whitepaper © risk decisions 2011 The first step to ERM: What risk managers need to know to establish an Enterprise Risk Structure by Val Jonas CEO Risk Decisions Group www.riskdecisions.com management solutions Val Jonas: The first step to ERM: whitepaper The first step to ERM: What risk managers need to know to establish an Enterprise Risk Structure Executive Summary "At companies that have a formal ERM program -- by no means a majority – ERM is generally in a nascent stage. We believe that ERM eventually will not be a distinct discipline because it will become integrated with everyday practice. At some point, risk management may be likewise part of every senior executive's repertoire of skills." Standard & Poors Credit FAQ: Standard & Poor's Looks Further Into How Nonfinancial Companies Manage Risk June 24, 2010 Most organisations aspire to practise effective Enterprise Risk Management (ERM), but very few are achieving it. Over the last decade, much effort has gone into implementing systems to comply with Sarbanes Oxley, COSO, Turnbull, Basel II, COBIT and other regulatory standards. Most organisations are now stuck in a world of compliance-oriented risk management. They are therefore failing to take advantage of the benefits gained from a more strategic approach to risk. Figure 1: The five steps to ERM This first step is not costly or time consuming; it just requires simple and practical steps to get the right people involved in ERM. Putting ERM in place delivers significant benefits: • Accurate business planning and objective setting 1. Enterprise risk documentation: framework, policy and process • Enhanced reputation and credit rating • Better decision making: It is the board’s role, as part of its corporate governance, transparency and disclosure responsibilities, to maintain a framework, policy and process for managing risk. • Use of capital • Negotiating key contracts However, for management of risk to be effective, it is important that everyone in the organisation understands their role in managing risk. To achieve this, the risk manager needs to ensure that three key documents are in place and communicated across their organisation: a risk framework; a risk policy; and a risk process. • Supply chain management • Product demand and development • Improved performance and shareholder value • Reduced cost of insuring risk • A sound platform for corporate governance. Our “Five Steps to Enterprise Risk Management” whitepaper, published in December 2010 gives an overview of how organisations can address this shortfall, providing insights for the Chief Risk Officer, based on Risk Decisions experience of helping organisations implement ERM. This new whitepaper “The First Step to Enterprise Risk Management” is the first in a series of five that builds on this overview to give risk managers insights into how to start embedding ERM into their organisation. This whitepaper describes the three most important documents required to achieve effective ERM. It also stresses the importance of understanding risk attitude and accommodating different perspectives of risk across the enterprise. Finally, it considers the risk structure required to provide a consolidated view of risk at different levels in the organisation. 2 Figure 2: Enterprise risk documentation www.riskdecisions.com © risk decisions 2011 whitepaper Val Jonas: The first step to ERM: Risk framework – getting people involved This document sets out for everyone in the organisation how the management of risk (threats and opportunities) maps onto the organisation’s structure. Remember, it’s important to understand your senior management’s information requirements, and ensure that your risk process(es) can deliver these. 2. Understanding enterprise risk attitude It includes information on: Of the three documents outlined in section 1, the policy document is likely to be the most difficult one in which to align aspiration with reality. This makes it important that all employees understand what management of risk actually means to your organisation. • Who is responsible for different types of risk (e.g. strategic, financial, safety), • The wider stakeholder community’s involvement. (e.g. contractors and suppliers) For example: • Objectives and expected outcomes Essentially, the risk framework is about getting people engaged in the management of risk. Risk policy – defining thresholds Senior management is responsible for ensuring that their organisation behaves in a pre-determined and measured way when faced with significant threats or opportunities. One way to achieve this is through setting the risk policy. In which risk managers clarify their organisation’s vision and therefore how risk taking or risk averse they are willing for the organisation to be. In the risk policy document risk managers give guidance on: • What level of risk taking is acceptable • For more on this see Section 2: Understanding risk attitude • Which risks owners should escalate to senior management, and when • Budgetary sign off for risk and mitigation actions • Risk approval levels (e.g. for business cases). In keeping with existing company policy you may find it appropriate to align risk budget sign-off thresholds with general budget sign-off (i.e. delegated powers). Risk process – communicating consistently The risk process is a statement on how you want your organisation to identify, manage, mitigate, report, and otherwise communicate risks consistently across the organisation. a) A high tech company A high tech company may pride itself on being innovative and therefore seek opportunities and take risks, with a view to maximising reward. Top down, managers will tend to encourage employees to think out of the box in an environment free of excessive control. To balance this, management are likely to develop close working relationships with key employees and have communication mechanisms that allow fast decision making. In this scenario, it is vital to properly understand and take measured risks. b) A long established business In contrast, a long established business relying on its trustworthy reputation for repeat business and referrals may take a risk averse attitude. The organisation will expect employees to follow strict codes of conduct: avoid deviating from procedure, and maintain the status quo. However, it needs to guard against becoming introverted and overtaken by external events. Risk management can address this. Of course, most organisations take a position somewhere between risk taking and risk averse extremes, adopting a portfolio approach to balance investment, innovation and core business. Whatever position your organisation takes, it is essential that it consciously understands its risk attitude, measures the risk and makes sound decisions on the basis of good information. It may be useful to get some external help in assessing this. You may think you are risk averse, but actually are avoiding facing up to risk, which in turn can be extremely risky. Identifying a suitable process for your organisation is generally the most straightforward of these three steps, as there are many well established standards to choose from. This includes the recently published ISO:31000 international risk management standard. It is up to you to decide which best suits your organisation. See Appendix 1 for a selection of those available. Whichever process you select you will often need to adapt it to reflect your organisation’s specific requirements or existing working practices. Bear in mind too that these needs may differ across different divisions, business units, functions etc. See Section 4 for more on accommodating multiple perspectives on risks. You may also have certain areas (e.g. safety, environmental) that require specialised risk procedures – we suggest that you either document these separately or add them as appendices to the main risk process. Figure 3: Balancing risk and reward © risk decisions 2011 www.riskdecisions.com 3 Val Jonas: The first step to ERM: whitepaper Some organisations find it useful to form a Risk Committee – although take care to consider the benefits and barriers of this approach. It is generally better to integrate risk into all board activities as opposed to making it a separate exercise. However, the complexity of risk in some organisations (e.g. financial institutions) may require this specialist committee approach. Functional-level Risk Steering Group For ERM to work effectively, communication about risk must flow in all directions in your organisation, so the most efficient way to implement communication of risk information is to focus on middle managers, and in particular the functions. Each function is responsible for oversight of their discipline across the organisation, and therefore it makes sense for them also to be responsible for overseeing risk. However, clarifying responsibility for risk at this level is not enough: using risk management to break down the traditional functional stove pipes gains the most benefit. Creating a function-led Risk Steering Group can be an effective way to achieve this. A significant number of an organisation’s risks occur in one area of the business and impact in another, so the benefit of bringing managers together to work as a team on managing risk is a major step forward. Figure 4: Vertical & horizontal Enterprise Risk Management Risk Champions 3. Embedding risk into the corporate structure Having documented your risk management framework, policy and process, (including a definition of risk attitude), you then need a practical strategy for implementing and embedding them across the enterprise. The organisation’s risk manager is likely to have responsibility for this strategy. This requires a major change programme, taking a threepronged approach: • Top down from “board level risk representatives” including input from non-executive board members • Middle out via a “risk steering group” (comprising function, business unit and programme managers) • Bottom up from existing pockets of good practice via “risk champions”. Board-level Risk Representatives Your organisation will take the lead on what people do from the top down. Therefore, you need to ensure that each member of the board takes a specific interest in risk. It is a good idea to map each board member to a relevant organisational risk perspective, according to their skills, experience, interests and expertise. Forming a comprehensive set of board level ‘Risk Representatives’, covering all the organisation’s perspectives on risk, provides a natural way of hooking into risk and opportunity activities further down the company. For example, an oil company will require specific focus on safety and the environment, whereas a technology company may have a particular focus on market competitors. All organisations will have finance and HR perspectives. See section 4 for more information on multiple risk perspectives. 4 There will already be pockets of good risk management in your organisation, which you should encourage and reward to demonstrate that the organisation values risk management activities. One of the ways to do this is to identify and recognise risk champions and task them with the job of helping to spread good risk management practice more widely. However, it is important to understand the issues with ‘not invented here’ and ‘but we’re different’ attitudes often found in large organisations. Each area of the business should be encouraged to adopt their own take on the management of risk, subject to remaining within the defined framework, policy and overarching process. See Section 4 for more information on multiple risk perspectives. Having identified these three key groups, the final step is to generate lines of communication between them, whereby board representatives can gain a deeper insight into specific risks through dialogue with relevant members of the functional Risk Steering Group Figure 5: Risk and decision making: lines of communication www.riskdecisions.com © risk decisions 2011 whitepaper Val Jonas: The first step to ERM: of specialist risk champions. Similarly, risk champions can sound out higher level opinions on areas and types of risk that they believe should be gaining more management attention. The role of the Chief Risk Officer (CRO) and Internal Audit The CRO and the internal audit team play a key role in facilitating communication and understanding between these different levels of risk management. They will play a practical role in meetings and help ensure that appropriate lines of communication are in place. Instead, you need a number of ways to slice and dice data, by discipline, budgetary authority, contracting mechanism, geographical location, technology and so on. So therefore, rather than create a single hierarchy, a more effective approach is to create a number of hierarchies containing risk information. Combined with this multi-hierarchy structure, you also need a simple risk map (covered in a later white paper), to ensure risk information is communicated horizontally and vertically and reported at the right levels. Finally, you will need a central repository for risk information. The current practice of trying to consolidate a myriad of spreadsheetbased risk registers cannot deliver efficient ERM: 4. Accommodating multiple risk perspectives In the same way that risk attitude varies from one organisation to another, so perspectives differ within each organisation. This is easiest to understand when you consider different functions or disciplines. For instance: • They do not provide an audit trail • Considerable effort is required to produce a consolidated view for reporting and analysis • Spreadsheets do not give multiple users concurrent access. • IT departments will be concerned with risks relating to data protection and e-security, cyber crime, virus protection and so on; so they may follow the COBIT guidelines as part of their working practices. • Safety, Health and Environment’s risk focus will include hazard analysis and prevention, staff training and awareness, risk assessment checklists; they will need to adhere to HSE legislation. There are many tools available on the market, but one of the key criteria when you are selecting a tool is to ensure that it is configurable to match the multiple perspectives in your organisation. 5. Summary • Finance Directors, Heads of Major Projects and Operations Managers will place a different emphasis on risk again. An effective ERM strategy must not only recognise and accommodate all of these disciplines, but more importantly find the right level at which they fit together. Organisations often assume that they can only implement ERM as a single structure, with risks being rolled up from bottom to top, and the CEO sitting at the top of the pyramid, reviewing everything underneath. In fact, there are many different ways to aggregate risk and therefore, a pyramid is unlikely to be best way to gather and report on risk information. Top down governance of risk is the responsibility of the board, setting the vision and direction for the organisation, including the way forward on embedding Enterprise Risk Management. Producing guidance and documentation is the easy bit. Developing and implementing a strategy to roll ERM out across the organisation is the challenge. Establishing top down risk representatives, a middle layer risk steering group and champions within the organisation is one of the fastest ways to move from a tactical fragmented approach to risk management to embedded ERM. While there will be many perspectives on risk, with different capture and reporting requirements, it is important that the basic risk process steps are the same for everyone. When cross-functional groups meet, they need to use a common language. ERM provides central visibility, consistent identification, reporting, communication and aggregation for decision making at all levels. But it also maintains distributed responsibility of management of the risks and response actions. Overall, make sure your organisation’s attitude to risk is well defined from the top and communicated down through the organisation in a practical way. Finally, remember that Enterprise Risk Management should be simple to understand and simple to implement. Keep it simple! Make it effective! Figure 6: Enterprise Risk Structure in the Predict! Hierarchy Tree © risk decisions 2011 www.riskdecisions.com 5 Val Jonas: The first step to ERM: whitepaper Appendix 1: Risk Management Standards ISO:31000: Risk Management – Principles and Guidelines (2009). ISO, ISO/FDIS 31000:2009 AS/NZS 4360:2004 Risk management (2004), SAI Global Ltd, ISBN 0-7337-5904-1 Project Risk Analysis and Management Guide, Second Edition (2006). Association of Project Management, ISBN: 1-903494-12-5 Enterprise Risk Management - Integrated Framework (2004). COSO, AICPA Management of Risk: Guidance for Practitioners Book (2007). Office of Government Commerce, The Stationary Office, ISBN 13: 9780113310388 Practice Standard for Project Risk Management, First Edition, 2009, Project Management Institute 6 www.riskdecisions.com © risk decisions 2011 whitepaper Val Jonas: The first step to ERM: Appendix 2: Glossary Where ‘source’ is in brackets, minor amendments have been incorporated to the original definition. Glossary of Terms Term Budget Definition Source The resource estimate (in £/$s or hours) assigned for the accomplishment of a specific task or group of tasks. Risk Decisions Change Control (Management) Identifying, documenting, approving or rejecting and controlling change. (PMBoK) Control Account A management control point at which actual costs can be accumulated and compared to earned value and budgets (resource plans) for management control purposes. A control account is a natural management point for budget/schedule planning and control since it represents the work assigned to one responsible organisational element on one Work Breakdown Structure (WBS) element. APM EVM guideline Cost Benefit Analysis The comparison of costs before and after taking an action, in order to establish the saving achieved by carrying out that action. Risk Decisions Cost Risk Analysis Assessment and synthesis of the cost risks and/or estimating uncertainties affecting the project to gain an understanding of their individual significance and their combined impact on the project’s objectives, to determine a range of likely outcomes for project cost. (PRAM) Enterprise Risk Management (ERM) The application of risk management across all areas of a business, from contracts, projects, programmes, facilities, assets and plant, to functions, financial, business and corporate risk. Risk Decisions Enterprise Risk Map The structure used to consolidate risk information across the organisation, to identify central responsibility and common response actions, with the aim of improving top down visibility and managing risks more efficiently. Risk Decisions Left shift The practice by which an organisation takes proactive action to mitigate risks when they are identified rather than when they occur with the aim of reducing cost and increase efficiency. Risk Decisions Management Reserve (MR) Management Reserve may be subdivided into: • Specific Risk provision to manage identifiable and specific risks • Non-Specific Risk Provision to manage emergent risks • Issues provision APM EV/Risk Working Group Non-specific Risk Provision The amount of budget / schedule / resources set aside to cover the impact of emergent risks, should they occur. APM EV/Risk working group Operational Risk The different types of risks managed across an organisation, typically excluding financial and corporate risks. Risk Decisions Opportunity An ‘upside’, beneficial Risk Event. PRAM Baseline An approved scope/schedule/budget plan for work, against which execution is compared, to measure and manage performance. (PMBoK) Performance Measurement The objective measurement of progress against the Baseline APM EV/Risk Working Group Proactive Risk Response An action or set of actions to reduce the probability or impact of a threat or increase the probability or impact of an opportunity. If approved they are carried out in advance of the occurrence of the risk. They are funded from the project budget. (PRAM) Reactive Risk Response An action or set of actions to be taken after a risk has occurred in order to reduce or recover from the effect of the threat or to exploit the opportunity. They are funded from Management Reserve. (PRAM) Risk Appetite The amount of risk exposure an organisation is willing to accept in connection with delivering a set of objectives. APM EV/Risk Working Group Risk Event An uncertain event or set of circumstances, that should it or they occur, would have an effect on the achievement of one or more objectives. PRAM Risk Exposure The difference between the total impact of risks should they all occur and the Risk Provision. APM EV/Risk Working Group Risk Management Clusters® Functionality in Risk Decisions’ Predict! risk management software that enables users to organise different groups of risks to form a single, enterprise-wide risk map. Risk Decisions Risk Provision The amount of budget / schedule / resources set aside to manage the impact of risks Risk provision is a component part of Management Reserve APM EV/Risk Working Group Risk Response Activities Activities carried out to implement a Proactive Risk Response. APM EV/Risk Working Group Schedule Risk Analysis Assessment and synthesis of schedule risks and/or estimating uncertainties affecting the project ability to meet key milestones. (PRAM) Schedule Reserve The schedule component of Management Reserve. APM EV/Risk working group Specific Risk Provision The amount of budget / schedule / resources set aside to cover the impact of known risks, should they occur. It is not advisable to net opportunities against threats and so a separate value is calculated for each. APM EV/Risk working group Threat A downside, adverse Risk Event PRAM Uncertainty The spread in estimates for schedule, cost, performance arising from the expected range of outcomes. Often termed estimating error. APM EV/Risk © risk decisions 2011 www.riskdecisions.com 7 Val Jonas: The first step to ERM: whitepaper About Risk Decisions Risk Decisions Limited is part of Risk Decisions Group, a pioneering global risk management solutions company, with offices in the UK, USA and Australia. The company specialises in the development and delivery of enterprise solutions and services that enable risk to be managed more effectively on large capital projects as well as helping users to meet strategic business objectives and achieve compliance with corporate governance obligations. Risk Decisions has introduced many innovative features that have since become standard features in the industry including the risk hierarchy tree, combined threat and opportunity risk impact grids and automated schedule risk analysis. The company plays a significant role in influencing risk management policy, making important contributions to APM, OGC and PMI risk management guides and standards, including guidance on interfacing risk with other disciplines, such as Earned Value and Systems Engineering. Clients include Lend Lease, Mott MacDonald, National Grid, Eversholt Rail, BAE Systems, Selex Galileo, Raytheon, Navantia, UK MoD, Australian Defence Materiel Organisation and New Zealand Air Force. For further information visit: www.riskdecisions.com or contact Alex Leggatt at: Risk Decisions Ltd, Whichford House, Parkway Court, Oxford Business Park South, Oxford, OX4 2JY Tel: 01865 718666 Email: [email protected] European HQ For enquiries from the UK and mainland Europe. Risk Decisions Ltd Whichford House Parkway Court Oxford Business Park South Oxford OX4 2JY United Kingdom For general enquiries: Tel: +44 (0)1865 718666 Fax: +44 (0)1865 718600 Email: [email protected] For help desk support: Tel: +44 (0)1865 395698 Fax: +44 (0)1865 718600 Email: [email protected] www.riskdecisions.com management solutions
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