In today’s edition of Daily Compliance News:
Tag: Supply Chain
Welcome to the newest addition to the Compliance Podcast Network, Compliance and Coronavirus. As the Voice of Compliance, I wanted to start a podcast which will help to bring both clarity and sanity to the compliance practitioner and compliance profession during this worldwide health and healthcare crisis. In this episode, I am joined by Matt Whitaker, Vice President, Growth at Assent Compliance. We visit Assent’s COVID-19 Supply Chain Impact Map, and how it assists companies, the data that Assent Compliance is seeing from it and where Supply Chains will go in the new normal of Covid-19.
You can use the Assent Compliance Covid-19 Supply Chain Impact Map to visualize and assess the impact of the Coronavirus on your supply chain, by clicking here. The COVID-19 Supply Chain Impact Map is a free tool that overlays COVID-19 data onto supply chain maps, providing visibility into its impact on key suppliers and shipping hubs. This enhanced transparency provides companies with the information required to make informed business decisions, and adapt to supply chain and market access disruptions.
In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I have explored the market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, CSR value propositions, the current state of responsible mineral sourcing and where all of this is headed. In this fifth and concluding episode, I visit with Jonathan Hughes, Director, Strategic Relationships at Assent Compliance. We considered how the market impacts are driving the need for more technology-based solutions for supply chain management.You can check out more about Assent Compliance Inc. at their website, by clicking here.
In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, Corporate Social Responsibility (CSR) value propositions, the current state of responsible mineral sourcing and where all of this is headed. In this episode, I visit with Sarah Carpenter, Manager, Business and Human Rights for Assent Compliance on the value proposition of CSR for corporations. Join us tomorrow where we consider the current state of conflict minerals/responsible minerals with Jared Connors? You can check out more about Assent Compliance Inc. at their website, by clicking here.
In this five-part podcast series, sponsored by Assent Compliance Inc. (Assent), I explore market impacts of emerging regulations on supply chain compliance and the supply chain professional. During the course of this series, I visit with several members of the Assent team to introduce the topic, look at Human Trafficking and Slavery (HTS), supply chain risk management programs, CSR value propositions, the current state of responsible mineral sourcing and where all of this is headed. In this second episode, I visit with Jared Connors, subject matter expert for Assent Compliance on Corporate Social Responsibility (CSR) on how to institute a broader supply chain risk management program. Join us tomorrow where we ask, ‘what’s your CSR value proposition’? You can check out more about Assent Compliance Inc. at their website, by clicking here.
Highlights include:
- Have you checked out the new OFAC compliance program? If not see Mike Volkov’s 5-part series on Corruption, Crime and Compliance. (Part 1, Part 2, Part 3, Part 4) For those who prefer the podcast format, you can list to his podcast on the topic here.
- Hui Chen and Pam Davis weigh in on the 2019 DOF FCPA Guidance. In Bloomberg.
- Noose tighten around Credit Suisse and Privinvest in Mozambique tuna boat scandal? Rick Messick explores in Global Anti-Corruption
- What are the compliance lessons from a messy and very public food fight? Matt Kelly explores in two postings on Radical Compliance. (hereand here)
- How does scape-goating come into play in cross-border anti-corruption enforcement? Laurent Cohen-Tanugi discusses on NYU’s Compliance and Enforcement Blog.
- Jay continues his exploration of using a monitor, in his Corporate Compliance Insights
- What do dawn raids have in common with fires (at least in the UK)? Barry Vitou explores on com.
- Is Equifax about to settle for its massive data breach? Jon Rusch explores on Dipping Through Geometries.
- Why should compliance training start with a smile? Ronnie Feldman explains on Corporate Compliance Insights.
- What are the compliance lessons for hospitality around major sporting events? Tom explores in a white paper on Corporate Compliance Insights.
- This week Tom had a special 5-part podcast series sponsored by Assent Compliance on the issue of maintaining market access. Check out the following: Part 1-Introduction to Market Access; Part 2-Trade Compliance; Part 3– Continuous Monitoring; Part 4-FARs and flow downs; Part 5-Chemical and Product Compliance. The podcast is available on multiple sites: the FCPA Compliance Report, iTunes, JDSupra, Megaphone,YouTube, Spotifyand Corporate Compliance Insights. The Compliance Podcast Network
- Join Tom in Boston for industry leading Compliance Master Class at the offices on AMI on June 11 & 12. Listeners who attend will receive a complimentary copy of The Compliance Handbook. Registration and Information is here. Join Tom, Eric Feldman, Vin DiCianni and Jay at the AMI Roundtable in Boston on June 13 for a deep dive into the DOJ’s new Evaluation of Corporate Compliance Programs-2019 Guidance. Information and registration is here.
Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.For more information on how an independent monitor can help improve your company’s ethics and compliance program, visit our sponsor Affiliated Monitors at www.affiliatedmonitors.com.
I began by asking Gellert the following: What is the ability of the compliance procurement, credit professional and other cross functional areas to have seamless communication of their data analytics and findings? Obviously, this is vitally important with a hindrance of siloed information across those different business units. He stated, “what we are finding is the most evolved and sophisticated risk management programs are making sure that each one of those areas that may touch on risk is in some form or another connected with the others on findings, so there’s efficiency in that process”; from the Chief Information Officer (CIO) to the Chief Compliance Officer (CCO) to the Chief Financial Officer (CFO).
This means that data and analytics should be shared across business units to benefit from the supply chain. Continuous monitoring and understanding that when a company is deteriorating its financial health could be an indicator of problems. Further, fraud, and even corruption, is more likely to occur when the company is weak and under extreme financial duress and pressure. This is why having a leading indicator like the Financial Health Rating (FHR) is critical because it can communicate to a compliance professional when a company is weakening and enables a risk management to be focused on those suppliers who require a more focused risk management solution.
Gellert related that another “big part of it is making sure that everyone in your organization is speaking from a common language and that the analysis and the findings are shared. This means developing workflow efficiency and also creating a return on the investment for an overall risk management program.” It also allows companies to help their suppliers. Finally, it allows your organization to have a dialogue with suppliers. “It comes from transparency around financials and other risk areas and being able to perform the appropriate risk analysis that can be fostered through a dialogue. The more a company understands the problems that its supplier may have, the more it can do things to help that supplier through those problems.”
The bottom line is that companies want to continue to work with their suppliers. It is not good or even efficient business to engage in looking for ways to stop working with them. The more a business can work with a supplier in a collaborative way to help them through times of difficulty benefits everyone and allows a company that is engaged in risk management and invested in a risk management process to be able to demonstrate the return on investment to the finance side of an organization.
With this process in place, you can develop a well mapped out workflow for handling problems when they arise so that if one comes up, it allows your organization to repurpose and reuse the workflow. Gellert said it “allows for maximum leverage, maximum workflow efficiency.” Once the “tools necessary to put these systems and process are in place, they can be replicated.” Lastly, “When that occurs, the business efficiency and the gain that can come from this kind of an analysis on financial health and other risk areas really does pay dividends in the companies that do it, I think are benefiting significantly across all the different business units that it touches.”
Gellert concluded, “It’s about creating ecosystem that can grow with your business. When your business is doing well, the last thing you want to do is have the opportunity to expand, but then all of a sudden there is a problem in your supply chain that you could have avoided, but you were not being proactive enough to do so. It is very much about creating the most resilient supply chain where you are reducing risks, but you’re also expanding the opportunities to grow over time.” This is the real supply chain efficiency premium.
This podcast series is sponsored by Rapid Ratings International, Inc. For more information, check out their website at www.rapidratings.com.
Gellert began by observing that organizations are aligning their suppliers and supply chain to be the more resilient to market volatility. With this increased volatility, suppliers need to be able to go through such periods and come out on the other side still in good business and financial health. This certainly contributes to the longer-term core health of a company. Another area critical to understanding your business risk is “what the two to three-year perspective is on a company as well as the one-year perspective. Companies tend to try to align themselves with suppliers that have strong core health so they will be around, be trusted, be nimble and agile over the next handful of years.” However, even if you wanted to avoid all risks, your organization cannot do so. This means you must work to manage risk. But with greater risk this usually means greater business opportunity.
It really turns on getting “full risk visibility”. As Gellert noted, “one cannot manage the unknown risks that can occur in unknown.” This goes to the big risks such as is now going on in the UK with the Brexit imbroglio that Parliament has put not only itself but the British nation into. Gellert said, “Everyone knows that Brexit is extremely important for the companies that are affected in the UK and in Europe, but without a resolution on what the Brexit plans going to be, no one really knows how much. This uncertainty is affecting companies and the management of their supply chains in all sorts of ways.” But even turning away from such massive unknowns as Brexit, down to a much more macro environment, Gellert believes “it is important for people to recognize that over the last 10 years this country has been in an incredible credit market, with artificially low interest rates and investors scrambling down the credit curve to find yield wherever they can.” It will end and are you ready from a supply chain risk management perspective?
While the easy credit market has bolstered the low end of the credit markets so that weak or inefficient companies have had access to capital and been able to raise money at inexpensive rates; as the market begins to change you will see more volatility in the market, higher interest rates, therefore higher costs of capital. This means that over the next couple of years, companies will be unable to refinance the debt that they have so easily financed over the last few years. Gellert believes this is “going to cause a lot of problems because private companies and smaller businesses will have a harder time raising money and that will affect their ability to expand and just deliver on goods that have obligations to deliver on.” This translates to supply chains as a convergence of factors wreaking havoc over the next few years on supply chain risk management.
We then turned to cyber risk, which is one of the, if not the, hottest risk management issues for a variety of parties, sectors and relationships for 2019 being discussed at the Board level. While this topic gets a fair amount of attention when someone starts to work with a new supplier, it gets less attention in the continuous monitoring of those suppliers. Gellert says that you must “be able to look over time during the lifecycle of working with a company on whether they’re able to continue to invest in state-of-the-art information technology systems that will allow them to avoid those cyber risks or manage those cyber risks. And companies that are weakening in financial health have less flexibility to be able to invest in the other areas that are in areas that are going to protect or expose their customers and other counterparties to risk cyber being one.”
RapidRatings has found more correlations between financial health ratings and the weak companies that carry high financial risk and their ability to deliver a quality product. The ability to deliver on time and the ability to invest in cybersecurity programs are all interconnected. Gellert sees that “They really need to be viewed as interconnected elements and not looked at as a separate topics and separate risks. The more sophisticated risk management programs are evaluating them as connected risks and making sure that their suppliers have programs in place to try to be able to spot problems before they exist.” This is another facet of getting transparency and a collaborative relationship with suppliers to discuss these problems before they become crippling events so that you can review and remediate them as they are potentially emerging. It means, above all, being proactive and understanding the interconnected relationship involved.
Many compliance practitioners and supply chain professionals understand the need for due diligence but that is only the starting point. It is the starting point for an ongoing relationship and ongoing dialogue, ongoing monitoring companies with more mature compliance programs certainly understand that in the supply chain realm. More and more companies are embracing this process. Gellert stated, “it is being able to action the analytics and action the data that emerges from the risk management itself to be able to build a more cohesive risk management process. It’s really about linking all of those through the business units of a company that may touch on the risk management of an individual supplier as well as the supply base as a whole.”
Please join us tomorrow when we conclude the series by considering the supply chain efficiency premium going forward.
This podcast series is sponsored by Rapid Ratings International, Inc. For more information, check out their website at www.rapidratings.com.