Category Archives: Strategic Risk Management

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Firestorm Over Forced Removal Proves Costly for United

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United Airlines stock tumbled nearly 4% in early trading Tuesday morning before recovering late in the day as the company continued to deal with fallout after video surfaced showing a passenger being forcibly dragged from a United flight at Chicago’s O’Hare International Airport. United shares were down by as much as 6% in premarket trading Tuesday morning, according to MarketWatch.

Shocked viewers responded with universal outrage Monday to a video appearing to show a 69-year old man being brutally dragged off his flight by three uniformed officers from the Chicago Department of Aviation, one of which has since been placed on leave. The man’s face was bloodied and he appeared disheveled as officers dragged him along the narrow aisle of the plane.

“The incident on United flight 3411 was not in accordance with our standard operating procedure and the actions of the aviation security officer are obviously not condoned by the Department,” the agency said in a statement. “That officer has been placed on leave effective today pending a thorough review of the situation.”

Compounding the Airline’s misery was a letter sent to employees Monday night by United’s CEO, Oscar Munoz, saying that he supported the actions of the flight’s crew in removing the passenger, who Munoz accused of being “disruptive and belligerent.” Munoz later apologized directly to the passenger but his public sentiment was judged disingenuous in the wake of the leaked employee memo.

The passenger was removed from the flight to make room for four United employees, although it was initially reported that the passenger was removed from the flight to Louisville due to overbooking—a standard industry practice of selling more seats on any given flight than are actually available to shield the airline from lost revenue from no-shows. Although the flight was not technically overbooked, United followed the policy in order to seat the four employees.

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In 2016, the 12 largest U.S. airlines bumped slightly more than 40,600 of 659.7 million passengers, for a rate of 0.62 per 10,000 passengers, down from 0.73 per 10,000 in 2015, according to the Bureau of Transportation Statistics, Bloomberg reported.

In this case, the airline requested that four passengers relinquish their seats to United employees. According to reports, the airline first offered passengers $400 in addition to hotel and flight vouchers, and then raised the cash component to $800. When there were no takers, the airline chose four passengers to be removed. Approached by the flight’s crew, the man declined to give up his seat, asserting that he is a doctor and needed to see patients Monday morning.

The incident also sparked an international outrage across China, where it was the top item trending on Sina Weibo, as it was reported the removed passenger was Asian.

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The BBC reported that a passenger seated next to the doctor said the doctor was originally from Vietnam, where there was also widespread negative reaction. The hashtag #UnitedForcesPassengerOffPlane had more than 270 million views and an online petition, “Chinese Lives Matter,” which has some 38,000 signatures and calls for a U.S. investigation into the case, according to Bloomberg.

Reputational damage can be potentially costly as a company may have to deal with expenses related to managing a crises, such as public relations and advertising, as well as any loss to the company’s stock market value. The incident is the second in as many weeks to envelop United, which previously suffered scorn in the court of public opinion after barring two nonrevenue passengers from boarding a flight based on a dress code violation.

United’s largest shareholder is Warren Buffet, whose 9% stake in the airline, worth roughly $2 billion, was down some $90 million when United’s stock was at its lowest point on Tuesday.

Increasing Risk Complexity Outpaces ERM Oversight

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More organizations are recognizing the value of a structured focus on emerging risks. The number of organizations with a complete enterprise risk management (ERM) program in place has steadily risen from 9% in 2009 to 28% in 2016, according to the N.C. State Poole College of Management’s survey “The State of Risk Oversight: An Overview of Enterprise Risk Management Practices.”

Yet this progress may lag behind the increasingly complicated risks that need addressing. Of respondents, 20% noted an “extensive” increase in the volume and complexity of risks the past five years, with an additional 38% saying the volume and complexity of risks have increased “mostly.” This is similar to participant responses in the most recent prior years. In fact, only 2% said the volume and complexity of risks have not changed at all.
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Even with improvements in the number of programs implemented, the study—which is based on responses of 432 executives from a variety of industries—found there is room for improvement. Overall, 26% of respondents have no formal enterprise-wide approach to risk oversight and currently have no plans to consider this form of risk oversight.

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Organizations that do have programs continue to struggle to integrate their risk oversight efforts with strategic planning processes.

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“Significant opportunities remain for organizations to continue to strengthen their approaches to identifying and assessing key risks facing the entity especially as it relates to coordinating these efforts with strategic planning activities,” the researchers found.

According to the study:

Many argue that the volume and complexity of risks faced by organizations today continue to evolve at a rapid pace, creating huge challenges for management and boards in their oversight of the most important risks. Recent events such as Brexit, the U.

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S. presidential election, immigration challenges, the constant threat of terrorism, and cyber threats, among numerous other issues, represent examples of challenges management and boards face in navigating an organization’s risk landscape.

Key findings include:

Eliminating Language Barriers Between Information Security and the C-Suite

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Whether or not security operations pose a core focus to a company or are an afterthought, the largest obstacle now affecting business and security outcomes is the language barrier that exists between security teams and the C-Suite.

In general, security groups’ budgets have increased over the years, with organizations adding more vendors to the mix, “layering” security with the latest new tool to address the latest threat. One of the newest such tools is “threat intelligence” which organizations are using to form an “intelligence-led security” program, a security operations center, or incident response capabilities. While threat intelligence and other solutions hold the answers to many of the important questions executives ask about cyberattacks, this terminology means nothing to C-level executives, nor does the output from these systems and programs. What does it mean that you have stopped one billion attacks this past month? What impact have the 30 incident responses you’ve run over that same period of time had on the business? What’s the significance to reducing response time from one month to one day?

Executives running and overseeing a company have two primary concerns: increasing revenue and shareholder value. There is a big disconnect between security and the C-suite because they speak two different languages. One is a very technical language that needs a translation layer to explain it to the executives. The other is a very strategic language that needs to be conveyed in a way that makes security part of the team and company, and ensures alignment and participation with the business units and executive suite.

What’s the fix? Communication. Each group has to understand the other at least enough to relay the core concepts as they apply to the other and in a language the other understands. As a first step, some companies are adding a technical expert—a “designated geek,” if you will—to their board of directors so they can work on improving communication and understanding. While that can help, it takes a lot more to make sure priorities, efforts and results don’t get lost in translation.

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A Two-Way Street

Executives need to include the chief information security officer or chief technical officer as part of their strategic discussions and make sure that security leadership has the ability to push that communication down to their teams in a way everyone understands. To that end, CISOs and executives need to train their security operations personnel to ensure they understand the business. This starts by asking some critical questions:

  • Does every member of the security team understand what is it that you sell/produce/provide?
  • What are the things your security teams need to watch out for to protect revenue?
  • Many organizations operate large industrial control systems. If your organization has such a system, is your security team aware of this?
  • If your company is moving into the cloud or is about to launch a mobile app, does your security team know about this and have you enabled them to get the right monitoring in place to protect it?
  • Have you involved the security team as you were designing that new revenue stream, or evolving your business model in some other way, to be sure that security isn’t an afterthought?
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These are just a few examples of how executives need to think about the enterprise to ensure that security is strategically aligned. It is incumbent on the business to train the security personnel on its priorities so that security teams can look for attacks that are important to the business and take action.

Likewise, security teams need to change how they communicate to the C-suite. Every security team should conduct a stakeholder analysis to identify who needs to be informed of what and when. It all comes down to content, format and frequency. Make sure you have regular communications with not only your peers in security and network operations, but with the business units, risk management, C-level executives, the board of directors, and anyone else in the company that is involved in the day-to-day objectives and operations of the company. The CISO should be the link to make this connection happen, working with executives to establish regular communication.

There is no “right way” to communicate.

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Some executives and boards are more technical than others. Security teams need to take the time to learn what type of communication will be most effective or forever struggle to align security with the business. Sticking with the generated metrics of number of events, alerts and incidents per month has far less impact than an update that contains the “who, what, when, where and why” of a thwarted attack. For example: “We identified and stopped one attack this month from a cyber espionage group targeting our Western European manufacturing facility, which is responsible for $20 million per year in revenue to the company.”

For those in security who feel they can’t deliver such a statement because their security infrastructure doesn’t provide that kind of information about threat actors and campaigns, there is a path forward. Look into creating a program that uses adversary-focused, contextual cyber threat intelligence and make sure you understand enough about your business to know the impact of threats against the various business units. With the communication gap closed, and security and business goals aligned, organizations can become more secure, and profitable.

Key Steps to a Robust Risk Management Program

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Our business environment is constantly changing—technologies improve, regulations are modified, competition increases, and demand evolves. Effective risk management grants an ability to adapt to these changes.

Recent headline events, including the Volkswagen emissions deception, the Wells Fargo scandal, and the penalty paid by Dwolla to the Consumer Financial Protection Bureau (CFPB), illuminate powerful motivators for strong risk management programs. Key to a robust program is preventing stressful, and possibly catastrophic, surprises.

When Plains All American Pipeline failed to detect corrosion in its pipeline, for example, the result was a 3,000-barrel oil spill and millions of dollars in fines. The corrosion had run under the radar because the company did not delegate sufficient inspection resources and did not maintain proper procedures and systems for preventing problems from escalating into emergencies. Risk management best practices, however, could have standardized these procedures throughout the organization and prevented the disaster from occurring.

Complying with regulators like the SEC and CFPB
Dwolla, a small, private e-commerce and online payment company, was found by the CFPB to be guilty of risk management negligence for inadequate data security practices. The catch is that Dwolla did not suffer a data breach and none of its customers were compromised.
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The CFPB fined Dwolla $100,000 as part of its increased focus on companies’ existing prevention strategies. Regulators are no longer simply pursuing organizations that have suffered risk management incidents; organizations need to take proactive approaches rather than simply hope to get by.

Improving productivity and encouraging innovation
An independent, peer-reviewed report, “The Valuation Implications of Enterprise Risk Management Maturity,” published in The Journal of Risk and Insurance, proved that organizations with mature ERM programs (as defined by the RIMS Risk Maturity Model) can achieve a 25% firm valuation premium over those without. Risk management does not have to be a burdensome addition to daily responsibilities—and if it is executed properly, it won’t. It simplifies daily operations by increasing transparency and allowing more resources to be devoted to value-add activities, like product development and customer services.

Checklist for evaluating your risk management efforts

A better question than “does my organization perform risk management?” is “how effectively does my organization identify and mitigate risks?” The following checklist outlines characteristics common to effective risk management programs. Your organization should prioritize development in these areas.

  1. Effective risk management governance

Boards, through their risk oversight role, are accountable for a risk’s material impact, whether the cause is at the executive level or on the front lines. The SEC considers “not knowing about a material risk” negligence, which carries the same penalties as fraud.

  • The board must monitor the effectiveness of the organization’s risk management process, ensuring it reaches all levels and business areas.

  • Internal auditors must independently confirm the board is informed on all material risks.
  • All material risks must be disclosed to shareholders, along with evidence that they are effectively mitigated.
  1. Performance management and goal management
  • Divide corporate objectives into business-unit contributions.
  • Identify business processes contributing to a goal within each business unit.
  • Cascade goals to all front-line managers within contributing processes.

  • Aggregate goal assessments and determine links between contributing business processes.
  1. Consistent risk identification and prioritization

Risk assessments must address more than high-level concerns. Effective assessments drill into risk events, uncovering the root cause, or problem “driving” the risk. Repeatable risk assessments are based on common numerical scales and scoring criteria across departments.

  1. Actionable risk tolerances

Risk appetite is a high-level statement that serves as a guide for strategic decisions. In order to be actionable, it should be accompanied by its quantitative cousin, risk tolerance. Risk tolerance is an effective monitoring technique for key performance goals and risk metrics.

  1. Centralized risk monitoring and control activities

Risk managers need to do more than design processes to identify risks and appropriate responses. A critical third component—monitoring—is the verification of a control’s effectiveness over the risk. A few key things to keep in mind to make monitoring effective:

  • Adjust risk assessments over time (spend less time on risks with decreasing indexes).
  • Reduce testing by identifying areas that can share controls (increase organizational efficiency).
  • Link risks and activities to determine which processes need to be monitored (prioritize activities/initiatives).
  • Monitor business metrics (discover concerning trends before they affect the organization).
  1. Forward-looking risk and goal reporting and communication

In order to continue funding their organizations’ risk management programs, boards need evidence that those programs are working. Risk managers should ask two basic questions before reporting to the board:

  • How might identified risks affect the board’s strategic objectives and key concerns?
  • Which metrics or trends most validate the program’s effectiveness?

These items are just a starting point for an analysis of your organization’s program. For a more in-depth blueprint and “state of ERM” report, take the RIMS Risk Maturity Model (RMM), a free best-practice assessment tool that scores risk management programs and generates an immediate report of your organization’s risk maturity.