Page 69 - COSO Guidance

Enterprise Risk Management | Compliance Risk Management: Applying the COSO ERM Framework | 29

Principle 20 — Reports on risk, culture, and the reporting gets to the department head/manager level,
performance information should focus on what is needed to manage
Closely related to the communication of risk information is compliance risk in that area, although periodic reporting on
reporting on risk, culture, and performance associated with organization-wide risk may provide helpful context.
compliance-related risks. These stakeholders include the
board of directors, any board-level committee delegated the Reports on compliance risk management should address
responsibility of compliance risk oversight (if one exists), the externally generated risks as well as those that result from
senior executive team, any internal compliance committee (if the internal risk universe (e.g., employee acts). Third-party
one exists), and appropriate managers/heads of departments risk management is an important element of a C&E program.
or functions within the organization. Reporting to these groups Accordingly, reports should be prepared and distributed
should be tailored to the unique needs and responsibilities of to appropriate stakeholders on the status of third-party
each, as should the frequency of reporting. suppliers, sales agents, and others who could create risk for
the organization. These reports should focus on the results of
For example, reporting to the board should focus on what third-party due diligence efforts in the selection or continued
is needed for the effective oversight of the entire C&E use of vendors and other third parties, site visits, auditing and
program — information about the risk assessment process, monitoring procedures, training provided to third parties, and
identification of the most material risks and actions being any other matter associated with managing this area of risk.
taken in response to those risks, meaningful compliance
metrics addressing both the structural and substantive One final aspect of reporting that is critical to C&E program
performance of the program, information about compliance- effectiveness is documentation. Typically, documentation
related investigations, resource allocations and needs, etc. involving investigations is maintained and reviewed only by
Reporting to the board should also periodically address the compliance, legal, and/or investigations team. It is crucial
culture as it pertains to compliance and ethics. Culture can to properly handle, preserve, and maintain these materials
be a difficult area to assess; however, efforts should be made and records in the event of legal action or government
to provide the board with some perspective and trends on inquiry. Each compliance-related investigation should be
organizational culture associated with compliance and ethics. well documented, include a timeline of events and key steps/
This may be accomplished through employee surveys; data actions taken along the way, and summarize any remedial
associated with culture; and other less formal methods, such steps. Whether a formal case management software tool is
as interviews and focus groups. used or something simpler is utilized, maintaining this record
is an important part of a C&E program. From these records,
As reports are designed for each level in the organization useful reports can be generated that provide insight into the
chart, the information included should be more granular needs and effectiveness of the investigations element of
and customized to the needs of each layer. By the time compliance risk management.

Table 6.3 Reports on risk, culture, and performance
Key • Provide periodic reports on compliance and ethics risk assessments and related remediation efforts tailored to
characteristics key stakeholder needs
• Develop and report on meaningful operational and substantive metrics associated with the effectiveness of
the C&E program
• Provide managers with reports on completion and results of training of their direct reports
• Use a case management and reporting system for investigations and outcomes
• Establish and follow a policy that clearly articulates the nature of reporting on all significant remediation
efforts

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