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Risk Management

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Risk Management in Australia​

01 Introduction

Risk Management as a Strategic Discipline

Every organisation, regardless of size, industry, or strategic goals, operates in a state of perpetual uncertainty. The extent to which an organisation understands, manages and articulates the fact that uncertainty is one of the most certain signs of its stability in the future.

The Evolution of Enterprise Risk Management

Risk management has changed dramatically in the past 20 years due to a series of high-profile corporate failures, regulatory measures and the acknowledgment that proactive, siloed risk management is not suitable to the complexity of the current operating environment.

Who This Guide Is For

This is a guide to junior and mid-level practitioners building experience in risk management, whether you have a financial, operations, audit, legal, or specialist background, e.g. compliance risk or climate and ESG risk.

Risk management is not the act of eliminating uncertainty – it is the act of being clear about uncertainty to make better decisions. It is not its intention to make the organisation risk-free but risk-conscious.

02 Enterprise Risk Management in Australia Framework

What the ERM Framework Is

An enterprise risk management framework is the structure within which an organisation identifies, analyses, manages, oversees, and reports on all the risks it faces. Contrary to siloed risk management models, where financial risk is with the treasury, operational risk with operations, and compliance risk with legal, an enterprise risk management model brings these components together into a cohesive whole.

The COSO and ISO 31000 Reference Frameworks

The COSO ERM framework, most recently updated in 2017, is the most popular conceptual framework for designing enterprise risk management structures, supported by the internationally recognised ISO 31000 standard.

Tailoring the Framework to the Organisation

The enterprise risk management framework should be designed to suit the specific characteristics of the individual organisation- its size, complexity, regulatory environment and strategic objectives.

03Financial Risk

What Financial Risk Encompasses

Financial risk involves risks to an organisation’s financial status due to fluctuations in market variables, credit quality failures, liquidity mismatches, and weaknesses in financial reporting.

The Three Primary Sub-Categories

Market risk, credit risk, and liquidity risk are the three primary sub-groups of financial risk that practitioners are most likely to face, and each is unique yet closely linked.

Real-World Example: Financial Risk Management in Practice

An instructive case of financial risk policy and practice going awry – with tangible results – is given by a European manufacturing conglomerate.

04 Operational Risk

Definition and Scope of Operational Risk

The Basel Committee on Banking Supervision, the most authoritative standard-setter in this area, defines operational risk as the risk of loss caused by inadequacy or failure of internal processes, people, and systems, or by external events.

Preventive and Detective Controls

Operational risk management involves a set of preventive controls (to reduce the likelihood of a risk event) and detective controls (to detect when a risk event occurs, so the impact can be limited and the cause mitigated).

Technology and Cyber Risk — The Dominant Sub-Category

In the past 10 years, technology and cyber risk have emerged as the largest sub-category of operational risk for most organisations due to increasing digital reliance and the advancement of external threat actors.

05Compliance Risk

What Compliance Risk Is

Compliance risk refers to the risk of legal or regulatory penalties, financial penalties, or reputational damage resulting from non-compliance with laws, regulations, rules, standards, and codes of conduct that apply to the organisation’s operations.

Three Fundamental Capabilities for Managing Compliance Risk

Compliance risk management needs three core capabilities that constitute a complete compliance function.

Compliance Culture — Who Owns the Risk

Among the most useful lessons concerning compliance risk management is that compliance risk is not the risk of the compliance function to own, but rather the risk of the business to manage. The compliance function is the part that offers oversight, guidance, and challenge.

06 Climate and ESG Risk

From the Periphery to the Centre of the Risk Framework

Climate and ESG risks have moved from the periphery of the enterprise risk management system to the centre in an incredibly short time. All boards and management teams across all industries are now expected to demonstrate that they have identified, evaluated, and are actively addressing their exposure to climate and broader ESG-related risks.

Physical and Transition Risks

Climate and ESG risks can be split into two main categories that require distinct analytical methods and management actions.

Broader ESG Risks and Integration into the ERM Framework

In addition to climate, the broader ESG risk category includes social and governance risks, which need to be incorporated into the enterprise risk management framework alongside traditional financial and operational risks.

07 Controls Testing

What Controls Testing Is and Why It Matters

Control testing is the verification activity in which an organisation ensures that the controls it has designed to address the identified risks are functioning effectively in practice. It is between risk assessment and risk assurance.

Three Types of Controls Testing Activity

There are three types of control testing activities with varying verification purposes.

Feeding Results Back into the ERM Framework

The results of control testing should be systematically fed into the enterprise risk management system – this is one of the most crucial yet underdeveloped areas of ERM.

08 Risk Appetite Statement

What the Risk Appetite Statement Is

The official statement of the amount and character of risk an organisation can assume to achieve its strategic objectives is the risk appetite statement. It is one of the most important governance documents within the enterprise risk management structure.

Qualitative and Quantitative Elements

A good risk appetite statement is structured so that both qualitative and quantitative components work together to create a complete statement.

The Most Common Failure Mode

The commonest risk in the design of risk appetite statements is the production of a document approved by the board that does not impact operational behaviour.

09Incident Escalation — Five Key Steps

What Incident Escalation Is

The process of identifying, categorising, reporting risk events to the appropriate levels of the organisation, investigating, correcting, and learning is known as incident escalation; risk events may be operational failures, compliance breaches, financial losses, or near-misses.

Step 1 — Detect and Classify the Incident

Timely detection is the initial step to successful incident escalation, and it involves ensuring that all levels of the organisation understand what constitutes an incident worthy of reporting and feel free to report without fear of being blamed.

Step 2 — Contain and Stabilise

The first step after an incident is detected and classified is containment, to prevent further impact.

Step 3 — Notify and Escalate

The enterprise risk management procedures in the organisation should pre-define the pathway for incident escalation – so that those involved are always informed immediately and reliably, without the need to make ad hoc decisions about who should be informed.

Step 4 — Investigate and Document

A thorough root cause investigation – not only what, but why – is the analytical heart of the incident escalation process.

Step 5 — Remediate and Review

Remediation fills the gap between the incident and the improvement of the enterprise risk management framework – it should address underlying causes, rather than symptoms.

10Risk Identification and Assessment

The Analytical Engine of the ERM Framework

Risk identification and assessment is the analytical engine of the enterprise risk management model – the ongoing process through which the organisation identifies, assesses, and prioritises the threats it experiences. It is not a regular workout that is done once a year and stored until the next annual cycle.

Risk Identification and Risk Assessment — Two Distinct Phases

The risk identification and assessment process usually follows two distinct stages with different analytical purposes.

The Risk Register as a Living Document

The result of the risk identification and assessment process is the risk register, the final list of risks identified and prioritised by the organisation, their owners, and the controls in place to address them.

Table 1: Risk Assessment Matrix — Rating Framework

Likelihood / Impact

Low Impact

Medium Impact

High Impact

Critical Impact

Almost Certain

Medium

High

Critical

Critical

Likely

Medium

High

High

Critical

Possible

Low

Medium

High

High

Unlikely

Low

Low

Medium

High

Rare

Low

Low

Low

Medium

All four risk rating categories have different governance and management implications.

Table 2: Enterprise Risk Management Framework — Implementation Process Flow

Phase

Key Activities

Responsible Party

Output

1. Framework Design

Establish ERM policy, risk taxonomy, risk governance structure, risk appetite dimensions, and board approval.

CRO + Board + Legal

ERM framework and risk appetite statement approved by the Board.

2. Risk Identification

Carry out risk workshops; scan operational data and incident history; conduct a horizon scan of the external environment.

Risk Business Units + Function.

Create a risk register listing all identified risks by category.

3. Risk Assessment

Assess each identified risk in terms of likelihood and impact; assign a risk owner; map to the controls.

Risk + Risk Function Risk Owners.

Control mapping rated risk register.

4. Controls Design and Testing

Evaluate the sufficiency of controls in place; develop new controls where gaps exist; perform initial controls testing.

Risk Function + Internal Audit + Operations.

Controls register; initial controls testing results.

5. Risk Appetite Calibration

Create quantitative risk appetite measures; translate them down to business-unit risk tolerances; connect with financial planning.

CFO + CRO + Board

Quantitative risk-appetite measures; business unit limits.

6. Monitoring and Reporting

Introduce continuous monitoring; create the incident escalation routes; create board and management reporting.

Risk Function + Compliance + IT.

Live risk monitoring; template board risk report.

7. Annual Review

Review and update the risk register; re-evaluate risk ratings; re-evaluate the risk appetite statement; update the controls program.

Board Risk Committee + CRO.

Revised ERM model; new risk register.

8. Continuous Improvement

Incorporate lessons from incidents; test the control cycle; enhance risk models using new data.

Internal Audit + Risk Function.

Enhanced controls, refined risk models, and risk culture.

11 Challenges and Lessons Learned

Challenge 1 — The Culture-Framework Gap

The disconnect between an effective enterprise risk management structure and the culture in which it is implemented is the most recalcitrant failure mode in risk management practice.

Challenge 2 — Emerging Risk Blindspots

By definition, any enterprise risk management framework is built on identified risks. The most dramatic failures are likely to be found in the risks that are still unknown, the unknown unknowns.

Challenge 3 — The Integration Gap

Various functions, methodologies, reporting on different cycles, and the use of different professional languages tend to manage financial risk, operational risk, compliance risk, and climate and ESG risk, which can lead to silos and the failure of the so-called enterprise risk integration.

12 Conclusion and Actionable Insights

What Risk Management Ultimately Delivers

Optimal risk management helps organisations pursue their ambitions with a clear understanding of the extent to which they are willing to take risks, and with mechanisms in place to identify warning signs when they are about to exceed acceptable limits.

Five Actionable Steps for Practitioners

The five steps below provide a systematic career progression for junior to mid-level professionals in the field of risk management.

Risk managers are not the ones who make organisations avoid risks; they ensure that when risks are undertaken, they are known, quantified, and kept within the limits set by the board with a clear intention. The most fundamental level of risk management is the establishment of organisations that learn from successes and failures, and from the surrounding environment, and apply that learning to become more resilient, more informed, and more purposeful in the search for form value.

That is the discipline.