Openreach Board Audit Risk & Compliance Committee (OBARCC) bulletin - May 2021

Posted on 17/05/2021

The below update has been sent from Openreach:

The OBARCC is the Openreach Board committee responsible for monitoring Openreach’s regulatory compliance.  This is our ninth bulletin, reporting on our meeting in April 2021.

The Commitments Monitoring Office (CMO) supports the OBARCC.  Communications Providers (CPs) who have queries or concerns about the Commitments are welcome to raise them with the CMO – either informally or as formal complaints.  Details of how to contact the CMO, including guidelines for raising formal complaints, are available on the OBARCC page on the CP portal. 

Headlines

The key headlines since our last bulletin are as follows:

The CMO updated us on its ongoing monitoring of key compliance risks;

We are continuing to closely monitor Fibre-to-the-Premises (FTTP) pricing discussions and CP input into the FTTP footprint selection process;

BT’s Commitments Assurance Office (CAO) updated us on a number of Commitments-related activities; and

Openreach reported one trivial breach and one trivial non-conformance to policy to the April OBARCC meeting.

Report on the April 2021 OBARCC meeting

Commitments compliance

At our April 2021 meeting we noted the following:

The CMO provided updates on its monitoring of key Commitments risks, considering two of these to be both significant and ongoing: 1) the risk of inappropriate BT interventions in Openreach commercial decision-making and 2) the risk of erosion of corporate memory around the Commitments as key senior people left BT.

Openreach’s proposals for future FTTP pricing were in the process of being considered under formal internal governance procedures.

We welcomed the BT Compliance Committee’s (BTCC’s) review of the extent to which the Commitments remain embedded in BT and noted that a report on this is due to be discussed at the BTCC’s July 2021 meeting. The Director of the CAO had met with two new recent appointments to the BT Executive Committee (ExCo) and plans to meet the new BT Chair, when appointed. The new BT ExCo members are in the process of meeting the members of the Openreach Board.

The OBARCC is currently monitoring three areas on the dashboard: product performance KPIs, risk of erosion of compliant culture and behaviours, and systems separation, which relates mainly to user access controls for the new BT finance and accounting system.  The CMO will keep these areas under review.

Breaches and complaints

At our April meeting one trivial breach and one trivial non-conformance to policy were reported. 

The trivial breach arose because an Openreach employee had inadvertently sent an email containing Openreach information to two individuals in the BT Group strategy team who did not have the appropriate regulatory compliance marker.  The OBARCC decided this was a trivial breach as it occurred over the course of a single day, the data shared did not offer the incorrect recipients any advantage and the incorrect recipients confirmed they deleted the file without opening it.

The trivial non-conformance arose when Openreach information was shared with a BT employee who had previously worked in Openreach.  The BT employee was eligible to see the information but was not listed on the project disclosure record.

No new formal or informal complaints were received by the CMO during the fourth quarter.

BTCC bulletin

Our colleagues in BT have asked us to mention that they too publish a bulletin following each BTCC meeting.

Next OBARCC meeting

Our next quarterly meeting is scheduled for July 2021.

If you have any comments on the bulletin or our annual report, or would like to be added to our contact list for future publications, please contact us using the following email address: [email protected].

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