Quick Bites: Policy Frameworks (Pt II)

Quick Bites is a series where I pen three quick learning points about a particular topic, to fit in with my post COVID-19 lockdown schedule. 

This post is a continuation of my previous post on Policy Frameworks. I will summarise three elements of a good policy framework:

1. Policy hierarchy: Any framework will have a series of associated levels, with each having different objectives. The figure below illustrates an example.

The article points out that some organisations will differentiate between policies and procedures. Procedures generally reflect governance or operational standards, provide a specific guide to decision making, and explain how policies are put into effect. But sometimes ‘policy’ and ‘procedures’ are linked in a document, which will be collectively referred to as a ‘policy’. For example, there may be the expectation that some policies, such as those related to conflicts of interest, will include the relevant procedures to deal with a conflict or potential conflict when it arises.

2. Policy levels: The article shares two common levels of policy frameworks:

i. Governance: policy with board level risk or strategic implications or with board level statutory or regulatory requirements (e.g. ASX, APRA), and relates to the processes of decision making and the controls and behaviours that support effective accountability and performance outcomes (e.g. risk management policy, code of conduct);

ii. Operational: (my own definition) policy that determines working-level outcomes, such as the day-to-day functioning of a company, and guidance for a company’s operations. Examples include employee travel, finance, and HR.

3. Roles and Responsibilities: The article prefaces this point with the importance of having clear terminology. A glossary or vocabulary of definitions can help ensure consistency of terms throughout policy documents. They should always be written in plain English, avoiding jargon, acronyms/abbreviations, obscure terms and technical/professional jargon as far as possible, especially if the policy is meant for organisation-wide compliance.

Setting roles and responsibilities includes:

  • The need for clear authority for the formulation of policy documents (i.e., delegations of authority);
  • Guidance concerning the responsibilities of policy owners and how policy is formulated, approved and disseminated;
  • The selection of a policy system manager for the management of organisational policy documents and for setting standards as to the development, content and review of those documents.

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