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Putting risk in the
comfort zone
Nine principles
for building the Risk
Intelligent Enterprise
                     TM
Table of contents



                                                                                                 Preface                                                                        1

                                                                                                 Uncomfortable risk                                                             2

                                                                                                 A framework is a coat rack                                                     3

                                                                                                 Symphonic risk management                                                      4

                                                                                                 Follow the same map                                                            5

                                                                                                 The mushroom treatment                                                         6

                                                                                                 “We manage risk every Friday”                                                  7

                                                                                                 Risk lives here                                                                8

                                                                                                 The risk support system                                                        9

                                                                                                 The comforters                                                              10

                                                                                                 Be risk intelligent                                                         11

                                                                                                 Nine principles                                                             12

                                                                                                 Contacts                                                                    13




Disclaimer

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Preface

The publication represents the first installment in Deloitte’s     Although this paper is the first in our “Fundamental
series on the fundamental principles of Risk Intelligence.         Principles” series, it is by no means our initial words on
The papers in the series are intended to offer plain-              the subject of Risk Intelligence. In fact, we’ve published
English descriptions of the foundational elements of a Risk        over a dozen related titles as well as numerous podcasts
Intelligence program, as well as insights and practical steps      and webcasts. You may access all of this material free of
you may consider for incorporating the concepts within your        charge at www.deloitte.com/RiskIntelligence.
own organization.
                                                                   Open communication is a key characteristic of a Risk
On each of the following pages, you will find a statement          Intelligent Enterprise. Consider sharing this whitepaper
describing a single principle of a Risk Intelligence program,      with the other executives, board members, and key
along with an elaboration on the topic. In aggregate, we           managers in your organization. The issues and concepts
believe application of these principles will help create what we   outlined herein should provide an excellent starting point
consider the epitome of enlightened risk management: The           for a crucial dialogue on enhancing your organization’s
Risk Intelligent Enterprise.                                       Risk Intelligence.

Keep in mind that the application of these principles will
differ based on your industry practices, regulatory schema,
and organizational maturity. For example, in the financial
services and energy industries, many of these principles
have been discussed for over a decade and thus may seem
elementary; but for many other industries, we see these
principles just starting to be embraced. Regardless of what
industry you are in, the Fundamental Principles still apply.
Uncomfortable risk

Like politics and religion, risk can be an uncomfortable topic
of conversation. Understandably so, because many people
unintentionally limit the parameters of the discussion.

You probably think of risk in terms of threats — bad things
happening to your business. Not a pleasant subject of
conversation.

But the discussion can flow freely if you consider the other side
of risk, the one that applies to value creation — risk taking for
reward.

Introducing new products; entering foreign markets; acquiring
competitors — all are challenging endeavors, and if you don’t
properly manage the associated risks, you may not reap the
potential rewards.

So consider adopting a more expansive definition of risk,
one that gives equal weight to managing the risks related to
growth and profitability:

Risk is the potential for loss or harm — or the diminished
opportunity for gain — that can adversely affect the
achievement of an organization’s objectives.




Principle #1: In a Risk Intelligent Enterprise, a
common definition of risk, which addresses both
value preservation and value creation, is used
consistently throughout the organization.
A framework is a coat rack

             When it comes to keeping your parka off the parquet or your
             cape off the carpet, the solution may seem deceptively simple:
             All you need is a hook.

             But what’s holding up that hook? In fact, the support structure
             will vary, depending on whether you’re hanging heavy winter
             gear or gauzy summer fashions.

             It might be helpful to think of your risk management
             framework in the same manner: something to hang your risk
             management program on.

             A risk framework — such as COSO ERM, Turnbull, and ISO —
             provides a structure that helps you decide which opportunities
             to pursue and which hazards to avoid.

             But the framework must be sturdy enough to support your risk
             management objectives. It must accommodate your unique
             strategies, initiatives, and organizational structure. And it must
             be adaptable to your industry and regulatory requirements.

             There’s no need to overanalyze. Don’t get snagged on the
             selection of your risk framework. Just make sure it’s something
             you can hang your hat on.




Principle #2: In a Risk Intelligent Enterprise, a
common risk framework supported by appropriate
standards is used throughout the organization to
manage risks.
Symphonic risk management

Done right, risk management is a coordinated effort, as
finely tuned as a symphony orchestra. In both risk and music,
multiple roles are played simultaneously in often complex
arrangements.

Of course, some people in your organization may not even
realize they are part of the band. Your product development
manager, IT supervisor, or deputy vice president responsible
for MA probably considers risk management somebody else’s
job.

Changing that mindset is a precursor to promoting Risk
Intelligence in your organization. You’ll need clear messaging
at the individual level to convey what Risk Intelligence means;
why it is important to the organization collectively and to
employees individually; and what your people actually need to
do on a daily basis.

This effort requires clear communications; a strong risk-
focused culture; reward programs that incorporate risk-related
objectives; and learning programs to promote intelligent risk
management.

In sum, it’s needs to be a harmonious collaboration. Here’s
what the score looks like:

• The board sets the tone (see page 6).
• The executive wields the baton (page 7).
• The business units play the music (page 8).
• Certain functions (HR, finance, IT, legal, tax) support the
  concert backstage (page 9).
• Other functions (internal audit, risk, and compliance) monitor
  the performance (page 10).




                                              Principle #3: In a Risk Intelligent Enterprise, key
                                              roles, responsibilities, and authority relating to risk
                                              management are clearly defined and delineated within
                                              the organization.
Follow the same map

                                                    Risk specialists tend to behave like any subculture: They stick
                                                    together. They share similar beliefs, rituals, and habits. They
                                                    develop their own dialect.

                                                    But practices that sustain, say, an indigenous people may
                                                    not be ideally suited to the risk managers of a multinational
                                                    corporation.

                                                    Not to say that specialization is unnecessary. Quite the
                                                    contrary: effective risk management would not be possible
                                                    without it. Rather, risk specialists just need to poke their
                                                    heads outside their silos once in a while. Risk doesn’t exist in
                                                    isolation, so risk managers can’t either.

                                                    To effectively and efficiently manage risks and reap the
                                                    rewards, organizational silos must be bridged. The bridging
                                                    process means creating a common infrastructure; it means that
                                                    all the business units and functions use the same supporting
                                                    technologies and processes where possible and practicable.
                                                    It involves synchronizing — coordinating across institutional
                                                    boundaries; harmonizing — ensuring that risk managers all
                                                    speak the same language and define risk in the same manner;
                                                    and rationalizing — eliminating duplication of effort.

                                                    Use tools like The Risk Intelligence Map™1 to facilitate your
                                                    discussions; it may get you thinking and talking about risk in
                                                    ways you never envisioned. Draw upon your risk framework
                                                    to help standardize your approach. Develop a risk catalog to
                                                    inventory your most critical risks.

                                                    Common technology, metrics, processes, and terminology will
                                                    transcend your siloed subculture.




                 Principle #4: In a Risk Intelligent Enterprise, a
                 common risk management infrastructure is used
                 to support the business units and functions in the
                 performance of their risk responsibilities.




1
For information on Deloitte’s Risk Intelligence Map, contact your Deloitte practitioner. See page 13.
The mushroom treatment

Some boards of directors are subjected to “The
Mushroom Treatment,” an approach that is summarized,
in abridged form, below:

           “Keep ‘em in the dark ...”


Such treatment should obviously be avoided. In the U.S., boards
have a fiduciary responsibility to ensure that management has
appropriate processes in place to manage risk. This duty cannot
be executed in the absence of light.

To fulfill their responsibilities and to provide value, board
members should:

• Put risk on the agenda. Make time for risk before risk demands
  it. Every board meeting is not too often to discuss risk.

• Inventory the current risk structure. How are risks managed?
  Are silos being bridged?

• Summon the management team. Engage in periodic risk
  dialogue. Identify risks that will prevent the organization from
  executing on its key strategies.

• Discuss risk scenarios. Where do the greatest opportunities lie?
  What could thwart the organization’s strategic objectives?

• Check organizational appetite — and diet. Determine how
  much risk the organization is able to take on. How much is it
  willing to take on? And how much is it actually taking on? Are
  these in line?

• Get reasonable assurance. Ask management: How confident
  are you? Why?

• Get independent reassurance. Have internal audit or an
  outside consultant evaluate the effectiveness of the full risk
  management program. Can management’s assurances be
  relied upon?



Principle #5: In a Risk Intelligent Enterprise,
governing bodies (e.g., boards, audit committees,
etc.) have appropriate transparency and visibility
into the organization’s risk management practices
to discharge their responsibilities
“We manage risk every Friday”

                      Don’t laugh — that’s an actual quote from a real business executive.
                      And here’s the sobering reality: If you treat risk management as a
                      part-time job, you might soon find yourself looking for one.




  nage
                      We noted earlier that everyone has responsibility for risk. But



Ma k
                      if you’re a member of the executive team, this obligation is
                      ratcheted even higher. You are tasked with tone, direction,
                      design, and metrics.



 Ris
                      Inherent in your executive role is leadership and authority. And
                      you need to exercise it: To get people thinking about risk taking
                      for reward. To push risk management through all the layers of
                      the organization. To set expectations. To ensure accountability.
                      To engage the board. To drive change. To establish a Risk
                      Intelligent culture.

                      An ambitious agenda, to be sure. How can you get it all done?
                      Here’s a good place to start: Form a Risk Intelligence group — an
                      executive-level risk committee — to bring better risk insights to your
                      management team and help create a Risk Intelligence program.

                      In some organizations, a key member of this executive-level Risk
                      Intelligence group is the chief risk officer. Sitting at the table with
                      other top executives, the CRO helps develop policy and common
                      approaches that are rolled out to business units; communicates
                      and monitors the organization’s risk appetite; and reports risk
                      information to the management and board-level oversight
                      functions. Some organizations may choose a more expansive role.
                      The style of the CRO varies considerably and needs to match that
                      of the organization and its risk philosophy. Some may choose a
                      business partner, some a facilitator, some a traffic cop.

                      Whatever the role, you can be sure: None of them work only
                      on Fridays.




         Principle #6: In a Risk Intelligent Enterprise,
         executive management is charged with primary
         responsibility for designing, implementing, and
         maintaining an effective risk program.
Risk lives here

OK, so everyone’s responsible for risk. But who “owns” it? In
our view, the business units hold the title and deed.

The ownership question causes plenty of confusion throughout
organizations, so it might be helpful to state it in simple terms:

If you own the business unit, you own the risk.

In other words, if you are accountable for the success of a
business unit, you have primary responsibility for the day-to-
day management of the risks associated with that unit. (Of
course, this does not absolve other members of the business
unit from carrying out their risk-related responsibilities.)

What does ownership entail? Among other things, risk owners
have the responsibility to identify, measure, monitor, control, and
report on risks to executive management; promote risk awareness;
and reprioritize activities as dictated by effective risk analyses.

Yet, just as a property owner must abide by municipal zoning
regulations, business unit managers must operate under
certain constraints. For example, they don’t choose the
framework — they live within it. They don’t determine the
organization’s risk appetite — they stick to the diet. And they
don’t unilaterally “bet the farm” — they tend to the crops.
In fact, if they can place that bet without oversight or limits,
you’ve got a serious risk infrastructure issue.




                                               Principle #7: In a Risk Intelligent Enterprise,
                                               business units (departments, agencies, etc.) are
                                               responsible for the performance of their business and
                                               the management of risks they take within the risk
                                               framework established by executive management.
The risk support system

                                             Certain functions, including finance, legal, HR, tax, and IT,
                                             differ from the business units in that they don’t just own risk
                                             management — they also help support it. The role of these
                                             functions is inherently different than either that of the risk
                                             “comforters” (described on the next page) or the business
                                             units (discussed on the previous page).

                                             Like the business units, these functions bear primary
                                             responsibility for the risks that originate within their operations.
                                             For example, finance takes the lead on Sarbanes-Oxley-related
                                             risk, IT on technology-related risk, legal on litigation risk, and
                                             HR on talent and human resource risks.

                                             At the same time, they also have risk responsibilities that
                                             transcend their functions. For example, finance, through its
                                             Sarbanes-Oxley role, may have a broad and sophisticated risk
                                             assessment capability that can be leveraged. Meanwhile, IT
                                             is pervasive and thus can play a role in helping other parts
                                             of the business monitor and mitigate their risks. HR may use
                                             employee engagement surveys, exit interview results, and other
                                             information to identify risk areas of emerging concern.

                                             These ubiquitous functions are responsible for developing and
                                             enforcing company-wide policies, procedures, and controls that
                                             help mitigate risk. They support each business unit and help
                                             them understand their requirements for intelligent risk taking
                                             for reward. They collect key information for management and
                                             perform risk mitigation analyses.

                                             It is important that these key functions join the risk team
                                             by having articulated roles in the risk framework and by
                                             participating in risk committees and other key risk forums.




Principle #8: In a Risk Intelligent Enterprise, certain
functions (e.g., finance, legal, IT, HR, etc.) have a
pervasive impact on the business and provide support
to the business units as it relates to the organization’s
risk program.
The comforters

When it comes to risk management, certain groups carry a unique         • Champion: advocating for resources related to risk-taking
mandate — namely, the internal audit, compliance, and risk                for reward: addressing those risks associated with increasing
management functions. One might describe “comfort” as one                 profitability and increasing shareholder value.
major responsibility of these functions: to provide reassurance that    • Advocate: drawing attention to and advocating for resources
the internal control and risk structure operates effectively (thereby     to address risk areas deemed insufficiently covered.
helping the executive team and board members sleep at night).
                                                                        • Subject matter resource: providing deep knowledge and
This role sets them apart from every other entity within the              expertise in key risk areas, such as fraud.
organization. These comfort groups are not operational in               • Troubleshooter: getting involved in control remediation and
nature: They have no responsibility for setting and directing             design; helping to conduct and interpret risk assessments.
the operations of the business. Rather, they exist to monitor
and enhance the effectiveness of the organization’s risk
management activities.

Of course, specific roles and responsibilities vary from one
organization to another. Some groups do far more than
provide reassurance; others are more proscribed in their
activities. Potential roles that expand the job description
include the following:

• Visionary: assessing not only the current state of risk
  management, but peering ahead to help management divine
  future risks and opportunities.
• Dietician: determining whether the organization’s risk diet
  matches its appetite.
• Aggregator: ascertaining whether the organization is
  appropriately considering how risks interact and cascade.
• Efficiency expert: investigating means to eliminate
  inefficiencies in risk management.




                                                Principle #9: In a Risk Intelligent Enterprise, certain
                                                functions (e.g., internal audit, risk management,
                                                compliance, etc.) provide objective assurance as
                                                well as monitor and report on the effectiveness of an
                                                organization’s risk program to governing bodies and
                                                executive management.



0
Be risk intelligent

In the recent past, finance and energy industries have been
perceived as paragons of sophisticated risk management.
Then the subprime crisis swept billions from corporate balance
sheets and Katrina knocked platforms and derricks offline in
the Gulf.

Books have been written on what went wrong. But here’s a
quick summary:

1) The potential interaction of multiple risks was
   underestimated or disregarded.
2) Probabilistic modeling was overemphasized; shortcuts were
   taken; scenario planning was underutilized; transparency
   into potential issues was absent.
3) Risk managers were isolated in silos.
4) Warnings were ignored; those who delivered them were
   dismissed as naysayers or criticized for not being team
   players.
5) A short-term perspective with a single-minded focus on
   making the quarterly numbers predominated.
6) Companies lacked a comprehensive approach to firm-wide
   risk management; authority and responsibility were poorly
   controlled and defined.
7) Risk management often focused on compliance rather
   than performance, leading to inadequate assessments
   and responses.

All were significant breakdowns, to be sure, yet it would be
an even greater failure if companies responded by turning
risk averse. Risk taking for reward is a fundamental precept
of capitalism and should be encouraged. But the pursuit of
organizational success must be handled skillfully.

In other words: It’s time to become Risk Intelligent.
Nine fundamental principles of a
Risk Intelligence program
1. In a Risk Intelligent Enterprise, a common definition of risk, which
   addresses both value preservation and value creation, is used consistently
   throughout the organization.
2. In a Risk Intelligent Enterprise, a common risk framework supported by
   appropriate standards is used throughout the organization to manage risks.
3. In a Risk Intelligent Enterprise, key roles, responsibilities, and authority
   relating to risk management are clearly defined and delineated within the
   organization.
4. In a Risk Intelligent Enterprise, a common risk management infrastructure
   is used to support the business units and functions in the performance of
   their risk responsibilities.
5. In a Risk Intelligent Enterprise, governing bodies (e.g., Boards, Audit
   Committees, etc.) have appropriate transparency and visibility into the
   organization’s risk management practices to discharge their responsibilities.
6. In a Risk Intelligent Enterprise, executive management is charged with
   primary responsibility for designing, implementing, and maintaining an
   effective risk program.
7. In a Risk Intelligent Enterprise, business units (departments, agencies, etc.)
   are responsible for the performance of their business and the management
   of risks they take within the risk framework established by executive
   management.
8. In a Risk Intelligent Enterprise, certain functions (e.g., Finance, Legal, IT,
   HR, etc.) have a pervasive impact on the business and provide support to the
   business units as it relates to the organization’s risk program.
9. In a Risk Intelligent Enterprise, certain functions (e.g., internal audit, risk
   management, compliance, etc.) provide objective assurance as well as monitor
   and report on the effectiveness of an organization’s risk program to governing
   bodies and executive management.
U.S. Contacts:
National Contacts:                                                                             Regional Contacts:


Henry Ristuccia                            Eric Hespenheide                                    Mid-America
U.S. Leader                                Partner                                             Bill Kacal
Governance  Risk Management               Global Leader                                       Partner
Deloitte  Touche LLP                      Internal Audit Services                             Deloitte  Touche LLP
+1 212 436 4244                            Deloitte  Touche LLP                               +1 713 982 2517
hristuccia@deloitte.com                    +1 313 396 3163                                     bkacal@deloitte.com
                                           ehespenheide@deloitte.com

Scott Baret                                Ed Hida                                             Midwest
Partner                                    Partner                                             John Peirson
Deloitte  Touche LLP                      Global Leader                                       Partner
+1 212 436 5456                            Risk  Capital Management                           Deloitte  Touche LLP
sbaret@deloitte.com                        Deloitte  Touche LLP                               +1 612 397 4714
                                           +1 212 436 4854                                     jpeirson@deloitte.com
                                           ehida@deloitte.com

Donna Epps                                 Katy Hollister                                      North Central
Partner                                    Partner                                             Brad Carrier
Deloitte Financial Advisory Services LLP   Deloitte Tax LLP                                    Partner
+1 214 840 7363                            +1 513 784 7283                                     Deloitte  Touche LLP
depps@deloitte.com                         khollister@deloitte.com                             +1 313 396 2775
                                                                                               bcarrier@deloitte.com

Michael Fuchs                              Michael Kearney                                     Northeast
Principal                                  Partner                                             Henry Ristuccia
Deloitte Consulting LLP                    Assurance and Enterprise Risk Services Innovation   Partner
+1 212 618 4370                            Deloitte  Touche LLP                               Deloitte  Touche LLP
mfuchs@deloitte.com                        +1 510 817 2185                                     +1 212 436 4244
                                           mkearney@deloitte.com                               hristuccia@deloitte.com

Bob Hansen                                 Chris Lee                                           Northern Pacific and Hawaii
Principal                                  National Managing Partner                           Ed Byers
Global Leader                              Security  Privacy Services                         Principal
Control Assurance Services                 Deloitte  Touche LLP                               Deloitte  Touche LLP
Deloitte  Touche LLP                      +1 408 704 4314                                     +1 415 783 4402
+1 203 708 4256                            chrislee@deloitte.com                               ebyers@deloitte.com
bohansen@deloitte.com
                                           Owen Ryan                                           Pacific Southwest
                                           Partner                                             Darrin Kelley
                                           Deloitte  Touche LLP                               Partner
                                           +1 212 436 3992                                     Deloitte  Touche LLP
                                           oryan@deloitte.com                                  +1 213 688 5420
                                                                                               darkelley@deloitte.com

                                           Steve Wagner                                        Southeast
                                           Managing Partner                                    Larry Ishol
                                           U.S. Center for Corporate Governance                Partner
                                           Deloitte  Touche LLP                               Deloitte  Touche LLP
                                           +1 617 437 2200                                     +1 202 220 2970
                                           swagner@deloitte.com                                lishol@deloitte.com
International Contacts:
Mark Layton
Global Leader
Governance  Risk Management
Deloitte  Touche LLP
+1 214 840 7979
mlayton@deloitte.com


AMERICAS                                ASIA PACIFIC                               EMEA

Canada                                  China                                      Belgium
Eddie Leschiutta                        Danny Lau                                  Stephan Raemaekers
Partner, Enterprise Risk Services       Partner , Enterprise Risk Services         Managing Partner
Deloitte Canada                         Deloitte China                             Deloitte Belgium
+1 416 601 5841                         +852 2852 1015                             +32 2 749 5921
eleschiutta@deloitte.ca                 danlau@deloitte.com.hk                     sraemaekers@deloitte.be

Mexico                                  Commonwealth of Independent States (CIS)   France
Walter Fraschetto                       Wayne G. Brandt                            Damien Leurent
Partner                                 Partner                                    Partner
Deloitte México                         Deloitte CIS                               Deloitte France
+52 55 5080 6265                        +7 495 787 0600 x2922                      +33 1 4088 2969
wfraschetto@deloittemx.com              waybrandt@deloitte.ru                      dleurent@deloitte.fr

United States                           India                                      Germany
Henry Ristuccia                         Abhay Gupte                                Joerg Engels
Partner                                 Partner                                    Partner
Deloitte  Touche LLP – United States   Deloitte India                             Deloitte Germany
+1 212 436 4244                         +91 22 6681 0600                           +49 211 8772 2376
hristuccia@deloitte.com                 agupte@deloitte.com                        jengels@deloitte.de

                                        Japan                                      Italy
                                        Masahiko Sugiyama                          Carlo Peschiera
                                        Partner, Enterprise Risk Services          Partner
                                        Deloitte Japan                             Deloitte Italy
                                        +81 3 4218 7283                            +39 05 1658 1863
                                        msugiyama@deloitte.com                     cpeschiera@deloitte.it

                                        Singapore                                  Netherlands
                                        Uantchern Loh                              Wim Eysink
                                        Partner, Enterprise Risk Services          Partner, Enterprise Risk Services
                                        Deloitte Singapore                         Deloitte Netherlands
                                        +65 6216 3282                              +31 65 141 7099
                                        uloh@deloitte.com                          weysink@deloitte.nl

                                                                                   Spain
                                                                                   Alfonso Mur
                                                                                   Partner
                                                                                   Deloitte Spain
                                                                                   + 349 1 514 5000 x2103
                                                                                   amur@deloitte.es

                                                                                   United Kingdom
                                                                                   Graham Richardson
                                                                                   Partner
                                                                                   Deloitte United Kingdom
                                                                                   +44 20 7007 3349
                                                                                   grrichardson@deloitte.co.uk
#8224




About Deloitte

As used in this document, “Deloitte” means Deloitte LLP and its subsidiaries. Please see www.deloitte.com/us/about for
a detailed description of the legal structure of Deloitte LLP and its subsidiaries

                                                                                                                         Member of
Copyright © 2008 Deloitte Development LLC. All rights reserved.                                                          Deloitte Touche Tohmatsu

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Risk Consulting-Putting Risk In The Comfort Zone

  • 1. Putting risk in the comfort zone Nine principles for building the Risk Intelligent Enterprise TM
  • 2. Table of contents Preface 1 Uncomfortable risk 2 A framework is a coat rack 3 Symphonic risk management 4 Follow the same map 5 The mushroom treatment 6 “We manage risk every Friday” 7 Risk lives here 8 The risk support system 9 The comforters 10 Be risk intelligent 11 Nine principles 12 Contacts 13 Disclaimer These materials and the information contained herein are provided by Deloitte Touche Tohmatsu and are intended to provide general information on a particular subject or subjects and are not an exhaustive treatment of such subject(s). Accordingly, the information in these materials is not intended to constitute accounting, tax, legal, investment, consulting, or other professional advice or services. The information is not intended to be relied upon as the sole basis for any decision which may affect you or your business. Before making any decision or taking any action that might affect your personal finances or business, you should consult a qualified professional adviser. These materials and the information contained therein are provided as is, and Deloitte Touche Tohmatsu makes no express or implied representations or warranties regarding these materials or the information contained therein. Without limiting the foregoing, Deloitte Touche Tohmatsu does not warrant that the materials or information contained therein will be error-free or will meet any particular criteria of performance or quality. Deloitte Touche Tohmatsu expressly disclaims all implied warranties, including, without limitation, warranties of merchantability, title, fitness for a particular purpose, noninfringement, compatibility, security, and accuracy. Your use of these materials and information contained therein is at your own risk, and you assume full responsibility and risk of loss resulting from the use thereof. Deloitte Touche Tohmatsu will not be liable for any special, indirect, incidental, consequential, or punitive damages or any other damages whatsoever, whether in an action of contract, statute, tort (including, without limitation, negligence), or otherwise, relating to the use of these materials or the information contained therein. If any of the foregoing is not fully enforceable for any reason, the remainder shall nonetheless continue to apply.
  • 3. Preface The publication represents the first installment in Deloitte’s Although this paper is the first in our “Fundamental series on the fundamental principles of Risk Intelligence. Principles” series, it is by no means our initial words on The papers in the series are intended to offer plain- the subject of Risk Intelligence. In fact, we’ve published English descriptions of the foundational elements of a Risk over a dozen related titles as well as numerous podcasts Intelligence program, as well as insights and practical steps and webcasts. You may access all of this material free of you may consider for incorporating the concepts within your charge at www.deloitte.com/RiskIntelligence. own organization. Open communication is a key characteristic of a Risk On each of the following pages, you will find a statement Intelligent Enterprise. Consider sharing this whitepaper describing a single principle of a Risk Intelligence program, with the other executives, board members, and key along with an elaboration on the topic. In aggregate, we managers in your organization. The issues and concepts believe application of these principles will help create what we outlined herein should provide an excellent starting point consider the epitome of enlightened risk management: The for a crucial dialogue on enhancing your organization’s Risk Intelligent Enterprise. Risk Intelligence. Keep in mind that the application of these principles will differ based on your industry practices, regulatory schema, and organizational maturity. For example, in the financial services and energy industries, many of these principles have been discussed for over a decade and thus may seem elementary; but for many other industries, we see these principles just starting to be embraced. Regardless of what industry you are in, the Fundamental Principles still apply.
  • 4. Uncomfortable risk Like politics and religion, risk can be an uncomfortable topic of conversation. Understandably so, because many people unintentionally limit the parameters of the discussion. You probably think of risk in terms of threats — bad things happening to your business. Not a pleasant subject of conversation. But the discussion can flow freely if you consider the other side of risk, the one that applies to value creation — risk taking for reward. Introducing new products; entering foreign markets; acquiring competitors — all are challenging endeavors, and if you don’t properly manage the associated risks, you may not reap the potential rewards. So consider adopting a more expansive definition of risk, one that gives equal weight to managing the risks related to growth and profitability: Risk is the potential for loss or harm — or the diminished opportunity for gain — that can adversely affect the achievement of an organization’s objectives. Principle #1: In a Risk Intelligent Enterprise, a common definition of risk, which addresses both value preservation and value creation, is used consistently throughout the organization.
  • 5. A framework is a coat rack When it comes to keeping your parka off the parquet or your cape off the carpet, the solution may seem deceptively simple: All you need is a hook. But what’s holding up that hook? In fact, the support structure will vary, depending on whether you’re hanging heavy winter gear or gauzy summer fashions. It might be helpful to think of your risk management framework in the same manner: something to hang your risk management program on. A risk framework — such as COSO ERM, Turnbull, and ISO — provides a structure that helps you decide which opportunities to pursue and which hazards to avoid. But the framework must be sturdy enough to support your risk management objectives. It must accommodate your unique strategies, initiatives, and organizational structure. And it must be adaptable to your industry and regulatory requirements. There’s no need to overanalyze. Don’t get snagged on the selection of your risk framework. Just make sure it’s something you can hang your hat on. Principle #2: In a Risk Intelligent Enterprise, a common risk framework supported by appropriate standards is used throughout the organization to manage risks.
  • 6. Symphonic risk management Done right, risk management is a coordinated effort, as finely tuned as a symphony orchestra. In both risk and music, multiple roles are played simultaneously in often complex arrangements. Of course, some people in your organization may not even realize they are part of the band. Your product development manager, IT supervisor, or deputy vice president responsible for MA probably considers risk management somebody else’s job. Changing that mindset is a precursor to promoting Risk Intelligence in your organization. You’ll need clear messaging at the individual level to convey what Risk Intelligence means; why it is important to the organization collectively and to employees individually; and what your people actually need to do on a daily basis. This effort requires clear communications; a strong risk- focused culture; reward programs that incorporate risk-related objectives; and learning programs to promote intelligent risk management. In sum, it’s needs to be a harmonious collaboration. Here’s what the score looks like: • The board sets the tone (see page 6). • The executive wields the baton (page 7). • The business units play the music (page 8). • Certain functions (HR, finance, IT, legal, tax) support the concert backstage (page 9). • Other functions (internal audit, risk, and compliance) monitor the performance (page 10). Principle #3: In a Risk Intelligent Enterprise, key roles, responsibilities, and authority relating to risk management are clearly defined and delineated within the organization.
  • 7. Follow the same map Risk specialists tend to behave like any subculture: They stick together. They share similar beliefs, rituals, and habits. They develop their own dialect. But practices that sustain, say, an indigenous people may not be ideally suited to the risk managers of a multinational corporation. Not to say that specialization is unnecessary. Quite the contrary: effective risk management would not be possible without it. Rather, risk specialists just need to poke their heads outside their silos once in a while. Risk doesn’t exist in isolation, so risk managers can’t either. To effectively and efficiently manage risks and reap the rewards, organizational silos must be bridged. The bridging process means creating a common infrastructure; it means that all the business units and functions use the same supporting technologies and processes where possible and practicable. It involves synchronizing — coordinating across institutional boundaries; harmonizing — ensuring that risk managers all speak the same language and define risk in the same manner; and rationalizing — eliminating duplication of effort. Use tools like The Risk Intelligence Map™1 to facilitate your discussions; it may get you thinking and talking about risk in ways you never envisioned. Draw upon your risk framework to help standardize your approach. Develop a risk catalog to inventory your most critical risks. Common technology, metrics, processes, and terminology will transcend your siloed subculture. Principle #4: In a Risk Intelligent Enterprise, a common risk management infrastructure is used to support the business units and functions in the performance of their risk responsibilities. 1 For information on Deloitte’s Risk Intelligence Map, contact your Deloitte practitioner. See page 13.
  • 8. The mushroom treatment Some boards of directors are subjected to “The Mushroom Treatment,” an approach that is summarized, in abridged form, below: “Keep ‘em in the dark ...” Such treatment should obviously be avoided. In the U.S., boards have a fiduciary responsibility to ensure that management has appropriate processes in place to manage risk. This duty cannot be executed in the absence of light. To fulfill their responsibilities and to provide value, board members should: • Put risk on the agenda. Make time for risk before risk demands it. Every board meeting is not too often to discuss risk. • Inventory the current risk structure. How are risks managed? Are silos being bridged? • Summon the management team. Engage in periodic risk dialogue. Identify risks that will prevent the organization from executing on its key strategies. • Discuss risk scenarios. Where do the greatest opportunities lie? What could thwart the organization’s strategic objectives? • Check organizational appetite — and diet. Determine how much risk the organization is able to take on. How much is it willing to take on? And how much is it actually taking on? Are these in line? • Get reasonable assurance. Ask management: How confident are you? Why? • Get independent reassurance. Have internal audit or an outside consultant evaluate the effectiveness of the full risk management program. Can management’s assurances be relied upon? Principle #5: In a Risk Intelligent Enterprise, governing bodies (e.g., boards, audit committees, etc.) have appropriate transparency and visibility into the organization’s risk management practices to discharge their responsibilities
  • 9. “We manage risk every Friday” Don’t laugh — that’s an actual quote from a real business executive. And here’s the sobering reality: If you treat risk management as a part-time job, you might soon find yourself looking for one. nage We noted earlier that everyone has responsibility for risk. But Ma k if you’re a member of the executive team, this obligation is ratcheted even higher. You are tasked with tone, direction, design, and metrics. Ris Inherent in your executive role is leadership and authority. And you need to exercise it: To get people thinking about risk taking for reward. To push risk management through all the layers of the organization. To set expectations. To ensure accountability. To engage the board. To drive change. To establish a Risk Intelligent culture. An ambitious agenda, to be sure. How can you get it all done? Here’s a good place to start: Form a Risk Intelligence group — an executive-level risk committee — to bring better risk insights to your management team and help create a Risk Intelligence program. In some organizations, a key member of this executive-level Risk Intelligence group is the chief risk officer. Sitting at the table with other top executives, the CRO helps develop policy and common approaches that are rolled out to business units; communicates and monitors the organization’s risk appetite; and reports risk information to the management and board-level oversight functions. Some organizations may choose a more expansive role. The style of the CRO varies considerably and needs to match that of the organization and its risk philosophy. Some may choose a business partner, some a facilitator, some a traffic cop. Whatever the role, you can be sure: None of them work only on Fridays. Principle #6: In a Risk Intelligent Enterprise, executive management is charged with primary responsibility for designing, implementing, and maintaining an effective risk program.
  • 10. Risk lives here OK, so everyone’s responsible for risk. But who “owns” it? In our view, the business units hold the title and deed. The ownership question causes plenty of confusion throughout organizations, so it might be helpful to state it in simple terms: If you own the business unit, you own the risk. In other words, if you are accountable for the success of a business unit, you have primary responsibility for the day-to- day management of the risks associated with that unit. (Of course, this does not absolve other members of the business unit from carrying out their risk-related responsibilities.) What does ownership entail? Among other things, risk owners have the responsibility to identify, measure, monitor, control, and report on risks to executive management; promote risk awareness; and reprioritize activities as dictated by effective risk analyses. Yet, just as a property owner must abide by municipal zoning regulations, business unit managers must operate under certain constraints. For example, they don’t choose the framework — they live within it. They don’t determine the organization’s risk appetite — they stick to the diet. And they don’t unilaterally “bet the farm” — they tend to the crops. In fact, if they can place that bet without oversight or limits, you’ve got a serious risk infrastructure issue. Principle #7: In a Risk Intelligent Enterprise, business units (departments, agencies, etc.) are responsible for the performance of their business and the management of risks they take within the risk framework established by executive management.
  • 11. The risk support system Certain functions, including finance, legal, HR, tax, and IT, differ from the business units in that they don’t just own risk management — they also help support it. The role of these functions is inherently different than either that of the risk “comforters” (described on the next page) or the business units (discussed on the previous page). Like the business units, these functions bear primary responsibility for the risks that originate within their operations. For example, finance takes the lead on Sarbanes-Oxley-related risk, IT on technology-related risk, legal on litigation risk, and HR on talent and human resource risks. At the same time, they also have risk responsibilities that transcend their functions. For example, finance, through its Sarbanes-Oxley role, may have a broad and sophisticated risk assessment capability that can be leveraged. Meanwhile, IT is pervasive and thus can play a role in helping other parts of the business monitor and mitigate their risks. HR may use employee engagement surveys, exit interview results, and other information to identify risk areas of emerging concern. These ubiquitous functions are responsible for developing and enforcing company-wide policies, procedures, and controls that help mitigate risk. They support each business unit and help them understand their requirements for intelligent risk taking for reward. They collect key information for management and perform risk mitigation analyses. It is important that these key functions join the risk team by having articulated roles in the risk framework and by participating in risk committees and other key risk forums. Principle #8: In a Risk Intelligent Enterprise, certain functions (e.g., finance, legal, IT, HR, etc.) have a pervasive impact on the business and provide support to the business units as it relates to the organization’s risk program.
  • 12. The comforters When it comes to risk management, certain groups carry a unique • Champion: advocating for resources related to risk-taking mandate — namely, the internal audit, compliance, and risk for reward: addressing those risks associated with increasing management functions. One might describe “comfort” as one profitability and increasing shareholder value. major responsibility of these functions: to provide reassurance that • Advocate: drawing attention to and advocating for resources the internal control and risk structure operates effectively (thereby to address risk areas deemed insufficiently covered. helping the executive team and board members sleep at night). • Subject matter resource: providing deep knowledge and This role sets them apart from every other entity within the expertise in key risk areas, such as fraud. organization. These comfort groups are not operational in • Troubleshooter: getting involved in control remediation and nature: They have no responsibility for setting and directing design; helping to conduct and interpret risk assessments. the operations of the business. Rather, they exist to monitor and enhance the effectiveness of the organization’s risk management activities. Of course, specific roles and responsibilities vary from one organization to another. Some groups do far more than provide reassurance; others are more proscribed in their activities. Potential roles that expand the job description include the following: • Visionary: assessing not only the current state of risk management, but peering ahead to help management divine future risks and opportunities. • Dietician: determining whether the organization’s risk diet matches its appetite. • Aggregator: ascertaining whether the organization is appropriately considering how risks interact and cascade. • Efficiency expert: investigating means to eliminate inefficiencies in risk management. Principle #9: In a Risk Intelligent Enterprise, certain functions (e.g., internal audit, risk management, compliance, etc.) provide objective assurance as well as monitor and report on the effectiveness of an organization’s risk program to governing bodies and executive management. 0
  • 13. Be risk intelligent In the recent past, finance and energy industries have been perceived as paragons of sophisticated risk management. Then the subprime crisis swept billions from corporate balance sheets and Katrina knocked platforms and derricks offline in the Gulf. Books have been written on what went wrong. But here’s a quick summary: 1) The potential interaction of multiple risks was underestimated or disregarded. 2) Probabilistic modeling was overemphasized; shortcuts were taken; scenario planning was underutilized; transparency into potential issues was absent. 3) Risk managers were isolated in silos. 4) Warnings were ignored; those who delivered them were dismissed as naysayers or criticized for not being team players. 5) A short-term perspective with a single-minded focus on making the quarterly numbers predominated. 6) Companies lacked a comprehensive approach to firm-wide risk management; authority and responsibility were poorly controlled and defined. 7) Risk management often focused on compliance rather than performance, leading to inadequate assessments and responses. All were significant breakdowns, to be sure, yet it would be an even greater failure if companies responded by turning risk averse. Risk taking for reward is a fundamental precept of capitalism and should be encouraged. But the pursuit of organizational success must be handled skillfully. In other words: It’s time to become Risk Intelligent.
  • 14. Nine fundamental principles of a Risk Intelligence program 1. In a Risk Intelligent Enterprise, a common definition of risk, which addresses both value preservation and value creation, is used consistently throughout the organization. 2. In a Risk Intelligent Enterprise, a common risk framework supported by appropriate standards is used throughout the organization to manage risks. 3. In a Risk Intelligent Enterprise, key roles, responsibilities, and authority relating to risk management are clearly defined and delineated within the organization. 4. In a Risk Intelligent Enterprise, a common risk management infrastructure is used to support the business units and functions in the performance of their risk responsibilities. 5. In a Risk Intelligent Enterprise, governing bodies (e.g., Boards, Audit Committees, etc.) have appropriate transparency and visibility into the organization’s risk management practices to discharge their responsibilities. 6. In a Risk Intelligent Enterprise, executive management is charged with primary responsibility for designing, implementing, and maintaining an effective risk program. 7. In a Risk Intelligent Enterprise, business units (departments, agencies, etc.) are responsible for the performance of their business and the management of risks they take within the risk framework established by executive management. 8. In a Risk Intelligent Enterprise, certain functions (e.g., Finance, Legal, IT, HR, etc.) have a pervasive impact on the business and provide support to the business units as it relates to the organization’s risk program. 9. In a Risk Intelligent Enterprise, certain functions (e.g., internal audit, risk management, compliance, etc.) provide objective assurance as well as monitor and report on the effectiveness of an organization’s risk program to governing bodies and executive management.
  • 15. U.S. Contacts: National Contacts: Regional Contacts: Henry Ristuccia Eric Hespenheide Mid-America U.S. Leader Partner Bill Kacal Governance Risk Management Global Leader Partner Deloitte Touche LLP Internal Audit Services Deloitte Touche LLP +1 212 436 4244 Deloitte Touche LLP +1 713 982 2517 hristuccia@deloitte.com +1 313 396 3163 bkacal@deloitte.com ehespenheide@deloitte.com Scott Baret Ed Hida Midwest Partner Partner John Peirson Deloitte Touche LLP Global Leader Partner +1 212 436 5456 Risk Capital Management Deloitte Touche LLP sbaret@deloitte.com Deloitte Touche LLP +1 612 397 4714 +1 212 436 4854 jpeirson@deloitte.com ehida@deloitte.com Donna Epps Katy Hollister North Central Partner Partner Brad Carrier Deloitte Financial Advisory Services LLP Deloitte Tax LLP Partner +1 214 840 7363 +1 513 784 7283 Deloitte Touche LLP depps@deloitte.com khollister@deloitte.com +1 313 396 2775 bcarrier@deloitte.com Michael Fuchs Michael Kearney Northeast Principal Partner Henry Ristuccia Deloitte Consulting LLP Assurance and Enterprise Risk Services Innovation Partner +1 212 618 4370 Deloitte Touche LLP Deloitte Touche LLP mfuchs@deloitte.com +1 510 817 2185 +1 212 436 4244 mkearney@deloitte.com hristuccia@deloitte.com Bob Hansen Chris Lee Northern Pacific and Hawaii Principal National Managing Partner Ed Byers Global Leader Security Privacy Services Principal Control Assurance Services Deloitte Touche LLP Deloitte Touche LLP Deloitte Touche LLP +1 408 704 4314 +1 415 783 4402 +1 203 708 4256 chrislee@deloitte.com ebyers@deloitte.com bohansen@deloitte.com Owen Ryan Pacific Southwest Partner Darrin Kelley Deloitte Touche LLP Partner +1 212 436 3992 Deloitte Touche LLP oryan@deloitte.com +1 213 688 5420 darkelley@deloitte.com Steve Wagner Southeast Managing Partner Larry Ishol U.S. Center for Corporate Governance Partner Deloitte Touche LLP Deloitte Touche LLP +1 617 437 2200 +1 202 220 2970 swagner@deloitte.com lishol@deloitte.com
  • 16. International Contacts: Mark Layton Global Leader Governance Risk Management Deloitte Touche LLP +1 214 840 7979 mlayton@deloitte.com AMERICAS ASIA PACIFIC EMEA Canada China Belgium Eddie Leschiutta Danny Lau Stephan Raemaekers Partner, Enterprise Risk Services Partner , Enterprise Risk Services Managing Partner Deloitte Canada Deloitte China Deloitte Belgium +1 416 601 5841 +852 2852 1015 +32 2 749 5921 eleschiutta@deloitte.ca danlau@deloitte.com.hk sraemaekers@deloitte.be Mexico Commonwealth of Independent States (CIS) France Walter Fraschetto Wayne G. Brandt Damien Leurent Partner Partner Partner Deloitte México Deloitte CIS Deloitte France +52 55 5080 6265 +7 495 787 0600 x2922 +33 1 4088 2969 wfraschetto@deloittemx.com waybrandt@deloitte.ru dleurent@deloitte.fr United States India Germany Henry Ristuccia Abhay Gupte Joerg Engels Partner Partner Partner Deloitte Touche LLP – United States Deloitte India Deloitte Germany +1 212 436 4244 +91 22 6681 0600 +49 211 8772 2376 hristuccia@deloitte.com agupte@deloitte.com jengels@deloitte.de Japan Italy Masahiko Sugiyama Carlo Peschiera Partner, Enterprise Risk Services Partner Deloitte Japan Deloitte Italy +81 3 4218 7283 +39 05 1658 1863 msugiyama@deloitte.com cpeschiera@deloitte.it Singapore Netherlands Uantchern Loh Wim Eysink Partner, Enterprise Risk Services Partner, Enterprise Risk Services Deloitte Singapore Deloitte Netherlands +65 6216 3282 +31 65 141 7099 uloh@deloitte.com weysink@deloitte.nl Spain Alfonso Mur Partner Deloitte Spain + 349 1 514 5000 x2103 amur@deloitte.es United Kingdom Graham Richardson Partner Deloitte United Kingdom +44 20 7007 3349 grrichardson@deloitte.co.uk
  • 17. #8224 About Deloitte As used in this document, “Deloitte” means Deloitte LLP and its subsidiaries. Please see www.deloitte.com/us/about for a detailed description of the legal structure of Deloitte LLP and its subsidiaries Member of Copyright © 2008 Deloitte Development LLC. All rights reserved. Deloitte Touche Tohmatsu