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Responses to risk

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CIMA-P3 · Chapter 2
  1. Responses to risk

1 A framework for risk management – the CIMA risk management cycle

Seven stages in a loop: establish the group and set goals, identify risk areas, understand and assess the scale of the risk, develop a risk response strategy, implement the strategy and allocate responsibilities, implement and monitor controls, review and refine.The CIMA risk management cycle1 Establish a riskmanagement group, set goals2 Identify risk areas3 Understand and assessthe scale of the risk4 Develop a riskresponse strategy5 Implement the strategy,allocate responsibilities6 Implement andmonitor controls7 Review and refinethe process, and repeatthe cycle never stops —risks change, so stage 7feeds stage 1 again

The framework is logical and easy to understand.

1.1 Establish a risk management group and set goals

Ultimately risk management is the responsibility of the board (or, more broadly, those charged with governance). However, like many functions in organisations the board is likely to delegate responsibility to a sub-group of suitable specialists. The board should set goals which reflect the risk appetite of the organisation. For example, if the organisation is an airline, the board would set goals of Zero accidents but it might be prepared to tolerate a degree of risk of bad publicity from over-booking flights.

1.2 Identify risk areas

It is important not to be complacent about risks. Some will be obvious and well-known but others might be undiscovered until something goes wrong. We will see later in this Chapter methods that might help to discover potential risks.

1.3 Understand and assess the scale of the risk

Not all risks are equal. Some risks that are discovered might be judged as being of little consequence; others could be of major significance. Techniques will be covered later.

1.4 Develop a risk response strategy

Having identified and assessed the risks decisions have to be made about what to do about them. The TARA approach will be explained later.

1.5 Implement strategy and allocate responsibilities

Simply identifying risks and working out suitable responses will not reduce risk: proper actions have to be specified and must then be consistently carried out. For example, ensuring that the safety of machines is monitored or that customer credit limits are regularly reviewed. Individuals have to be put in charge of risk management strategies and procedures and must be held accountable for failures.

1.6 Implement and monitor controls

Controls must then be implemented. For example, setting out dates by which risks have to be addressed, ensuring that inspections are done at regular intervals or by sending staff on training courses. It is very important to document risk reduction strategies and how those strategies are realised.

1.7 Review and refine the process and repeat

Of course, the solutions implemented to deal with identified risks are unlikely to work perfectly the first time. They will often need to be improved. But it is also very important to realise that nothing stands still: risks will be evolving all the time and the organisation must keep them under constant review to ensure that all are properly addressed.

The chapter-2 lecture walks the risk management cycle, risk identification, the risk map, TARA, gross and net risk, the risk register and assurance mapping — sections 1, 2, 6, 8, 9, 10 and 11. Four things to be aware of:

  • the tutor calls the gross-risk decomposition in section 9 a “risk cube”. That is his name for the asset / threat / vulnerability model and it is a good one, but the notes do not use it, and it must not be confused with COSO’s 2004 cube, which is no longer examinable — see chapter 6 for the COSO framework that is actually examinable;

  • the tape uses “lines of defence”. The Institute of Internal Auditors replaced that model with the Three Lines Model in 2020; section 11 below sets out the current version and explains what changed. Everything the tutor says about what each line actually does still holds;

  • the tape walks two risk-map slides and mentions a third variant, and notes out loud that the axes are the other way up on one of them. This chapter carries one map (section 6) and one response map on the same axes (section 8), so follow the notes for the orientation;

  • sections 3, 4 and 5 — analysing strategic choice, scenario planning and stress testing — are not on the tape at all. They are named 2027 syllabus outcomes and have to be read from the notes.

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2 Identifying risk areas

The trick is to use every method at your disposal to identify risks. Throw the net as widely as you can at this stage. Later, risks might be dismissed as being of little importance, but it is important that as many as possible potential risks are initially considered.

Methods include:

  • Physical inspection and observation (for example, that safety equipment is still used on machinery).

  • Inspect documents (for example, the accident log book).

  • Internal audit. Internal auditors are employees of the company (usually) who examine and report on the organisation systems of internal control. Not only do they report on financial controls but they can also be required to examine systems such as quality control accident reporting and so on.

  • Outside consultants brought in to audit procedures (for example, security consultants to advise on IT security).

  • Observation of competitors’ procedures (question why they carry out operations in a particular way).

  • Enquiries (for example, ask employees, customers and suppliers about problems).

  • Brainstorming (wide-ranging discussions to anticipate potential problems).

  • Checklists (for example, use a checklist to evaluate how a job went and consider action where there had been problems).

  • Benchmarking (falling short of targets can imply that things are going wrong).

  • External events (for example, be alert for economic events that could affect the organisation).

  • Internal events (for example, high staff turnover can indicate problems with employments conditions).

  • Leading event indicators (for example, if a customer takes longer and longer to pay each month then there would appear to be a risk of non-payment).

  • Escalation triggers (for example, if you are twice late filing a tax return, then the third default could be very serious).

  • Event interdependencies (for example, a major customer going into liquidation could cause excess inventory problems).

  • Scenario planning and stress testing (see below)

3 Analysing strategic choice

Scenario planning and stress testing, in the two sections that follow, ask what the world might do to a strategy. Before either of them is worth running there is a prior question: is the strategy itself a sensible choice? The 2027 syllabus names “analysis of strategic choice” as a topic under P3B1, and it is the first place a strategic risk can be found — not in the environment, but in the decision.

A strategic option is tested on three headings. The risk is what each heading exposes:

Test

The question

The risk it exposes

Suitability

Does the option address the circumstances the organisation is actually in — its position, its capabilities, the way its market is moving?

That the strategy solves a problem the organisation does not have, or relies on a capability it does not possess.

Acceptability

Are the expected return, the risk and the stakeholder reaction acceptable?

That the return is adequate only on optimistic assumptions, that the risk exceeds capacity (Chapter 1, section 7.1), or that a powerful stakeholder blocks it.

Feasibility

Can it actually be done — with the money, the people, the time and the operational capacity available?

That the plan is undeliverable, which is a risk of execution rather than of judgement and is the one most often discovered late.

Two further questions belong to this stage, and both are risk questions rather than strategy questions:

  • What assumptions is the strategy standing on? Write them down as a list. An assumption that is never written down is never tested, and it is the untested assumption — “our main customer will renew”, “the regulator will not intervene”, “we can recruit forty engineers a year” — that turns a good plan into a failed one. This is what P3B1a means by analysing the relevance of the assumptions on which strategy is based.

  • Is this an incremental change or a radical departure? An incremental strategy carries execution risk. A radical one carries execution risk plus the risk that the organisation has no experience of the new territory, so its own estimates are worth less. Section 5 makes the same point when it stress-tests a strategy.

4 Scenario planning and stress testing

4.1 Introduction

Scenario planning looks at all the things that could happen (and there can be many permutations of future events) and from those builds viable scenarios: a number of believable, internally consistent futures. This greatly reduces the number of ‘universes’ that need to be considered and allows the organisation to focus on the relatively few most likely scenarios.

It operates on the principle that, for some decisions, thinking in terms of multiple possible futures, or scenarios, is more effective than relying on single-point forecasts about the future.

For example, our political horizon might suggest that either Government 1 or Government 2 will be elected within the next year. Our economic predictions might suggest that interest rates will be either 3% or 5%. However, if Government 1 favours high public expenditure then this makes 5% interest rates much more likely as high interest rates are offered to allow government borrowing. If Government 2 favours austerity, then interest rates are likely to stay at 3%. Therefore, the only two viable scenarios are:

Government 1

Government 2

Interest rates 3%

Not feasible

Yes

Interest rates 5%

Yes

Not feasible

  • Government 1; 5%

  • Government 2; 3%

Other permutations can be ignored because they are implausible.

4.2 Steps in scenario planning

  1. Define the scope, for example: What time horizon? Which part of the business? Which country (for multi-national organisations)?

  2. Identify which factors will most affect the organisation.

  3. What are the plausible outcomes for each factor?

  4. What are the plausible, internally consistent combinations of factors?

  5. What effect would each scenario have on the organisation?

  6. How should the organisation respond? For example, it could decide to retreat to an Internet-only presence, it could move up-market/down-market, or it could withdraw from the market.

  7. Go back and recheck assumptions and scenarios in the light of the decisions made, as some of those decisions might affect them.

4.3 Advantages and disadvantages of scenario planning

Scenario planning can have the following advantages:

  • It challenges managers and other stakeholders to be more forward-looking when business planning.

  • It challenges assumptions about the future, and about the drivers and forces that influence its industry sector.

  • It forces managers to consider previously unimagined possibilities and tests the rationale for current strategies.

  • It does not attempt to forecast the future – almost certainly a lost cause. Instead it results in several outcomes, each of which can have a planned response.

  • It encourages communication and planning within the company as scenario building requires inputs from many areas.

  • It can encourage the identification and evaluation of ‘weak signals’. Weak signals are small signs of changes that do not currently have much effect but which might be game-changing in the future. For example, early adopters of Facebook might have used it for purely personal use, but some might have foreseen the major effect it would have on marketing.

Scenario planning can have the following disadvantages:

  • It can be very time-consuming: identification of all the relevant variables, collection of data and the distillation to a few plausible, internally consistent scenarios.

  • It is important to use experts who can assess possible outcomes – and the cost of experts‘ time can be considerable.

  • It is important not to eliminate all scenarios except the most likely one or the most attractive one. The point of scenario planning is to obtain a range of possibilities – both favourable and unfavourable - and to plan for those.

5 Stress testing strategy

If there is one certainty in business it is that strategic plans rarely produce outcomes that are precise matches for the original plan. A strategic plan has a time horizon of around five years and an awful lot can happen in that time. So, what happens if unfavourable events occur? Will the company survive? Does the strategic plan have enough flexibility built into it so that it can be adapted part way through? Are there enough resources (such as cash) to see the company safely through bad times? Stress-testing attempts to identify risks and scenarios that might occur to help organisations understand where vulnerabilities exist and to build in risk resilience.

A stress test is, therefore, an assessment of how a system or strategy is likely to function if severe adverse events occur. For example, would your company survive if your major customer went into liquidation? What would happen if a major product had to be withdrawn (in 2019 Boeing had to ground its whole 737 MAX fleet after two similar accidents involving nearly new aircraft and the airlines that operated them sought compensation). What would happen if a monopoly supplier of a vital component were taken over by one of your rivals?

Stress tests should be carried out on all strategies, whether an existing strategy is being followed (perhaps it has become high risk) or a new strategy is planned.

Of course, there will always be a problem envisioning all the things that can go wrong and deciding if their probabilities are significant and many organisations can disapprove of the Jeremiahs in their midst who think about calamity when the rest of the organisation is expected to embrace enthusiastically and, perhaps sycophantically, the board’s new strategy.

It is therefore important that in the rules and culture of the organisation stress-testing becomes mandatory and valued.

There are many potential approaches to stress testing, but the following list is as helpful as any:

  • Look to the future. What consumer trends, technical developments and political changes might occur and which will affect the business. Going through the PESTEL headings and projecting these into their possible future effects on the business can be a good start. Don’t flinch from unpleasant possibilities or engage in wishful thinking: evaluate events’ likelihood and their effects.

  • Understand what makes your business currently successful. Understand your value chain and what you are good at. What would happen if your unique capability in an important area were to disappear? For example, if you were a pharmaceutical firm, what will happen when your patent on a block-buster drug runs out? If you are a car manufacturer, what would happen if a competitor discovers a battery technology that increases range by a factor of 10? What happens if you are a firm of lawyers and artificial intelligence develops to such a degree that reliable advice can be offered on line and perhaps even disputes can be judged on-line?

  • Does the strategy embody objectives? If there are no objectives (eg following the SMART pattern of specific, measurable, achievable, relevant and time-limited) then the strategy is useless as it will not be achieved.

  • Is the strategy an incremental change to the current strategy (relatively safe) or a radical departure (relatively dangerous)? Sometimes a radical approach is needed to save businesses but be aware that the company is then venturing into areas where it will have little expertise or market knowledge. Assumptions and feasibility have to be examined much more critically.

  • Have stakeholders bought into the strategy? If there are powerful dissenters then the strategy will probably not work.

  • Does the new strategy offer the hope of adding value for customers?

  • Set up a financial model and change the parameters and assumptions used to examine how sensitive success or survival is to each. We can all produce cash flow forecasts on a spreadsheet which allows our company to live within its overdraft limit. Simply change assumptions about sales, costs etc until you get the required answer. But that is no way to stress test. Be at least realistic, then be pessimistic. No reward will come without risk, but at least understand the risks arising from the strategy.

So, questions that could be asked and scenarios that could be played out could include:

  • What happens if interest rates double?

  • What happens if there is a serious recession?

  • What would happen if our major customer failed?

  • What would happen if a major product was discovered to have a serious flaw?

  • What happens if a competitor makes an important technical breakthrough?

These can be built into sets of viable, if unpleasant, scenarios and the company can then respond however it sees fit.

Stress-testing a strategic plan

Ridgeway’s five-year plan starts from revenue of $200 million and assumes revenue growth of 6% a year and a contribution margin of 30%. Fixed costs are $42 million a year and interest is $6 million a year, both of which the plan holds constant.

Ridgeway’s borrowing agreement requires interest cover — contribution less fixed costs, divided by interest — of at least 3.0 times.

Required

  • (a) Test the plan’s year-1 interest cover against the covenant.

  • (b) Stress it: revenue flat instead of growing 6%, and the margin down to 26%. Does the covenant hold?

  • (c) With the margin held at 30%, how far can revenue fall below the plan before the covenant breaks — and what does that tell the board?

Show answerHide answer

Stress-testing a strategic plan

(a) The plan as written

Working

$m

Revenue, year 1

200 × 1.06

212.0

Contribution

212.0 × 30%

63.6

Fixed costs

given

(42.0)

Contribution less fixed costs

21.6

Interest cover

21.6 / 6.0

3.60 times

3.60 against a covenant of 3.00, so the plan passes with 0.60 times of headroom.

(b) The stressed case

Working

$m

Revenue, year 1

flat

200.0

Contribution

200.0 × 26%

52.0

Fixed costs

(42.0)

Contribution less fixed costs

10.0

Interest cover

10.0 / 6.0

1.67 times

1.67 against a covenant of 3.00. The covenant breaks, and it breaks badly.

(c) How far can revenue fall?

The covenant needs contribution less fixed costs of at least 3.0 × $6m = $18m, so contribution must be at least 18 + 42 = $60m. At a 30% margin that needs revenue of 60 / 0.30 = $200m.

Revenue can therefore fall from the planned $212m to $200m — a fall of $12m, or 12 / 212 = 5.7% — before the covenant breaks.

What it tells the board. $200m is this year’s revenue. The whole of year 1’s covenant headroom comes from the assumption that revenue grows 6%: if growth is merely zero, Ridgeway is exactly on its covenant, with no margin for anything else at all. That is a finding about an ASSUMPTION, and it is the reason a plan is stress-tested rather than merely appraised. Two further points belong in the answer:

  • the two variables were stressed together in (b) and separately in (c). Sensitivity analysis moves one variable at a time (Chapter 4, section 7), which is why it must not be the only test — the stressed case in (b) is much worse than either variable on its own, and it is also the more likely combination, because flat revenue and discounting usually arrive together;

  • nothing here says how LIKELY any of it is. A stress test asks what would happen, not what will. The board’s next question — and it is a risk-appetite question, not an arithmetic one — is whether it can live with a plan whose covenant compliance depends entirely on hitting its growth number.

6 Understand and assess the scale of the risk

The scale of the risk depends on:

  1. The likelihood that the event will occur; and

  2. The impact of the event.

Of course, these will be estimates, particularly the probability of an event occurring. However, precise figures are not needed, just an idea of whether they are ‘high’ or ‘low’. Nevertheless you will see some mathematical techniques that can be used to quantify events.

A very standard tool to assess the scale of the risk is a risk map — sometimes called a risk heat map. It is not the same thing as an assurance map, which is a different technique, dealt with in section 11:

Severity or impact increases to the right; frequency or probability increases downwards. Four example risks are placed, one in each quadrant.A risk mapLoss of amobile phoneComplete breakdownof the IT systemRoutinestaff turnoverDisruption to flightsat a difficult airportSeverity / impactLowHighLowHighFrequency /probabilityNothing about these placements is absolute — they are one organisation’s judgement.

Note that there is nothing absolute about the categorisation of these risks. For example, the chance of flight disruption has been assessed as high, but that depends on the airports used. Similarly, the loss of a mobile has been categorised as being of low impact – but this wouldn’t be correct if that mobile was the only place where important contact data is held.

The severity of the risk can be estimated by methods such as:

  • Calculation of average/expected loss, largest predictable loss

  • Exposure of physical assets: total loss, repair, decrease in value

  • Exposure of financial assets

  • Exposure of human assets (injury, death, staff leaving)

Obviously, great attention should be given to risks in the bottom right hand quadrant (high/high) whereas those risks in the top left quadrant are less important.

7 The interaction of risks

A risk map treats every risk on its own. Real risks are not independent, and the 2027 syllabus asks specifically for an analysis of the interaction of different risks. Three interactions matter.

7.1 Risks that move together

Two risks that are driven by the same thing will crystallise at the same time. A recession raises the risk of customer default, of falling volumes and of a covenant breach at once — and it does so precisely when the organisation is least able to absorb any of them. Assessing the three separately, and finding each of them tolerable, misses the point. Two risks that always crystallise together are, in effect, one large risk.

7.2 Risks that offset each other

The opposite also happens, and it is why risk is consolidated at group level rather than managed unit by unit (Chapter 3). If one subsidiary earns US dollars and another spends them, the group’s net exposure is smaller than the sum of the two — and a treasury policy that hedged each subsidiary separately would spend money removing an exposure the group does not have.

7.3 Risks that cause each other

Some risks are linked in sequence rather than in parallel. Falling sales produce an inventory-valuation problem and a cash-flow problem; an IT outage produces a service failure, then a compliance breach, then a reputational one. The risk register lists these as separate lines, which is why an event that looks small on its own line can still escalate. The identification checklist in section 2 names both of these effects — escalation triggers and event interdependencies — and they belong to the assessment stage as much as to identification.

The practical consequence for the map: alongside each risk, record what else moves with it. A risk that is amber on its own and red in company with two others has been assessed wrongly if only the first number is written down.

8 Risk response

The risk responses can be remembered by the TARA approach:

Transfer

Methods of transferring risk include insurance, sub-contracting operations or joint ventures (partial transferring). Insurance is, for example, used to protect against risk in motoring accidents. Individuals do not have bad accidents often, but if they do the consequences can be very severe.

Avoid

The risk has been assessed as being so serious that all possibility of the event occurring should be avoided.

Reduce

Take steps to mitigate the risk. For example, instead of installing a new computer system in every branch over one weekend, run a pilot operation then gradually extend.

Accept

Don’t do anything about the risk. It’s just part of everyday business

(You might occasionally see these approaches referred to as the 4Ts: Transfer, terminate, treat, tolerate.)

The four responses can be mapped onto the risk map as follows:

Accept in the low frequency, low impact quadrant; Transfer in low frequency, high impact; Reduce in high frequency, low impact; Avoid in high frequency, high impact.The four responses on the same mapACCEPTlive with it, andkeep it under reviewTRANSFERinsure, subcontract,or share in a joint ventureREDUCEmitigate, so that ithappens less or hurts lessAVOIDdo not do it, orwithdraw from itSeverity / impactLowHighLowHighFrequency /probabilityThe map is a prompt, not an instruction: a risk you depend on cannot be avoided, only reduced.

So, phones are lost (or stolen) from time to time and most people live with that risk (though insurance is always a possibility and might be taken out for very expensive phones).

The complete breakdown of an IT system could be dealt with by outsourcing the system so the supplier shoulders the risk.

Routine staff turnover has costs associated with it (recruitment and training) so better employment policies might be worthwhile to reduce the cost and disruption.

Flights to an airport with very bad weather or safety records might simply be abandoned because they cause more trouble than they are worth.

Mapping four risks and choosing a response

Northgate has estimated, for each of four risks, the probability that it happens in a year and the loss if it does:

Risk

Probability in a year

Loss if it happens

A Loss of one of many small suppliers

0.20

$15,000

B Fire in the finished-goods warehouse

0.02

$2,000,000

C Voluntary turnover of junior staff

0.90

$60,000

D Failure of the order-entry system

0.40

$750,000

Required

  • (a) Compute the expected annual loss of each risk.

  • (b) Say which quadrant of the risk map each falls in.

  • (c) Recommend a TARA response for each.

  • (d) A retention scheme for risk C would cost $22,000 a year and is expected to cut the loss, if it happens, from $60,000 to $25,000. Is it worth doing?

Show answerHide answer

Mapping four risks and choosing a response

(a) and (b)

Risk

Expected annual loss

Quadrant

(c) Response

A

0.20 × 15,000 = $3,000

Low frequency, low impact

Accept

B

0.02 × 2,000,000 = $40,000

Low frequency, high impact

Transfer — insure it

C

0.90 × 60,000 = $54,000

High frequency, low impact

Reduce

D

0.40 × 750,000 = $300,000

High frequency, high impact

Avoid — see the comment below

A word about D. The map says avoid, and an organisation cannot avoid the system it takes its orders on. That is not a failure of the map; it is the point at which the map stops being an instruction. Where avoidance is not available, the response is to reduce hard — resilience, failover, a tested recovery plan — and to keep reducing until the residual risk is inside the appetite. If it cannot be brought inside the appetite, the activity itself has to be reconsidered.

(d) Is the retention scheme worth doing?

Working

$

Expected loss now

0.90 × 60,000

54,000

Expected loss after the scheme

0.90 × 25,000

22,500

Reduction in expected loss

31,500

Cost of the scheme

given

(22,000)

Net benefit

9,500

Yes — but only just, and only on these estimates. The general rule is that the benefit of a risk response must exceed its cost: there is no point in doubling everybody’s pay to shave a little off staff turnover. Note also that the scheme reduces the impact and not the probability. A scheme that reduced the probability instead — better recruitment, so that fewer people leave — would be worth a different amount, and the arithmetic is the same either way.

9 Gross and net risks

It is important to know these terms:

Gross risk = the risk before any mitigation (reduction) procedures. Gross risk is sometimes referred to as inherent risk.

Net risk = the residual risk after reduction and mitigation.

The gross risk is initially dependent on:

  • The asset: what you are trying to protect. For example, property, cash, people, reputation and so on.

  • The threat: what you are trying to protect against. For example, destruction of property, theft of cash, injury to people, damage to reputation.

  • The vulnerability: weaknesses or gaps that can be exploited. For example, no fire alarms, cash not banked, no hand rails on stairs, poor PR.

The gross risk can be reduced to a lower net risk, or residual risk by reducing any of these variables through the application of counter-values or counter-measures.

Management must then decide whether the residual risk is within the organisation’s risk appetite.

Gross or inherent risk is reduced by counter-measures acting on the asset, the threat and the vulnerability, giving net or residual risk, which is then compared with the organisation’s risk appetite.From gross risk to net riskGross risk(inherent risk)Reduce the ASSET at risksplit the inventory over two sitesReduce the THREATno smoking; inspect the wiringReduce the VULNERABILITYsmoke alarms; sprinklersNet risk(residual risk)Is it within the risk appetite?If it is not, the counter-measures are not finished — or the activity itself has to be reconsidered.

Examples:

Asset: the inventory in warehouse; threat: fire; vulnerability: full of inflammable material

Counter values could be:

Asset: reduce the amount of inventory

Threat: impose no-smoking rules (if not already present),

Vulnerability: install smoke detectors and a fire suppression system that is suitable for the type of inventory stored.

Asset: valuable sales manager; threat: moves to a competitor; vulnerability: enticing offers from competitors.

Counter values could be:

Asset: divide sales over two managers (each person is half as valuable).

Threat: impose contracts that require 3 – 6 months’ notice to make moving more difficult

Vulnerability: offer good pay, conditions and prospects.

10 The risk register

Identified risks, their probability of occurrence, impact and responses to them should be entered into a risk register. Typical contents of a risk register are:

  • Description of the risk

  • Date identified

  • Its estimated likelihood of occurrence before mitigation

  • Its likely impact before mitigation

  • Pre-mitigation rating

  • The risk owner (who is responsible for dealing with the risk)

  • Detailed response strategy to the risk (TARA)

  • Its estimated likelihood of occurrence after mitigation

  • Its likely impact after mitigation

  • Post mitigation rating

  • Date by when response should be implemented

  • Date response implemented

  • Signed off by risk owner

The board and risk management committee should take an active interest in the risk register to ensure that identified risks have been satisfactorily dealt with.

11 Assurance mapping

Risk identification and risk mapping identify the problems and their severity, but those processes are a waste of time if suitable responses are not made. The risk register is one way to record risks and to assign responsibilities for mitigating the risks where necessary. Another approach to ensure that risks are properly dealt with is to construct an assurance map. The aim of an assurance map is to identify where the safeguards against risks are to be found.

An assurance map sets out where an organisation’s assurance over each risk comes from. The roles that provide it are conventionally grouped into three:

Role

Who

The assurance it gives

Governing body

The board, and the committees it delegates to

Accountability to stakeholders for oversight. It sets the appetite, requires the structures, and receives the reporting; it does not provide assurance to itself.

First line

Management, running the business

The controls built into the work itself — authorisation, reconciliation, segregation of duties, physical controls, quality checks. Assurance from the people who own the risk.

Second line

Management, in specialist support roles

Risk management, compliance, health and safety, information security, quality assurance: expertise, policy and challenge, still inside management.

Third line

Internal audit

Independent and objective assurance on whether the first and second lines are working, reporting to the governing body rather than to the management it examines.

External providers

Outside the organisation

External audit, regulators, actuaries, consulting engineers, certification bodies. Not one of the three roles, but a real source of assurance that an assurance map should show.

Some organisations group the roles differently, and the grouping matters less than the question the map is asking: for this risk, who is doing something about it, and is that enough?

A table is then drawn up listing the risks, how important each one is, and what assurance each role actually provides over it. For example:

Risk

First line

Second line

Third line

External

Assurance required

Finance: liquidity and gearing

Strong

Moderate

Moderate

Moderate

High

IT and information security

Moderate

Strong

Moderate

Strong

High

Health and safety

Strong

Strong

None

Moderate

High

Human resources: retention

Moderate

Moderate

None

None

Medium

Supplier conduct

Weak

None

None

None

High

The last column is the one that makes the map usable. Without a view of how much assurance each risk NEEDS, a row of three “moderate” entries cannot be judged: moderate assurance may be ample for a medium risk and quite inadequate for a high one.

Read it row by row. Two rows are doing what they should: finance and IT have assurance from several sources, and the strongest source is in the place you would expect. Three rows are findings:

  • health and safety has strong first-line and second-line assurance and nothing independent at all. If the supervisors are wrong, nobody would know;

  • retention is a medium risk with only moderate assurance and no independent source. That may be an acceptable answer — it is a medium risk — and the map’s job is to make the choice visible rather than accidental;

  • supplier conduct is a high risk with weak assurance from one source and nothing anywhere else. That is a gap, and it is the row the board should be asked about.

The map also finds the opposite problem: a low-importance risk with four strong sources is over-assured, and the effort spent on it is effort not spent on the row above.

Older material — including this chapter’s own lecture — calls these the “three lines of defence”. The Institute of Internal Auditors replaced that model in 2020 with the Three Lines Model, and the change is more than a name. “Defence” described the roles as though their only job were to stop bad things happening; the current model describes them as roles that support the achievement of objectives, makes the governing body an explicit part of the picture, and stops treating the three as a rigid sequence — the second line challenges the first continuously rather than catching what it drops. The substance of what each role does is unchanged, which is why an assurance map built on either version looks much the same.

12 Test your knowledge

Two quick checks before you move on: work through the flashcards to fix this chapter’s key terms and definitions, then sit the objective questions for exam-style practice. Both mark themselves and explain the answers as you go.

Practice questions

Responses to risk

12 questions

Answer the questions one at a time. Your progress is saved so you can leave and come back.

Open chapter practice