Anthony Fitzsimmons recently sent me a review copy of his new book, Rethinking Reputation Risk. He says that it “Provides a new perspective on the true nature of reputational risk and damage to organizations and traces its root causes in individual and collective human behavior”.
I am not sure that there is much that is new in the book, but if you want to understand how human behavior can be the root cause (in fact, it is very often the root cause) of problems for any organization, you may find it of interest.
The authors (Fitsimmons and Professor Derek Atkins) describe several case studies where human failures led to serious issues.
Humans as a root cause is also a topic I cover in World-Class Risk Management.
As I was reading the book, I realized that I have a problem with organizations placing separate attention to reputation risk and its management. It’s simply an element, which should not be overlooked, in how any organization manages risk – or, I should say, how it considers what might happen in its decision-making activities.
The same thing applies to cyber risk and even compliance risk.
They are all dominoes.
A case study:
- There is a possibility that the manager in HR that recruits IT specialists leaves.
- The position is open for three months before an individual is hired.
- An open position for an IT specialist who is responsible for patching a number of systems is not filled for three months.
- A system vulnerability remains open because there is nobody to apply a vendor’s patch.
- A hacker obtains entry. CYBER RISK
- The hacker steals personal information on thousands of customers.
- The information is posted on the Internet.
- Customers are alarmed. REPUTATION RISK
- Sales drop.
- The company fails to meet analyst expectations for earnings.
- The price for the company’s shares drop 20%.
- The CEO decides to slash budgets and headcounts by 10% across the board.
- Individuals in Quality are laid off.
- Materials are not thoroughly inspected.
- Defective materials are used in production.
- Scrap rates rise, but not all defective products are detected and some are shipped to customers.
- Customers complain, return products and demand compensation. REPUTATION RISK
- Sales drop, earnings targets are missed again, and …….
- At the same time as the Quality staff is downsized, the capital expenditure budget is cut.
- The Information Security Officer’s request for analytics to detect hackers who breach the company’s defenses is turned down.
- Multiple breaches are not detected. CYBER RISK
- Hackers steal the company’s trade secrets.
- Competitors acquire the trade secrets and are able to erode any edge the company may have.
- The company’s REPUTATION for a technology edge disappears. REPUTATION RISK
- Sales drop. Earnings targets are not achieved, and……..
It is true that every domino and the source of risk to its stability (what might happen) needs to be addressed.
But, focusing on one or two dominoes in the chain is unlikely to prevent serious issues.
One decision at a low level in the company can have a domino effect.
I welcome your comments.
This is the time of year when people are rushing to share the top risks to organizations across the world.
Those lists include such items as cyber, political change, economic instability, and so on.
Here’s a different type of list.
It’s comprised of risks that are perhaps the most critical but, for whatever reason, rarely figure on any risk register (those awful devices) or other ERM report.
They are not in any particular order.
- Bad decisions, for any number of reasons such as involving the wrong people; relying on gut experience instead of information; failing to act; and so on
- Poor information flowing to decision-makers and the board (it may be out-of-date, slow, incomplete, indigestible, wrong, or simply off the mark)
- Hiring the wrong people
- Not having sufficient people
- Lack of teamwork
- Lack of shared goals
- Legacy systems that make the organization lack agility
- Bureaucracy that slows decisions and stifles ingenuity and innovation
- A bully of a CEO
- Executives who don’t listen
- Poor morale
- High turnover of staff
- Failing to fire poor customers
- Ignorance of new technology that could disrupt the business
- Being excessively risk averse
- An ineffective internal audit function
- An ineffective risk management function
- A legal function that does not provide quality advice when it is needed
- A CFO who does not get involved in the business and its operations
- And so many more
I welcome your thoughts – and additions of risks that are too often overlooked, usually for political reasons.
HAPPY NEW YEAR!
My apologies in advance to all those who talk about third-party risk, IT risk, cyber risk, and so on.
We don’t, or shouldn’t, address risk for its own sake. That’s what we are doing when we talk about these risk silos.
We should address risk because of its potential effect on the achievement of enterprise objectives.
Think about a tree.
In root cause analysis, we are taught that in order to understand the true cause of a problem, we need to do more than look at the symptoms (such as discoloration of the leaves or flaking of the bark on the trunk of the tree). We need to ask the question “why” multiple times to get to the true root cause.
Unless the root cause is addressed, the malaise will continue.
In a similar fashion, most risk practitioners and auditors (both internal and external) talk about risk at the individual root level.
Talking about cyber, or third party risk, is talking about a problem at an individual root level.
What we need to do is sit back and think about the potential effect of a root level issue on the overall health of the tree.
If we find issues at the root level, such as the potential for a breach that results in a prolonged systems outage or a failure by a third party service provider, what does that mean for the health of the tree?
Now let’s extend the metaphor one more step.
This is a fruit tree in an orchard owned and operated by a fruit farmer.
If a problem is found with one tree, is there a problem with multiple trees?
How will this problem, even if limited to a single tree or branch of a single tree, affect the overall health of the business?
Will the owner of the orchard be able to achieve his or her business objectives?
Multiple issues at the root level (i.e., sources of risk) need to be considered when the orchard owner is making strategic decisions such as when to feed the trees and when to harvest the fruit.
Considering, reporting, and “managing” risk at the root level is disconnected from running the business and achieving enterprise objectives.
I remind you of the concepts in A revolution in risk management.
Use the information about root level risk to help management understand how likely and to what extent it is that each enterprise business objective will be achieved.
Is the anticipated level of achievement acceptable?
I welcome your thoughts.
I have been a proponent and supporter of the OCEG view and definition of GRC for a very long time. In fact, OCEG honored me for my GRC thought leadership by making me one of the first OCEG Fellows (along with my friends, Michael Rasmussen and Brian Barnier).
I remain an advocate of their definition of GRC as well as their focus on Principled Performance.
Very recently, OCEG leadership published a maturity model for GRC (developed by RSA Archer, which has been an active member and sponsor of OCEG for as long as I can remember). You can download it (and become a member for free, which I heartily encourage) from the OCEG web site.
This paragraph from the Introduction to the paper explains both GRC and Principled Performance.
As the think tank that defined the business concept of GRC, OCEG has long talked about the need for a harmonized set of capabilities that enable an organization to reliably achieve its objectives, while addressing uncertainty and acting with integrity. These capabilities are outlined in the GRC Capability Model (“the OCEG Red Book”), the publicly vetted, free and open source standards for GRC planning and execution. The outcome of applying effective GRC is Principled Performance, which demands a mature, integrative approach to governance, risk management and compliance; the component parts of GRC.
GRC is defined by OCEG, repeated in the section above, as “a harmonized set of capabilities that enable an organization to reliably achieve its objectives, while addressing uncertainty and acting with integrity.”
What I like about their definition is:
- It focuses on achieving objectives and delivering value to stakeholders, not just avoiding harm and remaining in compliance. Risk is managed, not for its own sake, but to help drive performance.
- It describes a capability that is more than the sum of its parts. It is more than governance, which includes not only the operation of the board but those of the legal department, internal audit, the strategic planning function, performance management, investor relations, and more; it is more than simply risk management, because it requires that the consideration of risk be part of the rhythm of the business (credit to EY for that expression) as decisions are made and strategy not only developed but executed; and, it is more than compliance: in fact, the OCEG definition includes not only compliance with applicable laws and regulations (what they call a ‘mandated boundary’) but with societal norms and the values of the enterprise (a ‘voluntary boundary’).
- It emphasizes the need for harmony between all the various elements of the organization if they are to drive towards and achieve shared goals for the enterprise.
This section from OCEG’s Red Book (version 2.0) builds on the short definition above. It says that GRC is:
“A system of people, processes and technology that enables an organization to:
- Understand and prioritize stakeholder expectations
- Set business objectives that are congruent with values and risks
- Achieve objectives while optimizing risk profile and protecting value
- Operate within legal, contractual, internal, social and ethical boundaries
- Provide relevant, reliable and timely information to appropriate stakeholders
- Enable the measurement of the performance and effectiveness of the system”
The question for me as I review the maturity model is whether it truly describes a GRC capability.
I believe it is a valuable piece of work, but only if you are concerned about the R and the C.
I am afraid that the authors, who are friends as well as colleagues, have fallen into the trap I started talking about more than 6 years ago.
The ‘G’ in GRC is silent.
Where is there mention of everybody, from the board down to the shop floor worker, working to shared objectives? If enterprise objectives are not just set and approved by the board and top management, but cascaded down and across the enterprise with all performance incentives fully aligned, how can we expect the right risks to be taken and value delivered?
Don’t expect harmony when people do not see the songsheet.
Where is there mention of effective decision-making? Both the ISO and COSO risk guidance is moving towards an emphasis on intelligent and informed decision-making. But, I don’t see that here.
Where is the integration of performance management and risk management? Sadly, it is not here either.
This is a fine document for risk and compliance maturity. But is it a maturity model for GRC?
Hopefully, there will be a version 2.0 of the model where the G is not silent, where it is in fact dominant.
I welcome your views.
 OCEG, the Open Compliance and Ethics Group, is a not-for-profit think tank that focuses on Principled Performance and GRC. It has a wonderful website at www.oceg.org with many valuable resources for members. Membership is free for individuals.
 I like the OECD definition of governance: “A set of relationships between a company’s management, its board, its shareholders and other stakeholder. Corporate governance also provides the structure through which the objectives of the company are set, and the means of attaining those objectives and monitoring performance are determined.”
Overall, I am pleased to see the progress the internal audit practice has made over the last few years. While there are still serious problems regarding independence and resources in some parts of the world (where internal audit is established only to “check-the-box, not with any intent to be a serious activity), more and more organizations are moving to what I call “enterprise risk-based” auditing; perhaps half are providing assurance through formal audits and assessments of the management of risk; and, many are focusing on identifying problems before rather than after the occur has become a recurring mantra.
Yet, the picture is not entirely rosy.
This year, I have been privileged to work with the National Association of Corporate Directors. I was a panelist at three separate events where they discussed cyber risk.
In one group session, a director said that the board could not ask internal audit to assess and help with cyber risk because they lacked that capability. The others voiced their agreement, one and all.
This is a huge problem!
Internal audit may not always have the talent on staff to address every risk or concern, but if the board would only give it the resources, internal audit can either hire that staff or outsource the task.
As a chief audit executive, I have hired specialists to address specific risks in IT (including highly technical personnel), environmental compliance, engineering, fraud investigations, and more. Where possible, I have provided staff (including myself) training in specialized areas, such as derivatives trading, Six Sigma, and Lean Manufacturing.
I also used outside resources from consulting and personnel agencies:
- A derivatives trading and management specialist
- A “white hat” penetration testing team
- A former global procurement executive
- An expert in sales contracting and management
- A corporate tax specialist
- and more
Some talk about internal audit being the “consultant of choice”. I wouldn’t go that far. Where I would go is that internal audit should have the capability, whether through its own personnel, co-sourcing, or other contract staffing, to address and provide assurance on the key risks facing the enterprise.
Internal audit should:
- Inform the audit committee when it has insufficient resources to address a specialized area of risk, and endeavor to persuade them to provide such additional resources (headcount or dollars) to address the need
- Inform the audit committee that it has the capability to obtain the necessary resources to address specialized areas such as cyber security, ethics compliance, corporate culture, corporate governance and more. This means that the CAE needs to build a network that he/she can tap to locate and hire the necessary expertise
- Challenge management and even the audit committee when either goes outside to obtain assurance on an area of risk
I welcome your comments.
One of the readers of my work sent me this message.
I was reading your article about modern risk based audit [link added] published in the IIA journal. I find the approach very interesting.
In developing my plan I used to do the traditional risk assessment by identifying the audit universe then prioritizing entities based on risk. In your suggested approach, an auditor should start from the company strategy and objectives, identify the risks that jeopardize these objectives (this could be done through risk management) then audit controls related to those risks.
I had a discussion about that approach 4 months back and I got a lot of opposition from CAEs who audit banks. Their opinion is that they have to audit the big branches every year. I would really appreciate your opinion on that as, for some industries, it seems that covering the audit universe is as important as starting from the risks to objectives (such as expansion in a certain country).
I have seen a lot of CAEs surrender to the old approach simply because they are not politically strong to raise big strategic alarms to their board audit committees and senior management.
Apologies for reaching out to you this way, but I’m very passionate about what I do and I would like to learn and implement new good ideas such as the one suggested by you in the IIA journal.
I will start working on my annual plan now changing the lens to start from the risks on objectives and not from the audit universe. I appreciate the opportunity to be able to reach out for you if I had a difficulty in implementing this?
I enjoy the opportunity to mentor others and to evangelize internal auditing, so I replied straight away.
I used to be in internal audit at a bank, in ancient history, and understand the perspective. The idea is that the larger branches are a significant source of risk. I don’t quarrel with that, but how much work do you need to do there – that’s the key question! Do you look at every risk that is significant to the branch, or only those that are significant (in aggregate) to the bank as a whole?
The risk (pun intended) is that by focusing on details at the branch level you miss the big picture. I write about this in my internal audit book. At Solectron, we had about 120 factories (sites) and margins were so small that a serious issue at any one site could be significant to the business as a whole. My predecessor had an audit plan that spent 90% of the time auditing the sites.
Soon after I took over as CAE, I went over to my IT auditor who, like the rest of the team, was preparing for the next site audit. I asked what he was working on – perhaps looking at some analytics to improve his understanding of the business before he arrived. No. He was starting to draft the audit report! He told me that he found the same issues at every site, so he knew in advance what he would find at the next one!
I asked what corrective actions came from his findings and he explained that local management would upgrade the security, etc.
But, when I asked whether he or the former CAE had thought about whether this pervasive problem should be escalated to corporate and the office of the CIO, he said “no”. No audit had been performed of corporate IT, even the corporate IT security function.
Down in the weeds, missing the big picture.
I changed the approach to the one I discuss in my writing. We looked at the business risks to the enterprise should IT fail in some fashion. That led us to audit the way in which the company approached IT security, the leadership and capabilities of the corporate IT function, and so on.
Recently, Paul Sobel and I were on an OCEG webinar and talked about the topic of my book, world-class internal auditing. One of the survey questions asked whether those listening based their audit plans on risks at the location level or at the enterprise level. Unfortunately, the great majority used the ‘old’ approach, but we were heartened to hear that they intended to move to the ‘newer’ enterprise-risk based approach.
Where are you now and are you changing?
What should be audited at each location or within each business process? The risk to the process or the risk to the enterprise?
By the way, look at a related post on the IIA blog (it will appear this week) where a board member says that most internal audit ‘findings’ are mundane. I believe that is due, in part, to auditors being focused on risks in the weeds rather than to the enterprise.
It’s not that long since we were dismissing the Internet of Things as something very much ‘next generation’. But, as you will see from Deloitte’s collection of articles (Deloitte Review Issue 17), many organizations are already starting to deploy related technologies. I also like Wired magazine’s older piece.
Have a look at this article in the New York Times that provided some consumer-related examples. Texas Instruments has a web page with a broader view, mentioning building and home automation; smart cities; smart manufacturing; wearables; healthcare; and automotive. Talking of the latter, AT&T is connecting a host of new cars to the Internet through in-auto WiFi.
At the same time, technology referred to as Machine Learning (see this from the founder of Sun Microsystems) will be putting many jobs at risk, including analysis and decision-making (also see this article in The Atlantic). If that is not enough, the IMF has weighed in on the topic with a piece called Toil and Technology.
Is your organization open to the possibilities – the new universe of potential products and services, efficiencies in operations, and insights into the market? Or do you wait and follow the market leader, running the risk of being left in their dust?
Do you have the capabilities to understand and assess the risks as well as the opportunities?
Do your strategic planning and risk management processes allow you to identify, assess and evaluate all the effects of what might be around the corner? Or do you have one group of people assessing potential opportunity and another, totally separate, assessing downside risk?
How can isolated opportunity and downside risk processes get you where you need to go, making intelligent decisions and optimizing outcomes?
When you are looking forward, whether at the horizon or just a few feet in front of you, several situations and events are possible and each has a combination of positive and negative effects.
Intelligent decision-making means understanding all these possibilities and considering them together before making an informed decision. It is not sufficient to simply net off the positive and negative, as (a) they may occur at different times, and (b) their effects may be felt in different ways, such as a potentially positive effect on profits, but a negative potential effect on cash flow and liquidity; the negative effect may be outside acceptable ranges.
With these new technologies disrupting our world, every organization needs to question whether it has the capability to evaluate them and determine how and when to start deploying them.
COSO ERM and ISO 31000 are under review and updates are expected in the next year or so. I hope that they both move towards providing guidance on risk-intelligent and informed decision-making where all the potential effects of uncertainty are considered, rather than guiding us on the silo of risk management.
Are you ready?
I welcome your comments.
For more on this and related topics, please consider World-Class Risk Management.