Human Rights Risk Management Process

Bangladesh Building Collapse

The fire in a nine-story factory building in Bangladesh killed 400 people. More than 600 people remain unaccounted for. It housed five garment factories that supplied to international brands – J.C. Penny, The Children’s Place, Dress Barn, Primark, Wal-Mart etc. The workers were asked to come to work even when cracks appeared in the building the previous day.

Bangladesh is the second largest exporter of clothes and the workers get the lowest compensations. Just around USD 37-40 per month. The question arises why are the multinational organizations not following the UN Guiding Principles for Human Rights protection. The reason is simple; they want to show higher and higher profits to the investors.

In Delhi, in Munirka one will find numerous small factories full of workers making export garments. A friend of mine also ran one. I had bought a few shirts from her at cost price ranging from Rs 300-500 (USD 6-10). In one international visit, I found the same shirts selling in range of USD 15-30. The fivefold increase in price was because of the brand tag attached to the shirt.

The multinational buyers push the prices down and some supplier gives a rock bottom price. The others are forced to match that price to get the business. End result is that basic facilities are not provided to the workers and they work at really low wages. Unknown workers are paying with their lives in developing countries to satisfy the growth targets set by CEOs to earn their bonuses and keep investors happy.  It is the dark side of capitalism which organizations want to hide.

In most companies, human rights risk management is not a focus area. The 2013 Global Risk Management Survey conducted by RIMS identified seven risks related to human resources among the top fifty risks. Though worker injury and harassment were included there was no specific emphasis on human rights risk management.

The risk management team can conduct annually or bi-annually a human rights risk management assessment. It requires attention not only from human resources perspective but from operational, financial, legal and reputational risks perspective. Any breach can result in huge losses.

Here are some of the steps mentioned in the UN Guiding Principles on Human Rights and guide “Investing the Right Way” issued by Institute of Human Rights and Business.

1.     Review the Human Rights Policy Statement

Human rights risk management is emerging as an important issue, especially with multinationals entering emerging markets and developing countries. They are expected to protect and respect rights of workers, communities and society. Investors can play a crucial role by influencing companies to promote human rights relating to gender equality, child labor, rights of indigenous people, land acquisition, mineral processing etc.

Hence, companies need to publish Human Rights Policy Statement on their websites. The UN Guiding Principle 16 states –

 “As the basis for embedding their responsibility to respect human rights, business enterprises should express their commitment to meet this responsibility through a statement of policy that:

(a) Is approved at the most senior level of the business enterprise;

(b) Is informed by relevant internal and/or external expertise;

(c) Stipulates the enterprise’s human rights expectations of personnel, business partners and other parties directly linked to its operations, products or services;

(d) Is publicly available and communicated internally and externally to all personnel, business partners and other relevant parties;

(e) Is reflected in operational policies and procedures necessary to embed it throughout the business enterprise.”

As a first step risk managers need to check whether the organization has a human rights policy statement and the above mentioned steps have been adhered to.

2.     Human Rights Impact Assessment

The second aspect of UN Guiding Principles is for companies to establish human rights due diligence processes. Guiding Principle 17 states:

 “In order to identify, prevent, mitigate and account for how they address their adverse human rights impacts, business enterprises should carry out human rights due diligence. The process should include assessing actual and potential human rights impacts, integrating and acting upon the findings, tracking responses, and communicating how impacts are addressed. Human rights due diligence:

(a) Should cover adverse human rights impacts that the business enterprise may cause or contribute to through its own activities, or which may be directly linked to its operations, products or services by its business relationships;

(b) Will vary in complexity with the size of the business enterprise, the risk of severe human rights impacts, and the nature and context of its operations;

(c) Should be on going, recognizing that the human rights risks may change over time as the business enterprise’s operations and operating context evolves.”

Human rights risk management is complex and challenging. If ignored, they can increase political risks and deteriorate relationships of the organization with the government. For example, Tata Motors wished to establish Nano manufacturing plant in Singur, West Bengal. The government allocated agriculture land using 1894 land acquisition rule, meant for public improvement projects, to take over 997 acres farmland. The farmers protested with help of activists and the then opposition leader Mamta Banerjee. Tata Motors moved out of West Bengal and established the factory in Gujarat. Multinationals looking for large tracts of land to establish factories are facing similar challenges in India.

Another aspect to look into is that scrap, waste disposal, sewage, environment pollution etc. from factories can impact food, water and health of local communities.

Decision needs to be taken whether investments should be made in countries or states with poor human rights record. In India, the Naxalite area is extremely conflict prone and business operations can have severe human rights impact.

Risk managers should evaluate the strategy and operations of the company from human rights, environmental, social and governance factors. The companies can face operational risks (project delays or cancellation), legal and regulatory risks (lawsuits and fines) and reputational risks (negative press coverage and brand damage). The impact assessment should be done from investors, customers, employees, society and supplier perspective. Identify business owners for the risks and devise appropriate risk mitigation plans to address adverse impact.

3.   Grievance Mechanisms

UN Guiding Principles state that victims of corporate related human rights abuse should have access to judicial or non-judicial remedies. Companies should provide some remedies themselves and cooperate in the remediation process.

UN Guiding Principle 29 states –

“To make it possible for grievances to be addressed early and remediated directly, business enterprises should establish or participate in effective operational-level grievance mechanisms for individuals and communities who may be adversely impacted.”

However, this isn’t followed by the companies in true spirit. “A Vigieo analysis of human rights records of 1500 companies listed in North America, Europe and Asia revealed that, in the previous three years, almost one in five had faced at least one allegation that it had abused or failed to respect human rights.”

Ideally the investors in the company should ensure that grievance mechanisms exist and address human rights issues. The transparency and disclosure of the same in annual reports would highlight the financial, legal and reputational risks. However, the investors don’t seem to be bothered by it.

See the case of Apple. It reported  Gross Profit Margin – 42.5%, Net Profit Margin – 26.7%, Revenue Per Employee – $ 2,149,835 and Net Revenue Per Employee – $ 573,255. It has 43000 employees in US and 20,000 outside US. However, Apple contractors hire an additional 700,000 people to engineer, build and assemble iPads, iPhones and Apple’s other products.

An Apple supplier in Taiwan, Foxconn was recently in the news for its workers attempting suicide. As per reportsWorkers are required to stand at fast-moving assembly lines for eight hours without a break and without talking. Workers, sharing sleeping accommodations with nine other workmates, often do not know each other’s names. They do not have much time to get to know each other. The basic starting pay of 900 RMB($130) a month – barely enough to live on – can be augmented to a more respectable 2,000RMB ($295) only by working 30 hours overtime a week.”

See the difference the company earns per employee and the payment made to the supplier’s employees. Apple shows profits at the expense of lives of Taiwanese workers.  The workers don’t have much of a grievance mechanism in China as the government stated that the suicides are within the normal suicide rate. Can Apple investors sacrifice some profit margin for safety and security of the contractual workers?

Another old example is the class action suit since 2001 on Wal-Mart Stores that involved 1.5 million current and former Wal-Mart female employees. It is the largest workplace bias case in US history.

 4.    Human Rights Reporting

 The biggest challenge is that most of the human rights abuses are not reported. The victims of human rights exploitation hold little power in comparison to the exploiters. They can hardly take up the might of powerful businesses when they are struggling to get basic food and shelter. Secondly, in the developing and emerging countries, corruption levels are generally high. Hence, media, law enforcement agencies etc. are bribed by the power players to silence the victims. However, with internet and social media, things are gradually changing. People have a voice and collectively they can fight.

UN Guiding Principle 21 lays out the requirement for companies to communicate human rights impact externally. It states -

 “In order to account for how they address their human rights impacts, business enterprises should be prepared to communicate this externally, particularly when concerns are raised by or on behalf of affected stakeholders. Business enterprises whose operations or operating contexts pose risks of severe human rights impacts should report formally on how they address them. In all instances, communications should:

(a) Be of a form and frequency that reflect an enterprise’s human rights impacts and that are accessible to its intended audiences;

(b) Provide information that is sufficient to evaluate the adequacy of an enterprise’s response to the particular human rights impact involved;

(c) In turn not pose risks to affected stakeholders, personnel or to legitimate requirements of commercial confidentiality.”

 As per the UN principles, the reports must cover appropriate qualitative and quantitative indicators, feedback from internal and external sources including affected stakeholders.

Risk managers can evaluate the reports and the reporting process to ensure that all risks are properly addressed. They should evaluate whether cautionary steps are taken and nothing is being done to exacerbate the situation. They should highlight severe or irreversible risks to the management to ensure appropriate decisions are taken.

Closing Thoughts

 Inequalities in income are the main cause of human rights abuse. The rich want to get richer at the expense of blood and sweat of the poor, and sometimes life. The diamond manufacturers and sellers took the right step to publish that they do not source blood diamonds. Since 2003, the Kimberley Process Certification Scheme (KPCS), supported by national and international legislation, has sought to certify the legitimate origin of uncut diamonds. Trade organizations – International Diamond Manufacturers Association (IDMA) and the World Federation of Diamond Bourses (WFDB) – representing virtually all significant processors and traders – have established a regimen of self-regulation.

Other industries, be it technology, electronics or textile manufacturers,  need to come out with similar steps to stop human rights abuse. The risk managers have a vital role to play in it. If we do not do anything, we are cheating this and the next generation of their right to live happily.

References:

  1.  Investing the Right Way – A Guide for Investors on Business and Human Rights – By Institute of Human Rights and Business
  2. Singur farmland-  Tata Motors conflict
  3. Apple financial ratios
  4. Foxconn Case Study
  5. Diamond industry sales clauses
  6. 2013 RIMS Global Risk Management Survey

 

Role of Positivity in Risk Management Communication

locking horns

Can something as simple as appreciation make business teams more willing to accept a risk manager’s viewpoint?

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The Conflict

Proverbially risk managers are locking horns with business managers. Of course business managers out number risk managers, hence more often than not risk managers are licking wounds and complaining that business managers don’t listen to them. Business managers claim that they are running the show, so an interfering risk manager who is perpetually criticizing their hard work  should be shown the door.

Then risk manages lament that it is their job to high light risks which means negatives, so why go after them for being messengers of bad news. The conflict brews and sometimes reaches boiling point. No one wishes to see eye to eye because they wish to get eye for an eye. End result, the business suffers in this battle.

What is the cause of the stormy relationship? Criticism and negative feedback! No one likes it, so why blame the business managers.

What if risk managers change the approach? With the criticism they give a lot of positive reinforcement? Will the behavior of business managers change?

Research on Role of Positivity in Performance

Marcial Losada and Emily Heaphy conducted a research titled – “The Role of Positivity and Connectivity in the Performance of Business Teams – A Nonlinear Dynamics Model”. They studied the dynamics of team interaction in relation to approving and disapproving verbal feedback statements. Researchers coded the verbal communication among team members along three bipolar dimensions, positivity/negativity, inquiry/advocacy, and other/self. Sixty teams developing annual business strategy were analysed.

The results of the study have extremely important implications  from business performance aspect and for risk managers. The table below defines the ratios of various dimensions.

team ratio1

The positivity/ negativity ratios indicate that high performing teams give 5.6 positive comments to 1 negative comment. In contrast the low performing team give three negative comments to one positive comment. The medium performing teams give approximately two positive comments to one negative comment.

Similarly, under inquiry/advocacy ratios, the high performance teams are more balanced in their approach towards inquiry and advocacy. The team members question in an exploratory way. On the other hand, low performance teams are highly unbalanced and members advocate their own viewpoint. The medium performance teams are little bit tilted in favor of advocacy.

Again, high performance maintained a balance in discussing internal and external aspects. Whereas, low performance teams focus on internal inquiry. The medium performance are slightly more focused on internal than external aspects.

Thus, the high performance team have higher levels of connectivity, which results in better performance.

Overall, high performing teams show buoyancy throughout the meeting. They appreciate, compliment and encourage their team members. This expands the emotional space for team to function. In contrast, in low performance teams sarcasm and cynicism rules which restricts the emotional space. There is lack of mutual support, enthusiasm and a high degree of distrust.  The medium performance team don’t show distrust or cynicism but neither are they openly supportive and enthusiastic about their team members.

team dynamics

Implications for Risk Managers

The results are very important from a risk manager’s perspective. As the author states – “to do powerful inquiry, we need to put ourselves sympathetically in the place of the person to whom we are asking the question. There has to be as much interest in the question we are asking as in the answer we are receiving. If not, inquiry can be motivated by a desire to show off or to embarrass the other person, in which case it will not create a nexus with that team member.”

Hence, from the time we approach the business team, we need to ensure that we are inquiring about the business. We should not be advocating any quick recommendations based on high-level interactions.

Another point to note is that the questions should cover both the internal and external environment of the business. This would motivate the business team into a more open discussion.

The most important point is about positive feedback. In our verbal communication and written reports we focus on highlighting the negatives.

The research showed that positive comments (that is a terrific idea) create emotional space within the listener, hence the listener is more willing to take the feedback. The emotional space created by positive comments in high performing teams is twice the size of medium performing teams and three times that of low performing teams.

Negative reporting restricts the emotional space of the business team. To build a positive environment for acceptance of our views, recommendations and report, we need to give 6 positive comments for each negative comment.

The researchers have given equations to assess the emotional space based on various dimensions. It might be a good idea to calculate the same before issuing a report.

Closing thoughts

One of the incorrect assumptions that risk managers make is that there is a linear relationship between the observations and recommendations in the report. However, the study showed the impact of non-linear relationships on functioning of teams. Hence, the fault may lie in the straight forward cause and effect attitude taken by risk managers to get buy-in from business managers.

We generally discuss that in reports we should highlight the positives first to balance out the negatives. This research clearly points out the importance of doing so and the reasons why we are failing. We have to change our approach to be effective. We need to be part of the business team, develop a positive feedback system before giving any negative observations

References:

The Role of Positivity and Connectivity in the Performance of Business Teams: A Nonlinear Dynamics Model - Marcial Losada and Emily Heaphy

Risk Management Version 3.0

RM tiger

The business world is changing so rapidly that companies are either not willing to publish growth predictions or they are getting it wrong. In this new world trends can’t be analysed from historical data. The best business analytic teams fail because the new business models have totally different risks. Moreover, now the risks are interconnected and can’t be addressed separately. An operations risk may have a huge impact on financial risks.  The old compasses are useless and most are walking on uncharted territory.

This is the ideal time for risk managers to shed their old avatars and  become new super heroes of business. First they have to get out of their comfort zone of addressing internal risks that are preventable. The compliance and control based approach leaves over 60% of the risks un-addressed. If we consider that Risk Management version 1.0, we need to rapidly move to Risk Management version 3.0.

So what does version 3.0 look like?

1. Focus on Strategic Risk Management

I consider Enterprise Risk Management frameworks approach as Risk Management version 2.0. Though they covered strategic risks the focus was on finance, processes and technology. Hence, in reality it has become a bottom-up approach though the initial purpose was to make it top down. Risk managers are still not involved at strategic level and it is the Chief Strategy Officers who are analyzing strategic risks.

My guess estimate is that we depute less than 10% of resources to strategic risk management. We need to put in processes and resources where approximately 25% of efforts are focused on strategic risk management. Strategy failure probability has increased in present business environment.  For managing strategic risks reduce  probability of occurrence of assumed risks and effectively manage them if they occur.

2. Focus on Human Behavioral Risks

Industrial age focused on mechanization and streamlining of processes. Products were produced on the assumption that human behavior can be straight jacketed. In the age of technology and social media, this assumption has proved false.  Social media and data analysis allows behavioral analysis of each individual.

Secondly, the bigger challenge the world is facing is of changing demographics. In the last few decades, the average age has changed from 60 years to 75-80 years. The older generation lives longer and works longer. The Gen Y is entering the workforce with different expectations. Women have not only broken ground in the corporate world, but have become main decision makers for household purchases. Emerging market customers and employees have different behavior patterns.  The leadership skill sets have changed drastically. Participative and consultative cultures are more successful now.

Therefore, whether an organization wishes to fight  war of talent or entice customers, understanding human behavior has become crucial. Each segment of employee, customer and other stakeholders present different risks which an organization needs to manage successfully. Without addressing these risks at strategic and operational level, an organization is unlikely to succeed.  Risk managers traditionally haven’t focused on people, leadership or culture risks. In this century they need to.

3. Integrate Risk Management Knowledge & Resources

The traditional approach of having different experts of financial, operational and other risks in separate departments and addressing each risk in a linear manner is redundant. Moreover, now businesses are significantly exposed to external risks, which was not the case before. The Vodafone and Nokia tax cases are prime examples of risks occurring due to change in government stance.

Risk Management version 3.0 requires integrated risk management where risk managers with diverse skills can assess inter-related risks – internal and external. Secondly, risk managers have to be available within the business and as a separate department. The risk managers operating as part of the business unit need to identify the business risks and update the risk management department. The department needs to devise holistic solutions.

The risk management tools, technology, processes and resources all need to restructured to operate in an integrated manner at all levels.

Closing Thoughts

I suspect, group think is prevailing among risk managers. No one wishes to be a bull in a china shop and say – “hey this isn’t working.” It is ironic that risk managers are not doing adequate risk management of their own role and function. Old habits die hard and getting out of the comfort zone is scary, but I think we need to do it. Else, business failures are going to increase at a high rate. In the current economic environment, we can’t afford those losses. Think about it and share your views.

Wishing all my readers a very Happy Holi.

5 Things CFOs Should Do In Planning Process

In December, senior management focuses on formulating strategies. Department heads prepare business plans and budgets. Risk management departments define the next year’s agenda and plans. Everyone works hard at planning and preparing for the coming year. However, most of the efforts are in vain and result in failure. The problem is that generally people do these activities independently and make no attempt to align them. The ideal integrated sequence is below.

strategy

However, this does not happen. For instance, department heads do capital expenditures while ignoring the strategy. Business teams define performance indicators and risk managers establish risk indicators, without syncing the two indicators. Situations occur where desired performance is achieved at very high-risk levels. Business teams ignore the risk levels until disaster occurs. With the multitude of unsynchronized management information, boards make incorrect decisions with information overload. Hence, at the end of the year only a few organizations can claim that they achieved the strategy and targets.

The Chief Financial Officers (CFOs) can play a pivotal role in bringing the different facets together. CFOs sit on the board and participate in the strategy formation process. Department heads submit their plans and budgets to CFOs for review and consolidation. Generally, Chief Audit Executives (CAE) administrative reporting is to the CFO. Quite frequently, CFOs act as defacto Chief Risk Officers (CRO). Hence, CFOs can put the jigsaw puzzle together. The key things they need to look into to revamp the process are as follows:

 1.     Strategy Formulation

 The common misperception is that organizations have a proper strategy formation process. In reality, the ideas supported by the CEO and politically strong CXOs are adopted without much constructive discussion since no one wishes to rock the boat. Secondly, a formal strategy process is not in place in most organizations. Moreover, at the time of strategy formation upside and downside risks remain unidentified, as CXOs do not invite CRO to the discussion. The CFOs can influence the other CXOs to implement a formal strategy development process and conduct a strategic risk assessment in each phase of strategy formation.

2.     Business Plans

While strategies are for 3-5 year period, business plans are drawn annually. However, the changing business landscape makes business plans redundant on formation. Reason being that business plans are prepared on a set of assumptions on customer behavior  engagement and market situation. Real interaction with customers and entry into the market prove most of the assumptions incorrect. Additionally, department heads make independent business plans to show one up man ship. Hence, performance objectives are missed and risks remain unidentified. The need of the hour is for businesses to react fast and give cohesive messages in response to market changes. Therefore, CFOs must make the business planning process dynamic and integrated.

3.     Budgets

More than 60% of the organizations are unsatisfied with their ability to link strategy to operating budgets. Additionally, organizations spend 4 to 6 months in preparing budgets with numerous iterations back and forth between departments. Meanwhile the business plans change due to the volatility in the market. Hence, organizations are feeling the need of speed in the budgeting and forecasting process. CFOs must adopt rolling forecasts rather than static budgets to improve planning and control. Rather than doing post facto variance analysis they can collaborate with business teams to give real-time analysis.

4.     Performance Indicators

Performance indicators measure the reward side of the strategy. Without the risk indicators, they give an incomplete picture of business status. Another aspect is that performance indicators and risk indicators for the same strategy or plan are not aligned together and are reported at different periods. Organizations sometimes continue to measure redundant parts and do not update the indicators with change in strategy and objectives. A prime example is the financial crises. A few banks achieved performance targets without understanding the risk levels. Hence, CFOs must use technology to create relevant dashboards to monitor indicators to keep a firm grasp on the business.

5.     Risk Indicators

 Risk managers fail to address the twin shortcomings in process of identifying key risk indicators. Firstly, risk managers do not ascertain strategic risk indicators. Secondly, a lot of meaningless indicators are created which do not really find out the overall business risks. Hence, CXOs fail to separate the noise from the inflection points. Moreover, Nassim Taleb’s point of view that most significant risks are unpredictable needs to be thought over. There might be too much data available and organizations might look at risk indicators they are comfortable with, until the bubble bursts. CFOs can identify key risk indicators for strategy and business plans, and synchronize them to performance indicators. That will close the loop and move the business in the right direction.

Closing Thoughts

Synchronizing multiple factors between strategy and indicators influences a company’s capacity to achieve goals. With predictions of recession and volatile business environment, dropping the ball is highly probable. Understanding which economic predictions to rely on, which market trends will impact long-term and what are the strategic inflection points, spells the difference between success and failure. Hence, CFOs must play the vital role of coordinating and aligning various steps between strategy formation and identifying indicators.

IBM CEO Survey Insights On Customer Focus

The 2012 CEO survey conducted by IBM gives some interesting insights. Seventy-three per cent CEOs are gearing their organizations to gain meaningful insights from customer data. This is the area of highest investment.  The traditional approach to segment customer data to calculate statistical averages has been replaced with understanding the attitudes and tastes of individual customers.

The main aim of gathering holistic customer information is to devise services and products targeted at the customers and improve the response time. As stated in the report – “The challenge for organizations is two-fold: can they pick up on these cues, especially if the information comes from outside? And can the appropriate parts of the organization act on the insights discovered?” The graph depicts the main reasons for capturing customer information.

Further, the report mentions, that though most of the CEOs focus on capturing information, out-performers excel at acting on insights. The difference is innovation and execution. A quarter of the CEOs reported that their organizations are unable to derive value from the data. Speed of action is required to capture data, analyse, prepare strategies and respond to customers. As one CEO stated the most crucial characteristic is to “organize a major wake-up call.” The customer obsessed CEOs are driving the organizations to more contextual customer insights.  The graph below highlights the marked difference in under-performers and out-performers.


Risk managers can play a pivotal role in helping CEO’s achieve these objectives. They can focus on the following.

1.     Organization Culture and Process Change

A customer oriented organization culture is required to leverage the opportunities. Secondly, the organization needs to align the processes towards customer relationship management. Risk managers can conduct organization culture survey to assess customer orientation. Moreover, they can review processes to determine risks and controls to mitigate risks.

2.     Security of Data

The activity requires accumulation of extensive customer personal information. Generally, companies use separate data centres to collect and analyse the data. However, the risks of loss and theft of data is huge. As in the recent case of Facebook 1.1 million users’ data was sold for US $5. Therefore, it is a good idea to review security polices and test data centre security.

3.     Return on Investment

Data collection requires huge investments in technology and resources. As the CEOs are saying the failure rate is quite high. A review of projects, plans and strategy would identify the pain points and misdirected activity. Calculating return on investment on various programs might steer the investments in the right direction. Timely identifying failing projects and reasons for failure is critical to maintain cost effectiveness.

Closing thoughts

Technology and social media has brought customers closure to companies. The face-to-face customer interaction is gradually shifting towards social media. The companies that are able to navigate this transition successfully will outperform their peers in the industry. Hence, risk managers should support this CEO initiative to enable the organization to leverage upside risks.

What is your organization doing in this respect? How do you think risk managers should facilitate CEOs in this initiative?

References:

Leading Through Connections – IBM CEO Survey

Is Doing Nothing A Reputation Risk?

Tim Cook, CEO of Apple, recently issued an open letter on Apple website, publicly apologizing for the shortcomings in the Apple maps. The first paragraph reads:

“To our customers,

At Apple, we strive to make world-class products that deliver the best experience possible to our customers. With the launch of our new Maps last week, we fell short on this commitment. We are extremely sorry for the frustration this has caused our customers and we are doing everything we can to make Maps better.”

The purpose was to pacify the angry customers who found inaccuracies in the Apple maps. The words of the CEO mattered.

Now let us assume that none of the customers knew who the CEO of Apple is. They have not heard of the CEO before. The CEO visibility was zilch in media, social networks, business conferences etc. Would the words have mattered then? Wouldn’t the customers say – “Who is this guy? We never heard from him before and now he is giving excuses for horrid products?”

Managing an organization’s reputation is part of CEO/CXO job. When reputation risks occur, their communication is part of the risk mitigation plan. Hence, the effectiveness of risk mitigation plan is dependent on the CEO/CXO profile. Until here, I think you will agree with me.

Now let me ask you the difficult question. If the senior management of the organization does nothing to add to the brand or reputation of the organization, is it a risk?

Here is my argument. Normally, we take the following criteria for reputation risks.

Source- ICAI ERM Training Material

This measures only the negative impact. We talk about negative coverage in the media, but what about no coverage in media. In India, most of the CEO/CXOs have no media visibility and unlike the west, 90% do not give interviews etc. in the media. They even don’t have a social media presence and one can hardly find them directly interacting with customers. That is, except for traditional advertising of products in newspapers, magazines and television, there is no coverage of the organization and the senior management in the media.

Now let us see from risk management perspective. One of the strategic objectives of the organization is to build brand and reputation of the organization. The purpose of enterprise risk management is to give an assurance to the board that the entity is moving in the right direction to achieve its objectives. As risk managers, we focus if something goes wrong, but what if, the company is not moving at all in any direction – positive or negative – in meeting its objectives. Should we capture that as a risk?

Closing thoughts

Negative viral messages in social media tarnish a reputation in a span of few hours. It takes just one tweet to go viral. It will be very difficult for a company to defend itself if a company does not have a twitter account and reputation management plan. The same applies to executives. Now the thought process is either develop a brand or get branded. Silence gives an opportunity to others to put labels and develop negative perceptions. Continuous positive messages at a personal level need to go out about the brand for customers to have a favorable opinion. Doing nothing may become a huge risk.

Industry Disruption Risks

The biggest risk of all is industry disruption risks. One fine day the competitive landscape of the industry transformed and it caught us by surprise. Ouch, the world changed while we were sleeping. It is a CEO’s recurring nightmare, and the risk managers do not focus on it much. Reason as I mentioned in my recent posts is that risk managers assume they do not have the right or duty to question the strategy or strategic objectives. Let us discuss this in detail.

Andrew Grove in his book “Only the Paranoid Survive” described the strategic inflection point. He said – “An inflection point occurs where the old strategic picture dissolves and gives way to the new, allowing the business to ascend to new heights. However, if you don’t navigate your way through an inflection point, you go through a peak and after the peak the business declines.” The strategic inflection point disrupts the industry completely and can wipe out old companies in a few years.

1.      The Intel Story

Fascinatingly, Intel itself missed the strategic inflection point of mobile computing. Intel controls 80% of the world’s PCs chip market. It failed to make a timely dent in the handheld devices. Nvidia, Texas Instruments, Qualcomm and Samsung rule the ARM chips market for smartphones and tablets. Intel is now positioning itself in this market with its x86 chips. With the shrinking in the PC, laptop and server market, let us see whether Intel can re-position itself as the smartphone and tablet chipmaker. IPhones and IPads disrupted the technology industry; and surprisingly the giants of the industry – Intel and Microsoft – both missed the boat.

2.      The India FDI Retail Story

Closer home, the opening up of foreign direct investment in retail industry has shaken the complacent industry from its roots. Expected entry of Wal-Mart is causing havoc in the minds of established players. Most of the food retail sector in India comprises of Mom-Pop local stores that supply at low costs. Some organized chains as Reliance, Bharti, Nilgiri’s etc. have started catering to the upper middle class requirements; however have not wiped out the smaller stores. The opening of the retail sector to foreign investment is indicative of industry disruption. The industry is gearing itself to deal with the new risks to retain the competitive advantage.

3.      The ERM Perspective

COSO ERM –Integrated Framework, 2004 defines ERM as:

Enterprise Risk Management is a process, effected by an entity’s Board of Directors, management and other personnel, applied in strategy setting and across the enterprise, designed to identify potential events that may affect the entity, and manage risks to be within its risk appetite, to provide a reasonable assurance regarding the achievement of entity objectives.

 Going by the definition, identifying industry disruption risks comes under risk managers’ purview. However, we tend to take strategy as given and don’t challenge the strategy and strategic objectives. We need to change our perspective. Building and retaining competitive advantage is a strategic objective. The industry disruption events can wipe that out. Hence, include identifying disruption risks as part of risk assessment.

Closing thoughts

Industry disruptions occur due to external forces – regulators, competitors, suppliers, customers and society. To identify strategic inflections points risk managers must meticulously track the external environment. Understanding external environment is difficult and requires extensive industry knowledge. Therefore, I know, some of you would be wondering whether it is part of our job. Let us check with the readers.

Misunderstanding of Risks Between Business Teams and Auditors

PWC Internal Audit survey highlighted one critical shortcoming of Chief Audit Executives and Internal Audit Department. The risks that business teams consider critical are being ignored. I have been covering some of the risks on the blog, namely – people risks, competitive advantage, innovation and creativity, marketing, country risks, etc. According to the survey, more than 20% of the stakeholders reported that internal audit paid too little attention on these risks. Hence, the question is why are internal auditors and risk managers not looking at them. Take a look at this chart first.

PWC Internal Audit Survey 2012

From the survey results, two assumptions can be made. First, the internal audit function is still focused on auditing the processes that link to the financial numbers. Second, they are not understanding the business aspects of the organization. As given below, three things need to be done.

1. Understand business requirements

The situation reminds me of an Archie-Veronica joke. Veronica is trying out a new pair of jeans in a store. She looks in the mirror and says – “The jeans are tight, I wonder what could be the problem.” Archie promptly replies – “You might have gained a few pounds”. Veronica gives one whack on Archie’s head and again makes the same statement. This time Archie replies – “The store may have marked a wrong size on the jeans”. If the internal audit reports were hard hitting, business teams may give the internal auditors a rosy picture. They may not be sharing the true concerns in respect to various business risks. Hence, internal auditors would focus their energies on some unsubstantial risks.  Improve the communication with business teams to understand the risk environment. Create an environment where truthful interactions occur.

2. Add in next year business plan

Last quarter of the year has started today, and most of the organizations will prepare 2013 plans in this quarter. This is a good time to understand the business risks and prepare the 2013 annual audit plan and budgets accordingly. Coordinate with the business teams to understand their annual plans. Identify the risks relating to the plans. Discuss with the teams on how internal audit function can help them. Attempt using collective intelligence and crowd sourcing techniques to develop your plan. Where required, take a call to provide advisory services rather than assurance services. Business managers expect much more from the internal audit function. Hence, gear yourself to meet if not exceed those expectations.

3. Develop talent and skills

In the 20th century internal auditors audited the same financial numbers as external auditors. In the 21st century, the function requires revamping. In my previous article – “New Risks and Uncertainties in 21st Century” – I had conducted a poll. I had asked respondents whether they thought present day risk managers were equipped to deal with 21st century risks. Out of 17 total votes, 15 had responded that less than 50% of the risk managers can manage the new business risks. The verdict was by the risk managers about risk managers. Don’t be a dinosaur and learn new skills to survive in the market. In another 5 years when Gen Y become middle managers, Gen X may become redundant.

Closing Thoughts

With the turmoil in various economies, the 2013 risk landscape will be drastically different. Organizations that are well geared in risk management, have a higher probability of sailing through. Internal auditors and risk managers need to incorporate the impact of globalization, technology and social media in their annual plans. There is no purpose in serving stale bread and expecting business teams to swallow it. Rejuvenate in the new business age.

Wishing all my readers a Happy Gandhi Jayanti. Let us pray that each person believes a little more in non-violence and work towards a peaceful world.

References: 

PWC Internal Audit Survey 2012

Reflections on Reputation Risks

Indians think more highly of themselves than they are. I am not making this up, it is a factually correct statement according to the Country report of Reputation Institute. Respondents ranked India 25th with 51.93 RepTrak score. According to its own evaluation, India deserved a score of 75.67 with 11th ranking. It is ranked 5th for having perception differences between internal and external reputation. A 25th rank among 50 countries ranked isn’t anything to talk about.

In the Companies Reputation report, there was no Indian company in the top 100. Yes, my ex-company Intel was ranked 16th, though its ranking has fallen from previous years.  BMW, Sony and Walt Disney are the top three. Though reputation has a huge impact, most companies do not focus on it. Below is a chart from the Reputation Institute report on the impact of good and negative reputation of various factors.

Reputation Institute Company Report 2012

Customers, society, employees and investors – all are influenced by the reputation of the company. While companies may enjoy a good local reputation, as is the case for many Indian companies, maintaining a global reputation is a different ball game altogether. From the above chart it is clear, investing in a good reputation pays off and adds to the profit margin. Question is what all is required to build a good reputation. Another chart from the report highlights the main aspects:

Seven factors - leadership, performance, products/services, innovation, workplace, governance and citizenship are required to build a global reputation. For instance, Intel was among the top ten for – governance, workplace, performance, and products and services.

On the other hand, in respect of reputation damage, risk managers mostly focus on reputation damage due to misstatement of financial statements and governance. That accounts to just 28% of reputation.  The impact on reputation of other aspects are generally ignored. The question is how can these be built into a risk assessment framework? Besides reducing downside risks, this gives a good option to leverage upside risks. Here are a few things that risk managers can look into:

1. Reputation map – Does the company have a reputation map covering these parameters and defining its progress through the years?

2. Integration level – Is reputation aspects integrated into all the functions of the organization, or is it left to the advertising and communications department?

3. External perceptions – Is the organization depending on advertisements to build its reputation or is it undertaking CSR and other activities also?

4. Participation in industry competitions - Does the organization participate and win industry competitions, for instance “great place to work”, “most innovative company” etc. ?

5. Social Media – How is the company using social media to build its reputation and manage the negative feedback?

6. Risk assessment - Is a risk assessment for reputation conducted to highlight the risks in all the seven areas and mitigation plans prepared?

Closing thoughts

Reputation damage is difficult to quantify and often the risks are not categorically listed. In social media environment, it is far easier to lose the reputation and more difficult to build a good one. In the present environment, they old age thinking  - no news is good news - has become redundant. Just because the organization name hasn’t made headlines for the wrong reasons, it doesn’t mean all is well. The negative under currents slowly erode the good name of the organization. Hence, risk managers need to actively address reputation risks on all seven parameters.

References:

Reputation Institute reports

PS: I changed the background and added a little color to the blog. How is it looking? Please give feedback.

Risk Assessment of Marketing Function

The global economy is facing turbulent times with US in recession, Europe in economic crises and emerging markets growth slowing down. Frequently organizations panic on hearing forecasts of looming recession. They cut down marketing budgets, innovation of products and capital investments. The reaction further adds to the woes, and accelerates the downward trend in sales. Risk managers normally do not focus on marketing department activities and generally are not called upon to share their views on marketing strategies. A look on these areas may prevent the company from going in red and thrive in chaotic times. Here are a few suggestions for risk managers.

1. Bench-mark Marketing Function

The complexities of business world are escalating marketing risks. For survival and growth organizations need resilient marketing and sales functions. They have to identify strategic inflection points in the market and adapt accordingly. In recession customers interest, values and budgets change. With new competition and changing regulations, organizations need to reinvent business models. Hence, as a first step risk managers  need to bench-mark the organization’s marketing function.

Philip Kotler and Johan A. Caslione in their book “Chaotics - The business of managing and marketing in the age of turbulence” have presented a table on marketing function attributes. Out of the 14 attributes, below are 5 critical ones distinguishing between poor, good  and great marketing functions.

Srl    Poor                                        Good                                              Great

1. Product driven                    Market driven                                    Market driving

2. Product offer                       Augmented product offer                 Customer solutions offer

3. Price driven                        Quality driven                                     Value driven

4. Reacting to competitors    Bench-marking competitors             Leapfrogging competitors

5. Function oriented               Process oriented                                Outcome oriented

McDonalds marketing strategies reflect these attributes. In India, McDonalds is opening a purely vegetarian restaurant near Vaishu Devi ( a renowned Hindu temple) and Golden Temple (Sikh’s foremost gurdwara). It is catering to the Indian sentiments; in most religions Indians do not eat non-vegetarian food in a place of worship. Near the temples, generally local vegetarian eating joints thrive and there are no global food chains. The huge number of devotees provide a large market.

A few years back, McDonalds customized its menu according to Indian tastes and introduced vegetarian burgers. The McAloo Tikki (a potato burger) contributes to 25% of the total sales.  It may shock the Americans, but no beef burgers are served in India.

2. Evaluate Cost-cutting Measures

The attitude frequently is to cut costs across board. For instance, if marketing budget is XXX dollars, the total budget will be reduced by 25% without assessing the details and profitable products. Here risk managers need to assess the soundness of decisions taken to reduce costs. Below are a few examples to look for:

a) Advertising : Is the total advertising budget reduced? This would be a wrong move. During recession, the core products that contribute to revenue need aggressive advertisement. The advertising budget spent non-core products and loss making products can be dropped. Moreover, explore cheaper advertising models – social media, internet etc. and reduce budgets on paper and television media.

b) Discounts : Another option adopted to increase sales is to discount all products by a certain percentage. This is a self-destructive strategy as discounts on core premium products would damage the revenue stream in the long-run. If customers require cheaper products, cut the frills in the premium products and introduce a bare minimum model. This will maintain the brand and revenue.

3. Assess Strategy and Systems

Risk managers must assess the marketing strategy and systems to ensure that the risks are systematically identified in a timely manner. Here are a few examples of the same:

a) Core products: Does the strategy focus on core products? Are there systems in place to show the winners and losers? If the systems are inadequate profitability, market spend and customer behavior cannot be captured accurately. Hence, the organization will be unable to adapt strategy to the changing marketing trends and customer behavior. Moreover, companies cannot  reduce costs without identifying inefficient spending.

b) New products : Has the organization delayed the launch of new products during recession? The customers require cheaper products during hard times. Hence, the strategy should be to delay expensive products but focus on products that cater to the new customer requirements and changes in behavior.

Closing thoughts

With economies slowing down, the marketing functions are facing many challenges. Customers are better informed through social media and internet, competitors copy products faster, and price of the product is a driving factor. Risk managers can contribute by conducting risk assessments of the marketing function and helping the teams in identifying the upside and downside risks to their strategies. This is a good place to add to  profitability.

References:

  1. Chaotics - The business of managing and marketing in the age of turbulence - Philip Kotler and Johan A. Caslione
  2. Beefy McDonald’s to Open Veg-Only Outlet in Katra – Economic Times