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Defining Reputational Risk

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

One of the more striking conclusions contained in Aon’s 2015 Global Risk Management Survey is that damage to reputation and/or brand was considered by the survey cohort to be the most significant risk to the enterprise. The survey was conducted in Q4 of 2014 and received input from over 1,400 respondents coming from both the private and public business on a worldwide basis.

The “Top Ten” most identified risks included:

  1. Damage to reputation/brand
  2. Economic slowdown/slow recovery
  3. Regulatory/legislative changes
  4. Increasing competition
  5. Failure to act or retain top talent
  6. Failure to innovate/meet customer needs
  7. Business interruption
  8. Third-party liability
  9. Computer crime/hacking/viruses/malicious codes
  10. Property damage.

The survey results should not come as any real surprise given the number of sensational news stories coming from around the world that highlight potential or real reputational or brand problems. We have witnessed data breaches ranging from credit card identity theft in consumer retail, to serious product recall notifications in the food and beverage industry, to product performance/ warranty failures in the automotive arena, as well as “hints of reputational quality,” defined as “trust” in the early stage politics of the presidential selection process involving private vs. public use of email servers. There is little doubt that news, sensational or not, impacting reputational or brand, will continue for some to come. The real question is: Should anyone care?

Defining reputational/brand risk is hard to accomplish:

Based on some additional research done by my colleague Sylvesto Lorello, reputational risk is not a new concept, but it arguably has no established or universally agreed upon definition. Academic and business thinking about this subject continues to evolve. Within the insurance underwriting community that I have been in touch with, reputational or brand risk is being compared in scope to contingent liability risks, but with a serious caveat: the basis of the risk is highly variable and the duration of the risk event/loss event is difficult to pin down economically.

The concept of reputation and brand for example, are notably absent from the 2004 framework for enterprise risk management proposed by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). It is also overlooked in the Basel II international accord for regulating bank capital, which was also issued in 2004.

A lack of common standards or definitions of reputational risk mean that companies perceive it in different ways.

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Some risk practioners are beginning to view reputation as a “risk of risks” similar to the dialogue surrounding the “internet of things/objects.” Interestingly, an emerging dialogue is developing around whether reputation or brand is actually a risk or a residual event stemming from other extenuating risk domains or actions.

The ISO 31000 (2009)/ISO Guide 73:2002 definition of risk is the “effect of uncertainty on objectives.” In this definition, uncertainties include events (which may or may not happen) and uncertainties caused by ambiguity or a lack of information.

The U.S. Federal Reserve in 1995 defined reputational risk as “…the potential that negative publicity regarding an institution’s business practices, whether true or not, will cause a decline in the customer base, costly litigation or revenue reductions.

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In this case, the definition points to the potential for hard data from which basis and duration can be calculated.

Definitional issues aside, eventually societies will develop benchmarks with which to measure reputational or brand acceptability. One way of thinking about this approach is shown in the following exhibit.

UntitledHere we ignore some of the more difficult definitional discussion around a combined reputation/brand perspective, and limit our view to reputation alone.

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From a practical early stage standpoint, an entities reputation could be view from potential threat and potential impact perspective. On the threat side, it may be possible to segregate threats into four categories:

  • Risk to reputation stemming from employment activities;
  • Risk to reputation coming from product or customer issues;
  • Risk to reputation derived from governance; and,
  • Other less easily classified risks to reputation.

These categories appear for graphical purposes as if they are mutually exclusive, but in reality, there are good examples of causal overlap that increased risk volatility and severity. Recent oil spills and automobile product failure/recalls are enduring situations where more than one causal category created a economically catastrophic reputational problem.

On the other side of the graphic we outline the potential impacts to reputation coming from the threat categories. Again, while not mutually exclusive or exhaustive, the impact areas include:

  • Customer base
  • Financial valuation
  • Brand and media
  • Staf
  • Other less easily defined impacts.

Coming next, who are the stakeholders and how might one approach measuring reputational risk.

Insider Fraud: How to Identify and Prevent Internal Threats

Organizations of all sizes, across all industries have become data breach victims as cyber crooks become more sophisticated in identifying vulnerable targets.

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Attackers can compromise an organization within scant minutes in 60% of breaches, reports the latest Verizon Data Breach Investigations Report. Still, insiders persist as one of the biggest fraud perpetrators, costing organizations globally about $3.7 trillion annually in 2014, estimates the Association of Certified Fraud Examiners. The puzzling question is this: With the advances in technology, why aren’t organizations preventing these incidents and why aren’t the offenders being nabbed earlier?

The answer to the insider fraud dilemma lies in a lag in robust risk-management technologies that help organizations identify and prevent insider fraud, especially in such industries as banking. With this type of breach, tracking behavior becomes a key component of managing risks and threats proactively. While basic data tracking isn’t new, what is fresh is grasping the internal behavior of employees in a real time, comprehensive view across multiple platforms and applications.

Unfortunately, disparate legacy systems that don’t share information easily create larger problems by limiting an organization’s ability to monitor across all systems. And siloed information makes it impossible to find “normal” employee behavior that should serve as a benchmark for day-to-day activity.

For example, banks must be on the lookout continually for employees who exhibit illegal behavior when, say, handling a dormant bank account, who are manipulating customer information or who collude with colleagues.

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By benchmarking regular employee activity and leveraging link analysis to spot relationships across accounts or employees, banks also can monitor for and spot instances of employee negligence that can offer cyber crooks easy access to customer data.

Sophisticated surveillance technology exists that lets organizations monitor and detect suspicious behavior in real time, then analyze and develop an evidence trail. Organizations can use the following activities to help identify and prevent an internal threat before it escalates and triggers substantial monetary and brand damage.

  • Monitor all user activity: It is critical to establish what is normal and what is abnormal. Each organization has different user personas with unique activities considered “normal.” By defining organizational benchmarks for normal versus abnormal activity, risk managers can identify inconsistencies in employee behavioral patterns.
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    Visibility into user activity across applications and networks enables them to highlight incidents that warrant deeper analysis and determine threats.

  • Track behavior in real time: Rather than analyze data retroactively, organizations should adopt a solution which can alert from the moment data is captured from the corporate applications and networks. Long-lead systems or those heavily reliant on log-file data don’t allow for real-time tracking and often result in discovering a breach after the fact.

Enable searchability: Organizations can deploy a user-friendly monitoring system with Google-like searchability features with highly specific behavioral criteria. Moving beyond clunky legacy systems to technology that is intuitive eliminates user error and enables more advanced rule-based monitoring.

  • Record screen activity: Gaining visual evidence of illegal activity while it occurs is critical for use during an investigation. Technology that records screen-by-screen activity at the application level creates the comprehensive data trail needed for courtroom presentation.

A combination of these activities can assist organizations in identifying anomalies in employee behavior, track digital activities and contrast them with an employee’s normal routine or that of a peer group’s pattern. If incongruities appear, advanced risk-management technology develops a data trail and a case strong enough to stand up in court. Leveraging these measures, insider fraud can be discovered at an earlier stage to prevent customer data breaches and malicious attacks.

Creating a Risk Intelligent Organization

Many organizations spend time and effort building and developing robust risk mitigation frameworks and strategies to handle business-specific risks. In spite of constant monitoring through dashboards and reports, many companies still face major and unexpected issues. One of the main reasons for shortfalls in risk management is the general attitude towards risk mitigation. Although companies are well-prepared with an infrastructure in place, they often struggle when cultivating a sense of risk awareness, responsibility and intelligence into and across the fabric of an organization, which results in gaps and deficiencies.

Every organization realizes the significance of risk intelligence, but they frequently face issues in the initial stage of their transition. Developing a risk culture is frequently viewed as just a requirement to be fulfilled rather than something that adds value to an enterprise. Without a clear agenda, many companies find it impossible to cultivate risk-taking capabilities into its employee base.

Risk intelligence demands that every individual in an organization take responsibility for managing risks in the day-to-day operations. Senior management should assess the existing risk management strategy and gauge its effectiveness in alleviating risks as well as developing awareness throughout the organizational structure.

Factors Influencing Risk Culture

For a smooth journey in risk intelligence, the senior management has to be completely aware of the levers influencing risk-taking behavior of their employees. Some of the major factors that impact smart risk-taking decisions include talent management, training and education, qualification of staffs, incentives, leadership at the top of the organizational hierarchy, and the ability of an organization to take risk-based decisions.

To develop a risk-intelligent structure in business enterprises, organizations should perform a thorough assessment. This can be achieved by setting up objectives, conducting surveys and interviews, analyzing gaps, prioritizing actions, incorporating recommendations and keeping track of the effectiveness of the strategy.

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Comparing the existing culture against other influential factors such as governance, policies and procedures, competence, relationships, performance, and accountability will help the top management understand the current state of culture and the level of contribution of existing risk initiatives to create a positive impact on the business’s risk culture.

Conducting gap analysis around the influential factors will offer a better understanding of what needs improvement. To create an effective risk culture and make it work successfully to the benefit of an organization, management should continuously improve it to fit the changing business objectives and requirements.

Strengthening Risk Culture through Technology

Leveraging technology to create a centralized framework for capturing risks and organizing data elements will strengthen the risk culture to a greater extent. A risk management framework should speak a common language that is well understood throughout the organization, including stakeholders. Developing a technically assisted risk management strategy will eliminate the most common challenges faced by an organization.

A centralized data model will aid in managing risks that may arise due to external and internal events. It will also give the organization a top-down view of the business goals, global risks and controls associated with it.  A common risk environment enables effective monitoring and reporting of the gaps and risks using heat maps, dashboards, and charts. This will enhance the organization’s risk intelligence by providing real-time visibility into scores, its risk appetite, as well as limitations towards risks.

Risk and security officers will be able to get a better picture through trend analysis and obtain useful insights. A flexible framework that is developed on the basis of industry standards will provide a strong foundation for risk intelligence and aid in timely capture and categorizing of risks and initiate appropriate corrective actions.

Key Elements of a Risk Intelligent Organization

  • A risk intelligent organization follows a unified and standardized risk framework that speaks the same language across the entire organization. A framework that follows a common language is easy to understand and helps mitigate risks in a timely manner, thereby driving value.
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  • Successful creation of risk intelligence defines roles, responsibilities, and the hierarchy structure in an enterprise.
  • A centralized framework will also bolster support to business operations and a wide array of functions.
  • Creating risk intelligence will enhance performance and accountability.
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  • A risk intelligent organization will be able to strike a perfect balance between risk and reward.
  • Risk intelligent architecture offers the executive management, board members, stakeholders, and audit committees the ability to effectively perform their duties by promoting a greater level of transparency. Executive management is assigned with the task of developing, incorporating, and maintaining a robust and efficient risk management strategy and improvise it on a regular basis it to fit the changing requirements.
  • Business units are obligated to monitor the performance of their respective units and their approaches to managing risks as specified by the risk management and independent assurance functions, as well as oversight from executive management.
  • In a risk intelligent organization, finance, legal, HR, and IT units offer support to the individual departments in the organization in their efforts to mitigate risks.

The role of the internal audit is assigned with providing independent and unbiased assurance to the senior management by assessing the efficiency of the risk management practices and finding ways to enhance those strategies.

How Does Google Face Global Challenges?

NEW YORK—Staying a step ahead of regulators around the world is challenging for any global business. For Google, it is a “significant challenge, to say the least,” said Andy Hinton, vice president of global ethics and compliance at Google, Inc. After organizing the world’s information and making it universally accessible, the company’s secondary mission is products that help users, he said.

“Google is boundary-less when it comes to what those products might be and what they might look like,” Hinton said during The Wall Street Journal’s Newsmaker’s Forum in April. “So trying to keep up with driverless cars, drones and providing internet service with floating balloons around the world (Project Loon) is a challenge.”

Google’s compliance program includes the company’s trade, bribery, internet security and privacy issues. While any number of issues may surface, he said, “one of them is to help the company respond to some of the criticism leveled against it, mostly in jurisdictions outside the United States, and to make sure responses are consistent with applicable laws.”

With Google Earth, for example, equipment must be moved around the world. Google Earth “enables people to get information access to the earth, where they otherwise might not be able to see those things,” Hinton said, noting that people can now view Mt. Everest and other places they may never get to see otherwise. This involves contact with customs officials and governments and also creates “lots of opportunities to do things wrong and get in trouble,” he said. “So we are always on top of that. Plus, the equipment we use is so unique that we show up in front of a customs official with a camera on top of a tripod on top of a car and they ask, ‘What is that? It’s not in the manual.’ You have to spend time explaining what it is and help them to be comfortable with it.

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While some governments are more difficult to deal with than others, “there are definite challenges in all the continents and countries,” he said. “Obviously privacy is a challenge in Europe, because there is a different perspective around privacy and internet security than there is in the United States. With APAC [Asia Pacific] there is an integration of gift-giving and business that is relatively unique to the APAC region and can present challenges.”

An important part of its compliance strategy is the company’s diversity, which he added is also part of its mission. “Not just diversity in the traditional perspective, but in bringing on people who can understand the challenges in these regions,” he said.

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“So for gift-giving in the Middle East, sure I can sit in Mountain View trying to figure it out, but we hired an attorney who is in that culture and understands U.S. law and can, in that context, help us navigate the region—balancing expectations of the region with legal expectations in the United States.”

Company Strategy

In fact, Google’s overall hiring policies are part of its strategy to “do things differently, or do them better than other companies,” he said. “That requires us to be incredibly sharp in the way we do hiring.” Now that the company has about 60,000 employees, “it’s important to hire people who share your values and buy into your mission. Because if you are not going to have a lot of rules and you are not going to have an enormous compliance program and checkers following people around, there is a lot of trust and autonomy that you give to your Googlers.”

How does the company accomplish this? “When I interview people and they talk about winning and beating the competition, that’s a huge red flag to me,” he said. “When we started, Larry was very much about the users and we still are. If you build something good that users really like, you can figure out the rest. Revenue and everything else will come. People who have that backwards are tremendously dangerous to the company.”

Google also acquires staff through acquisitions, he said, adding that this talent is “much harder to manage. The larger the acquisition and the more the acquisition has its own culture, the greater the challenge.”