October 2014 How much progress have we made since the crisis? Second National Survey of Risk Management in the Netherlands 2014 The researchers (from left to right): Casper Ruizendaal, Remko Renes, Dirk Swagerman, Marcel Prinsenberg, Esra Aktas, Leen Paape, Johan Scheffe, Matthijs van de Belt. Gerben Posthumus is missing from the photograph. Title: How much progress have we made since the crisis? Subtitle: Second National Survey of Risk Management in the Netherlands 2014 Commissioning parties: University of Groningen; Nyenrode School of Accountancy & Controlling; NBA (Netherlands Institute of Chartered Accountants); PwC Copyright: 2014 NBA Amsterdam, PwC Amsterdam, Nyenrode Breukelen, University of Groningen Visuals: Dreamstime, Nationale beeldbank Edited by: Margreeth Kloppenburg ISBN/EAN: 978-90-75103-79-3 October 2014 Foreword Results as expected, unfortunately. But some encouraging signs In this report, the authors reveal the truth about what is still sadly lacking in risk management in the Netherlands today. Of course, this is first and foremost the responsibility of the board members. The good news is that we have also seen examples of organisations that take proper responsibility for effective risk management. But the fact remains that not all board members appear to understand what can go wrong. This can lead them to believe that they have things under control when an objective evaluation shows that this is not the case. This may be because risk management is not taken sufficiently seriously, or because board members find it difficult, for example if they are asked to assess unquantifiable risks, such as reputational risks, or the risk culture within the organisation. I will explain both of these causes in more detail. Not serious? If the first cause is the case, and organisations do not take risk management seriously, it is necessary for us, the Dutch National Bank (DNB), to demonstrate how a serious approach to risk management can contribute to a stable economy. Indeed, many of the organisations under our supervision are legally obliged to do this in any case. In accordance with the Financial Supervision Act (Wet op het financieel toezicht/Wft) and the associated regulations, the organisations under our supervision must systematically analyse their risks and take appropriate measures. This means that it is up to organisations themselves to determine what the greatest risks are for their organisations and how they adjust their policy and procedures accordingly. Current practice shows us that many organisations are still failing to carry out an effective systematic analysis of the risks on a systematic basis and are not taking sufficient actions in response to an (in some cases inadequate) analysis. It is important for this analysis to be continuous in nature, because risks do not remain static. Risks for an institution are liable to change as a result of both internal and external factors. The institution applies this kind of systematic risk analysis in order to determine whether the current control measures are proving effective. If they are not, the institution makes adjustments to the control measures. A systematic risk analysis also involves the institution conducting this kind of analysis regularly in accordance with a set methodology and recording the results in writing. Risk management difficult? There is no denying that risk management is difficult. But that is the idea: dissent is never pleasant and neither is the need to abandon grand designs and plans because the risks are too high. But it is a necessity. The more independently-positioned risk management is within the organisation, the stronger that risk management can develop and – of course – the more potential dissent there will be. There is a need to clearly demonstrate to the risk managers of the Netherlands (and the DNB is happy to contribute to this) what constitutes effective risk management and how it can actually help to achieve business objectives. Including an independent chief risk officer alongside a chief financial officer on the board can help to make risk management a natural part of the business process and thereby incorporate safeguards for healthy operation, continuity and the survival of a company. In my view, it is possible to eradicate both causes. Perhaps in five years’ time, when the third National Survey of Risk Management in the Netherlands has been conducted, we will at least be able to conclude that the experience of board members and researchers has become closer and we will hopefully see the scores improve significantly. I wish you the best of luck in this. Jan Sijbrand, DNB Board of Directors Second National Survey of Risk Management in the Netherlands Open letter to directors in the Netherlands Board members in the Netherlands, In 2009, we presented our first survey of the status of risk management in the Netherlands. Now, five years on, we are pleased to present the follow-up to our research. To what extent have organisations like yours been engaged in the introduction and improvement of their risk management systems? Much to our surprise, we have noticed that hardly any improvement has been achieved; in fact, there has even been a slight regression in some cases. The really bad news is that you yourself believe that you have actually made progress. This might mean that you have been misled and will have to pay the cost for it when you least expect it. Have you carefully considered which risks you are willing to accept and which you are not? Is there a culture in place to ensure that bad news reaches you on time? When making decisions in the face of uncertainty – your solemn duty – has enough thought been given to potential scenarios or have you perhaps gone no further than a bad scenario and a good one, and something in-between? 4 Many of your fellow board members were also of the opinion that things were in order. Despite this, various organisations have met with serious difficulties. Vestia, Imtech, Rabobank, BAM, Meavita, Douwe Egberts, Ballast Nedam, SNS Reaal and Amarantis are just a few examples. The extraordinary thing in all of these cases is that the organisations faced serious difficulties at the heart of their business. Not in peripheral activities but in the activities they were actually assumed to excel at! They were hit hard, at the very core of their business. Every director, probably also including you, will wonder: “Could this also happen to me?” Our answer to that question is: “That could indeed happen”; if, like many of the respondents to our survey, you assume that you are doing a better job than those unfortunate organisations. If you would like to find out if your organisation actually is doing a better job, we invite you to become acquainted with this report. You should at least read the whole of Chapter 3 and talk to your chief risk officer, compliance officer, internal auditor or head of finance and ask what lessons you can both learn from this report. “Which conclusions and recommendations also apply to us? What can we do to improve this?” At the very least, we call on you to take a critical look at the following six questions: - Is risk management properly integrated within our performance management? Is there a direct link to the appraisal and remuneration of our employees? - Are risk management and internal controls embedded in the DNA of our organisation? - How can we raise the structure, quality and position of our risk management department to a higher plane? - Have we properly articulated our risk appetite? Has this been consistently applied and communicated across the entire organisation? - Do we have truly integral risk management, that covers all of the risks, including external influences? - How can we further enhance our strategic thinking about risk? We assure you that this will help you to avoid being mentioned in a list of scandals like the one above, in the survey we will conduct in five years’ time. We wish you every success in this endeavour. October 2014 Open letter to risk managers in the Netherlands Risk managers in the Netherlands, In 2009, we presented our first survey of the status of risk management in the Netherlands. Now, five years on, we are pleased to present the follow-up to our research. To what extent have organisations like yours been engaged in the introduction and improvement of their risk management systems? Much to our surprise, we have noticed that hardly any improvement has been achieved; in fact, there has even been a slight regression in some cases. The really bad news is that you yourself believe that you have actually made progress. This might mean that you are being misled and will have to pay the cost for it when you least expect it. Have you carefully considered which risks you are willing to accept and which you are not? Is there a culture in place to ensure that bad news reaches you on time? When making decisions in the face of uncertainty, are you capable of properly informing your board members about the advantages and disadvantages of the potential scenarios or have you perhaps gone no further than a bad scenario and a good one, and something in-between? Of course, you are well aware that a lot still needs to be improved. It may not always be easy to convince those around you of that fact. Risk management is important, but is often seen as secondary; a necessary evil that can also sometimes even be seen as an obstacle. In recent years, you have had the wind behind you; the financial crisis and corporate scandals featured in the press caused interest in your work to increase, occasionally even imposed by regulation. But there is still more than enough work to be done. The press is still packed with scandals of not insignificant size. You would be well advised to take a look at this report and determine the position of your organisation and what can be improved. Engage in conversation with your board members and ask them what you can do, together with the board. These questions may prove useful in that conversation: - What role do we want our risk management to play: from reactive to pro-active? From technical skills to business skills? And what does that mean for our team? - How can we involve all layers of management more effectively and help line management to assume responsibility for risk management? - Is there technology available that can assist us in making risk management more effective and efficient and at the same time make it more attractive and convenient for line management? - How can we find and implement new techniques and methods in order to remain alert to strategic and emerging risks and their management in the future? Armed with this report, you can make a well-substantiated plea to be included in the executive board as chief risk officer (CRO), since our research provisionally suggests that, as dedicated risk champion, the CRO can achieve better results than in organisations in which risk management is just one of the many tasks of one of the board members. We look forward to hearing the progress you have made in five years’ time. We wish you the greatest success in this endeavour, confident that it will be for the benefit of your organisation. Second National Survey of Risk Management in the Netherlands October 2014 Contents Foreword 3 Open letter to board members in the Netherlands 4 Open letter to risk managers in the Netherlands 5 Contents 7 1 Introduction 8 2 Trends in risk management 2009 - 2014 2.1 Zero-tolerance 2.2 Increasing legislative and regulatory pressure 2.3 Speed and impact of changes 2.4 Risk culture 2.5 Integration of performance and risk management 10 10 10 11 11 12 3 Summary: our assessment of the development of risk management 3.1 Improvements in some areas – no structural progress made 3.2 Where do we go from here? 13 13 16 4 Survey results: analysis and observations 4.1 Introduction 4.2 Profile of the respondents 4.3 Risk assessment and analysis 4.4 Risk management reporting and risk monitoring 4.5 Risk management and organisation 17 17 17 28 36 40 5 Risk culture 49 6 Two alternative perspectives 6.1 Another look at the dataset, with two different questions 6.2 Enterprise Risk Management, automatically a higher score? 6.3 Risk management maturity, how do you make progress? 54 54 54 55 Bibliography 59 Appendix 1: Methodology 63 Appendix 2: Score guide for survey of Risk Management in the Netherlands 2014 67 Appendix 3: Questionnaire for survey of Risk Management in the Netherlands 2014 73 Appendix 4: Conceptual model Second National Survey of Risk Management in the Netherlands 85 1. Introduction We are proud to present you – valued reader, director, risk manager or stakeholder of profit and non-profit organisations in the Netherlands – with the results of the second national survey of the current status of risk management. In 2009, we presented the first national survey of risk management in the Netherlands involving more than 900 participants. In the foreword, we indicated that we would gauge how much progress had been made in five years’ time. This means that the time has now come for an update. The timing of the first national survey could not have been better: it came just after the start of the greatest financial crisis in living memory. The fact that many organisations were not in control of their risk management became all too painfully clear. Financial organisations in particular, generally assumed to have the best systems and methodologies at their disposal and undeniably the best supervision of their activities, failed to make the grade. The world continues to suffer the consequences. Equally, there seems no end in sight to the constant stream of new incidents in the field of risk management and internal controls, although the term incident does not fully convey their true impact, as in recent cases involving Vestia, Imtech, Rabobank, Amarantis, BAM, Douwe Egberts, Ballast Nedam, SNS Reaal, etc. Similar questions to 2009, but now also featuring risk culture Would things be better five years later, after numerous reports, studies and attempted improvements, was the question we asked ourselves. Have we learned from our previous mistakes? What questions would assist us in gaining a greater understanding of developments in risk management in recent years? From an academic perspective, very little knowledge had been acquired in this area and, of course, change takes time to have an effect. What did emerge clearly is that both risk culture and ‘tone at the top’ have become overriding themes. If the instruments and methodologies are not the problem, perhaps it is the people and the culture in which they have to work, is the argument. We therefore attempted to include the concept of risk culture in our questionnaire. It was a flawed attempt, because useful results on how to measure risk culture are still hard to come by or not available at all. In any case, a proper assessment of culture calls for research on a major scale, which was unfortunately impossible in practice. Despite that, this report offers plenty of interesting pointers on risk culture. And we would also now like to invite you to make a contribution to advancing our understanding of risk culture. In many cases, the questions we posed in this second survey have remained unchanged compared to the first survey in 2009, whereas others have been slightly updated on the basis of the latest insights, where relevant. Thanks to the unchanged questions, we are able to compare the results with those from 2009. Has progress been made? Has there even been regression in some cases? If so, in what areas? The 727 respondents – from the almost 10,000 questionnaires sent out – provided us with information about many different sectors. This enables us to make a series of comparisons. For example, we were particularly interested in comparing profit and nonprofit, as well as drawing a distinction between businesses in the financial sector and the rest. In the first survey, there was a significant difference between the two. You will find out whether that continues to be the case later in this report. October 2014 We were also interested in providing you with more information on the use of tools, techniques and software to support risk management activities. Quite a lot of these have been introduced into the market in recent years and there have also been changes within the suppliers’ market. The suppliers have consolidated and software tools have been improved and are being used more often. We also wondered to what extent these new instruments have actually reached the organisations. When used effectively, tools and software provide a considerable boost to the monitoring, analysis and early detection of risks. They are also extremely useful in ensuring people remain focused on the matter in hand. Have the effects been noticeable? This report The report starts with a brief outline of the history since the previous report in 2009. This is followed by our final assessment, our answer to the question: “How much progress has been made in the crisis?” We link that answer to a series of recommendations, ranging from concrete and easy-to-implement improvements to suggestions for intervention on a much wider scale. If you would like to find out more about a specific sector, or a particular subject, you should go straight to Chapter 4. Here we provide substantiation for our judgements and recommendations and point out where things sometimes work and sometimes prove less successful, always in the light of the questions from our survey. We also focus on and explain any interesting statistics, for example a particular sector that stands out or a score that is unexpected or unusual. Because risk culture plays such an instrumental role in the current debate about the failure of organisations and their risk management, we have added risk culture as a new section in our questionnaire and devoted a separate chapter to it in this report: Chapter 5. Finally, Chapter 6 includes something extra: we looked at the collected data from two alternative perspectives: firstly, we explored the advantages that risk management has to offer in the eyes of the respondents. Secondly, the research data has enabled us to make a substantiated assessment of which internal and external factors have an influence on the maturity of a risk management system. The detailed explanation of the methods we have used can be found where you might expect it: at the end, immediately after the bibliography. We hope you enjoy reading the report and that you find the survey results to be of use. If you feel that specific questions are missing, or would like to have seen your own company featured in the results, please do not hesitate to let us know or, even better, sign up as an organisation to participate in the next survey in 2019! Breukelen/Amsterdam/Groningen, 29 October 2014 Second National Survey of Risk Management in the Netherlands 2. Trends in risk management 2009 - 2014 ‘How things can change in the space of five years’… these were the opening words of the 2009 report. We were then at the height of the crisis. So what impact did the crisis have on people’s perceptions of risk management? Would risk management enable organisations to arm themselves against political and macro-economic storms waging elsewhere? Suddenly, these questions had genuine urgency. Anyone who assumed that the storm we were referring to would have calmed five years later was sadly mistaken. The economic environment remains turbulent and the threat of a double, or even triple dip, continues. In the search for people to blame, tolerance of mistakes by board members and supervisory authorities plummeted in terms of public opinion. Supervisory authorities responded by creating stricter regulations and becoming ever more prescriptive in terms of the implementation of primary processes. The economic crisis and sluggish recovery have also had a noticeable effect on developments within the profession of risk management. Traditional methods for managing risks no longer seem adequate in an environment subject to faster and more far-reaching change. This can be seen in the increasing focus on a proper risk culture and the ever-increasing integration of performance and risk management. Rather than more of the same, it was a case of the same, but in a different and better way. Below, we outline the five most important trends of the last five years. 2.1 Zero tolerance The former board members of such companies as Vestia, Imtech, Rabobank, Amarantis, BAM, Douwe Egberts, Ballast Nedam and SNS Reaal have all experienced it: customers, shareholders, politics – indeed no one has tolerance any longer for managing or supervisory board members who make major errors. Society wants to see them pay, via the courts or otherwise, for the errors they made in their former roles. The liability of senior executives and supervisory board members has increased in recent years, partly as a result of political pressure. Whereas the courts still require evidence of ‘serious misconduct’, politics and public opinion have been rather less reticent in their criticism, often before any criminal enquiry has been completed. The reputational and financial risks that the managing and supervisory board members run have increased significantly in the wake of these developments and increasing litigiousness. As a result, much more needs to happen before a managing director will put a signature to an ‘in control’ statement, which has increased the importance and impact of the underlying methods used. There are increasing calls for transparent business operations and management of risks: from customers, investors, supervisory authorities and credit-rating agencies. 2.2 Increasing legislative and regulatory pressure From the very first day of the public hearings into the causes of the crisis conducted by the committee of enquiry into Financial Recovery1 in the Netherlands, the finger of blame was clearly being pointed towards the supervisory authorities. 1 De Wit Committee (Commissie De Wit) October 2014 The supervision was said to be too focused on compliance with regulations rather than on compliance with principles. But despite this, even more regulations have been added in recent years! So many, in fact, that a PwC survey2 of more than 1,300 CEOs from 68 countries revealed that the increasing regulatory pressure is seen as the greatest threat to economic recovery (and the well-being of their organisations). In fact, the trend has actually been towards a greater focus on compliance with principles. But that needs to be demonstrable, as a result of which even more rules are added. Organisations that operate internationally or have international clients face an additional challenge of having to deal with discrepancies in terms of the regulatory regimes and philosophies. 2.3 Speed and impact of changes The risk landscape is changing incredibly rapidly: demographic changes, accelerated urbanisation, shifts in economic power, climate change, technological innovations, the role of social media, changes in the labour market and increasingly interdependent value chains that are becoming ever more complex. How can all this be managed? As a result of the wide range of strategic risks resulting from these changes and the unpredictability of the associated risks, a traditional ad-hoc (one-dimensional) approach to managing risks is no longer adequate and an alternative approach is required. In 2012, the World Economic Forum3 concluded that the risks to which modern organisations are exposed can be managed only by means of cooperation between businesses, government authorities and wider society, based on long-term thinking. The early detection of so-called ‘Black Swans4’ calls for the status quo to be challenged and the introduction of external and possibly even bizarre ideas in the development of strategy and identification of risk. Cooperation (across value chains, with consumers, suppliers, within sectors, with government, NGOs, etc.) is fundamental for the success of this. 2.4 Risk culture Organisations like to focus on tangible measures when implementing risk management. Examples of this include describing all of the risks, appointing a risk manager or establishing concrete management measures. But risk management is about much more than the risks at management level. There are also employees at a much lower level who decide on a daily basis whether or not to take a risk, as an everyday part of their work. Much of the success of risk management therefore depends on the awareness of risk and control at all levels within an organisation. There is also increased focus on soft controls, which are required in order to enable more stringent control methods to take effect. They include such things as leadership, leading by example and communication styles. 2 PwC: 17th Annual Global CEO Survey: Fit for the future 3 World Economic Forum: Global Risks 2012 4 In his book ‘The Black Swan’, Nassim Nicholas Taleb looks at extraordinary events that have a major impact, but that no one can foresee. Second National Dutch Survey of Risk Management in the Netherlands 2.5 Integration of performance and risk management A key indication of the risk culture of an organisation is the extent to which management is based on a balance between performance and risks. Is the analysis and control of risks already an essential part of operations? The PwC survey referred to previously shows that 65 percent of the organisations do not analyse and manage their risks and performance in relation to each other. This makes little sense, if one realises that the outside world expects an organisation to take responsibility not only for its results but also for the risks involved. The point of departure for successful integration is for organisations to begin considering risk appetite as an important part of strategic planning. The best way forward after that involves ensuring that performance and risk are managed cohesively. Ultimately, risk and returns are inextricably linked. Increased risk can result in greater returns, but the other side of the coin is that there will be increased volatility and greater difficulty in predicting the results. An increasing number of organisations is beginning to acknowledge – often in response to incentives from supervisory authorities – the need to take greater account of risk appetite in planning. Few organisations have advanced as far as to take the second step of managing results and risk simultaneously. This process takes time, but the outside world is demanding it already. In our next chapter, we present our judgement of the development of risk management by 2014. “Risk management largely remains the preserve of people. It starts with risk awareness, a systematic assessment of the risks and dialogue about the key risks at each level of the organisation.” Siebe Riedstra, Secretary-General at the Ministry of Infrastructure and the Environment “The dialogue between management and supervision improves significantly when risk management is taken seriously and is regularly placed on the agenda.” Paul van Gelder, Executive Board Member, Royal Imtech NV October 2014 3. Summary: our assessment of the development of risk management 3.1 Improvements in some areas – no structural progress made What progress has been made since the crisis? The results reveal that progress has been made in some areas, but there is even a slight regression in others. There are also remarkable discrepancies between developments in the public sector and the private sector. Below, we analyse which factors contribute to improved risk management and which do not. Our aim in doing this is to enable you as a risk manager or entrepreneur to make the right choices in further improving your risk management system. No structural improvement in five years, despite the crisis Based on a detailed survey, comparable to that of five years ago, we have been unable to determine that risk management in the Netherlands has seen any significant structural improvement and this applies to the total score, as well as the scores for each sector and criterion. Figure 1: Spider diagram of comparison scores 2014-2009 for each criterion We also asked the respondents to give a rating for their own risk management systems and the results surprised us: It would appear that organisations feel relatively secure about the quality of their own risk management systems. This confidence has even increased slightly compared to the results from 2009. We asked them to score themselves on a scale of 1 to 10 (1 = very poor, 10 = excellent). The average rating that organisations gave themselves is 6.85 (+0.37 compared to 2009). In addition, approximately 89 percent (+9 percent compared to 2009) of respondents believe their risk management systems to be satisfactory: a score of 6 or higher. There is also a significant correlation between a higher self-score and a higher score for our criteria: respondents who give themselves a high score, also score higher on our score guide. None of this affects our view that risk management in the Netherlands remains at an unsatisfactory level. 5 According to the researchers’ scoring guide. Second National Survey of Risk Management in the Netherlands Why is this not good enough? There is a serious need for structural improvement, for three reasons. Firstly, many studies5 show that inadequate or low-quality risk management was one of the causes of the financial crisis. Secondly, if self-regulation is not improved (or if, in this case, companies fail to improve their risk management), there is a danger of government intervention involving more laws and regulations in the area of risk management. This is especially so if one takes account of the fact that there have been incidents involving risk management in all sectors in the last five years. We have already seen this happen in such sectors as financial services, energy and trade. Thirdly, there is the looming threat that organisations currently engaging in cutbacks will actually cut back on essential areas of risk management, possibly believing that their efforts towards recovery mean there is less need for it. Some improvement, in part So, are we of the opinion that no progress has been made at all? On balance, the answer is probably no, but in some areas we have noticed both interesting and at times disquieting results. Looking at the scores of the various respondents, we particularly noticed that larger organisations achieve higher scores in our survey, and this applies to organisations that are larger in terms of turnover as well as those larger in terms of number of FTEs (full-time equivalents). The position of chief risk officer is on the rise, especially in financial services. We are able to conclude that this is the sector that has invested most in risk management since the last survey. For the scores for risk assessment and analysis, it was noticeable, first of all, that more than two thirds of respondents does not make an assessment of the relevant risks more than once each year and slightly more than 13 percent admitted that they conduct absolutely no risk assessment or analysis. We did not find any major differences between sectors for this question. What we did see, fortunately, was an increase compared to 2009: an increasing number of organisations is assessing and analysing the risks for their operations and this fortunately also applies to all types of risk. Further progress can be achieved if organisations assess their risks in a more integrated way and if the assessments and analyses take place deeper within the organisation: an enterprisewide risk analysis is more valuable than those conducted solely by board members or an executive board. As far as reporting and monitoring of risks is concerned, we unfortunately did not see many differences compared to 2009. There was however one exception to this: whereas, in 2009, 11 percent of respondents said that there was no internal reporting about risks, this has now fallen to 5 percent. For all the other subsidiary questions on reporting and monitoring, we continue to see similar results to those in 2009, usually with a slight increase. With regard to the questions about risk management and organisation, we were pleased with the answers to the question about risk appetite. The number of respondents that have now formulated a risk appetite has improved compared to 2009. However, we did find it strange that not all of them recorded and communicated this risk appetite. This could be related to another surprising 6 Including Huber, C. and Scheytt, T. (2013): The Dispositif of Risk Management: Reconstructing Risk Management after the Financial Crisis. Management Accounting Research, 24(2), pp 88 - 99 Mikes, A. (2009): Risk Management and Calculative Cultures, Management Accounting Research, 20, pp 18 - 40 Power, M. (2009): The Risk Management of Nothing, Accounting, Organizations and Society, 34, pp 849 - 855 October 2014 result: a significant majority of respondents applied no accepted standard when setting up risk management and internal controls. Of course, a standard (such as ISO, Basel, COSO, INK, EFQM) provides no guarantee, but it does offer the opportunity for comparisons and the application of best practices. The use of a standard introduces a language in which to share information about risks and control. Based on to the answers to the (new) questions about risk culture, we gained the impression that in many organisations risk management is still very much compliancedriven. “We engage in risk management because people ask us to”, is what the answers appear to be saying. “People”, here could refer to an accountant, an external supervisory body or the public. The effectiveness of risk management is, for example, a factor in the remuneration system for only 9 percent of respondents. For half of all respondents, the section on risk in the annual report is primarily or exclusively the preserve of the financial function in the organisation. A key conclusion from our survey that supports the notion that risk management is primarily compliance-driven can be seen from the fact that companies consider the prevention of reputational damage and the reduction of capital costs as significant drivers for awarding their risk management a good score. On the other hand, the inherent possibilities that risk management offers in terms of higher profitability and more opportunities for growth do not appear to result in people giving their own risk management system a higher score. This impression is also confirmed by our conclusion that the maturity of risk management is primarily determined by the influence of external parties, such as Big4 accountancy firms, the supervisory body and governance codes that impose standards (voluntary or not). Risk management for the outside world or as a result of external pressure. This is despite the fact that ownership structures, with the exception of listed companies, financial institutions and (semi-)public institutions, and audit committees have no significant influence on risk management. The internal boost to risk management resides primarily in the chief risk officer, preferably with a position dedicated especially to this. This is also despite the fact that, in terms of culture, the position is not regarded as a career advancement and risk management still primarily involves the top layers of the organisation. All of this amounts to little improvement compared to five years ago, which is anything but reassuring. However, we do realise that these things do not happen automatically and five years is a short space of time. We cannot expect risk management to have become fully integrated in all sectors in just five years. It does not happen automatically and in any case, can we actually manage all of the risks? Instrumentally, it is possible, but what exactly are we managing in that case? In an increasingly complex world, the highest level of risk management maturity is not yet realistic and we also understand that all types of management (including risk management) are the work of human beings. This means that we continue to be let down by human characteristics such as overestimation of one’s own ability, we tend to seek confirmation of what we already believe, allow ourselves to be reassured by trusting in others and we keep ineffective structures in place merely in order to avoid rocking the boat. “No, the chance of interest rates falling even further is extremely low”, “Things have been going well for quite some time, haven’t they? Well then!” There is also another factor: risk management is as rich as the imagination of the individual applying it. Second National Survey of Risk Management in the Netherlands Although this is understandable, it is also dangerous. We should not allow ourselves to tolerate things purely because they are understandable and human: the investment is too great for that. Deliberately opting for risky investments as a semi-public body, making key policy decisions that no one can explain five years later or hedging with swaps, but later claiming in the press “I do not even know what a swap is”: these are things we can no longer accept. 3.2 Where do we go from here? We use our results to develop recommendations for organisations who want to make progress and move closer towards mature risk management so that they are prepared for the next crisis or at least adopt a slightly smarter approach than their competitors, thereby gaining a competitive advantage. Recommendations for you, the readers of this report. But we also see opportunities on a larger scale, opportunities to enable risk management to play a more serious role. We have noticed that in all the sectors where there was greater focus on risk management, the scores have increased and sectors that have been regulated (again resulting in greater focus) also have demonstrably better and more risk management maturity. Auditors, investors, supervisory authorities and analysts should therefore continue to exert pressure. As for the risk managers of the Netherlands, you have an important ally in these groups. Speak to your managing director to raise the profile of risk management. And, for those of you who are yourselves board members: you could take more time to assess and analyse risks – not only in terms of risk management, but generally – and organise constructive dissent: ensure that there is dissent that offers a wider perspective. Often, it turns out that there was awareness within an organisation that something was not right for quite some time, but this never reached the top of the organisation, because no one had the confidence to spoil the party. Take risk analysis and risk management seriously. Do not focus solely on compliance, but decide what kind of organisation you want to be, which risks you are still willing to take and which you are not, and develop your risk profile based on that. Record that profile in writing and share it across the organisation, with built-in checks: that is what risk management is all about. And, of course, monitor it and update it regularly. Finally – and this will come as no surprise – we will continue with our surveys and research. We also cordially invite other people to investigate how we can make risk management more effective, starting in the Netherlands. “Control is a vitamin at the start of the growth and a poison at the end of the same growth.” Peter Robertson, Nyenrode and Monterey Institute (USA) “Effective risk management prevents surprises and leads to better results.” Erik van de Merwe, supervisory director and jury member for the FD Henri Sijthoff Prize October 2014 4. Survey results: analysis and observations 4.1 Introduction Below, you will find the results of our survey, categorised according to the five main areas of our questionnaire: 1. 2. 3. 4. 5. general characteristics of the respondents and their organisations (section 4.2); risk assessment and analysis (section 4.3); risk management reporting and monitoring (section 4.4); risk management and organisation (section 4.5); risk culture (Chapter 5). Here you will find the facts and figures, comparisons, analyses and observations on the basis of which we reached our judgement and our recommendations in Chapter 3. Details of the research structure, methodology and the quality of the data obtained and used can be found in Appendix 1. The questionnaire was sent in April 2014 to organisations whose addresses were obtained from the database of ‘Company Info’. A total of 9,582 questionnaires were sent to organisations with a budget or turnover in excess of EUR 10 million, of which 20 were returned because of bankruptcy or an incorrect address. Ultimately, this resulted in 727 usable questionnaires. The 7.6 percent response rate is relatively high for this kind of survey. We can now make a comparison with 2009 because the questions in our survey are almost completely the same as those in our survey then (details of the differences can be found in Appendix 1). So how do we stand, five years after the start of the crisis? What progress has been made? 4.2 Profile of the respondents Figure 2: Changes in the position of respondents 2014 - 2009 3 0 % Second National Survey of Risk Management in the Netherlands The majority of respondents (52 percent, compared to 55 in 2009) are executive board members. As is customary, we also included CFOs in this category. This is important, because risk management is ultimately a responsibility of the executive board. We did not do this for the position of CRO, because it is not yet common practice for the CRO to be a member of the executive board in all cases. The results included in Figure 7 still support this choice (half of the CROs are members of the executive board). A total of 32 percent of respondents hold a financial position (CFO and Controller). This is a significant change compared to 2009, when the figure was 46 percent, but still in line with the general thinking that risk management should be coordinated by the finance function. The distribution for 2014 differs from 2009 on three points: 1. the importance of risk management at executive board/directors level (almost 10 percentage points higher); 2. the role and importance of the CRO (up by almost 5 percent); 3. a shift from the financial/support function to more business functions. Distribution of respondents by sector A total of 35 percent (2009: 40 percent) of the organisations are in the healthcare and non-profit sectors. In order to enable a better comparison between profit and non-profit organisations, we have included healthcare under non-profit. It is noticeable that the ‘Others’ category, consisting of Transport & Logistics, Telecommunications, Information Technology and Entertainment and Energy & Utilities has seen a significant fall in terms of the number of respondents. Despite this, the numbers are still sufficiently representative in order to draw conclusions for each sector. Figure 3: Respondents by sector 2014 - 2009 Figures 4 and 5 present an overview of the size of the organisations in terms of turnover or budget and full-time equivalents (FTE). The only difference compared to five years ago is that there has been less participation by the larger organisations (turnover/budget in excess of 1 billion) this year. October 2014 Figure 4: Respondents by turnover category Figure 5: Respondents by FTE categories Characteristics of respondents The share ownership structures of respondents reveal something of an anomaly: more than half of the organisations are not in the ownership categories we asked about. This applies to almost all of the non-profit organisations (35 percent) and a number of other organisations from other sectors. In addition, 8 percent (2009: 9 percent) of the respondents are listed companies and 29 percent (2009: 65 percent) are active in more than three countries. The difference in terms of international activities is remarkable and there is no obvious explanation for it. Second National Survey of Risk Management in the Netherlands Figure 6: Ownership structure Ownership Profit Non-profit 2014 2009 (N=475) (N=251) (in %) (in %) Not applicable 30.0 92.9 51.4 46.2 Anonymous shareholder 6.2 - 4.1 4.5 Several institutional investors 3.4 - 2.3 11.3 One or several families 19.3 2.1 13.5 14.4 Accounting consultancy 2.4 - 1.6 2.5 (Director and) majority shareholder 18.7 2.9 13.3 15.4 Subsidiary of holding company 7.3 - 4.8 5.7 Banks 0.9 0.4 0.7 - Others 11.8 1.7 8.4 - Total 100 100 100 100 Chief risk officer The survey reveals that 58.2 percent of the listed companies have appointed a CRO or similar. In view of the major focus on risk management and being ‘in control’ over the last ten years, backed by corporate governance codes, we see this as a relatively low percentage that does not reflect our own experience in practice. 20 Figure 7: Chief Risk Officer (CRO) or not 10.5% 64.4% 9.3% CRO at Executive Board/Directors level CRO, but not at Executive Board/Directors level 15.7% No CRO, but a comparable position at Executive Board/Directors level No CRO and no comparable position at Executive Board/Directors level It is interesting to note that 35.5 percent of respondents have appointed a CRO or similar position with ultimate responsibility for risk management; in 2009 the figure was just 18.7 percent. It is apparent that risk management is increasingly being linked to an officer involved in the process and this role is positioned at a higher level within the organisation, at least in terms of the name. The figures also confirm that it is relatively common practice in financial services to have a CRO or equivalent position: this applies to two thirds of these organisations. The results for Transport & Logistics and Commercial Services are also interesting, since almost half of all respondents in this sector have a CRO or equivalent position. October 2014 Below, you can also see that the size of an organisation in terms of its turnover/budget is a key factor in determining whether there is a CRO or equivalent position. Also of note: almost one third of the smallest organisations have gone so far as to appoint a CRO or equivalent. Figure 8: CRO, by sector (in percentages) Appointment of CRO by sector Has CRO or equivalent position Trade 33.1 Transport & Logistics 48.0 Manufacturing 27.5 Financial services 68.4 Commercial services 44.4 Telecommunications, IT and Entertainment 27.8 Energy & Utilities 27.8 Healthcare 33.6 Government/Non-profit 27.8 Figure 9: CRO, by turnover/budget (in percentages) Appointment of CRO by turnover Has CRO or equivalent position 0 - 50 million 32.5 51 - 100 million 26.8 101 - 500 million 40.5 501 million - 1 billion 55.6 > 1 billion 68.4 Second National Survey of Risk Management in the Netherlands When divided by sector, the following picture emerges: Figure 10: Appointment of CRO or otherwise, by sector (in percentages) Appointment of CRO by sector CRO at CRO not at No CRO, but No CRO or Executive Executive equivalent equivalent Board/Dir. level Board/Dir. level position position Trade 3.4 14.5 15 66.7 Transport & Logistics 8.0 20.0 20.0 52.0 Manufacturing 10.1 4.1 17.6 68.2 Financial services 42.1 7.0 21.1 29.8 Commercial services 11.2 10.1 15.7 62.9 Telecommunications, IT 11.1 11.1 5.6 72.2 Energy & Utilities 5.9 11.8 11.8 70.6 Healthcare 7.5 9.3 16.8 66.4 Government/Non-profit 6.9 8.3 12.5 72.2 and Entertainment Figure 11: Appointment of CRO or otherwise, by turnover/budget (in percentages) Appointment of CRO by turnover/budget CRO at CRO not at No CRO, but No CRO or Executive Executive equivalent equivalent Board/Dir. level Board/Dir. level position position 0 - 50 million 11.4 7.8 13.5 67.3 51 - 100 million 3.2 9.0 14.7 73.1 101 - 500 million 10.4 8.7 21.4 59.6 501 million - 1 billion 18.5 14.8 22.2 44.5 > 1 billion 36.8 21.1 10.5 31.6 Additional supervisory position In addition to the chief risk officer, external governance mechanisms in particular, such as the external supervisory authority and the Big4 accountancy firms, would seem to be important drivers for a mature risk management system. Supervisory authorities, such as the Dutch National Bank (DNB), focus in the supervision on the importance of risk management, thereby potentially boosting its quality. The Big4 accountancy firms and auditors who, following a change of auditors, view the organisation from a new perspective also contribute to more mature risk management. The debate enriches your risk management and clearly provides the constructive dissent that we encourage. October 2014 A total of 42.2 percent of respondents deal with an external supervisory authority, such as the AFM (Financial Markets Authority), DNB or ACM (Consumer and Market Authority). As much as 72.1 percent has a supervisory board of some kind and 49.5 percent (2009: 47.8 percent) has set up an audit committee and/or risk committee. Finally, more than 76.2 percent of the organisations (2009: 77.1 percent) are audited by the Big4 accountancy firms. In the last three years, 24.4 percent of the organisations surveyed has appointed a new external auditing organisation. Higher self-evaluation versus our lower score On average, all respondents gave the risk management in their own organisation a significantly higher score than our score guide for the survey would suggest (see Appendix 2). In both cases, the non-profit sector scores relatively low and healthcare is just slightly higher. Figure 12: difference between self-evaluation and surveys score, by sector Sector Number Average report Average mark (self- survey score Difference evaluation) Trade 117 6.86 4.27 2.59 Transport & Logistics 25 6.76 4.70 2.06 Manufacturing 147 6.90 4.21 2.69 Financial services 55 7.55 6.26 1.29 Commercial services 89 6.82 4.65 2.17 Telecommunications, IT 18 6.67 4.03 2.64 and Entertainment Energy & Utilities 18 7.11 5.24 1.87 Healthcare 107 6.75 4.61 2.14 Government/Non-profit 144 6.59 4.53 2.06 Total 720 6.85 4.60 2.25 If we compare the 2009 figures with those from 2014 (see figures 13 and 14), a positive trend can be observed. Both the non-profit and healthcare sectors have seen a significant increase and both have caught up with the profit sector, according to their own scores. The difference between them is now minimal, with the exception of financial services and energy & utilities. All sectors have made improvements in their risk management – in their self-evaluation score and the survey score – with the exception of telecommunications, information technology and entertainment and trade (own report mark only). The fact that the telecommunications, information technology and entertainment sector has actually worsened according to its own admission is endorsed by our survey score. In view of the relatively strong increase compared to 2009, financial services seem to have invested further in risk management. Second National Survey of Risk Management in the Netherlands Figure 13: Comparison of report scores (self-evaluation) 2014 versus 2009 24 Based on our score guide, financial services scores highest and telecommunications, information technology and entertainment the lowest. The greatest discrepancy between the self-evaluation score and our score can be seen for manufacturing, and the least discrepancy in financial services and transport & logistics. The non-profit sector does not score significantly lower than the other sectors, but is slightly lower than financial services and energy & utilities. Figure 14: Comparison of survey score (score guide) 2014 versus 2009 October 2014 We also broke down the scores from the survey according to turnover and organisation size. This clearly shows that the larger the organisation, in terms of turnover/budget or number of FTEs, the higher the score for risk management. There is just one exception to this rule, which is the smallest category, with a score of 4.52 (2009: 4.42). They score higher than the subsequent two categories. Figure 15a: Survey score, by turnover 2014 2009 Number Average Number Average 0 - 50 million 335 4.22 418 4.16 51 - 100 million 157 4.48 198 4.22 101 - 500 million 173 4.99 215 4.81 501 million - 1 billion 27 5.48 29 6.09 > 1 billion 19 6.73 50 6.92 Total 711 4.60 910 4.54 Turnover category in € Figure 15b: Survey score, by size 2014 FTE category Number 2009 Average Number Average 0 - 49 FTE 96 4.52 110 4.42 50 - 99 FTE 98 4.26 120 4.15 100 - 500 FTE 323 4.36 404 4.22 501 - 1,000 FTE 86 4.79 107 4.75 1,001 - 10,000 FTE 103 5.42 159 5.37 6 6.72 12 7.06 714 4.60 912 4.54 > 10,000 FTE Total How do self-evaluation scores relate to survey scores? We assessed whether there is a significant relationship between our scores and the scores the respondents gave themselves, and this would appear to be the case. In other words, if respondents rate themselves higher, we also give them a higher (survey) score. This relationship applies in 25 percent of the cases. Although this may appear to be a low percentage, it is still respectable for this type of survey. A similar comparison with the maturity model (see below) reveals a less close relationship. In this case, almost 19 percent of the report marks the respondents give themselves corresponds with the level of maturity they accord themselves based on the five Beasley levels. Second National Survey of Risk Management in the Netherlands We conclude from this that the respondents’ report mark does not depend on the level of maturity of their risk management. The relationship between their own report mark and the survey score based on our score guide, confirms that respondents base their mark less on the tangible aspects of their risk management than we did. The advantages of risk management as identified by the respondents themselves A new question in our 2014 survey involved explicitly identifying the advantages of a risk management system for an organisation according to the respondents’ own views. The more generic, qualitative characteristics such as fewer surprises, more confidence that goals will be achieved and improved reputation are noticeably rated as positive. However, more quantitative advantages that have a direct impact on the balance sheet or profit and loss account, such as lower capital costs, fewer fines, higher margins, a higher turnover and/or increased market share actually score lower. This is disappointing, in terms of substantiating the business case for risk management from a quantitative perspective, but does confirm that there has only been limited research related to effective risk management and the direct financial contribution it makes to the success of the organisation. Figure 16: Advantages of risk management Advantages 26 Average score Standard (scale 1-5) deviation Fewer surprises 3.6 0.88 More confidence in achieving the budget/objectives 3.5 0.86 Fewer departures from the budget/planning 3.2 0.88 Reduced capital costs 2.5 1.06 Improved estimation of provisions 3.1 1.02 Fewer complaints from customers/staff 2.9 1.04 Fewer and less serious corporate incidents 3.0 1.07 Fewer claims and lawsuits 2.9 1.11 Fewer instructions and/or fines from the supervisory authorities 2.7 1.21 Less negative media attention 2.9 1.16 Increased customer satisfaction 3.1 1.02 Increased employee satisfaction 2.9 0.98 Increased margin 2.6 1.03 Increased turnover/profitability 2.6 1.04 Improved reputation 3.4 0.98 Increased growth/market share 2.5 1.02 (Quantitative advantages are in orange) Based on the rating for the risk management system and the advantages gained according to the respondents’ own judgements, we investigated whether the risk management system has an influence on business performance. Our empirical research revealed that organisations do not see the benefit of risk management in controlling growth. The application of risk management results according to its users in reduced capital costs and enhances the organisation’s reputation. October 2014 Risk maturity We also asked the respondents to categorise their own organisation using a risk maturity model. In this case, the responses are less easily compared with those from 2009. This is because we have based the definition of the different stages on recent literature. Five years ago, we were more generous in defining the different stages6. The model uses five stages of development (see question 35 in the questionnaire, Appendix 3). The higher the figure, the more mature the risk management: • • • • • Stage 1: there are currently no plans for the introduction of a risk management system; Stage 2: we are investigating the possibility of introducing a risk management system, but have not yet made a definitive decision; Stage 3: we are currently planning the implementation of a risk management system; Stage 4: currently, a risk management system is partly in place and implemented; Stage 5: a fully-fledged risk management system is in place and implemented. In view of their own maturity scores, organisations appear to be quite confident about their risk management. Almost 49 percent ended up with maturity level 4 or 5, and if we deem level 3 to be a pass, the percentage awarding itself a pass increases to 57. Almost half of all respondents (43 percent) have no risk management system, no plans to introduce one or are only investigating the desirability of such a system. The remaining half (49 percent) have implemented at least a partial risk management system. Only 8 percent have concrete plans for the introduction of a system. It would appear that, by 2014, the choice of whether or not to have a risk management system has already been made. Figure 17: Risk maturity model 9% 27% Stage 1 Stage 2 Stage 3 16% 40% Stage 4 Stage 5 8% 6 This type of maturity model has previously been applied in the studies by Beasley et al. (2005) and Ward (2003). In 2009, the stages of maturity were defined more generously than those according to Beasley et al. This leaves greater room for interpretation making the difference between stages slightly vaguer than the original stage categories of Beasley et al. Although this did not ultimately lead to any confusion among respondents, as the way they answered this question shows, the levels have been reformulated again in 2014 in order to better reflect the original basic categories of Beasley et al. For this reason, the results 2014 cannot be compared with those from 2009, or only to a very limited extent. Second National Survey of Risk Management in the Netherlands If we look at the different sectors, the distribution appears to be relatively wide in the healthcare, government/non-profit and manufacturing sectors. Figure 18: Maturity levels, by sector Maturity score Sector 1 2 3 4 5 Energy & Utilities 3 3 1 7 2 Number Average Median 16 3.1 4 Financial services 4 3 2 27 17 53 3.9 4 Healthcare 18 19 13 47 6 103 3.0 4 Trade 32 17 6 53 5 113 2.8 4 Gov./Non-profit 40 19 14 52 9 134 2.8 3 Manufacturing 46 28 9 47 10 140 2.6 2 Telecoms, IT, etc. 7 7 1 2 1 18 2.1 2 Transport & Logistics 8 3 1 9 2 23 2.7 3 Commercial services 25 16 7 31 5 84 2.7 3 Total 183 115 54 275 57 684 2.9 3 As a percentage 27% 16% 8% 40% 9% 100.0% Here too, we see the earlier report marks confirmed: the high score for financial services and energy & utilities. This is also the case for the lower report marks, as telecommunications, information technology and entertainment shows. Trade, manufacturing and government account for the majority of stage 1 organisations (around 60%). Government and healthcare still tend to be at the third level: the planning stage. There is a significant link between the survey score and the maturity score based on the five Beasley stages, which provides a good indication that our score guide is an effective measure of the maturity of the risk management system. 4.3 Risk assessment and analysis How often is an integrated and enterprise-wide risk assessment and analysis conducted within the organisation? The key to the success or failure of any risk management is a clear and shared view of the relevant risks for the organisation, their characteristics and priorities. A risk analysis offers just that. In a rapidly changing environment, organisations obviously regularly assess their risk profile in terms of how up-to-date and relevant it is and make any necessary adjustments to enable them to respond quickly and effectively to changes. October 2014 This makes it all the more noteworthy that 68.1 percent (2009: 52.8 percent) of respondents does not conduct this kind of analysis more than once annually and as much as 13.3 percent (2009: 27.8 percent) still conducts no assessment and analysis. The notion that these organisations conduct no risk management at all is an exaggeration, but this does raise important questions. The fact that there has been improvement since 2009 is positive progress, since it happens at least once annually now. Managers also often point out that managing risks is part of their everyday work. It often happens implicitly. But is that enough? It reflects the impression we have gained from our observations of practice: when risk assessment and analysis is conducted, it is relatively instrumental, often once per year immediately before or after the start of a new planning year. Figure 19: Frequency of risk assessment and analysis Profit and non-profit organisations appear to spend an equal amount of time and energy on analysing risks and there is no major difference between the various sectors. Although that may seem acceptable in itself, it is remarkable. After all, we would expect risk management to be common practice in highly-regulated sectors, such as financial services, and therefore for this kind of analysis to be conducted with greater regularity. In view of the competitive environment in which they work, one might also expect profit organisations to conduct analyses more frequently than those in the nonprofit sector. However, we were able to confirm one of our other assumptions. We expected that the size of the organisation would have an impact on the extent to which risk management has become institutional and therefore also on the frequency of risk analyses. This proved to be the case: all organisations with turnover/a budget in excess of € 1 billion conduct risk assessments with significantly greater frequency. When is the risk assessment and analysis conducted? We consider it important for organisations to regularly assess risks in relation to the strategy and objectives of the organisation and believe that risk management activities should be integrated as far as possible within existing management activities. This would lead one to expect to see risk assessment or analysis at least included within the planning & control (P&C) cycle. After all, the logical rhythm and nature of that cycle can be effectively combined with thorough risk assessment and analysis. The results show that the P&C cycle is used in 78.4 percent (2009: 60.1 percent) of the cases Second National Survey of Risk Management in the Netherlands 29 to conduct the risk assessment and analysis, whereas one might expect that figure to be around 100 percent. We also noted that non-profit organisations do this more than profit organisations do (87.6 versus 73.7 percent). These percentages are higher than those in the survey in 2009, with a significant increase in the non-profit sector being particularly noticeable. In 2009, only 60 percent of those surveyed incorporated the risk management process within the P&C cycle. Figure 20: Timing of risk assessment and analysis (in %) 2014 When? Planning & Control Average 2009 Profit Non-profit (N=475) (N=251) Average Profit Non-profit (N=548) (N=368) 78.4 73.7 87.6 60.1 56.9 65.5 20.1 23.8 13.1 15.9 19.9 10.3 33.3 33.9 32.3 24.3 24.3 24.7 30.9 31.6 29.9 22.5 27.0 16.0 16.1 15.6 17.1 11.7 13.1 9.8 cycle Acquisitions/ (dis)investments Key projects/ developments Strategic decisions Important incidents However, since risks are not generally dictated by the rhythm of the cycle, it also makes sense to evaluate the risk profile whenever there are important changes, whether internal or external. But the survey reveals that organisations do not apply this good sense. The highest score for this question is 31.6 percent for the profit sector, which we consider to be a very low percentage. After all, strategic decisions are of great importance for any organisation and should involve an assessment of risk. In all other cases, the level of risk analysis remains the same or is even less, which can only be described as disquieting. Fortunately, there does appear to be a positive trend, since there is a rise compared to 2009 for all occasions mentioned. Various things are worthy of note: in the non-profit sector, a risk analysis is conducted for strategic decisions almost twice as often (from 16.0 to 29.9 percent). This also applies for important incidents (from 9.8 percent to 17.1 percent). Possible explanations for this include: reduced pressure from the government, pressure on budgets, a shift of activities and budgets to lower levels of government, the large number of incidents and the vulnerability of society and the resulting need to take greater risks. There is increasingly less room to deal with the unexpected. October 2014 What risks are being assessed? Figure 21: Risks identified 2014 – 2009 In the best-case scenario, risk analyses include all potential risks. It would therefore seem logical to focus primarily on (financial) reporting risks in view of the emphasis on this in corporate governance regulations in particular. But research7 actually shows that operational risks and, to an even greater extent, strategic risks ultimately represent the greatest threats and involve the greatest consequences. On a positive front, all risks are being assessed more frequently than they were in 2009, and especially strategic, operational and financial risks. Whereas compliance risks achieved a relatively low score in 2009, these are now being assessed almost twice as often. This reflects a familiar trend of increasing legislation and regulations and decreasing tolerance within society of poor risk management. We also note that financial reporting risks and legitimacy risks score low. Below, you will find an overview of all of the risks identified/assessed, divided into profit and non-profit, comparing 2014 and 2009. Figure 22: Risks identified8 profit – non-profit (in percentages) 2014 Risk Average Strategic risks 66.2 Financial risks Operational risks (Financial) 2009 Profit Non-profit (N=475) (N=251) 64.8 68.9 86.4 85.1 77.6 79.2 27.9 Legitimacy risks Compliance risks Reputation risks Average Profit Non-profit (N=548) (N=368) 49.4 49.8 49.2 89.2 69.1 67.6 71.5 74.9 59.9 62.7 56.5 30.9 22.3 23.2 26.1 15.9 27.5 21.7 38.6 - - - 47.0 50.9 39.8 26.8 29.2 20.5 38.0 34.3 45.0 - - - Reporting risks 7 PricewaterhouseCoopers Advisory, Internal Audit, ‘‘An opportunity for transformation’’, 2008 8 The categories have been changed since 2009, with the addition of legitimacy risks and reputation risks Second National Survey of Risk Management in the Netherlands Compared to the profit sector, the non-profit sector assesses and analyses its strategic, financial and reputational risks more. This is easily explained in view of the public and social nature of their work. The highest score for financial risk can possibly be explained by the pressure on budgets, reduced room for setbacks, less pressure from the government and a shift of core activities to lower levels of government. By the same token, one might also expect operational risks (quality, no room for error, right first time, etc.) to play a greater role in the profit sector. This is not confirmed by the results of our survey. For profit organisations, the low score for compliance can possibly be explained by the fact that non-profit respondents do not see a clear distinction between compliance risks and legitimacy risks. Finally, it is interesting to note that legitimacy risks also play a role in the profit sector. At 21.7 percent, that risk scores unexpectedly high, which can only be explained by possible contributions from commercially-oriented semi-government organisations. Figure 23 in particular shows the integrated nature of risks (or the lack of this integration). In it, the number of different types of risks that respondents take into account becomes clear. We draw a distinction in this between profit and non-profit. In profit organisations, all seven types of risk are taken into account in only 20.8 percent of the cases (2009: 16.5 percent). Non-profit organisations do this slightly more frequently: in 21.9 percent of the cases. Several things stand out, compared to 2009. Greater numbers of respondents adopt an integrated approach to assessing risk, with a significant increase for non-profit in particular: from 7.9 percent for a maximum of 5 to 21.9 percent for 7 risks. In this, nonprofit is now ahead of profit, which reflects the greater focus on and increase in the quality of risk management within the government/non-profit organisations. A similar picture – but more extreme – can be seen for ‘assessing 6 risks’ (4 in 2009). The significant difference between profit and non-profit is genuinely noteworthy, but difficult to explain. This also applies for ‘assessing/identifying 3 types of risks’, which scores highest in nonprofit and, together with ‘7 types’ would appear to be common practice in almost 45 percent of the cases. However, the picture for ‘4 types of risks’ is the exact opposite. For non-profit, the spread in the number of times is relatively wide, whereas in the case of profit organisations, the number of types of risk categories appears to be reasonably concentrated at 1 to 4, with one outlier towards integrated (is 7). It is almost encouraging that only 6.9 percent (for profit, compared to 4.8 percent for non-profit) of respondents still do not take a single risk category into account, where it is interesting to note that this is greater for profit than it is for non-profit. Of course, this is in line with the 13.3 percent that do not conduct risk assessments (see Figure 19). October 2014 Figure 23: Number of types of risks identified/assessed 20.8% 21.9% 7 6 5 1.2% 14.7% 4 13.7% 3 2 12.6% 1 Profit 0 Non-profit 4.8% 0 5 10 15 20 25 30 How many layers of management does your organisation have and at which levels of management are the risks assessed? The number of levels of management involved in risk assessment and analysis shows how widely spread risk management is across the business. In an ideal scenario, all layers of the organisation will be involved in drawing up a risk assessment and analysis. However, at first glance the results do not appear to offer much hope in this regard: in 75 percent of the cases, the Executive Board/Directors/first level management only is/are involved. The results from 2014 and 2009 cannot be compared directly (see caption below Figure 24), but in 2014 there does appear to be a trend for the assessment to be conducted at a higher and limited number of levels only. Figure 24: Risk assessment management level 2014 2009* Percentage Percentage Executive Board/Directors only 20.6 54.5 Executive Board/Directors and 1st management level 54.5 41.0 Risk assessment management level Executive Board/Directors and 1st and 2nd 19.3 23.2 Executive Board/Directors and 1st, 2nd and 3rd third management level management level 3.7 14.0 Executive Board/Directors and more than three management levels 1.8 2.3 * In 2009, this question was different since it asked about participation in each management level; as a result, several responses were possible and responses were not mutually exclusive. This also explains why the total exceeds 100% The above requires some qualification and the number of management layers in the organisation needs to be taken into account. If there is a big difference between the number of layers present and the layers in which the assessment takes place, we believe the above to be particularly concerning. Second National Survey of Risk Management in the Netherlands Figure 25 explains this and broadly confirms the above. There is a noticeable discrepancy between Executive Board/Directors only and Executive Board/Directors and first and second management level. The number of organisations with two or more management levels is almost 45 percent, but only 25 percent of risk assessments are conducted at these levels. In view of the fact that it is desirable for these assessments to take place across the business, this is somewhat surprising. It means that the risk management is not conducted at any great depth within organisations. Finally, we compared the organisational layer at which an ‘in control’ statement is requested with the number of layers and the risk assessments. This reveals a similar trend, in other words an activity/responsibility that is rising higher within the hierarchy. We believe this to be an important indicator of the risk culture and control awareness of the organisation. As long as this responsibility is not broadly shared and there is no accountability for it, risk management will never truly become part of the DNA of the organisation in our experience. We have established (see Figure 25 below) that there is a significant link between turnover and the number of management layers, but even in organisations with turnover in excess of 1 billion euros, there is still only limited participation by the third layer of management (10.5 percent). Figure 25: Management level of risk assessment compared to number of layers of management (in percentages) Number of layers of management How many layers At what level of management are the risks are there in the assessed? For which organisational level is an in control statement requested? company? Not applicable - 7.2 45.5 Executive Board/Directors 7.3 20.6 29.3 Executive Board/Directors and 1st layer 49.9 54.5 11.4 Executive Board/Directors and 2nd layer 33.3 19.3 3.6 Executive Board/Directors and 3rd layer 6.5 3.7 1.5 Executive Board/Directors and >3 layers 3.0 1.9 - Which techniques are used for risk assessment and analysis? The results show virtually no difference between profit and non-profit across the board. More regulated sectors, such as financial services and the energy sector stand out positively from the average. The quality of any risk assessment and analysis depends on the choice of techniques, the people and the sources used. The quality improves if many people are involved in it and different techniques are used simultaneously in order to access as many sources of information as possible. In addition, certain techniques are specific to particular sectors, with more quantitative techniques primarily being used in the financial sector. The results reveal that 68.8 percent of respondents use quantitative techniques and 87.1 percent use qualitative techniques. Relatively speaking, we find the first figure surprisingly high and it confirms the trend observed in practice for making risk management more tangible by quantifying it. October 2014 Significant increases can be seen for almost all techniques compared to 2009, with incident recording leading the way (see Figure 26). This is an indication of the increasing professionalisation of the discipline. In many cases, there are only very limited differences between profit and non-profit for the qualitative techniques and the increase is more or less the same. Document study (2014: 1 compared to 2 in 2009) and interviews (2014: 2 compared to 1 in 2009) have swapped places in terms of being the most popular technique. All of the newly-added techniques (not to be confused with new techniques) would appear to be primarily specialist in nature, achieving scores of around 10 percent. The technique of serious gaming/war gaming, which is to be classified as a relatively new technique, stands out from the rest by achieving a score of only 2.1 percent. Figure 26: Risk management techniques, 2014 compared to 2009, financial services, profit and non-profit (in percentages) Technique Average Financial services (N=64) Profit (N=475) 2014* 2009 2014* 2009 2014* 2009 Document study 73.7 38.6 71.9 39.1 73.5 Interviews 70.0 42.2 80.7 57.8 68.4 Workshop 40.6 17.4 68.4 34.4 Questionnaires/Checklist 69.7 36.8 82.5 56.3 Incident recording 69.7 24.7 89.5 42.2 72.6 Scenario analyses 57.3 31.0 82.5 48.4 60.0 Sensitivity analyses 33.3 19.3 57.9 34.4 38.7 Simulations 28.1 9.6 49.1 15.6 30.7 Stress testing 22.9 5.4 73.7 31.3 Value at Risk 23.1 8.7 59.6 32.8 Economic capital 16.1 5.7 47.4 29.7 Back testing 8.3 - 36.8 - Serious gaming/war gaming 2.1 - 7.0 Fault tree analysis 11.7 - 7.0 Fishbone method 11.3 - Hazard and operability study 8.0 - 10.5 - Non-profit (N=251) 2014* 2009 34.3 74.1 44.3 42.1 72.9 42.4 41.1 17.2 39.8 17.9 70.9 37.7 67.3 35.3 27.3 63.7 20.9 33.6 52.2 27.7 22.4 23.1 14.9 10.9 23.1 7.6 26.7 8.2 15.5 1.1 28.8 11.1 12.4 5.2 21.1 7.5 6.8 3.3 11.6 - 2.0 - - 2.3 - 1.6 - - 12.8 - 9.6 - 8.9 - 12.2 - 9.6 - 5.3 - 11.4 - 1.6 - 8.8 - 12.8 - 6.0 - (HAZOP) Failure Method and Effects Analysis (FMEA) * In 2014, six techniques were added to the set of tools (see table for the techniques that were not recorded in 2009) Second National Survey of Risk Management in the Netherlands Interviews, document studies, questionnaires and incident recording are seen to be the most frequently-used techniques, hovering around 70 percent. Enabling a proper dialogue about risks and the background to them and how to deal with them is more important than agreeing a risk profile. The process itself is more important than the result. In this respect, we are surprised by these results. The number of workshops has increased significantly since 2009, rising from 17.4 percent to 40.6 percent, but remains relatively low in our view. Another surprising result is that more than half of respondents make use of scenario analysis, making this technique the fifth most frequently used. 4.4 Risk management reporting and risk monitoring How frequent is internal reporting about risks? Internal reporting about risks is an important element of risk management. For senior management within an organisation, it makes sense to have a good understanding of the nature and scope of the risks being run by the various organisational divisions. Only if that understanding exists can a board truly assess the value of the financial and other performance of an organisational division. A properly-conducted risk management report gives a clear answer to the question of how much risk is involved in achieving the reported (financial) results. This kind of report also gives more senior management an understanding of what is happening lower down within the organisation and how the managers responsible are dealing with the issues. Of course, this primarily makes sense if the internal reporting is both periodic (preferably monthly, but in any case reflecting the P&C cycle) and ad hoc, whenever a specific situation calls for it. Our first impression is that there have been hardly any shifts/changes compared to 2009, suggesting a stable picture, with one, highly favourable, exception. Only 5 percent (2009: 11 percent) of respondents now indicate that there is no internal reporting about risks. This is a considerable improvement since 2009. It is likely that this 5 percent engage in hardly any risk management at all. In any case, conducting risk analysis without reporting on it is of little use. Without the reports, it is impossible to monitor or manage your risks. Figure 27: Frequency of internal reporting about risks Frequency 2014 (in %) 2009 (in %) Not applicable 5 11 Weekly 3 4 Monthly 22 23 Quarterly 42 38 Annually 33 31 Occasionally/ad hoc 20 29 October 2014 For the 95 percent (2009: 89 percent) of respondents that conduct internal reporting, it is worth noting that 33 percent (2009: 31 percent) does this once annually only. In view of the rapid changes in risks caused by the current dynamic, this figure is far too low. Surprisingly, if we distinguish between the results based on organisation size, this percentage is even higher for organisations with an annual turnover/budget in excess of € 1 billion. Unfortunately, this trend is not compensated for by occasional/ad-hoc reports. Here too, we still see a low score and further regression compared to 2009. Of the respondents, 42 percent (2009: 38 percent) reports internally about risks every quarter and 22 percent (2009: 23 percent) every month. In the financial sector in particular, almost half of respondents report on a monthly basis. This is in line with our expectations, in view of the reporting requirements laid down by supervisory authorities such as the DNB. The energy sector also largely reports about risk on a monthly basis. Only a very small group (3 percent) shows the response option “weekly”. In addition, 20 percent (2009: 29 percent) indicated that they (also) report about risks on an occasional/ad-hoc basis. What does an internal risk report include? Reporting about risks only really make sense if the report is tailored to the target group. This puts the recipient in the best position to carry out his or her duties and responsibilities and make decisions, take action and where necessary make adjustments. We therefore expect the report at least to include the most important risks, the status of the main management/control measures, the development of risks and the status of improvement measures. In general, the picture here is stable compared to 2009, with (slight) increases almost across the board. The status of the main control measures is the only thing that stands out slightly. Only ‘important external changes’ shows a slight decrease compared to 2009. Approximately 71 percent (2009: 66 percent) reports internally about the most important risks. Organisations also report frequently about incidents. This is understandable and makes complete sense: you learn from errors and further improve the risk profile. The other scores show that there is still a lot that can be improved. For example, critical risk indicators are hardly ever used now. Figure 28: Subjects included in internal reports Report about 2014 (in %) 2009 (in %) Most important risks 70.8 65.8 Status of the main control measures 46.7 37.4 Critical risk indicators 22.9 16.4 Development of/changes to risks 45.6 41.0 Incidents that have occurred 50.0 46.5 Important internal changes and consequences 29.9 29.9 Important external changes and consequences 30.6 31.8 Status of improvement measures 41.0 37.9 Second National Survey of Risk Management in the Netherlands When are the risks discussed? Risk management should preferably be anchored within regular management activities and primarily as part of the natural combination with the P&C cycle. This means that management and risk management coincide naturally. The time to discuss risks is during regular internal meetings of the Executive Board/Directors/management. There is also regular discussion of risks on an ad-hoc basis. Somewhere between 40 and 45 percent of respondents discuss risks as part of discussions about internal and external audit reports and at audit committee or supervisory board meetings. We consider this to be too low a percentage and it has even reduced somewhat since 2009. The low(er) score for business reviews/business plan progress discussions (just 26.2 percent) also stands out. This may be because it is now part of the planning & control cycle, which previously scored much higher for risk assessment and analysis or because of the frequency of monitoring/reporting on a quarterly basis. Another option is that this is partly cancelled out/covered by the higher score for budget discussions. The role of risk management in project progress meetings is also still low, although there has been a slight improvement since 2009. Figure 29: When do you discuss risks? Discussion 2014 (in %)* 2009 (in %) As part of Executive Board/Directors/Management Team meetings 75.6 66.0 As part of business reviews/business plan progress meetings 26.2 28.4 As part of discussions of internal and external audit reports 43.0 43.7 As part of audit committee/supervisory board meetings 44.1 45.9 As part of budget discussions 41.2 46.1 Ad hoc/ in the event of incidents/at major meetings 43.5 48.2 As part of project progress discussions 36.5 31.2 As part of the Annual Shareholders Meeting 10.7 - As part of consultations with external parties 20.7 - 9.8 - As part of risk committee meetings * Here too, several options were added to the questions in 2014 (see elements with no score in 2009) In organisations with an audit committee, risks are discussed at these meetings in 70 percent of the cases9. We consider this to be a low percentage, also in view of the fact that many corporate governance codes include the discussion of risks as best practice. It would appear that this has not hit home everywhere. Finally, the low score of 9.8 percent for risk committee meetings is extremely low. This may be related to the fact that still only few organisations – outside the financial sector10 – have separate risk committees. 9 356 respondents have an audit committee, but only 248 organisations discuss the risks with the audit committee. (248/356 = 70%) 10 In the Banks Code (Code Banken, 2009) published by the Dutch Banking Association (Nederlandse Vereniging van Banken) the risk committee is introduced as a subcommittee of the supervisory board. Committees of this kind focus on risk management in banks, but are still relatively rare in the Netherlands. October 2014 Do you use statements from the management responsible indicating that their organisational division is ‘in control’? Risk management becomes explicit when it is confirmed by means of an ‘in control’ statement. In the best-case scenario, this kind of statement serves to boost the quality of the underlying information and risk management. It is recommended that whenever the most senior management issues a statement of this kind, it is based on in control statements issued by lower layers of management. This is actually increasing since more and more organisations are obliged to issue an external in control statement, often as a result of corporate governance codes, such as the Dutch Corporate Governance Code. Almost 63 percent of the respondents do not make use of internal statements. Figure 30 below shows what the internal statement for the remaining 37% actually relates to. For this question it was possible to give multiple answers. Figure 30: ‘In control’ risks Risks* In the area of strategic risks Percentage (N=271) 27.3 In the area of financial risks 77.1 In the area of operational risks 54.2 In the area of (financial) reporting risks 50.2 In the area of legitimacy risks 33.6 In the area of compliance risks 46.9 * In 2009, there were only three potential answers to this question: no, yes for financial reporting or yes for all risk areas. In 2014, it is possible to provide a more nuanced picture of risk areas. Of respondents who indicated that they use this kind of statement for financial reporting risks, 18.5 percent (50 percent of those voting yes; 2009: 21 percent) are primarily in the profit sector. Strategic risks and legitimacy risks apparently play only a limited role. In view of the importance of strategic risks this is remarkable. For legitimacy risks this is explainable, as this primarily plays a role within governmental organisations/ non-profit organisations. This one-sided approach seems to agree with the integrated nature of the statements. There is still a large group that only prepares a statement on a single risk type (22.9 percent). Although the question was posed differently in 2009 (choices: no, only financial reporting risk, integrated risk) only the 21 percent score on financial reporting risks is comparable. A significant increase is visible in the scores for the integrated nature of the statement: 27.3 percent in 2014 compared to 10 percent in 2009. This means that the focus is on the more traditional risk groups. A comparison with 2009 is not possible. In 2009, there were three potential answers: • • • No, no ‘in control’ statement Yes, in the area of financial reporting Yes, in all risk areas (strategic, operational, financial reporting, legislation and regulations) Second National Survey of Risk Management in the Netherlands So, if an in control statement is used, which layers of the organisation does it ?apply to? The more layers of management are involved in an in control statement, the more successful an organisation is in conducting risk management effectively. Because the deeper the awareness of the risks (preferably down to the sinews of the organisation) and of the importance of being in control, the better the potential for effective risk management. As was to be expected, the percentage falls the deeper we go down the organisation. Interestingly, only 29 percent (2009: 22 percent) of respondents issue a statement to the highest layer of management. In the previous question, we saw that 37 percent (2009: 31 percent) works with an in control statement. It is possible that some of the respondents felt unable to answer yes to this question because they issue an external statement only. What is both surprising and concerning is that the level of penetration within the organisation is lower at all levels than in 2009, which means that the in control statement increasingly ends up with the Executive Board/Directors only. We believe that this fails to promote a culture of awareness of risk and control involving active and visible accountability. This point is reinforced further by the fact that the total percentage of organisations issuing a statement has fallen compared to 2009 (from 49.2 percent in 2009 to 46 percent in 2014). Figure 31: In control by organisational layer In control by organisational layer 2014 (in %) 2009 (in %) In control statement from the Executive Board/Directors 29.3 22.1 In control statement from the 1st layer of management 11.4 14.4 In control statement from the 2nd layer of management 3.6 8.1 1.5 3.2 0.8 1.4 In control statement from the 3rd layer of management In control statement from more than three layers of mgt. below Executive Board/Directors 4.5 Risk management and organisation Has the risk appetite been determined or recorded within your organisation? If risks are to be effectively managed, it is important to be clear about the extent of risk appetite. This provides an impression of what is considered to be a major or minor risk. Risk appetite also provides information about where action is required and perhaps even what kind of action. Without a clear-cut and explicit risk appetite, it is difficult to talk of integrated and enterprise-wide risk management. In response to the question as to whether risk appetite had been determined at all, 42 percent indicated that this had happened. This is a significant increase compared to the result reported in 2009 (31.8 percent). This is encouraging, in view of its importance and because many organisations still struggle to apply the concept of risk appetite to their business operations in practice. October 2014 Figure 32: Determining risk appetite Risk appetite characteristics* Percentage (N=305) Determined qualitatively 77.0 Determined quantitatively 68.2 Determined specifically for one or more risk groups 48.2 Risk appetite recorded 66.2 Risk appetite communicated 61.0 * These aspects were added in 2014 to the question about risk tolerance/appetite The quality of the risk appetite concept in an organisation (application, effect, etc.) is determined by various characteristics, as detailed in Figure 32. All of these characteristics score higher than 60 percent, with the exception of the specific approach adopted for certain risk groups. Although in practice risk appetite is often expressed in qualitative terms, the score for it being determined quantitatively is still almost 70 percent. It is strange that recording and communication score relatively low and are not approaching 100 percent, since this lies at the heart of the power of this concept. If applied, it sends out a clear message. Only in small, ‘simple’ organisations is it possible to forego this and still achieve an effect. The results cannot be compared to 2009, because the question has been changed (“Has risk tolerance been quantified?”). We can of course explore whether there are differences across sectors. This turns out to be the case. In the non-profit sector, it is communicated significantly more and risk appetite is also determined qualitatively more often. Figure 33: Determining risk appetite, profit – non-profit Risk appetite characteristics* Profit (N=226) Non-profit (N=79) Determined qualitatively 75.7 81.0 Determined quantitatively 68.1 68.4 Determined specifically for one or more risk groups 51.3 39.2 Risk appetite recorded 67.3 63.3 Risk appetite communicated 63.3 54.4 * N = 305 (42.0%) breaks down as 226 (74.1%) profit and 79 (25.9%) non-profit. Who coordinates the risk management activities? Of course, the management itself has ultimate responsibility for risk management in an organisation. However, we also see a role for a coordinator, often a central officer who serves as a facilitator. We therefore expect this to be a role for a central support department, preferably. Second National Survey of Risk Management in the Netherlands So why is this? Various departments and positions can serve as coordinators. The term coordination can sometimes prove confusing because it is open to interpretation. Some people argue that a situation involving various coordinating positions can cause problems. Others assert that the more positions are involved with risks, the more effective risk management will be. The respondents’ answers provide a few points of interest. First of all, the increase in the number of special risk management functions/departments. This is further supported by a reduction in the number of respondents with no organised function and a slight increase in the role played by the quality department. It is difficult to link this with Figure 7 on the subject of the CRO position, because based on that, an even higher score would have been expected. The same applies for the special committee (see link with Figure 34). Figure 34: Coordination of risk management Function A special risk management function/department 42 2014 (in %) 2009 (in %) 19.9 12.8 A special committee 7.3 6.0 Line management 30.4 33.9 The financial function 47.7 64.1 The insurance department 3.3 5.0 Internal audit/internal auditing service 15.0 17.7 The compliance department 9.8 7.4 The quality department 20.5 18.7 Not organised 5.2 6.7 The diminishing role of the first line can be explained in two ways. Either the respondents are applying the ‘three lines of defence’ concept more strictly (see also the next question), or risk management is primarily a line activity and part of regular business operations; seen this way, a decrease is unfortunate. It is not surprising that the financial function remains at the top, with 47.7 percent, although it has decreased significantly compared to 2009 (64.1 percent). Because some people were of the view that more than just one coordinating position or department should be avoided, we also calculated the number of coordinators. Most organisations, 48 percent, have a single coordinating position, 17 percent has two and 30 percent has three or more coordinating positions. The number of organisations applying the three lines of defence principle is 148 (22.5 percent). From the perspective of practice, this is still surprisingly low. Recently, a lot has been written and said about the lines of defence as a concept for organising governance in the field of risk, compliance and control. Incidentally, the theoretical and academic evidence for this is limited. October 2014 In our analysis, we therefore looked at the differences for each sector and each turnover category. The fact that the three lines of defence principle is primarily common practice in the financial sector is hardly very surprising. However, it is surprising to see telecommunications, information technology and entertainment in second place, in view of the low score for the level of maturity and the report mark/survey score. All of the other sectors are at a level of 24 percent or lower, with manufacturing being a sector in which the concept has made hardly any headway at all. Examining turnover size also confirms what might be expected, in other words that it is primarily large companies that know and apply this principle. Only in organisations with a turnover of 500 million or more is the figure of 42 percent reached. Figure 35 and 36 below provide a more detailed specification of the concept by sector and turnover size. Figure 35: Three lines of defence, by sector Three Lines of Defence by sector Application of Three Lines of Defence (in %)* Trade 23.7 Transport & Logistics 24.0 Manufacturing 8.7 Financial services 66.67 Commercial services 13.3 Telecommunications, IT and entertainment 33.3 Energy & Utilities 22.2 Healthcare 12.1 Government/Non-profit 14.6 * N = Number of organisations per sector. Figure 36: Three lines of defence, by turnover Three Lines of Defence by turnover Application of Three Lines of Defence (in %)* 0 - 50 million 9.9 51 - 100 million 18.6 101 - 500 million 27.9 501 million - 1 billion 42.3 > 1 billion 73.7 * N = Number of organisations per sector. Which standards do organisations apply when setting up risk management and internal controls? Best practice is to use a widely-accredited standard. There may also be specific standards for certain areas such as IT, or for sectors, such as the financial sector. Second National Survey of Risk Management in the Netherlands The results for the question as to which standard organisations apply also came as a surprise. We were not expecting to see a mind-boggling 51.3 percent still not applying any standard at all, although this score has improved since 2009. Although there is no guarantee that the use of a model is necessary in order to manage risks, some kind of reference is helpful. It is not a surprise that COSO is still at the top of this list, although not particularly convincingly, despite people’s frequent references to COSO. INK comes second and is fast catching up with COSO. The emergence from nowhere of ISO to reach number three with a modest 12 percent and definite potential is also surprising. In all cases, there is an increase compared to 2009, although this is still not particularly convincing. The previous survey in 2009 revealed that 63.2 percent did not make use of a standard/model. Figure 37: Overview of standards used (in percentages) Standard Financial services (N=57) 44 Profit sector (N=475) Non-profit 2014 2009 sector (N=251) No standard 10.5 49.1 47.8 48.6 63.2 COSO 64.9 29.5 20.3 26.3 21.2 INK/EFQM model 10.5 14.5 31.5 20.4 14.4 ISO 31000* 17.5 12.0 12.0 12.0 - 6Sigma 5.3 10.3 3.6 8.0 3.7 Basel/Solvency 63.2 11.2 1.2 7.7 4.7 Management of Risk (M_o_R)* 3.5 4.6 4.4 4.6 - Australian/New Zealand 1.8 0.4 1.2 0.7 0.3 OCEG 1.8 0.4 0.4 0.4 0 AIRMIC 1.8 0.2 0.4 0.3 0 Others 19.3 10.9 13.1 11.7 7.5 * In 2009 this was not included as a category since ISO 31000 had not yet been published. The same applies to Management of Risk, but this was because it was unknown at that time. The following differences between sectors are also worthy of note: • • • • • As expected, INK/EFQM is primarily applied in non-profit organisations. ISO31000 is applied relatively little in the profit sector. We know of no logical explanation for this, particularly since ISO guidelines are used a lot in industrial environments. 6Sigma has a high level of penetration in the profit sector. There is, however an explanation for this: it is originally a manufacturing concept. Basel/Solvency is only applied in the financial sector (no explanation required), but still achieves a surprising score of 63 percent, since it is mandatory for insurance companies and banks; one would expect it to achieve a score in the lowest quartile unless it involves financial institutions other than banks and insurance companies. Management of Risk and OCEG occur primarily within the profit sector. October 2014 Which software is used? The use of software is not necessary in itself, but improves efficiency and therefore the further professionalisation of risk management. There are many options for supporting the risk management process. Certain larger and/or more developed organisations in the field of risk management use software. The answers given demonstrate that people may not be fully up to speed with the possibilities of the packages they have purchased. For example, every Enterprise Resources Planning (ERP) package now has ‘segregation of duties (SoD)’ built into it as standard. This category should therefore have achieved a much higher percentage in the table below (Figure 38) if the respondents had been aware of that. Senior management is probably insufficiently familiar with IT to answer this question properly or – and this is less likely – it does not classify SoD as a risk management tool. We asked which software organisations use in order to support the implementation of risk management. The results are more positive than in 2009 and reflect the trend towards the increasing importance of technology in managing risks. This trend can also be seen in the increasing professionalisation and consolidation of GRC software companies in recent years. In 32,3 percent of cases, no software is used. Compared to the 2009 survey (73.8 percent), this has fallen significantly, which means that the use of software has increased. The question from 2009 has been supplemented to include the integrated software solutions (referred to as vendors) that are the most well-known, applied and developed according to Gartner/Forrester. In the Dutch market, the scores for these solutions are very low. SAP/GRC are the only ones that can claim to have any presence. A diversity of solutions, including self-built ones in Excel or Lotus Notes for example still seem to have the upper hand. There is clearly still a lot of progress to be made and growth to be expected in the future. Figure 38: Risk management software application and vendors Risk management software Percentage No (supporting) software 32.2 Nasdaq OMX Bwise 0.8 EMC (RSA Archer) 0.1 Thomson Reuters (Accelus) 0.4 SAP (GRC) 3.3 IBM (OpenPages) 0.3 Software AG (Aris) 0.7 Wynyard (Methodware) 0.1 Self-developed software 10.9 Other software 15.6 The results for functionalities supporting risk management are still depressingly low even in 2014. There is no clear trend towards improvement and there is even a slight worsening between 2009 and 2014 (see Figure 39). Second National Survey of Risk Management in the Netherlands Only 1.4 percent of respondents claim to use segregation of duties (SoD) software. We conclude from this that many of the respondents do not understand the standard software – for example ERP systems that are supplied by SAP and other software organisations – but still use them. The percentage of users of this type of standard software is actually expected to be much higher and therefore the figure of 1.4 percent (2009: 1.5 percent) should also be much higher. Figure 39: Use of software for and in support of risk management Other support software 2014 (in %) 2009 (in %) Brainstorm software 1.2 1.3 Voting software 2.1 2.7 SoD (segregation of duties) software 1.4 1.5 Data-analysing software 6.8 6.4 Process management software 8.0 10.2 Internal audit management software 5.8 7.7 Monitoring software 6.9 5.6 Performance management software 6.1 7.1 Other support software 4.0 5.8 What form does the external reporting about risk management take? Broadly speaking, the same applies for external reporting as for internal reporting. Relevant issues to include are: clarity about the integrated risk profile, the changes in it, the way it is managed and the key measures taken. Corporate governance codes mean that external reporting about risks is increasingly becoming common practice. We also assume that external reports have a positive impact on the level of risk management. This is because in order to report, you also need to start collecting data. Comparing the results from 2014 to those from 2009 reveals that reporting has generally increased and improved: in 2009, 25.4 percent of respondents said they reported nothing, and this has fallen to 16.7 percent; almost all categories score higher than in 2009. Slightly more than half of all respondents report financial risks. Although more or less all corporate governance rules insist that organisations report at least about finance or financial risks, the results are nowhere near 100 percent. From this, we conclude that there is a lot of room for improvement. October 2014 Figure 40: Contents of external risk management reports (in %) Report includes 2014 (in %) 2009 (in %) The way in which risk management was set up 37.2 30.5 Effectiveness of risk management/internal controls (all risks) 14.8 12.0 Effectiveness of risk management/internal controls (financial risks) 20.0 13.1 Risk tolerance in a qualitative sense 11.6 5.3 Risk tolerance in a quantitative sense 7.2 5.2 The most important strategic risks 41.4 36.8 The most important financial risks 53.0 53.8 The most important (financial) reporting risks 14.9 10.6 The most important operational risks 31.7 33.7 The most important compliance risks 17.9 11.3 The most important areas for improvement/measures taken 25.8 27.1 The most important incidents that have occurred 18.2 19.2 The material consequences of incidents 9.0 9.5 The most important changes in our risk profile and internal control system 15.0 12.4 Nothing 16.7 25.4 The slight fall in operational risks (from 33.7 percent to 31.7 percent) is worth noting. On the other hand, the relatively significant increase in compliance risks can easily be explained in today’s world. The decrease (albeit slight) seen for the most important points for improvement/measures taken is counter-intuitive in view of the requirements set by society and attempts to make the information more accessible to readers/users. The figure for ‘contents of external reports’ also clearly demonstrates that the risk tolerance is generally not mentioned either in qualitative or quantitative terms in external reports, although the former does feature to some extent. External reporting elements by turnover category (Figure 41) show that the larger the organisation, the more it is likely to report about risk management and to do so more effectively. Interestingly, the turnover category 101 - 500 million is an exception to this rule on several occasions. We have been unable to find an explanation for this. Finally, there are several notable exceptions in the picture portrayed of a linear improvement by turnover: • • • the distribution across turnover categories for effectiveness of risk management/internal control for financial risks (no clear picture that can be explained); an outlier in the turnover category 501 - 1000 million for most important changes in our risk profile; the above also applies to a slightly lesser extent for (financial) reporting risks. Second National Survey of Risk Management in the Netherlands Figure 41: Contents of external risk management reports by turnover category (in percentages) Reporting by turnover (in millions) 0 - 50 51 - 100 101 - 500 501 - 1000 >1000 The way in which risk management was set up 29.8 33.3 44.8 65.4 73.7 Effectiveness of risk management/ 11.4 10.9 18.6 26.9 52.6 20.2 17.3 23.3 15.4 31.6 8.4 11.5 10.5 23.1 52.6 internal controls (all risks) Effectiveness of risk management/ internal controls (financial risks) Risk tolerance in a qualitative sense Risk tolerance in a quantitative sense 6.0 6.4 5.2 15.4 21.1 The most important strategic risks 35.8 42.3 42.4 61.5 84.2 The most important financial risks 48.5 57.1 52.3 69.2 84.2 The most important (financial) reporting risks 12.7 13.5 13.4 42.3 31.6 The most important operational risks 26.2 35.3 34.3 50.0 57.9 The most important compliance risks 13.6 17.3 19.8 46.2 63.2 The most important areas for improvement/measures taken 23.5 30.1 25.0 38.5 42.1 The most important incidents that have occurred 17.8 19.9 18.0 15.4 26.3 The material consequences of incidents 9.4 8.3 7.0 11.5 15.8 The most important changes in our risk profile/internal 11.4 16.7 14.5 66.7 47.4 18.1 18.6 14.5 11.5 - control system Nothing 48 October 2014 5. Risk culture In the lead-up to our survey in 2009 and in the light of the results, we often had intensive discussions about the role of culture in the quality of risk management and whether this can be incorporated in a questionnaire. This is because a balance needs to be struck between sufficient relevance/depth and a questionnaire that is attractive/convenient and quick to complete. At the time, we took the view that this was difficult, if not impossible and adopted an alternative approach. We need to look at the way in which organisations configure risk management; it is – as we said at that time – a reflection of the risk culture/control environment and the importance that organisations attach to risk management. Who is involved, how often, and is there a dedicated function/position, a clear scope of risk, how is accountability provided, etc. This may not be completely watertight, but we are still of the same opinion. Despite this, when it came to the new survey, we were determined, partly in view of the discussion in recent years and the actual reconfirmation of the role and importance of risk culture, to address this issue more emphatically in the questionnaire. The risk culture/control environment actually forms the foundation for the setting up and above all the effectiveness of the risk management system. Unfortunately, this was again confirmed in all of the corporate scandals (including in the non-profit sector!) of recent years in the Netherlands and beyond. As well as the fundamental lack of effective control measures, there was always something amiss with the culture. We opted to gain an impression of the risk culture by asking about management involvement, the relationship with appraisal and remuneration (incentives) and a number of statements describing the control environment. We make no claims that the questions below are exhaustive or cover the issue adequately (if that is at all possible with a questionnaire/self-assessment alone). We present the results below, together with a brief analysis. Who writes the risk section in your annual report? The annual report constitutes the only formal way of reporting and providing accountability to all external stakeholders, including society as a whole. The risk section has been part of the annual report for many years and has recently evolved further in terms of its size, depth and relevance. In our view, the importance attached to risk management can be seen reflected in the management function and position responsible for writing and compiling the report. Although no comparison with 2009 is possible, it is interesting to note that it is the financial function, with more than 50 percent of the response, that writes the risk section. This can partly be explained based on the traditional perspective of the role played by the financial discipline in risk management and internal controls and, on the other hand, by the fact that it is not yet common practice to have a separate risk management officer in every organisation (for more on this, see the question and analysis about the CRO and coordination of risk management). Second National Survey of Risk Management in the Netherlands Figure 42: Official responsible for writing risk section Function Number Percentage Not applicable 128 17.7 Managing Director/CEO 168 23.2 The financial function 383 52.8 The risk manager/IC officer/GRC officer 130 17.9 Secretary to the board/secretarial function 40 5.5 Legal department 14 1.9 Other 55 7.6 The low score for the legal department is worth noting because we have the impression that the legal department actually plays a major role in compiling the report on some occasions, for example in terms of what information is placed in the public domain. The same applies, to a lesser extent, to the secretary of the board, which is after all a specialist position. We do not consider the score of 23.2 percent for the Managing Director/CEO to be a bad figure, in view of the role we accord to line management with regard to risk management and because respondents were able to give several answers and the Managing Director/CEO is often jointly involved. The answers to the culture question also show that the risk manager actually contributes to the risk section in very limited cases only, despite the fact that he or she coordinates risk management. In only 36 percent of the cases in which a CRO has been appointed (210), is he or she involved at board level (76 of the 210). How is the remuneration and appraisal system linked to the effectiveness of risk management? Incentives, positive or otherwise, play a central role in people’s actions and the choices they make. This also applies to risk management. The amount that people focus on and the importance they attach to risk management is encouraged by the appreciation and any reward, material or otherwise, that they receive for it. This needs to be embedded within the position and job descriptions as well as in personal (annual) plans. In view of the context described, it is disquieting to note that in only 9 percent of the cases there is actually such a formal and direct relationship between the effectiveness of risk management and the remuneration and appraisal systems. There is no such relationship at all in 66 percent of the cases. In our view, this does not facilitate the permanent embedding of risk management within the organisation (in the organisation’s DNA) or help make it part of day-to-day activities. We have no clear explanation for this, apart from the possibility that respondents do not see the relationship as clearly as we do, something that is confirmed by a relatively low score of 1.9 and 2.1 for the last two statements on the next pages. We would however go so far as to say that there are still a lot of potential improvements in this area that can be relatively easily achieved. October 2014 Figure 43: Relationship between remuneration/appraisal and risk management Function Number Percentage There is no direct formal relationship between the effectiveness of risk management and the remuneration and appraisal systems. 65 9.0 There is no direct relationship, but risk management is taken into account informally in the remuneration and appraisal systems. 181 25.1 There is absolutely no relationship between the effectiveness of risk management and the remuneration and appraisal systems. 475 65.9 Total 721 100 Eleven statements about risk management in relation to culture In order to gain an impression of the risk culture, we presented a series of 11 statements to the respondents about various subjects relating to risk management11 that we feel reveal something about the role and importance of risk management in the organisations surveyed, as well as the extent to which it is embedded within them. Respondents were asked to rate the questions on a scale from 1 (completely disagree) to 5 (completely agree). Because the survey was by nature a self-assessment, it is justifiable to ask whether there is a social desirability bias in the responses or whether they are an approximation of the reality seen from the perspective/context of the respondent. We were unable to rule this out by means of cross-checks. In view of these limitations, the high score for the inherent importance of risk management for good business operations stands out. In practice, and especially in view of the other scores, we have the impression that risk management remains very much a compliance-driven activity that is either enforced or elicited by means of incentives. This score surprises us and appears to confirm social desirability bias. The same can be said for the statement: “it is permissible to make mistakes, as long as you learn from them”. But we cannot draw the same conclusion for the answers to one of the previous questions. The positioning of risk management and the filling of a position in that area would appear to confirm what we already knew, including the complaints from the business about the quality of risk management or risk managers. Although we cannot of course tar everyone with the same brush, this does appear to be a fundamental problem, especially if we bear in mind that 50 percent of respondents were board members. They can break through this by raising the status of risk management and the people who work in it to a higher plane and give quality (including knowledge of business) a priority in filling positions in this area. The focus on short-term results also scores relatively low and seems at odds with the experience of many people both within and outside organisations at least. This may also be an example of social desirability bias, which we cannot dismiss based on other evidence or insights. Moreover, many of the responses appear to opt for the security of the centre ground, with a score around 3.5 and an acceptable and definitely not outstanding standard deviation in all cases. 11 Based on The Institute of International Finance, 2012 Second National Survey of Risk Management in the Netherlands Figure 44: Score for statements Statements Average score Standard (scale 1-5) deviation 1. Risk management takes place because it contributes to better business operations and is not seen as a cost item. 3.9 0.92 2. Staff are encouraged when they take risks to do so from a wellconsidered position. 3.6 0.95 3. A position in risk management is seen as a boost to your career. 2.5 0.96 4. It is permissible to make mistakes, as long as you learn from them. 4.0 0.80 5. The culture in our organisation promotes risk management. 3.2 0.98 6. Breaches of internal rules are taken seriously and are punished. 3.2 1.00 7. The Executive Board/Directors is/are very committed to risk management and actively support(s) it. 3.5 1.01 8. Employees feel at liberty to draw risks to the attention of their line managers. 3.7 0.81 9. In our organisation, the emphasis is primarily on short-term results. 2.5 1.11 10. The remuneration structure promotes risk-taking. 1.9 0.99 11. A clear link is made between achieving goals, risks and remuneration. 2.1 1.08 Figure 45: Score for statements by sector Statements by sector 1 2 3 4 5 6 7 8 9 10 11 Trade 3.88 3.61 2.43 3.96 3.21 3.35 3.41 3.70 2.43 1.94 2.03 Transport & Logistics 3.76 3.36 2.48 3.88 3.28 3.32 3.32 3.72 2.44 2.00 2.56 Manufacturing 3.79 3.51 2.54 4.07 3.16 3.23 3.31 3.71 2.56 2.25 2.46 Financial services 4.04 3.74 3.09 3.84 3.70 3.67 3.93 3.89 2.28 1.91 2.91 Commercial services 3.95 3.59 2.40 3.98 3.13 3.28 3.50 3.78 2.85 2.02 2.17 Telecommunications, 3.41 3.59 2.29 4.11 2.94 3.12 3.35 3.59 3.00 2.59 3.06 Energy & Utilities 4.17 3.67 2.83 3.89 3.22 3.67 3.72 3.50 2.83 1.40 2.50 Healthcare 3.96 3.57 2.33 4.14 3.12 2.97 3.55 3.56 2.56 1.68 1.69 Government/Non-profit 3.99 3.42 2.21 3.35 2.85 2.88 3.35 3.55 2.35 1.49 1.62 IT and entertainment October 2014 Figure 46: Score for statements by turnover Statements by turnover 1 2 3 4 5 6 7 8 9 0 - 50 million 3.87 3.54 2.42 51 - 100 million 3.90 3.45 2.36 101 - 500 million 3.95 3.60 3.50 501 million - 1 billion 3.92 3.65 2.58 > 1 billion 3.95 3.79 3.32 10 11 4.03 3.15 3.06 3.42 3.67 4.02 3.03 3.16 3.37 3.69 2.45 1.74 2.05 2.50 1.95 2.06 3.96 3.18 3.38 3.50 3.69 3.08 3.45 3.50 3.66 2.67 2.10 2.19 3.58 2.27 2.12 2.54 3.69 3.63 3.84 4.00 3.53 3.05 2.26 2.63 Report marks for risk management seen from a different perspective Despite all of the reservations about the risk culture scores, we are curious to see what the results of the risk culture section mean for the total score. The score guide was based on seven quality aspects (see Appendix 2) to which we added the element ‘Risk culture in the DNA’, but with a different weighting. Unless there is a reasonable ‘Risk culture in the DNA’ score, risk management cannot be of good quality and is nothing more than window dressing. However we choose to weight this additional quality aspect, the total score for the quality of risk management falls significantly. Below, we have included two variants for the effect that DNA has on the survey score: 1. DNA is weighted the same as the other seven aspects (15 percent contribution); 2. DNA is given a greater weighting, approximately one third of the total (30 percent contribution). The results speak for themselves: the difference between the self-evaluation score and our scores merely increases further. We would like to emphasise once again that this contributes to the discussion of the role of risk culture in organisations, but that the depth and scope of our questions are not sufficient in order to draw any wellsubstantiated conclusions in this area. Figure 47: Total score with weighting, compared to self-evaluation Average report Survey score weighting Survey score weighting mark (self-evaluation) 85% - 15% 70% - 30% Trade 6.86 4.21 3.95 Transport & Logistics 6.76 4.58 4.38 Manufacturing 6.90 3.94 3.72 Financial services 7.55 6.01 5.74 Commercial services 6.82 4.29 4.03 Telecommunications, IT 6.67 3.78 3.53 Energy & Utilities 7.11 4.95 4.67 Healthcare 6.75 4.36 4.06 Government/Non-profit 6.59 4.10 3.81 Total 6.85 4.32 4.06 Sector and entertainment Second National Survey of Risk Management in the Netherlands 6. Two alternative perspectives 6.1 Another look at the dataset, with two different questions Based on the research data we collected for the survey, we put two other questions. Firstly: Do organisations that say they use Enterprise Risk Management also perform better? You will find the answer in section 6.2. Secondly, we asked: What factors make a positive contribution to a more mature risk management system? We provide the answer to this in section 6.3 – you can consider this as a series of very concrete recommendations for your own organisation. 6.2 Enterprise Risk Management, automatically a higher score? In recent years, increasing numbers of organisations have instigated Enterprise Risk Management (ERM) in order to manage risks. Unlike the traditional approach to risk management, in which risks are seen from various organisational divisions or perspectives, ERM assumes that the entire spectrum of risks is seen in a more integrated way. This means that in the ERM, strategic, operational, reporting and compliance risks are all handled simultaneously. The aim of an approach of this kind is to help businesses to deal with opportunities and risks. The assumption here is that it helps organisations to manage risks and seize opportunities more effectively. So far, this has not proven to be an easy task for many organisations as all kinds of things can still go wrong. Another message one might take from this is that it is not realistic to assume that incidents will no longer ever occur after the implementation of this kind of system. Outlining the advantages and disadvantages of implementing ERM is also far from straightforward. Some studies have shown that it becomes cheaper to provide for capital requirements and that the allocation and use of capital is improved (COSO 2004). The development and implementation of an ERM system calls for the investment of a great deal of time, knowledge and resources. The question is whether the advantages outweigh the costs incurred. Obviously, ERM costs money and if it delivers no observable results, its introduction can be placed in doubt. We conducted research to find an answer to this question. Statistical analyses were used to investigate whether an ERM system has an impact on business performance. The expectation is that the higher the value of the ERM, the greater the benefits for the organisations. Below, we provide a summary of the most important results. Opportunities for growth We asked respondents the extent to which ERM was beneficial in terms of the organisation’s opportunities for growth. Businesses with potential for growth face uncertainties with regard to future cash flows and this would make them more inclined to introduce ERM (Liebenberg and Hoyt, 2003). Growth should lead to an increase in the value of the business and of course that calls for a weighing up of the risks and potential returns. In this process, risks are identified, consequences assessed and additional measures taken in order to manage risks. ERM can assist in this. October 2014 Unfortunately, our research did not show that ERM has a positive influence. It would appear that fast-growing organisations do not see the benefit of ERM. Profitability We also asked respondents to what extent ERM made a positive contribution to profitability. It is assumed that if respondents rate their ERM system highly, this will imply a similarly high contribution to profitability. After all, looking at risks in an integral way makes it possible to limit the volatility of profit and therefore also the predictability of the results. Unfortunately, we were unable to identify any positive relationship on this point in our research. Cost of capital The respondents then gave an indication of the extent to which ERM proved beneficial in terms of capital costs. Does it result in lower capital costs? Capital costs are directly influenced by the risk profile. Investors demand a higher return if a business takes more risks. When ERM has been fully implemented, the business has more information of higher quality about its risk profile. This information can be shared with investors, which results in more transparency about (future) risks. This kind of information should primarily be of importance for businesses whose activities are complex, because such businesses are difficult to assess from the outside. The management of risks also improves the business’s own perception of its risks. This improved perception could in turn result in the financial market demanding lower risk premiums on shares and loans and permit a lower level of solvency (more internal equity capital compared to external equity). Ultimately, this should lead to a reduction in capital costs. This indeed proved to be the case. Reputation Finally, we investigated the extent to which ERM improves reputation. We assume that the higher respondents rate their ERM, the more it contributes to their reputation. The sections about risk management in the annual report imply that companies are increasingly aware of the need to analyse a wide range of risks and to see which measures have been taken to reduce these risks. The awareness of the risks and the management of these risks, result in protecting the organisation’s image and contributing to reputation. This also proved to be the case. 6.3 Risk management maturity, how do you make progress? The survey provided a wealth of valuable information on the question of which factors contribute to a higher rating for the risk management system in an organisation. This means that you can immediately benefit from this. Your Chief Risk Officer will provide assistance, involvement of the board is crucial Because risk management is increasingly becoming a strategic affair, more and more businesses are appointing a chief risk officer (CRO) to take ultimate responsibility for risk management. On the one hand, the CRO is responsible for coordinating risk management and communicating the objectives and results to the Executive Board and investors. Second National Survey of Risk Management in the Netherlands This enables an organisation to reduce the likelihood of asymmetric information between representatives of the company and shareholders. On the other hand, the CRO plays a leading role in promoting risk management among managers. In addition, the CRO should ensure that the risk management system is in line with the organisational strategy. In the public management letter from the NBA (Netherlands Institute of Chartered Accountants, 2013), there is no explicit reference to a CRO as holder of the risk management function, but it has been shown in practice that only one third of respondents have appointed a CRO and a quarter have placed ultimate responsibility for risks at the top of the organisation. Our research shows that the appointment of a CRO is indeed to be recommended, since it results in a higher score for the risk management system. However, what is strange is that the CRO that does not act at senior management level scores considerably better than one that is a member of the team of directors. This means that as risk champion, the CRO has been shown to have added value in the field of risk management. The appointment of such an officer is therefore very much to be recommended! Audit committees: more visibility and relevance required (and less technology) The audit committee (AC) was introduced in order to supervise executive management and in particular its duty to provide reliable financial reporting. Since 2008, it has been a legal requirement in the Netherlands for what is termed ‘a public interest organisation’ to appoint an AC. This is the result of the compulsory implementation in the Netherlands of European Directive 2006/43/EC on statutory audits. One of the areas of focus of an AC in fulfilling its role as supervisory body is risk management and internal controls. The AC must regularly discuss the most important risks and the way in which these risks are managed in consultation with the Executive Board/Directors and the AC can exert an influence in these consultations. For example, the AC can encourage management to focus sufficient attention on the risk management system and on freeing up resources to develop the risk management system further (Paape and Speklé, 2012). However, an AC must meet certain requirements: an effective AC must have expertise in, time for and involvement in day-to-day affairs in order to be able to fully and effectively assess all the risks. It does seem to be the case that the AC has a positive influence on risk management. An AC primarily scrutinises risk management from an instrumental perspective, but our survey suggests that respondents do not perceive it to have sufficient relevance yet. Respondents indicate that an AC does not contribute to a higher score for the risk management system. ACs can therefore still make further headway in this area. International diversification as a natural mechanism for risk management The Netherlands has always been an exporting country and in 2003 it was even the second most important exporting country in the European Union for the sixth consecutive year (CBS/Statistics Netherlands, 2014). This means that organisations that have diversified internationally play an important role in the Dutch economy. But organisations that operate internationally face more complicated risks (Wagner, 2010) and the concomitant increase in complexity of the organisational structure means that the behaviour of organisations is less predictable for investors and therefore more difficult to monitor. October 2014 Leaven and Levine (2007) argue that this creates room for opportunism. On the other hand, international diversity helps reduce risks according to the portfolio theory. This is achieved by the imperfect cohesion between various areas and markets (Carson et al, 2008; Song and Cummins, 2008). This means that diversity also leads to a need for a more advanced organisational structure in order to transfer knowledge, coordinate activities and effectively allocate resources (Lang and Stulz, 1994). International diversification is therefore a new variable added to the survey into risk management in the Netherlands. It is possible to conclude from our survey that international diversification results in a more mature risk management system. However, far from all organisations that operate internationally have the same level of maturity when it comes to their ERM. One third has no plans to introduce a risk management system and one fifth is still thinking about it. One explanation for this is that these organisations assess and manage their risks in a different way. Auditors increasingly focusing on risk management In their role as auditors, accountants have not emerged from the crisis unscathed, as was shown all too clearly in the article ‘Financial Crisis and the silence of the auditor’ (Sikka, 2009) targeted at the Big4 accountancy firms. Even the Financial Markets Authority has expressed its criticism of the auditing quality of the accountancy firms. This has led, among other things, to new legislation on the compulsory rotation of auditors in listed companies, new requirements with regard to independence (Regulation on the independence of auditors in insurance engagements, ViO in Dutch) and revised codes of conduct and professional rules (VGBA) as well as the more recent reform proposals presented by the sector and described as ‘in the public interest’. This is all primarily aimed at the Big4 accountancy firms and our survey shows that it is they who are primarily taking the lead in this discussion. Companies that are audited by the Big4 have a higher level of risk management maturity than those that are not. This finding is in line with Beasley et al. (2005). Another key development that will contribute to an increased focus on risk management is the customer-specific auditor’s statement. The Big4 accountancy firms experimented with this for the first time for the financial year 2013, which may explain part of the Big4 effect. In this statement, the auditor explains the most important control risks identified, the tolerances applied, the going concern assumption and potentially also the scope of the group audit. The aim of this new statement is to provide more information to the user of the annual accounts with regard to what the auditor has actually done. After all, the user wishes to know which areas of risk have been identified by the auditor and what action he or she has taken in response (PwC, 2014). A fresh perspective does wonders An offshoot of this new legislation for auditors is that public interest companies are obliged to change auditors more frequently. Although the jury is still out with regard to whether this is of benefit for the audit and there is actually evidence to suggest that it has a negative impact on quality, especially in the first three years after appointment, this new legislation is a fact. Auditors may be expected to focus on risk management in the planning phase (customer acceptance and risk analysis). The auditor uses the client’s own risk analysis for this purpose. The company’s internal risk management system and the auditor’s discussion with the client about this could challenge companies to reflect on their risk management system and the new auditor could offer a fresh perspective on this. Second National Survey of Risk Management in the Netherlands This impression would appear to be confirmed by this partial survey which identifies a statistically significant relationship between a change of auditing firm in the last three years and a higher score for risk management maturity. In addition, companies that have changed auditors appear (although not to an extent that is statistically significant) to be slightly more negative about their risk management systems, which could on the one hand mean that a fresh perspective from a new auditor leads to an understanding that there may still be shortcomings in terms of internal controls and risk management. On the other hand, a change of auditor may lead to a more realistic assessment of an organisation’s own risk management, and therefore less difference between the organisation’s own perception and that of the auditor. However, because the results are not significant, further research will be required on this. If the influence of a change of auditor is measured using the score guide, it appears that the fresh perspective of a newly-appointed auditor is not statistically observable. Risk management as a response to supervision The requirements of supervisory authorities are seen by businesses as the minimum requirements that the business must meet as a form of compliance, as well as a form of licence to operate. Risk management is just one of the instruments used to achieve that (for example in the form of incident management). This means that as an instrument, risk management can serve as a form of legitimacy vis-à-vis supervisory authorities in order to demonstrate that the aspects of supervision are being sufficiently managed. Based on the institutional theory introduced by Powell and DiMaggio 1983, isomorphisms (mirroring) can be used to explain risk management being seen as an accepted method of compliance within a sector. Compared to other sectors, financial institutions have specific requirements with regard to risk management and an obligation to apply the three lines of defence principle. The DNB’s specific focus on risk management (partly in the form of its research on the theme of risk management) is also quite logically expressed in the governance codes of financial institutions. This also supports the theory of normative isomorphism, risk management as a form of compliance. In other words, supervision as a form of enforced risk management, but legitimised as best practice for organisations. Governance codes form a relevant boost, also in the case of self-regulation Governance codes as a whole make a positive contribution to the maturity of risk management, compared to sectors were no code applies. It is interesting to note here that (non-listed) financial institutions have a higher maturity score than unlisted companies, which can be explained by the more explicit focus on risk management in the codes of the financial sector. The most startling result from this survey is that the (semi-)public sector, which involves working with the help of codes of conduct, has clearly undergone a positive development in terms of the maturity of its risk management system in the space of five years. This provides proof that self-regulation in the form of codes can make a positive contribution to the maturity of risk management. Governance codes as a boost for risk management in the public sector actually work! Institutional investors speak out! As was the case in 2009, companies whose ownership is in the hands of institutional investors have been reluctant to speak publicly about their risk management and have not participated in the survey in large numbers. 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North Carolina State University working paper. Pagach, D., Warr, R. (2010): The Effects of Enterprise Risk Management on Firm Performance, Working Paper, North Carolina State University, Raleigh Pooser, D.M. (2012): An Empirical Examination of the Interrelations of Risks and the Firm’s Relation with Enterprise Risk Management. (3539604 Ph.D.), The Florida State University, Ann Arbor. Retrieved from http://search.proquest.com/docview/1095535349 ProQuest Dissertations and Theses Full Text database. Posthumus, G.J. (2014): Risicomanagement in Nederland - Een onderzoek naar het effect van de Chief Risk Officer, Audit Commissie en Internationale diversificatie op het volwassenheidsniveau van risicomanagement anno 2014, Master’s thesis, Accountancy and Controlling, University of Groningen 62 PwC. (2014): Klare taal! Nederlandse beursfondsen. Benchmark controleverklaringen ‘nieuwe stijl’ onder Weick, K.E., Sutcliffe, K.M. (2007): Managing the Unexpected, 2nd ed. John Wiley and Sons, San Francisco October 2014 Appendix 1: Methodology Survey In order to assess the current status of risk management, a survey was used. This type of research is frequently used in academic literature in order to gauge the status of risk management (e.g. Kleffner et al. 2003; Beasley et al., 2005; Gates et al., 2012). A conceptual model was developed for the previous survey (see graphic in Appendix 4) and this served as our framework. It has also been used to determine much of the content of the questionnaire. As part of our overall research, statistical analyses have been used as a basis for evaluating the conceptual model in the light of the survey results. In addition, we re-evaluated the score guide that was also used in the previous survey, and applied it in order to have an independent and uniform standard with which to measure the maturity of the risk management system. The questionnaire The first step in setting up the new survey involved deciding to use the same questionnaire as for the survey conducted in 2009. A range of group meetings were held to evaluate that questionnaire in the light of the survey results. This involved investigating which questions had proven to be less than effective in practice, either in terms of interpretation or the analysis of the results. Questions were also added on the subject of risk culture. The following elements of interest were added to the questions in the general section: ‘external supervision’ and ‘change of accountancy firm’. Both of these were translated into yes/no questions with clear interpretations. In question 6, the categories concerning the number of countries were added in order to enable enhanced grading of the complexity involved in operating internationally. Question 12 about the chief risk officer was amended in order to draw a distinction between the position itself and the involvement of management in this kind of position. On the subject of internal supervision, an extra question was added to the new questionnaire (question 10) asking about the presence of a supervisory board. With the help of this question, it is easier to interpret the operation of the internal supervisory body than by asking questions about the presence of an audit committee only. In addition, the sectors in which respondents operate were categorised according to the CBS categories. However, in order to enable comparison with 2009, a renumbering table was also compiled. Question 35 was also reformulated, partly as a result of criticism with regard to comparability raised in the study by Paape and Speklé (2012). This is explained in more detail in the research results. The pilot phase In order for any survey to be effective, the questioning needs to be unequivocal and not lead to issues of interpretation, which could result in prejudice or differing interpretations during completion. It is also important that completion of the questionnaire is not too time-consuming, as this can also lead to a reduced response. After the definitive questionnaire was compiled, the research group’s network was deployed to send the questionnaire to professionals practising in several well-known leading companies (approximately 5 - 10). Any comments that arose were evaluated and the question formulation or sequence modified in response. The modified questionnaire as a whole was then individually re-evaluated by the research group. This resulted in the definitive questionnaire and accompanying documentation. Second National Survey of Risk Management in the Netherlands Research population As was the case in 2009, the survey was conducted among all organisations in the Netherlands with turnover/budget (government/ non-profit) in excess of € 10 million. This limit was chosen based on the expectation that organisations with turnover less than € 10 million are unlikely to have a formalised risk management system. The survey is aimed at all organisations in the Netherlands, rather than any specific sector or groups. The dataset was based on an export from the database Company.info (which is linked to the records of the Dutch Chamber of Commerce, among other things), sorted by turnover. This database includes all organisations registered in the Netherlands. After an analysis of the addresses file, including some additional analyses, this ultimately resulted in a database of addresses that included 9,582 organisations. Sending out the questionnaire Special thought was given to timing when sending out the questionnaire. We took into account any holidays and peak periods for reporting/auditing of annual reports for listed organisations, for example, which could result in undesirable levels of nonresponders. There were also discussions within the research group about how the questionnaire should be distributed (using online survey tools or a paper-based survey). In the end, it was decided to send out a paper-based survey. This option was chosen in the light of expectations that an e-mail invitation would be more likely to lead to no response, since the invitation would then be sent to a general e-mail address at the organisation, running the risk of it being interpreted as spam. Although the paper-based version was addressed rather generally (To the Executive Board/Directors of…), which basically involves a similar risk, the proportion of respondents at director-level appears high (52 percent of all responses). In order to increase the response, various forms of social media were used to draw attention to the survey. As in 2009, respondents were offered the opportunity to complete the survey anonymously (in order to increase the response). In addition to this, the opportunity was also offered of receiving a copy of the research report, benchmarking the organisation’s own results (based on the score guide) relative to the population as a whole as a means of evoking interest among respondents. Response and non-response Of the total of 9,582 surveys sent out, approximately 20 were returned because of bankruptcies or incorrect addressing. This resulted in a total of 727 usable surveys, a response of 7.6 percent. This makes it slightly lower than the survey in 2009, when there was a 9.9% response and the database resulted in 929 usable surveys. However, this includes a representative distribution of profit and non-profit organisations and public versus private companies. In addition, organisations of different sizes are also represented. Score guide For the score guide, we formulated a number of principles that we believe an effective risk management system should fulfil. As in 2009, these were derived from a number of widely-accepted standards for risk management, such as COSO ERM, AS/NZS 4360 2004 and ISO 31000. Insights acquired from practical experience, research and interviews also played a role in this. As a result of this, the score guide contains various subjective elements that are open to discussion. We welcome any such discussion since we believe it can only benefit the development of risk management as a whole. October 2014 We took the following seven principles of effective risk management as our basis: • • • • • • • the regularity/frequency with which risk management is applied; the integrated nature of it (scope, types of risks); enterprise-wide application (the level of the organisation on which it is implemented); the degree of pro-activity; the explicitness; the degree of structure (methodological nature); the regular internal or external reporting about risks and risk management. On the basis of these, 16 questions were developed to cover the seven principles. Several points were then allocated for each principle and each question within it. For further details of the allocation of points, we refer you to the appended score guide (Appendix 2), which indicates the associated questions for each principle and the maximum number of points that can be achieved. The questionnaire and point allocation were also slightly improved compared to 2009. These modifications have a negligible impact on the scores. Statistical analyses of the conceptual model and added value of risk management In addition to presenting the raw research results, additional statistical analyses were conducted in order to draw conclusions about the validity of the conceptual model in the context of this survey. Similar statistical analyses were also conducted in order to be able to make a statement about the added value of risk management as perceived by the respondents. The conclusions from these analyses are presented in Chapter 6. In the statistical analyses, conducted in SPSS, all necessary assumptions required to legitimise multiple linear regression and ordinal regression were assessed and found to be adequate (including multi-collinearity, normally distributed residuals, test on uniformlydistributed probabilities). Correlation matrices and descriptive statistics were also used. Risk management maturity In line with the academic studies conducted by Beasley et al. (2005) and Paape and Speklé (2012), it was decided to define maturity based on the five levels first introduced by Beasley et al., which were assessed in question 35. These results were also partly set against the results that would have emerged using our own score guide. However, with the exception of the role of the audit committee, this did not lead to significantly different results. Although both methods have their shortcomings, the consistency in the results for both confirms that they are scientifically tenable. Differences in definition compared to research results in Chapter 4 It is important to point out that there may be differences in terms of definition between the data presented in the research results and the data applied in the statistical analyses. For example, 43 respondents were excluded from the statistical analysis because they did not answer one or several relevant questions and only fullycompleted questionnaires were used. In addition, in defining the (semi-)public sector, it was decided to include housing associations categorised in the trade sector by the CBS as part of the public sector and charitable organisations, considered to be non-profit organisations equivalent to government in the results, were not regarded as a (semi)government in the statistical analyses. This has some impact on the results of the analysis. As a result of this, the conclusion that the (semi-)public sector has made important advances is less explicitly visible in the raw research results. Second National Survey of Risk Management in the Netherlands Finally, we would like to point out that we primarily conducted the statistical analyses on internal and external bodies, governance regulations and supervision and took less account of factors that can be more or less taken as given and are less subject to influence by management reactions or that result in interaction with management. As a result, factors such as the ratio of internal to external equity (leverage), organisational size and result volatility were disregarded. October 2014 Appendix 2: Score guide for survey of Risk Management in the Netherlands 2014 Introduction The quality of risk management is measured based on 7 quality factors, identical to the survey conducted in 2009. These are measurable factors. The maximum possible number of points is 100, subdivided as follows: 1. 2. 3. 4. 5. 6. 7. Regularity/frequency of RM Integrated Enterprise-wide (and -deep) Pro-active Explicit Structured/methodical Reports (internal and external) 14 points 14 points 14 points 14 points 15 points 15 points 14 points Total 100 points These points have been allocated to a large number of questions in the questionnaire. Further explanation for each quality factor is provided below. 1. Regularity/ frequency of RM, 14 points maximum Question 17 (8 points maximum) How often is an enterprise-wide (for all organisational divisions) risk assessment and risk analysis conducted in your organisation? (Choose one answer only) • • • • • Never Annually Quarterly Monthly Weekly/very frequently 0 points 2 points 4 points 8 points 8 points Question 24 (6 points maximum) How frequent are internal reports to the Executive Board/Directors about risks and their management in your organisation? (several answers possible) • • • • • • • Not applicable Weekly Monthly Quarterly Annually Occasionally/ad hoc Other, please specify Second National Survey of Risk Management in the Netherlands 0 points 6 points 6 points 4 points 2 points 1 point 1 point 2. Integrated, 14 points maximum Question 19 (14 points maximum) What risks are assessed? (several answers possible) • • • • • • • • Not applicable Strategic risks Financial risks Operational risks (Financial) reporting risks Legitimacy risks Compliance risks Reputational damage risks 0 points 2 points 2 points 2 points 2 points 2 points 2 points 2 points 3. Enterprise-wide (and -deep), 14 points maximum Question 21 (10 points maximum) At what level of management are the risks in question 19 assessed? (several answers possible) 68 • • • • • • Not applicable Executive Board/Directors Executive Board/Directors and first management level Executive Board/Directors and second management level Executive Board/Directors and first, second and third management level Executive Board/Directors and more than three management levels 0 points 3 points 6 points 8 points 10 points 10 points Question 28 (4 points maximum) For which organisational levels is an in control statement requested? (several answers possible) • • • • • • Not applicable In control statement from the Executive Board/Directors In control statement from the first layer of management (for example, divisional management) In control statement from the second layer of management (for example, business unit management) In control statement from the third layer of management (for example, departmental management) In control statement from more than three layers of management below the Executive Board/Directors 0 points 1 point 1 point 1 point 1 point 1 point October 2014 4. Pro-active, 14 points maximum Question 18 (7 points maximum) When is the risk assessment and analysis conducted? (several answers possible) • • • • • • • Never/not applicable As part of the (annual) P&C cycle At the time of acquisitions/(dis)investments During important projects/developments At the time of strategic decisions After important incidents Other, please specify: 0 points 3 points 2 points 2 points 2 points 2 points 2 points Question 26 (7 points maximum, 1 point per answer) When do you discuss your risks? (several answers possible) • • • • • • • • • • • As part of the Annual Shareholders Meeting As part of consultations with external parties, such as external supervisory bodies and other stakeholders As part of Executive Board/Directors/Management Team meetings As part of business reviews/business plan progress meetings As part of discussions of internal and external audit reports As part of risk committee meetings As part of audit committee/supervisory board meetings As part of budget discussions Ad hoc/in the event of incidents/at major meetings As part of project progress discussions Other, please specify: 5. Explicit, 15 points maximum Question 27 (5 points maximum) Does your organisation make (internal) use of a statement from the management responsible that their organisational division is in control, for example by means of an internal Letter of Representation (LOR) or another comparable document? (several answers possible) • • • • • • • • No, no ‘in control’ statement Yes, in the area of: Strategic risks Financial risks Operational risks (Financial) reporting risks Legitimacy risks Compliance risks Second National Survey of Risk Management in the Netherlands 0 points 1 point 1 point 1 point 1 point 1 point 1 point Question 29 (10 points maximum) Has the risk appetite been determined or recorded within your organisation? This refers to the amount of risk the organisation is willing to accept in implementing its strategy and activities. (several answers possible) Has the risk appetite within your organisation been determined? If yes: • • • • • Has the risk appetite been determined qualitatively? Has the risk appetite been determined quantitatively? Has the risk appetite been specifically determined for one or more risk groups? Has the risk appetite within your organisation been recorded? Has the risk appetite within your organisation been communicated? 3 points 4 points 1 point 2 points 3 points 6. Structured/methodical, 15 points maximum Question 23 (4 points maximum, 1 point per answer) Please indicate which of the techniques below is used for risk assessment and risk analysis. (several answers possible) 70 • • • • • • • • • • • • • • • • • • Document study Interviews Workshops Questionnaires/checklists Incident recording Scenario analyses Sensitivity analyses Simulations Stress testing Value at Risk Economic capital Back testing Serious gaming/war gaming Fault tree analysis Fishbone method Hazard and operability study (HAZOP) Failure Method and Effects Analysis (FMEA) Other, please specify October 2014 Question 30 (3 points maximum if a single department coordinates. In the case of two departments 2 points, three departments just 1 point and even more departments no points) Who coordinates the risk management activities in your organisation? (several answers possible) • • • • • • • • • • A dedicated risk management function/department A dedicated committee (risk management committee, etc.) Line management The financial function The insurance department Internal audit/internal auditing service The compliance department The quality department Not organised Other, please specify: Question 31 (2 points maximum if the answer is Yes) In your organisation, do you apply the ‘Three Lines of Defence’ principle? Question 32 (3 points maximum) In setting up risk management and internal controls in your organisation, have you been influenced by any of the standards listed below? (several answers possible) • • • • • • • • • • COSO/COSO ERM ISO 31000 Management of Risk (M_0_R) Basel/Solvency Australian/New Zealand Framework INK/EFQM model OCEG 6Sigma AIRMIC Other, please specify: 3 points 3 points 3 points 1 point 2 points 2 points 1 point 1 point 2 points 1 point Question 33 (3 points maximum, 1 point per answer) Which software does your organisation use to support risk management? (several answers possible) • • • • • • • • • Brainstorm software Voting software SoD (Segregation of Duties) software Data-analysing software Process management software Internal audit management software Monitoring software Performance management software Other, please specify Second National Survey of Risk Management in the Netherlands 7. Reports (internal and external), 14 points maximum Question 25 (7 points maximum, 1 point per answer) What do the internal risk reports report about? (several answers possible) • • • • • • • • • • Not applicable/there are no internal risk reports The most important risks Status of the main management/control measures Critical risk indicators (CRIs) Development of/changes to risks Incidents that have occurred Important internal changes and their consequences for your organisation Important external changes and their consequences for your organisation Status of improvement measures Other, please specify: Question 34 (7 points maximum, 1 point per answer) What does your organisation report externally about risk management, for example in your annual report? (several answers possible) • • • • • • • • • • • • • • The way in which risk management was set up Wide-ranging ‘in control’ statement Effectiveness of risk management/internal controls in full (report relates to all risks) Limited ‘in control’ statement Effectiveness of risk management/internal controls concerning financial reporting risks (report relates solely to financial reporting risks) Risk appetite in a qualitative sense Risk appetite in a quantitative sense The most important strategic risks The most important financial risks The most important (financial) reporting risks The most important operational risks The most important compliance risks The most important areas for improvement/measures taken The most important incidents that have occurred The material consequences of incidents The most important changes in our risk profile and internal control system. October 2014 Appendix 3: Questionnaire for survey of Risk Management in the Netherlands 2014 General questions 1. My position is: 2. In which sector is your organisation primarily active? (Choose one answer only from the CBS categories below) o o o o Agriculture, forestry and fisheries Mineral extraction Industry Production, distribution and trade in electricity, natural gas, steam and cooled air o Water sourcing and distribution; waste and wastewater management and sanitation o Construction industry o Wholesale and retail trade; car repair o o o o o o Transport and storage Accommodation, food and drink Information and communication Financial institutions Real estate: letting and sales Consultancy, research and other specialist commercial services o Renting of movable property and other commercial services o Security and detection o Public administration, government services and compulsory social insurance o o o o o Education Healthcare and welfare services Culture, sports and recreation Other services Households as employer; non-differentiated production of goods and services by households for their own use o Extraterritorial organisations and bodies 3. What is the annual turnover of your company/organisation as of the end of the last accounting year? (If turnover is not used in your company, please give the annual budget) € 4. What is the total number of employees (expressed as FTEs) in your organisation as of the end of the last accounting year? FTE Second National Survey of Risk Management in the Netherlands 5. As of the end of the last accounting year, please indicate for your organisation the ratio that applies to the relationship between internal and external equity (internal/external). o o o o o 10% or less internal/external 11 to 20% internal/external 21 to 30% internal/external 31 to 40% internal/external more than 40% internal/external 6. In how many countries is your organisation active? o o o o 1 country 2 countries 3 countries More than 3 countries 7. Is your organisation a listed company? Y-N 8. Your shares are primarily owned by: (Choose one answer only) o Not applicable o Anonymous shareholders o Several institutional investors o o o o o One or several families Accounting consultancy (share certificates) Banks (Director and) majority shareholder Other, please specify: 9. Are your organisation’s activities subject to supervision by an external supervisory body, such as AFM, DNB, ACM (OPTA)? Y-N 10. Does your organisation have a supervisory board? Y-N October 2014 11. Has this supervisory board established an audit committee and/or risk committee (in the case of financial institutions)? Y-N 12. Has your organisation appointed a separate chief risk officer (or comparable officer or function such as a risk committee) at the level of the Executive Board/Directors that has ultimate responsibility for risk management? (Choose one answer only) o Yes, there is a CRO at Executive Board/Directors level o Yes, there is a CRO, but not at Executive Board/Directors level o No, there is no CRO, but a comparable position at Executive Board/Directors level o No, there is no CRO, and no comparable position at Executive Board/Directors level 13. Which accountancy firm audits your annual reports? 14. In the last three years, have you appointed a new external accountancy firm? Y-N 15. Please give a report mark for the risk management system in your organisation: (scale 1 - 10, where 1 is the lowest and 10 is the highest score) 1 2 3 4 5 6 7 8 9 10 16. To what extent does your organisation benefit from the risk management system? (scale 1 - 5, where 1 indicates ‘no benefit’ and 5 ‘a great deal of benefit’) Less uncertainty/variation in results a. Fewer surprises b. More confidence in achieving the budget/objectives c. Fewer departures from the budget/planning d. Lower cost of capital e. More reliable estimation of provisions 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 Less damage f. Fewer complaints from customers/staff g. Fewer and less serious corporate incidents h. Fewer claims and lawsuits i. Fewer instructions/fewer fines from the supervisory authorities j. Less negative media attention 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 Second National Survey of Risk Management in the Netherlands Better results k. Increased customer satisfaction l. Increased employee satisfaction m. Increased margin n. Increased turnover/profitability o. Improved reputation p. Increased growth/market share 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 Questions concerning risk assessment and analysis 17. How often is an enterprise-wide (for all organisational divisions) risk assessment and risk analysis conducted in your organisation? (Choose one answer only) o Never o Annually o Quarterly o Monthly o Weekly/very frequently 18. When is the risk assessment and analysis conducted? (several answers possible) o Never/not applicable o As part of the (annual) planning & control cycle o o o o o At the time of acquisitions/investments/disinvestments During important projects/developments At the time of important decisions After important incidents Other, please specify: 19. What risks are assessed? (several answers possible) o o o o o Not applicable Strategic risks Financial risks Operational risks (Financial) reporting risks o Legitimacy risks o Compliance risks o Reputational damage risks October 2014 20. How many layers of management are there in your organisation? (Choose one answer only) o Executive Board/Directors only o Executive Board/Directors and one management level below that o Executive Board/Directors and two management levels below that o Executive Board/Directors and three management levels below that o Executive Board/Directors and more than three management levels below that 21. At what level of management are the risks in question 19 assessed? (several answers possible) o o o o o o Not applicable Executive Board/Directors Executive Board/Directors and first management level Executive Board/Directors and first and second management level Executive Board/Directors and first, second and third management level Executive Board/Directors and more than three management levels 22. Which techniques are used for risk assessment and analysis in your organisation? (several answers possible) o Quantitative techniques o Qualitative techniques 23. Please indicate which of the techniques below is used for risk assessment and risk analysis. (several answers possible) Yes a. Document study b. Interviews c. Workshops d. Questionnaires/checklists e. Incident recording f. Scenario analyses g. Sensitivity analyses h. Simulations i. Stress testing j. Value at Risk k. Economic capital l. Back testing m. Serious gaming/war gaming Second National Survey of Risk Management in the Netherlands No Don’t know Yes No Don’t know n. Fault tree analysis o. Fishbone method p. Hazard and operability study (HAZOP) q. Failure Method and Effects Analysis (FMEA) r. Other, please specify Questions concerning risk management reporting and monitoring 24. How frequent are internal reports to the Executive Board/Directors conducted about risks and their management in your organisation? (several answers possible) o o o o o o o Not applicable Weekly Monthly Quarterly Annually Occasionally/ad hoc Other, please specify: 25. What do the internal reports report about? (several answers possible) o o o o o o o o o o Not applicable/there are no internal risk reports The most important risks Status of the main management/control measures Critical risk indicators (CRIs) Development of/changes to risks Incidents that have occurred Important internal changes and their consequences for your organisation Important external changes and their consequences for your organisation Status of improvement measures Other, please specify: 26. When do you discuss your risks? (several answers possible) o As part of the Annual Shareholders Meeting o As part of consultations with external parties, such as external supervisory bodies and other stakeholders o As part of Executive Board/Directors/Management Team meetings o As part of business reviews/business plan progress meetings o As part of discussions of internal and external audit reports October 2014 o o o o o o As part of risk committee meetings As part of audit committee/supervisory board meetings As part of budget discussions Ad hoc/in the event of incidents/at major meetings As part of project progress discussions Other, please specify: 27. Does your organisation make (internal) use of a statement from the management responsible that their organisational division is in control, for example by means of an internal Letter of Representation (LOR) or another comparable document? (several answers possible) o o o o o o No, no ‘in control’ statement Yes, in the area of: strategic risks financial risks operational risks (financial) reporting risks o legitimacy risks o compliance risks 28. For which organisational levels is an in control statement requested? (several answers possible) o Not applicable o In control statement from the Executive Board/Directors o In control statement from the first layer of management (e.g. divisional management) o In control statement from the second layer of management (e.g. business unit management) o In control statement from the third layer of management (e.g. departmental management) o In control statement from more than three layers of management below the Executive Board/Directors Second National Survey of Risk Management in the Netherlands Questions concerning risk management and organisation 29. Has the risk appetite been determined or recorded within your organisation? This refers to the amount of risk the organisation is willing to accept in implementing its strategy and activities. (several answers possible) Yes No Don’t know a. Has the risk appetite within your organisation been determined? If yes: b. Has the risk appetite been determined qualitatively? c. Has the risk appetite been determined quantitatively? d. Has the risk appetite been specifically determined for one or more risk groups? e. Has the risk appetite within your organisation been recorded? f. Has the risk appetite within your organisation been communicated? 30. Who coordinates the risk management activities in your organisation? (several answers possible) o A dedicated risk management function/department o A dedicated committee (risk management committee, etc.) o o o o Line management The financial function The insurance department Internal audit/internal auditing service o The compliance department o The quality department o Not organised o Other, please specify: 31. in your organisation, do you apply the ‘Three Lines of Defence’ principle? Y-N 32. In setting up risk management and internal controls in your organisation, have you been influenced by any of the standards listed below? (several answers possible) o Not applicable/we have not been influenced by a standard October 2014 Yes No Don’t know a. COSO/COSO ERM b. ISO 31000 c. Management of Risk (M_o_R) d. Basel/Solvency e. Australian/New Zealand Framework f. INK/EFQM model g. OCEG h. 6Sigma i. AIRMIC j. Other, please specify 33. Which software does your organisation use to support risk management? (several answers possible) o Not applicable/we do not use software for risk management Broad so-called GRC platforms Yes No Don’t know Yes No Don’t know (risk data management software) a. Metricstream b. Nasdaq OMX Bwise c. EMC (RSA Archer) d. Thomson Reuters (Accelus) e. SAP (GRC) f. IBM (OpenPages) g. Enablon h. Software AG (Aris) i. Wynyard (Methodware) j. Self-developed software k. Other, please specify Other support software (single functionality) (possibly in addition to the software mentioned above) l. Brainstorm software m. Voting software n. SoD (Segregation of Duties) software o. Data-analysing software p. Process management software q. Internal audit management software r. Monitoring software s. Performance management software t. Other, please specify Second National Survey of Risk Management in the Netherlands 34. What does your organisation report externally about risk management, for example in your annual report? (several answers possible) o The way in which risk management was set up o Wide-ranging ‘in control’ statement Effectiveness of risk management/internal controls in full (report relates to all risks) o Limited ‘in control’ statement Effectiveness of risk management/internal controls concerning financial reporting risks (report relates solely to financial reporting risks) o Risk appetite in a qualitative sense o Risk appetite in a quantitative sense o The most important strategic risks o The most important financial risks o The most important (financial) reporting risks o The most important operational risks o The most important compliance risks o The most important areas for improvement/measures taken o The most important incidents that have occurred o The material consequences of incidents o The most important changes in our risk profile and internal control system o Nothing 35. Please indicate the stage of risk management maturity in which you would categorise your organisation. (Choose one answer only) o Stage 1: There are currently no plans for the introduction of a risk management system. o Stage 2: We are investigating the possibility of introducing a risk management system, but have not yet made a definitive decision. o Stage 3: We are currently planning the implementation of a risk management system. o Stage 4: Currently, a risk management system is partly in place and implemented. o Stage 5: A comprehensive risk management system for Enterprise Risk Management is in place and implemented. Questions concerning risk culture 36. Who writes the risk section in your annual report? (several answers possible) o Not applicable o Managing Director/CEO o The financial function (CFO, head of financial administration, treasury department) October 2014 o The risk manager/IC officer/GRC officer o Secretary to the board/secretarial function o The legal department o Other, please specify: 37. To what extent does the remuneration and appraisal system used by your board and line management take account of the effectiveness of risk management? (Choose one answer only) o There is a direct relationship between the effectiveness of risk management and the remuneration and appraisal systems. o There is no direct relationship, but risk management is taken into account informally in the remuneration and appraisal systems. o There is absolutely no relationship between the effectiveness of risk management and the remuneration and appraisal systems. 38. To what extent do you agree with the following statements about risk management? (scale 1 - 5, where 1 indicates ‘disagree’ and 5 ‘agree’) Statements about risk management a. Risk management takes place because it contributes to better business operations and is not seen as a cost item. b. Staff are encouraged when they take risks to do so from a well-considered position. c. A position in risk management is seen as a boost to your career. d. It is permissible to make mistakes, as long as you learn from them (learning organisation). e. The culture in our organisation promotes risk management. f. Breaches of internal rules are taken seriously and punished. g. The Executive Board/Directors is/are very committed to risk management and actively support(s) it. h. Employees feel at liberty to draw risks to the attention of their line managers. i. In our organisation, the emphasis is primarily on short-term results. j. The remuneration structure promotes risk-taking. k. A clear link is made between achieving goals, risks and remuneration. Second National Survey of Risk Management in the Netherlands 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 1-2-3-4-5 39. Do you have any further comments in the light of this survey? 84 Organisation: Your name: Your position: Address: Postcode + town/city: Your e-mail address: October 2014 Appendix 4: Conceptual model Chief Risk Officer (+) Internationalisation(+) Stock market listing(+) (Semi-)public (+) maturity Big4auditor(+) Financial institutions (+) Second National Survey of Risk Management in the Netherlands 86 October 2014 Second National Survey of Risk Management in the Netherlands
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