Corporate governance
Global workforce diversity policy
Introduction
The introduction and following sections are located in the Corporate Governance Statement in the 2010 Annual Report dated February 2011.
This statement aims to disclose in summary form as clearly and objectively as possible QBE’s corporate governance standards and practices so that they can be readily understood by our shareholders, policyholders and other stakeholders. QBE also continues to focus on other equally important issues such as the strength of its outstanding claims provision, the quality of its reinsurers and the depth of its culture of honesty, integrity and business acumen.
The statement incorporates the disclosures required by the revised recommendations of the ASX Corporate Governance Council (ASX CGC) issued in June 2010.
Board of directors
Directors are selected to achieve a broad range of skills, experience and expertise complementary to the Group’s activities. Details of individual directors are included on pages 50 and 51 and can also be found on the QBE website at www.qbe.com. The board currently comprises eight directors including an independent chairman, the chief executive officer and six independent non-executive directors applying the “independence” definition of the ASX CGC. Applying this definition, the board has determined that a non-executive director’s relationship with QBE as a professional adviser, consultant, supplier, customer or otherwise is not material unless amounts paid under that relationship exceed 0.1% of revenue.
The roles of chairman and chief executive officer are not exercised by the same individual.
The relationships identified by the ASX CGC as affecting a director’s independent status no longer refer to the period for which a director has served on a board. Nevertheless, as a general guide, the board has agreed that a non-executive director’s term should be approximately 10 years. The board considers that a mandatory limit on tenure would deprive the Group of valuable and relevant corporate experience in the complex world of international general insurance and reinsurance. Ms BJ Hutchinson AM has been a non‑executive director since September 1997 and chairman since July 2010. She was re-elected as a director at the 2009 AGM. QBE’s other directors believe that Ms Hutchinson AM continues to exercise independent judgment and, through her QBE experience, makes an important contribution. They also believe that the chairman’s experience gained from directorships in other businesses provides an advantage to QBE.
In 2010, Mr Bleasel AM was appointed lead independent director, which role includes leading the board’s evaluation of the chairman.
The chairman oversees the performance of the board, its committees and each director. The board review procedure involves an annual assessment of the entire board and each director, comprising a combination of written questions and answers together with an interview with each director. The chairman reports the overall result to the board and it is discussed by all directors. This review procedure is a precursor to other directors determining whether to support, via the notice of meeting, a non-executive director for re-election at an AGM. The last board review was completed in accordance with the process above in December 2010 ahead of nominating Mr CLA Irby for re‑election at the 2011 AGM. The last board review included the audit and risk, investment and remuneration committees as the main committees of the board. The review concluded that each committee was operating soundly and meeting the terms of its charter.
QBE’s constitution provides that no director, except the chief executive officer, shall hold office for a continuous period in excess of three years or past the third AGM following a director’s appointment, whichever is the longer, without submission for re-election at the next AGM. Under QBE’s constitution, there is no maximum fixed term or retirement age for non-executive directors.
Directors advise the board on an ongoing basis of any interest they have that they believe could conflict with QBE’s interests. If a potential conflict does arise, either the director concerned may choose not to, or the board may decide that he or she should not, receive documents or take part in board discussions whilst the matter is being considered.
In accordance with its charter, the board:
• oversees corporate governance;
• selects and supervises the chief executive officer;
• provides direction to management;
• approves the strategies and major policies of the Group;
• monitors the achievement of strategies and policies;
• monitors performance against plan;
• considers regulatory compliance;
• monitors people-related strategies (including people development and succession planning); and
• reviews information technology and other resources.
The board ensures it has the information it requires to be effective including, where necessary, independent professional advice. A non‑executive director may seek such advice at the company’s cost with the consent of the chairman. All directors would receive a copy of such advice. Non-executive directors may attend relevant external training courses at QBE’s cost with the consent of the chairman.
Strategic issues and management’s detailed budgets and three year business plans are reviewed at least annually by the board. The board receives updated forecasts during the year. Visits by non-executive directors to the Group’s offices in key locations are encouraged. To help the board to maintain its understanding of the business and to effectively assess management, directors have regular presentations by the divisional chief executive officers and other senior managers of the various divisions on topics including budgets, three year business plans and operating performance. They have contact with senior employees at numerous times and in various forums during the year. The board meets regularly in Australia and, due to QBE’s substantial overseas operations, usually spends five days in the UK and the US each year. Meetings are held in other overseas offices as and when the board considers it appropriate. Each meeting normally considers reports from the chief executive officer and chief financial officer together with other relevant reports. The board regularly meets in the absence of management. The chairman and chief executive officer in particular, and board members in general, have substantial contact outside board and committee meetings.
The board delegates responsibility to the chief executive officer for management of the business on a day‑to‑day basis.
Board Selection Process
The board considers that a diverse range of skills, backgrounds, knowledge and experience is required in order to effectively govern the Group. The board believes that its composition, including selection, appointment, renewal and retirement of members, to be of such importance that it is the role of the board as a whole to review. As a result, all directors are members of the nomination committee.
The board believes that orderly succession and renewal contributes to strong corporate governance and is achieved by careful planning and continual review. Directors review the size and composition of the board regularly and at least once a year as part of the board evaluation process. The board has a skills matrix covering the competencies and experience of each member. When the need for a new director is identified, the required experience and competencies of the new director are defined in the context of this matrix and any gaps that may exist. Generally a list of potential candidates is identified based on these skills required and other issues such as geographic location and diversity criteria. External consultants may be employed where necessary to search for prospective board members. Candidates are assessed against the required skills and on their qualifications, backgrounds and personal qualities. In addition, candidates are sought who have a proven track record in creating shareholder value, utmost integrity, a commitment to corporate governance, the required time to commit to the position, a strategic mindset, a preparedness to constructively question and challenge and an independence of mind. The board has adopted non-executive director nomination guidelines.
Committees
The board is supported by several committees which meet regularly to consider the audit and risk management processes, investments, remuneration and other matters. The main committees of the board are the audit and risk committee, the investment committee and the remuneration committee. The first of these committees became the audit and risk committee during the year to better reflect its role. These committees operate under a written charter approved by the board. Any non-executive director may attend a committee meeting. The committees have direct and unlimited access to QBE’s senior managers during their meetings and may consult external advisers when necessary at QBE’s cost, including requiring their attendance at committee meetings. Committee membership is reviewed regularly. The chairman of each of the audit and risk and investment committees changed in September 2010 based on experience and following the appointment of Ms BJ Hutchinson AM as Group chairman in July 2010.
In addition, the board has established a funding committee comprising the chairman, Mr JM Green, Ms IYL Lee and the chief executive officer. This committee meets as required.
A report on each committee’s last meeting is provided to the next board meeting. The company secretary acts as secretary to all committees. Details of directors’ attendance at board and committee meetings are outlined in the table of meeting attendance set out in the directors’ report on page 62.
Audit and risk committee
The membership of the audit and risk committee may only comprise non-executive directors. This committee normally meets four times a year. The chairman must be a non-executive director who is not the chairman of the board. The current members are Mr DM Boyle (chairman), Mr LF Bleasel AM, Ms IF Hudson, Ms BJ Hutchinson AM and Ms IYL Lee.
The role of the audit and risk committee is to oversee the integrity of QBE’s financial reporting process. This includes review of:
• the quality of financial reporting to the Australian Securities and Investments Commission (ASIC), ASX and shareholders;
• the Group’s accounting policies, practices and disclosures; and
• the scope and outcome of external and internal audits.
This committee’s responsibilities include reviewing the financial statements (including items such as the outstanding claims provision, reinsurance recoveries and income tax), risk management, internal controls, compliance other than regulatory compliance and significant changes in accounting policies.
The chairman of the board and other non-executive directors normally attend audit and risk committee meetings which consider the 30 June and 31 December financial reports. Meetings of this committee usually include, by invitation, the chief executive officer, the chief financial officer, the chief actuarial officer, the chief risk officer, the Group head of internal audit and the external auditor. As appropriate, other relevant senior managers also attend.
The audit and risk committee has direct and unlimited access to the external auditor. The external auditor, the Group head of internal audit, the chief risk officer and the chief actuarial officer have direct and unlimited access to this committee.
The chief executive officer and chief financial officer provide the board with certificates in relation to risk management and internal control as recommended by the ASX CGC and on the financial reports as required by the Corporations Act 2001.
External auditor independence
QBE firmly believes that the external auditor must be, and must be seen to be, independent. The external auditor confirms its independence in relation to the 30 June and 31 December financial reports and the audit and risk committee confirms this by separate enquiry. The audit and risk committee has contact with the external auditor in the absence of management in relation to the 30 June and 31 December financial reports and otherwise as required. The external auditor normally confers with the audit and risk committee in the absence of management as part of each meeting.
QBE has issued an internal guideline on external auditor independence. Under this guideline, the external auditor is not allowed to provide the excluded services of preparing accounting records, financial reports or asset or liability valuations. Furthermore, it cannot act in a management capacity, as a custodian of assets or as share registrar.
The board believes some non-audit services are appropriate given the external auditor’s knowledge of the Group. QBE may engage the external auditor for non-audit services other than excluded services subject to the general principle that fees for non-audit services should not exceed 30% of all fees paid to the external auditor in any one financial year. External tax services are generally provided by an accounting firm other than the external auditor.
The external auditor has been QBE’s auditor for many years. As a diverse international group, QBE requires the services of one of a limited number of international accounting firms to act as auditor. It is the practice of QBE to review from time to time the role of the external auditor. The Corporations Act 2001, Australian professional auditing standards and the external auditor’s own policy deal with rotation and require rotation of the lead engagement partner after five years. In accordance with such policy, the lead engagement partner of the external auditor rotated in 2009.
Investment committee
The membership of the investment committee comprises four non-executive directors and one executive director. The investment committee normally meets five times a year. The chairman must be a non-executive director who is not the chairman of the board. The current members are Ms IYL Lee (chairman), Mr JM Green, Mr CLA Irby, Ms BJ Hutchinson AM and Mr FM O’Halloran. Meetings of the investment committee usually include, by invitation, the chief investment officer and the chief financial officer. As appropriate, other relevant senior managers also attend.
The role of the investment committee is to oversee QBE’s investment activities. This includes review of:
• investment objectives and strategy;
• investment risk management;
• currency, equity and fixed interest exposure limits;
• credit exposure limits with financial counterparties; and
• Group treasury.
The investment committee’s responsibilities include review of economic and investment conditions as they relate to QBE and overseeing investment performance, including the performance of any defined benefit superannuation funds sponsored by QBE.
Remuneration committee
The membership of the remuneration committee may only comprise non-executive directors. The remuneration committee normally meets four times a year. The chairman must be a non-executive director who is not the chairman of the board. The current members are Mr LF Bleasel AM (chairman), Mr DM Boyle, Mr JM Green, Ms IF Hudson and Ms BJ Hutchinson AM. Meetings of the remuneration committee usually include, by invitation, the chief executive officer and the Group general manager, human resources.
QBE’s governance of remuneration focuses on ensuring that the remuneration and reward strategy and frameworks are aligned with robust risk management practices and strong governance principles and that shareholders receive value for remuneration expenditure.
The role of the remuneration committee is to oversee QBE’s general remuneration practices. The remuneration committee, in particular, assesses the appropriateness of remuneration frameworks and practices in order to fairly and responsibly reward the chief executive officer and other members of the Group executive. The remuneration committee ensures rewards are commensurate with performance and that remuneration levels are competitive in the various markets in which QBE operates. The remuneration committee has access to detailed external research from independent consultants.
The remuneration committee’s responsibilities include:
• recommendation of the total remuneration (fixed and at‑risk) of the chief executive officer to the board and approval of the total remuneration of other members of the Group executive;
• review and approval of short-term and deferred incentives such as equity‑based plans;
• review of superannuation;
• review of performance measurement criteria, succession plans and other major human resource practices;
• monitoring of personal development plans (PDP) for the Group executive and other senior positions;
• recommendations on non-executive director remuneration to the board;
• review of reward structures (including incentive schemes) for employees of APRA regulated entities (such as risk and financial control employees) in accordance with the requirements of APRA prudential standards relating to the governance of remuneration; and
• review of workplace diversity.
The remuneration committee recognises that the key to achieving sustained performance is to motivate and retain quality employees and align executive reward with changing shareholder wealth. The remuneration committee has the discretion to reduce deferred equity awards to the Group executive where financial results subsequently deteriorate.
The remuneration committee receives information on the performance of the Group executive, being the senior executives as defined by the ASX CGC (namely those employees who have the opportunity to materially influence the integrity, strategy, operation and financial performance of the QBE Group).
A PDP involves a meeting between the relevant member of the Group executive, the chief executive officer and the Group general manager, human resources to:
• review past performance;
• discuss career opportunities; and
• consider areas of further development.
PDPs occur periodically in accordance with the process above, and several took place in 2010. In addition, the board continually monitors the performance of the Group executive through regular contact and reporting.
QBE has operations and staff in 49 countries with differing laws and customs. QBE’s remuneration policy therefore reflects the fact that QBE is a global organisation, whilst also taking into account local remuneration levels and practices.
Details of remuneration
Details of remuneration of executives and non-executive directors, such as employee entitlements under the Employee Share and Option Plan, deferred equity awards and superannuation are included in the remuneration report on pages 64 to 88 and in notes 30 and 31 to the financial statements.
Global workforce diversity policy
On 3 December 2010, the remuneration committee approved a global workforce diversity policy in early adoption of the amendments to the ASX CGC recommendations. The policy provides a platform for an integrated diversity management policy across the Group, leveraging initiatives already in place within QBE’s divisional operations and improving governance and monitoring of diversity at all levels. A workforce diversity committee will annually set and monitor specific objectives in line with the policy.
The Group has considerable diversity in its workforce. Diversity in the context of QBE encompasses differences in ethnic background, gender, age, sexual orientation, religion and disability. The Group has been assessed as compliant with the Equal Opportunities for Women in the Workplace Act 2010 (for Australian-based employees) and has received positive endorsement regarding the accessibility of employee programs to women and the introduction of new initiatives that support parents returning to work after parental leave. Gender diversity throughout the organisation is in line with Australian industry benchmarks. Women comprise 55.6%(1) of employees throughout the Group. Across all divisional operations, 19.4%(2) of senior leadership roles(3) are occupied by female employees. Representation of women at the board level is considered strong with three members of the QBE Group board being female.
Subject to local legal requirements and other commitments within each market within which QBE operates, QBE’s aspirational goal for women in senior positions is 25% for Group head office and 20% for its divisions by 31 December 2012. The policy is available in the corporate governance area of QBE’s website or on request from the company secretary.
Risk management
QBE’s core business is the underwriting of risk. The Group’s successful performance over many years clearly establishes its substantial risk management credentials.
It is QBE’s policy to adopt a rigorous approach to managing risk throughout the Group. Risk management is a continuous process and an integral part of quality business management. QBE’s approach is to integrate risk management into the broader management processes of the organisation. It is QBE’s philosophy to ensure that risk management remains embedded in the business and that the risk makers or risk takers are themselves the risk managers.
Diversification is used as a tool to reduce the Group’s overall insurance risk profile by spreading exposures, thereby reducing the volatility of results. QBE’s approach is to diversify insurance risk, both by product and geographically. Product diversification is achieved through a strategy of developing strong underwriting skills in a wide variety of classes of business. A combination of core and speciality products under the control of proven employees skilled in such products allows QBE to lead underwrite in many of the markets in which we operate. Geographic diversification is achieved by operating in 49 countries.
QBE has a global risk management framework that defines the risks that QBE is in business to accept and those that we are not, together with the material business risks that QBE needs to manage and the framework and standards of control that are needed to manage those risks.
The foundation of our risk management is the obligation and desire to manage our future and create wealth for our shareholders by maximising profitable opportunities through:
• achieving competitive advantage through better understanding of the risk environment in which we operate;
• optimising risk and more effectively allocating capital and resources by assessing the balance of risk and reward;
• adequate pricing of risk;
• avoiding unwelcome surprises by reducing uncertainty and volatility, such as by controlling aggregate exposures and maintaining sound reinsurance arrangements;
• complying with laws and internal procedures; and
• improving resilience to external events.
The Group has established internal controls to manage material business risks in the key areas of exposure relevant to QBE. The broad risk categories are strategic risk, insurance risk, credit risk, market risk, liquidity risk, operational risk and Group risk. Internal controls and systems are designed to provide reasonable assurance that the assets of the Group are safeguarded, insurance and investment exposures are within desired limits, reinsurance protections are adequate, counterparties are subject to security assessment and foreign exchange exposures are within predetermined guidelines.
The board approves a comprehensive risk management strategy (RMS) and reinsurance management strategy (REMS) annually, both of which are lodged with APRA. The RMS outlines the principles, framework and approach to risk management adopted by the Group, deals with all areas of significant business risk to the Group and outlines the Group’s risk tolerances. The REMS covers topics such as the Group’s risk tolerance and the Group’s strategy in respect of the selection, approval and monitoring of all reinsurance arrangements. The Group security committee assesses reinsurer counterparty security. This management committee normally meets four times a year and holds special meetings as required.
While the RMS and REMS are approved by the board, QBE believes that managing risk is the day‑to‑day responsibility of the Group head office and the business units, and that all staff need to understand and actively manage risk. The business units are supported by risk management teams, compliance teams, the Group risk and compliance manager and by senior management. Further information on risk management is provided on pages 28 to 31 of the annual report and in note 5 to the financial statements.
Management has reported to either the audit and risk committee or the board on the effectiveness of QBE’s management of its material business risks.
Internal audit
A global internal audit function is critical to the risk management process. QBE’s internal audit function reports to senior management and the audit and risk committee on the monitoring of the Group’s worldwide operations. Internal audit provides independent assurance that the design and operation of the controls across the Group are effective. The internal audit function operates under a written charter from the audit and risk committee. Other governance documents include a reporting protocol, internal audit manual, internal audit issue rating system, internal audit opinion levels and internal audit timetables. A risk-based internal audit approach is used so that higher risk activities are reviewed more frequently. The Group’s internal audit teams work together with the external auditor to provide a wide audit scope.
Delegated authorities
QBE has operated under an extensive written system of delegated authorities for many years. In particular, a written delegated authority with specified limits is approved by the board each year to enable the chief executive officer to conduct the Group’s business in accordance with detailed budgets and business plans. This authority deals with topics such as underwriting, reinsurance protection, claims, investments, acquisitions and expenses. The chief executive officer delegates his authority to management throughout the Group on a selective basis taking into account expertise and past performance. Compliance with delegated authorities is closely monitored by management and adjusted as required for actual performance, market conditions and other factors. Management and the Group’s internal audit teams review compliance with delegated authorities and any breach can lead to disciplinary procedures, including dismissal in serious cases.
Actuarial review
It is a long‑standing practice of the directors to ensure that the Group’s insurance liabilities are assessed by actuaries. The Group’s outstanding claims provision is reviewed by experienced internal actuarial staff. The chief actuarial officer is based in head office and there are over 220 actuarial staff in the Group. Actuarial staff are involved in forming an independent view, separate from management, of the central estimate and the probability of adequacy of the outstanding claims provision and premium liabilities, premium rates and related matters. More than 95% of QBE’s outstanding claims provision is also reviewed by external actuaries annually. External actuaries are generally from organisations which are not associated with the external auditor.
Insurance and other regulation
General insurance and, to a lesser extent, reinsurance are heavily regulated industries. In addition to the Group’s accounting, legal, tax and other professional teams, each division has compliance personnel and there is a Group regulatory manager based in Australia. Regulators in Australia include ASIC, the Australian Competition and Consumer Commission, APRA, the Australian Privacy Commissioner and relevant state authorities for compulsory third party motor insurance and workers’ compensation insurance. These regulatory bodies enforce laws which deal with a range of issues, including capital requirements and consumer protection. Similar local laws and regulations apply to the Group’s operations outside Australia.
Communication and guidelines
ASX Listing Rule 3.1 requires QBE to inform the ASX immediately once QBE is or becomes aware of any information concerning it that a reasonable person would expect to have a material effect on the price or value of QBE’s shares. Procedures are in place to ensure that items which potentially require announcement to the ASX are promptly notified to Group head office for assessment and released as required. The chief executive officer is responsible for authorising market releases. All market releases are posted promptly to the Group’s website.
QBE takes the spirit of its continuous disclosure obligations very seriously and issues frequent market releases during the year to satisfy those obligations. A list of the material releases made since 1 January 2010 is included on page 173.
Communication with shareholders
The Corporations Act 2001 no longer requires QBE to distribute an annual report to all shareholders except to those who elect to receive it. QBE also produces a half year report which is sent to all shareholders who elect to receive it. Both reports are available on the QBE website. The website also contains historical and other details on the Group. Shareholders can discuss their shareholding with either the shareholder services department or the share registrar, both located in Sydney.
The AGM is held in Sydney each year, usually in April. In 2011, it will be 5 April. Shareholders are encouraged to attend the AGM in person or by proxy. Most resolutions in the notice of meeting have explanatory notes. During the AGM, shareholders may ask questions of either the chairman or the external auditor.
Communications with analysts, investors, media, rating agencies and others
The chief executive officer, chief financial officer, chief executive officer of global underwriting operations, chief actuarial officer, chief risk officer, general counsel and company secretary, investor relations manager, divisional chief executives and divisional finance officers generally deal with analysts, investors, media, rating agencies and others, taking account of regulatory guidelines including those issued by the ASX on continuous disclosure. The presentations on the 30 June and 31 December results and other major presentations are sent to the ASX before the presentations commence and are available promptly on the Group’s website. The 30 June and 31 December presentations are also webcast live and subsequently archived on the Group’s website.
Share trading guidelines
QBE revised its policy in 2010 for directors and senior Group executives relating to the purchase and sale of QBE securities. These are in addition to the insider trading provisions of the Corporations Act 2001. In particular, the policy states that directors and senior Group executives should:
• never actively trade the company’s securities;
• not hedge unvested entitlements; and
• notify any intended transaction to nominated people within the Group, including notification of any hedging of vested entitlements.
The policy identifies set periods during which directors or senior Group executives may buy or sell QBE’s securities, being one to 30 days after each of the release of QBE’s half year results, the release of QBE’s annual report and the date of the AGM, and also one day after the issue of any prospectus until the closing date. Any QBE share dealings by directors are promptly notified to the ASX.
Other Group guidelines
The Group has adopted a code of conduct for Australian operations, Group head office and Group investment division which forms the basis for the manner in which these employees perform their work involving both legal obligations and the reasonable expectation of stakeholders. The code of conduct requires that business be carried out in an open and honest manner with our customers, shareholders, employees, regulatory bodies, outside suppliers, intermediaries and the community at large. The code also deals with confidentiality, conflicts of interest and related matters. The non-executive directors have adopted a code of conduct for themselves which is substantially the same as the code above.
Other divisions have developed codes of conduct based on the Group code above, with some differences to allow for the requirements of the particular countries in which the division operates.
There are other Group policies covering anti-discrimination, employment, harassment, QBE essential behaviours, health and safety, privacy, whistle-blowing and many other business practices. These policies, like the code of conduct, are underpinned by the Group’s vision and values statements. The vision and values statements form part of the induction information given to new employees. One of the core values of the Group is integrity.
QBE in Australia follows the general insurance code of practice, a self-regulated code developed by the Insurance Council of Australia relating to the provision of products and services to customers of the general insurance industry of Australia. A revised code of practice commenced in July 2010.
QBE in Australia is a member of the Financial Ombudsman Service, an ASIC approved external dispute resolution body which deals with general insurance disputes between consumers and insurers.
Similar insurance practice rules apply to the Group in certain other countries outside Australia.
Details of indemnification and insurance arrangements are included in the directors’ report on page 61.
The following documents are available either in the corporate governance area of QBE’s website or on request from the company secretary:
• board charter;
• audit and risk, investment and remuneration committee charters;
• non-executive director nomination guidelines;
• code of conduct for non-executive directors;
• code of conduct for Australian operations, Group head office and Group investment division;
• trading policy for dealing in securities of QBE Insurance Group Limited or other entities by directors and senior Group executives;
• global workforce diversity policy;
• continuous disclosure guidelines; and
shareholder communication guidelines.
QBE is a corporation involved in an industry that seeks to play a role, in conjunction with governments, individuals and organisations, in managing and reducing environmental risk. In an initiative to collaborate with the United Nations Environment Program, QBE, together with a number of other major international insurers, is a signatory to a statement of environmental commitment by the insurance industry. QBE is also a signatory to the Carbon Disclosure Project (CDP). The CDP is an independent, not-for-profit organisation which acts as an intermediary between shareholders and corporations on all climate change related issues, providing climate change data from the world’s largest corporations to the global market place.
QBE’s response to the latest CDP questionnaire, CDP2010, was published in September 2010 and is available on our website in the investor information section.
(1) As at 30 June 2010
(2) As at October 2010
(3) Senior leadership roles for the purpose of this statement includes all roles that have strategic, financial and operational accountability with responsibility for complex and operational people management and policy development
