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Emerging Market Risk: Leaders, Laggards and Rules for Avoiding Loss

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When the developed world’s economies ground to a halt during the Great Recession of 2009, large, Western-based multinational companies turned their growth-hungry eyes toward developing markets. The slow recovery that followed the recession in the U.S. and Europe did little to change this trend. In fact, according to the United Nations Conference on Trade and Development (UNCTAD), foreign direct investment in emerging markets reached a new high in 2013 of $759 billion (the most recent year for which data is available). This represented more than half the world’s estimated $1.46 trillion total outward investment flows for that year. Given this intense interest in doing business in emerging markets, FTI Consulting, a global professional services firm, conducted a survey in November and December 2014 on the character of the risks businesses face in these markets and how they attempt to mitigate them.

FTI surveyed 150 companies with revenues of more than $1 billion and business interests in developing economies, as well as interviews with 32 executives focused on compliance and risk management from those companies. Our results indicated an enormous difference between leaders (defined as companies whose self-reported losses as a percentage of revenues was in the lowest quartile, averaging 0.2%) and laggards (those in the highest quartile, with a loss rate averaging 2.2% of revenues), not only in the ways they managed overseas risk, but how they thought about it.

Quantifying Risk: The Numbers

According to our survey, 83% of multinational companies have suffered significant losses in emerging markets since 2010, with an average cost per company over that time of $1.38 billion, and the average loss per year $260 million, or 0.7% of revenues.

In virtually all loss-making incidents (99%), our respondents reported that the issue was either a matter of a regulatory violation, bribery or fraud, or reputational damage. In incidents with the highest losses, two or three of these types of risk converged: 60% of reported incidents involved more than one type, 35% involved two, and 25% were perfect storms that involved all three.

Regulatory issues are the most frequent cause of loss (either due to the difficulty of keeping up with ever-changing regulations or lax or inattentive corporate compliance policies), but legal and criminal issues (engaging in fraud or paying bribes) lead to the most expensive incidents. The most frequently cited consequences of getting caught were noted as reputational harm (67%), loss of revenues (56%), and prosecution (44%). In all cases, reputational issues invariably make matters worse.

These are serious issues, and some companies respond with equal seriousness. Some do not.

Leaders vs. Laggards: The Three Greatest Ways They Differ

According to our survey, there are enormous differences in the ways companies that have suffered the lowest rate of loss in emerging economies and companies that have experienced the highest approach risk mitigation in the three major categories. (See Figure 2.) From these differences, we have derived three rules that leaders follow to best mitigate overseas risk.

Rule 1: Walk Away From Countries Where Compliance is Impossible

Our leading companies believe it is more important to avoid doing business in jurisdictions where compliance may not be possible than do laggards by a ratio of more than 5:1. In other words, our leaders are willing to walk away, even when environments are hyped and offer the potential for quick profits. Globalized companies often overestimate their ability to estimate and analyze overseas risk accurately.

For instance, it is extraordinarily difficult to stay compliant with Brazil’s tax laws. According to Renato Niemeyer, Chief of Tax Legislation in Roraima State, each of Brazil’s 27 states has its own tax regulations “and the rules change all the time.” Neimeyer said this has led some companies to postpone paying taxes as the penalties for late payment are relatively low. However, when a company does pay the penalties, “corrupt officials will solicit the organization for bribes in order to lessen the penalties,” Neimeyer said. This, of course, is the proverbial slippery slope that can lead to both bribery and fraud prosecution and concomitant reputational damage – the perfect storm.

Latin America is also growing increasingly green in its politics, and environmental regulations are becoming problematic, especially in the energy, mining and construction sectors. Chevron vs. Ecuador, the nasty, ongoing, eight-year trial over liability concerning alleged environment damage, is an example of how damaging running afoul of environmental regulations can be.

When successful companies do attempt to do business in countries where it is difficult to comply with regulations, they invest time and energy into helping host countries develop more rational regulatory frameworks. Our leaders consider this kind engagement more important than do laggards by a ratio of almost 3:1.

Rule 2:  Keep to the Straight and Narrow

In most developed markets, it is understood that paying bribes to win or facilitate business is bad business and, if there were any doubt, the U.S. Foreign Corrupt Practices Act (FCPA) and U.

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K. Bribery Act remove them. But in many developing economies bribery is just how business gets done. In China, facilitation payments are customary to keep projects on target. The long-established Chinese custom of giving gifts to customers violates both the FCPA and U.K. Bribery Act. For our leading companies, the first rule for avoiding getting caught in the coils of bribery and corruption is to “conduct continuous dialogue with local staff on compliance issues.” Leaders rate that more important than do laggards by a ratio of nearly 7:1.

It is very difficult for local managers to resist making a facilitation payment when that’s the only way to get a pallet off a loading dock, or a critical part to a factory. That’s why companies that avoid getting in trouble make significant investments in internal communication and compliance training. They also go the extra mile when conducting due diligence on potential local partners and suppliers that may not have the same commitment to hewing to the straight and narrow as do their own organizations.

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Companies sometimes forget that the contractors their local managers hire, and the subcontractors the contractors hire, also need to be vetted and watched. Ted Unton, a former director of global financial compliance at Bemis Company, a U.S. global manufacturer, said his company has hired private investigators to look into partner companies and even partner executives.

Rule 3: Walking the Compliance Talk

Our respondents said that reputational damage – of the sort famously experienced by Walmart (accused of bribery in Mexico) and McDonald’s (accused of using tainted meat in China) – most often leads to loss of revenues, followed by exclusion from markets and even expropriation of assets. In our research, we found the greatest difference between how leaders and laggards approach mitigating reputational risk was how the regarded maintaining a good reputation over the long term. Leaders rate it more important than do laggards by an impressive ratio of 10:1.

This variance is mind-boggling when one considers that those companies that do not rate the importance of maintaining a good reputation highly have, by definition, suffered far greater losses than those that do.

Maintaining that good reputation is difficult as local populations are prone to regard multinational corporations as bad actors, and rich exploiters of resources and people – a belief often reinforced all-too willingly by the local press. It requires action and investment. One former president of an energy company operating in Bangladesh (who requested anonymity) told us his company, which had purchased land for a 40-mile pipeline, set up offices to help displaced farmers find jobs.

By demonstrating its concern for the community and by conveying that the company was involved for the long-term, planned protests were averted. (Indeed, many of the farmers were hired by the company and their living standards improved.) According to the former president, the company became seen as a benefactor, not a despoiler, and he believes that reputation will improve the company’s future business prospects.

Notably, laggards believe that running “preemptive publicity campaigns to counteract negative reactions” is a fine strategy. Leaders do not. That spread is one of the largest differences we’ve found.

Do It Right or Don’t Do It at All

As we’ve seen, multinational companies have suffered significant and severe losses in emerging markets. And the difference in the loss-rate as a percentage of revenue – 2.2% for the laggards; 0.2% for the leaders – is certainly wide. Developing risk management competence in the three major categories of risk defined by our survey not only helps to stem these losses, but builds a strong foundation for future profits.

It is bad to be a laggard. What’s more, it is unnecessary.

10 Tips to Excel in ERM

05a9ef2CHICAGO—For many risk managers looking to implement enterprise risk management programs, one of the biggest challenges is figuring out how to do it properly. Unfortunately, as Steve Zawoyski, ERM leader at PwC, pointed out in a session at this year’s RIMS ERM Conference, you will never find the perfect ERM program—it’s basically as mythical as a unicorn. But there are certain key steps you can take to increase your chances for a successful ERM program. Zawoyski’s top tips are:

  1. Establish ERM program objectives. One of the common stumbling blocks to a successful program is the lack of agreement as to why you are doing this in the first place. Some may be doing it in order to make better decisions around strategy while others have governance concerns in mind or are simply doing it because the board said so. Establishing proper objectives will allow you create the program that works best for your organization.
  2. Manage stakeholders. There are likely multiple parties that have a vested interest in your ERM efforts from the board to business managers to legal and audit to regulators.
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    You will need to consider all of their specific needs and concerns.

  3. Align risk functions. Risk management is part of every division’s responsibility. Getting everyone on the same page will avoid allowing fatigue to set in over yet another risk management effort.
  4. Align risk and management processes.
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    It is important to understand how the business is being managed and connect to those processes in order to be in a position share information up and down the organizational hierarchy.

  5. Define risk. The traditional definition of risk denotes a hazard or a failure of some process. Make sure you organization understands that risk is merely uncertainty that can have both a positive or negative impact on objectives. It is ok to take on risk.
  6. Give credit. Different functions already have risk management capabilities and processes. Rather than reinvent the wheel, harvest the data and expertise already out there and build off that. Don’t build unnecessary steps into the process when those areas are already being addressed.
  7. Remember that risk is a four-letter word. Risk is an overused, ambiguous word with an often negative connotation. Risks are nothing more than variables that can present opportunities for greater success.
  8. Beware of risk categories. Labels like operational, financial, strategic or technology are overemphasized and not how business units think of risk.
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    It is more effective to talk about risk in terms of management of hazards, compliance obligations or other uncertainties.

  9. Do your research. It is vital to develop a thorough understanding of the business and its drivers, from its capabilities to its competitive advantages to its strategic priorities and objectives.
  10. Simplify risk appetite. Risk appetite should be considered on a risk-by-risk basis and should boil down to a simple question of once risk controls and processes are in place, are you satisfied with the results?

ERM implementation can be challenging. But according to Zawoyski, it is all about keeping it simple for the stakeholders, ensuring that value is created, aligning to the business and evolving over time. By approaching your program in this way, all stakeholders will understand their role and how ERM relates to the overall strategy of the organization.

Risk Managers’ Role in Addressing Climate Change

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QUEBEC CITY, CANADA—Salutations de la ville de Québec! At the first day of this year’s RIMS Canada Conference, climate change quickly emerged as one of the key challenges facing risk managers—and an area with tremendous potential for risk professionals to effect change.

Government clearly has a role to play, but the slower pace and greater number of obstacles they face lessen some of the possible impact. According to Tim East, director of risk management at the Walt Disney Company, that is where businesses come in. Every one of the Dow 30 companies has created environmental and sustainability initiatives, but only 12% of companies have a C-suite or other top-level executive charged with leading action on this front. The clear trend of embracing corporate responsibility stems from a moral obligation businesses all have, and corporations must take initiative in changing how people think, East said.

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Addressing sustainability and other climate change concerns cannot be done in a silo, and efforts must focus on building resilience in all of the assets a business has: facilities, systems and people.

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Risk managers should be taking a leadership role, using their perspective of corporate objectives and performance to help identify and execute the most impactful change.

Risk professionals can particularly help drive this objective to boost awareness within the organization and in the broader community, while also ensuring the business itself is performing in line with sustainability goals. “Risk managers can help become part of the solution by helping to close the gap between the desires and intentions of our organizations and the performance and impact they have,” East said. “This is part of our moral obligation to reduce our impact on the environment.”

Why should companies act? “Not just because it’s good business—although it is, and not just because it’s profitable—although I think it is, but because it’s the right thing to do in the world and for the communities they serve,” East said.

To maximize the impact of these initiatives, East urges risk managers to set and pursue to reduction targets, otherwise they stand little chance of truly achieving change.

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Then, he advises they commit to a process of assessing, identifying opportunities, and measuring impact annually.

On the organizational level, changing mindsets extends beyond having employees recycle or monitoring water use. Business continuity planning is a critical task at Disney, East said, and they were always good at crisis management, addressing urgent problems over the course of a couple of days. Now, however, they are devoting more focus to planning for longer events.

To that end, the company is working to delink events from their consequences—rather than focusing on discrete emergency situations, it is focusing on how the business will be impacted by the conditions that could stem from any of these specific scenarios, he explained.

Getting started and shifting to a long-term focus seem daunting, and the slow rate of observable change often means adaptation and mitigation are not top of mind for businesses, said Lou Gritzo, vice president of research at FM Global. But risk professionals cannot wait for the next disaster or policy change to prompt a more serious evaluation of exposure and strategy.

Getting started on—or further investing in—mitigation efforts may be best focused on one of the main changes we are already seeing: flooding. Existing data shows a clear increase in flooding, and due to sea level risk and increased rainfall and intensity of rainfall, there will only be more, Gritzo said. To manage this growing risk, he recommends risk managers take four key steps:

  1. Know your flood exposure
  2. Be above the water level, and ensure any new construction is as far above it as possible
  3. Have and exercise a plan for flood emergencies
  4. Keep water out – in the wake of Hurricane Sandy, a number of physical protection measures have been certified and made commercial available to guard against up to a meter of water

Gauging the Impact of Reputational Risk

The following article is part of a continuing blog series that will explore ideas, concepts, discussions, arguments and applications associated with the field of enterprise and strategic risk management.

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In my previous article, I made the point that the public discussion of reputational risk lacks a set of common standards or definitions. This lack of consistency allows organizations to interpret or define the concept of reputational risk in very different ways. For some, reputation is beginning to be viewed as something like the “risk of risks” in the same way people are starting to discuss the concept of the “internet of things.” I questioned whether reputation or brand is actually a risk or a residual event stemming from other extenuating risk domains or actions.

Upon further reflection and discussions with academics and risk professionals who are thinking carefully about this issue, I would go further now to suggest that reputation or brand risk involves perceived or real human behaviors that are, to some extent, measured against societal, economic or moral standards. The adherence or deviation from established standards generates the basis for the risk, and the variability from the standard influences the duration of the outcome.

The bigger question is: What impact does reputational risk have on economic performance when possibly mitigated by the existence of a robust enterprise or strategic risk management methodology? Is the data available to see the “correlates” between a reputational risk event that trigger or influence operational key process indicators like EBIT, ROA, ROE and share price (public or private)?

What we do know from the Aon 2015 Global Risk Management Survey is that business leaders are concerned about reputational risk in general and the possible linkages with other hazard and operational risks within their organizations.

The respondents to the survey said that they worried that a reputational risk event would significantly impact financial performance.

reprisk1If reputation/brand risk was identified as a precipitating event, the respondents identified regulatory change, increasing competition, talent retention, cash flow/liquidity and share price volatility as “follow on” risk consequences. In effect, reputation/brand risk might constitute a “gateway” risk, where other related “follow on” risk consequences are triggered and serve to increase the overall volatility/impact of the reputation event.

Another way to view the data is to see what events could trigger a reputation event.

reprisk2In this case, the survey respondents identified nine non-correlated risks that could precipitate a reputation/brand event. Here social media plays an important role.

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The speed by which information, accurate or not, is transmitted, consumed and iterated across the nine risk categories may have a material impact on the basis and duration of the reputation/brand event. There is also an error component associated with social media.

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How many times have we witnessed an initial media report of a brand damaging event that turns out to be prematurely reported and the facts distorted, only to be corrected in a later reporting cycle?

Next up: Fat vs. thin tail distributions.