48 49
Boards and CEOs around the
world are being told repeatedly
from multiple sources that they
need to do a better job managing
and overseeing risk and,
most recently, ‘risk culture’.1
Unfortunately, current methods
of providing stakeholders with
assurance that risk management
processes are effective are
fundamentally the same methods
that have been used for decades.
The 2008 global crisis is a graphic illustration
of their inability to cope with an increasingly
fast moving and complex world. This article
is a call to boards, CEOs, law makers,
regulators, investor groups and others for a
major paradigm shift in risk management
and assurance thinking to create and better
preserve shareholder value.
Paradigm paralysis in the enterprise risk
management (ERM) and internal audit
communities blocks their ability to see new
methods available to better meet the needs of
stakeholders. This article will outline status
Paradigm paralysis
in ERM & internal auditTheinternalaudit
professionneedsto
reinventitselftobetter
respondtotheemerging
expectationsfacingsenior
managementandboards
quo ERM and internal audit paradigms;
describe why the current paradigms are
blocking progress; and propose some simple,
but radically different ideas to assist boards,
CEOs and ERM and internal audit specialists
make the paradigm shift necessary to drive
positive change.
Paradigm paralysis:
ERM methods
Although there is wide variation in how
companies have implemented ERM, the
most common feature is the creation and
maintenance of ‘risk registers’ as a foundation.
The extent risks identified are linked to the
company’s business objectives and strategies
varies greatly. Supplementing the risk registers
are ‘risk heat maps’ that depict individual risks
in terms of likelihood and consequence. Risk
heat maps may, or may not, depict residual
risk, the risk remaining after considering risk
responses/risk treatments on a single risk.2
These risk registers are typically maintained
by ERM specialists or internal audit groups
and results are reported upwards to the board.
ERM paradigm flaws
The primary drawback of this risk-centric
ERM paradigm is that it looks at risks in
isolation from the company’s top value
creation and value preservation objectives
(see the sidebar for the authors’ definition).
This approach does not allow decision
makers to see the current state of residual
risk linked to the achievement of the
company’s most important objectives.
All of the risks relevant to individual
objectives are not looked at in totality in terms
of their collective effect on the achievement
of specific objectives. The process does not
produce information to evaluate the
acceptability of the current residual risk
status (i.e. is it within risk appetite/
tolerance?). It also creates confusion and
uncertainty around who is really responsible
for the risks identified, as assigned ‘risk
owners’ may not align with those responsible
for achieving the linked objective(s). This
risk-centric approach has also tended to
focus more on value preservation objectives
(e.g. ‘three lines of defence’) rather than a
balance, which puts at least equal emphasis
on value creation/strategic objectives.
Value Creation Objective
Objectiveskeytothelong-termsuccess
oftheenterprisethatwillcreateenhanced
shareholdervalue(e.g.increasemarket
shareby20percent)
Value Preservation Objective
Objectivesthat,ifnotachieved,have
significantpotentialtoerodestakeholder
value(e.g.ensurereliablefinancial
statementsdisclosures)
Another flaw is that the process is typically
completed as a static annual or semi-annual
exercise with a heavy compliance connotation.
The risk assessment methodology used to
populate the risk register and risk heat maps
is often not the same assessment approach
used by internal audit to complete internal
audits, or the assessment approach used by
other specialists groups, such as safety,
compliance, insurance, quality, etc. It is also
important to note that the dominant ERM
method to identify risks is ‘brainstorming’,
based heavily on the knowledge and experience
of participants. The full range of methods
available to identify significant risks is rarely
used. Key risks linked to top strategic objectives
are often missed. The approach often does not
consider the full range of risk responses/risk
treatments available as it tends to focus heavily
on ‘controls’ linked to individual risks, not the
full range of risk responses/treatments.
Another critical flaw of the current ERM
paradigm is that when work units are candid
and disclose very serious and material
retained risk positions, the result in some
companies is that the area is then scheduled
for a traditional internal audit – in essence,
participants are punished for being upfront
and disclosing information key to better
decision making and a healthy risk culture.
Another significant concern is that the areas
that are generally low risk from a culture
perspective often do the best job identifying
and disclosing risks and residual risk status.
Groups and executives that represent major
risk to the organisation culturally are least
likely to candidly disclose significant risks
and the true retained risk position.
The way forward: a board
-driven ERM paradigm shift
Boards and CEOs need to take the time
to understand the substantial differences
between risk-centric and objective-centric
assessment risk management frameworks.
More information on the business case for
objective-centric risk management vs
traditional risk-centric approaches that use risk
registers as a foundation can be found online.
Enterprise Risk Management | Board GovernanceBoard Governance | Enterprise Risk Management
Ethical Boardroom | Summer 2016 Summer 2016 | Ethical Boardroom
Tim Leech & Lauren Hanlon
Tim is the Managing Director; Lauren is a
Director at Risk Oversight Solutions Inc ■	 Influential ERM guidance sources, including COSO and ISO 31000, while defining risk in
terms of its ability to effect achievement of objectives, implicitly endorse risk-centric
approaches to risk management that use risk registers, not objectives registers, as a
foundation. COSO and the authors of ISO 31000 do not advocate that the process should
start by identifying and prioritising objectives, then make conscious decisions on which
objectives warrant the cost of formal risk assessments. The COSO ERM exposure draft
issued in June 2016, while increasing the focus on value creation objectives, stops short
of calling on companies to create and use objectives registers as a foundation for ERM.
■	 Itmaybeaveryuncomfortableandunfamiliarexercisefortheboardandmanagementto
agreeonthetopvaluecreationandvaluepreservationobjectives.Thisreluctanceprevents
efficiententitylevelresourceallocationanddecisionmaking.Anobjective-centric
approachfocussesfirstondefiningthetopobjectiveskeytosustainedlong-termsuccess
–itseeksabalancebetweenvaluecreationandvaluepreservation.Arisk-centric/risk
registerERMapproachisoftenquitevagueonitslinkagestotopvaluecreation/
preservationobjectivesandrarelymakesalinktoperformance.
■	 Management has to take on substantially greater ownership and act as primary risk
assessor/reporter for the company’s top objectives, including providing a report and
opinion on the overall residual risk status for each objective to the board. This is a
fundamental shift that requires changes to how management and traditional ERM and
internal audit teams interact and discharge their responsibilities. It may also include a
fundamental risk culture shift, where candidly described significant negative residual risk
positions is rewarded, not punished by internal audit and senior management.
■	 Aglobalshortageofstaffwiththeknowledgeandskillstoimplementanobjective-centric
riskself-assessmentframework.Businessschoolsarestillintheirinfancyinproducing
enterpriseriskmanagementcurriculumbeyondtraditionalinternalauditandaccounting
coursesthatteachcontrol-centricmodelsheavilylinkedtoeffectivenessofinternalcontrols
overfinancialreportingandITsecurity.Thoseschoolsthatdocoverriskmanagement
holisticallygenerallyteachERMmethodsthatuseriskregistersasafoundation.
■	 The use of the three lines of defence (3LoD) endorsed by the Institute of Internal Auditors
(IIA) and some regulators as a risk governance framework.3
The IIA 3LoD model sees the
board and CEO as stakeholders who receive information, not active and key participants
in the risk management process. It perpetuates the notion that risk management is
fundamentally about hazard avoidance and defence – not a key support tool to take risks
intelligently and drive increased stakeholder value.
■	 TheIIAhasnotactivelysupportedashiftfromtraditionalrisk-centricERMmethods
andcontrolandprocess-centricdirectreportinternalauditmethodstoa
management-driven,objective-centricriskself-assessmentapproach.IIAguidance
onhowtoassesstheeffectivenessofERMframeworksdoesnotcallforanevaluation
ofwhethertheapproachbeingevaluatedisassessingriskslinkedtoacompany’s
topvaluecreationandvaluepreservationobjectives.
barriers to change
Require a robust management-driven,
objective-centric risk self-assessment
framework that uses an objective register
as the foundation. Risk management efforts
should be aligned with the top value creation
and preservation objectives to ensure optimal
capital allocation. The objectives register
should include the company’s top value
creation and value preservation objectives.
These should be defined by management and
reviewed by the board. ‘Owner/sponsors’
should be assigned to each objective.
Owner/sponsors are responsible for
assessing and reporting on the state of
residual risk related to each of the objectives
to the CEO and the board using an ISO 31000
compliant assessment methodology (for an
example of an objective-centric/ISO 31000
compliant approach see the RiskStatusline™
assessment approach shown on page 50).
Conscious decisions should be made on the
target level of risk assessment rigour and
independent assurance. The board should
receive regular reports on the residual risk
status of the objectives in the register,
including the current Composite Residual Risk
Status (CRRR). A sample set of definitions for
CRRRs is also on page 50.
Require that the CEO or his/her
designate regularly (bi-annually or
quarterly) provide the board with a
consolidated report on residual risk
status linked to the company’s top
value creation and value preservation
objectives. This simple step has great
potential to drive the necessary changes
to the way management and all of the
specialist assurance groups do their work.
Ethical Boardroom | Summer 2016
Board Governance | Enterprise Risk Management
Summer 2016 | Ethical Boardroom50 51
Enterprise Risk Management | Board Governance
Assign responsibility to ERM specialist
staff to implement and maintain a robust
objective-centric risk self-assessment
framework. This repositions the role of
risk specialists to one where their primary
role is providing training, facilitating
objective-centric management-driven risk
self-assessments and helping the CEO produce
reliable consolidated reports for the board on
the residual/retained risk status of top value
creation and preservation objectives.
Require annual opinions from internal
audit on the effectiveness of the company’s
risk management framework and reliability
of the consolidated report from the CEO to
the board on company’s residual/retained
risk status linked to top value creation/
value preservation objectives.
Paradigm paralysis: internal audit
The internal audit profession is based on a
core paradigm, largely unchanged since the
profession began, that calls for internal
auditors to audit a unit, topic, process, or
other ‘audit universe’ element and form an
opinion as to whether the auditor believes the
‘internal controls’ in the audit universe subject
matter are ‘effective’ or ‘adequate’. From a
technical perspective, this approach is called
a ‘direct report audit engagement’.
Internal auditors must, of necessity, use a
direct report audit approach in cases where
management has not self-assessed and made
a formal representation on the state of risk.
When this does happen, internal audit can
use an ‘attestation’ approach that reports on
management’s self-assessment. Unfortunately,
the percentage of companies where
management complete self-assessments and
report on the state of residual risk linked to
key value creation and preservation objectives
is still a very small percentage of the total.
Ironically, most internal audit departments
claim their audit methodology is ‘risk based’.
What this means is often unclear as their
audit plans often do not cover the company`s
top value creation/strategic objectives.
Internal audit coverage expressed as a
percentage of the entire risk universe of a
company is rarely more than 10 per cent in
any given year. Results of individual internal
audits are reported to management and
summary reports provided to the audit
committee of the board of directors.
Internal audit paradigm flaws
The key flaw in the current internal audit
paradigm is that it does not position
responsibility for assessing risks and reporting
upwards on the state of residual risk linked to
the company’s most critical value creation and
value preservation objectives squarely with the
people that should have primary responsibility
– management. It discourages management
from learning how to formally assess and
report on residual risk status linked to key
■	 A large percentage of companies and their boards have not embraced the need for
management to self-assess and report on the state of residual risk linked to their most
important value creation and value preservation objectives and report consolidated
results upwards to the company’s board of directors. As long as management in a
company is unwilling to perform this role, internal audit must continue to do direct report
audit engagements on a small percentage of the risk universe (i.e. there are no
management representations on risk status on key objectives to audit, hence attestation
internal audit engagements are not possible).
■	 Becausethemajorityofcompaniesintheworldtodayhavenotimplementedrobustobjective
-centricriskself-assessmentframeworks,alargepercentageoftheIIAcurriculum,training,
andcertificationstandardsarebuiltonthedirectreportauditparadigmwithaheavyfocus
oninternalauditorsopiningonthesufficiencyof‘internalcontrols’. Amassiveandconcerted
effortwouldberequiredtoequipinternalauditorswiththeskillsnecessarytoformopinions
onthereliabilityofobjective-centricriskself-assessmentsasmanyinternalauditorslackthe
skillstocompletethem. ManyinternalauditorsarenotcurrentlytrainedtocompleteISO
31000/COSOERMcompliantriskassessmentsand,byextension,notequippedtoreport
whetherobjective-centricriskassessmentsdonebymanagementarereliable.
■	 Many boards and senior executives don’t believe internal audit can add significant
value to their company’s top value creation objectives and are content to have
internal audit focus on a relatively narrow range of objectives with a heavy focus on
financial controls, IT security, business continuity, fraud prevention and other value
preservation/defence areas.
barriers to change (Continued)
0	 Fully acceptable Composite residual risk status is acceptable. No changes to
risk treatment strategy required at this time. (NOTE: this could mean that one
or more significant risks are being accepted. Information on accepted concerns is
found in the residual risk status information)
1	Low Inaction could result in very minor negative impacts. Ad hoc attention may
be required to adjust composite residual risk status to an acceptable level
2	Minor Inaction or unacceptable terms could result in minor negative impacts.
Routine management attention may be required to adjust composite residual risk
status to an acceptable level
3	Moderate Inaction could result in or allow continuation of mid-level negative
impacts. Moderate senior management effort required to adjust composite residual
risk status to an acceptable level
4	Advanced Inaction could allow continuation of/or exposure to serious negative impacts.
Senior management attention required to adjust composite residual risk status
5	Significant Inaction could result in or allow continuation of very serious entity
level negative impacts. Senior management attention urgently required to adjust
composite residual risk status to an acceptable level
6	Major Inaction could result in or allow continuation of very major entity level
negative consequences. Analysis and corrective action to adjust composite
residual risk status required immediately
7	Critical Inaction virtually certain to result in or allow continuation of very major
entity level negative consequences. Analysis and corrective action to adjust
composite residual risk status required immediately
8	Severe Inaction virtually certain to result in or allow continuation of very severe
negative impacts. Senior management/board-level attention urgently required to
adjust composite residual risk status
9	Catastrophic Inaction could result in or allow the continuation of catastrophic
proportion impacts. Senior management/board level attention urgently required
to adjust composite residual risk status and avert a catastrophic negative impact
on the organisation
10	Terminal The current composite residual risk status is already extremely material and
negative and having disastrous impact on the organisation. Immediate top priority action
from the board and senior management required to prevent the demise of the entity.
COMPOSITE RESIDUAL RISK RATING DEFINITIONS
Endresultobjectives
(implicitorexplicit)
Internal/externalcontext
Residualriskstatus
Threatsto
achievement/risks?
Risktreatmentstrategy
Riskmitigators/controls
Risktransfer,
share,finance
(selectedconsciously
orunconsciously)
Acceptable?
Risktreatment
optimised?
YES
RiskStatuslineTM
NO
NO
Re-examinerisktreatment
strategyand/orobjective
anddevelopactionplan
YES
–Moveon
2015RiskOversightSolutionsInc.
SAMPLE summary report for senior executives and the board
Independent
assurance
level (IAL)
Low
Medium
Current risk
assessment
rigor (RAR)
Medium (M)
VeryLow(VL)
Potential to
erode entity
value
Low
High
Potential to
increase
entity value
Medium
High
CRRR
update
date
6/12/2014
6/10/2014
Composite
residual risk
rating (CRRR)
6 — Major
4 — Advanced
End result
objective owner/
sponsor(s)
Tim Leech
Tim Leech
Corporate
l
l
Description
Ensurethatfinancial
statementsarereliableand
incompliancewithGAAP
Safeguardandenhance
ABCsreputation
A call to action — boards
and CEOs need to drive
paradigm shift efforts
Globally, the ERM and internal audit
professions have a serious case of paradigm
paralysis that is impeding their ability to help
boards and CEOs meet new risk governance
expectations. Boards and CEOs need to play
a key role driving a quantum paradigm shift
in risk management and assurance thinking
to make improvements in risk culture. When
paradigm paralysis occurs it is always worth
remembering the words of Albert Einstein,
“Insanity: doing the same thing over and
over again and expecting different results”.5
Expecting the same internal audit and ERM
methods used over the last 20 to 30 years to
produce dramatically different and better
results for stakeholders is poor judgement
at best. The authors hope that the paradigm
shift ideas in this paper will help drive further
thought leadership and the developments
necessary to produce the quantum paradigm
shift in ERM and internal audit methods
necessary to help boards and CEOs better
meet new risk governance expectations.
1
Example:SeeFinancialStabilityBoardPrinciplesforanEffective
RiskAppetiteFrameworksenttoregulatorsaroundtheworld
http://www.fsb.org/wp-content/uploads/r_131118.pdf 2
Note:
COSOusestheterm‘riskresponses’.ISO31000,theglobal
riskmanagementstandardusestheterm‘risktreatments’.In
bothcasesthetermreferstothefullrangeofwaystofinance,
share,transfer,mitigate,avoidandacceptrisk. 3
SeeOfficeof
SuperintendentFinancialInstitutionsJune2016E21Operational
RiskGuidelinesforanexampleofaregulatorendorsing‘Three
LinesofDefense’ 4
SeeFinancialStabilityBoardPrinciples
foranEffectiveRiskAppetiteFrameworkhttp://www.fsb.org/
wp-content/uploads/r_131118.pdfandIIAResearchFoundation
AuditingRiskAssessmentandRiskManagementProcesses
5
Source:AlbertEinstein.(n.d.).BrainyQuote.com.Retrieved
29June,2016,fromBrainyQuote.comWebsite:http://www.
brainyquote.com/quotes/quotes/a/alberteins133991.htm)
Boards and CEOs
need to play a
key role driving
a quantum
paradigm shift in
riskmanagement
and assurance
thinking to make
improvements
in risk culture
value creation/preservation objectives (i.e. it’s
not their job to assess and report, so why do
they need the skills to do it?). Internal audit
coverage is usually a small percentage each
year of the total risk universe and often has a
heavy bias towards value preservation and
financial accounting controls.
The audit plan often does not cover the
company’s most important value creation/
strategic objectives and is often not well
integrated with the work of other assurance
groups, including ERM, safety, IT security,
environment, compliance, insurance and
others. The traditional internal audit paradigm
often puts serious political pressure on business
units to put in place additional ‘internal
controls’ linked to the topic audited, even when
residual risk status in other areas linked to key
value creation/strategic objectives not covered
by internal audit warrant more of the scarce
risk treatment resources.
Our work globally suggests that only a
small percentage of internal auditors today
use objective-centric risk assessment methods
on their audits that conform to risk assessment
methods defined by the global risk
management standard, ISO 31000, or COSO
ERM 2004/ED 2016. A large percentage of
internal auditors report opinions on sufficiency
of internal controls, not the full range of risk
responses/risk treatments in place. This can
result in seriously flawed results and opinions.
An opinion from internal audit on whether
internal controls are effective, or not, is
fundamentally an opinion from the internal
auditors on whether they think residual risk
status is acceptable to the company and the
board – information the internal auditors often
don’t have and decisions internal auditors
aren’t authorised or trained to make.
It is important to note that the Financial
Stability Board (FSB) and the Institute of
Internal Auditors (IIA) are increasingly calling
on internal audit groups to assess and report
on all of their company’s risk management
processes.4
When internal audit is the group
with primary responsibility for completing
documented risk and control assessments this
requires internal audit report on itself – a
violation of audit independence standards.
The way forward:
a board/CEO-driven
internal audit
paradigm shift
Boards and CEOs need to
call for implementation of
robust objective-centric
risk self-assessment
frameworks that use an
objective register as the
foundation. See details above.
When an objective register is
used as a foundation for ERM
it defines the role of owner/
sponsors, ERM specialists, and
independent assurance staff
and, by definition, focusses resources on
objectives key to long-term value creation
and preservation.
Require internal audit use the
company’s objectives register not an
audit universe as their work foundation.
Once management with the assistance of
ERM specialists has completed the assigned
risk assessments at the defined level of risk
assessment rigour, internal audit completes
quality assurance reviews where internal
audit has been defined as the independent
assurance providers to achieve the target
independent assurance level defined in the
objectives register. For some objectives in the
objectives register the board and/or C-Suite
may assign other independent assurance
providers. The primary goal of internal audit is
to provide the board with opinions on the
effectiveness of company’s enterprise risk
management processes and the reliability
of the consolidated report from the CEO
to the board on residual risk status. Internal
audit should also flag any areas where they
think management is accepting
levels of residual risk that
they believe may be outside
of the CEO and/or the board’s
risk appetite/tolerance.
Ensure the internal audit
team is staffed appropriately
to contribute on top value
creation and value
preservation objectives.
This can include management
rotation programmes and hiring
of staff from non-traditional
internal audit backgrounds
(i.e. outside of accounting,
IT security, external audit).

Paradigm Paralysis in ERM & IA EB7_p48-51 Tim Leech v2

  • 1.
    48 49 Boards andCEOs around the world are being told repeatedly from multiple sources that they need to do a better job managing and overseeing risk and, most recently, ‘risk culture’.1 Unfortunately, current methods of providing stakeholders with assurance that risk management processes are effective are fundamentally the same methods that have been used for decades. The 2008 global crisis is a graphic illustration of their inability to cope with an increasingly fast moving and complex world. This article is a call to boards, CEOs, law makers, regulators, investor groups and others for a major paradigm shift in risk management and assurance thinking to create and better preserve shareholder value. Paradigm paralysis in the enterprise risk management (ERM) and internal audit communities blocks their ability to see new methods available to better meet the needs of stakeholders. This article will outline status Paradigm paralysis in ERM & internal auditTheinternalaudit professionneedsto reinventitselftobetter respondtotheemerging expectationsfacingsenior managementandboards quo ERM and internal audit paradigms; describe why the current paradigms are blocking progress; and propose some simple, but radically different ideas to assist boards, CEOs and ERM and internal audit specialists make the paradigm shift necessary to drive positive change. Paradigm paralysis: ERM methods Although there is wide variation in how companies have implemented ERM, the most common feature is the creation and maintenance of ‘risk registers’ as a foundation. The extent risks identified are linked to the company’s business objectives and strategies varies greatly. Supplementing the risk registers are ‘risk heat maps’ that depict individual risks in terms of likelihood and consequence. Risk heat maps may, or may not, depict residual risk, the risk remaining after considering risk responses/risk treatments on a single risk.2 These risk registers are typically maintained by ERM specialists or internal audit groups and results are reported upwards to the board. ERM paradigm flaws The primary drawback of this risk-centric ERM paradigm is that it looks at risks in isolation from the company’s top value creation and value preservation objectives (see the sidebar for the authors’ definition). This approach does not allow decision makers to see the current state of residual risk linked to the achievement of the company’s most important objectives. All of the risks relevant to individual objectives are not looked at in totality in terms of their collective effect on the achievement of specific objectives. The process does not produce information to evaluate the acceptability of the current residual risk status (i.e. is it within risk appetite/ tolerance?). It also creates confusion and uncertainty around who is really responsible for the risks identified, as assigned ‘risk owners’ may not align with those responsible for achieving the linked objective(s). This risk-centric approach has also tended to focus more on value preservation objectives (e.g. ‘three lines of defence’) rather than a balance, which puts at least equal emphasis on value creation/strategic objectives. Value Creation Objective Objectiveskeytothelong-termsuccess oftheenterprisethatwillcreateenhanced shareholdervalue(e.g.increasemarket shareby20percent) Value Preservation Objective Objectivesthat,ifnotachieved,have significantpotentialtoerodestakeholder value(e.g.ensurereliablefinancial statementsdisclosures) Another flaw is that the process is typically completed as a static annual or semi-annual exercise with a heavy compliance connotation. The risk assessment methodology used to populate the risk register and risk heat maps is often not the same assessment approach used by internal audit to complete internal audits, or the assessment approach used by other specialists groups, such as safety, compliance, insurance, quality, etc. It is also important to note that the dominant ERM method to identify risks is ‘brainstorming’, based heavily on the knowledge and experience of participants. The full range of methods available to identify significant risks is rarely used. Key risks linked to top strategic objectives are often missed. The approach often does not consider the full range of risk responses/risk treatments available as it tends to focus heavily on ‘controls’ linked to individual risks, not the full range of risk responses/treatments. Another critical flaw of the current ERM paradigm is that when work units are candid and disclose very serious and material retained risk positions, the result in some companies is that the area is then scheduled for a traditional internal audit – in essence, participants are punished for being upfront and disclosing information key to better decision making and a healthy risk culture. Another significant concern is that the areas that are generally low risk from a culture perspective often do the best job identifying and disclosing risks and residual risk status. Groups and executives that represent major risk to the organisation culturally are least likely to candidly disclose significant risks and the true retained risk position. The way forward: a board -driven ERM paradigm shift Boards and CEOs need to take the time to understand the substantial differences between risk-centric and objective-centric assessment risk management frameworks. More information on the business case for objective-centric risk management vs traditional risk-centric approaches that use risk registers as a foundation can be found online. Enterprise Risk Management | Board GovernanceBoard Governance | Enterprise Risk Management Ethical Boardroom | Summer 2016 Summer 2016 | Ethical Boardroom Tim Leech & Lauren Hanlon Tim is the Managing Director; Lauren is a Director at Risk Oversight Solutions Inc ■ Influential ERM guidance sources, including COSO and ISO 31000, while defining risk in terms of its ability to effect achievement of objectives, implicitly endorse risk-centric approaches to risk management that use risk registers, not objectives registers, as a foundation. COSO and the authors of ISO 31000 do not advocate that the process should start by identifying and prioritising objectives, then make conscious decisions on which objectives warrant the cost of formal risk assessments. The COSO ERM exposure draft issued in June 2016, while increasing the focus on value creation objectives, stops short of calling on companies to create and use objectives registers as a foundation for ERM. ■ Itmaybeaveryuncomfortableandunfamiliarexercisefortheboardandmanagementto agreeonthetopvaluecreationandvaluepreservationobjectives.Thisreluctanceprevents efficiententitylevelresourceallocationanddecisionmaking.Anobjective-centric approachfocussesfirstondefiningthetopobjectiveskeytosustainedlong-termsuccess –itseeksabalancebetweenvaluecreationandvaluepreservation.Arisk-centric/risk registerERMapproachisoftenquitevagueonitslinkagestotopvaluecreation/ preservationobjectivesandrarelymakesalinktoperformance. ■ Management has to take on substantially greater ownership and act as primary risk assessor/reporter for the company’s top objectives, including providing a report and opinion on the overall residual risk status for each objective to the board. This is a fundamental shift that requires changes to how management and traditional ERM and internal audit teams interact and discharge their responsibilities. It may also include a fundamental risk culture shift, where candidly described significant negative residual risk positions is rewarded, not punished by internal audit and senior management. ■ Aglobalshortageofstaffwiththeknowledgeandskillstoimplementanobjective-centric riskself-assessmentframework.Businessschoolsarestillintheirinfancyinproducing enterpriseriskmanagementcurriculumbeyondtraditionalinternalauditandaccounting coursesthatteachcontrol-centricmodelsheavilylinkedtoeffectivenessofinternalcontrols overfinancialreportingandITsecurity.Thoseschoolsthatdocoverriskmanagement holisticallygenerallyteachERMmethodsthatuseriskregistersasafoundation. ■ The use of the three lines of defence (3LoD) endorsed by the Institute of Internal Auditors (IIA) and some regulators as a risk governance framework.3 The IIA 3LoD model sees the board and CEO as stakeholders who receive information, not active and key participants in the risk management process. It perpetuates the notion that risk management is fundamentally about hazard avoidance and defence – not a key support tool to take risks intelligently and drive increased stakeholder value. ■ TheIIAhasnotactivelysupportedashiftfromtraditionalrisk-centricERMmethods andcontrolandprocess-centricdirectreportinternalauditmethodstoa management-driven,objective-centricriskself-assessmentapproach.IIAguidance onhowtoassesstheeffectivenessofERMframeworksdoesnotcallforanevaluation ofwhethertheapproachbeingevaluatedisassessingriskslinkedtoacompany’s topvaluecreationandvaluepreservationobjectives. barriers to change Require a robust management-driven, objective-centric risk self-assessment framework that uses an objective register as the foundation. Risk management efforts should be aligned with the top value creation and preservation objectives to ensure optimal capital allocation. The objectives register should include the company’s top value creation and value preservation objectives. These should be defined by management and reviewed by the board. ‘Owner/sponsors’ should be assigned to each objective. Owner/sponsors are responsible for assessing and reporting on the state of residual risk related to each of the objectives to the CEO and the board using an ISO 31000 compliant assessment methodology (for an example of an objective-centric/ISO 31000 compliant approach see the RiskStatusline™ assessment approach shown on page 50). Conscious decisions should be made on the target level of risk assessment rigour and independent assurance. The board should receive regular reports on the residual risk status of the objectives in the register, including the current Composite Residual Risk Status (CRRR). A sample set of definitions for CRRRs is also on page 50. Require that the CEO or his/her designate regularly (bi-annually or quarterly) provide the board with a consolidated report on residual risk status linked to the company’s top value creation and value preservation objectives. This simple step has great potential to drive the necessary changes to the way management and all of the specialist assurance groups do their work.
  • 2.
    Ethical Boardroom |Summer 2016 Board Governance | Enterprise Risk Management Summer 2016 | Ethical Boardroom50 51 Enterprise Risk Management | Board Governance Assign responsibility to ERM specialist staff to implement and maintain a robust objective-centric risk self-assessment framework. This repositions the role of risk specialists to one where their primary role is providing training, facilitating objective-centric management-driven risk self-assessments and helping the CEO produce reliable consolidated reports for the board on the residual/retained risk status of top value creation and preservation objectives. Require annual opinions from internal audit on the effectiveness of the company’s risk management framework and reliability of the consolidated report from the CEO to the board on company’s residual/retained risk status linked to top value creation/ value preservation objectives. Paradigm paralysis: internal audit The internal audit profession is based on a core paradigm, largely unchanged since the profession began, that calls for internal auditors to audit a unit, topic, process, or other ‘audit universe’ element and form an opinion as to whether the auditor believes the ‘internal controls’ in the audit universe subject matter are ‘effective’ or ‘adequate’. From a technical perspective, this approach is called a ‘direct report audit engagement’. Internal auditors must, of necessity, use a direct report audit approach in cases where management has not self-assessed and made a formal representation on the state of risk. When this does happen, internal audit can use an ‘attestation’ approach that reports on management’s self-assessment. Unfortunately, the percentage of companies where management complete self-assessments and report on the state of residual risk linked to key value creation and preservation objectives is still a very small percentage of the total. Ironically, most internal audit departments claim their audit methodology is ‘risk based’. What this means is often unclear as their audit plans often do not cover the company`s top value creation/strategic objectives. Internal audit coverage expressed as a percentage of the entire risk universe of a company is rarely more than 10 per cent in any given year. Results of individual internal audits are reported to management and summary reports provided to the audit committee of the board of directors. Internal audit paradigm flaws The key flaw in the current internal audit paradigm is that it does not position responsibility for assessing risks and reporting upwards on the state of residual risk linked to the company’s most critical value creation and value preservation objectives squarely with the people that should have primary responsibility – management. It discourages management from learning how to formally assess and report on residual risk status linked to key ■ A large percentage of companies and their boards have not embraced the need for management to self-assess and report on the state of residual risk linked to their most important value creation and value preservation objectives and report consolidated results upwards to the company’s board of directors. As long as management in a company is unwilling to perform this role, internal audit must continue to do direct report audit engagements on a small percentage of the risk universe (i.e. there are no management representations on risk status on key objectives to audit, hence attestation internal audit engagements are not possible). ■ Becausethemajorityofcompaniesintheworldtodayhavenotimplementedrobustobjective -centricriskself-assessmentframeworks,alargepercentageoftheIIAcurriculum,training, andcertificationstandardsarebuiltonthedirectreportauditparadigmwithaheavyfocus oninternalauditorsopiningonthesufficiencyof‘internalcontrols’. Amassiveandconcerted effortwouldberequiredtoequipinternalauditorswiththeskillsnecessarytoformopinions onthereliabilityofobjective-centricriskself-assessmentsasmanyinternalauditorslackthe skillstocompletethem. ManyinternalauditorsarenotcurrentlytrainedtocompleteISO 31000/COSOERMcompliantriskassessmentsand,byextension,notequippedtoreport whetherobjective-centricriskassessmentsdonebymanagementarereliable. ■ Many boards and senior executives don’t believe internal audit can add significant value to their company’s top value creation objectives and are content to have internal audit focus on a relatively narrow range of objectives with a heavy focus on financial controls, IT security, business continuity, fraud prevention and other value preservation/defence areas. barriers to change (Continued) 0 Fully acceptable Composite residual risk status is acceptable. No changes to risk treatment strategy required at this time. (NOTE: this could mean that one or more significant risks are being accepted. Information on accepted concerns is found in the residual risk status information) 1 Low Inaction could result in very minor negative impacts. Ad hoc attention may be required to adjust composite residual risk status to an acceptable level 2 Minor Inaction or unacceptable terms could result in minor negative impacts. Routine management attention may be required to adjust composite residual risk status to an acceptable level 3 Moderate Inaction could result in or allow continuation of mid-level negative impacts. Moderate senior management effort required to adjust composite residual risk status to an acceptable level 4 Advanced Inaction could allow continuation of/or exposure to serious negative impacts. Senior management attention required to adjust composite residual risk status 5 Significant Inaction could result in or allow continuation of very serious entity level negative impacts. Senior management attention urgently required to adjust composite residual risk status to an acceptable level 6 Major Inaction could result in or allow continuation of very major entity level negative consequences. Analysis and corrective action to adjust composite residual risk status required immediately 7 Critical Inaction virtually certain to result in or allow continuation of very major entity level negative consequences. Analysis and corrective action to adjust composite residual risk status required immediately 8 Severe Inaction virtually certain to result in or allow continuation of very severe negative impacts. Senior management/board-level attention urgently required to adjust composite residual risk status 9 Catastrophic Inaction could result in or allow the continuation of catastrophic proportion impacts. Senior management/board level attention urgently required to adjust composite residual risk status and avert a catastrophic negative impact on the organisation 10 Terminal The current composite residual risk status is already extremely material and negative and having disastrous impact on the organisation. Immediate top priority action from the board and senior management required to prevent the demise of the entity. COMPOSITE RESIDUAL RISK RATING DEFINITIONS Endresultobjectives (implicitorexplicit) Internal/externalcontext Residualriskstatus Threatsto achievement/risks? Risktreatmentstrategy Riskmitigators/controls Risktransfer, share,finance (selectedconsciously orunconsciously) Acceptable? Risktreatment optimised? YES RiskStatuslineTM NO NO Re-examinerisktreatment strategyand/orobjective anddevelopactionplan YES –Moveon 2015RiskOversightSolutionsInc. SAMPLE summary report for senior executives and the board Independent assurance level (IAL) Low Medium Current risk assessment rigor (RAR) Medium (M) VeryLow(VL) Potential to erode entity value Low High Potential to increase entity value Medium High CRRR update date 6/12/2014 6/10/2014 Composite residual risk rating (CRRR) 6 — Major 4 — Advanced End result objective owner/ sponsor(s) Tim Leech Tim Leech Corporate l l Description Ensurethatfinancial statementsarereliableand incompliancewithGAAP Safeguardandenhance ABCsreputation A call to action — boards and CEOs need to drive paradigm shift efforts Globally, the ERM and internal audit professions have a serious case of paradigm paralysis that is impeding their ability to help boards and CEOs meet new risk governance expectations. Boards and CEOs need to play a key role driving a quantum paradigm shift in risk management and assurance thinking to make improvements in risk culture. When paradigm paralysis occurs it is always worth remembering the words of Albert Einstein, “Insanity: doing the same thing over and over again and expecting different results”.5 Expecting the same internal audit and ERM methods used over the last 20 to 30 years to produce dramatically different and better results for stakeholders is poor judgement at best. The authors hope that the paradigm shift ideas in this paper will help drive further thought leadership and the developments necessary to produce the quantum paradigm shift in ERM and internal audit methods necessary to help boards and CEOs better meet new risk governance expectations. 1 Example:SeeFinancialStabilityBoardPrinciplesforanEffective RiskAppetiteFrameworksenttoregulatorsaroundtheworld http://www.fsb.org/wp-content/uploads/r_131118.pdf 2 Note: COSOusestheterm‘riskresponses’.ISO31000,theglobal riskmanagementstandardusestheterm‘risktreatments’.In bothcasesthetermreferstothefullrangeofwaystofinance, share,transfer,mitigate,avoidandacceptrisk. 3 SeeOfficeof SuperintendentFinancialInstitutionsJune2016E21Operational RiskGuidelinesforanexampleofaregulatorendorsing‘Three LinesofDefense’ 4 SeeFinancialStabilityBoardPrinciples foranEffectiveRiskAppetiteFrameworkhttp://www.fsb.org/ wp-content/uploads/r_131118.pdfandIIAResearchFoundation AuditingRiskAssessmentandRiskManagementProcesses 5 Source:AlbertEinstein.(n.d.).BrainyQuote.com.Retrieved 29June,2016,fromBrainyQuote.comWebsite:http://www. brainyquote.com/quotes/quotes/a/alberteins133991.htm) Boards and CEOs need to play a key role driving a quantum paradigm shift in riskmanagement and assurance thinking to make improvements in risk culture value creation/preservation objectives (i.e. it’s not their job to assess and report, so why do they need the skills to do it?). Internal audit coverage is usually a small percentage each year of the total risk universe and often has a heavy bias towards value preservation and financial accounting controls. The audit plan often does not cover the company’s most important value creation/ strategic objectives and is often not well integrated with the work of other assurance groups, including ERM, safety, IT security, environment, compliance, insurance and others. The traditional internal audit paradigm often puts serious political pressure on business units to put in place additional ‘internal controls’ linked to the topic audited, even when residual risk status in other areas linked to key value creation/strategic objectives not covered by internal audit warrant more of the scarce risk treatment resources. Our work globally suggests that only a small percentage of internal auditors today use objective-centric risk assessment methods on their audits that conform to risk assessment methods defined by the global risk management standard, ISO 31000, or COSO ERM 2004/ED 2016. A large percentage of internal auditors report opinions on sufficiency of internal controls, not the full range of risk responses/risk treatments in place. This can result in seriously flawed results and opinions. An opinion from internal audit on whether internal controls are effective, or not, is fundamentally an opinion from the internal auditors on whether they think residual risk status is acceptable to the company and the board – information the internal auditors often don’t have and decisions internal auditors aren’t authorised or trained to make. It is important to note that the Financial Stability Board (FSB) and the Institute of Internal Auditors (IIA) are increasingly calling on internal audit groups to assess and report on all of their company’s risk management processes.4 When internal audit is the group with primary responsibility for completing documented risk and control assessments this requires internal audit report on itself – a violation of audit independence standards. The way forward: a board/CEO-driven internal audit paradigm shift Boards and CEOs need to call for implementation of robust objective-centric risk self-assessment frameworks that use an objective register as the foundation. See details above. When an objective register is used as a foundation for ERM it defines the role of owner/ sponsors, ERM specialists, and independent assurance staff and, by definition, focusses resources on objectives key to long-term value creation and preservation. Require internal audit use the company’s objectives register not an audit universe as their work foundation. Once management with the assistance of ERM specialists has completed the assigned risk assessments at the defined level of risk assessment rigour, internal audit completes quality assurance reviews where internal audit has been defined as the independent assurance providers to achieve the target independent assurance level defined in the objectives register. For some objectives in the objectives register the board and/or C-Suite may assign other independent assurance providers. The primary goal of internal audit is to provide the board with opinions on the effectiveness of company’s enterprise risk management processes and the reliability of the consolidated report from the CEO to the board on residual risk status. Internal audit should also flag any areas where they think management is accepting levels of residual risk that they believe may be outside of the CEO and/or the board’s risk appetite/tolerance. Ensure the internal audit team is staffed appropriately to contribute on top value creation and value preservation objectives. This can include management rotation programmes and hiring of staff from non-traditional internal audit backgrounds (i.e. outside of accounting, IT security, external audit).