Accountability report

Corporate governance report

Members report 

South West London Integrated Care System (ICS), works to:  

• Improve outcomes in population health and healthcare  

• Tackle inequalities in outcomes, experience and access  

• Enhance productivity and value for money  

Help the NHS support broader social and economic development. The ICS works in partnership to deliver its four aims and is made up of The Integrated Care Partnership (ICP), The Integrated Care Board (ICB) and our six Places.   
 
The Integrated Care Partnership (ICP), has been established by the Integrated Care Board and the six South West London Local Authorities as a statutory committee that brings together a broad alliance of organisations and representatives concerned with reducing health inequalities, improving the quality of services and care, health and wellbeing of the population.   
 
This means that key partners responsible for managing health outcomes in South West London, i.e. provider trusts, local authorities, voluntary, community and eocial Enterprise organisations, and other local partners across primary and secondary care, come together to make decisions about local health services by using their local knowledge to improve services and focus resources where there is greatest need.   
 
The South West London Integrated Care Board is the statutory NHS organisation responsible for developing a plan for meeting the health needs of the population, managing the NHS budget and arranging for the provision of health services. The Integrated Care Board is overseen by a Board, which is the senior decision-making forum and is collectively accountable for the delivery of the Integrated Care Board’s responsibilities. Key decisions and functions reserved for the Integrated Care Board include agreeing the vision, values, strategic direction of the Integrated Care Board and determining actions that will improve health and health services for local people.  
 
The Board includes members from key NHS providers, local authorities, as well as Non-Executive Members, Integrated Care Board Executives and observers from voluntary sector organisations.   
 
Mike Bell has served as Chair of the Integrated Care Board since 1 May 2023. 

Katie Fisher, as Chief Executive, is the Accountable Officer for the Integrated Care Board. Non-Executive Members have specific areas of responsibility and Chair committees of the Integrated Care Board.   

Our Board

Role of the ICB Board

The Integrated Care Board operates as a unitary board, which means that all Board Members are collectively and corporately accountable for organisational performance. The purpose of the Board is to govern effectively and in doing so, build patient, public and stakeholder confidence that their healthcare is in safe hands.   
 
The Board is responsible for co-ordinating and supporting the provision of high-quality healthcare to the community, encompassing primary and secondary care services. It is the Board’s responsibility to ensure the organisation is successfully discharging its duties today and will continue to do so in the future. To do this the Board uses the information available to:  

• plan effectively: look at what is driving changes in demand, identify services which can help tackle immediate and long-term conditions, reduce avoidable ill-health and eliminate inequalities – and in parallel ensure workforce and capital plans reflect these areas 

• manage resources: based on what the organisation knows about care needs across the system’s communities and strategic priorities, establish a focused set of delivery and outcome expectations to make the most effective use of budgets and resources 

• ensure high-quality care is being provided: understand the provider landscape across different services, the collaborative(s), place(s) and other dynamics between organisations and procure cost-effective services to improve outcomes and wider population health 

• has assurance about care being delivered: use timely, accurate information on the quality and efficiency of care provided to gain assurance on the services being commissioned, pre-empt any issues and identify areas of improvement 

• consider risks and mitigations: identify, evaluate and manage risks to the ICB’s strategic and operational objectives.  

Our Board met in public seven times between May 2024 and March 2025, and we encourage our community to join us to find out about the work we’re doing. Read about public board meetings and download the papers  
 
As part of the establishment of the Integrated Care Board, the Health and Care Act 2022 introduced a new duty for NHS organisations to have regard to the effects of their decisions on the ‘triple aim’ of better health and wellbeing (including its effects in relation to inequalities), improved quality of services (including the effects of inequalities in relation to the benefits that people can obtain from those services) and the sustainable use of resources. Our structures and governance ensure we meet the triple aim and are described throughout this annual report.  
 
Effective working with people and communities is essential to deliver the triple aim. During the year, the principles of the triple aim have been embedded across the Integrated Care Board, including at Place (within boroughs) and through the Integrated Care Partnership as demonstrated in some of the following areas:  

• Development of the Integrated Care Strategy and related priorities at system level.  

• Engagement on the South West London Integrated Care Board’s Five-Year Joint Forward Plan.  

• Engagement with an Investment Fund, comprised of two funding streams:  

• The Innovation Fund  

• The Health Inequalities Fund 

The ICB’s Board was established on 1 July 2022 by ‘The Integrated Care Boards (Establishment) Order 2022’. Under the NHS South West London Integrated Care Board Constitution and Standing Orders. 

Read profiles of our board members 

Composition of the Board

Members of the Board are as follows: 

Committees including the Audit Committee

The Integrated Care Board has established four committees which are accountable to the Board. The delegated powers and responsibilities of the committees are as set out in the Scheme of Reservation and Delegation (SoRD). 

The committees supported our Board to carry out its statutory duties. The SoRD sets out: 

• Decisions and functions that are reserved to the Board as a whole. 

• Decisions delegated by the Board to the Integrated Care Board committees. 

• Decisions delegated to individual members and employees. 

The Integrated Care Board remained accountable for all of its functions including those that it had delegated. 
 
In discharging their delegated responsibilities, the Board and its committees were required to: 

• Comply with the principles of good governance. 

• Operate in accordance with the Integrated Care Board’s SoRD. 

• Comply with the Integrated Care Board’s Standing Orders. 

• Comply with the Integrated Care Board’s arrangements for discharging its statutory duties. 

Where appropriate, ensured that members have had the opportunity to contribute to the Integrated Care Board’s decision-making process through the membership group. 
 
When discharging their delegated functions, the Board and committees operated in accordance with their approved terms of reference. 

Audit and Risk Committee

The Audit and Risk Committee was responsible for providing oversight and assurance to the Integrated Care Board on the effectiveness of governance, risk management and internal control processes across the whole of the Integrated Care Board’s activities that supported the achievement of the Integrated Care Board’s objectives. A key purpose of the committee was to monitor the integrity of the financial statements of the Integrated Care Board and assure itself that relevant risks, particularly financial, are appropriately identified and managed within a robust system of internal control. The Committee was also responsible for seeking appropriate assurance on functions relating to arrangements for counter-fraud and audit work programmes. 

Remuneration Committee

The Remuneration and Nominations Committee’s main purpose is to exercise the functions of the Integrated Care Board relating to paragraphs 17 to 19 of Schedule 1B to the NHS Act 2006. 

The Committee was responsible for advising the Board on the implementation of the Integrated Care Board Pay Policy including adoption of any pay frameworks, and in meeting their responsibilities to ensure appropriate remuneration for all employees including very senior managers/directors (including Board Members) and Non-Executive Members, excluding the Chair. 

The Committee provides oversight of the nominations and appointments to Integrated Board member roles. 

Finance and Planning Committee

The Finance and Planning Committee was responsible for ensuring that there is both a robust financial strategy and planning framework in place and to oversee the system planning and broader financial management, including the review of financial plans and the current and forecast financial position of the Integrated Care Board and Place budgets. 

The Committee also aimed to understand the drivers behind any variances against the plans, ensure any risks have been identified, and mitigating actions had been taken to address these whilst providing assurance to the Board about delivery and sustained performance. 

Quality and Oversight Committee

The Quality and Oversight Committee was responsible for ensuring the Integrated Care Board secured continuous improvement in the quality of services, against each of the dimensions of quality set out in the Shared Commitment to Quality and enshrined in the Health and Care Bill 2021. This includes reducing inequalities in the quality of care. 

The Committee provided assurance to the Integrated Care Board, that there was an effective system of scrutiny, quality governance and internal control underpinning the effective delivery of its strategic objectives, and provision of sustainable, high-quality care. The Committee reviewed and escalated key performance risks to the Board, ensuing that there was system oversight of Performance including at Place and Collaborative level. 

With the engagement of respective Committee Chairs, members and attendees, the Terms of Reference for the Audit and Risk Committee, Quality and Oversight Committee, Finance and Planning Committee and Remunerations Committee have been reviewed and updated where appropriate to ensure they are fit for purpose and meet the needs of the Integrated Care Board. 

Membership and attendance at the Board and committees

Membership and attendance at the Board and respective committees is shown in the table below. All meetings were quorate. [TBC] 

The Board

The Integrated Care Board held seven meetings in public between 1 April 2023 and 31 March 2024.

Audit and risk committee

Finance and planning committee

_{~ required for planning and relevant items only} 

_{^ required for planning and relevant clinical-related items only} 

Quality and oversight committee

Remuneration and nominations committee

Register of interests

The ICB operated a robust policy for the management of Conflicts of Interest.  

All attendees were required to declare their interests as a standing agenda item for every ICB Board, Committee or meeting before the item was discussed.  

To protect the integrity of decision-making, arrangements for managing conflicts of interest and potential conflicts of interest were established. These includes recusing potentially conflicted members from deliberations where appropriate, and / or ensuring material (papers) were not circulated to potentially conflicted members. 

Personal data related incidents

During the period, the ICB identified no Serious Untoward Incidents relating to data security breaches, that were reportable to the Information Commissioner. 

Modern Slavery Act

NHS South West London Integrated Care Board fully supports the Government’s objectives to eradicate modern slavery and human trafficking.  

Read our slavery and human trafficking statement for the period ending 31 March 2025 

Statement of Accountable Officer’s responsibilities 

Under the National Health Service Act 2006 (as amended), NHS England has directed each Integrated Care Board to prepare for each financial year a statement of accounts in the form and on the basis set out in the Accounts Direction. The accounts are prepared on an accruals basis and must give a true and fair view of the state of affairs of the South West London ICB and of its income and expenditure, Statement of Financial Position and cash flows for the financial year. 

In preparing the accounts, the Accountable Officer is required to comply with the requirements of the Government Financial Reporting Manual and in particular to: 

• Observe the Accounts Direction issued by NHS England, including the relevant accounting and disclosure requirements, and apply suitable accounting policies on a consistent basis; 

• Make judgements and estimates on a reasonable basis; 

• State whether applicable accounting standards as set out in the Government Financial Reporting Manual have been followed, and disclose and explain any material departures in the accounts; and, 

• Prepare the accounts on a going concern basis; and 

• Confirm that the Annual Report and Accounts as a whole is fair, balanced and understandable and take personal responsibility for the Annual Report and Accounts and the judgements required for determining that it is fair, balanced and understandable. 

The National Health Service Act 2006 (as amended) states that each Integrated Care Board shall have an Accountable Officer and that Officer shall be appointed by NHS England. 

NHS England has appointed the Chief Executive Officer to be the Accountable Officer of South West London ICB. The responsibilities of an Accountable Officer, including responsibility for the propriety and regularity of the public finances for which the Accountable Officer is answerable, for keeping proper accounting records (which disclose with reasonable accuracy at any time the financial position of the Integrated Care Board and enable them to ensure that the accounts comply with the requirements of the Accounts Direction), and for safeguarding the South West London ICB assets (and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities), are set out in the Accountable Officer Appointment Letter, the National Health Service Act 2006 (as amended), and Managing Public Money published by the Treasury. 
 
As the Accountable Officer, I have taken all the steps that I ought to have taken to make myself aware of any relevant audit information and to establish that South West London ICB’s auditors are aware of that information. So far as I am aware, there is no relevant audit information of which the auditors are unaware.

Governance statement

***KLOE A3: How has the ICB implemented effective governance?***

Introduction and context

South West London ICB is a body corporate established by NHS England on 1 July 2022 under the National Health Service Act 2006 (as amended).   

The South West London ICB’ s statutory functions are set out under the National Health Service Act 2006 (as amended). 

The ICB’s general function is arranging the provision of services for persons for the purposes of the health service in England.  The ICB is, in particular, required to arrange for the provision of certain health services to such extent as it considers necessary to meet the reasonable requirements of its population.   

Between 1 April 2024 and 31 March 2025 the Integrated Care Board was not subject to any directions from NHS England issued under Section 14Z61 of the of the National Health Service Act 2006 (as amended). 

Scope of responsibility

As Accountable Officer, I have responsibility for maintaining a sound system of internal control that supports the achievement of the South West London ICB’s policies, aims and objectives, whilst safeguarding the public funds and assets for which I am personally responsible, in accordance with the responsibilities assigned to me in Managing Public Money. I also acknowledge my responsibilities as set out under the National Health Service Act 2006 (as amended) and in the South West London ICB’s Accountable Officer Appointment Letter. 

I am responsible for ensuring that the South West London ICB is administered prudently and economically and that resources are applied efficiently and effectively, safeguarding financial propriety and regularity. I also have responsibility for reviewing the effectiveness of the system of internal control within the ICB as set out in this governance statement. 

Governance arrangements and effectiveness

The main function of the Board is to ensure that the Integrated Care Board has made appropriate arrangements for ensuring that it exercises its functions effectively, efficiently and economically, and complies with such generally accepted principles of good governance as are relevant to it. 

The Integrated Care Board’s constitution sets out how it shall fulfil its statutory duties and the primary governance rules for the Integrated Care Board. It includes information on Board membership and governance arrangements in line with relevant guidance issued by NHS England and complies with the Health and Care Act 2022. Following extensive engagement with local stakeholders, and approval by NHS England, the constitution came into effect following the establishment of the Integrated Care Board on 1 July 2022.  

Following guidance from NHS England, the Board agreed revisions to the constitution in November 2024 which incorporated several small amendments.   

UK Corporate Governance Code

We are not required to comply with the UK Corporate Governance Code. However, we have reported on our Corporate Governance arrangements by drawing upon best practice available, including those aspects of the UK Corporate Governance Code and the Corporate Governance in Central Government Departments: Code of Good Practice 2011 (HM Treasury and Cabinet Office) that we consider to be relevant to the Integrated Care Board. 

Discharge of statutory functions

The arrangements put in place by the Integrated Care Board and explained within the corporate governance framework were developed to ensure compliance with all relevant legislation. 

The Integrated Care Board has reviewed all of the statutory duties and powers conferred on it by the National Health Service Act 2006 (as amended) and other associated legislation and regulations.  As a result, I can confirm that the Integrated Care Board is clear about the legislative requirements associated with each of the statutory functions for which it is responsible, including any restrictions on delegation of those functions. 

Responsibility for each duty and power has been clearly allocated to a lead Director.  Directorates have confirmed that their structures provide the necessary capability and capacity to undertake all of the Integrated Care Board’s statutory duties. 

Risk management arrangements and effectiveness

The Integrated Care Board has a robust internal control mechanism to allow it to prevent, manage and mitigate risks. The risk assessment section describes our approach to risk management and appetite for risk, explaining the key components of the internal control structure. Alongside the Integrated Care Board’s governance framework, these arrangements underpin the ICB’s ability to control risk through a combination of: 

• Prevention – the Integrated Care Board’s structures, governance arrangements, policies, procedures, and training minimise the likelihood of risks materialising 

• Deterrence – staff are made aware that failure to comply with key policies and procedures, such as the Standards of Business Conduct Policy or the Fraud, Bribery and Corruption Policy, will be taken seriously by the Integrated Care Board and could lead to disciplinary action, or dismissal 

• Management of risk – once risks are identified, the arrangements for ongoing monitoring and reporting of progress through the Committee structure to the Integrated Care Board ensures appropriate action is taken to manage risks. 

Capacity to handle risk

The Senior Management Team is responsible for oversight of the risk management process, its members review both risk registers and the Board Assurance Framework (BAF) as part of their business cycle, and the management of all Integrated Care Board corporate risks are overseen by an executive director. It evaluates the status of risks, identifies new risks, and monitors effectiveness of the Integrated Care Board’s board assurance and risk management control systems 

The responsibilities of Directors and Committees are set out in the Constitution and the accompanying Scheme of Delegation, as well as the governance reporting lines. Timely and accurate information to assess risk and ensure compliance with the Integrated Care Board’s statutory obligations, is supported by the annual plan of committee work. The Board has rigorous oversight of the performance of the Integrated Care Board, via formal Board meetings, seminars and through assurances received from committees and audits. 

The overall responsibility for the management of risk lies with the Accountable Officer. The Board collectively ensures that robust systems of internal control and management are in place. These arrangements, and the enhancements that have been made to them, are described in the Risk Assessment section of this report. 

Risk management capacity continues to be developed across the Integrated Care Board. The statutory and mandatory training programme includes numerous elements relevant to risk management, including information governance, health and safety, fire safety, safeguarding adults and children and counter fraud.  Staff have been invited, and attended a Risk Awareness workshop, conducted by the Head of Risk. 

Board and Committee reporting arrangements prompt authors to consider that key aspects of risk have been reviewed. 

Risk assessment

The Senior Management Team is responsible for oversight of the risk management process. It evaluates the status of risks, identifies new risks, and monitors effectiveness of the Integrated Care Board’s board assurance and risk management control systems. 

The Audit Committee provides scrutiny and independent assurance to the ICB Board on the effectiveness of the Integrated Care Board’s board assurance and risk management processes. 

The Board reviews the content of the BAF twice a year as a means of assessing the current level. 

All other sub committees of the Board review those risks specific to their area and are made aware of significant changes to the risk register at each meeting. 

Operational management of the BAF is provided by the Integrated Care Board’s Corporate Affairs team. Regular meetings are held with manager leads to review progress and performance of each of the priority areas and associated risks. 

The BAF forms the basis for the Board to assess its position regarding achieving its corporate objectives. It uses principal risks to achieve those objectives as the foundation for assessment. It considers the current level of control alongside the level of assurance that can be placed against those controls.  

The BAF has been created from three core areas of the Integrated Care Board’s more detailed Corporate Risk Register: 

• Risks with a significant residual score, for example, those that score 15 and above 

• Those risks that we believe are either likely to be growing in significance or that we wish to flag to the Board as posing a risk to delivering essential areas of work. 

• Overarching risks that collate and summarise several more detailed risks present on the risk register. For example, finance. 

The Integrated Care Board views risk management as key to the successful delivery of its business and remains committed to ensuring staff are equipped to assess, manage, escalate and report risks. This ensures a comprehensive overview of all the risks affecting the organisation and facilitates decision making about those risks that need immediate treatment and those that the organisation can tolerate for a specified amount of time. 

The Integrated Care Board uses an NHS standard risk scoring matrix (CASU 2002) to determine the scales of impact and likelihood of adverse events. The scale is scored from 1-25 (with 1 being the least severe and 25 being the most). The risk will continue to be managed at director level with oversight by the committee relevant to the risk as well as oversight from the Audit and Risk Committee. This allows: 

• The appropriate level of investigation and causal analysis to be carried out. 

• Identification of the level at which the risk will be managed, the assigning of priorities for remedial action and determination of whether the risk will be accepted. 

Using the residual risk rating (i.e., after controls are taken into account), in the most recent iteration of the BAF, there are seven risks of significant nature (significant risks are those on the risk register scored at 15 and above or deemed to be of a significant in nature to be included on the BAF): 

• RSK-001 Delivering access to care (NHS Constitution Standards. 

• RSK-011 Failure to modernise and fully utilise our estates. 

• RSK-014 Financial Sustainability.   

• RSK-025 Workforce capacity wellbeing and availability. 

• RSK-037 Urgent and Emergency Care. 

• RSK-087 System Quality Oversight. 

• RSK-149 Interruption to clinical and operational systems as a result of a cyber-attack.   

Other sources of assurance

Internal Control Framework

A system of internal control is the set of processes and procedures in place in the South West London ICB, to ensure it delivers its policies, aims and objectives. It is designed to identify and prioritise the risks, to evaluate the likelihood of those risks being realised and the impact should they be realised, and to manage them efficiently, effectively and economically. 

The system of internal control allows risk to be managed to a reasonable level rather than eliminating all risk; it can therefore only provide reasonable and not absolute assurance of effectiveness. 

While the Health and Care Act 2022 places responsibility on ICBs to manage conflicts of interest and publish their own CoI policy, which should be included in ICB’s governance handbook, NHS England’s engagement with local stakeholders suggests nationally-commissioned basic training would be of value to avoid unnecessary duplication across systems. NHS England will provide updated national e-learning modules on managing conflicts of interest in the context of the new ICB arrangements and also explore developing additional guidance on conflicts of interest in consultation with ICB Chairs. 

Our governance structures are used to ensure effective oversight of operational and strategic decisions and compliance with the NHS regulatory environment. Details of the Board responsibilities and those of its committees are outlined above and described in further detail within the Constitution.   

Ensuring effective risk management, financial management and compliance with statutory duties is high on the list of our priorities. We have implemented policies, systems processes, and training  to reduce exposure in these areas and to ensure that we are legally compliant. Each committee and group oversees risks and policies relating to their area of responsibility. Clinicians and management work in partnership through the commissioning cycle, adding value and delivering outcomes, to ensure the procurement of quality services that are tailored to local needs and deliver sustainable outcomes and value for money. 

The Integrated Care Board has established an effective organisational structure with clear lines of authority and accountability which guards against inappropriate decision making and delegation of authorities enabling the Integrated Care Board to meet its statutory duties and follow best practice guidelines. Work to ensure that we promote and demonstrate the principles and values of good governance and the review of governance related risks takes place at Senior Management Team meetings and assurance is provided by the Audit and Risk Committee to the Board with insight from Internal Audit.  

The Committee also ensures that, in non-financial and non-clinical areas that fall within the remit of its terms of reference, appropriate standards are set and compliance with them is monitored. We have considered the effectiveness of our governance framework and processes and raised no significant concerns on governance related matters this year. 

The system of internal control is based on an ongoing process designed to identify and prioritise the risks to the achievement of the policies, aims and objectives of the Integrated Care Board, to evaluate the likelihood of those risks being realised and the impact should they be realised, and to manage them efficiently, effectively, and economically.  

The system of internal control has been in place in the Integrated Care Board for the year ended 31 March 2025 and up to the date of approval of the annual report and accounts. 

Data quality

The Board regularly receives reports that cover financial, governance, compliance, performance and quality matters for the Integrated Care Board. 

The Integrated Care Board has a business intelligence and performance function which monitors how local providers are performing against key performance indicators. This information is reported to the Board on a regular basis. 

The data contained in the reports is subject to significant scrutiny and review, both by management and by Integrated Care Board committees. The quality of information received to direct decision making is also assured through South West London Business Intelligence and Analytics function. The Board is confident that the information it is presented with has been through appropriate review and scrutiny, and that it continues to develop with organisational needs. 

Information governance

The NHS Information Governance Framework sets the processes and procedures by which NHS organisations handle data and information on patients and employees, in particular personal identifiable and sensitive personal information. The NHS Information Governance Framework is supported by a Data Security and Protection Toolkit (DSPT) and the annual submission process provides assurances to the Integrated Care Board, other organisations and to individuals that personal information is dealt with legally, securely, efficiently and effectively. 

The Integrated Care Board is due to submit its DSPT in June 2025. The ICB previously published its DSPT in June 24 to ‘Standards Met’. 

We place high importance on ensuring there are robust information governance systems and processes in place to help protect both patient and corporate information. We have established an information governance management framework and have developed robust information governance processes and procedures in line with the Data Security and Protection Toolkit. We ensure all staff and interim contractors undertake mandatory annual information governance training to ensure staff are aware of their information governance roles and responsibilities in line with the implementation of our information governance framework. 

There are processes in place for the reporting and investigation of information governance breaches or suspected breaches. We have a developed and implemented information risk assessment and management procedures which is regularly reviewed via our information governance steering group chaired by our Deputy SIRO. 

Third party assurances

The Integrated Care Board relies on a number of third-party providers (such as NHS SBS and NHS BSA) to provide a range of transactional processing services ranging from finance to data processing. Our requirements for the assurance provided by these organisations are reviewed every year. Appropriate formal assurances are obtained to supplement routine customer/supplier performance oversight arrangements. 

Control issues

NHS South West London Integrated Care Board received services from a number of external providers and at the end of the year received a service auditor report from each of these: 

1. NHS Business Services Authority (BSA) – Electronic Staff Record (ESR) -Type II ISAE 3000 Controls Report 

2. Transformation Directorate within NHS England (previously NHS Digital) – Extraction and Processing of General Practitioner Data Services in England -Type II ISAE 3000 

3. NHS Business Services Authority (BSA) – Prescription Payments Process -Type II ISAE 3402 

4. Capita Business Services Limited – Primary Care Support England – Type II ISAE 3402 

5. NHS England South, Central and West Commissioning Support Unit – Calculating Quality Reporting Service (CQRS) National – Type II ISAE 3402 

6. NHS North of England Commissioning Support Unit – Payroll Services – Type II ISAE 3402 

7. NHS Shared Business Services Limited (SBS) – Finance and Accounting Services – Type II ISAE 3402 

Where exceptions have been raised in these, we consider the impact on the Integrated Care Board and if appropriate add local controls to mitigate the impact of any weaknesses identified. We have shared these Service Auditor Reports with Internal Audit who do not consider there are any issues sufficiently significant to alter their view of the controls as designed and operating at the Integrated Care Board. 

Review of economy, efficiency and effectiveness of the use of resources

The Integrated Care Board, through its meetings, retains primary oversight of the appropriateness of arrangements in place within the organisation to exercise its functions in an effective, economic and efficient manner. The Accountable Officer for the Integrated Care Board retains overall executive responsibility for the use of our resources. 

The organisation has a number of key processes and internal mechanisms that provide assurance that we are operating within our statutory authority: 

Within our constitution there are clearly defined standards for conducting business, Standing Orders, Scheme of Reservation and Delegation along with Prime Financial Policies that ensure the effective management and protection of assets and public funds. 

Key policies are in operation in respect of contract management and procurement that ensure effective operational and financial performance whilst ensuring we operate within regulatory frameworks and reduce the likelihood and impact of risk. 

There is a clearly defined process for the consideration of business cases and saving opportunities to ensure transparency and value for money is upheld. 

The Commercial Procurement Advisory Group evaluates the robustness of proposed business cases before these are then considered by the Senior Management Team,  Finance and Planning Committee or ICB Board.  

The Quality and Oversight Committee is accountable for overseeing a robust, organisation-wide system of quality and performance. 

The Finance and Planning Committee ensures that the finances of the Integrated Care Board are scrutinised to ensure budgets are managed in an appropriate and timely manner. It will ensure that the Board is fully aware of any financial risks which may materialise throughout the year. It works alongside the Audit and Risk Committee to ensure financial probity in the organisation. 

These committees have on behalf of the Integrated Care Board, an overview of all aspects of finances (including capital spend and cash management). 

Delegation of ICB functions

To enable effective decision making, the Integrated Care Board operated under its Scheme of Reservation and Delegation (SoRD), as agreed by the Board, which sets out how and where decisions are taken. The SoRD specified which functions are reserved to the Board, and which functions have been delegated to an individual, committee or other group.  

The Integrated Care Board has an effective Governance Framework which supports and enables the Board to comply with its statutory functions and duties. As noted in the member profiles, the Board is constituted from a broad range of organisations from within South West London, either as full members, participants or observers of the Board. The Board was appointed in line with NHS England guidance and ensures we have a broad range of experience and expertise helping us to deliver an effective decision-making process.   

In South West London, we have six ICS Places: Croydon, Kingston, Merton, Richmond, Sutton, and Wandsworth which are co-terminus with the respective six Local Authorities. Our Places allow the Integrated Care Board to join up and co-ordinate the development and delivery of services according to the needs of their local populations.  

Each Place discharges its duties in accordance with the Integrated Care Board’s SoRD, and as such a robust model of governance has been developed to ensure clear and transparent decision-making at Place level which support the overall delivery of the Integrated Care Board’s statutory responsibilities. 

Counter fraud arrangements

Counter fraud arrangements are in place in the Integrated Care Board to ensure compliance with standards set by the NHS Counter Fraud Authority Standards for Commissioners: Fraud, Bribery and Corruption. 

• An accredited Local Counter Fraud Specialist (LCFS) is contracted to undertake counter fraud work proportionate to identified risk 

• The Integrated Care Board’s Audit and Risk Committee receives progress reports throughout the year and an annual report against each of the standards for commissioners. 

• There is executive support and direction for a proportionate proactive work plan to address identified risks. 

• Regular fraud related communications are shared with Integrated Care Board staff and training is delivered to all staff. 

• The LCFS meets with the Director of Finance and Internal Audit to agree tasks to be undertaken as part of the workplan. 

• The LCFS also has regular liaison with the Director of Finance to discuss any concerns that come to light throughout the year. 

• A member of the Executive Team (the Chief Finance Officer) is proactively and demonstrably responsible for tackling fraud, bribery and corruption. 

There have been no assessments from the NHS Counter Fraud Authority, but should one occur an action plan would be taken forward following any recommendation made.

Head of Internal Audit opinion

****To be included by internal audit once completed for final draft **** 

Review of the effectiveness of governance, risk management and internal control

My review of the effectiveness of the system of internal control is informed by the work of the internal auditors, executive managers and clinical leads within the Integrated Care Board who have responsibility for the development and maintenance of the internal control framework. I have drawn on performance information available to me. My review is also informed by comments made by the external auditors in their annual audit letter and other reports.  

Our assurance framework provides me with evidence that the effectiveness of controls that manage risks to the Integrated Care Board achieving its principles objectives have been reviewed.  

I have been advised on the implications of the result of this review by:  

• The Board 

• The Audit and Risk committee 

• Finance and Planning committee,  

• Quality and Oversight committee 

• Internal audit 

The role and conclusions of each were captured within the reports of the assurance committees to the Board. 

Remuneration report

*****To be included once final year figures are available in next draft *****

Staff report

Communications and engagement

Staff communications and engagement remained a top priority as we supported our staff through the Management Costs Savings programme while continuing to deliver services to support local people.  

In September 2024, we held a staff conference bringing together over 300 staff for the first time since the pandemic. It was opportunity to meet and connect with colleagues in person and share our hopes and aspirations for the future of our organisation. We also shared our new organisation values and launched a staff recognition programme.  

Throughout the year, we continued to provide clear and effective communications, including:  

• online all staff briefings led by our Chief Executive Officer, who shares and discusses the latest NHS and South West London priorities. 

• monthly Team Talk meetings led by executive directors who discuss organisational news and updates and celebrate our achievements. 

• support to line managers to ensure they are equipped to support their staff during the management cost savings process.  

• a weekly email bulletin which provides news and workforce updates. 

• an intranet where staff can find all the latest news and updates, policies, learning and development opportunities, and health and wellbeing support. 

• Community Office Days that bring staff together in person once a month to connect, collaborate, and make the most of the office environment.  

• staff networks that bring staff together to talk and share ideas and suggestions about what matters most to us at work such as health and wellbeing, the green agenda, and our ways of working. 

• staff stories that celebrate our diverse workforce and an opportunity to learn about our cultures and traditions that are important to us. 

NHS staff survey

NHS South West London commissioned Picker Institute Europe to run a National Staff Survey for us locally during September and October 2024. The ICB had a score of 6.41 for Staff Engagement which was slightly lower than our 2023 score of 6.51. For comparison, the average ICB score across the country was 6.63. 

A total of 470 took part in the survey, giving a response rate of 75%. We are grateful to everyone who completed the survey as this provides us with rich data to inform further improvements to staff experience. 

The results of the survey were published in March 2025. We are pleased to see some improvements, however, there are several areas where we need to act. 

Where we’re doing well

Where we’re doing less well

During May and June 2025, we will be holding interactive sessions with each of our teams to review the findings together and develop directorate and organisational action plans to address the improvement areas identified. We will launch the action plan and areas of focus at our staff conference in June. 

Read more about the NHS staff survey on the NHS staff survey website

Staff policies

We promote a working environment in which we aim to ensure all policies and procedures relating to recruitment, selection, training, promotion and employment are free from discrimination, ensuring that no employee or prospective employee is discriminated against, whether directly or indirectly on the grounds of age; disability; gender reassignment; pregnancy and maternity; race including ethnic or nationality; religious belief; sex (gender); sexual orientation; disability; marriage and civil partnership status; trade union membership; responsibility for dependents or any other characteristic identified legally as protected in the Equality Act 2010 or through any other relevant legislation. 

Where staff who have a disability we endeavour to make sure that the requirements and reasonable adjustments necessary for employees with a disability are considered both during each stage of the recruitment process and during employment. 

Our Sickness Absence Policy confirms that where an employee becomes disabled during their employment, we will support them with occupational health advice and to see if any reasonable adjustments will enable the employee to return and remain at work in accordance with the Equality Act. The types of adjustments may include adjustments to work base, working hours, redeploying the employee to another suitable position, and providing any necessary equipment to assist the employee to perform their role. 

We have centralised our people policies ensuring they have gone through the Equality Impact process to ensure there are fair outcomes for our workforce, and that they meet the accessibility standards. 

People and organisational development strategy

Since the publication of the Joint Forward Plan in July 2023 and a number of significant drivers including: the NHS long-term plan; Equality, Diversity and Inclusion Improvement Plan; and Integrated Care Partnership’s four priorities, we have reshaped our ambitions and the associated delivery plans into four workforce transformation programmes to make South West London a great place to work: 

• Attract – our recruitment strategies, partnerships for talent sourcing, and the measures we have implemented to make South West London ICS a great place to work.   

• Retain – our efforts to ensure that once talented staff are part of our team, they find a supportive and fulfilling work environment that encourages long-term commitment and career growth within South West London.   

• Develop – our commitment to ongoing education and professional development, ensuring that our staff are not only competent but also at the forefront of healthcare innovation and best practices.  

• Transform – our initiatives aimed at reshaping our workforce structure and practices to ensure maximum efficiency, adaptability, and responsiveness to the changing healthcare landscape.  

Compassionate and inclusive leaders

We have commissioned a learning partner to support our compassionate and inclusive leadership programme, the aim of which is to explore and build an inclusive and compassionate culture through our most senior leaders. The programme has been developed to inform, challenge, and extend thinking and apply that thinking to the practical ways in which leaders act as cultural influencers in the organisation. 

Inclusive culture

Over the year we have provided many opportunities for staff to talk and learn about diversity, equality and inclusion. We have: 

• Worked with our leaders through the leadership forum and delivered bespoke development sessions for our leaders and managers. 

• Trained over 40 members of staff to sit on recruitment panels and be an inclusive recruitment champion.  

• Held a number of drop-in sessions. 

• We celebrate key events such as LGBT+ History Month; Disability History Month and International Women’s Day as well as acknowledging important days for all the main faiths in our internal communications. 

All our people policies have gone through the Equality Impact process to ensure there are fair outcomes for our workforce. 

Management cost savings programme update

Last year, we continued to implement the Management Costs Savings programme and reduce our staffing levels workforce by 30%. 

We developed a plan on how the ICB will operate from 1 April 2024 to ensure that we deliver our ICB priorities with reduced staffing levels and that we have a well-managed transition to our new structures.  

In September 2024, we held a staff conference bringing together over 300 staff to meet and connect with colleagues in person and share our hopes and aspirations for the future of our organisation. We also shared our new organisation values and launched a staff recognition programme.  

Caring for our staff

We recognised last year was an unsettling time for our staff and continued to put in place a range of support for them over this time, including interview support and career coaching. To support people who have Suitable Alternative Employment status we have held a number of sessions to answer any questions our staff had and outlined the change process and requirements as we move forward. We also continued to meet with managers to outline the important role they have to support our staff during time.  

In addition, we acknowledged important days in our internal communications channels such as: World Mental Health Day, World Menopause Day, Movember, Stress Awareness Month, and Sickle Cell Awareness Month. We also provided health advice to stay hydrated during the hot weather and stay healthy during winter. 

The staff health and wellbeing network continued to develop organised activities to support staff to maintain their mental and physical health and wellbeing.  

We also continued to promote free health and wellbeing resources for NHS staff through our internal communications channels including: 

• Employee assistance programme – free and confidential life management and personal support service 

• Staff discounts and offers 

• Mental health reps – trained mental health first aiders who can listen, support and signpost people to expert advice and help 

• South West London Mental health and wellbeing hubs – provide health and social care colleagues with rapid access to local, evidence-based mental health and wellbeing services and support offering staff a clinical assessment, quick access to counselling and supported onward referrals to more specialist services.  

• #Our NHS People – access to the national NHS staff wellbeing support service 

• Drop-in open sessions – providing an opportunity for staff to connect with colleagues. Once a month, the session is hosted by a Psychological Wellbeing Practitioner from NHS Richmond Talking Therapies who leads discussions around mental health. 

• Book club – including free subscription to Borrow Box 

• FutiTalks sessions – a weekly sport/talk therapy group 

• Health and Wellbeing webinars hosted by NHS England 

Diversity and workforce race equality

The Workforce Race Equality Standard (WRES) was developed to narrow the gap between the treatment of black and minority ethnic and white staff through collection, analyses and acting on specific workforce data. In addition, the WRES aims to improve diversity of leadership and the experience of staff from ethnic minorities within an organisation. The WRES was introduced in 2015 to ensure employees from Black and minority ethnic backgrounds have equal access to career opportunities and receive fair treatment in the workplace. We have made significant progress in several areas and are committed to continued innovation and progress for the WRES. 

Nationally there has been a significant increase in the number of Black and ethnic minority staff. An increase of over 27,500 was seen in the last year, with Black and ethnic minority representation in the workforce increasing from 22.4% to 24.2%. In London, Black and ethnic minority staff make up 49.9% of the workforce. In South West London, Black and ethnic minority staff make up 51% of the workforce, this is the largest percentage of out of the five ICBs in London and has significantly increased from 39.7% over the last two years. 

Anti-racism approach

In South West London, we oppose all forms of racism and will work to dismantle racist and discriminatory policies and practices across all of health and care. We want to make anti-racism everyone’s business. We want to be an anti-racist system by developing an anti-racism approach, focusing on the strategic commitments: 

• Leadership commitment: to being anti-racist health and care systems and organisations, with Board representation, strategy development and anti-racist approach to all policies. 
• Commitment to our ethnic minority workforce: to support our ethnic minority staff and create enabling workplaces. 
• Commitment to target health equity: to prioritise and deliver evidence informed, culturally competent interventions to narrow the gap, by reducing inequities people from ethnic minorities face in access, uptake, experiences and outcomes of our health and care services. 
• Commitment to becoming an anchor institution: anchor institutions are large organisations like local NHS trusts who have a strong connection with the wellbeing of the populations we serve, we will work to leverage our position to tackle the wider determinants of inequality. 
• Commitment to our local communities: to work with our communities to amplify their voices, in the decision, design and delivery of services, to rebuild trust and confidence. 

We have set up a South West London anti-racism strategy and implementation group represented by health inequalities and/or EDI partners from the NHS, local authorities and VCSEs. The group will provide strategic direction and inform the development of the anti-racism approach. 

Parliamentary accountability and audit report

***To be included in a later draft   ***

Independent auditor’s report

***To follow****