Building a Successful ERM Program

Iman H. Al-Gharabally is responsible for the enterprise risk management program at Kuwait Petroleum Corporation (KPC) and its subsidiaries since 2004. She is the team iman-h-al-gharabally-picleader, coordinator and project manager for the ERM program and its strategic implementation across the Kuwait oil sector. Al-Gharabally, a speaker at RIMS’ Middle East Risk Forum 2016, taking place Dec. 13 and 14 in Dubai, United Arab Emirates, discusses the implementation strategies and successes of KPC’s ERM program.

RIMS: How did you begin the process of building KPC’s ERM program?

Al-Gharabally: In 2002 the KPC managing directors at the time recognized there was a serious need to look into and have in place a consolidated view of potential risks and a consolidated risk management format of those risks facing the organization. Hence the ERM initiative was introduced as a way to instill this unified format of consolidated risk management mainly through the insurance section. In 2004 the ERM initiative was introduced and in 2006 the ISO 31000 was launched.

RIMS: How did you develop your ERM structure?

Al-Gharabally: Initially I had no prior knowledge of what ERM stood for. I was recruited in April 2004 from Kuwait Oil Company (a subsidiary to KPC) to project manage and lead this new ERM initiative. I studied the topic extensively and slowly had to lay down the foundation for a dynamic ERM program for KPC and its subsidiaries. We started at the very top, first in the corporate office looking at the strategy of the corporation and what the corporate objectives aimed to achieve in the coming five years from 2004 to 2009. We then looked at the potential risks that would prevent the corporation from achieving those objectives and started the communication lines across the subsidiaries to initiate awareness on these potential risks and put forth mitigation options to ensure the corporation was well prepared and to increase our abilities to deliver on our strategic objectives.

It was imperative at the very beginning to ensure that we worked hand-in-hand with the various planning, HSE and marketing units across the entire value chain. The idea was to start the conversations early and brainstorm unilaterally for solutions to be placed to counteract any potential risks emerging that would hinder our 2020 strategic business goals.

Over the first few months in 2004, we managed to convince CEOs across the group to create and assign a focal point to be internally responsible for ERM and coordinate and liaise with us at the corporate head office on all ERM related matters. It took 10-12 months before having each subsidiary assign a dedicated ERM focal point. Once there were dedicated individuals to communicate with and be internally responsible for monitoring and reporting on all risk-related matters, the next phase of setting up an ERM framework and governance structure was initiated. In 2007 the ISO 31000 framework was launched across the group for implementation.

KPC’s ERM structure is that of a hybrid matrix in which central ERM policies, procedures and key performance measures are set, while subsidiaries and ERM units across the group are free to implement according to their individual company’s needs and business model.

RIMS: How did you make ERM a success?

Al-Gharabally: It was not an easy task, to be honest. KPC is the corporate head office to eight other companies from upstream to downstream. The nature of their business is quite complex and diversified. So to lead ERM initiatives and have them fully incorporated and periodically monitor and report on the progress is a challenging full time task. The key is to be well integrated. From the very start of our initiative in 2004 we made certain that the corporate head office ERM unit was well integrated with each and every single subsidiary ERM unit. We put in place a platform establishing a community of ERM best practice and there are means to discuss, troubleshoot and share various topics to ensure the benefit is widely absorbed across the entire oil sector. We conduct periodic risk culture surveys and benchmark ourselves not only internally across the group, but also against international financial and oil corporations with advanced risk management programs.

RIMS: What is unique about KPC’s approach to ERM?

Al-Gharabally: Having an ERM program in place in an oil corporation is in itself unique. To take that further and have a single unified ERM strategy and shared initiatives across multi discipline functions and across eight subsidiaries elevates the uniqueness. Having delivered a successful fully functioning ERM program over the past 13 years in close collaboration with the corporation’s strategic planning, financial and marketing departments sets KPC’s ERM program apart.

RIMS: What tools/resources have been the most helpful on this journey?

Al-Gharabally: From a risk culture perspective, establishing a community of best practices for ERM individuals to have a platform to share and collaborate various ideas, trouble-shoot implementation issues or integrate objectives on unilateral ERM implementation plans is critical to the success of our program. Having a risk operating committee chaired by the CFO and reporting to the corporation’s risk and audit committee was also a critical success factor to KPC’s ERM initiative. Subsidiaries learned early on that having a dedicated ERM unit reporting directly to the CEO, with no conflicts of interest of shared ownership of risks in the reporting line, was a critical success factor to KPC’s ERM structure. From a technical perspective, establishing a clear ERM framework, policy and procedure as well as systematic reporting of risks in a unified ERM information system, and linking the reporting to the corporations was a critical success factor.

Rims: How can ERM best inform strategy?

Al-Gharabally: KPC’s decision to maximize transparency and work closely with strategy marketing and finance was a key aspect in making our ERM program successful. To be able to look at leading risk indicators and have in place the appropriate mitigation options for improving the corporation’s performance in meeting its strategic objectives is an invaluable resource.

RIMS: What advice can you give those embarking on building a world-class ERM program?

Al-Gharabally: Communication, communication, communication! Had we not lobbied, or brainstormed across various business functions early in our journey in 2004, or not ensured that we had the full support of planning and finance on board for our ERM initiatives, our program most likely would have flopped!

Retail Data Security: Preparing for the Top Threat for Holiday Breaches

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Here’s the question of the season: What is the true cause of the retail breaches we read about year after year? While malware or ransomware may get most of the scary security press, they aren’t in fact the main culprit. The primary cause of most retail breaches is, by far, stolen credentials. These are the usernames and passwords of employees, contractors or partners of a retail firm. Victim firms such as Target Corp., Home Depot, eBay and others have fallen prey to similar attacks in recent years: a trusted insider’s credentials were stolen and hackers used those to access the network. In some cases, the credentialed access led to the installation of malware on card reader systems, while in others, hackers took different paths.

The point is clear, however: the access credentials of trusted insiders are in fact the biggest risk factor for a breach in the retail sector. Verizon’s annual data breach survey, released earlier this year, confirms this, with credential attacks identified as the top source of data breaches as 63% occurred via weak or stolen credentials.

This isn’t a particularly new insight. The Target and Home Depot breaches, both via stolen vendor credentials, happened more than two years ago. And yet, as the Verizon report indicates, large firms are still quite vulnerable to credential attacks. Why is a credential-based attack so hard to detect? The point of the attack is to impersonate a valid user (an employee, contractor or some other insider) going about his or her daily job. When a financial analyst logs into a financial system using her regular ID and password, for example, we do not expect an alarm to sound.

The retail environment has some unique factors that make detection more difficult. For example, retailers employ large numbers of seasonal workers, so knowing whether a particular person should be allowed near a secure server in the back room of a store may be difficult. The general buzz and chaos in retail stores may weaken security checks, and sheer volume of transactions, returns, special orders, and the like can distract employees and open up security gaps.

There are, however, concrete steps that can be taken.

The first is simple: most if not all retailers have two networks, one corporate and one retail (in-store). Human resources, research and development, accounting, and other corporate functions operate on the corporate network. Point of sale systems, cashiers, and store managers operate on the retail network. In theory, these networks are completely walled off from each other, using two-factor authentication and other security systems. A temporary sales clerk should not be able to access the payroll system at corporate headquarters and download employee social security numbers, just as an HR specialist at headquarters should not be able to access the credit card database within a store point-of-sale (POS) server. This is especially sensitive since many retailers haven’t yet rolled out chip-and-pin readers. If a card number is stolen from a POS system, it’s usable in many places.

A basic check would be to ensure that the two-factor authentication system between the corporate and retail networks is working correctly, is updated with patches, and is applied as broadly as possible. However, this is not always the case, and there have been instances where hackers have been able to steal a corporate user’s credentials (using a keylogger or other type of malware) and then bypass the authentication system to connect to hundreds of in-store POS systems. Perhaps the system configuration has “drifted” over time and needs re-certification. This is an easy check on network security risk.

Another step relates to context—in other words, understanding what is normal. As mentioned above, a retailer during the holiday season manages chaos on a daily basis. It is too easy for attacks to slip by without notice during the noise and commotion. Recall the advice given to New Yorkers after 9/11: “If you see something, say something.” While relying on employees to notice unusual behavior is fine, a better approach is to augment humans with smart technology that understands normal behavior and can raise an alarm when behavior is suddenly not normal.

For example, a specialist in IT is accessing hundreds of POS systems in multiple stores via the corporate network. Is that okay? It is hard to say. Perhaps he is doing it as part of a backup process or maybe he is helping restore systems after a failure. Without knowing what is normal for this person, as well as for his peers, it is very difficult to judge the riskiness of his actions. Behavioral analytics systems are built for this problem. They analyze past behavior and build baselines, just as VISA and MasterCard do for every credit card owner. When an employee suddenly starts logging into store POS systems but has never done so before, behavioral baselines can provide the context needed to alert that this user might in fact be a hacker.

Retailers are getting better about security every year, improving risk management processes and rolling out new security technologies. Credential attacks remain the top threat for retail breaches, however, and retail firms must both verify their processes and also look to new solutions, such as behavioral analytics, to close the risk gap.

Wells Fargo: What Should Have Happened

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When Wells Fargo fired 5,300 employees in September for inappropriate sales practices, then-CEO John Stumpf approached the scandal with an outdated playbook. In response to the $185 million in fines levied by regulators, he first denied any knowledge of the illegitimate accounts. Attempting to mitigate press fallout by distancing the company from a group of “bad eggs” acting independently is not the answer, however. Even if Stumpf had maintained this assertion of innocence, changes in the risk environment over the past few years demand a proactive approach.

Rather than simply deflecting responsibility in these situations, executives must be able to accomplish two things:

• Provide historical evidence of due diligence and risk management (if such a program was actually used)
• Demonstrate how the company is adjusting its policies and/or implementing new policies to ensure a similar incident doesn’t happen in the future

In 2010, the SEC’s Proxy Disclosure Enhancement (rule 33-9089) explicitly made boards of directors responsible for assessing and disclosing risk management effectiveness to shareholders. It mandates the use of risk monitoring systems to demonstrate that existing controls (mitigation activities) are effective. Under this rule, “not knowing” about an activity performed by employees is considered negligence. This is a crucial development; negligence carries the same penalty as fraud, but it does not require proof of intent. The Yates Memo (2015) gave the SEC ruling more “teeth” by requiring organizations to provide the Department of Justice with all the facts related to responsible individuals.

As a result, many companies have suffered significant penalties and frequently criminal charges, even though their executives were allegedly unaware of illicit activities. Consider the emissions scandal at Volkswagen and fines paid (to the SEC) by global health science company Nordion Inc. In both instances, deceptions were perpetrated by individuals below the executive level, but senior management’s inability to detect/prevent the incidents came back to bite them.

How to Prevent Risk Management Failures at Your Organization

John Stumpf’s approach should have started with an admission of Wells Fargo’s failure in risk management processes across the enterprise, followed by evidence that a more effective, formal enterprise risk management process is being implemented. For example, risk assessments must cascade from senior management down to the front lines and across all business silos. This ensures that the personnel most familiar with operational risks (and how to mitigate them) can keep the board informed.

In other words, instead of simply apologizing and attempting to provide restitution, Stumpf should have demonstrated that Wells Fargo is taking proactive risk management measures to protect its many stakeholders. It is the company’s duty to ensure that something like this never happens again.

The scandal is predictably following the same track as have previous failures in risk management: it starts with regulatory penalties, then leads to punitive damages, class action lawsuits, and finally, criminal charges and individual liability, depending on the particular case. The key to this pattern is the absence of adequate risk management, which means negligence under the new enterprise risk management laws, regulations and mandates passed since 2010.

The good news is that avoiding serious, long-term consequences is possible if proper actions are taken. For example, by providing a historical record of risk management practices, Morgan Stanley avoided regulatory penalties when an employee evaded existing internal controls. Other corporations that can provide evidence of an effective risk management program (risk assessments, internal controls that address risks, monitoring activities over these internal controls, and an electronic due-diligence trail) are largely exempt from punitive damages, class-action lawsuits, and possible jail time.

When implemented proactively, effective risk management systems have and will continue to prevent scandals, regulatory fines, litigation and imprisonment. For a more in-depth analysis of the Wells Fargo scandal, read the LogicManager blog post “The Walls Fargo Scandal is a Failure in Risk Management.”

Establishing Company Gift-Giving Guidelines

With increased regulatory oversight around the globe, companies’ external and internal gift-giving are under scrutiny. With the holiday season upon us, it is up to organizations, no matter what the size, to clearly state policies and leave no question about what is and what is not allowed. Establishing monetary limits for gifts given and received is also a good idea.

According to a report by Thomson Reuters:

While bribery and corruption charges are widespread, it’s important to note that bribery is not synonymous with gift-giving. When it comes to gift-giving, businesses cannot offer, promise or give anything of value, directly or indirectly, to a foreign official for the purpose of obtaining or retaining business. Corporate gifts need to be carefully evaluated to ensure they do not appear to violate these prohibitions.

Internal gifting policies vary from company to company, and while there is no one-size-fits-all approach, it is extremely important that organizations have policies in place and that employees are aware of what those policies are. No matter how well-intentioned a gift, the potential exists that it falls outside of the appropriate boundaries.

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Organizations need to be clear about what types of gifts are acceptable and what are not.

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Both employers and employees should also be aware of what constitutes a bribe and what types of bribes to watch out for.

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Regulatory bodies are holding companies accountable, and depending on the countries involved, regulatory fines can range from prison terms to millions of dollars in fines.

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