Procurement Policy

Policy Owner - Executive Director Finance and Strategy
Accountable Lead - Director of Asset, Procurement and Contract Management

Policy level - Regulatory / Strategic
Policy Reference - FR/001/2013
Link to Strategy - Procurement Strategy
Version Control
V1 – Jan 14 to Mar 16 (replaced 2007 policies)
V2 – Mar 15 to Mar 18
V3 – Nov 18 to Mar 22
V4 – Mar 22 – Mar 23
Approved by - Exec Director Property Services
Consultation - Procurement Board Mar 22
Equality analysis - March 2022
Next review date - March 2023

1. Policy Statement
Curo’s framework for the procurement of goods, works and services and for the subsequent management of its contracts reflects the Group’s mission, vision and values and supports Curo’s strategic objectives.
The policy provides for procurement to be undertaken by colleagues throughout the Group in an efficient, common manner with probity, transparency and equality, and ensuring that the standing orders and financial regulations are complied with.
The policy provides for effective contract management to be undertaken for all Curo contracts throughout their life, ensuring service performance is delivered, value for money is achieved and identified benefits are realised.

2. Scope, Roles and Responsibilities
This policy applies to all Curo colleagues and residents who are involved with the procurement of goods, works or services and the management of Curo contracts.
The Director of Asset, Procurement and Contract Management is accountable for the delivery of the policy.
The Procurement Board is responsible for reviewing the progress of procurement activities against the procurement plan, reviewing and approving Procurement Stage reports for all High Risk tenders and FTS (including mini-competition exercises) and monitoring the outcomes in terms of the procurement performance targets. The Board is chaired by the Executive Director Finance and Strategy. In exceptional circumstances, the Procurement Board may review Procurement Stage Reports electronically.
Each work package will be sponsored either by an Executive, a member of the SMT (Senior Management Team) or a member of the LG (Leadership Group). The Sponsor will have primary responsibility for adhering to the policy but may delegate to an officer the responsibility for leading the procurement and managing the contract.
The Contract Manager is the officer responsible for day to day contract management and for the end-to-end procurement activity. They own the budget for the expenditure and manage the relationships and performance with the suppliers. The Procurement and Supply Chain Manager is responsible for engaging and communicating with all stakeholders impacted by the procurement activity.
The Contract Manager (who may also be the Procurement Lead) ensures that both parties to a contract meet their obligations to ensure the services or works are delivered and overall performance throughout the life of a contract is maintained at expected levels. The Contract Manager is responsible for ensuring compliance with the terms and conditions of contract, as well as documenting and agreeing any changes or amendments that may arise during its implementation or execution.
The Procurement Team will provide a procurement framework, advice and assistance, training and support to enable the Sponsor and Lead to undertake effective procurement activities.

3. Procurement and Contract Management principles
The primary aim is to award contracts that reflect our customers’ aspirations, whilst achieving a target reduction in cost without compromising quality, encouraging competition and delivering value for money. In addition our aims are:
• To ensure that the procurement process is clear, proportional and focussed on achieving the overall strategy and outcomes for the contract and stakeholders
• To encourage stakeholder involvement throughout the procurement process through communication and consultation
• To ensure that goods, works and services are delivered to the required standard and in a cost effective manner
• To deliver social and environmental benefit such as the use of apprenticeships in our supply chain
• To enable the impact of investing in existing and new stock and the contribution to local neighbourhoods to be maximised
• To ensure that procurement activities are completed and contracts placed in accordance with current legislation and best practice, including Modern Slavery and UK-GDPR.
• To implement new contracts successfully, in line with agreed terms and conditions and effectively meet deliverables
• To ensure that throughout the procurement and contract management process, risks and opportunities are identified and managed appropriately
• Using performance indicators that are relevant to the service object and are proportionate to the size and complexity of the contract to measure and improve the performance of contracts.
• Driving collaboration with other contracting authorities operating in the housing sector to improve procurement processes, make use of economies of scale and realise wider community benefits.

4. Procurement and Contract Management application
Procurement
Green paper – 6 new headings WTO Procurement Principle
Public Good
Value for Money
Transparency
Integrity
Fair Treatment of Suppliers
Non discrimination

Leverage procurement activities to deliver both national and local priorities, including tackling climate change, reducing waste in the delivery of contracts and improving supplier diversity.
We will deliver these principles through the structures and responsibilities set out in 2 above. In undertaking any procurement activity, those teams will:

• Clearly define individual roles and responsibilities
• Deliver procurement in accordance with Group Financial Regulations
• Ensure appropriate cross functional membership of the group so that individuals representing customers and all departments who will be utilising the works, goods or services under review, are included
• Clearly define budget and objectives, supported by the business before the market is approached
• Provide a timetable and resource plan for the procurement that will ensure adequate consultation throughout
• Assess risks associated with the procurement and mitigate accordingly
• Ensure early and effective market engagement in the process so that the specification and service level requirements are appropriate and clearly communicated
• Undertake an Equality and Diversity impact assessment where necessary
• Prepare an exit strategy and communicate this to the relevant contractor
• Be mindful of Curo’s Loyalty and Conflicts of Interest policy.

Contract Management
For each contract the Procurement Lead will use the Intend Contract management system to store and maintain a contracts records in line with Curo’s Contract Management Handbook.
Contracts will be effectively managed to ensure:
• Ongoing value for money and delivery within budget
• Service solutions to meet ongoing demand of Curo and its customers
• Realisation of benefits, including social value
• Sustainable service delivery
• Performance compliance and monitoring
• Continuous improvement and innovation
• Management of risk
• Compliance with statutory obligations

Throughout Procurement and Contract Management activity Curo colleagues will consider the following:

Customer focus
Specifications of works, goods and services will define outcomes required for customers. Procurement Leads will consider consultation requirements and, where appropriate customers will be consulted throughout the procurement process and at relevant points throughout the life of the contract.
Social and environmental considerations
Consideration will be given to including social or environmental conditions in contracts, including:
• Provision for work placements, apprenticeships, employment and skills opportunities for local people including our own residents
• Contributions to Curo Community schemes
• Environmental issues forming part of the decision making process
• Measurement of these benefits by key performance indicators and through day to day contract management.

Aggregation and packaging of contracts
Curo will comply with Procurement rules and the UK Public Contract Regulations regarding the aggregation of contracts.

Term of contracts, partnering and frameworks
To deliver efficiencies and improved buying power for both Curo and our suppliers, we will:
• look to establish longer term contracts and partnering arrangements
• make use of consortia or purchasing club frameworks and contracts
• Utilise the Dynamic Purchasing (DPS plus) systems
• ensure the terms of contract are managed by Curo and delivered by the contractor

Advertising requirements
Curo will follow the FTS Procurement advertising directives. Contract opportunities below FTS thresholds will be advertised in accordance with UK Public Contract Regulations to ensure open and fair competition and transparency.

E-Procurement
The Intend Organiser is Curo’s tendering and contract management tool. Intend must be used to register quotations and manage tenders for all procurements over £10k in line with Curo’s Tendering Thresholds. Intend’s Quick Quote function is to be used for requirements between £1k and £10k. Intend must also be used by colleagues for contract administration.
Intend manages all aspects of the tender and contract management process. It also enables Curo to maintain an accurate and up to date Contract Register to ensure risk and spend can be monitored.

Evaluation and award criteria
Contracts will be awarded on the basis of economic advantage, taking into account the optimum combination of cost and quality. When considering our specifications and evaluating proposals, the environmental, economical and social impact as well as the total cost over the whole life of the works, goods and services will be assessed.

Post tender requirements
All competitive tendering decisions are documented in value for money or Procurement Stage reports which:
• confirm relevant authorisations have been obtained at each stage of the process,
• detail all procurement savings and benefits that have been agreed, and
• is approved prior to contract award in accordance with the standing orders.
Feedback to bidders concerning their performance will be offered.

Storage and Retention of Contracts
Contract Managers securely store each of their hard copy, signed contract documents.
Signed Contract Documentation is recorded on the Electronic Contract Register on InTend by the Procurement Team, including all required supplier certificates and declarations.
Original hard copy contract documentation is retained for a period of 6 years following the termination/expiry for contracts (12 years for contracts signed under seal or executed as deed).

Standing Orders
The standing orders detail the procurement processes, which vary in respect of the level of consultation, competition, and authorisation required.
The Procurement Lead must comply with the standing orders, financial regulations, and all relevant UK and European Union legislative requirements. The Executive may waive the requirement of a standing order in exceptional circumstances on approval of a Deviation Report, which provides:
• Rationale and proposed terms and conditions agreed with the contractor
• Demonstration of Value for Money through negotiation and agreed costs

Contract Management Handbook
It is the responsibility of all Curo colleagues involved in managing, overseeing or monitoring contracts to use the Contract Handbook which sets out the detail of actions and responsibilities for colleagues in relation to procurement and contract management.

5. Measurement of procurement and contract management success
Procurement performance will be monitored in respect of:
• Compliance with all relevant laws and policies and procedures
• Appropriate involvement of relevant stakeholders.
• Achievement of target procurement savings and non-cashable benefits
• Timely planning, start and completion of procurement activities
The Procurement and Supply Chain Manager will be responsible for the co-ordination and maintenance of the procurement plan. Procurement work packages and targets will be agreed as part of the budget planning process and encapsulated within team plans and individual personal development reviews.
Contract Management performance will be monitored in respect of:
• Realisation of contract benefits, including savings and social value deliverables
• Contract performance and KPI management
• Delivery of on-going value for money and customer satisfaction (CSS)
• Management of risk and statutory obligations
• Customer Satisfaction
• Budget Management

The implementation of the procurement and contract management policy and procedures will be supported, monitored and reported by the procurement function through the e-procurement system.
Contract management across Curo will be reported on monthly. Key metrics have been defined and colleague compliance with these will be monitored and reported to the Procurement Board.

6. Value for money implications
This policy ensures that Curo achieves best value by utilising cost effective and best practice procurement and contract management processes. It ensures that we procure contracts that reflect our customers’ requirements.
The policy supports the empowerment of colleagues to manage their procurement activities and contracts by the most efficient means within a policy framework that provides guidance, support and direction.

7. Equality and Diversity implications
By applying this policy and ethical procurement and contract management practices we will;
• ensure that our contracts are compliant with our legal obligations to protected groups under the Equality Act 2010
• manage competitions fairly and be objective and transparent when making decisions
• seek evidence about contractors’ employment practices and their demonstrable ethical way of working embedded within their business
• strive towards equality and diversity outcomes through our purchasing power and procurement function.

8. Modern Slavery
Curo’s Procurement and Contract Management policy supports and complies with the UK Modern Slavery Act 2015.
All colleagues must be familiar with Curo’s Modern Slavery policy.
Contract Managers are responsible for understanding their contractor’s compliance with the Modern Slavery Act, requesting statements and evidence of contractor compliance as a minimum.
Contract Managers are responsible for being vigilant to the signs or indicators that could mean operatives working on Curo contracts are victims of Modern Slavery. Contract Managers are responsible for reporting any instances to Curo’s Procurement or Governance Teams.