow for necessary clearances with the relevant teams as set out in the Communications and Marketing Guidance annex of the ALB Schedule of Delegations.

Relations with DHSC’s other ALBs

HFEA will work in partnership with DHSC and its other ALBs, in the interests of patients, people who use services and the public, to maximise the health and wellbeing gain for the population, demonstrating our commitment to the values of the NHS as set out in the NHS Constitution for England.

DHSC and its ALBs have complementary but distinct roles within the system to ensure that service users receive high-quality services which provide value for public money. Details of the working arrangements with other ALBs and important bodies will, where appropriate, be agreed and set out in a partnership agreement.

Transparency

HFEA is an open organisation that carries out its activities transparently. It demonstrates this by:

  • proactively publishing on its website important information on areas including:
    • pay
    • diversity of the workforce
    • performance
    • the way it manages public money
    • the public benefits achieved through its activities
  • supporting those who wish to use its data by publishing the information within guidelines set by Cabinet Office

HFEA holds open Authority meetings in line with the Public Bodies (Admission to Meetings) Act 1960. HFEA will publish an annual report. The annual report will include a governance statement, which is to be reviewed by the senior departmental sponsor.

To underpin the principles of good communication, ‘no surprises’ and transparency, HFEA and DHSC have put in place arrangements for managing communications.

HFEA’s non-executive board members operate within the general principles of the corporate governance guidelines set out by HMT. They will also comply with Cabinet Office’s code of conduct for board members of public bodies and with HFEA’s rules on disclosure of financial interests, including those of Authority members.

HFEA has developed a code of conduct for all staff which will comply with the principles in Cabinet Office’s code of conduct for board members of public bodies, which includes rules on conflicts of interest, political activity and restrictions on lobbying.

HFEA will take all necessary measures to ensure that:

  • patient, personal and/or sensitive information within its care and control is well managed and protected through all stages of its use, including through compliance with the Data Protection Act
  • it provides public assurance in respect of its information governance practice by completing and publishing an annual information governance assessment using an agreed assessment mechanism
  • it meets its legal obligations for records management, accountability and public information by compliance with relevant standards, including government and NHS codes of practice on confidentiality, security and records management

HFEA’s Senior Information Risk Owner and Caldicott Guardian will work together to ensure that both patient and other personal information are handled in line with best practice in government and the wider public sector.

Public and parliamentary accountability

DHSC and its ALBs share responsibility for accounting to the public and to Parliament for policies, decisions and activities across the health and care sector. Accountability to Parliament will often be demonstrated through parliamentary questions, MPs’ letters and appearances before parliamentary committees. Accountability to the public may be through the publication of information on HFEA’s website, as well as through responses to letters from the public and responses to requests under the Freedom of Information Act 2000.

DHSC and its ministers remain responsible to Parliament for the system overall, so will often have to take the lead in demonstrating this accountability. Where this is the case, HFEA will support DHSC by, among other things, providing information for ministers to enable them to account to Parliament. In its turn, DHSC provides leadership to the system for corporate governance, including setting standards for performance in accountability.

HFEA, however, has its own responsibilities in accounting to the public and to Parliament, and its way of handling these responsibilities has been agreed with DHSC. In all matters of public and Parliamentary accountability, DHSC and its ALBs will work together considerately, co-operatively and collaboratively, and any information provided by HFEA is to be timely, accurate and, where appropriate, consistent with information provided by DHSC.

Equalities

The public sector equality duty (PSED) requires HFEA (as a public body) to have due regard to the need to:

  • eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under this act
  • advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it
  • foster good relations between persons who share a relevant protected characteristic and persons who do not share it

The specific duties require HFEA, as a public body, to:

  • annually publish information to demonstrate compliance with the PSED. This information must include, in particular, information relating to persons who share a relevant protected characteristic who are its employees and other persons affected by its policies and procedures
  • prepare and publish one or more objectives it thinks it should achieve to meet the PSED every 4 years

Whistleblowing

HFEA, as with DHSC and all its ALBs, has whistleblowing policies and procedures in place that comply with the Public Interest Disclosure Act 1998 and best practice guidance. The act prohibits the use of confidentiality clauses that seek to prevent staff from speaking out on issues of public interest.

Sustainability

As a major public sector body, HFEA has an important role to play in driving forward the government’s commitment to sustainability in the economy, society and the environment. As a minimum, HFEA should comply with the Greening Government Commitments that apply to all government departments, executive agencies and NDPBs, set out in the action plan for driving sustainable operations and procurement across government. Reporting is through DHSC (including the consolidation of relevant information in DHSC’s annual resource account) and DHSC will ensure HFEA is aware of the process for this.

Annex A: guidance

HFEA shall comply with the following guidance, documents and instructions.

Corporate governance

This includes:

Financial management and reporting

This includes:

Management of risk

This includes:

Commercial management

This includes:

Public appointments

The following are relevant where public bodies participate in public appointments processes:

Staff and remuneration

This includes:

General

This includes:

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