Recommendations & Conclusions
17 items
2
Recommendation
Twentieth Report - Monitoring and respo…
Accepted
We are concerned that departments are not maintaining institutional knowledge relating to ‘at risk’ companies and sectors. HM Treasury monitors the health and resilience of the corporate sector as a whole and the Department for Business and Trade oversees industry and different priority sectors and has a role in responding …
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We are concerned that departments are not maintaining institutional knowledge relating to ‘at risk’ companies and sectors. HM Treasury monitors the health and resilience of the corporate sector as a whole and the Department for Business and Trade oversees industry and different priority sectors and has a role in responding to economic shocks. It is the responsibility of individual departments to monitor the health of their sectors, and those at the centre of government say they are not aware of any one sector that is more at risk than others. However, a high turnover of staff in government means that corporate knowledge held by departments, which may be commercially sensitive and therefore restricted to a small handful of individuals, is at risk of being lost. HM Treasury spending teams act as the filter for warnings from departments, but turnover of staff in HM Treasury is historically even higher. Recommendation 2: In the Treasury Minute response, HM Treasury and the Cabinet Office should set out how they will support departments to maintain a continuous level of knowledge about risks to companies and supply chains in sectors that are relevant to their departmental duties and objectives.
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Government response AI summary
The government states it already supports departments through existing mechanisms, including commercial engagement on supplier risk, two-way intelligence sharing, Orange Book guidance, and Cabinet Office commercial teams providing regulation, guidance, and playbooks. Additionally, the DBT recently published a Critical Imports and Supply Chains Strategy to …
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HM Treasury
3
Recommendation
Twentieth Report - Monitoring and respo…
Accepted
We are not convinced that accounting officers give sufficient consideration to the commercial models of those they contract with, which means they do not understand the potential risks (including supplier failure). HM Treasury suggests accounting officers should produce a formal Accounting Officer Assessment for 6 Monitoring and responding to companies …
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We are not convinced that accounting officers give sufficient consideration to the commercial models of those they contract with, which means they do not understand the potential risks (including supplier failure). HM Treasury suggests accounting officers should produce a formal Accounting Officer Assessment for 6 Monitoring and responding to companies in distress any significant novel and contentious proposal involving the use of public funds. However, we often see a tendency in government to push ahead with new projects and commitments involving the private sector without careful consideration of the risks and liabilities it exposes the government to. Too often, the government has failed to understand the economic and business models of the suppliers it contracts with, and as a result has not been able to assess whether the gain-share and pain-share mechanisms of the contract are appropriate. This includes risks with outsourcing a service for the first time in “untested markets”, which we saw materialise when the Ministry of Justice rushed through reforms to outsource probation services to community rehabilitation companies. The Government Commercial Function now advocates piloting and scenario-testing in these situations but could not tell us how it measured success. Recommendation 3: HM Treasury should set out in the Treasury Minute response how it will ensure accounting officers explicitly address the risks presented by suppliers’ commercial models in Accounting Officer Assessments for new projects and commitments involving private companies. Should the assessment identify a risk of company failure, we expect it to include an estimate of the impact of supplier failure, high-level contingency plans should failure occur, and an estimate of the potential costs incurred.
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Government response AI summary
The government states it already ensures Accounting Officers address supplier commercial risks through existing guidance documents like the AO Assessments Guidance, Managing Public Money, the Sourcing Playbook (which includes guidance on supplier failure and contingency planning), and the Orange Book for risk management.
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HM Treasury
4
Recommendation
Twentieth Report - Monitoring and respo…
Accepted
We are concerned that accounting officers may not always be equipped to protect taxpayers’ money when making decisions on intervention in these fast-paced, high-pressure situations. This Committee and previous committees have reported many times over the past two decades on government interventions in financially distressed companies. Prior to 2020, the …
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We are concerned that accounting officers may not always be equipped to protect taxpayers’ money when making decisions on intervention in these fast-paced, high-pressure situations. This Committee and previous committees have reported many times over the past two decades on government interventions in financially distressed companies. Prior to 2020, the government acknowledges that it took an ad hoc approach to providing support to distressed companies. Since then, HM Treasury has established some high-level principles to apply to company distress cases. Nonetheless, decisions about whether or how to intervene in companies require accounting officers to make difficult judgements and balance complex trade- offs, often at speed. In the case of Silicon Valley Bank UK, government officials had to rapidly draw up several options for how the government could respond to the situation, over the course of a weekend. Accounting officers need to ensure any decisions on intervention adhere to the principles of feasibility, propriety, regularity and value for money, as set out in Managing Public Money. It is important therefore that accounting officers can articulate the trade-offs they are balancing and any consequences of their decisions, including how any moral hazard (where support for one company creates an incentive for other companies to take risks with the expectation they will also be supported) or free rider risks (where the company’s incumbent lenders or shareholders may benefit from government support without having to contribute themselves) might be managed over the course of an intervention. It is also important that they consider exit strategies and articulate how they will manage the intervention under different scenarios, including if the government ends up being involved for the medium to long term, and consequent unforeseen costs. Recommendation 4: HM Treasury should set out in the Treasury Minute response what it is doing to support accounting officers to dis
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Government response AI summary
The government explains it supports Accounting Officers through various existing guidance, playbooks, training, and specialist teams. It also commits to shortly re-issuing information, including the NAO’s good practice guide, to departments and AOs to further highlight guidance for dealing with distressed companies.
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HM Treasury
1
Conclusion
Twentieth Report - Monitoring and respo…
Accepted
On the basis of a report by the Comptroller and Auditor General, we took evidence from HM Treasury (the Treasury), the Department for Business and Trade, the Cabinet Office, and UK Government Investments (UKGI).1
Government response AI summary
The government accepts the committee's observation and outlines its Lead Government Department (LGD) approach for emergency planning and risk assessment, noting significant improvements in supplier monitoring since 2018 through the Sourcing Playbook. It details how the Cabinet Office monitors strategic suppliers and how responsibility for …
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HM Treasury
7
Conclusion
Twentieth Report - Monitoring and respo…
Accepted
Departments are at different stages and have different approaches to understanding their sectors’ supply chain dependencies and exposure.13 The Treasury told us that individual departments lead on their sectors and it is for each of them to monitor the health of their sectors.14 It explained how information that a particular …
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Departments are at different stages and have different approaches to understanding their sectors’ supply chain dependencies and exposure.13 The Treasury told us that individual departments lead on their sectors and it is for each of them to monitor the health of their sectors.14 It explained how information that a particular sector or company is in distress is shared through “the informal network of interaction between relevant teams” or through the Treasury spending teams if the department was seeking to prepare a financial contribution to support the company. The Treasury explained that it also monitored various indicators of health and resilience of the corporate sector as a whole. Although the Insolvency Service statistics indicate an increase in insolvencies in absolute terms, it told us that the number of businesses had also increased.15 We asked the Treasury about how it measures the number of businesses and ensures that these are trading businesses, as we were concerned that the figures may be misleading if they include new companies being created that do not exist or have no intention of carrying out any activity.16 The Treasury wrote to us after the evidence session and confirmed that “there is a risk these figures include some inactive firms.” However, it said it was reassured by the fact new legislation 8 C&AG’s Report, paras 2.2–2.4 9 Q41 10 Department for Business and Trade, Critical Imports and Supply Chains Strategy, 17 January 2024 11 Q43 12 Q48 13 C&AG’s Report, para 2.17 14 Q41 15 Qq33–34 16 Q40 Monitoring and responding to companies in distress 11 when introduced would improve the accuracy and quality of data on Companies House registers, that it could still make judgements on the overall trend by comparing numbers over time, and that it also used other metrics to analyse the corporate sector.17
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Government response AI summary
The government states the recommendation is already implemented, highlighting its Lead Government Department approach, improved supplier monitoring since 2018, the Sourcing Playbook, Cabinet Office monitoring, and published strategies for critical sector supply chain resilience.
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HM Treasury
8
Recommendation
Twentieth Report - Monitoring and respo…
Accepted
Companies and markets can cut across several departments’ policy responsibilities or provide services to multiple departments. This meant that in the cases of Carillion, CF Fertilisers and UKCloud, no single department had a complete picture of the government’s exposure to the company in advance of it becoming distressed.18 We asked …
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Companies and markets can cut across several departments’ policy responsibilities or provide services to multiple departments. This meant that in the cases of Carillion, CF Fertilisers and UKCloud, no single department had a complete picture of the government’s exposure to the company in advance of it becoming distressed.18 We asked the Treasury about instances where its alert system had not worked. The Treasury told us that CF Fertilisers was an example where they “could have been alerted ahead of time had we understood that supply chain risk more systemically” as they had not known “that the supply of CO2 was dependent on that particular company”. The Department for Business and Trade agreed that it had been “slightly caught off guard”.19 Around two thirds of the UK’s CO2 was sourced from CF Fertilisers in 2018, supplying the food and drink, energy, nuclear, medical and water sectors among others. In 2019, following a CO2 supply shortage the previous year, the Food and Drink Federation recommended a clearer focus in government on the significance of the UK’s CO2 supply chain, but at the time no action was taken.20 The government had to provide temporary financial support to the company in 2021 to avoid a CO2 supply shortage after it halted operations at its site due to high natural gas prices.21
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Government response AI summary
The government states the recommendation concerning the lack of a complete cross-departmental picture of exposure to distressed companies is already implemented. It refers to the existing Lead Government Department approach, improved supplier monitoring since Carillion, and Cabinet Office monitoring of strategic suppliers.
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HM Treasury
9
Recommendation
Twentieth Report - Monitoring and respo…
Accepted
The National Audit Office (NAO) reported that the Cabinet Office’s markets, sourcing and suppliers team were in the early stages of exploring how departments map their supply chains, and whether a similar approach could be taken for public service supply chains.22 The Cabinet Office spoke about the example of UKCloud, …
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The National Audit Office (NAO) reported that the Cabinet Office’s markets, sourcing and suppliers team were in the early stages of exploring how departments map their supply chains, and whether a similar approach could be taken for public service supply chains.22 The Cabinet Office spoke about the example of UKCloud, which provided secure cloud data services to several government departments and went into liquidation in 2022.23 It explained how this was a “very difficult-to-spot problem” because it was “four tiers down” and it would be very costly and difficult to maintain a database that mapped “other subcontractors to people way down our supply chain”.24 Retaining corporate knowledge
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Government response AI summary
The government states the recommendation to improve supply chain mapping is already implemented. It describes existing measures such as the Lead Government Department approach, improved supplier monitoring via the ‘Sourcing Playbook’, and Cabinet Office monitoring of strategic suppliers.
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HM Treasury
10
Recommendation
Twentieth Report - Monitoring and respo…
Accepted
The Treasury told us that some of its staff work on monitoring the health of the UK corporate sector overall, by looking at a series of indicators.25 It told us that actively monitoring the corporate sector is an important and critical part of what the Treasury does centrally. The Department …
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The Treasury told us that some of its staff work on monitoring the health of the UK corporate sector overall, by looking at a series of indicators.25 It told us that actively monitoring the corporate sector is an important and critical part of what the Treasury does centrally. The Department for Business and Trade also explained its “industry brief” and its “role in economic shocks generally, and monitoring and forecasting”. Nonetheless the Treasury told us that it is reliant on departments monitoring their own sectors.26
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Government response AI summary
The government states the recommendation on monitoring the UK corporate sector and relying on departments is already implemented. It highlights existing approaches like Lead Government Departments, improved supplier monitoring, Cabinet Office oversight of strategic suppliers, and published strategies for critical supply chain resilience.
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HM Treasury
11
Recommendation
Twentieth Report - Monitoring and respo…
Accepted
The government’s corporate knowledge about the health of key sectors and companies may be vulnerable because of the high turnover of civil servants in this field, who may have 17 Correspondence from HM Treasury to Committee, 30 January 2024 18 C&AG’s Report, para 1.8 19 Q23 20 C&AG’s Report, para …
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The government’s corporate knowledge about the health of key sectors and companies may be vulnerable because of the high turnover of civil servants in this field, who may have 17 Correspondence from HM Treasury to Committee, 30 January 2024 18 C&AG’s Report, para 1.8 19 Q23 20 C&AG’s Report, para 2.15 21 National Audit Office (NAO) Report, Good practice guide: Monitoring and responding to companies in distress, October 2023, page 10 22 C&AG’s Report, para 2.17 23 Qq13,27; C&AG’s Report, para 6 24 Q12–13 25 Q23 26 Qq 41–43 12 Monitoring and responding to companies in distress built trusted relationships with the private sector and be skilled at handling information “sensitively and carefully”.27 The Cabinet Office told us that the last time it had a company it needed to look at, the Chief Operating Officer for the Civil Service wrote to all departments to nominate a single point of responsibility in their operations team. It told us that “it is important to have someone in departments so we can have a Government-wide call.”28 Despite this, it explained that next time there is a similar case, this will need to be updated because “doubtless people will have moved on.” The Treasury also explained to us how its spending teams are formally alerted when a department is seeking to make any sort of financial contribution to a company.29 We have previously raised concerns about the high staff turnover in the Treasury and a lack of operational experience at more junior levels of the Treasury spending teams.30 Analysis of the latest civil service statistics shows that the Treasury has the highest turnover rate of all departments.31 The Treasury told us that it had launched a corporate finance network as one way of maintaining institutional memory, and that there is a regular permanent secretaries’ group focused on growth where it shares its guidance and principles on company distress situations, to be cascaded to teams across the civil service.32
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Government response AI summary
The government agrees with the recommendation, stating it is implemented through ongoing actions such as making supplier risk a standing item for engagement, fostering two-way intelligence sharing to retain corporate memory, and requiring departments to escalate risk indicators via their governance frameworks and the Orange …
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HM Treasury
12
Conclusion
Twentieth Report - Monitoring and respo…
Accepted
We asked the witnesses what lessons they had learned about companies’ resilience across the economy from supporting them during the pandemic. The Treasury told us that it had learned the “importance of departments having a good sectoral understanding, understanding the nature of their sectors and things like the composition of …
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We asked the witnesses what lessons they had learned about companies’ resilience across the economy from supporting them during the pandemic. The Treasury told us that it had learned the “importance of departments having a good sectoral understanding, understanding the nature of their sectors and things like the composition of their sectors”. The Treasury and Department for Business and Trade told us that, prior to the pandemic, knowledge of some sectors was “mixed” and they “did not know some almost at all”. However, they said that departments now have a much better understanding of their sectors and have been building those relationships.33 Given the current high levels of insolvencies across the economy, we asked the witnesses if there were any particular sectors giving cause for concern. The Treasury told us that there was “no one sector that seems to be more in trouble than any others”.34 We were told by the Cabinet Office that “16% of insolvencies are in construction” but “construction is usually held as the most fragile sector” due to low margins and complex working capital arrangements. The Cabinet Office explained how it has built resilience into this sector by introducing a prompt payment exclusion to prohibit companies from bidding for contracts if they do not pay their suppliers promptly.35 Understanding risks when contracting
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Government response AI summary
The government states the recommendation is already implemented, citing its existing Lead Government Department approach, improved supplier monitoring since 2018, the Sourcing Playbook, Cabinet Office monitoring of strategic suppliers, and published strategies for supply chain resilience.
Read full response →
HM Treasury
13
Recommendation
Twentieth Report - Monitoring and respo…
Accepted
This Committee has continually advocated for the use of Accounting Officer (AO) Assessments to support high quality decision-making and enhance transparency. The Treasury’s guidance suggests that it is good practice for an AO Assessment to be produced for each significant novel and contentious transaction or proposal involving the use of …
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This Committee has continually advocated for the use of Accounting Officer (AO) Assessments to support high quality decision-making and enhance transparency. The Treasury’s guidance suggests that it is good practice for an AO Assessment to be produced for each significant novel and contentious transaction or proposal involving the use of public funds.36 Our 2022 report on Improving the Accounting Officer Assessment process 27 C&AG’s Report, para 3.10; Q48 28 Q27 29 Q22 30 Committee of Public Accounts, Improving government planning and spending, Seventy-Eighth Report of Session 2017–19, HC 1596, 8 February 2019, Conclusions and recommendations para 1 31 Institute for Government, Whitehall Monitor 2024, January 2024, page 19 32 Q16 33 Q69 34 Qq33–34 35 Q37 36 HM Treasury, Accounting Officer Assessments: Guidance, May 2023 Monitoring and responding to companies in distress 13 found that departments do not make as much use of these assessments as they should.37 The quality of these assessments varies across departments, with some not providing sufficient detail to allow for a good understanding of the programme or the accounting officer’s assessment of risks.
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Government response AI summary
The government states the recommendation regarding Accounting Officer Assessments is already implemented. It details existing guidance for AOs on considering commercial risks, value for money, and feasibility, as well as the support provided by finance directors and commercial teams.
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HM Treasury
14
Conclusion
Twentieth Report - Monitoring and respo…
Accepted
For several decades, successive governments have contracted out public services to private providers. Where providers or suppliers fail, the government is often the fall-back owner of risks. This was demonstrated when Carillion failed and the government had to step in to fund a trading liquidation while contracts and services were …
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For several decades, successive governments have contracted out public services to private providers. Where providers or suppliers fail, the government is often the fall-back owner of risks. This was demonstrated when Carillion failed and the government had to step in to fund a trading liquidation while contracts and services were transferred.38 We asked the Cabinet Office how likely it was that we would see another Carillion. It told us “never say never” but that it had introduced ‘playbooks’ to help define how to go to market in these areas. For complex outsourcing where government is the only customer, the Cabinet Office told us that it is “particularly important that we really understand the economics for the supplier and whether the gain share and pain share mechanisms are appropriate” and that it had “spent a lot more time thinking about that recently”. The Cabinet Office also explained how it requests a living will statement for critical contracts or complex outsourcing contracts. Each year, the vendor will have to confirm to the contracting authority whether it still passes the financial entry tests that are expected to be met at the beginning of a contract.39
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Government response AI summary
The government states the recommendation is already implemented, detailing its Lead Government Department approach for emergencies, significantly improved supplier monitoring since Carillion, the Sourcing Playbook, and the Cabinet Office's monitoring of strategic suppliers and critical sector resilience strategies.
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HM Treasury
16
Conclusion
Twentieth Report - Monitoring and respo…
Accepted
In 2020, the government set out publicly some broad principles which it uses to underpin decisions on providing last-resort bespoke financial support to financially distressed companies. The government has publicly stated that there is an “extremely high bar for putting taxpayers’ money at risk in this way”.42 The Treasury told …
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In 2020, the government set out publicly some broad principles which it uses to underpin decisions on providing last-resort bespoke financial support to financially distressed companies. The government has publicly stated that there is an “extremely high bar for putting taxpayers’ money at risk in this way”.42 The Treasury told us that before developing the principles, it had had “a rather ad hoc framework for addressing companies in distress-type situations.”43
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Government response AI summary
The government agrees with the recommendation and aims for a July 2024 implementation. It outlines existing guidance, expert teams (HM Treasury's Special Situations team, UKGI), and departmental responsibilities for managing interventions, committing to shortly re-issue relevant information and the NAO's good practice guide to departments.
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HM Treasury
17
Recommendation
Twentieth Report - Monitoring and respo…
Accepted
As with any activity involving public money, a department must adhere to the principles of regularity, feasibility, propriety and value for money set out in the Treasury’s Managing Public Money. A department will likely be required to carry out a formal Accounting Officer Assessment when considering an intervention in a …
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As with any activity involving public money, a department must adhere to the principles of regularity, feasibility, propriety and value for money set out in the Treasury’s Managing Public Money. A department will likely be required to carry out a formal Accounting Officer Assessment when considering an intervention in a private company.44 The Treasury told us that if a department is seeking to provide financial support to a company and “it is highly likely to be novel, contentious or repercussive”, it is likely that it will require Treasury’s approval.45
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Government response AI summary
The government states the recommendation to adhere to principles of regularity, feasibility, propriety, and value for money for interventions is already implemented. It outlines existing guidance in Accounting Officer Assessments, Managing Public Money, and the Sourcing Playbook, along with support from finance directors and commercial …
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HM Treasury
18
Conclusion
Twentieth Report - Monitoring and respo…
Accepted
Propriety is concerned with meeting high standards of public conduct and parliamentary expectations, and cannot be dispensed with even when making difficult judgements on competing issues in an emergency.46 Responding in these situations often requires rapid decision-making by officials and ministers, based on imperfect information and a set of unattractive …
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Propriety is concerned with meeting high standards of public conduct and parliamentary expectations, and cannot be dispensed with even when making difficult judgements on competing issues in an emergency.46 Responding in these situations often requires rapid decision-making by officials and ministers, based on imperfect information and a set of unattractive options.47 We heard how quickly departments have to weigh up different options and make decisions in a crisis situation. For example, when the government was notified of the imminent failure of Flybe in 2020, UKGI told us that advisors spent four days in the company and assessed that intervention “would not be a good use of government money because, if we put a penny in at the top, we might not be able to work out where that penny would go and it might not be focused on what we needed it to”.48 More recently, when the issues surrounding Silicon Valley Bank arose, a number of teams were stood up over the course of a weekend to come up with a rapid set of different contingency plans.49
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Government response AI summary
The government agrees with the recommendation, with a target implementation date of July 2024. It outlines existing guidance and expert support available to departments for rapid, proper decision-making in crisis situations, and commits to shortly re-issuing information and the NAO's good practice guide.
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HM Treasury
19
Conclusion
Twentieth Report - Monitoring and respo…
Accepted
We asked the witnesses how they manage the risks of moral hazard (where support for one company creates an incentive for other companies to take risks with the expectation they will also be supported) and free riders (where the company’s incumbent lenders or shareholders may benefit from government support without …
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We asked the witnesses how they manage the risks of moral hazard (where support for one company creates an incentive for other companies to take risks with the expectation they will also be supported) and free riders (where the company’s incumbent lenders or shareholders may benefit from government support without having to contribute themselves) when deciding if and how to intervene in a company.50 The Treasury explained how it sets “the bar very high” and conducts very detailed due diligence on the companies, 42 C&AG’s Report, para 1.4, Figure 4 43 Q15 44 C&AG’s Report, paras 3.3, 3.5 45 Q22 46 C&AG’s Report, Lessons learned: tackling fraud and protecting propriety in government spending during an emergency, Session 2023–24, HC 444, 8 February 2024, Lesson 2, para 19 47 C&AG’s Report, para 3.6 48 Qq18–19 49 Q28 50 Qq61–64 ; C&AG’s Report, para 3.2 Monitoring and responding to companies in distress 15 such that the cases where it does intervene “are very few and far between”. UKGI told us how it is very mindful of the free rider problem and, if other financial stakeholders did not play their part, government would take assets as security to protect the taxpayer’s position.51 For example, when providing a £30 million loan to Celsa Steel, the government set the conditions of the support so that public money would be protected if the company became insolvent and it would get a greater return if the company did well. UKGI agreed that this would be a model it would intend to follow in the future.52
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Government response AI summary
The government agrees with the recommendation and aims to implement it by July 2024. It details existing guidance, support teams, and practices for managing interventions and protecting taxpayer interests, and commits to shortly re-issuing relevant information and the NAO's good practice guide to departments.
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HM Treasury
21
Recommendation
Twentieth Report - Monitoring and respo…
Accepted
Departments must have, or be able to access, the skills, expertise and capacity needed through the whole lifecycle of any intervention in a company, including to prepare for and respond to company distress scenarios.56 We have repeatedly highlighted longstanding issues with a lack of specialist skills in the civil service …
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Departments must have, or be able to access, the skills, expertise and capacity needed through the whole lifecycle of any intervention in a company, including to prepare for and respond to company distress scenarios.56 We have repeatedly highlighted longstanding issues with a lack of specialist skills in the civil service and the challenges with attracting and retaining specialist staff.57 We recently found in our 2023 Bulb Energy report that the need for commercial and corporate finance skills across government has increased but these are in limited supply.58 We highlighted the importance of all departments being able to access these skills to make appropriate judgements concerning activities that link the public and private sectors. Our report on Competition in public procurement raised concerns that the government may not fully understand the commercial skills and 51 Q59 52 Qq64–65 53 C&AG’s Report, paras 3.1, 3.7–3.8 54 Qq67–68; NAO Report, page 20 55 Dr John Tribe (Senior Lecturer in Law, University of Liverpool) (LGD0001) 56 NAO Report, page 7; C&AG’s Report, Figure 1 57 Committee of Public Accounts, Specialist skills in the civil service, Thirty-Second Report of Session 2019–21, HC 686, 7 December 2020, Summary 58 Committee of Public Accounts, Bulb Energy, Seventy-Fourth Report of Session 2022–23, HC 1232, 1 November 2023, Conclusions and recommendations, para 5 16 Monitoring and responding to companies in distress capabilities needed across government to implement far-reaching changes to the public procurement landscape.59 We have also highlighted the variability in departments’ risk management capabilities.60
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Government response AI summary
The government agrees to the recommendation and aims to implement it by April 2025. The Cabinet Office Commercial Function will collaborate with other bodies to develop a more targeted approach for building skills in monitoring and responding to companies in distress.
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HM Treasury