Anne McGowan, Head of Supplier Management at Lloyds Banking Group, calls for a bold redefinition of vendor exit planning. Drawing on operational disruptions, regulatory expectations, and supplier ownership risks, she makes the case for embedded testing, r
In a climate of rolling outages, cyber incidents and fast-moving vendor failures, the Head of Supplier Management at a major international banking group is blunt about what must change.
“Exit planning isn’t a process - it’s an outcome,” she says. “In a crisis, your plan is binary. It either functions or fails.”
She argues that exit planning has long been treated as an administrative afterthought: a handful of contract clauses and notional contingencies filed away until renewal.
That approach, they contend, collapses under real-world pressure. “Outdated notions of exit planning don’t meet the demands of a live incident,” she says. “You need something you can actually execute.”
Regulatory expectations are pushing in the same direction. Under the UK Prudential Regulation Authority’s SS2/21, supervisors have been deliberately non-prescriptive, asking firms to determine proportionate approaches.
“That flexibility is both a gift and a challenge,” the executive notes. “It puts the focus where it belongs - on service continuity when a supplier disappears, data is held hostage or the reputational fallout begins.”
Recent events have sharpened the point. At the end of April, a cyberattack linked Marks & Spencer, the Co-op and Harrods - brands with little else in common.
Weeks earlier, a major power outage rippled across Spain and Portugal. Last year’s Snowflake breach and the CrowdStrike outage showed how nth-party weaknesses can escalate quickly and publicly.
“Operational resilience has moved into the public’s consciousness - and for good reason,” said the expert.
For this executive, business continuity and exit planning are inseparable. “It’s not a clean handoff,” she explains.
“It’s more like the UK weather - one season blurs into the next. Business continuity keeps you online in the short term; exit planning ensures the long-term path, whether that’s onboarding a new supplier or transitioning in-house.”
Trying to split the disciplines entirely, she warns, creates governance gaps. “You need end-to-end ownership and integration.”
Complexity is the daily battle. Exit plans attract a crowd: procurement, legal, security, data governance, first and second lines, business owners and more.
“Getting sign-off can feel circular,” the executive acknowledges. “The more people involved, the more signatures you need. Supplier managers have to be the central thread - coordinating, convening and connecting across domains.”