There are subtle differences
between risk based approaches and process based
approaches and each serves a purpose. For
comparative purposes, the following frameworks
are compared:
-
Enterprise Risk Management (ERM),
a risk based framework developed by the COSO
(Committee of Sponsoring Organizations of
the Treadway Commission. Quickly becoming
THE industry standard for Enterprise Risk
Management.
-
ISO, the International
Standards Organization has developed a
series of standards or best practices that
includes taking measurements for process
improvement.
-
Six Disciplines – a
methodology and toolset that helps
organizations meet objectives
-
Eight Disciplines – a team
based approach at problem solving.
First of all, following any of
these approaches vastly improves your chance of
success, so if you are following any of these
approaches you are light years ahead of those
who are not. If you are not following any formal
approach, hopefully this paper can make it
easier to identify which approach to take.
If you implement ERM correctly
it should be measuring progress (or lack
thereof), include all of the six or eight
disciplines, and ensure processes are executing
effectively. However, the ERM framework
developed by COSO is not very
process/deliverable based. Likewise, a process
or deliverables based system, if implemented
correctly, should be addressing risks (SWOT
analysis). However this approach creates the
possibility of having the organization manage
issues rather than manage risks.
Typically, ERM assumes that most
of the process based approaches are already
implemented in the organization in some manner.
With that in mind, it is important to understand
the differences and how to integrate both
methodologies since most small to mediums sized
businesses are process/deliverables based and
the accounting/investment community will be
attempting to have these organizations be risk
based. There is a push for organizations to be
risk based with the advent of two recent
phenomena:
-
Financial auditors are now
commenting on the strength of organizations
internal controls(SAS112);
-
Standard and Poor’s will now
be using the strength of an organization’s
ERM system to determine an organization's
Credit Rating. In this current economic
climate an organization must do everything
in its power to improve their credit rating
to help them grow or even survive.
Click here for S&P guidance.
It may not necessarily come to
pass that Managing Risks becomes a “Seventh or
Ninth Discipline”. ISO has even released its
first Risk Based standard (ISO27001 –
Information Security), but most probably will
not implement risk based approaches to many
other standards. However, it would be best for
an organization to know how best to incorporate
the ERM concepts to avoid competing
philosophies. Businesses will have a limited
band width to adopt a major philosophy. Process
based frameworks may be viewed as ‘elective’,
where as ERM may eventually be viewed as
‘required’.
There are plenty of similarities
in the approaches with 8 Disciplines focusing on
one particular “problem”; ISO ensuring that
processes continue to improve; Six Disciplines
allowing organizations to meet their strategic
objectives and managing the “distracting” day to
day issues; and ERM managing all risks
associated with an organization meeting its
objectives.
At the end of the day, the
process based approach may be positioned as one
giant entity level control that allows a company
to mitigate the risk of not meeting its
objectives. The problem is that the external
auditors will have a hard time recognizing that.
Most process documentation is
full of controls that mitigate risks, however if
those risks and controls were identified, an
auditor would be able to ascertain that the
risks were being mitigated. If those risks were
measured by probability and impact, the
organization might be able to reduce the
overheads and controls that are baked into
processes.
In summary, if your organization
is following any process based approach, it is
positioned well to manage a number of risks, but
without a true risk based approach you may be
spending more time managing issues rather than
managing risks, which is becoming more important
in these tough economic and soon to be more
regulated times.