MANAGEMENT
    STRATEGY
    MEASUREMENT
    Identifying,
    Measuring, and
    Managing
    Organizational
    Risks for Improved
    Performance
    By
    Marc J. Epstein
    and
    Adriana Rejc
    Published by:
    MANAGEMENT ACCOUNTING GUIDELINE

    NOTICE TO READERS
    The material contained in the Management Accounting Guideline
    Identifying, Measuring, and Managing Organizational Risks for
    Improved Performance
    is designed to provide illustrative information with respect to the subject matter covered. It does not
    establish standards or preferred practices. This material has not been considered or acted upon by any senior technical
    committees or the board of directors of either the AICPA or the Society of Management Accountants of Canada and does not
    represent an official opinion or position of either the AICPA or the Society of Management Accountants of Canada.

    STRATEGY
    MEASUREMENT
    Identifying,
    Measuring, and
    Managing
    Organizational
    Risks for Improved
    Performance
    By
    Marc J. Epstein
    Rice University and Harvard Business School
    and
    Adriana Rejc
    Faculty of Economics, University of Ljubljana
    MANAGEMENT ACCOUNTING GUIDELINE
    Published by The Society of Management Accountants of Canada
    and The American Institute of Certified Public Accountants
    MANAGEMENT

    Copyright © 2005 by the Society of Management Accountants of Canada (CMA-Canada).
    All rights reserved.
    Reproduced by arrangement with CMA-Canada.
    For information about the procedure for requesting permission to make copies of any part of this work, please visit
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    1 2 3 4 5 6 7 8 9 0 PP 0 9 8 7 6 5
    ISBN 0-87051-619-1

    INTRODUCTION
    The world has changed significantly in the
    last five years. New and greater pressures
    and risks have dominated both the
    international and business news,
    dramatically altering the issues that
    corporate managers must address.The
    attacks of September 11, 2001 made
    business executives aware that they must
    take action to prevent acts of terrorism
    as well as to prepare for their occurrence
    at the corporate site and in the wider
    community.The collapse of notable
    companies such as Enron and WorldCom
    highlighted the risk of financial fraud,
    raised new concerns about corporate
    governance and internal control, and
    resulted in the Sarbanes-Oxley Act of
    2002 (also referred to as SOX). For
    multinational organizations,because of
    globalization and the rapid development
    of international communications through
    the Internet, corporate activities related
    to environmental degradation, child labor,
    or other social issues in a developing
    country have been able to impact profits
    significantly and quickly in the home
    country. In addition, the risks associated
    with Information Technology (IT)
    installations,mergers,human resource
    policies, and other daily organizational
    activities have escalated.
    IDENTIFYING, MEASURING, AND
    MANAGING ORGANIZATIONAL RISKS
    FOR IMPROVED PERFORMANCE
    CONTENTS EXECUTIVE SUMMARY
    Risk is an inescapable element of
    competing in a market economy.
    Organizations must be able to evaluate
    many types of risk — political, social,
    environmental,
    technological,
    economic,
    competitive, and financial — and
    incorporate the results into decisions
    regarding investments and operations, as
    well as into the systems used to monitor
    and evaluate the effectiveness of the
    actions taken.
    This guideline provides a
    Risk Management
    Payoff Model
    that includes a selection of
    performance measures to properly
    identify, measure, manage, and report risks.
    The model demonstrates that improved
    risk measurement and management not
    only helps the organization prevent loss,
    achieve performance and profitability
    targets, and increase shareholder value, but
    also produces organization-wide benefits,
    such as allocation of resources to the risks
    that really matter, enhanced working
    conditions, and sustained or improved
    corporate reputation.
    INTRODUCTION 5
    DRIVERS OF INCREASED RISK
    AWARENESS
    6
    INCREASED RESPONSIBILITIES IN
    RISK MANAGEMENT
    8
    APPROACHES TO RISK MANAGEMENT
    8
    THE PROCESS OF RISK MANAGEMENT
    9
    RISK MANAGEMENT FOR SPECIFIC
    BUSINESS FUNCTIONS
    31
    INFORMATION RISK
    33
    RISK ASSESSMENT IN DUE DILIGENCE
    34
    COMPREHENSIVE RISK MANAGEMENT
    34
    THE ROLE OF SENIOR FINANCIAL
    MANAGERS 35
    CONCLUSION
    36
    BIBLIOGRAPHY
    37
    APPENDIX:
    REGULATORY
    REQUIREMENTS ON ENHANCED
    INTERNAL CONTROL
    39
    Page
    MANAGEMENT
    5

    6
    STRATEGY
    MEASUREMENT
    Today, organizations must learn to manage
    these increased risks. In the publication entitled
    Enterprise Risk Management — Integrated
    Framework
    , the Committee of Sponsoring
    Organizations of the Treadway Commission
    (COSO) described the underlying principles of
    risk management and its components. However,
    boards of directors and their audit committees,
    senior corporate managers, senior financial
    managers,auditors,and external stakeholders
    often need more detailed guidance with respect
    to the measurement and management of
    organizational risk.
    In addition to the COSO framework and the
    newly effected regulatory requirements for
    internal control (see Appendix), this guideline
    provides a
    Risk Management Payoff Model
    that
    includes a selection of performance measures
    to properly identify, measure, manage, and
    report risks.The model demonstrates that
    improved risk measurement and management
    produces organization-wide benefits, such as
    enhanced working conditions, allocation of
    resources to the risks that really matter, and
    sustained or improved corporate reputation.
    These consequences help the organization
    prevent loss, achieve performance and
    profitability targets, and increase shareholder
    value. Measuring a broader set of risks more
    effectively is necessary not only to meet the
    new regulatory requirements but also, primarily,
    to improve managerial performance and
    stakeholder confidence.Risk management
    involves the identification,evaluation,and
    mitigation of business risks in order to
    maximize opportunities and turn risks into
    sources of competitive advantage.
    The
    objectives
    of this guideline are as follows:
    ● To provide a comprehensive overview of
    risk management and highlight the role of
    risk identification and measurement within
    the risk management process;
    ● To create a broader framework for risk
    identification;
    ● To describe key elements of a measurement
    model (the Risk Management Payoff Model)
    for success in dealing with risks strategically
    and operationally.The model includes the
    critical
    inputs
    and
    processes
    that lead to risk-
    related
    outputs
    and ultimately to overall
    organizational success (
    outcomes
    ). As such,
    the model helps managers identify and
    evaluate risks, determine the potential
    profits of risk management initiatives, and
    compare different risk responses;
    ● To outline specific drivers related to these
    inputs, processes, outputs, and outcomes. By
    identifying the causal relationships among
    the drivers, managers can better understand
    the way in which risk strategies, structures,
    and systems affect organizational
    performance;
    ● To provide specific performance metrics, so
    that managers can better prepare for,
    measure, and manage risks; and
    ● To demonstrate the calculation of return on
    investment (ROI) for risk management
    initiatives.
    The
    target audience
    of this guideline includes
    boards of directors, members of audit
    committees, chief executive officers (CEOs) and
    chief financial officers (CFOs) with increased
    responsibilities,senior management teams,and
    accounting, internal audit, and finance
    professionals that face the challenges of risk
    assessment,analysis,and control.The guideline
    is also aimed at external auditors who must
    attest to, and report on, internal control over
    financial reporting.
    DRIVERS OF INCREASED RISK
    AWARENESS
    Regulatory Compliance
    In recent years, facing more difficult business
    conditions and the growing expectations of
    shareholders, some corporate executives —
    fueled partly by excessive corporate and
    personal greed — deliberately bent the rules or
    blatantly reported false financial results for their
    organizations, causing a series of accounting
    scandals and corporate failures.These high-
    profile collapses demonstrated the potential
    consequences of failing to adopt even the basic
    principles of risk management as a key
    component of good corporate governance. In
    response, the pressure for improved risk
    assessment has increased throughout the
    world, taking the form of guidance documents
    (e.g., the Ontario Securities Commission’s
    proposed policy on effective corporate
    governance in Canada) and compulsory
    regulations (e.g.,SOX).
    Containing some of the most major and radical
    alterations in securities regulations in the
    United States since the 1930s, SOX has caused
    MANAGEMENT

    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    7
    important changes in public accounting, corporate
    governance, and internal audit. For many decades,
    the protection of the investing public focused
    primarily on financial reporting. It was believed
    that investors provided with transparent financial
    results, and the information necessary to
    understand them, could make fully informed
    decisions. In 2002, SOX stated that the reporting
    of financial results was insufficient and required
    organizations to do more — to analyze and
    evaluate the quality of the processes and controls
    used to report these results. In order to
    harmonize the Canadian regulatory reporting and
    certification rules with SOX, Canadian Securities
    Administrators issued a set of proposals entitled
    Reporting on Internal Control over Financial Reporting
    .
    Beyond the Sarbanes-Oxley Act
    SOX specifically addresses the evaluation of risks
    related to financial reporting. However,
    organizations should look beyond the recent
    legislation, rather than merely comply with it, and
    learn to evaluate and monitor other types of risks
    and their underlying causes. Herein lies the
    opportunity to develop a business discipline:
    create formal systems of internal control, detail
    how these systems will identify, evaluate
    (measure), and respond to significant risks to the
    business, monitor these risks, and communicate
    the results to the appropriate parties.The
    mismanagement of risk and uncertainty may carry
    an enormous price. Beyond the traditional
    financial risk factors, internal and external
    stakeholders today expect reports on a wider
    range of issues that can affect future performance,
    reputation, and financial health.
    In general terms, a risk can be described as any
    event or action that will affect adversely the ability
    of an organization to achieve its business
    objectives and execute its strategies successfully.
    More specifically, risk is the probability that
    exposure to a hazard will lead to a negative
    consequence. As such, risks do not arise from
    internal environments alone. External factors such
    as technological progress, customer demands, and
    global forces continuously change business models
    and increase competitive pressures. Government
    regulations, deregulation of key industries, and
    freer trade and investment worldwide create
    additional uncertainty. Risk is an inescapable
    element of competition and is integral to the
    economics of trading, investing, and competing in a
    market economy.
    Thus, organizations need better ways to integrate
    the consideration of many types of risk —
    political,
    social,
    environmental,
    technological,
    economic, competitive, and financial — with the
    making of management decisions. For example,
    political instability in a host country, potential
    product liability, process emissions that are
    environmentally undesirable, and human resource
    policies that have social consequences can be
    important factors in managerial decisions.
    Organizations must be able to evaluate such risks
    and incorporate the results into decisions
    regarding investments and operations, as well as
    into the systems used to monitor the issues and
    the effectiveness of the actions taken.This
    guideline seeks to address these concerns.
    Risk Management Pays Off
    Many organizations view the effort to comply
    with SOX as a high-cost, largely administrative
    exercise. Indeed, significant resources are needed
    both to comply with regulatory requirements
    and to manage other risks. Estimates of the
    costs to comply with the new accounting and
    auditing regulations range from $400,000 to
    $750,000 for smaller companies alone.
    Moreover, these estimates do not include the
    time executives and other employees must
    spend dealing with compliance issues. A recent
    survey conducted by Financial Executives
    International reveals that a company with more
    than $5 billion in revenue could expect Section
    404 costs of about 0.06 percent of sales, whereas
    a company garnering less than $100 million could
    see costs of about 2.55 percent of sales (Katz,
    2005). As a result, the number of companies
    announcing plans to go private has risen steadily
    since the passage of the Act.
    Though there are legitimate concerns about the
    costs of implementing SOX, organizations should
    not see the activity as merely an enormous
    tactical undertaking, producing little more than a
    list of tasks and corresponding costs. On the
    contrary, the potential benefits of the new,
    rigorous examination of risks and controls should
    be acknowledged. For visionary organizations, the
    requirements of SOX present a unique
    opportunity to pursue and implement the best
    risk management practices.Through the careful
    and thorough examination process, organizations
    can become aware of risks that are larger, more
    varied, and more global than anticipated, assess
    these risks, prepare appropriate responses, and
    measure the efficiency and effectiveness of the

    8
    STRATEGY
    MEASUREMENT
    risk management initiative.This can result in
    improved internal control processes, better
    decision making, increased reliability of
    information for external users, and enhanced
    investor
    confidence.
    INCREASED RESPONSIBILITIES
    IN RISK MANAGEMENT
    Because of the new and greater risks in the
    business environment and the strengthened
    regulatory requirements for internal controls,
    the responsibilities of corporate boards, audit
    committees, and the internal audit function have
    increased with respect to risk management.
    The board of directors has a central role in
    governance, its primary duty being to promote
    the long-term interests of the organization and
    of its shareholders. Epstein and Roy (2002)
    highlight three critical roles of boards of
    directors: overseeing strategic direction and risk
    management,
    ensuring
    accountability,
    and
    evaluating performance and senior-level staffing.
    Related to the first is the board’s responsibility
    to review carefully the organizational processes
    of risk identification, monitoring, and
    management. Specific reviews of financial
    objectives, plans, major expenditures, and other
    significant material transactions should also be
    included in the board’s responsibilities with
    respect to risk. Although the ultimate risk
    manager of any organization is the CEO, the
    board of directors must provide advice and
    ensure that relevant direction is being given on
    matters related to risk and internal control.
    The audit committee is responsible for
    examining the performance of the internal
    control function and the exposure of the
    organization to a variety of risks.This role has
    become much more critical. Although there is
    no regulatory mandate for the implementation
    of enterprise risk management, the New York
    Stock Exchange’s Corporate Governance
    Rules require that a listed company’s audit
    committee have a written charter of duties and
    responsibilities, and that these include discussing
    policies with respect to risk assessment and
    risk management.The Rules’ commentary notes
    that, although other mechanisms to assess and
    manage risk need not be replaced by the audit
    committee, the audit committee must discuss
    the company’s major financial risk exposures
    and the management processes in place to
    monitor and control such exposures.Thus, in
    order to help focus energies in this area, many
    organizations are developing and implementing
    Risk Management Charters that establish the
    authority, roles, and responsibilities of their
    audit committees as well as define the scope of
    the activities of their internal auditors.
    Internal auditors now have greater responsibility
    vis-à-vis the audit committee, the external
    auditors, and corporate governance in general.
    Although the responsibility for SOX compliance
    rests with management, the internal audit
    function typically has responsibility for the
    Section 404 review of internal controls over
    financial reporting and presents documented
    results to the audit committee and to the
    external auditors. The external auditors then
    attest to the adequacy of that review, giving their
    opinion regarding management’s assessment of
    internal control over financial reporting, and
    providing their own assessment of internal
    control over financial reporting. In addition,
    internal auditors provide independent assurance
    regarding the risk management process by
    forming an opinion about the extent to which
    sound controls have been implemented and
    maintained to mitigate the significant risks that
    management has agreed to embrace. Also,
    internal audit often has primary responsibility
    for monitoring the ethics and whistle-blower
    functions to ensure that these comply with
    company and regulatory requirements.
    APPROACHES TO RISK
    MANAGEMENT
    Traditional
    Approach
    Historically, a silo approach has been favored,
    with different types of risk (e.g., insurance,
    technology,financial,and environmental risk)
    being managed independently in separate
    departments. Usually, there has been little or no
    coordination of risk management and, often,
    organizations have been slow to identify new
    and emerging business risks. Nevertheless, well-
    managed organizations have always managed
    risk
    successfully.
    Risk can be viewed as uncertainty, hazard, or
    opportunity.Traditional risk management has
    concentrated on the two former views,
    attempting to reduce the variance between
    anticipated outcomes and actual results. In
    contrast, the goal of an organization-wide risk
    management system is to create, protect, and
    enhance shareholder value by managing the
    uncertainties that could affect the achievement
    MANAGEMENT

    of the organization’s objectives either positively
    (opportunity) or negatively (hazard).
    Current Frameworks
    Each of the major publications that address the
    growing importance of comprehensive and
    integrated risk management suggests ways to
    assess and manage risks within a generalized
    framework (e.g., DeLoach, 2000; Shaw, 2003; and
    McCarthy and Flynn, 2004).The required tasks,
    which vary in number, generally include
    establishing a context, identifying risks, analyzing
    and assessing risks, designing strategies for
    managing risks, implementing and integrating risk
    management,
    measuring,
    monitoring,
    and
    reporting (e.g., AICPA and Canadian Institute of
    Chartered
    Accountants,
    2000).Typically,
    these
    publications do not provide clear guidance as to
    either the actions that managers should take to
    identify risks or the specific performance
    measures that should be implemented for
    effective risk management.
    Among the most prominent works are those
    published by COSO. In 1992,
    Internal Control —
    Integrated Framework
    departed from the
    traditional internal accounting control model by
    presenting a broad framework of five interrelated
    components:control environment,risk
    assessment,control activities,information and
    communication, and monitoring. In 2004,
    Enterprise Risk Management — Integrated
    Framework
    provided a risk management
    framework that included key principles and
    concepts, used a common language, and consisted
    of eight interrelated components: internal
    environment,objective setting,event identification,
    risk assessment, risk response, control activities,
    information and communication, and monitoring.
    Expanding on the internal control framework, this
    document presented a more extensive treatment
    of the broader subject of enterprise risk
    management, including aligning risk appetite and
    strategy, enhancing risk response decisions,
    reducing operational surprises and losses,
    identifying and managing multiple and cross-
    enterprise risks, seizing opportunities, and
    improving deployment of capital (COSO, 2004a).
    Both COSO documents offered clear direction
    and relevant guidance with respect to the
    identification and management of risks.
    Nevertheless, empirical evidence reveals that
    companies have difficulties designing and
    implementing new internal control systems to
    comply with the regulatory requirements. A
    recent survey of the US Fortune 500 indicated
    that less than 30 percent of those organizations
    had implemented any form of enterprise system
    to support risk management (Teixeira, 2003).
    There is an apparent knowledge gap with respect
    to risk management and in particular, a lack of
    performance metrics for risk management
    initiatives. Given the increasing demand for
    significantly improved risk management, specific
    risk measurement tools are necessary.
    THE PROCESS OF RISK
    MANAGEMENT
    With the speed of change increasing for all
    organizations, senior managers must deal
    constantly with a myriad of complex risks that
    have substantial consequences for their
    organizations.The goal of risk management is not
    to eliminate risks, which would also eliminate
    potential rewards, but to find the right responses
    to them. Risk management seeks to maximize
    business opportunities and turn risks into
    competitive advantage. Effective risk management
    (see Exhibit 1) involves identifying risks, evaluating
    potential effects, identifying and analyzing possible
    solutions, adopting the most appropriate
    solutions, measuring the results (payoffs) of
    managing risks, communicating results, and
    monitoring risk evolution.
    Step 1: Event Identification
    In today’s rapidly changing, complex, and globally
    oriented businesses, risk is not always apparent.
    Although, ultimately, the CEO is the organization’s
    chief risk management officer, decision makers at
    all levels should consider risk identification a
    critical part of their jobs. Moreover, both
    managers and employees must learn to spot the
    warning signs of risks. For example, in the area of
    human resources, signs of risk could include a
    change in the demeanor of an employee, a decline
    in productivity, or a sudden increase in
    absenteeism.A list of potential risks to the
    organization could increase the attention paid by
    managers and employees to the events that might
    indicate risk occurrence.
    There are several ways to classify risks. Building on
    the COSO framework, Exhibit 2 provides a risk
    classification scheme that comprises four broad
    categories of risk — strategic, operational,
    reporting, and compliance. Strategic risks relate to
    an organization’s choice of strategies to achieve its
    objectives. Such risks endanger the organization’s
    achievement of high-level goals that support its
    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    9

    10
    mission, and call into question management’s
    view of the environment. Operational risks
    relate to the possible loss of organizational
    assets and include threats from ineffective or
    inefficient business processes for acquiring,
    financing,transforming,and marketing goods
    and services as well as threats to the reputation
    of the organization. Reporting risks relate to
    the reliability and accuracy of information
    systems and to the reliability, timeliness, and
    completeness of information for internal and
    external decision making.Finally,compliance
    risks relate to the communication of laws,
    regulations, internal codes of behavior, and
    contract requirements and include the adequacy
    of information about the failure of management,
    employees, or trading partners to comply with
    applicable laws,regulations,contracts,and
    expected behaviors (Kinney,2000).
    Although controlling compliance risk is
    recognized as important, regrettably little
    attention has been focused on improving
    methods to reduce strategic, operational, and
    reporting risks. It is true that compliance
    failures have accounted for the most
    spectacular organizational losses in the last
    decade, generating legal costs, tarnishing
    corporate image, potentially affecting future
    profitability, and sometimes leading to
    corporate failure. However, all four categories
    Event Identification
    Risk Assessment
    Accept Risk
    Control Activities
    Is Risk/Reward
    Acceptable?
    Avoid Risk
    Can Risk Be Mitigated?
    Information &
    Communication
    Monitoring
    Quantify
    Magnitude
    Assess
    Probability
    Qu antify
    Impact
    Cost/Benefit
    Analysis
    Priority/
    Rank
    Yes
    No
    No
    Yes
    Reduce Risk
    Transfer Risk
    Share Risk
    R
    i
    s
    k
    R
    e
    s
    p
    o
    n
    s
    e
    1
    2
    3
    4
    5
    6
    Exhibit 1: Risk Management Process
    Adapted from Kinney, 2000 and COSO, 2004.
    STRATEGY
    MEASUREMENT
    MANAGEMENT
    3
    1
    2
    4
    6
    5

    are major sources of organizational risk and
    deserve an equally high level of managerial
    attention and relevant response.
    The risk classification scheme attempts to define a
    risk universe and provide a sample listing of
    organizational risks.To this end, the selected risks
    included in Exhibit 2, and explained in Exhibits 3, 4,
    5, and 6, are representative of the most critical
    risks faced by organizations today. However, each
    organization should establish a working list of the
    risks that are most relevant to its own businesses
    and business environments.
    In each organization, a combination of techniques
    and supporting tools may be used to identify risks.
    Approaches include:internal analysis;process
    flow analysis; creation of event inventories;
    identification of escalation or threshold triggers;
    discovery of leading event indicators; loss event
    data methodologies;facilitated,interactive group
    workshops and interviews; scenario analysis; and
    brainstorming sessions.
    At Microsoft, the world’s leader in the
    development of software for personal computers,
    the risk management group spends a great deal of
    time face-to-face with the business units (Barton
    et al., 2002).At Telus, one of Canada’s leading
    providers of data, Internet Protocol (IP), voice, and
    wireless communications services,risk
    identification involves conducting surveys of
    various stakeholder groups and asking them to
    identify possible risks — low, medium, and high —
    in their areas of responsibility (Telus, 2004).
    In the brainstorming approach, participants should
    be highly visible, represent a broad range of
    business operations, and have a global perspective
    of the organization. Some organizations have
    established a brainstorming team that comprises
    most of the executive group, including the CEO
    and the CFO, as well as employees selected for
    their understanding of different operational areas.
    Event identification should ensure that all relevant
    risks are identified and their sources determined.
    In this regard, it is important to look beyond silos
    of risk. For example, when considering the risks of
    an earthquake, Microsoft managers thought about
    potential damage to equipment and buildings and,
    therefore, looked at property insurance. However,
    management must also take a broader view and
    consider the elements that are most important to
    the organization. In the case of an earthquake, the
    real risk is not that buildings can be damaged but
    that this can cause an interruption in the
    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    11
    Exhibit 2: Risk Classification Scheme
    Operational Risks
    Strategic Risks
    Reporting Risks
    Economic risks
    Industry risks
    Strategic transaction risks
    Social risks
    Technological risks
    Political risks
    Organizational risks
    Environmental risks
    Financial risks
    Business continuity risks
    Innovation risks
    Commercial risks
    Project risks
    Human resource risks
    Health and safety risks
    Property risks
    Reputational risks
    Information risks
    Reporting risks
    Compliance Risks
    Legal and regulatory
    risks
    Control risks
    Professional risks
    Risks

    12
    Risk
    Type
    Definition
    Example
    Ecomonic Risks
    Industry Risks
    Strategic
    Transaction Risks
    Social Risks
    Technological
    Risks
    Political Risks
    Organizational
    Risks
    Risks related to macroeconomic
    policies and economic cycles
    .
    Risks related to competitive
    positioning,industry profit
    margins, market structure, and
    competition laws
    Risks related to activities
    undertaken to initiate significant
    change in strategic direction
    Risks related to changing
    demographics and social mores
    Risks related to technological
    progress and technology-driven
    disruptive forces
    Risks related to changes in
    government,public policy,and
    federal oversight, and global risks
    related to political instability
    Risks related to control systems,
    business policies, and business
    culture
    Government’s monetary and fiscal
    policy
    Changes in supply and demand,
    industry concentration,or
    competitive structure;introduction of
    new products and services
    Asset reallocation via mergers and
    acquisitions,
    spin-offs,
    alliances,
    and
    joint ventures
    Child labor; changes in family
    structures and work/life priorities
    (human resource issues that could
    alter demand for products/services
    or change buying venues)
    Engineering
    success/failure;
    technological obsolescence of
    product or product assembly
    (issues that could give a competitor
    an advantage)
    Management of government
    relations;
    terrorist
    activities
    Alignment between performance
    measurement and reward systems
    Exhibit 3: Strategic Risks
    production/business cycle so that the
    organization cannot do business.The risk
    identification effort should produce a portfolio
    of risks, classified as strategic, operational,
    reporting, and compliance, for the organization
    as a whole and for every business unit.
    Step 2: Risk Assessment
    All risks identified as potentially important
    should be assessed as to their magnitude — the
    monetary loss or severity of the negative effect
    if the event should occur. In this regard, it is
    important to concentrate on the impact of an
    incident and, especially, on its duration. In
    addition, the probability of the occurrence of an
    adverse event of a given magnitude should be
    determined.The organization can gain a much
    better understanding of the potential effects of
    a given risk by calculating both the probability of
    its occurrence and the expected losses.
    Traditional,quantitative techniques for risk
    measurement and evaluation include:
    benchmarking; probabilistic models such as
    value at risk (VAR), cash flow at risk, earnings at
    risk, development of credit, and operational loss
    distributions; and non-probabilistic models such
    as sensitivity models, stress tests, and scenario
    analyses. In order to quantify the real costs of a
    risk, its correlation with other risks must be
    considered as well. Using scenarios may be
    helpful, particularly in studying the experiences
    of other organizations.
    In addition to the costs that may be incurred if a
    risk materializes, the benefits that may be
    provided by an appropriate response to the risk
    should be assessed.The quantification of both
    costs and benefits then makes it possible to
    determine the payoff of a risk management
    initiative.Traditional risk assessment techniques
    often focus on those elements that can be
    STRATEGY
    MEASUREMENT
    MANAGEMENT

    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    13
    Exhibit 4: Operational Risks
    Risk
    Type
    Definition
    Example
    Environmental
    Risks
    Financial Risks
    Business
    Continuity
    Risks
    Innovation Risks
    Commercial
    Risks
    Project Risks
    Human Resource
    Risks
    Health and
    Safety Risks
    Property Risks
    Reputational
    Risks
    Risks related to the natural
    environment that could result in
    damage to buildings, restricted
    access to raw materials, or loss of
    human capital
    Risks related to credit, interest
    rates, the stock market, currency,
    and collateral
    Risks related to conditions that
    could result in work stoppage or
    adversely affect production,
    delivery,marketing,supplier and
    customer management,
    outsourcing,or compliance
    with industry and other
    standards and codes
    Risks related to the
    transformation of some aspect of
    the business in an effort to
    improve operating performance
    Risks related to the expected
    performance of products or
    services
    Risks related to the completion of
    a project
    Risks related to the adequacy and
    execution of human resource
    standards,policies,and practices
    Risks related to employee health
    and safety in the workplace
    Risks related to the security of
    both tangible and intangible assets
    Risks related to the perception of
    the organization by its
    stakeholders, the media, and the
    general public that could impact
    liquidity, capital, or credit rating
    Weather conditions, such as
    earthquake, fire, or flood;
    environmental pollution
    Foreign exchange rates; strategic
    equity; asset liquidity; employee stock
    option program; commodity risks
    Reliability within the supply chain;
    supplier integrity; quality of goods;
    price of external supply
    Underperformance in new product
    development and in Research &
    Development (R&D) investment
    Quality of engineering, marketing,
    communication,and sales;product
    liability in the event of failure
    Technical
    difficulties;
    commercial
    obstacles
    Ethical/unethical conduct by
    management and employees;
    availability of assistance to employees
    for career planning and personal
    development; issues that could result
    in work stoppage, loss of personnel,
    or monetary or reputational damage
    Unsafe equipment or environment;
    workplace stress; potential for injury
    from repetitive strain or falls from
    heights
    Inventory protection against spoilage
    or theft; intellectual property rights;
    potential for enforcement action
    Publicity regarding production
    methods, business practices, or
    internal controls

    14
    quantified easily and fail to address all critical
    drivers of successful risk management.What is
    needed is a framework of key factors
    (antecedents and consequences) that can
    enable decision makers to assess the impacts of
    risks in terms not only of the costs but also, and
    more importantly, of the benefits that successful
    risk management initiatives may provide.
    Following is the description of a specific
    framework that can be used as a tool for risk
    assessment and risk management. Because of
    the fundamental nature of risk and its
    consequences, the Risk Management Payoff
    Model is equally applicable to for-profit and not-
    for-profit organizations.
    The Risk Management Payoff Model
    Business measurement systems are designed to
    measure and display key success factors for
    achieving specific objectives.The Risk
    Management Payoff Model (Exhibit 7) describes
    the key factors for corporate success in risk
    management.These include the critical
    inputs
    and
    processes
    that are needed for success in risk
    management
    outputs
    (e.g., increased regulatory
    compliance), which then reduce the cost of risk
    and increase revenues. Finally, the payoff of risk
    management is determined by its contribution
    to overall organizational success (
    outcomes
    ) in
    terms of shareholder value — the ultimate
    measure of success.This approach helps
    Exhibit 5: Reporting Risks
    Exhibit 6: Compliance Risks
    Risk
    Type
    Definition
    Example
    Information Risks
    Reporting Risks
    Risks related to the quality and
    accessibility of information
    Risks related to the process of
    capturing,analyzing,and submitting
    data in a meaningful format to
    managers and external
    stakeholders for decision-making
    purposes
    Data
    accuracy,
    relevance,
    reliability,
    and completeness; security of
    information;integration of
    information systems
    Reliability and completeness of
    financial information; efficiency of
    the process for internal decision
    making and for external reporting
    Risk
    Type
    Definition
    Example
    Legal and
    Regulatory Risks
    Control Risks
    Professional Risks
    Risks related to meeting legal and
    regulatory requirements with
    respect to corporate governance,
    labor relations, industry standards,
    the environment, etc.
    Risks related to the internal
    control systems and security
    policies that could result in system
    downtime, backlogs, fraud, and the
    inability to continue business
    operations
    Risks related to organizational
    liability and the personal liability of
    directors and managers
    Employee compliance with the
    organization’s code of conduct and
    Non-Governmental
    Organization
    standards; human rights violations
    (e.g., child labor)
    Data integrity; data and system
    availability;potential for malpractice
    by employees or outsiders (e.g., theft,
    deception,forgery,false accounting);
    potential for operational errors (e.g.,
    clerical,record-keeping,and those
    resulting from faulty IT systems)
    Misrepresentation;
    defamation;
    corporate
    insolvency
    STRATEGY
    MEASUREMENT
    MANAGEMENT

    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    15
    managers understand the critical drivers of
    reduced long-term risk and related costs as well as
    increased long-term shareholder value. It also
    helps managers determine the value of the risk
    management efforts and improved internal control.
    Inputs
    are the
    external environment
    in which the
    organization operates and the
    risks
    it faces.The
    organization’s ability to develop an appropriate
    internal environment
    — risk appetite and culture
    — to respond to external forces, to anticipate
    risks and allocate resources in its
    corporate
    strategy
    , and to develop specific
    risk management
    strategies
    to deal with these risks effectively is
    critical and is reflected in the strategic fit.The
    better the alignment between the organization’s
    internal strengths and its external opportunities
    and threats the more effective is the risk
    management process. Existing organizational and
    governance
    structure
    and
    systems
    , such as incentive
    pressures, may either support the risk
    management strategy or inhibit the risk
    management efforts.Thus, if an organization wants
    to secure the necessary conditions for effective
    risk management processes, it must continuously
    examine its external environment and establish a
    risk culture and appropriate strategies, structures,
    and systems in relation to the defined
    environment. Inputs and processes are the most
    critical success factors.
    Processes
    involve
    risk management leadership, risk
    management structure
    , and
    risk management
    systems
    . Committed leadership at the corporate
    level and focused efforts of the risk management
    leaders will affect the dedication of employees
    involved in the event identification, risk
    assessment, response, and control activities.
    Together with a carefully designed risk
    management structure, measurement and reward
    systems, and IT support systems, this will ensure
    the achievement of various risk management
    outputs
    .These include
    intermediate outputs
    , such
    as improved regulatory compliance, business
    process continuity, or enhanced internal and
    external reporting, and
    final outputs
    , such as
    reduced overall costs and increased revenues.
    Ultimately, effective risk management should lead
    to improved overall success and increased
    shareholder value (
    outcomes
    ).
    In Exhibit 8, inputs, processes, outputs
    (intermediate and final), and outcomes of risk
    management activities are further articulated as
    risk management objectives.This is consistent
    with the COSO framework.The list of risk
    Exhibit 7: Risk Management Payoff Model — Antecedents and Consequences
    of Successful Risk Management
    Organizational
    Success
    and
    Shareholder
    Value
    Feedback Loop
    INPUTS
    PROCESSES
    OUTPUTS
    Intermediate
    Final
    Compliance with
    Regulations
    Business Process
    Continuity
    Enhanced Working
    Environment
    Improved Resource
    Allocation
    Enhanced Internal
    Reporting
    Improved External
    Reporting
    Improved
    Organizational
    Reputation
    Reduced Earnings
    Volatility
    Risk
    Management
    Leadership
    Risk
    Management
    Structure
    Risk
    Management
    Systems:
    Measurement &
    Rewards
    Event Identification,
    Risk Assessment,
    Risk Response,
    Control Activities,
    Information and
    Communication,
    Monitoring
    Reduced Costs:
    Reduction of Short -
    term Costs of Risk,
    Reduction of
    Long-term Costs of
    Risk, and
    Reduction of
    Other Costs
    Increased
    Revenues
    Increased
    Program
    Effectiveness
    Strategic,
    Operational,
    Reporting, and
    Compliance
    Risks
    External
    Environment
    Internal
    Environment
    Strategy,
    Structure,
    Systems, and
    Resources
    Risk
    Management
    Strategy
    OUTCOMES
    Organizational
    Success
    and
    Shareholder
    Value

    16
    management objectives is not comprehensive;
    rather, it is an example of the type of objectives
    that might be selected. Ideally, all objectives
    should be quantified so that, later, the extent to
    which the objectives have or have not been
    achieved can be determined numerically.
    After specific risk management objectives
    have been articulated, the drivers of risk
    management success (see Exhibit 9) must
    be determined. In order to identify the
    specific causes of risks, determine the best
    way to control them, and analyze the way
    in which specific risk responses affect
    overall organizational costs to produce
    financial benefits, managers need a clear
    understanding of the most influential drivers
    of risk management success and their
    causal relationships.
    For example, consider that an organization’s
    risk objective is to prevent unauthorized
    transactions by employees. On one hand, the
    organization may invest resources in belief
    systems (communicating the core values of the
    company and expected employee behavior) and
    boundary systems (specifying actions and
    behaviors that are unacceptable) to prevent the
    risk from occurring (see Simons, 1999, for more
    on belief and boundary systems). On the other
    hand, the organization may increase risk
    awareness through training and encourage
    whistle-blowing
    through
    appropriate
    compensation and disciplinary systems, which
    may result in adequate risk identification,
    assessment, and response. In both cases, there
    should be a positive impact on business process
    continuity, resulting in sustained or increased
    revenues and decreased costs of risks, or both.
    Alternatively, if corporate and risk management
    strategies are aligned, the organization may
    allocate more resources to risk management
    initiatives and thereby further the
    implementation of appropriate boundary and
    diagnostic control systems, which may lead to
    the prevention of risks. Higher risk management
    spending may also increase employee awareness
    of risk and dedication to event identification,
    which may lead to timely risk responses. Both
    the prevention of risks and timely risk responses
    should enable the organization to sustain
    business process continuity and thus lead to
    higher customer satisfaction, sales, and revenues.
    Exhibit 9 provides a comprehensive example of
    risk management drivers and the causal
    relationships among them. Since the causalities
    are based on assumptions regarding leading and
    lagging elements, these hypothesized
    relationships need to be tested and revised
    continuously. In practice, there are many more
    drivers of risk management success than those
    presented in Exhibit 9. Nevertheless, when
    examining causal relationships, organizations are
    likely to articulate fewer drivers so that the
    illustration is less complex and more easily
    understandable, thereby allowing managers to
    focus on the drivers and relationships that are
    the most critical.
    Inputs
    The Risk Management Payoff Model is an
    effective risk assessment framework. In order to
    use the model to manage risks properly, improve
    internal control, and create added value, senior
    managers must first evaluate the inputs — the
    external elements that will affect the design of
    the risk management process — with respect to
    the objectives and drivers of success.
    All businesses are exposed to potential hazards.
    For each organization, the extent of exposure
    will vary according to the firm’s unique
    characteristics. Managers need to construct a
    comprehensive list of
    risks
    faced by the
    organization in order to ensure that all threats
    to achieving corporate objectives are assessed
    adequately, contained to a reasonable degree,
    and managed economically.Strategic,
    operational, reporting, and compliance risks, as
    presented in the risk classification scheme, are
    thus critical inputs in the Risk Management
    Payoff Model.
    The
    external environment
    is defined by the
    industry in which the organization operates; the
    country-specific political,economic,legal,and
    social forces; and the location of production and
    other facilities.These elements affect the risks
    that the organization faces and should be
    considered in the design of a risk management
    system.A Booz Allen Hamilton analysis of 1,200
    firms found that the poorest performers
    destroyed almost seven times more value
    through strategic missteps related to the
    business environment (e.g., ineffective reaction
    to competitive pressures, poor forecasting of
    customer demand, etc.) than through
    compliance failures.These findings suggest that,
    to manage growth, organizations must design
    robust and integrated strategic planning
    processes built on a broad understanding of all
    risks to the business (Kocourek et al., 2004).
    STRATEGY
    MEASUREMENT
    MANAGEMENT

    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    17
    Exhibit
    8: Risk Management Payoff Model—Setting Risk Management Objectives
    Outcomes
    Outputs:
    o
    Final
    o
    Intermediate
    Processes
    Inputs
    Increased Long-term Organizational Success and Shareholder Value
    Increased Short-term Organizational Success and Shareholder Value
    Reduced Costs:
    Reduction in short-term costs of risk by $1 million
    Increased Revenues:
    Increase in new-customer sales by $2 million
    Increased Program Effectiveness:
    10 percent increase in customer satisfaction
    Regulatory Compliance:
    Full compliance with strategically relevant regulations
    Business Process Continuity:
    Zero unplanned process interruptions
    Enhanced Working Environment:
    10 percent increase in labor productivity
    Improved Resource Allocation:
    Focus on compliance risks
    Enhanced Internal Reporting:
    Reliable, accurate, and on-time information
    Improved External Reporting:
    Reliable financial and other reports for external use
    Organizational Reputation:
    Sustained or enhanced corporate reputation
    Reduced Earnings Volatility:
    Reduction in earnings distribution
    Reduced Cost of Capital:
    Reduction in cost of capital by 0.2 percentage points
    Risk Management Leadership:
    Full commitment and focus
    Risk Management Structure:
    Full integration into business unit structure
    Risk Management Systems:
    1. Measurement & Rewards: Optimal balance between belief systems,
    boundary systems, diagnostic control systems, interactive control systems,
    and traditional control systems
    2. Risk Management Process:
    Event Identification: Enhanced risk identification techniques
    Risk Assessment: Increased quantification of risks
    Risk Response:Adequate risk response strategies
    Control Activities: Ongoing control of risk responses
    Information & Communication: High risk awareness throughout the
    organization
    Monitoring:Ongoing monitoring activities
    Risks:
    Development of a list of potential risks
    External Environment:
    Ongoing monitoring of external environment
    Internal Environment:
    Appropriate risk management philosophy,integrity,and
    ethical values
    Corporate Strategy:
    Strategic fit between the internal potential and external
    opportunities
    Organizational Structure:
    Appropriate organizational architecture and
    governance
    structure
    Organizational Systems:
    Suitable training and incentive systems, IT support
    systems
    Organizational Resources:
    Adequate capital and people
    Risk Management Strategy:
    Risk objectives coherent and aligned with the
    corporate strategy

    18
    The
    internal environment
    is the tone of the
    organization as revealed in its risk management
    philosophy, integrity, and ethical values. It is
    essential that all employees know how their
    actions affect one another and contribute to
    achievement of the organization’s risk objectives.
    In addition, developing and maintaining the right
    corporate culture is extremely important, since
    employees tend to copy the behavior of their
    superiors. For example, if employees see
    dishonesty and corruption at high levels, they
    often believe that this is acceptable. Some
    companies with demonstrable risk management
    processes collapsed (e.g., Enron) partly because
    they failed to take issues of culture and integrity
    into account, and procedural controls masked
    the existence of fraud.The way the business and
    its controls interact with people and, in
    particular, the way the organization
    communicates its attitude toward transgressions
    are elements of the internal environment that
    should not be ignored.
    Corporate strategy
    includes both the
    organization’s goals (corporate strategic
    objectives) in terms of its markets, products,
    and technologies and the plan for achieving
    these objectives. An organization expanding its
    operations to new markets, developing new
    products, targeting new market segments, or
    adopting new production technology may face
    new, more numerous, and more complex risks,
    which will affect the design of the risk
    management process.
    Another important determinant of the design
    of the risk management process is the
    organizational structure
    .This includes the number
    and geographical location of business units and
    Exhibit 9: Risk Management Payoff Model — Drivers of Risk Management
    Success and Causal Relationships
    Increased Revenues
    and Program
    Effectiveness
    Decreased Overall
    Costs
    Risk awareness
    Adequate risk
    responses
    strategies
    Improved
    reputation
    Risk manag ement
    spending
    Increased
    productivity
    Enhanced working
    environment
    Greater
    sales
    Risk training and literacy
    Aligned corporate and risk
    management strategies
    Reduced earnings volatility
    Event identification
    and assessment
    Needed risk mana gement
    knowledge and skills
    Increased Organizational Success and
    Shareholder Value
    Compliance with laws &
    regulation
    Business process
    continuity
    Enhanced internal and
    financial reporting
    Risk management philosophy and
    ethical values
    Appropriate compensation a nd
    disciplinary systems
    Prevention of risks
    Improved resource
    allocation
    Reduction of
    short-term cost of risk
    Decreased cost of capital
    Diagnostic control systems
    Boundary systems
    Ongoing monitoring of
    risk drivers
    Outcomes
    Outputs:
    Final and
    Intermediate
    Processes
    Inputs
    STRATEGY
    MEASUREMENT
    MANAGEMENT

    departments, lines of authority and responsibility,
    and lines of reporting. An organization with a
    large number of strategic business units having a
    high degree of autonomy and spread across a
    wide geographical area will have a different risk
    management process than an organization with a
    simple,centralized organizational structure.It
    should be noted that organizational structures
    differ greatly in the handling of risk information
    and in the associated control mechanisms.
    Organizational systems
    also shape the risk
    management process and include such elements
    as control systems, IT support systems, and
    compensation and disciplinary systems. Belief
    systems — communicated through mission
    statements, credos, and statements of values —
    may create a culture that rewards integrity and
    clarifies the types of choices that should be made
    in the face of temptation (Simons, 1999). IT
    support systems such as software tools may
    either limit the risk management process or
    enable the organization to quantify its risks more
    accurately and prepare alternative scenario
    analyses. Incentive systems may be aligned with
    the risk management philosophy, organizational
    view of integrity, and corporate ethical values or
    lead to dysfunctional employee behavior. An
    example of the latter is the case of Bankers Trust
    Company, a traditional commercial bank whose
    incentive system rewarded bankers and traders
    for creating and pushing new products as fast as
    they could. As a consequence of this incentive
    pressure, Bankers Trust was sued in 1995 by
    several clients for misrepresenting the risks
    associated with new financial products.This
    resulted in millions of dollars of fines, customer
    reimbursement costs, and the dismissal of top
    executives (Simons,1999).
    Organizational resources
    that are of vital
    importance to effective risk management include
    both the financial and the human resources
    needed for risk prevention, event identification,
    assessment,
    response,
    control,
    communication,
    and monitoring. In light of the challenges of
    complying with Section 404, many public
    companies are now facing the problem of
    unqualified or inadequate finance staffs. For
    example,AXA, an international insurance giant,
    was found to have insufficient personnel in the
    corporate accounting department and Advanced
    Materials Group Inc. was found to be operating
    with no full-time CFO and a lack of staff expertise
    (Nyberg, 2004).
    Risk management strategy
    — what the
    organization aspires to achieve in terms of its
    risk exposure and risk management — must be
    consistent with corporate strategy, structure, and
    systems. Objective setting is an integral part of
    this input and involves articulating specific
    operational, reporting, and compliance risk
    objectives. Risk management strategy must specify
    the organization’s risk appetite (risk tolerance),
    which may vary with different categories of risk.
    For example, an organization may have a low risk
    appetite relative to all compliance objectives but a
    high risk tolerance for operational objectives that
    include innovation and commercial risks.
    Organization-level risk objectives must be
    integrated with more specific risk objectives for
    strategic business units and business functions
    (e.g., IT, human resources, health and safety,
    production and engineering, etc.).
    Processes
    After senior managers have evaluated the inputs
    that affect successful risk management activities,
    they must plan, develop, and execute risk
    management processes. Careful attention to
    both inputs and processes with respect to
    objectives and success drivers will determine
    the risk management consequences: outputs
    and outcomes.
    The new regulatory demands on risk
    management processes and internal controls
    require a significant shift in thinking and
    leadership
    .
    Organizational leadership at all levels — that of
    the board, senior management, and the risk
    management group — must be committed to risk
    management and provide a role model for
    employees in terms of ethical values and behavior.
    In addition to regulatory compliance, the
    leadership focus should be on seizing the
    opportunities emanating from internal or external
    sources and gaining competitive advantage.The
    example of Citigroup, the world’s largest bank and
    a pioneer in international finance, provides a
    warning. Japanese regulators required the bank to
    close its private banking unit in Japan for, among
    other things, failing to guard against money
    laundering. Senior executives knew that their
    actions were violating the rules and a number of
    employees were fired, including three prominent
    senior executives (O’Brien and Thomas, 2004).
    Risk management
    structure
    provides the
    framework to plan, execute, control, and monitor
    risk management activities.Transparency in the
    assignment of roles and responsibilities to the risk
    management function enables improved
    accountability and awareness and,ultimately,
    improved management and control. A risk
    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    19

    20
    management committee may include the CEO,
    the CFO, a corporate risk manager, the
    treasurer, the manager of corporate audit, a
    compliance manager, and divisional managers. In
    addition to recommending policy and process,
    this committee would be responsible for formal
    reporting to the audit committee of the board
    of directors on risk management performance.
    The internal audit function must be structured
    in such a manner that organizational objectivity
    is achieved and access to top management and
    the audit committee is unrestricted.
    Many organizations recognize that improved
    decision making generally results from a well-
    structured framework for risk and assurance.
    At United Grain Growers, a Canadian grain
    handler and distributor of crop inputs, the risk
    management committee is responsible for
    assembling comprehensive information on
    performance in relation to the full range of risk
    exposures; the previous practice had been
    limited to reports of adverse experiences with
    insured risks, treasury, and derivatives trading
    (Barton et al., 2002).Without an appropriate
    risk management structure, organizations can
    easily miss new or changed risks and be unable
    to exploit opportunities.
    Risk management
    systems
    encompass specific
    controls aimed at preventing the occurrence
    of risks.These include belief systems to
    expound the core values of the business,
    boundary systems to identify specific actions
    and behaviors that are unacceptable, diagnostic
    control systems to monitor critical
    performance variables, interactive control
    systems to stimulate learning, and traditional
    internal control systems (Simons, 1999). Risk
    management systems may also include
    compensation and disciplinary systems, specific
    policies relating to risk training, and human
    resource standards for hiring the most
    qualified individuals, with emphasis on
    educational background, prior work
    experience, past accomplishments, and
    evidence of integrity and ethical behavior
    (COSO, 2004a). Finally, risk management
    systems incorporate six components of the
    COSO framework:
    event identification, risk
    assessment, risk response, control activities,
    information & communication,
    and
    monitoring
    .
    Organizations must develop appropriate
    activities for each of these six components.
    There must be consistency in the risk
    management system throughout the organization.
    For example, every business unit should use the
    same definition of risk and control, adopt the
    same criteria for evaluation, follow a standard
    process for defining what is material or significant,
    and test to the same extent.
    Outputs
    Managing risk effectively can result in several
    beneficial outputs, including compliance with
    laws and regulations, secured business process
    continuity,
    enhanced
    working
    environments,
    better allocation of resources, improved
    internal reporting and external disclosure, an
    increase in organizational reputation, reduced
    cost of capital, and a reduction in earnings
    volatility.These benefits are all considered to be
    intermediate outputs because they lead, in turn,
    to the final outputs of reduced overall costs and
    increased revenues.
    Compliance with laws and regulations
    includes the
    adequate design and operation of internal
    control as well as adherence to other legal
    guidelines, such as health and safety regulations,
    anti-competitive practices,commercial and
    professional indemnity rules,intellectual
    property regulations,employment practices
    regulations, and the like. By identifying, assessing,
    and properly responding to the risks related to
    laws and regulations, organizations can prevent
    the tremendous loss of organizational
    resources and avoid the unnecessary costs of
    prosecution and penalties.
    Business process continuity
    is reflected in on-
    time deliveries of products and services, zero
    unplanned interruptions in the functioning of
    information systems, zero unplanned
    production downtime, and generally smooth
    execution of the business process.This
    continuity is best achieved through a carefully
    elaborated risk management framework
    supported by a disaster recovery plan that
    covers critical risks, users, systems, and
    procedures, and is tested and updated to
    reflect changing conditions at least annually.
    Maintaining business process continuity is
    essential to profitability.
    Evidence of an
    enhanced working environment
    can
    be seen in reduced absenteeism and turnover
    and in increased productivity and creativity
    among employees. According to
    Health and
    Safety Executive
    , 40.2 million working days were
    lost in the United Kingdom in 2001-2002 due
    to work-related illness and injury, representing
    billions of pounds in lost revenues.Thus, the
    STRATEGY
    MEASUREMENT
    MANAGEMENT

    ability to identify and manage workplace risks
    alone can result directly in an increase in
    productivity and profitability (Cottell, 2003).
    Channeling appropriate resources to the most
    significant risks is more cost-effective and efficient
    overall.This
    improved allocation of resources
    is an
    important result of effective risk identification and
    measurement and contributes directly to the
    bottom line.
    Based on effective risk management processes,
    enhanced internal reporting
    of risk and control
    information can lead to improved decision making
    with respect to taking on risks knowingly, a more
    effective balance between risk and reward, and
    better responsiveness to internal and external
    activities and change. Improved internal
    communication and knowledge sharing can
    increase understanding of the main risks to the
    business and the effective strategies put in place
    to address these issues. Reliability, relevance, and
    timeliness of information will also improve
    internal reporting of other information, such as
    financial or operating information, so that heads of
    business units and senior managers can make
    better business decisions.
    Organizations are required to provide quality
    information to external stakeholders, and to
    ensure honest, balanced, and complete external
    reporting.With a proper risk management
    framework, an organization can produce reliable
    external reporting
    that will affect the organization’s
    reputation and shareholder value in a positive way.
    Improved organizational reputation
    is one of the
    most important outputs of successful risk
    management activities and the loss of reputation
    is one of the most significant risks that
    organizations face today. A recent survey of over
    100 CEOs of major European corporations
    ranked reputational risk as the second biggest
    threat to business, after business interruption.The
    same survey also ranked the effective
    management of reputational risk as the most
    important opportunity for increasing shareholder
    value (Blunden and Allen, 2003). A change in
    reputation impacts not only the immediate
    earnings of the organization but also several years
    of future earnings. Damage to an organization’s
    reputation can be accompanied by direct, short-
    term losses, such as regulatory fines, that affect
    the profit and loss statement almost immediately.
    However, most organizations consider the
    indirect, future loss from public disclosure to be
    far more significant, as well as more costly.
    Organizations can be proactive by building up
    reputational capital. For example, JP Morgan
    Chase, a New York-based leader in investment
    banking and asset management, released a free
    publication of its value-at-risk methodology that
    led to the broad adoption of this model in the
    financial markets and enabled the organization to
    establish a reputation for cutting-edge risk
    management (Blunden and Allen, 2003).
    Reduction of earnings volatility
    can be an output of
    integrated risk management. By bundling the
    management of various risks into one framework,
    organizations can not only eliminate the costs of
    operating multiple programs but also offset a
    negative experience relative to one risk with a
    favorable experience relative to another.This can
    reduce the volatility of earnings, which, in turn, can
    not only reduce share price volatility but also
    increase the average share price over time.
    Reduced cost of capital
    is a benefit that for-profit
    organizations can expect from an integrated risk-
    financing program.With integrated risk
    management, an organization can increase its
    leverage capacity by transferring part of a
    previously retained risk to a third party.The
    higher debt levels, carrying a lower cost than
    equity and forming a greater proportion of total
    financing costs, reduce the overall cost of capital
    to the organization.With respect to not-for-profit
    organizations, the corresponding benefit is the
    reduced cost of funds acquisition
    .
    The intermediate outputs described above result
    in improvements in two final outputs: notably
    reduced costs and increased revenues at the
    organizational
    level.
    Reduced costs
    include reductions in the short- and
    long-term costs of risk and in overall costs.The
    short-term costs of risk
    include the costs of
    prosecution and penalties.Typically,the reduction
    of costs in this area is a direct consequence of
    increased compliance with legislation. For example,
    implementation of health and safety standards in
    the workplace prevents work-related injury, illness,
    and death.The
    long-term costs of risk
    are reduced as
    a result of the portfolio effect, which should be of
    particular interest to all organizations. For
    example, discounts on the cost of insurance can be
    given for a wide range of risk management
    measures,including enhanced security,improved
    safety equipment, and new safety policies for staff.
    By bundling risks into a portfolio rather than
    managing them separately, United Grain Growers
    was able to use the very low loss ratios on some
    lines of insurance to offset less favorable loss ratios
    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    21

    22
    STRATEGY
    MEASUREMENT
    on other lines, and integrate insured business
    risks with non-insurable risks (e.g., grain-handling
    volume). As a result, the long-term cost of risk
    was reduced significantly (Barton et al., 2002).
    Overall cost reductions
    occur when unforeseen
    events are reduced in number, the associated
    costs being avoided, and when foreseen risks are
    planned and well-controlled, the associated costs
    being reduced.
    Increased revenues
    , in the case of for-profit
    organizations, and
    increased program
    effectiveness
    , in the case of not-for-profit
    organizations, result from several intermediate
    outputs. Compliance with regulations has a
    positive affect on business process continuity,
    which can increase customer satisfaction and
    loyalty and lead to higher revenues. An
    enhanced working environment increases
    employee satisfaction, motivation, and
    productivity and can lead to increased sales.
    Enhanced internal reporting supports better
    decision making and, together with improved
    external reporting, can increase organizational
    reputation, impact stakeholder perceptions
    and customer satisfaction, and lead to
    increased revenues.
    Outcomes
    For the risk management initiatives to be of
    value, the outputs must pay off eventually in the
    outcomes of
    increased organizational success
    and
    improved shareholder value
    . In other words,
    organizations can increase corporate success
    and shareholder value by using integrated risk
    management to reduce costs, increase
    revenues, and enhance program effectiveness.
    Metrics
    In order for senior managers to monitor the
    drivers and causal relationships in the Risk
    Management Payoff Model,appropriate
    measures must be developed that are
    consistent with, and supportive of, the
    objectives and drivers of success.The same
    metrics are not appropriate for every
    organization. Exhibits 10, 11, 12, 13, and 14
    present a selection of possibilities rather than a
    comprehensive set of measures for effective
    risk management and internal control. Managers
    must select or adapt a few metrics that most
    closely fit the corporate and risk management
    strategy of their respective organizations.
    It is important to focus on the key indicators,
    rather than introduce indicators for everything
    that can be measured, and to choose a
    manageable number of performance measures.
    In this way, decision makers will be able to focus
    on the critical elements of organizational
    success rather than try to cope with every
    aspect of the risk management process.
    However, with respect to the metrics for risks
    (Exhibit 10), organizations should have
    measures in place for all subcategories of
    strategic,operational,reporting,and compliance
    risks that the organization faces.
    Managers can encounter various difficulties when
    applying risk management performance measures.
    For some metrics, particularly with regard to
    intermediate and final outputs, existing data may
    be insufficient. For drivers such as enhanced
    working environment or increased organizational
    reputation, managers must establish baseline
    indicators with initial measurements in order to
    demonstrate improvement. In order to compile a
    satisfactory profile of some risks, it may be
    desirable to gather data going back as far as 15
    years. Finally, business risks that are not easily
    measurable are difficult to quantify at all.When
    sufficient credible data for a quantitative
    assessment are not practically available or when
    the risk does not lend itself to quantification,
    qualitative techniques must be used for risk
    evaluation. For example, with respect to
    technology and regulatory risks, the only
    measurement that can be made is a subjective
    ranking based on dollar effects or severity of
    impact; in such cases, it is common to use a scale
    from 1 (highly critical) to 3 (least important) with
    2 indicating moderate importance.
    The results of risk assessment can be projected
    on a risk map. Individual risks are prioritized on
    the map according to level of importance
    (significance),
    probability
    (frequency),
    and
    potential costs and benefits. In constructing a
    risk map, managers should consider a plan of
    three years or longer.
    The selection of appropriate performance
    measures should enable managers to monitor
    on an ongoing basis the risks to which the
    organization is exposed, the level of
    organizational preparedness for coping with
    risks, and the quality of the organization’s risk
    management process in terms of outputs and
    financial consequences.
    Calculating the Payoff
    The implementation of SOX requirements,
    particularly those related to Section 404,
    presents organizations with many challenges,
    MANAGEMENT

    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    23
    Exhibit 10: Risk Management Payoff Model: Examples of Metrics for Inputs
    Inputs
    Performance
    Measures
    Risks
    o Increase in number of customer complaints about service
    o Percentage of jobs filled with newcomers
    o Rate of expansion of operations relative to increase in
    organizational capacity to invest in more people and technology
    o Percentage of business based on new products and services
    generated by creative, risk-taking employees
    o Increase in frequency of failed deals, new products, or new services
    External Environment o Potential changes in laws and regulations
    o Political and cultural climate
    o Availability and cost of labor, materials, and capital
    o Changing customer tastes and preferences
    Changes in competitive position of the organization
    Internal Environment
    o Percentage of employees familiar with the organization’s
    risk management philosophy and risk appetite
    o Percentage of employees familiar with the organization’s
    risk management strategic objectives
    o Percentage of employees familiar with the corporate ethical values
    Corporate Strategy
    o Number of risk management projects approved in the strategic plan
    o Type of risk management projects (strategic, operational,
    reporting, and compliance) approved in the strategic plan
    o Percentage of aggressive stretch goals that are set from
    the top down with little or no input by subordinates
    Organizational
    o Level of risk management empowerment experienced by
    Structure
    business units and functional managers
    o Clarity in delegation of risk roles and responsibilities
    Organizational
    o Likelihood that employees are misconstruing the intentions
    Systems
    of senior managers
    o Likelihood that employees are taking on unacceptable levels
    of risk for personal gain
    o Percentage of total compensation represented by
    performance-variable
    pay
    o Percentage of employees ranked for purposes of comparison
    o Dollars invested in risk-related IT support systems
    o Percentage of hardware, databases, communications systems,
    and applications systems that are standardized
    o Number of IT applications that are not fully integrated with
    the overall IT system
    o Percentage of systems developed/maintained outside the organization
    (
    continued
    )

    24
    STRATEGY
    MEASUREMENT
    MANAGEMENT
    Exhibit 10: Risk Management Payoff Model: Examples of Metrics for Inputs (
    cont’d
    )
    Organizational
    o Rate of growth in risk management spending relative to rate
    Resources
    of growth in direct total spending
    o Dollars available for risk management infrastructure investment
    o S ize of systems security budget relative to total risk management budget
    o Dollars available for employee risk management training
    and development
    o Level of employee risk management literacy
    o Percentage of finance and accounting staff with adequate qualifications
    Risk Management
    o Number and scope of risks covered by risk management strategy
    Strategy
    o Level of integration planned in managing strategic, operational,
    reporting, and compliance risks
    o Anticipated increase in corporate reputation due to risk management
    o Anticipated level of business process continuity due to risk
    management
    o Planned reduction in annual total cost of risk
    o Planned costs, benefits, and profitability of risk management projects
    complexities, and new costs. However, with an
    approach to risk assessment and management
    that goes beyond the evaluation of internal
    control over financial reporting, organizations
    can realize benefits far wider than enhanced
    investor confidence in financial reporting.
    The Risk Management Payoff Model presented
    in this guideline provides organizations with a
    framework for the identification and assessment
    of various risks. Using the metrics selected in
    the model, managers can also determine the
    economic payoff of risk management activities.
    Exhibit 15 illustrates the calculation of ROI for a
    risk management initiative.
    Step 3: Risk Response
    In responding to risk, it is important for the
    organization to consider both the type and
    scale of risk that it should embrace and the
    extent to which stakeholders can be expected
    to accept the commercial consequences, if the
    risk materializes. Using the quantification
    process outlined in the Risk Management
    Payoff Model, the organization can determine
    the most appropriate response to a given risk
    and assess the effectiveness of the risk
    management processes and controls already in
    place. If these are found to be insufficient or
    excessive, and thus not cost-effective, the
    organization can use the knowledge it gains
    from the Risk Management Payoff Model to
    reallocate capital or resources.
    In general, risk responses include:
    ● Acceptance (no action taken to affect risk
    likelihood or impact).Usually,organizations
    accept risks because they can withstand the
    impact, they have transferred the risk, or
    they have reduced the risk to a tolerable
    level. It is the CEO’s responsibility to clarify
    with the board of directors both the
    categories of risk and the extent of
    exposure that are considered acceptable for
    the organization;
    ● Sharing (risk likelihood or impact reduced by
    transferring or otherwise sharing a portion
    of the risk);
    ● Transfer (risk passed to an independent,
    financially capable third party at a reasonable
    economic cost under a legally enforceable
    arrangement). For many years, buying
    insurance was seen as the only risk
    management tool that organizations could
    employ.Today, although insurance can help to
    provide financial security against
    unforeseeable events, other forms of risk
    management are essential to help guard
    against foreseeable risks that essentially
    remain within the control of the organization.

    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    25
    Processes
    Performance Measures
    Leadership
    o Percentage of senior executives’ time dedicated to risk management
    o Percentage of annual budget allocated to risk management initiatives
    o Percentage of CEO’s and CFO’s bonuses linked to decrease in
    overall cost of risk
    o Percentage of senior managers literate in risk management
    Structure
    o Clearly defined and transparent risk management roles and
    responsibilities
    o Degree of board’s independence from management
    o Level of experience and expertise of board members
    o Ratio of risk management support staff to total number of employees
    o Number of risk management professionals per employee
    Systems:
    o Percentage of employees compensated according to risk
    management
    effectiveness
    Measurement & Rewards
    o Percentage of employees’ variable pay linked to reduced
    long-term cost of risk
    o Percentage of risk management support staff receiving pay-for-
    performance compensation
    o Percentage of employees aware of the critical performance variables
    o Frequency of updates to risk policy and procedures
    o Frequency of government regulations compliance checks
    Event Identification
    o Percentage of employees involved in the risk identification processes
    o Number of different risk identification techniques applied
    o Number of risk identification initiatives using both future- and
    past-oriented techniques
    o Number of tests of risk occurrence applied
    o Percentage of uncertainties identified as risks
    o Percentage of risks identified that require regulatory compliance
    o Percentage of risks identified that require competitive repositioning
    Risk Assessment
    o Percentage of risks assessed with quantitative techniques
    o Percentage of risk rankings validated by specialists’ opinions
    o Percentage of risks assessed with respect to cost/benefit
    o Percentage of risk costs sufficiently defined and broken down
    Risk Response
    o Percentage of risks avoided with no costs
    o Percentage of risks reduced, transferred, shared, or accepted
    o Percentage of risks managed integrally
    (
    continued
    )
    Exhibit 11: Risk Management Payoff Model: Examples of Metrics
    for Processes

    26
    Processes
    Performance Measures
    Control Activities
    o Percentage of risk responses controlled by top-level reviews
    o Percentage of risk responses controlled by direct functional
    or activity managers
    o Number of executed periodic threat analyses of extremist
    groups with respect to current operations
    o Percentage of key areas (units) under camera surveillance to
    identify potential fraud or illegal activity
    Information &
    o Percentage of senior managers and employees that understand
    Communication
    the objectives of risk management initiatives
    o Dollars invested in employee risk awareness
    o Dollars invested in improving risk management skills and
    knowledge
    o Percentage of corporate-level performance measures and
    rewards linked to risk management effectiveness
    Monitoring
    o Percentage of risk project evaluations based on Return On
    Investment (ROI) metrics
    o Percentage of risk management initiatives monitored on an
    ongoing basis
    Intermediate
    Outputs
    Performance Measures
    Compliance with
    o Evaluation of effects of proposed or pending legislation on
    Regulations
    current operations
    o Percentage of relevant legal and regulatory risks that have been
    avoided by complete compliance with laws and regulations
    o Percentage of relevant legal and regulatory risks that have been
    reduced by partial compliance with laws and regulations
    Business Process
    o Percentage of information system downtime that was
    Continuity
    unplanned
    o Amount of time saved, previously earmarked for disaster
    recovery/business continuity efforts
    o Percentage reduction in operating cycle time
    o Percentage reduction in ordering, invoicing, tracking, and payment
    o Average time required to fill and process a customer order
    o Percentage increase in number of customer orders processed
    Exhibit 11: Risk Management Payoff Model: Examples of Metrics
    for Processes (
    continued
    )
    Exhibit 12: Risk Management Payoff Model: Examples of Metrics
    for Intermediate Outputs
    STRATEGY
    MEASUREMENT
    MANAGEMENT

    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    27
    Intermediate
    Outputs
    Performance Measures
    Business Process
    o Timeliness in order deliveries
    Continuity
    (
    cont’d
    )
    o Percentage reduction in customer grievances
    o Dollars saved based on time saved
    o Percentage increase in capacity utilization
    o Change in fixed costs per unit of capacity
    o Percentage of processes improved
    Enhanced Working
    o Dollars saved due to improved health and safety conditions
    Environment
    o Dollars saved due to decrease in absenteeism
    o Dollars saved due to lower rate of employee turnover
    o
    Dollars saved due to reduction in costs of employee grievances
    o
    Dollars saved due to reduction in costs of labor union grievances
    o Percentage increase in production output per employee
    o Dollar increase in sales due to productivity improvements
    o Percentage turnover in risk management support staff
    Improved Resource
    o Percentage of risks for which risk management responses were
    Allocation
    developed as part of an integrated risk-financing program
    o Financial effects of the integrated risk-financing program
    Enhanced Internal
    o Dollars saved due to increased IT security (i.e., reduced IT
    Reporting
    system downtime, reduced incidence of fraud, etc.)
    o Dollars saved due to improved information quality (i.e.,
    improved
    timeliness,
    accuracy,
    relevance,
    etc.)
    o Time saved due to improved quality of information and
    internal reports
    o Change in auditor’s evaluation of the quality of internal reports
    Improved External
    o Increase in shareholder satisfaction with financial reporting
    Reporting
    and risk disclosure
    o Increase in satisfaction of other stakeholders with financial
    reporting and risk disclosure
    o Change in auditor’s evaluation of the quality of financial reports
    Improved Organizational
    o Improved corporate reputation ranking
    Reputation
    o Frequency of positive media coverage
    o Improvements in the ratings of corporate brands
    Reduced Earnings Volatility o Percentage reduction in earnings volatility
    Reduced Cost of
    o Percentage reduction in cost of capital
    Capital/Funds Acquisition
    o Percentage reduction in cost of funds acquisition
    Exhibit 12: Risk Management Payoff Model: Examples of Metrics
    for Intermediate Outputs
    (
    continued
    )

    28
    STRATEGY
    MEASUREMENT
    MANAGEMENT
    Final Outputs
    Performance Measures
    Reduced Costs
    o Percentage reduction in costs of prosecution and penalties
    o Percentage reduction in overall short-term costs of risk
    o Percentage reduction in overall long-term costs of risk
    o Percentage reduction in overall operating costs
    Increased Revenues
    o Increase in sales due to business process continuity
    o Increase in sales due to improved organizational reputation
    o Percentage of sales from new customers
    o Increase in sales from existing customers
    o Number of new customer partnerships created due to
    improved regulatory compliance
    Increased Program
    o Percentage of strategic non-financial goals achieved
    Effectiveness
    o Increase in customer satisfaction
    o Increase in customer loyalty
    Outcomes
    Performance Measures
    Long-term
    o Percentage change in stock price attributable to risk
    Organizational Success/
    management
    initiatives
    Shareholder Value
    o Percentage of strategic financial goals achieved
    o Economic Value Added (EVA)
    o Growth in earnings
    o Return on Assets (ROA)
    o Return on Equity (ROE)
    Short-term
    o Growth in cash flow
    Organizational Success/
    o Value added per employee
    Shareholder
    Value
    o Profitability of risk management projects
    o Market value of financial instruments relative to contract value
    Ways to transfer risk include buying
    insurance, hedging risk in the capital markets,
    sharing risk through joint venture investments
    or strategic alliances, arranging outsourcing
    that is accompanied by a contractual risk
    transfer, and indemnifying risk through
    contractual agreements (DeLoach,2000);
    ● Reduction or mitigation (action taken to
    reduce risk likelihood or impact, or both).
    Building controls in response to risk is a
    form of mitigation.The CEO should evaluate
    the organization’s ability to reduce the
    incidence of risks and the impact on the
    business; and
    ● Avoidance (exiting the activities that give
    rise to risk).
    Exhibits 16, 17, 18, and 19 illustrate selected
    approaches and techniques for the prevention,
    Exhibit 13: Risk Management Payoff Model: Examples of Metrics
    for Final Outputs
    Exhibit 14: Risk Management Payoff Model: Examples of Metrics
    for Outcomes

    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    29
    Exhibit 15: Risk Management Payoff Model: Calculating ROI for a Risk
    Management Initiative
    CALCULATE THE MONETARY VALUE OF THE BENEFITS OF THE RISK MANAGEMENT INITIATIVE
    CALCULATE THE TOTAL COSTS OF THE RISK MANAGEMENT INITIATIVE
    CALCULATE THE ROI OF THE RISK MANAGEMENT INITIATIVE
    Outputs
    Benefits
    Monetary Value
    Compliance with Regulations Reduced costs of prosecution and penalties $...................
    Business Process Continuity
    Labor hours saved, machine hours saved,
    reduced cost of grievances, etc. due to
    increased on-time deliveries
    $...................
    Enhanced
    Working
    Environment
    Increase in output (units produced, services
    offered)
    $...................
    Improved Resource
    Allocation
    Savings in costs due to efficient capital
    allocations
    $...................
    Enhanced Internal and
    External Reporting
    Reduced direct administrative and operating
    costs, reduced incidence and costs of fraud, etc
    $...................
    Corporate Reputation
    Increased sales from existing and new
    customers
    $...................
    Reduced Earnings Volatility
    Increase in shareholder value
    $...................
    Reduced Cost of Capital
    Savings in costs of equity financing
    $...................
    Total Benefits
    $...................
    Costs
    Value
    Front-end Direct Costs of
    Risk Initiative
    Costs of event identification, assessment, and
    response (e.g.,hardware,software,installation
    and configuration,training,etc.)
    $...................
    Disruption Costs Related to
    Human Factors
    Hours lost because of risk training, decline in
    labor productivity, decline in product and
    service quality, lost revenues
    $...................
    Disruption Costs Related to
    Organizational Factors
    Costs of organizational restructuring,
    technical disruptions, breakdowns in service
    $...................
    Total Capital Costs
    $...................
    Operating Costs of Risk
    Management
    Initiative
    Costs of control activities, information &
    communication,and monitoring
    $...................
    Total Operating Costs
    $...................
    Total Benefits – Operating Costs
    ROI = ------------------------------------------------------ * 100
    Capital Costs (Investment)

    reduction (mitigation), transfer, and sharing of
    strategic,operational,reporting and compliance
    risks.When choosing an approach, an
    organization will be influenced by its risk
    appetite, or that of its stakeholders. In addition,
    the organization should consider the costs of
    operating particular controls relative to the
    benefit obtained in managing the risks.
    In addition, risk response involves planning and
    preparing to take action in the event that a
    disaster occurs.This may include practicing
    specific responses to hazardous situations or
    worst-case scenarios.
    Step 4: Control
    Control policies and procedures are needed to
    help ensure that the chosen risk responses are
    carried out properly and in a timely manner.
    Such activities typically include top-level reviews,
    direct functional or activity management, and
    the
    segregation of duties as well as the use of
    physical controls,information processing,and
    performance indicators.Control procedures
    can be implemented manually or make use of
    computers or other devices. Because risks
    change over time, ongoing evaluation is needed
    of both the risks and the policies and procedures
    designed to manage and control them.
    The Risk Management Payoff Model adds an
    extra dimension of control. Using the framework
    outlined above, organizations can determine
    whether or not the anticipated intermediate and
    final outputs have been realized and calculate the
    monetary effects (payoffs) of risk management
    initiatives. Thus, the model represents a control
    device for evaluating the efficiency of the risk
    management process.
    Step 5: Information and Communication
    Within the organization, effective risk
    communication is essential. Employees at all
    levels must understand the definition of risk,
    the corporate attitude to risk, the organization’s
    exposure to different risks, the consequences of
    those risks, and the organization’s response to
    them.This information can be disseminated by
    means of employee manuals, bulletins, and the
    corporate intranet. In addition, management
    must provide employees with specific and
    directed communication that addresses
    behavioral expectations for individuals and the
    risk-related responsibilities of personnel.This
    should include a clear statement of the
    organization’s risk management approach and a
    clear delegation of authority.
    Generally, risk communication should convey
    the commitment of senior management to the
    effective management of risk. More specifically, it
    should convey:
    ● the importance and relevance of an effective
    risk management framework;
    ● the organization’s risk-related strategic
    objectives;
    ● the organization’s risk appetite (risk
    tolerance); and
    ● the role and responsibilities of personnel in
    effecting and supporting the risk
    management efforts (COSO, 2004a).
    Some companies communicate the importance
    of effective risk management by establishing a
    link with employee incentives. For example,
    shareholder value-added (SVA) is applied at JP
    Morgan Chase (Barton et al., 2002).This metric
    calculates profit by subtracting a charge for
    invested capital from cash operating earnings.
    The more risk taken by a decision maker on the
    organization’s behalf, the higher the capital
    charge. By introducing SVA, an organization
    could ensure that all business decisions involve
    an explicit consideration of risk.
    At the board level, risk information must
    communicate the principal business threats and
    opportunities, the type of controls that are being
    implemented, and the relationship between the
    achievement of strategic and operational
    objectives and risk performance measures. A
    top-level risk management report should be
    provided to both the CEO and the auditor and
    should ensure that both individuals achieve a
    clear understanding of the level of risk exposure
    and the effectiveness of the controls in place.
    External stakeholders are interested in the
    risk-taking policy of the organization, the
    specific risks to which the organization is
    exposed, and the way in which those risks are
    managed.
    Communication
    of
    relevant
    risk-
    related
    information
    to
    shareholders,
    regulators,
    financial
    analysts,
    and
    other
    external
    parties
    leads to a better understanding of the
    circumstances
    and
    risks
    the
    organization
    faces.
    In
    addition,
    public
    expectations
    are
    growing
    with
    respect to reliability and security in financial
    reporting and in the disclosure of risks.
    Accordingly,
    risk-related
    communication
    should
    be
    meaningful,
    pertinent,
    timely,
    and
    in
    conformance
    with
    legal
    and
    regulatory
    requirements.
    30
    STRATEGY
    MEASUREMENT
    MANAGEMENT

    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    31
    Strategic Risks
    Approaches
    and Techniques
    Economic Risks
    Derivatives (futures, options, and swaps)
    Industry Risks
    Ensuring compliance with laws and regulations; training
    employees in compliance culture with respect to their
    dealings with customers, suppliers, and competitors
    Strategic Transaction Risks
    Derivatives (futures, options and swaps)
    Social Risks
    Marketing research; environmental scanning
    Technological Risks
    Industry analysis; environmental scanning
    Political Risks
    Lobbying
    Organizational Risks
    Adopting contemporary management control systems
    Step 6: Monitoring
    Businesses and circumstances change constantly,
    and risk management must evolve with them.
    Therefore, all aspects of the risk management
    process — risk identification, measurement,
    response, and control — need to be monitored.
    Risk-related strategic objectives,success drivers,
    and performance measures should be updated
    and elements of risk management modified as
    necessary. Generally, monitoring can be done in
    one of two ways: through ongoing activities or by
    means of stand-alone evaluations.The greater the
    depth and effectiveness of ongoing monitoring,
    the less need there is for separate evaluation
    projects. For example, Johnson & Johnson uses a
    highly interactive,long-range profit-planning
    system to assess opportunities and threats on a
    continuous basis. Under this system, managers
    constantly revise projections in response to three
    questions:What has changed? Why? What are we
    going to do about it? (Simons, 1999).
    Given the ongoing changes in corporate
    governance, organizations also need systems to
    monitor developments in this area and to identify
    those aspects of the existing compliance, audit,
    and risk management programs in which revision
    is needed.The board of directors should ensure
    that such a system is implemented. For example,
    at Telus, the audit committee is responsible for
    reviewing and monitoring the risk management
    systems currently in place in order to mitigate the
    company’s exposure.The committee reviews the
    risk management goals, proposed changes, annual
    risk assessment flow, benefits, and the risk
    management matrix and timeline (Telus, 2004).
    Another area of risk management that needs to
    be monitored is the organization’s contingency
    plan for business continuity. If the unexpected
    were to happen, critical business operations
    would have to be redeployed quickly, in order to
    reduce downtime and minimize the impact on
    productivity and profitability. In 2002, only 28
    percent of organizations had a business continuity
    strategy in place, and this figure was lower in
    2001 (McNeill, 2003). Managers need to identify
    the processes, equipment, and people that are
    essential for the organization to provide its
    customers with the products or services they
    need and, on that basis, construct a contingency
    plan for maintaining business operations. For the
    plan to be effective, it must be reviewed and
    rehearsed on a regular basis. It is advisable that
    the drills be as real as possible, with computers
    shut down, for example, or telephones switched
    off. Unless the plan is tested to this degree,
    participants,including senior management,may
    pay little attention to the rehearsal and flaws in
    the plan may go undetected. In many cases, a
    proven business continuity plan is essential for
    insurance coverage and may influence the insurer
    to retain more of the risk.The process described
    above can enable an organization to establish a
    viable plan for business continuity and significantly
    improve its management of risk.
    RISK MANAGEMENT FOR
    SPECIFIC BUSINESS FUNCTIONS
    Although the framework described above
    proposes measures for managing risks at the
    organizational level, and for complying with
    the new regulation on internal control,
    organizations face similar challenges in
    measuring and managing risks at the functional
    level. For example, operations and production
    Exhibit 16: Responding to Strategic Risks

    32
    Operational Risks Approaches and Techniques
    Environmental Risks
    Insurance; catastrophe plans and strategies; catastrophe protection
    products; compliance with environmental laws; certification on ISO
    14001(environmental controls within an organization)
    Financial Risks
    Regular credit checks on customers; setting terms of trade early in the
    process, checking invoices, and adopting a follow-up system; factoring
    and invoice discounting; derivatives (futures, options and swaps)
    Business
    Avoiding overreliance on a key supplier; improving supplier
    Continuity Risks
    management; adequate forecasting of demand; anticipating arrival of
    new competitors; anticipating a competitor’s promotion; coping with
    variability in production, bottlenecks, and IT systems; determining
    strategic inventory; establishing efficient internal control systems,
    rules, and policies; monitoring external risks; certification on ISO
    9000:2002 (quality of products and services); outsourcing
    Innovation Risks
    Derivatives (futures, options and swaps); patent watches; outsourcing
    Commercial Risks
    Derivatives (futures, options and swaps); ongoing identification of
    potentially registrable rights; patent watches; securing licenses and
    permissions;
    outsourcing
    Project Risks
    Well-defined project strategy; effective and well-defined project
    management with identified timelines and milestone markers; clearly
    defined roles and responsibilities; good understanding of project-
    specific requirements; effective tax and Value Added Tax (VAT)
    planning; precise definition and breakdown of costs; good matching
    of time, cost, and quality; complete and sufficiently detailed
    timetable; coping with decisions on design; effective monitoring of
    time and cost; complete operating and maintenance information;
    outsourcing of specific project activities
    Human Resource
    Adequate systems of promotion; regular reviews of staff competencies;
    (HR) Risks
    effective antidiscrimination policies; transparent and fair
    compensation schemes; pre-employment health checks to identify
    existing problems; high-quality supervision and leadership;
    compliance with employment laws; outsourcing of specific HR activities
    Health and
    Certification on OHSAS 18001 (health and safety within an
    Safety Risks
    organization); compliance with health and safety regulations;
    development of guidelines for adherence to corporate safety and
    environmental standards; ongoing health and safety training; regular
    plant, machinery, and equipment inspections; occupational health
    programs; ensuring proper fit and suitability of employees’ personal
    protective equipment; employee rotation; routine drills of
    organizational response to fire and other hazards
    Property Risks
    Insurance; ongoing identification of potentially registrable rights;
    adequate inventory and record keeping; securing licenses and
    permissions; staff training; clearly defined policies and guidelines
    Reputational Risks
    Investment in branding; investment in socially responsible projects;
    advertising;political lobbying;communications strategy;maintaining
    relationships with the media; media training for relevant staff;commu-
    nication of company policies on ethical conduct and human rights to
    public security providers; product and service excellence programs
    Exhibit 17: Responding to Operational Risks
    STRATEGY
    MEASUREMENT
    MANAGEMENT

    functions must manage supply chain risks;
    human resources managers and legal staff need
    to address personnel risks and health and safety
    risks; environmental quality managers have to
    deal with environmental regulation compliance
    and related risks; and R&D managers must find
    ways to manage innovation and commercial risks.
    In addition, many of these business functions have
    grown in importance recently and experienced
    increased pressure for accountability with
    respect to resources used. As a result, specific
    business functions will find it useful to apply the
    Risk Management Payoff Model in order to
    identify,measure,respond to,control,and
    monitor risks more carefully, as well as calculate
    the payoffs of risk management initiatives.
    INFORMATION RISK
    Information is at the heart of risk management,
    yet is itself a source of risk. Although information
    technology plays a critical role in many companies
    today and is expected to extend its influence to
    virtually all organizations in the near future, most
    companies do not have a formal process in place
    to identify potential risks associated with IT, or
    trace their sources. Information risk can be
    managed successfully only if IT risk strategies are
    integrated with the firm’s overall business risk
    strategies. Failure to do so makes it difficult to
    identify the links between business processes and
    the business risks that result from the use of IT.
    Some of the most worrisome IT risks relate not
    to the technology itself but to the integrity and
    security of the information. For example, the
    information on which management relies for
    decision making and reporting must be relevant,
    current, accurate, and representative. In addition,
    certain information must not fall into the hands of
    the organization’s competitors and thereby
    become a threat to the business.
    The COSO framework specifically addresses the
    need for controls over IT and information
    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    33
    Reporting Risks
    Approaches
    and Techniques
    Information Risks
    Certification on BS 7799 or ISO 17799 (information security
    standards within an organization); password security and
    encryptions; careful disposal of information; system design and
    training;random inspections
    Reporting Risks
    Certification on BS 7799 or ISO 17799 (information security
    standards within an organization); password security and
    encryptions; careful disposal of information
    Compliance Risks
    Approaches
    and Techniques
    Legal and
    Certification on ISO 14001 (environmental controls within an
    Regulatory Risks
    organization); certification on BS 7799 or ISO 17799 (information
    security standards within an organization); password security and
    encryptions; careful disposal of information; system design and
    training; random inspections; detective controls such as audits
    Control Risks
    Regular audits and inspections; risk policy, structures, and processes
    for responding to risk incidents; fraud awareness training; use of
    passwords and encryption; vetting all new and potential employees
    and following up on their references; establishing a system that
    ensures no single employee is in control of a financial transaction
    from beginning to end; safeguarding company check books and
    credit cards, maintaining a tight bookkeeping system
    Professional Risks
    Commercial and professional indemnity; employers’ liability
    coverage; directors’ and officers’ liability insurance
    Exhibit 18: Responding to Reporting Risks
    Exhibit 19: Responding to Compliance Risks

    34
    STRATEGY
    MEASUREMENT
    systems. General controls ensure the continued,
    proper operation of all application systems and
    include controls over security management, IT
    infrastructure and management, and software
    acquisition,
    development,
    and
    maintenance.
    Application controls focus directly on the
    completeness,
    accuracy,
    authorization,
    and
    validity of data capture and processing.These
    controls help ensure that data are captured or
    generated when needed, supporting applications
    are available, and interface errors are detected
    quickly (COSO, 2004a). Application controls
    include balancing activities, digit checks,
    predefined data listings, data reasonability tests,
    and logic tests.
    It is the responsibility of senior management to
    clarify what data should be protected, how
    sensitive this information is, how much
    protection is needed for different types of data,
    and how much risk the organization is willing to
    accept. Armed with this understanding, the IT
    department can then decide on the best way to
    provide the necessary security. It is advisable to
    concentrate responsibility for the security of
    information in all forms — printed and electronic
    — under a single management structure.
    Once an information security system has been
    established, organizational culture is a critical
    factor in ensuring that individual employees pay
    attention to the information security policies
    and implement the procedures. It is also
    important to monitor the system. For example,
    an overall assurance report can be generated,
    detailing regular security checks, the exceptions
    that were found, the effectiveness of escalation
    procedures in containing incidents, and other
    relevant information.
    RISK ASSESSMENT IN DUE
    DILIGENCE
    Assessing risk is also an important part of the
    due diligence required with respect to both
    mergers and acquisitions. Surveys and reports
    by the media and financial analysts reveal that
    most mergers fail, and that due diligence is one
    of the determining factors. Although an
    acquisition typically involves the much simpler
    process of fitting a smaller organization into the
    existing structure of a larger, acquiring
    organization, the perils of bad risk assessment in
    due diligence are much the same as those
    encountered in a merger of equals.
    Among the risks associated with mergers and
    acquisitions are those related to the conversion
    of existing systems and the initiation of new
    ones.The integration strategy should be well
    articulated and indicate the selected systems,
    processes, and practices that are most relevant
    to the functioning of the new entity.Targets and
    milestones must be created, especially for the
    measurement of synergies.Performance
    measurement systems must be aligned with the
    new strategy. Centralization of the IT function
    may be necessary to ensure compatibility and
    cohesiveness of data and to avoid adding
    unnecessary layers of technological complexity
    to the decision-making process. Specifically, it is
    critical to prevent deterioration of the key
    controls that were in place in the two
    organizations before they merged and to
    standardize the management of errors. Human
    resource issues must be handled with speed and
    clarity; employees of both organizations must be
    well informed of the severance policies and of
    the criteria for staff retention and promotion in
    order to prevent losing employees whose skills
    are vital to the new firm. Also, the issue of
    differing compensation programs must be
    resolved quickly (Epstein, 2004).
    Additional risk is associated with the need for
    integration and conversions to be completed
    within a short period of time so that the new
    organization can conduct business seamlessly
    after the merger/acquisition is formally
    completed. At the same time, it is vital that
    legal and regulatory issues be considered
    carefully.The Risk Management Payoff Model
    represents a useful tool that can be applied in
    the context of due diligence to risks
    encountered both in the merger/acquisition
    process and in the continuing operations of
    the new organization.
    COMPREHENSIVE RISK
    MANAGEMENT
    Today, the risk management perspective is
    shifting from a fragmented (departments or
    business functions managing risks
    independently), ad hoc (according to need, as
    perceived by managers), and narrow approach
    (focused primarily on insurable and financial
    risks), to one that is integrated, continuous, and
    broadly focused. Everyone in the organization
    should view risk management as part of his/her
    job and risk management efforts should be
    coordinated through senior-level oversight.The
    risk management process should be ongoing
    and all business risks and opportunities
    considered.
    MANAGEMENT

    Although the management of many operational
    risks (e.g., financial) can be assigned to specific
    departments (e.g.,treasury,insurance,audit,health
    and safety, procurement, etc.) strategic risk
    management cannot be delegated and remains
    firmly on the board agenda. It is the responsibility
    of the CEO to provide the leadership necessary
    for the active management of strategic risk and
    he/she must be held accountable for it in his/her
    annual performance review and evaluation by the
    board. Strategic risk management should form a
    significant part of the CEO’s job description and
    be a top priority for both the CEO and the
    senior management team.
    Risk management should become an integral part
    of strategic and operational decision making
    throughout the organization.The Risk
    Management Payoff Model should be applied to all
    operational and capital investment decisions so
    that managerial assessment of risk exposure can
    be part of the decision-making process. Ex ante
    calculation of the costs and beneficial
    consequences of alternative scenarios can help
    managers make the right decisions. For example, if
    a company plans to expand its operations and
    build new production facilities in a foreign country,
    managers must first determine the risks to which
    the company would be exposed. After carefully
    evaluating these risks, they must develop
    alternative risk responses and calculate the costs
    and benefits associated with each. Similarly, in an
    organization planning to set up a new incentive
    system for salespeople, the unintended risks of
    incentive pressures must be foreseen in various
    circumstances. In one such scenario, employees
    feel intense pressure to succeed at all costs, even
    if their actions overstep ethical bounds, out of fear
    that failure to meet performance expectations will
    jeopardize their status and compensation.
    Organizations can make risk consideration a part
    of the decision-making process by:
    ● articulating the organization’s risk management
    attitude in the mission statement and strategic
    objectives;
    ● communicating the risk management
    philosophy, specifically the link between risk
    management and strategy; for example,
    Dupont emphasizes that risk must be managed
    not in isolation but with a full understanding of
    what the organization wants to achieve
    (Barton et al., 2002);
    ● consistently incorporating risk awareness in
    the budgets;
    ● instilling risk awareness in the corporate
    culture (which may have been focused on
    other objectives) and enabling employees to
    become aware of all risks that are faced —
    both positive and transferable (insurable);
    ● conducting risk education and training to
    ensure that employees understand how risks
    can be identified and managed;
    ● articulating risk policies and tolerances
    through the use of analytical tools and risk
    assessments;
    ● introducing mechanisms to connect
    performance evaluation and incentive to risk
    management initiatives;and
    ● making risk assessment a required annual
    exercise within the business units; when
    participation in these assessments is broad,
    and the discussion and prioritization of risks
    thorough, the mindset of managers and
    employees can be altered so that risk
    management is viewed no longer as a
    verification of compliance with rules and
    regulations but rather as an important part of
    everyday decision making.
    THE ROLE OF SENIOR
    FINANCIAL MANAGERS
    Responding to the pressures of the business
    environment and stakeholder expectations,
    organizations are looking beyond regulatory
    demands to seek significant performance
    improvements from their risk management
    activities.This type of risk management, based on
    a proper risk assessment framework, is much
    more evolved than the provision of assurance
    that an organization has complied with corporate
    and regulatory standards.
    The adoption of such organization-wide risk
    management is a major cultural change for an
    organization and needs full support from the
    highest levels of management in order to succeed.
    Senior financial managers cannot merely delegate
    the task of implementing risk management
    initiatives; they must be the champions of the
    effort. In particular, the personal commitment of
    the CFO is of vital importance to the rapid,
    successful introduction of organization-wide risk
    management. In some organizations, the CFO is a
    member of the risk management committee. In all
    cases, risk management must be viewed as an
    integral component of good, overall business
    management, rather than a mere adjunct to it.
    The Risk Management Payoff Model can help
    senior financial managers improve internal control
    over various risks and better manage operational
    and capital decisions. As a result, reasonable
    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    35

    36
    STRATEGY
    MEASUREMENT
    assurance can be given that both management
    and the board of directors, in its oversight role,
    are being made aware in a timely manner of the
    extent to which the organization is moving
    toward the achievement of strategic and
    operational risk objectives.
    CONCLUSION
    The broad identification and measurement of
    risk is not easy and most organizations presently
    lack comprehensive risk evaluation systems.
    However, over the last few years, increasingly
    enormous costs have been associated with the
    failure to identify risks properly, integrate that
    information into operational and capital
    investment decisions, and provide adequate
    control systems and structures to plan for or
    reduce the risks.Whether these unanticipated
    costs have been related to financial frauds or
    ignored external risks, they have impacted
    corporate profits significantly and sometimes
    resulted in corporate demise.
    The recently increased regulatory and reporting
    requirements are one response to the critical
    need for both internal and external decision
    makers to have better information regarding
    the risks inherent in business decisions and to
    focus more explicitly on managing those risks.
    Some risks are foreseeable and can be planned
    for or reduced with various tools and
    techniques. More general business risks must be
    controlled through systems and structures.
    This guideline has provided a Risk Management
    Payoff Model that carefully articulates the
    inputs, processes, outputs, and outcomes of
    organizational activities related to risk
    management.The model demonstrates that
    corporate risks can be measured and the
    results integrated in all management decisions.
    The extensive set of metrics can be used to
    evaluate the payoffs of specific risk management
    initiatives as well as to assess the potential risks
    involved in decisions related to operations,
    processes, and capital projects (e.g., changes in
    performance measurement and reward
    systems, IT systems, or production facilities) and
    the costs of those risks to organizational
    profitability. More rigorous identification and
    measurement of broad corporate risks can
    enable senior managers to consider those risks
    more effectively in their decision making and
    manage them more successfully for improved
    corporate
    performance.
    MANAGEMENT

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    MANAGEMENT

    APPENDIX: REGULATORY
    REQUIREMENTS ON ENHANCED
    INTERNAL CONTROL
    The Sarbanes Oxley Act of 2002 — Section
    302 and 404 Requirements
    The Sarbanes-Oxley Act of 2002 creates new
    requirements for managers and accounting
    professionals related to corporate governance,
    including the responsibilities of directors and
    officers, the regulation of accounting firms that
    audit public organizations, corporate reporting,
    and enforcement. Sections 302 and 404
    particularly have created significant new
    requirements related to internal control and the
    assessment of risk.
    Under Section 302, the chief executive and
    financial officers of each publicly reporting
    company are required to certify each periodic
    (i.e., quarterly and annual) report filed or
    submitted to the SEC.The chief executive officer
    and chief financial officer must sign the
    certification themselves — another executive
    under a power of attorney cannot sign the
    certification. Section 302 requires the certification
    to cover the review of the report, its material
    accuracy, and fair presentation of financial
    information,disclosure controls,and internal
    accounting
    controls.
    The internal control requirements in Section 404
    represent among the more important aspects of
    the act to a corporation and its external auditors.
    Management always has been responsible for
    preparing periodic financial reports; external
    auditors reviewed those financial numbers and
    certified that they were fairly stated as part of
    their audit. Under the Sarbanes-Oxley Act,
    management now is responsible for documenting
    and testing its internal financial controls in order
    to prepare a report on their effectiveness. More
    specifically,management’s process for evaluating
    the effectiveness of the company’s internal
    controls must include:
    ● Determination of which controls are
    significant, which should include controls
    over transactions (routine,non-routine,
    estimation and judgment), fraud, controls on
    which other significant controls are dependent
    on the financial statement close process, and
    the locations or reporting entities to be
    included in the evaluation;
    ● The documentation of controls related to
    management’s assertion, including each of
    the five COSO definitions of internal
    control, controls designed to detect or
    prevent frauds or errors in significant
    accounts, transactions or disclosures, the
    financial statement close process, and
    controls over safeguarding of assets;
    ● Evaluation of design and most effective
    combination of manual and IT controls;
    ● Evaluation of the operating effectiveness by the
    testing of controls by internal audit or third
    parties under the direction of management, or
    a self-assessment process that includes
    procedures to verify that controls are working
    effectively. Inquiry alone is not adequate; and
    ● Determination of which control deficiencies
    constitute significant deficiencies or material
    weaknesses (Sheridan,2003).
    A self-assessment alone is not enough without
    the documentation and testing to back it up.The
    external auditors also review the supporting
    materials leading up to the internal financial
    controls report to assert that the report is an
    accurate description of that internal control
    environment.The report should cover key
    information such as risk control description,
    specification of those performing the control,
    types of controls, frequency, evidence, and results
    of testing from an efficiency point of view.
    Federal Sentencing Guidelines
    The United States Sentencing Commission
    announced that on November 1, 2004, stricter
    Federal Sentencing Guidelines for organizations
    would be effective.These guidelines define the
    essential elements of a corporate compliance
    program. All U.S. companies, regardless whether
    they are public or private, are required to have
    compliance plans if they wish to receive the
    benefit of prosecutorial discretion from a federal
    prosecutor, or sentencing mitigation from a federal
    judge.The primary purpose of a compliance
    program is to avoid these situations altogether by
    preventing violations of the law from occurring.
    The Federal Sentencing Guidelines set forth seven
    basic criteria, as follows:
    1. Establish standards and procedures reasonably
    capable of reducing the chances of criminal
    conduct;
    2. Appointment of compliance officer(s) to
    oversee plans;
    3. Take due care not to delegate substantial
    discretionary authority to individuals who the
    organization knows, or should know, are likely
    to engage in illegal conduct;
    IDENTIFYING RISKS FOR IMPROVED PERFORMANCE
    39

    40
    STRATEGY
    MEASUREMENT
    4. Establish steps to effectively communicate
    the organization’s compliance standards and
    procedures to all employees;
    5. Take reasonable steps to ensure compliance
    through monitoring and auditing;
    6. Employ consistent disciplinary mechanisms;
    and
    7. When an offense is detected, take all
    reasonable steps to prevent future similar
    offenses, including modifying the compliance
    plan,when appropriate.
    Canadian Regulation
    In Canada, on February 4, 2005, the Canadian
    Securities Administrators released proposed
    requirements maintaining the harmonization of
    Canadian regulatory reporting and certification
    rules with Sarbanes-Oxley.The proposed
    Multilateral Instrument 52-111, Reporting on
    Internal Control over Financial Reporting,
    requires reporting issuers on the Toronto Stock
    Exchange to adhere to the following:
    ● Management will be required to issue a
    report on the effectiveness of internal
    control over financial reporting; and
    ● The external auditor will be required to
    issue an audit report on management’s
    assessment along with its own report.
    The earliest that the proposed instrument will
    be effective is for fiscal years ending on or after
    June 30, 2007.
    MANAGEMENT

    Kent
    Allingham,
    MBA,
    CPA
    Senior Manager, Corporate IT Controls
    MCI
    Barry Baptie, MBA, CMA, FCMA
    Board of Directors
    VCom Inc.
    Dennis C. Daly, CMA
    Professor of Accounting
    Metropolitan State University
    William Langdon, CMA, FCMA
    Vice President, Knowledge Management
    CMA Canada
    Melanie Woodward McGee, MS, CPA, CFE
    Manager
    of
    Accounting/Joint
    Venture
    Controller
    American
    Airlines/Texas
    Aero
    Engine
    Services,LLC
    John
    F.
    Morrow,
    CPA
    Vice President,The New Finance
    American Institute of Certified Public
    Accountants
    Kevin Simpson,MBA,CM&A,CPA
    Managing Director
    Focus Business Services, LLC
    William H. Steeves, B.Sc., CMA, FCMA
    Board Director and Business Consultant
    Derrick Sturge, MBA, CMA, FCMA, FCA
    Firm Director, CFO and Governance Services,
    Deloitte & Touche, LLP
    Al Wallace
    Chief Operational Officer (COO)
    WorkCare Inc.
    Kenneth W. Witt, CPA
    Technical Manager,The New Finance
    American Institute of Certified Public
    Accountants
    This
    Management Accounting Guideline
    was prepared with the advice and counsel of:
    For additional copies or for more information on other products available contact:
    In the U.S.A.:
    American Institute of Certified Public Accountants
    1211 Avenue of the Americas
    New York, NY 10036-8775 USA
    Tel (888) 777-7077, FAX (800) 362-5066
    www.aicpa.org
    Visit the AICPA store at www.cpa2biz.com
    In Canada and elsewhere:
    The Society of Management Accountants of Canada
    Mississauga Executive Centre
    One Robert Speck Parkway, Suite 1400
    Mississauga, ON L4Z 3M3 Canada
    Tel (905) 949-4200
    FAX (905) 949-0888
    www.cma-canada.org

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    ISO Certified
    AICPA Member and
    Public Information:
    www.aicpa.org
    AICPA Online Store:
    www.cpa2biz.com

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