Categories
Innovation in Compliance

Innovation in Compliance-Part 1: What is Supply Chain Financial Health?

Welcome to a special five-part podcast series on innovation in managing third party risk. This week I am joined by James H. Gellert, the Chairman and Chief Executive Officer (CEO) of Rapid Ratings International Inc. (RapidRatings), the sponsor of this special series. Our conversation is around helping companies manage their third-party supply chains through assessing financial health. The RapidRatings approach is incredibly innovative, with a series of products and services that should be considered by the compliance practitioner. In Episode 1, we begin with a discussion of why managing your supply chain risk is so critical in today’s business environment.
Supply chain risk management as a discipline that has been evolving significantly but still has a long way to go. Gellert began by noting that supply chain risk really means all third-party risk. These risks are getting more diverse from a geographic perspective as well as from a technology perspective. It can come from more aggressive mergers and acquisitions (M&A) activity, organic company expansion or an organization simply getting more creative with outsourcing and working with different kinds of companies for different solution sets. It also means that this group of third parties have the ability to impact businesses, both positively and negatively.
Too many suppliers can certainly be inefficient. This means that many companies are trying to trim down the numbers of third-parties with which they are working. This could be through  adjusting time or implementing lean types of philosophies around supply chain. This makes  each third-party partner more important and criticality is something that can be measured in lots of different ways. Gellert said it raised such questions as: “How much money you spend on a company? How much access will your third parties have access to company information? How much access will they have to your IT systems? All of these things have led to the evolution of a much more complex supply chain that people have to manage and they contain more risks.”
I asked Gellert how managing the risk and supply chain is different than managing on the sales side? He began by noting that there is “definitely overlap when looking at third parties.” Yet the more sophisticated method is a “360 degree” approach which means to look all aspects of the relationship. In the anti-corruption world, the focus has typically been on the sales side. But it can also “mean suppliers all the way through to customers and intercompany affiliates and so forth.” Another approach from the compliance perspective has been upon knowing your customer (KYC). Gellert stated, “Customer risk is inherently more transactional than supply chain risk, in part because of who’s buying and who’s selling. When you are selling to someone, you are evaluating their ability to pay you. In this situation an organization needs to make sure that the company is one you want to do business with, that’s going to be able to pay you on time and in the terms that determined are economical for you”
However, “when you are looking at suppliers, you’re buying from them, whether it’s a supplier of a product or a vendor of a service. You may have a five-year product cycle, a 10-year product cycle. If the suppliers your company is embedding into that portion of your business are not strong for the long-term or are not resilient, then you have problems that you are baking into the ecosystem of companies with which you are working.” Gellert concluded, “I think probably the biggest difference in customer evaluation and supply chain evaluations, you need to be able to understand the risks of those companies over the long haul as well as the short-term risks. So, you can avoid the short-term problems that could arise from a weak supplier.” It also means that you are “baking in the most resilient and strong long-term partners to work with, as you possibly can, into your organization.”
One of the frustrations for compliance professionals is that they do not know how far down the third party or supply chain they should go to either evaluate or manage the risk. They may understand who to go to for a direct counter-party, their immediate counter party, their first party supplier or their first party sales agent, they may certainly understand managing that risk. I asked Gellert how about much farther down the chain a compliance practitioner should begin to look at that issue? He said it can be quite complicated but that is where a technological solution can help.
He began by stating, “it’s not just first tier, second tier, third tier supplier in your supply chain may affect you.” One of the reasons it is so difficult for the compliance professional is there are so many areas you must consider. Gellert said these can include, “fraud detection, anti-money laundering, anti-corruption considerations and making sure that no one appears in a sanctions list. All of these things get more difficult exponentially as you go deeper into a supply chain and the people on supply chain risks sides who have been looking at delivery risk and logistics and other operational aspects including finance and newer elements like cybersecurity It gets really hard when you’ve got to go to your supplier’s supplier.”
The bottom line is that there is not a really good answer for this except that collaboration between a company and its first-tier supplier is really essential to understand what the second and third tier supplier risks will be. Unfortunately, “many times organizations do not even know who their second tier supplier is for particular good or product or service because the tier one supplier has been delivering fine and there has been no need to find out how or where that tier one is getting the parts that they are bringing in.” Gellert conclude by noting, this “is changing but needs to change more. It really does start with collaboration and an understanding between the company and its tier one suppliers that understanding the risk deeper than that is going to be important and beneficial to everybody involved in that chain.”
Please join us tomorrow when we consider the issue of criticality in supply chain risk management.
This podcast series is sponsored by Rapid Ratings International, Inc. For more information, check out their website at www.rapidratings.com.
Categories
FCPA Compliance Report

FCPA Compliance Report-Episode 424, David Childers on the New ECI Self-Assessment Tool

In this episode I visit with David Childers, the Senior Vice President at Ethics & Compliance Initiative (ECI). We discuss ECI’s High-Quality Ethics & Compliance Program (HQP) Self-Assessment Tool.

Some of the highlights from the podcast include:
What are the 5 Principals of a HQP? They include: Strategy, Risk Management, Culture, Speaking Up and Accountability.
What are the 5 operational areas of an E&C program? They include:

  • E&C is central to business strategy
  • E&C risks are identified, owned, managed and mitigated
  • Leaders at all levels across the organization build and sustain a culture of integrity
  • The organization encourages, protects and values the reporting of concerns and suspected wrongdoing
  • The organization takes action and holds itself accountable when wrongdoing occurs

What is the design of the Self-Assessment tool? While the methodology is fairly complex, for the participant it is only 107 multiple choice questions and it takes less than 30 minutes to complete.
What is it designed to measure? The HQP Assessment measures program maturity based on a combination of questions regarding 27 operating components and more than 100 program practices.
What are the four categories of reporting information for each principal? They include:(1) What to measure/review; (2) Questions to consider ; (3) Potential sources of information and (4) Leading practices illustrative of HQPs.
What are the five-point scale for program maturity? Program maturity is based on five levels, which are represented on a 0-100 scale.

  • UNDERDEVELOPED
  • DEFINING
  • ADAPTING
  • MANAGING
  • OPTIMIZING

The HQP Assessment tool is a measure of where an organization believes their E&C program operates based on the five principles.   The assessment can be used in several ways.  We have organizations that are looking for program improvement. The assessment can be a baseline for measured improvement.   It can also be a qualification.  As we said this isn’t about a score.  In some industries, being at the managing level of maturity may be sufficient for their risk.  Most of all it is a great way to create dialog and discussion with your leadership using a definitive measure of your program.
How will ECI use this information going forward? We are already seeing important trend and insights from the data. We will introduce many of these findings are our Annual Conference in Dallas, and we are developing working groups within our membership to explore some the findings to refine best practices and guidelines for program improvement.
For more information on the ECI Self-Assessment Tool, go to www.ethics.org
Registration and Information on IMPACT2019 here.

Categories
Daily Compliance News

Daily Compliance News: April 1, 2019-the Not April Fool’s edition

APRIL 1, 2019 BY TOM FOX


In today’s edition of Daily Compliance News:

  • GOP congressmen threaten to kill NAFTA 2. (Washington Post)
  • CBS Credit Union shut down as one employee embezzled $40MM. (Deadline)
  • Scott Moritz on why every college should now perform a root cause analysis. (Protiviti)
  • What does Occam’s Razor have to do with blockchain? (McKinsey White Paper)