High Performance Risk Management

LOS ANGELES—Risk managers, whose job once focused on a basic “bucket of risks,” and making decisions about which risks are transferable and which ones the company should retain, have been “migrating along an evolutionary path which is allowing us to be more strategic,” said Chris Mandel, senior vice president of strategic solutions at Sedgwick, at the RIMS ERM Conference 2017.

During the session “The Trouble with ERM,” he noted that risk managers now need to alter their focus. “The question for risk managers now is, how do we get our organizations to focus on long-term success and recognize the link between strategy and risk?” he said.

Erin Sedor, president at Black Fox Strategy, said that personal experience taught her the importance of connecting with the CEO and aligning with the company’s strategy when setting up a program. “You need to know what they are talking about and understand strategy,” she said.

Unable to find a satisfactory definition of strategy for ERM, Sedor came up with her own: “A strategic business discipline that allows an organization to manage risks and seize opportunities related to the achievement of its objectives.” She added that, unfortunately, enterprise risk is not a term that resonates with the C-suite, but strategy is.

She identified three major problems with ERM that can dampen its prospects:

  1. A limited view of the organization’s mission, growth and survival.
  2. Silos. Breaking through them is a nonstop process, no matter how a company tries to improve the situation—especially in the areas of risk management, continuity planning and strategy, which typically happen in very different parts of the company. “It is important to link risk management and continuity planning in the strategic planning process, because that will get some attention and get the program where it needs to be,” she said.
  3. Size. Because ERM programs are notoriously huge, she said, “the thought is that ERM will cost too much money, take too many resources and take too long to implement. And that by the time it’s finished, everything will have changed anyway.”

Starting the process by “saying you’re going to focus on mission-critical,” however, can help get the conversation moving. “Because as you focus on that, the lines between risk management, continuity planning and strategic planning begin to blur,” she said.

Sedor described mission-critical as any activity, asset, resource, service or system that materially impacts (positively or negatively) the organization’s ability to successfully achieve its strategic goals and objectives.

She said to find out what mission-critical means to the organization, what is the company’s appetite and tolerance for mission-critical, and the impacts of mission-critical exposures on the organization. “Risk managers will often ask this question first, but you have to come to grips with the fact that not every risk is a mission-critical risk,” she said. “And not everything in a risk management program is mission-critical.” Using that context helps in gaining perspective, she added.

When viewing risk management, continuity planning and strategic planning from a traditional perspective, strategic planning is about capturing opportunity and mitigating threats; risk management is the identification, assessment and mitigation of risk; and business continuity planning is about planning for and mitigating catastrophic threats.

Looking at them from a different vantage, however, strategic planning is planning for growth; risk management allows you to eliminate weaknesses that will impede growth, which is why it’s important; and continuity planning will identify and mitigate the threats that impact sustainability. “That is how they work together,” she said, adding, “you are also looking at weaknesses that, when coupled with a threat, will take you out. Those are your high-priority weaknesses. Using a mission-critical context makes it all manageable.”

At this point, if a risk manager can gain enough leverage to talk to executives throughout the organization about what mission-critical means to the company, its impact, and then about tolerances and creating a more integrated program, “all of a sudden, you’ve talked about ERM and they didn’t even know it,” she said. “They thought you were talking about strategy.”

In a Changing World, Questions For the CRO

Before the financial crisis in 2008-2009, many businesses didn’t think of risk as something to be proactively managed. After the crisis, however, that paradigm shifted. Companies began perceiving risk management as a way to protect both their reputations and their stakeholders.

Today, risk management is not just recommended, it is considered crucial to successful operations and is required by federal and state law. The SEC’s Proxy Disclosure Enhancements, enacted in 2010, mandate that organizations provide information regarding board leadership structure and the company’s risk management practices. Company leadership is required to have a direct role in risk oversight, and any risk management ineffectiveness must be disclosed.

The CRO’s role

Volatility in the current business environment—a confluence of factors including transfers of power, the world economy and individual markets—is nothing new. Political transitions have always been accompanied by new agendas and shifting regulations, economies have always experienced bull and bear markets, and the evolution of technology constantly changes our processes.

Even so, recent events like Brexit, the uncertainty of a new administration’s regulatory initiatives, and thousands of annual data breaches have contributed to an unprecedented atmosphere of fear and doubt. To navigate this environment, the chief risk officer needs to adopt a proactive risk management approach. Enterprise-wide risk assessments grant the visibility and insight needed to present an accurate picture of the company’s greatest risks. This visibility is what the board needs to safely recognize opportunity for innovation and expansion into new markets.

To grow a business safely—by innovating and adding to products/services and expanding into new markets—risk professionals should not focus on identifying risk by individual country. This approach naturally leads to a prioritization of “large-dollar” countries, which aren’t necessarily correlated with greater risk. Countries that contribute a small percentage of overall revenue can still cause major, systemic risk management failures and scandals.

A better approach is to look at risk across certain regions; how might expanding the business into Europe, for example, create new challenges for senior management? Are there sufficient controls in place to mitigate the risks that have been identified?

When regional risks are aggregated to create a holistic picture, it becomes possible for the board to make sure expansion efforts are aligned with strategic goals.

Three processes that require ERM

Risk management is an objective process, and best practices, such as pushing risk assessments down to front-line process owners who are closest to operational risk, should be adhered to regardless of the current state of the international business arena.

While today’s political climate has generated a significant amount of media strife, it’s important not to let emotion influence decision-making. By providing the host organization with a standardized framework and centralized data location, enterprise risk management enables managers to apply the same basic approach across departments and levels.

This is particularly important when an organization expands internationally, which involves compliance with new sets of regulations and staying competitive. Performing due diligence on an ad hoc basis is neither effective nor sustainable. Instead, the process should follow the same best-practice process as domestic risk management efforts:

  1. Identify and assess. Make risk assessments a standard part of every budget, project or initiative. This involves front-line risk assessments from subject matter experts, revealing key risks and processes/departments likely to be affected by those risks. For example, financial scrutiny is no longer a concern just for banks. Increased attempts to fight terrorism mean transactions of all kinds are becoming subject to more review. Anti-bribery and anti-corruption processes estimate and quantify both vulnerability and liability.
  2. Mitigate key risks. Connect mitigation activities to the resources they depend on and the processes they’re associated with. ERM creates transparency into this information, eliminating inefficiency associated with updating/tracking risks managed by another department. Control evaluation is the most expensive part of operations. Use risk management to prioritize this work and reduce expenses and liability.
  3. Monitor the effectiveness of controls with tests, metrics, and incident collection for risks and controls alike. This ensures performance standards are maintained as operations and the business environment evolve. Evidence of an effective control environment prevents penalties and lawsuits for negligence. The bar for negligence is getting lower; technology is pulling the curtain back not only internally but (through social media and news) to the public as well.

Lastly, the CRO role is increasingly accountable for failures in managing risk along with other senior leaders and boards—look no further than Wells Fargo.

Laremy Tunsil’s Social Media Controversy Highlights NFL Draft Risks

shutterstock_212182807Last night was the first round of the 2016 NFL Draft and the lead story was that of Laremy Tunsil. By many scouts’ accounts he was one of the most talented prospects in the draft and was expected to be chosen in the top five or six. Instead, Tunsil tumbled all the way to number 13 after an untimely video was posted to his Twitter account depicting him smoking marijuana through a gas mask. The tweet was quickly deleted but not before creating a snowball effect that will likely cost Tunsil approximately $8 million in lost contract value, as estimated by Forbes based on the NFL’s Salary Cap and Rookie Compensation Pool (a player chosen at #6 would be expected to receive a contract of $20.4 million, while the 13th pick would receive an estimated $12.4 million).

If you watched the first round coverage last night, the term “risk management” was thrown around generously by commentators. In many cases, NFL draft prospects are investments worth many millions of dollars. But with each investment comes questions of risk versus return. The Miami Dolphins, who selected Tunsil, made a decision last night that the investment of approximately $12 million dollars mitigated the risks posed by a player who could have drug related issues that could violate NFL player conduct rules. Moving forward, the Dolphins will have to consider the following risks:

  • Organizational Risk: In addition to the marijuana video, Tunsil admitted to what amounts to violating NCAA rules while in college, which will certainly result in disciplinary actions against his alma mater. The Dolphins still have to sign Laremy Tunsil and now have to determine if they can expect a positive return from a player who demonstrates the potential to weaken an entire institution.
  • Reputational risk: Will there be a backlash from the fan base for drafting someone who clearly demonstrates serious lapses in judgement? Remember, these players are not just investments in terms of their performance, but in the revenue and public relations image they create for their respective team. As has been demonstrated in the past with other NFL teams, reputational risk is not just an external factor but an internal one at that that can affect team’s performance on the field.
  • Social media risk: Laremy Tunsil’s agent claims that his client’s social media accounts were hacked. Regardless of whether or not that is true, the damage has been done. But what prevents any of his accounts from being hacked in the future? Will this inspire other potential black hats to hack athlete’s social media accounts? Can the Dolphins impose a social media blackout on its entire franchise? The Dolphins will need to consider what social media risks Laremy Tunsil may pose to the franchise’s image moving forward.

Overall, if Tunsil is as talented as he is expected to be, then the risk of selecting him will likely be worth the reward. Right now, the Miami Dolphins have made a decision that their potential investment of $12 million dollars will benefit the team in the future. Let’s hope for their sake that they have a risk management program in place that will give as much consideration to the risks listed above as they presumably give to winning a Super Bowl title.

Internal Audit Role Expanding Further into Risk Areas

With more companies focusing on enterprise risk management and strategic risk, the role of internal auditors is being expanded to include risk identification and risk management, a study by the Institute of Internal Auditors (IIA) and Protiviti has found.

According to Relationships and Risk, Insights from Stakeholders in North America, the top three areas where respondents wish to expand the role of internal audit involve identifying and managing risk. Of 433 North American stakeholders surveyed, 85% said they want internal audit involved in identifying known and emerging risk areas; 78% would like to see internal audit facilitating and monitoring effective risk management practices by operational management; and 78% want audit to identify appropriate risk management frameworks, practices and processes.
IIA 2

The survey also found that 58% of stakeholders believe internal audit should be more active in assessing strategic risk.
IIA 1

When asked to choose the best avenues for internal audit to improve its role in responding to the organization’s strategic risks, stakeholders said:

  • Internal audit should focus on strategic risks as well as operational, financial, and compliance risks during audit projects.
  • Internal audit should periodically evaluate and communicate key risks to the board and executive management.

The report concluded that chief audit executives (CAEs) should consider methods to meet and surpass the needs and expectations of their stakeholders, including:

  • Focusing on risk activities—risk identification and management—when performing advisory services.
  • Demonstrating an understanding of strategic risks in all audit work. Educating stakeholders on ways you can give attention to nontraditional strategic risks.
  • Building soft skills. Communication and relationship building are needed to set priorities when there are competing expectations.