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How we manage risk

Risk management process

We face many risks and opportunities in our day-to-day operations. We carefully manage these risks and capitalise on related opportunities to ensure our business remains sustainable and profitable. During these unprecedented times with COVID-19, our employees and patients' safety is of the utmost importance.

Compromises our operational employees, who are required to understand their roles and responsibilities and carry them out correctly and completely.

Consists of our oversight functions, including risk and compliance management. These functions define work practices, monitor adherence to policies, and oversees the first line of defence with regard to risk and compliance.

Comprises the internal and external assurance providers and the Board. Internal and external auditors regularly review the first and second lines of defence to ensure that they are carrying out their tasks as required. The Board mandates the audit committee to review the information provided by various Board committees regarding tasks and business information. The Board plays an oversight role and is responsible for approving the information reviewed by the audit committee among others.

Our risk management processes are fundamental to our business and align with our core values and strategic focus areas. The Board is ultimately responsible for governing enterprise risk management and ensuring that an effective and robust enterprise risk management framework and processes are in place. The Board risk, compliance and IT governance committee (RCITGC) and the Group risk management function support and assist the Board with the Group's risk management.

Our combined assurance process has three lines of defence to ensure accountability and distinguish between risk oversight, owning and managing risks, and providing independent assurance.

The RCITComm receives periodic, independent assurance on the effectiveness of our risk management processes from internal audit. Risks and opportunities are appropriately identified, assessed, evaluated and managed as part of our best practices. This is done by implementing an enterprise risk management strategy and framework that considers King IV's principles and is based on the ISO 31000 international standards on risk management. Risks are also monitored according to their nature, potential impact and likelihood.

We embed risk management processes into our everyday operations to help us identify any events with potential to affect our ability to create value and to manage risks in line with our strategy effectively. Our line managers and employees ensure that the risk management framework and processes are implemented across the Group. The Group Risk Manager engages with key executives and senior management across the Group to identify risks relevant to both our southern Africa and international operations, which are then recorded in the Group risk register.

The Board and the RCITGC confirm they are satisfied that adequate, ongoing risk management processes are in place to provide reasonable assurance that key risks and opportunities are identified, evaluated and managed across the Group.

Top risks

Change in short-term trend

  Increasing      Decreasing       Unchanged      New risk
Each risk is discussed below.

THE TABLE BELOW RANKS THE GROUP’S TOP 11 RESIDUAL RISKS (2020: 9 RISKS) AS AT 30 SEPTEMBER 2021.

Two new risks were identified during the year under review, namely risk 5 (Changing business environment and innovation risk) and risk 8 (Business resilience and continuity risk).


2021
Risk
ranking
2020
Risk
ranking
Risk description
Probable
short-term
trend
Link to strategic
objective
Link to material
matters
Line of
defence
Human capital (people) risk

1, 2
Funder risk
1, 2, 3
Cyber-crime and
data breach
1, 2, 3
Macroeconomic and
political risk

1, 2
Changing business
environment and
innovation risk


1, 2, 3
Skilled healthcare
professional shortages



1, 2, 3
Complexity of
regulatory environment
and compliance risk

1, 2, 3
Business resilience
and continuity risk
1, 2, 3
Clinical and patient
safety risk
1, 2, 3
IT systems,
infrastructure and
project implementation
1, 2, 3
Reputational risk
1, 2, 3
Levels of control:


Human capital (People) risk
   
Change:
Board oversight:
REMCO & CGC
    (2020: 2 + 4)
Risk description
   
Level of control:

People are our most important asset and are key to our ongoing success. There is a global shortage of clinical employees, especially nurses and radiographers. These shortages affect the Group's growth prospects, our ability to deliver quality care and services and, ultimately, our operations' sustainability.

The Group's strategic ambition places an additional demand on an already overstretched work force. Failure to attract and to retain sufficient skilled resources with the appropriate skillsets for these key roles could hamper performance and ultimately achievement of objectives.

The South African healthcare sector has experienced a general shortage of nurses, across all categories of nursing with increasing shortages in specialist registered nursing personnel. Internationally, Alliance Medical continues to be faced with a shortage of radiographers (particularly in Ireland) and aggressive competition for clinical resources from the NHS and private competitors in the UK.

Over the past year, the shortages were further impacted by COVID-19. Some contributing factors included:

  • Increased infection rates in healthcare professionals, nursing personnel, radiographers and frontline employees causing illness or death or requiring employees to go into quarantine or isolation.
  • Increased demand for clinical skills from other public and private sector providers.
  • Increased demand for additional nursing personnel in South Africa to treat the influx of COVID-19 positive patients at facilities.

Healthcare professionals, nurses and frontline employees have had to face high volumes of severely ill COVID-19 patients and an unprecedented number of patient deaths from COVID-19 related illnesses and have therefore been subjected to tremendous physical, mental and emotional pressure.

As a responsible employer, we are required to provide a safe work environment for all our employees. At the same time, we need to provide care to our patients and fulfil all essential service provider responsibilities.

How we manage the risk
  • Operating the Life College of Learning – a higher education institution offering one of the top three private nursing qualifications in South Africa.
  • Developing and retaining scarce skills through continuing professional education (CPE), for example through our pharmacists' internship and pharmacists' assistant programmes.
  • Ongoing review of senior management resources and succession plans in place for key positions.
  • Enhanced employee value propositions, including employee share schemes, remuneration benchmarking and other benefits to attract and retain employees.
  • Management and leadership development programmes in place.
  • Clear career path for employees and continuous training and development programmes.
  • Agency arrangements in place to provide agency employees if needed.
  • Redeployment strategy in place for the utilisation of nursing employees from other units and regions in the event of shortages in South Africa.
  • International nursing recruitment programme.
  • Employee wellness programmes in place for all employees, including trauma debriefing and psychological support.
  • Programmes promoting diversity and inclusion in place.
  • Several infection prevention protocols remain in place and regular training provided to safeguard and protect employees from exposure to COVID-19.
  • Designated COVID-19 compliance officers in place to oversee adherence to the standards of hygiene and health protocols related to COVID-19 at the workplace.
  • Phased-in mandatory vaccination for a safer work environment.
   
Key stakeholders
impacted
Opportunities
  • Through targeted succession planning, we ensure business continuity and that we can attract talented leaders.
  • Enhancing the skills base will improve business performance.
  • Engagement with the South African Nursing Council to increase student numbers.
  • Enhancing employee wellness programmes to address mental health issues for healthcare workers.
Outlook

We expect to see the risk increase in the short to medium term as competition for nursing resources from both private sector competitors and the public sector continues. The supply of nurses is likely to remain constrained as the number of nurses qualifying from training facilities will not be sufficient to replace the number of nurses retiring and emigrating.



Funder risk
   
Change:
Board oversight:
RCITGC
    (2020: 1)
Risk description
   
Level of control:

Life Healthcare is under continuous revenue pressure from healthcare funders looking to manage the overall cost of healthcare. In response to escalations in healthcare costs and the utilisation of healthcare services, funders have instituted a range of initiatives to manage down their costs.

In South Africa, funder managed care initiatives aim to reduce hospital admission rates. They have introduced more affordable plans but with less cover and increased restricted provider networks. Our admission rates could be impacted by our ability to secure preferred network agreements with healthcare funders.

Alliance Medical is exposed to a mix of public and private funders across the different territories in which it operates. Public revenue comprises c.90% of total revenue in the UK, c.60% in Italy and c.45% in Ireland.

How we manage the risk
  • Delivering excellent quality and cost-effective care.
  • Implementing an appropriate pricing strategy focusing on efficiencies and input costs.
  • Focusing on safeguarding good relationships with healthcare funders and engaging with them on their issues and concerns.
  • Providing a differentiated service offering.
  • Focusing interventions with doctors to increase clinical outcome data and efficiency.
  • Developing value-based clinical products in South Africa.
  • Placing case managers at facilities in South Africa to manage claims submitted to funders.
  • Managing long-term contracts with our international businesses and their national healthcare funds.

   
Key stakeholders
impacted
Opportunities
  • Through increased engagement, targeted interventions and a differentiated service offering, we can position ourselves as the local and international service provider of choice.
  • Developing clinical products that improve patient outcomes and drive market share growth.
  • New business offerings such as community diagnostic centres in the UK.
Outlook

Poor economic conditions brought on by COVID-19 will continue to place pressure on consumers and impact the affordability of healthcare. Healthcare funders will face increasing pressure to contain member contributions and provide innovative and cost-effective benefits to retain members. We expect the risk to continue to increase in the short to medium term.



Cyber-crime and data breach
   
Change:
Board oversight:
RCITGC
    (2020: 3)
Risk description
   
Level of control:

Cyber-security risk continues to remain a key risk to our business globally and the threats are evolving, unpredictable and increasing in frequency. Criminal elements continued to exploit the rapid and widespread adoption of work-from-home tools due to COVID-19 to launch wide scale cyber-attacks. Healthcare data is valuable and cyber-criminal elements have relentlessly targeted healthcare organisations across the globe to the detriment of patient care.

Extra vigilance and cyber-crime awareness are required around data security profiles and the accessibility of data. The balance between securing data behind a firewall and making it readily accessible to employees and business partners must shift to support new ways of working while keeping existing business processes and operations moving.

How we manage the risk
  • Appointed a Chief Information Security Officer (CISO).
  • Dedicated IT security team in place.
  • Continued mature information security management system (ISMS) implementation, internationally certified by the British Standards Institution (BSI) (ISO 27001:2003).
  • Performed regular risk assessments, including annual internal and external security assessments.
  • Implemented an information management strategy to improve security and manage residual risks, along with further measures to protect the Group's intellectual property from hacking and other illegal cyber-activities.
  • Ongoing logical and physical IT security controls implementation, including advanced email protection, firewalls, end-point protection, cyber-security enhancements and personal information protection.
  • Implemented proactive tools to detect and respond to cyber-threats.
  • Regularly providing information security and cyber-awareness training for employees.
  • Monitoring security events through our 24/7 security operations centre (SOC).
  • Ensuring adherence with the requirements of the General Data Protection Regulation (GDPR).

   
Key stakeholders
impacted
Opportunities
  • Investing in information security controls to enhance our existing security measures and safeguard our data to provide reassurance to our stakeholders.
Outlook

While significant investment has been made in strengthening our security posture, threat actors are quick to find new and sophisticated ways to target businesses and globally the number of security breaches is rising. We expect the risk to increase in the short to medium term as the threat of cyber-attacks increases. Our maturing cyber security practices will assist in minimising the impact on the business.



Macroeconomic and political risk
   
Change:
Board oversight:
RCITGC
    (2020: 8)
Risk description
   
Level of control:

We operate in the global healthcare market, and our operations are spread across different countries. The risk exists that country-specific factors, such as economic and political factors, or government policies, could adversely affect the Group.

While optimism is increasing in some countries with the vaccine roll-out programmes well underway, economies worldwide continue to be impacted by recurrences of COVID-19 waves. In South Africa higher unemployment and decreasing household income may impact on patients' ability to afford private healthcare cover. Deteriorating social conditions may result in further civil unrest.

How we manage the risk
  • Diversified business model offering both inpatient and outpatient services across multiple territories.
  • Annual strategy process in place with regular reviews of strategy and tracking against progress.
  • Active monitoring of country-specific factors in the countries where we operate.
  • Ongoing engagements with regulators and governments for long-term partnership solutions.
  • Continued focus on business optimisation programmes.
  • Focused on developing value-based clinical products.

   
Key stakeholders
impacted
Opportunities
  • Building relationships based on trust by actively working with local governments, thereby positively impacting the healthcare markets in the countries where we operate.
  • Providing patient centric care and improving access to care.
  • Integrating in-person and virtual healthcare solutions.
Outlook

We expect the risk to remain unchanged in the short term but it will stabilise over time due to the global economic recovery and the reducing likelihood of strict lockdowns (and their devastating economic impacts) as countries learn to live with COVID-19.



Changing business environment and innovation risk
   
Change:
Oversight by the Board
    (2020: n/a)
Risk description
   
Level of control:

COVID-19 has influenced how consumers view and consume healthcare. This has resulted in an altered case-mix of non-COVID medical admissions and reduced surgical admissions. Recovery to pre-COVID case-mix is unlikely.

Changing consumer behaviour has significantly ramped up the need for greater healthcare digitisation as consumers look for seamless, easily accessible and integrated physical and virtual care.

This changing landscape requires us to deliver patient care that is patient-centric.

An increasing competitor landscape and the growing vertical of health technology requires us to strategise accordingly to remain relevant and ensure sustainable growth.

How we manage the risk
  • Annual strategy process in place with regular reviews of strategy and tracking against progress.
  • Board approval of the strategy and performance oversight.
  • Regular executive review of strategy and management of performance against strategy.
  • Skilled and experienced executive and management team.
  • Strategic project governance and management.
  • Investment and acquisition governance and management.
  • Business environment scanning.
  • Product development governance in place with product development initiatives in progress.

   
Key stakeholders
impacted
Opportunities
  • Proactively managing strategic and business risks enables confident business decisions, minimises financial loss and promotes competitive differentiation.
  • Improved healthcare professionals' engagement allows us to deliver patient-centred, quality care to patients.
Outlook

The global healthcare marketplace and the delivery of healthcare is marked by unprecedented transformation catalysed by COVID-19. Digital transformation and innovative care offerings have become a priority and will continue to be so in the medium term. This risk is likely to increase as new competitors and market entrants race to meet the changing demand.



Skilled healthcare professional shortages
   
Change:
Oversight by the Board:
CGC, RCITGC
    (2020: 2)
Risk description
   
Level of control:

There is a general shortage of doctors in the South African market, and a shortage of radiologists in certain regions where Alliance Medical operates. These shortages affect the Group's growth prospects, our ability to deliver quality care and services and, ultimately, our operations' sustainability.

The general shortage of healthcare professionals was exacerbated by COVID-19 during the year.

How we manage the risk
  • A transparent recruitment and retention strategy exists that includes:
    • providing bursaries and sponsorship programmes to medical specialists in South Africa, and facilitating continuous professional development training for them;
    • ongoing engagement with healthcare professionals;
    • doctor partnership model and support policy, with regional clinical managers appointed to enhance doctor relationships and implement quality improvement initiatives in South Africa; and
    • ensuring infrastructure and equipment at facilities are improved.
  • Investment in various reward, development, recruitment and cultural initiatives to alleviate Alliance Medical's skills shortages.
  • Alliance Medical International recruitment programme.
  • Constituted a dedicated workstream and hospital-based committees to address the impact of COVID-19, focusing on doctor availability and recruitment.
  • Instituted tele-reporting in our international business, sourcing additional reporting capacity from other third-party houses.

   
Key stakeholders
impacted
Opportunities
  • Assisting to alleviate critical skills shortages through our interventions positions Life Healthcare as a business supporting our associated healthcare professionals.
Outlook

We do not expect to see any material movements in this risk in the short to medium term.



Complexity of regulatory environment and compliance risk
   
Change:
Oversight by the Board:
CGC, RCITGC
    (2020: 5)
Risk description
   
Level of control:

The Group is required to comply with all applicable laws and regulations of the countries where we operate. In addition to these general compliance requirements, the global healthcare industry is subject to a growing number of new and amended regulations.

In South Africa, regulators are increasingly focusing on healthcare reform aimed at making healthcare more accessible and affordable.

The Council for Medical Schemes (CMS) has issued a circular declaring certain practices related to the selection of Designated Service Providers (DSPs) and the imposition of excessive co-payments as undesirable business practices. The impact of this is uncertain at this stage.

The National Health Insurance (NHI) Bill, the Medical Schemes Amendment Bill and the Office of Healthcare Standards: Norms and Standards introduced by the Department of Health (DOH) continue to require our attention.

We continue to monitor and action any revisions to regulations pertaining to the management of COVID-19. The Protection of Personal Information Act, 4 of 2013 (POPIA) came into effect on 1 July 2021 and the Group has taken the necessary steps to ensure compliance with the requirements of the act.

Internationally, we remain committed to adhering to the GDPR, which applies to the European Union (EU) and the European Economic Area (EEA).

How we manage the risk
  • Proactively monitoring and, where possible, providing input for any new proposed legislation.
  • Ensuring compliance through our quality standards.
  • COVID-19 compliance officers in place in our southern Africa business, and the COVID-19 compliance forum remains active.
  • Consulted with legal, and health and safety experts to ensure compliance with Disaster Management Act requirements.
  • Privacy policy and standard operating procedures in place to guide our business.
  • Compliance Risk Management Plans (CRMPs) in place for all material legislation.
  • Instituted a bi-annual compliance attestation process across the Group.
  • Compliance Champions operating model in place.
  • Regular and ongoing training on GDPR and POPIA requirements.
  • Processes are in place to ensure adherence to POPIA and GDPR requirements.

   
Key stakeholders
impacted
Opportunities
  • Assisting the industry in developing appropriate solutions through continued engagement with regulators and relevant bodies.
  • Enhancing and protecting our reputation through ongoing compliance with laws and regulations.
  • Transparent engagement processes could potentially enhance our relationships with a variety of stakeholders, including regulatory bodies.
Outlook

We believe that the Group is well-placed to address changing legislative and regulatory requirements and to ensure compliance with requirements. We do not expect the risk to increase materially in the short term.



Business resilience and continuity risk
     
Oversight by the Board:
RCITGC
    (2020: n/a)
Risk description
   
Level of control:

Infrastructure and equipment are key pillars supporting the delivery of high-quality healthcare and an excellent patient experience.

Effective processes for the regular maintenance and replacement of plant and equipment are necessary in ensuring delivery of safe, effective care, a safe work environment and continuity of services.

COVID-19 and the recent social unrest in South Africa have highlighted the risk of supply chain disruptions. Ensuring continuity of supply of critical stock, consumables and equipment is necessary to deliver quality patient care.

We are also impacted by a lack of reliable electricity supply in the southern Africa business and certain geographies are also impacted by water shortages, driven by climate change.

In our International business, regular and effective maintenance of cyclotrons is critical and skilled resources are required to operate these.

How we manage the risk
  • Regular maintenance and upkeep of equipment.
  • Regular maintenance and servicing on equipment is carried out in line with OEM specifications.
  • On-site facility and engineering teams.
  • Fire detection and fire-fighting equipment on-site.
  • Emergency and disaster planning in place.
  • Internal fire assessments, compliance assessments and risk assessments are carried out at all facilities.
  • External assessments of fire equipment, buildings and general equipment.
  • Emergency back-up generators at facilities for electricity.
  • Back-up borehole water supply at certain facilities.
  • Insurance is in place for the replacement of plant and equipment.
  • Contingency and business continuity plans.

   
Key stakeholders
impacted
Opportunities
  • Managing operational risk results in better, effective and sustainable operations.
  • Enhanced patient experience and quality care.
  • Reduction in losses from damage and business disruption.
Outlook

Business resilience and continuity is highly susceptible to changing global and national political and market conditions. This coupled with impacts of climate change could affect our business. However, we see the risk decreasing in the short-to-medium term as we complete investments in our information technology infrastructure and the maintenance and renewal of our facilities and equipment.



Clinical and patient safety risk
   
Change:
Oversight by the Board:
CGC, RCITGC
    (2020: 7)
Risk description
   
Level of control:

The quality of healthcare services provided by the Group and healthcare professionals and our patients' safety is of utmost importance to us. Failure to consistently deliver safe, high-quality care to our patients is a risk.

COVID-19 has resulted in excessive demand during infection peaks which together with employee shortages and capacity constraints could negatively impact on the quality of care at facilities.

We are exposed to the risk of clinical employees and medical professionals not following appropriate treatment protocols or professional guidelines resulting in inadequate patient care.

With the highly contagious nature of COVID-19 there is the potential risk of a large-scale outbreak at one or multiple of our facilities. No outbreaks at our facilities were evident over the financial year.

How we manage the risk
  • Implemented a quality management system (QMS) to ensure we provide quality healthcare, and established quality control procedures.
  • Acquired QMS certification, and we are ISO 9001 and ISO 13485 accredited through BSI.
  • Monitoring clinical performance indicators.
  • Quarterly national quality review meetings are held.
  • Regular internal quality assessments are carried out at each hospital by the quality systems support specialist (QSSS).
  • Medical malpractice and professional indemnity insurance in place.
  • Ongoing training of employees on quality procedures.
  • Established a dedicated doctor work stream, and constituted doctor COVID-19 committees and ethics sub-committees at hospitals to ensure correct clinical protocols are followed and ensure an adequate doctor supply.
  • Addressed COVID-19 related resource shortages by leveraging agency employees to meet increased demand or to stand in for infected employees, redeploying existing employees from other wards and postponing or cancelling leave.
  • Increased capacity through the sourcing of additional ventilators and other equipment required for treatment.
  • Conducted independent verification reviews at facilities to review COVID-19 treatment readiness plans and ensure alignment with Group protocols.
  • Instituted the standard practice of temporary capacity diverts (TCDs) at facilities to ensure the best possible treatment options for patients based on their acuity level.
  • Implemented various measures and guidelines to curb the spread of COVID-19 at our facilities, including infection prevention protocols, screening protocols, and guidelines for using personal protective equipment.

   
Key stakeholders
impacted
Opportunities
  • Enhancing the patient experience and protecting our reputation through an ongoing focus on quality and safety.
  • Improving patient care and safety according to industry best practice through continuous, robust engagements with health authorities and specialists.
  • Delivering clinical excellence through a smaller, more efficient, better trained and educated nurse workforce.
  • Developing clinical products that improve patient outcomes and deliver patient centric care.
Outlook

We expect the risk will decrease as COVID-19 admissions decrease and as our healthcare professionals and nurses become increasingly adept at managing the treatment of COVID-19 patients.



IT systems, infrastructure and project implementation
   
Change:
Oversight by the Board:
RCITGC
    (2020: 8)
Risk description
   
Level of control:

Information and information exchange are crucial to the delivery of quality care at all levels of the healthcare delivery system - the patient, clinicians and other healthcare service providers, funders and regulators. There is a drive towards electronic health records and digitisation as healthcare becomes more patient centric. Therefore, our IT infrastructure and systems must be appropriate and fit-for-purpose to respond to this cultural shift.

There is also a risk of failure to maintain reliable information systems for business operations in the event of an IT disaster like a data breach.

We are exposed to implementation risk regarding information management projects underway to improve existing infrastructure and ensure better Group-wide integration.

How we manage the risk
  • Regular assessments of our IT infrastructure are conducted, and action plans to effect enhancements and address shortcomings are implemented.
  • Ensure all software and/or hardware are upgraded/replaced before their end of life (EOL) term.
  • Annually perform disaster recovery tests, with action plans documented and implemented to address any identified shortcomings.
  • Following rigorous project management methodology, with strong business sponsor leadership and oversight.
  • A formal systems development lifecycle (SDLC) process in place and a total cost of ownership (TCO) costing model is applied to each project.
  • Project risk registers in place, with a response plan in place for identified risks.

   
Key stakeholders
impacted
Opportunities
  • Offer better and more efficient services to our patients by investing in our IT infrastructure, thereby lowering the cost of care while maintaining quality.
  • Appropriate and effective IT infrastructure and systems in place to support growth initiatives and performance expectations, allowing us the opportunity to be more competitive.
Outlook

We expect the risk to decrease as the business' ability to execute improves and as progress is made with our information technology strategic imperatives.

       


Reputational risk
   
Change:
Board oversight:
SET, CGC, RCITGC
    (2020: 9)
Risk description
   
Level of control:

The Group's reputation and relationships with key stakeholders could be affected by adverse events that occur while employees or other healthcare professionals perform clinical procedures or other related activities. Furthermore, events outside of our control can adversely affect our brand.

How we manage the risk
  • Proactive complaints management system in place.
  • Implementing quality management processes across the business, with ISO 9001 certification held.
  • Dedicated media strategy in place for dealing with complaints raised through the media and other media-related issues.

   
Key stakeholders
impacted
Opportunities
  • Enhancing and protecting our reputation through an ongoing focus on quality and a clear communication strategy.
Outlook

We do not expect to see any material movements in this risk in the short to medium term.