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Brenig Moore DipNEBOSH, CMIOSH, CEnvH

Why Compliance is a Board-Level Priority | The Strategic Case for IOSH Managing Safely

November 2025


Health and safety compliance has shifted from operational necessity to strategic imperative, with directors now facing personal liability and organisations competing on safety credentials.

In facilities management, compliance has evolved into a strategic imperative that directly impacts business continuity, competitive positioning, and corporate liability. Throughout my consulting work with FM organisations, I've witnessed a fundamental shift: boards that once viewed safety training as an operational cost now recognise it as essential risk governance.

The stakes have never been higher. With the Building Safety Act now in full force, Martyn's Law establishing new terrorism risk requirements in future, and HSE consultations signalling regulatory tightening, facilities management leadership faces an increasingly complex compliance landscape. The question isn't whether to invest in management-level safety competence, it's how quickly you can embed it across your organisation.

 

Compliance Beyond Operations | A Competitive Advantage in FM Contracts

Compliance credentials now separate contract winners from losers, with clients demanding evidence of management competence beyond procedural documentation.

When tendering for major facilities management contracts, I've reviewed countless procurement documents where clients explicitly require evidence of management competence, not merely procedural documentation. IOSH Managing Safely certification demonstrates that your organisation takes a structured, recognised approach to safety leadership.

Under the Health and Safety at Work Act 1974, directors and senior managers carry personal liability for safety failures. Section 37 makes this explicit: where an offence results from neglect or consent of a director or manager, that individual can be prosecuted personally.

Key accountability drivers for FM boards:

  • HASAWA Section 37: Personal prosecution for directors whose neglect contributes to offences
  • Building Safety Act 2022: Clear governance requirements with digital "golden thread" tracing decisions to individuals
  • Contract performance clauses: Financial penalties for safety incidents increasingly standard in major FM agreements
  • Procurement requirements: Systematic safety training now explicitly required in tender documentation

The Building Safety Act reinforces this accountability further, establishing clear governance requirements for higher-risk buildings and creating documentation that traces responsibility directly to decision-makers.

This isn't a theoretical risk. Following the Grenfell Tower tragedy, the regulatory environment has fundamentally changed. Boards must demonstrate proactive competence, not reactive compliance. FM contracts increasingly include safety performance clauses with financial penalties for incidents. One major client I worked with recently lost a £3 million contract renewal because their management team couldn't evidence systematic safety training, despite an otherwise exemplary operational record.

IOSH Managing Safely provides the strategic framework that demonstrates board-level commitment. It signals to clients, regulators, and insurers that your organisation embeds safety thinking at the management level, where critical decisions are made daily.

 

The Legal and Financial Impact of Non-Compliance for Leadership

Safety failures expose directors to personal prosecution and organisations to fines exceeding £20 million, with reputational damage often outweighing direct financial penalties.

Corporate manslaughter prosecutions under the Corporate Manslaughter and Corporate Homicide Act 2007 target organisations where management failures result in fatalities. The sentencing guidelines consider turnover, culpability, and harm, factors that hit FM organisations particularly hard, given the multi-site, multi-stakeholder nature of the industry.

The true cost of a serious incident extends far beyond immediate fines:

  • Legal representation and prosecution defence.
  • Insurance premium increases: 100-300% typical.
  • Contract loss and tender exclusions.
  • Director disqualification proceedings.
  • Operational disruption and project delays.

Beyond fines, the Health and Safety (Offences) Act 2008 increased maximum penalties dramatically. Magistrates' courts can impose unlimited fines for major breaches, while Crown Court convictions routinely result in seven-figure penalties. Directors can face up to two years' imprisonment for the most serious offences.

Reputational damage frequently exceeds direct financial penalties. In our interconnected professional environment, news of serious incidents spreads rapidly. I've seen organisations lose three major contract opportunities within six months of a single RIDDOR-reportable incident, not because of the incident itself, but because their investigation revealed systemic management failures.

 

Emerging Compliance Trends Boards Must Watch

New legislation, including Martyn's Law and Building Safety Act digital requirements, combined with HSE consultations on asbestos and LOLER, signal significant regulatory expansion in 2025-2026.

Facilities management boards must track multiple regulatory developments simultaneously, each creating new compliance obligations for management teams.

Key regulatory changes impacting FM operations:

Regulation

Status

FM Impact

Martyn's Law (Terrorism Protection of Premises Act 2025)

Now in force

Terrorism risk assessments and protective measures required for qualifying public venues.

Building Safety Act "Golden Thread"

Ongoing implementation

Digital documentation of safety decisions throughout building lifecycle.

LOLER & Pressure Systems (HSE consultation)

Evidence gathering Oct 2025

Potential simplification but heightened enforcement focus expected.

Control of Asbestos Regulations

Consultation Nov 2025

Strengthened requirements anticipated for older building stock.

ESG Reporting Integration

Growing investor focus

Health and safety performance now material sustainability factor.

 

Martyn's Law requires qualifying premises to implement terrorism risk assessments and protective security measures. For facilities managers operating public venues, shopping centres, entertainment facilities, and large office buildings, this creates new compliance obligations. Management teams must understand threat assessment, evacuation planning, and coordination with emergency services, competencies addressed within comprehensive safety training frameworks.

The Building Safety Act implementation continues throughout 2025, with the "golden thread" requirement demanding digital documentation of safety decisions throughout a building's lifecycle. This affects not just new high-rise residential buildings but increasingly extends to complex commercial premises.

ESG reporting increasingly incorporates health and safety performance as a material sustainability factor. Institutional investors and major clients now scrutinise workplace safety records as indicators of operational excellence and ethical governance. I've worked with FM organisations preparing for ESG disclosure, where safety training completion rates and management competence formed explicit reporting metrics.

 

How IOSH Managing Safely Supports Strategic Goals

IOSH Managing Safely aligns safety leadership with risk governance, business continuity, and ESG objectives while delivering measurable ROI through incident reduction and insurance savings.

Rather than viewing safety training as compliance expenditure, progressive FM organisations recognise IOSH Managing Safely as strategic investment that supports multiple business objectives simultaneously.

Strategic business benefits of management-level safety competence:

  • Risk Governance: Provides conceptual framework for managers to participate meaningfully in enterprise risk management and ISO 31000 implementation.
  • Business Continuity: Prevents incidents that disrupt operations, damage client relationships, and trigger supply chain consequences.
  • Financial Performance: Reduces incident-related costs, including lost-time injuries, legal fees, emergency response, and operational disruption.
  • Insurance Efficiency: Demonstrates due diligence to underwriters, reducing premiums and improving coverage terms.
  • ESG Integration: Supports sustainability strategies, B Corp certification, and supply chain audits requiring safety performance evidence.
  • Workforce Engagement: Improves employee morale, retention, and safety culture when management demonstrates genuine competence.

Employees notice when management demonstrates genuine safety competence. Organisations where managers understand practical risk control and communicate effectively about safety typically see improved workforce morale and reduced turnover - meaningful advantages in today's competitive labour market.

 

Action Plan for FM Leaders

Implement systematic management competence through six strategic steps: audit current status, establish board-level priority, roll out structured training, integrate into governance, monitor outcomes, and maintain through refreshers.

Boards serious about strategic compliance should implement a systematic approach to building management competence across their organisations.

Six-step implementation roadmap

Step 1: Audit Current Compliance Status

  • Map management team safety qualifications against operational responsibilities
  • Identify gaps where managers carry safety-critical duties without appropriate training
  • Assess site-specific risks (asbestos, confined spaces, working at height, lone working)
  • Review recent incidents and near-misses for competence-related factors

Step 2: Establish Training as Board-Level Priority

  • Include safety competence in board discussions as strategic risk governance
  • Set explicit targets for management training completion with accountability
  • Allocate budget reflecting strategic importance, not discretionary spending
  • Make IOSH Managing Safely completion a condition for management promotion

Step 3: Implement Structured Training Rollout

  • Develop phased deployment plan rather than ad-hoc scheduling
  • Prioritise managers with highest risk exposure: contractor oversight, high-risk activities, compliance documentation
  • Create training cohorts that enable peer learning and build organisational safety language
  • Schedule around operational demands while maintaining momentum

Step 4: Integrate Training into Governance Frameworks

  • Link safety competence to existing management systems (quality, environmental, operational)
  • Update job descriptions to specify safety training requirements
  • Include competence verification in internal audit schedules
  • Reference management training as control measure in safety management system documentation

Step 5: Monitor and Demonstrate Outcomes

  • Track training completion rates as board-level KPI
  • Monitor incident trends to demonstrate training impact on safety performance
  • Document competence improvements in client reports, tender responses, and ESG disclosures
  • Use training completion as evidence during HSE inspections and insurance reviews

Step 6: Maintain Competence Through Refresher Training

  • Establish review cycles, ensuring managers maintain current understanding
  • Update training to address emerging risks (Martyn's Law, Building Safety Act requirements)
  • Schedule refreshers every 3-5 years aligned with regulatory changes
  • Consider additional modules for evolving compliance obligations

One successful FM provider embedded this approach by making IOSH Managing Safely completion mandatory for management promotion, creating clear career incentives while systematically building organisational competence.

 

Invest in Strategic Competence

Health and safety compliance has moved irrevocably from the operations floor to the boardroom. Directors and senior leaders now face personal liability, organisations compete on safety credentials, and emerging regulations demand demonstrable management competence.

IOSH Managing Safely provides the recognised framework that meets these strategic requirements. It demonstrates to clients, regulators, insurers, and employees that your organisation takes safety leadership seriously. More importantly, it builds genuine competence that protects your people, operations, and reputation.

The facilities management organisations that thrive in 2025 and beyond won't be those that merely comply, they'll be those that embed safety thinking at every management level, treat compliance as a competitive advantage, and demonstrate board-level commitment through systematic investment in competence.

Is your management team equipped with the safety leadership skills today's compliance environment demands? Explore how IOSH Managing Safely can strengthen your organisation's strategic approach to health and safety risk management, protect your board from personal liability, and position your business for sustainable success in an increasingly regulated industry.




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