Key Steps to a Robust Risk Management Program

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Our business environment is constantly changing—technologies improve, regulations are modified, competition increases, and demand evolves. Effective risk management grants an ability to adapt to these changes.

Recent headline events, including the Volkswagen emissions deception, the Wells Fargo scandal, and the penalty paid by Dwolla to the Consumer Financial Protection Bureau (CFPB), illuminate powerful motivators for strong risk management programs. Key to a robust program is preventing stressful, and possibly catastrophic, surprises.

When Plains All American Pipeline failed to detect corrosion in its pipeline, for example, the result was a 3,000-barrel oil spill and millions of dollars in fines. The corrosion had run under the radar because the company did not delegate sufficient inspection resources and did not maintain proper procedures and systems for preventing problems from escalating into emergencies. Risk management best practices, however, could have standardized these procedures throughout the organization and prevented the disaster from occurring.

Complying with regulators like the SEC and CFPB
Dwolla, a small, private e-commerce and online payment company, was found by the CFPB to be guilty of risk management negligence for inadequate data security practices. The catch is that Dwolla did not suffer a data breach and none of its customers were compromised. The CFPB fined Dwolla $100,000 as part of its increased focus on companies’ existing prevention strategies. Regulators are no longer simply pursuing organizations that have suffered risk management incidents; organizations need to take proactive approaches rather than simply hope to get by.

Improving productivity and encouraging innovation
An independent, peer-reviewed report, “The Valuation Implications of Enterprise Risk Management Maturity,” published in The Journal of Risk and Insurance, proved that organizations with mature ERM programs (as defined by the RIMS Risk Maturity Model) can achieve a 25% firm valuation premium over those without. Risk management does not have to be a burdensome addition to daily responsibilities—and if it is executed properly, it won’t. It simplifies daily operations by increasing transparency and allowing more resources to be devoted to value-add activities, like product development and customer services.

Checklist for evaluating your risk management efforts

A better question than “does my organization perform risk management?” is “how effectively does my organization identify and mitigate risks?” The following checklist outlines characteristics common to effective risk management programs. Your organization should prioritize development in these areas.

  1. Effective risk management governance

Boards, through their risk oversight role, are accountable for a risk’s material impact, whether the cause is at the executive level or on the front lines. The SEC considers “not knowing about a material risk” negligence, which carries the same penalties as fraud.

  • The board must monitor the effectiveness of the organization’s risk management process, ensuring it reaches all levels and business areas.
  • Internal auditors must independently confirm the board is informed on all material risks.
  • All material risks must be disclosed to shareholders, along with evidence that they are effectively mitigated.
  1. Performance management and goal management
  • Divide corporate objectives into business-unit contributions.
  • Identify business processes contributing to a goal within each business unit.
  • Cascade goals to all front-line managers within contributing processes.
  • Aggregate goal assessments and determine links between contributing business processes.
  1. Consistent risk identification and prioritization

Risk assessments must address more than high-level concerns. Effective assessments drill into risk events, uncovering the root cause, or problem “driving” the risk. Repeatable risk assessments are based on common numerical scales and scoring criteria across departments.

  1. Actionable risk tolerances

Risk appetite is a high-level statement that serves as a guide for strategic decisions. In order to be actionable, it should be accompanied by its quantitative cousin, risk tolerance. Risk tolerance is an effective monitoring technique for key performance goals and risk metrics.

  1. Centralized risk monitoring and control activities

Risk managers need to do more than design processes to identify risks and appropriate responses. A critical third component—monitoring—is the verification of a control’s effectiveness over the risk. A few key things to keep in mind to make monitoring effective:

  • Adjust risk assessments over time (spend less time on risks with decreasing indexes).
  • Reduce testing by identifying areas that can share controls (increase organizational efficiency).
  • Link risks and activities to determine which processes need to be monitored (prioritize activities/initiatives).
  • Monitor business metrics (discover concerning trends before they affect the organization).
  1. Forward-looking risk and goal reporting and communication

In order to continue funding their organizations’ risk management programs, boards need evidence that those programs are working. Risk managers should ask two basic questions before reporting to the board:

  • How might identified risks affect the board’s strategic objectives and key concerns?
  • Which metrics or trends most validate the program’s effectiveness?

These items are just a starting point for an analysis of your organization’s program. For a more in-depth blueprint and “state of ERM” report, take the RIMS Risk Maturity Model (RMM), a free best-practice assessment tool that scores risk management programs and generates an immediate report of your organization’s risk maturity.

Vendor Risks: Preventing Recalls with ERM

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In 2016 alone, there have been dozens of recalls, by food companies, car manufacturers, and vitamin producers, among others. Not only do these recalls greatly impact a company’s bottom line, they can also affect the health and safety of consumers. With this in mind, what can organizations—both within the food industry and otherwise—do to improve their chances of uncovering suppliers operating in subpar conditions? How can they mitigate the risk of recalls?

Customers of CRF Frozen Foods, for example, a full-line, individually quick frozen processing plant that packages fruits and vegetables for a variety of customers, recently had big problems when it was linked to a widespread listeria outbreak. Contaminated foods affected big-name distributors like Trader Joe’s, Costco and Safeway, and some customers fell ill as a result.

Even though a series of sanitation concerns and other facility issues at CRF had been exposed by regulators as early as 2014, the factory was allowed to continue operating and its customers weren’t notified.

Red flags raised by regulators aren’t always seen by the companies they’re most relevant to, however. The fact that these outbreaks occurred seems to demonstrate that customers’ vendor management practices either failed or simply weren’t robust enough to detect issues. It all comes down to effective enterprise risk management (ERM). ERM provides the tools and framework that allow any organization to standardize processes and effectively mitigate vendor risk.

An ERM approach is characterized by standard criteria, interdepartmental communication, and automatic alerts and notifications. It keeps everyone in the organization on the same page and ensures assessment results are always understandable and accessible. This eliminates redundancy in the risk management process. As a result, you can quickly and easily determine the last time your organization evaluated a supplier. Something as simple as a notification that regulators have published new requirements might save your organization from acquiring infected or defective products.

There are three general stages that apply to any successful risk management effort:

  1. Identify specific risks, followed by assessment and evaluation
  2. Implement tailored mitigation activities to address those risks
  3. Monitor those mitigations to ensure long-term effectiveness

The first step serves as the foundation for steps two and three. Without a proper understanding of what risks your organization faces, it is impossible to prioritize and mitigate them. Especially across multiple business departments or within supply chains—it is quite difficult to identify and account for every variable.

To keep up with vendors’ fluctuating conditions, teams need to systematically identify and assess risks, catching them as they crop up. Preventing assessments from becoming obsolete is the key to keeping a pulse on everything that may affect the business, therefore avoiding unwanted surprises.

Risk assessments also help determine the best way to allocate limited resources. Minimizing vendor-related risks needn’t be burdensome, however. It should be a streamlined process that, by enabling you to avoid harmful incidents, improves operational efficiency. Once your risk assessments reveal the areas of highest priority, you can determine exactly how to mitigate those concerns.

The Freedom of Information Act can be extremely helpful when it comes to your third-party risk management efforts. It grants all companies the right to ask vendors for specific information about plant processes, worker training, sanitation practices, and maintenance. Suppliers are required to be forthcoming with all information (when asked), and teams need to take advantage of this opportunity. It is an important part of the risk management equation and will help you understand your risks before disruptions occur.

Performing vendor risk assessments—in the form of inspections, questionnaires, and service level agreements—generates an enormous amount of data and information. This information is useful for mitigating risk, but only if it is up to date, consistent and distributed to the appropriate individuals. The Freedom of Information Act provides an opportunity to evaluate suppliers with robust risk assessments, and ERM provides the means to capitalize on that opportunity. Ad-hoc assessments of current and prospective vendors, without standardized processes, will only get your team so far.

Steps to Effective ERM

Capitalizing on your vendor assessment rights is only part of the equation. Without an appropriate means of processing, distributing, and making data actionable, you’re back at square one. To make sense of important data, follow these steps:

  1. Create a taxonomy: define relationships between risks, requirements, goals, resources and processes. If each area of the business uses its own system for identifying and classifying risk, the resulting information is subjective and unusable by other departments. There is also significant information overlap—and therefore waste. Use your existing information to create a standard for data collection with minimal work.
  1. Streamline with the standardized risk assessments identified in step one. Risk assessments can be conducted in many different formats and qualities. Use resources already in place and streamline the results using the standard from step one. The most effective way to collect risk data is by identifying the root cause, or why an incident occurred. Honing in on the root cause provides useful information about what triggers loss and your organization’s vulnerabilities. When you link a specific root cause to a specific business process, designing and implementing mitigations is simpler and more effective.
  1. Connect mitigation activities to each of the key risks in these processes. A risk taxonomy gives you a more holistic understanding of all the moving parts in your organization. This makes it easier to design mitigation activities.
  1. Connect incidents, complaints and metrics (for each business process) to mitigation activities. Typically, companies already dedicate many resources to monitoring business performance, collecting information about incidents, complaints and metrics. These processes are often inefficient and ineffective. Simply connecting them to mitigation activities, however, identifies the reason such incidents happen. You can then take straightforward corrective actions, meeting top priorities and allocating resources with forward-looking measures. Risk management, after all, is not about minimizing fallout after an incident, but preventing such an incident from happening in the first place.

To make this entire process effective, management must work to develop an enterprise-wide risk culture. ERM is not just an executive-level process, but should be pushed all the way to frontline managers, where everyday decisions are made and the risks are known—but resources are often absent.

Approach your vendor risk assessments as you would any other risk assessment—they should be reoccurring and standardized. Perform them regularly and evaluate the results with the same scale and criteria with which you evaluate all other risks. Finally, automate information collection and review so that reporting reveals cross-silo dependencies before these risks turn into scandals. The result will be increased vendor security and the prevention of surprises, at a fraction of the cost.

Intuit Wins 2015 ERM Award of Distinction

CHICAGO—In recognition of its success in building a sustainable enterprise risk management (ERM) program to enable its business lines to identify and intelligently manage the most important risks, software company Intuit was presented with the 2015 Enterprise Risk Management Award of Distinction at this year’s RIMS ERM Conference.

“ERM transformed Intuit’s risk management capability requiring our leaders to think cross-organizationally and cross-functionally to understand the most significant risks and drive strategies to address them,” said Janet Nasburg, chief risk officer at Intuit. “ERM was instrumental in not only providing insights about the company but has also driven changes in the way we align our focus. It is a tremendous honor to be recognized by RIMS for our hard work and to share our ERM experiences with the risk management community.”

Honorable mention for this year’s ERM Award of Distinction went to VIA Rail Canada Inc., the country’s national passenger rail company. As a result of its ERM program, the company developed a risk appetite and tolerance framework based on measurable leading key risk indicators.

“Applying this framework to its key strategic risks strengthened VIA’s ability to assess, monitor, and respond timely to changes in its enterprise-wide risk portfolio, thereby adding value to its decision-making process and enhancing risk oversight by its board of directors” said Denis Lavoie, VIA’s director of enterprise risk management.

“RIMS is delighted to recognize the accomplishments of these two organizations and their risk professionals through the RIMS Award of Distinction,” said RIMS Executive Director Mary Roth. “The Intuit and VIA Rail programs demonstrate the tangible value that ERM brings to their respective organizations for both strategy-setting and strategy execution.”

Judging criteria for the ERM Award of Distinction includes the scope of the ERM program and how it engages different levels throughout the organization; the program’s link or connection to the company’s overall mission; and its ability to create additional value for the organization.

10 Tips to Excel in ERM

05a9ef2CHICAGO—For many risk managers looking to implement enterprise risk management programs, one of the biggest challenges is figuring out how to do it properly. Unfortunately, as Steve Zawoyski, ERM leader at PwC, pointed out in a session at this year’s RIMS ERM Conference, you will never find the perfect ERM program—it’s basically as mythical as a unicorn. But there are certain key steps you can take to increase your chances for a successful ERM program. Zawoyski’s top tips are:

  1. Establish ERM program objectives. One of the common stumbling blocks to a successful program is the lack of agreement as to why you are doing this in the first place. Some may be doing it in order to make better decisions around strategy while others have governance concerns in mind or are simply doing it because the board said so. Establishing proper objectives will allow you create the program that works best for your organization.
  2. Manage stakeholders. There are likely multiple parties that have a vested interest in your ERM efforts from the board to business managers to legal and audit to regulators. You will need to consider all of their specific needs and concerns.
  3. Align risk functions. Risk management is part of every division’s responsibility. Getting everyone on the same page will avoid allowing fatigue to set in over yet another risk management effort.
  4. Align risk and management processes. It is important to understand how the business is being managed and connect to those processes in order to be in a position share information up and down the organizational hierarchy.
  5. Define risk. The traditional definition of risk denotes a hazard or a failure of some process. Make sure you organization understands that risk is merely uncertainty that can have both a positive or negative impact on objectives. It is ok to take on risk.
  6. Give credit. Different functions already have risk management capabilities and processes. Rather than reinvent the wheel, harvest the data and expertise already out there and build off that. Don’t build unnecessary steps into the process when those areas are already being addressed.
  7. Remember that risk is a four-letter word. Risk is an overused, ambiguous word with an often negative connotation. Risks are nothing more than variables that can present opportunities for greater success.
  8. Beware of risk categories. Labels like operational, financial, strategic or technology are overemphasized and not how business units think of risk. It is more effective to talk about risk in terms of management of hazards, compliance obligations or other uncertainties.
  9. Do your research. It is vital to develop a thorough understanding of the business and its drivers, from its capabilities to its competitive advantages to its strategic priorities and objectives.
  10. Simplify risk appetite. Risk appetite should be considered on a risk-by-risk basis and should boil down to a simple question of once risk controls and processes are in place, are you satisfied with the results?

ERM implementation can be challenging. But according to Zawoyski, it is all about keeping it simple for the stakeholders, ensuring that value is created, aligning to the business and evolving over time. By approaching your program in this way, all stakeholders will understand their role and how ERM relates to the overall strategy of the organization.