You are on page 1of 169

HARBIF Version: 2

HOLISTIC APPROACH TO RISK – BASED Revision: 0


INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 1/169

HARBIF
HOLISTIC APPROACH TO
RISK – BASED INTERNAL FINANCIAL
CONTROL FOR SMEs
Applying
Integrated Risk Management Scenarios

Co-Authors
Éva Sándor-Kriszt Ph.D. (BBS), János Ivanyos (BBS), Ganite Kurt Ph.D. (GU)
and Tuğba Uçma Uysal Ph.D. (MU)

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 2/169

Amendment history

Version Revision Date Pages Author Modification


1 0 27.12.2013 All JI (BBS), TU (MU) first version based on kick-off meeting discussions
1 1 18.01.2014 All JI (BBS) Chapter 4 and Annex A added
1 2 21.01.2014 All JI (BBS) Annex B added
2 0 11.10.2014 All JI (BBS), EK (BBS), final review and content edition
GK (GU), TU (MU)

Distribution list
Project partners
Project Officer
External Reviewers

Quality System References

ISO 9001 compliant planning and review processes are applied.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 3/169

Contents

1. INTRODUCTION....................................................................................................................................................6
1.1 OBJECTIVE .............................................................................................................................................................. 6
1.2 PURPOSE OF THE DELIVERABLE ................................................................................................................................... 6
1.3 SCOPE OF THE DELIVERABLE ....................................................................................................................................... 6
1.4 THE HARBIF PROJECT .............................................................................................................................................. 7
1.5 ACRONYMS USED .................................................................................................................................................... 8
1.6 REFERENCES ........................................................................................................................................................... 9
2. APPLIED PRINCIPLES........................................................................................................................................... 10
2.1 THE NEED FOR RISK-BASED ENTERPRISE GOVERNANCE IN STRENGTHENING BUSINESS TRUST BY SMES .................................. 10
2.2 RISK MANAGEMENT PRINCIPLES SUPPORTING ENTERPRISE GOVERNANCE ......................................................................... 11
2.3 THE HOLISTIC APPROACH BY IMPLEMENTING ENTERPRISE GOALS DRIVEN INTEGRATED RISK MANAGEMENT SCENARIOS ............ 13
2.4 APPLICABLE GOVERNANCE OBJECTIVES FOR SMES ....................................................................................................... 15
2.5 GOVERNANCE CAPABILITY ASSESSMENT FOR SUPPORTING HOLISTIC APPROACH................................................................. 16
2.6 LINKING GOVERNANCE OBJECTIVES TO ENTERPRISE GOALS & MEASURES ......................................................................... 18
2.7 SPECIAL APPLICATION AREA FOR SMES: ASSURANCE OF SERVICE ORGANIZATION’S CONTROL .............................................. 19
3. INTEGRATED RISK MANAGEMENT SCENARIOS SUPPORTING ENTERPRISE GOVERNANCE .................................. 21
3.1 COMMENTS FOR IMPLEMENTING INTEGRATED RISK MANAGEMENT SCENARIOS ................................................................. 21
3.2 MANAGING OPERATIONAL PERFORMANCE ................................................................................................................. 26
3.2.1 Context and Specific Learning Objectives of Managing Operational Performance .................................. 26
3.2.2 Selecting the Scope of the Management Assertions for Managing Operational Performance ................ 30
3.2.3 Defining Process Outcomes for Managing Operational Performance ...................................................... 33
3.2.4 Applying Generic - Level 2 - Managed Capability Indicators as Risk Criteria for Performance Goals ....... 35
3.3 MANAGING PERFORMANCE RELIABILITY ..................................................................................................................... 36
3.3.1 Context and Specific Learning Objectives of Managing Performance Reliability...................................... 36
3.3.2 Selecting the Scope of the Management Assertions for Managing Performance Reliability.................... 40
3.3.3 Applying Management Assertions for Managing Performance Reliability ............................................... 46
3.3.4 Selecting Specific Application Practices as Risk Criteria for Reliability Goals ............................................ 48
3.4 MANAGING OPERATIONAL EFFECTIVENESS ................................................................................................................. 50
3.4.1 Context and Specific Learning Objectives of Managing Operational Effectiveness .................................. 50
3.4.2 Selecting the Scope of the Management Assertions for Managing Operational Effectiveness ................ 54
3.4.3 Applying Management Assertions for Managing Operational Effectiveness ........................................... 59
3.4.4 Selecting Specific Application Practices as Risk Criteria for Operational Effectiveness Goals................... 61
3.5 MANAGING STRATEGIC DIRECTIONS .......................................................................................................................... 63
3.5.1 Context and Specific Learning Objectives of Managing Strategic Directions............................................ 63
3.5.2 Selecting the Scope of the Management Assertions for Managing Strategic Directions.......................... 67
3.5.3 Applying Management Assertions for Managing Strategic Directions ..................................................... 72
3.5.4 Selecting Specific Application Practices as Risk Criteria for Strategic Directions ...................................... 74
3.6 MANAGING OPERATIONAL RISKS .............................................................................................................................. 76
3.6.1 Context and Specific Learning Objectives of Managing Operational Risks ............................................... 76
3.6.2 Selecting the Scope of the Management Assertions for Managing Operational Risks ............................. 80
3.6.3 Applying Management Assertions for Managing Operational Risks ........................................................ 85
3.6.4 Selecting Specific Application Practices as Risk Criteria for Managing Operational Risks ........................ 87
4. GOVERNANCE PROCESS DESCRIPTIONS REFERRED BY THE INTEGRATED RISK MANAGEMENT SCENARIOS ........ 90
4.1 GOVERNANCE OF CONTROLLED BUSINESS OPERATION - APPLICATION CATEGORY............................................................... 91
4.1.1 Control Risks.............................................................................................................................................. 92
4.1.2 Control Management ................................................................................................................................ 96

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 4/169

4.1.3 Control Competence.................................................................................................................................. 99


4.1.4 Information Reliability ............................................................................................................................ 103
4.1.5 Process Control ....................................................................................................................................... 106
4.1.6 Data Protection ....................................................................................................................................... 110
4.1.7 Integrity Assurance ................................................................................................................................. 115
4.1.8 Control Efficiency .................................................................................................................................... 119
4.2 GOVERNANCE OF SUSTAINABLE BUSINESS OPERATION - APPLICATION CATEGORY ............................................................ 123
4.2.1 Competitive Operation ............................................................................................................................ 124
4.2.2 Exploitable Operation ............................................................................................................................. 127
4.2.3 Satisfactory Operation ............................................................................................................................ 131
4.3 LINKING GOVERNANCE PROCESSES TO SUSTAINABLE VALUE CREATION........................................................................... 134
ANNEX A: SAMPLE METRICS OF APPLICATION PRACTICES FOR SETTING RISK CRITERIA........................................... 135
ANNEX B: EVALUATING RESIDUAL RISK STATUS BY USING ISO/IEC 15504 CAPABILITY ASSESSMENT ...................... 164

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 5/169

Figures

Figure 1: Enterprise Goals driven Integrated Risk Management scenarios .......................................................... 13


Figure 2: Applicable Governance Objectives for SMEs maintaining Trusted Businesses .................................. 15
Figure 3: The Holistic Approach supported by Governance Capability Assessment (Governance SPICE) .... 16
Figure 4: Linking Governance Objectives to Enterprise Goals & Measures ......................................................... 18
Figure 5: Integrated Risk Management Scenarios with Enabling Governance Processes................................. 21
Figure 6: ISO/IEC 15504 Process Capability Levels and Attributes applicable for Risk Appetite Statements 22
Figure 7: Role of the Managing Operational Performance scenario in Enterprise Governance ........................ 26
Figure 8: Four point ordinal scale for evaluating the achievement of process attribute ...................................... 34
Figure 9: Role of the Managing Performance Reliability scenario in Enterprise Governance ........................... 36
Figure 10: Role of the Managing Operational Effectiveness scenario in Enterprise Governance ..................... 50
Figure 11: Role of the Managing Strategic Directions scenario in Enterprise Governance ................................ 63
Figure 12: Role of the Managing Operational Risks scenario in Enterprise Governance ................................... 76
Figure 13: Control Efficiency considerations in context of risk treatment costs.................................................... 84
Figure 14: Example target and assessed process capability profiles .................................................................. 165

Tables

Table 1: Operational Performance related risk areas ............................................................................................... 31


Table 2: Satisfaction related risk areas....................................................................................................................... 41
Table 3: Accuracy related risk areas ........................................................................................................................... 42
Table 4: Data Protection related risk areas ................................................................................................................ 44
Table 5: Exploitability related risk areas ..................................................................................................................... 55
Table 6: Process Integrity related risk areas.............................................................................................................. 57
Table 7: Competency related risk areas ..................................................................................................................... 58
Table 8: Competitiveness related risk areas .............................................................................................................. 68
Table 9: Accountability related risk areas................................................................................................................... 70
Table 10: Commitment related risk areas .................................................................................................................. 71
Table 11: Risk Awareness related risk areas ............................................................................................................ 81
Table 12: Control Efficiency related risk areas .......................................................................................................... 83
Table 13: Application Practices of Satisfactory Operation with possible metrics ............................................... 135
Table 14: Application Practices of Exploitable Operation with possible metrics ................................................ 139
Table 15: Application Practices of Competitive Operation with possible metrics ............................................... 147
Table 16: Application Practices of Control Risks with possible metrics ............................................................... 153
Table 17: Application Practices of Control Efficiency with possible metrics ....................................................... 158
Table 18: Risks associated with capability levels .................................................................................................... 167
Table 19: Internal Financial Control process related risk assessment example - 1 ........................................... 168
Table 20: Internal Financial Control process related risk assessment example - 2 ........................................... 168
Table 21: Internal Financial Control process related risk assessment example - 3 ........................................... 168

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 6/169

1. Introduction
1.1 Objective

The objective of this deliverable is to provide a handbook for the risk-based internal financial control trainings
by presenting how the Integrated Governance Capability Assessor and Internal Financial Control
Assessor skill cards [1] are applicable to use Integrated Risk Management scenarios in supporting the
implementation of the risk-based internal financial control system for SMEs. These Integrated Risk
Management scenarios are taking the governance objectives of the Governance Model for Trusted
Businesses [2] into the context of the operational and organizational levels and their specific business goals
relevant for SMEs.

1.2 Purpose of the Deliverable

The deliverable presents:


• the principles applied
• the Managing Operational Performance scenario
• the Managing Performance Reliability scenario
• the Managing Operational Effectiveness scenario
• the Managing Strategic Directions scenario
• the Managing Operational Risks scenario
• the 11 process descriptions of the Governance Model for Trusted Businesses
• examples for setting risk criteria and assessing residual risk status

by referring to and using of the following public deliverables of the MONTIFIC and BPM-GOSPEL Leonardo
da Vinci EU projects:
• Integrated Governance SPICE Assessor and Internal Financial Control Assessor skill cards
• Governance Model for Trusted Businesses

1.3 Scope of the Deliverable

The deliverable contains


• A chapter about principles applied
• A chapter covering the 5 Integrated Risk Management scenarios
• A chapter presenting the 11 process descriptions of the Governance Model for Trusted Businesses
• An Annex of sample metrics of application practices for setting risk criteria
• An Annex presenting process related risk assessment for determining residual risk status

Presentation of the 5 scenarios (in chapter 3) follows similar structure and contains some
overlapping information allowing even separate usage of any scenario as specific business
case for implementing enterprise goals driven Integrated Risk Management.

The deliverable does not contain:


• the full version of the Integrated Governance SPICE Assessor and Internal Financial Control
Assessor skill cards
• the detailed information described in the ISO 31000 and ISO/IEC 15504 standards
• the detailed technical manuals and user guides of the assessment methodologies applied
• the business case study reports.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 7/169

1.4 The HARBIF Project

It is noted by a report published by the European Commission about SMEs in 2011 that SMEs has a key role
in shaping out European economy with a share of 99 %. SMEs in Europe provide employment for 2/3 of the
private sector and constitute priority areas in terms of development of European economy. In this framework,
it is one of the priority issues to render SMEs, which have a significant place in European economy over the
EU’s growth strategy entailing future periods, compatible with the changing requirements of business
community. Taking these explanations as a starting point, it may well be pointed out that the Small and
Medium Enterprises (SMEs) have a major role in terms of economic and social welfare level and
development, particularly with respect to increased national income, tax revenues and contributions to
employment in a country. The internal control systems of SME’s which have such an influential role as part of
economy are generally omitted. In particular, the financial crises experienced, accounting and audit
standards regulations emerging as a result of acceleration of approximation efforts from 2009 onwards as
regards Basel II Framework, 8th Directive on Company Law and continuous audit practices which are
frequently focused on give rise to the requirement that there is concentration on internal financial control
models in the SMEs. Objectives in development of risk based internal financial control model in terms of the
SME’s:

• To provide reasonable assurance over attainment of enterprise targets as an instrument for


implementation of an effective risk management in the SMEs
• Giving encouragement and support to the provision of training activities for both managers and internal
auditors/internal controllers in SMEs;
• Developing internal financial control systems based on updated COSO framework in SMEs;
• Facilitating local training providers (trainers) and trainees in using their own language based on
multilingual terminology and ontology (Direct output of LLP-LdV-TOI-2008-HU-002 transferred project);
• Contributing multilingual e-content tools based on the terminology and ontology interoperability
framework (Direct output of LLP-LdV-TOI-2008-HU-002 transferred project);
• Extending the existing dictionary (glossary), learning ontology portal by new contents

At the Project, thanks to transfer of innovations, extension of internal financial control assessment model on
the level of SME’s in Europe could be ensured and it would also be possible to prepare information systems
and a multilingual glossary of terms in connection with the area of internal financial control. Furthermore,
extension of models and case studies to users could also be ensured on the basis of the processes of COSO
[4], COBIT [5], Enterprise SPICE [6], and ISO 31000 Risk Management [7], particularly addressing those
who are responsible for internal financial controls thanks to web based training modules prepared and face
to face training to be provided.

The holistic approach to risk-based internal financial control for SMEs means how the implementation of the
internal financial controls is aligned with the wider scoped enterprise governance objectives, as - especially
for SMEs - the cost effective achievement of financial reporting objectives cannot be separated from
the outcomes of the governance processes supporting the company’s specific business goals. The
ISO/IEC 15504 standard [8] based Governance Capability Assessment concept [9] is applied for targeting
and assessing capability of the core business and governance processes, representing the applicable risk
appetite relevant for achieving enterprise goals within their tolerable limits (risk tolerance). The evaluation of
compliance to pre-established risk appetite levels will focus on how the capability profiles of the implemented
core business and governance processes are aligned with the governance objectives customized for the
enterprise specific goals. These assessment results will provide reasonable assurance of achieving both
trusted business operation and reliable reporting objectives for SMEs by a cost effective implementation of
internationally recognized control frameworks and governance models. The Governance Model for Trusted
Businesses incorporates the relevant COSO, COBIT, Enterprise SPICE processes and generally accepted
privacy principles for providing a common reference model - as presented in chapter 4 - in supporting the
implementation of objective-centric risk management integrated into business processes by SMEs.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 8/169

The HARBIF project is co-funded by the European Commission under the LLP Leonardo da Vinci
Programme (Contract No: 2013-TR1-LEO05-47517). The consortium consists of the following partners:

• Mugla Sitki Kocman University (TR) – prime contractor to the Turkish Leonardo Agency
• Gazi University (TR)
• Uludag University (TR)
• Budapest Business School (HU)
• Kaunas University (LT)
• GEA College (SI)
• Chamber of Certified Public Accountants of Ankara (TR)
• Chamber of Certified Public Accountants of Bursa (TR)
• Turkish Foreign Trade Foundation (TR)

The project duration: December 2013 – November 2015

Contact: Tuğba Uçma, Mugla Sitki Kocman University, email: ucmatugba@gmail.com

1.5 Acronyms Used

Acronym Description
AICPA American Institute of Certified Public Accountants
BPM- Business Process Modelling for Governance SPICE and Internal Financial Control - LdV
GOSPEL Innovation Transfer Project (2010-1-HU1-LEO05-00036)
COBIT Control Objectives for Information and related Technology
COSO COSO Internal Control – Integrated Framework
COSO ERM COSO Enterprise Risk Management — Integrated Framework
ESPICE Enterprise SPICE
GAPP Generally Accepted Privacy Principles
ISO International Organization for Standardization
HARBIF Holistic Approach to Risk – Based Internal Financial Control for SMEs - LdV Innovation
Transfer Project (2013-TR1-LEO05-47517)
MONTIFIC Multilingual ONTology for Internal FInancial Control – LdV Innovation Transfer Project
(LLP-LDV-TOI-2008-HU-002)
PA Process Attribute
SME Small and Medium-sized Enterprise
SOC Service Organization’s Control
SPICE Process Improvement and Capability Determination (ISO/IEC 15504 Process
Assessment)

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 9/169

1.6 References

[1] Integrated Governance SPICE Assessor and Internal Financial Control Assessor skill cards,
MONTIFIC and BPM-GOSPEL Deliverables, 2011

[2] Governance Model for Trusted Businesses, BPM-GOSPEL Deliverable, 2011

[3] Report on the Development of a Multilingual Glossary/Terminology/Ontology, MONTIFIC


Deliverable, 2010

[4] The Committee of Sponsoring Organizations of the Treadway Commission (COSO):


• Internal Control — Integrated Framework (1992, 2013)
• Enterprise Risk Management – Integrated Framework (2004)
• Internal Control over Financial Reporting — Guidance for Smaller Public Companies (2006)
• Enterprise Risk Management - Understanding and Communicating Risk Appetite (2012)

[5] COBIT - Control Objectives for Information and related Technology,


COBIT 4.1 © 2007 and COBIT 5 © 2012, IT Governance Institute

[6] Enterprise SPICE® - An Integrated Model for Enterprise-wide Assessment and Improvement.
Technical Report – Issue 1 September 2010. Copyright © The SPICE User Group 2010.

[7] ISO 31000:2009, Risk management – Principles and guidelines


ISO Guide 73:2009, Risk management – Vocabulary

[8] ISO/IEC 15504-1:2004 Information technology -- Process assessment -- Part 1: Concepts and
vocabulary
ISO/IEC 15504-2:2003/Cor 1:2004 Information technology -- Process assessment -- Part 2:
Performing an assessment
ISO/IEC 15504-3:2004 Information technology -- Process assessment -- Part 3: Guidance on
performing an assessment
ISO/IEC 15504-4:2004 Information technology -- Process assessment -- Part 4: Guidance on use for
process improvement and process capability determination
ISO/IEC TR 15504-7:2008 Information technology -- Process assessment -- Part 7: Assessment of
organizational maturity

[9] J. Ivanyos, J. Roóz and R. Messnarz, Governance Capability Assessment: Using ISO/IEC 15504 for
Internal Financial Controls and IT Management, in: The MONTIFIC Book, MONTIFIC-ECQA Joint
Conference Proceedings, 2010.

[10] C. Wells, L. Ibrahim and L. LaBruyere, New Approach to Generic Attributes, Systems Engineering,
Vol. 6, No. 4, 2003. © 2003 Wiley Periodicals, Inc.

[11] Statement on Standards for Attestation Engagements (SSAE) No. 16, Reporting on Controls at a
Service Organization. Copyright © 2010 American Institute of Certified Public Accountants, Inc. New
York, NY 10036-8775

[12] Reporting on Controls at a Service Organization Relevant to Security, Availability, Processing


Integrity, Confidentiality, or Privacy (SOC 2). Copyright © 2011, American Institute of Certified Public
Accountants, Inc. All Rights Reserved.

[13] Trust Services Principles, Criteria, and Illustrations. Copyright © 2009 by the American Institute of
Certified Public Accountants, Inc. and Canadian Institute of Chartered Accountants.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 10/169

2. Applied Principles
2.1 The Need for Risk-based Enterprise Governance in Strengthening Business
Trust by SMEs

Corporate Governance principles are often referred as requirements and recommendations prepared by the
supervision authorities or international professional organizations only for the publicly listed, the state-owned
and the big multinational companies. However following these principles - far beyond the prescribed
compliance requirements - is important for all market-driven economic entities due to establishment and
maintenance of trusted business relations.

“Trusted Business” is highly substantial for all stakeholders, such as the owners and investors, the
employees, the customers and suppliers, the creditors, and the authorities and associations of public interest
for social, economic and ecologic sustainability. As the aware business risk taking is an essential element of
the economic growth and innovation, it is definitely stressful how the involved parties “grease the skids” for
successful management of uncertainties effecting business goals, like operational, environmental, legal,
societal, human, health, etc. risks - in either micro or macro environment. The lower is the level of business
trust measuring acceptance and undertaken of unavoidable uncertainties in business relationships, the
higher is the cost of risk-taking due to mistrust (like in the form of higher interest rates, insurance and
enforcement costs, etc.), which leads to lower efficiency and competitiveness by the unsubstantiated
increase of operational costs.

It is important to all economic and social partners, that the enterprise governance milieu - by keeping in mind
all the needs and requirements of the markets’ demand and supply relations, the regulatory environment
enforcing public societal interests, and the company stakeholders’ expectations together - supports the
optimal framework of risk taking in establishing and maintaining long term and fruitful business relationships
necessary for the sustainable development. Therefore it is desirable for the achievement of a standard level
of business trust that those governance principles and enabling practices which are commonly interpretable
and observable by all types of economic entities will be as widely as possible acquainted and also applied
according to the specific business conditions. Implicitly the enterprise has the more and the more types of
business relationships and stakeholders, the more important is the control and transparency of its
governance system supporting business trust. Nevertheless, the successful conformity to governance
requirements and the credible presentation of the achieved results are equally important to the entities either
in start-up, growing or matured phases - independently from size, industry sector or ownership types.

For publicly listed companies, the regulators or supervision authorities request compliance to the local
corporate governance codes or recommendations. In Europe the “comply or explain” type disclosures are
generally accepted, however stakeholders would be more happy with wider transparency of how the fulfilled
compliance objectives are achieved instead of just receiving short explanations of why some compliance
requirements are missed or managed in different than the recommended way.

Small or Medium sized Enterprises (SMEs) are typically not requested to disclose conformity statements.
However if their products or services are embedded into their customers’ production lines, the necessary
technical, quality and financial indemnity insurance requirements and the validation processes are
established and maintained within formal supply chain management. In outsourcing business even the small
entities might be asked to provide independent audit reports for Service Organization’s Control. Funding
agencies, investors and financial institutions can rate their potential SME clients not only based on the
historical financial figures, in optimal business environment the “soft” organizational management factors and
company goodwill are also evaluated and important for decision making. For these reasons, even the SMEs
can benefit from presenting their governance capability conforming to international standards without
exaggerated implementation and assurance costs by adapting the Governance Model for Trusted
Businesses aligned with their own business goals and environment.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 11/169

2.2 Risk Management Principles Supporting Enterprise Governance

For effective Risk Management integrated with Enterprise Governance, according to ISO 31000:2009 Risk
Management standard, the company should at all operational and organizational levels comply with the
following principles:

a) Risk Management creates and protects value.


Risk management contributes to the demonstrable achievement of enterprise objectives and
improvement of business performance.

b) Risk Management is an integral part of all organizational processes.


Risk management is not separated from the main activities and business processes of the
organization. Risk management is part of the responsibilities of management and an integral part of
all business and governance processes at all operational and organizational levels.

c) Risk Management is part of decision making.


Risk management assists management make informed choices, prioritize actions and distinguish
among alternative courses of action.

d) Risk Management explicitly addresses uncertainty.


Risk management explicitly takes account of uncertainty, the nature of that uncertainty, and how it
can be addressed.

e) Risk Management is systematic, structured and timely.


A systematic, timely and structured approach to risk management contributes to efficiency and to
consistent, comparable and reliable business results.

f) Risk Management is based on the best available information.


The inputs to the risk management process are based on information sources such as historical
data, experience, stakeholder feedback, observation, forecasts and expert judgement. However,
decision makers should take into account, any limitations of the data or modelling used or the
possibility of divergence among experts.

g) Risk Management is tailored.


Risk management is aligned with the organization's external and internal business context and risk
profile.

h) Risk Management takes human and cultural factors into account.


Risk management recognizes the capabilities, perceptions and intentions of external and internal
people that can facilitate or hinder achievement of the organization's business objectives.

i) Risk Management is transparent and inclusive.


Appropriate and timely involvement of stakeholders and, in particular, decision makers at all
operational and organizational levels, ensures that risk management remains relevant and up-to-
date. Involvement also allows stakeholders to be properly represented and to have their views taken
into account in determining risk criteria.

j) Risk Management is dynamic, iterative and responsive to change.


Risk management continually senses and responds to change. As external and internal events
occur, business context and knowledge change, monitoring and review of risks take place, new risks
emerge, some change, and others disappear.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 12/169

k) Risk Management facilitates continual improvement of the organization.


Management should develop and implement strategies to improve the risk management capability
aligned with all other (e.g. process) improvement aspects of the enterprise.

The above listed principles adopted from ISO 31000:2009 Risk Management standard comprise the base for
interpreting the Integrated Risk Management scenarios aiming at specific enterprise objectives within
different timescales for the operational and organizational levels of business operation. Therefor risk
management is integrated into the Enterprise Governance by supporting effective decision making and
improvement of business performance.

ISO 31000 Risk Management principles do not directly address the term of “risk appetite”, however its COSO
definition and interpretation is not really far from applying these principles in context of Enterprise
Governance:

COSO’s Enterprise Risk Management — Integrated Framework defines risk appetite as follows:

“The amount of risk, on a broad level, an entity is willing to accept in pursuit of value. It reflects the
entity’s risk management philosophy, and in turn influences the entity’s culture and operating style.
… Risk appetite guides resource allocation. … Risk appetite [assists the organization] in aligning the
organization, people, and processes in [designing the] infrastructure necessary to effectively respond
to and monitor risks.”

“This definition raises some important points. Risk appetite:


• is strategic and is related to the pursuit of organizational objectives;
• forms an integral part of corporate governance;
• guides the allocation of resources;
• guides an organization’s infrastructure, supporting its activities related to recognizing,
assessing, responding to, and monitoring risks in pursuit of organizational objectives;
• influences the organization’s attitudes towards risk;
• is multi-dimensional, including when applied to the pursuit of value in the short term and the
longer term of the strategic planning cycle; and
• requires effective monitoring of the risk itself and of the organization’s continuing risk
appetite.”
Source: Enterprise Risk Management - Understanding and Communicating Risk Appetite
(COSO 2012)

In this interpretation risk appetite is definitely not just a set of acceptable (practically hardly measureable and
comparable) risk levels, but much more a strategic thinking about how the uncertainties around the business
objectives and their effects on these objectives should be managed at all operational and organizational
levels. Implementation of enterprise governance and control processes should follow the related
management decisions aligned with specific business conditions, formalized as Risk Appetite Statements (at
strategic level) or Management Assertions (at operational and organizational levels), instead of complying
with generic models normally used as simple check-lists by assurance providers (e.g. auditors).

The ISO/IEC 15504 based process improvement and capability determination methodology provides a
conceptual framework for determining organizational risk appetite by setting target capability levels for key
business and governance processes. Evaluation of the gaps between target and actually assessed capability
profiles provides input for the next risk treatment planning and implementation cycle at the concerning
operational or organizational level.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 13/169

2.3 The Holistic Approach by Implementing Enterprise Goals driven Integrated


Risk Management scenarios

The suggested solution of this handbook describes how Integrated Risk Management scenarios can be
established by mapping already existing or newly developed management practices to governance
objectives - through company specific enterprise goals. By this way the compliance and assurance works will
be aligned with the enterprise specific business objectives and might keep the less meaningful elements of
general governance or control frameworks out of scope. However by comparing existing practices to those
offered by these frameworks, the management and - if requested due to company size or corporate laws -
the supervision bodies might benefit from getting wider professional knowledge and best practice
suggestions for improving enterprise governance.

Figure 1: Enterprise Goals driven Integrated Risk Management scenarios

The proposed Integrated Risk Management scenarios are distinguishing different operational and
organizational levels having specific targets and time-horizons. At each level “Usefulness” and “Efficiency”
goals and measures should be defined allowing management to see recognized professional framework
practices as enablers instead of just compliance requirements. The following Integrated Risk Management
scenarios are presented in this handbook:
• Managing Operational Performance
• Managing Performance Reliability
• Managing Operational Effectiveness
• Managing Strategic Directions
• Managing Operational Risks

Operational Performance is related to the core and supporting business processes of a business unit. The

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 14/169

processes might be described by using different methodology and tools; however the process purpose and
the necessary and sufficient outcomes of achieving this purpose are generally identifiable. Each specific
business operation consists of a set of interrelated business processes with allocated resources, specified
product or service delivery requirements and schedules. Managing Operational Performance scenario is
focusing on achievement of these - relatively - short term performance objectives, for example a unique
product or service delivery based on a specific client’s order. Most regulatory requirements (like health
protection, safety, human rights, technical or accounting standards, etc.) might be also incorporated within
activity goals and assured at this level.

Performance Reliability also refers to the above operational level with extended focus on additional aspects
of performance. For repeating, parallel or extended cycles of operational processes, the operational
management should establish longer term objectives such as customer retention and capacity utilization. At
most cases these objectives are related to contractual or pay-off periods. For example customer satisfaction
and capacity utilization rates are applicable measures for reoccurring business transactions for the monthly
pay-off period of an outsourcing service (mostly provided by SMEs).

Such as the Operational Performance instances drive the achievement of reliability objectives, the pay-off
cycles based Reliable Performance drives to achieve entity (business unit) level Operational Effectiveness
goals measured by profitability and agile resource allocation at business unit level for a quarterly or yearly
reporting period. The business unit level effectiveness is also a driver to achieve objectives set by Strategic
Directions (Business Goals), like revenue targets and operational cash flow positions set for the strategic
planning periods.

Managing Operational Risks sets risk tolerances (acceptable deviation from objectives) and risk appetites
(affordable levels of uncertainties effecting objectives) for operational and organizational levels based on
operational performance, reliability, effectiveness and strategic objectives. Each level’s objectives have
specific time-horizons, therefore the application of “traditional” consequence and probability metrics (“heat
maps”) for risk ratings and selecting or prioritizing the risk treatment options is reasonable only when
operational or organizational levels and timescales of risk events are comparable.

Risk Management practices might show significant differences in details at SME or bigger company cases;
however the same principles remain valid. Evidently a small entity or business unit also defines acceptable
tolerance levels of its business targets, and establishes its governance structure adequately to affordable
levels of internal and external uncertainties affecting these targets. Practically “affordable level” is different
for a smaller entity with a few service or production lines than for a big multinational company with much
more diversified activities.

The proposed Integrated Risk Management scenarios are applicable for all types of business entities and
they use generic purpose governance frameworks for selecting those processes and practices which enable
their business operations to achieve enterprise goals at adequately defined operational and organizational
levels.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 15/169

2.4 Applicable Governance Objectives for SMEs

The well established and recognized control frameworks and process reference models could be used for
implementing and evaluating effective and efficient enterprise governance by SMEs, if only the management
established its own governance related objectives. Unfortunately, structures of generic control frameworks
and reference models promoted by assurance professional bodies are not easily interpretable by SME
management for setting their business’ specific governance objectives.

The Governance Model for Trusted Businesses keeps both enterprise management and assurance (e.g.
audit) logics in mind by presenting governance processes in line with the objectives relevant for SMEs,
together with an exact mapping to processes of control frameworks (reference models) accepted and used
by assurance providers (e.g. auditors) for compliance attestation.

The Governance Model aims 11 governance objectives:

Supporting Business
Supporting Organization’s Internal Control System:
Sustainability:

Competitiveness Accountability Commitment


Process Risk Awareness
Exploitability Competency
Integrity Control Efficiency
Satisfaction Accuracy Data Protection

Figure 2: Applicable Governance Objectives for SMEs maintaining Trusted Businesses

While business sustainability objectives are significant for keeping business operation economically effective
and successful, the organization’s internal control objectives have the major focus on how effectively internal
control system is enabling achievement of strategic, operational effectiveness, reliability and business
process performance related Enterprise Goals. Each governance objective should be determined in context
of the specific organizational or operational level by considering the adequate time-horizon. The governance
objectives should be supported by “Usefulness” and “Efficiency” measures and other risk criteria for
improving business processes and management activities within the enterprise governance framework.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 16/169

2.5 Governance Capability Assessment for Supporting Holistic Approach

For implementing Enterprise Governance the executive management and - if it exists - the supervisory board
should follow scenarios to evaluate, direct and monitor business operation in alignment with the adapted
governance objectives. In this term the “Enterprise Governance” is driven by the organization’s specific
business goals and enabling governance objectives instead of generic control or regulatory framework based
“checklists”. When ISO/IEC 15504 standard (SPICE) based Governance Capability Assessment concept is
applied, the evaluation of compliance will focus on how the capability profiles of the implemented core
business and governance processes are aligned with the governance objectives customized for the
Enterprise Goals. This customization keeps in mind three dimensions:

• the business operation (processes and activities) under scope,

• the applicable governance practices from recognized reference models and

• the capability level targets.

Figure 3: The Holistic Approach supported by Governance Capability Assessment (Governance SPICE)

By using Governance Capability concept in customization of governance objectives, the SME management
is able to present management assertions in alignment with both business specific and generic (e.g.
regulatory) requirements. These assertions are linking business activities to governance practices within the
applied capability assessment model supporting both the implementation of the Enterprise Governance
Framework and its internal and external evaluation.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 17/169

The term of “Governance Capability Assessment” is used in context of Governance, Risk Management
and Internal Control processes based on different concepts:

• Corporate Governance Principles and Codes (OECD, etc.)

• Recognized Control Frameworks and Reference Models (like COSO, COBIT, Enterprise SPICE,
etc.)

• Risk Tolerance and Risk Appetite (as of COSO ERM)

• Performance Measurement (as of COBIT)

• Process Capability Assessment (ISO/IEC 15504-2:2003)

• Evaluating Process-related Risk (ISO/IEC 15504-4:2004)

• Quantitative Performance Measurement (ISO/IEC TR 15504-7:2008)

Internal and external audit standards (like IIA and ISA) recommend system based evaluation of existing
internal controls against internationally recognized control frameworks like COSO (Internal Control -
Integrated Framework) and COBIT (Control Objectives for Information and related Technology). The
contents of these frameworks – such as other models like Enterprise SPICE - are applicable to set up
Process Reference Models in compliance with ISO/IEC 15504-2 requirements.

The selected processes from the COSO, COBIT and the Enterprise SPICE reference models associated with
the process attributes defined in ISO/IEC 15504-2 provide a common basis for performing assessments of
governance capability regarding Enterprise Governance and reporting of results by using a common rating
scale. ISO/IEC 15504 standard (SPICE) offers not only transparent method for assessing performance of
relevant governance processes, but also tools for assessing related risk areas based on the gaps between
target and assessed capability profiles.

However traditional compliance-driven approaches have been facing to major problem as there is no
evidence that compliance (to any model) really drives business success. On the contrary: all big failure
companies of the last decades had been “equipped with” long list of compliance and excellence records for
many years. The key problem is that managing compliance issues has only limited focus on lower level
outcomes - like activity goals - without considering the overall success factors. Enterprise Governance
should focus on wider internal and external contexts of risks defined as effects of uncertainties on
enterprise objectives such as referred by the ISO 31000 Risk Management standard. Quantitative
Performance Measurement covering the overall governance structure is needed for establishing useful risk
criteria for supporting management decisions at all organizational and operational levels.

Most of the metrics applied by Quantitative Performance Measurement, like those related to “Usefulness”
and “Efficiency” generic attributes [10], are typically not interpretable for the ISO/IEC 15504 process
capability levels. These metrics are applicable in business context of the processes by providing tool for
defining and/or adapting economically meaningful base practices as process performance (level 1)
indicators. There is no meaning to establish such metrics for the generic practices of higher capability level
Process Attributes; however highlighting of the generic attribute metrics of those business or governance
practices, which are identified enablers of higher capability level practices for all processes within the scope
of the process assessment model, is more than reasonable. Those base practices adapted from control
frameworks or reference models as performance (level 1) indicators of a governance process, are applicable
to determine risk appetite at operational and organizational levels.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 18/169

2.6 Linking Governance Objectives to Enterprise Goals & Measures

The Governance Model for Trusted Businesses and Governance Capability Assessment help the
executive management and - if it exists - the board to look at compliance issues through customized
governance objectives aligned with enterprise specific business goals and stakeholders’ expectations:

Figure 4: Linking Governance Objectives to Enterprise Goals & Measures

The Governance Model for Trusted Businesses provides descriptions and applicable practices for the
governance processes supporting management assertions and assurance reports on effective risk management
and control over trusted business operation and financial reporting enabling achievement of Enterprise Goals
according to stakeholders’ needs and expectations. The Governance Capability Assessment (Governance
SPICE) is used to evaluate these management assertions established by Integrated Risk Management
scenarios implemented at different organizational and operational levels.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 19/169

2.7 Special Application Area for SMEs: Assurance of Service Organization’s


Control

Many companies function more efficiently and profitably by outsourcing tasks or entire functions to service
organizations (typically SMEs) that have the personnel, expertise, equipment, or technology to accomplish
these tasks or functions. Examples of such services include cloud computing, managed security, health care
claims management and processing, sales force automation etc. Although user management can delegate
these tasks or functions to a service organization, they are usually held responsible by those charged with
governance (for example, the board of directors), customers, shareholders, regulators and other affected
parties for establishing effective controls over those outsourced functions.

The so called Service Organization’s Control (SOC) reports [11], [12] provide user management with the
information they need about the service organization’s controls to help assessing and addressing the risks
associated with an outsourced service:

SOC 1 Report - Report on Controls at a Service Organization Relevant to User Entities’


Internal Control over Financial Reporting

These reports are specifically intended to meet the needs of entities that use service organizations
(user entities) and the certified professionals that audit the user entities’ financial statements (user’
auditors), in evaluating the effect of the controls at the service organization on the user entities’
financial statements. Use of these reports is restricted to the management of the service
organization, user entities, and user auditors.

SOC 2 Report - Report on Controls at a Service Organization Relevant to Security,


Availability, Processing Integrity, Confidentiality or Privacy

These reports are intended to meet the needs of a broad range of users that need information and
assurance about the controls at a service organization that affect the security, availability, and
processing integrity of the systems the service organization uses to process users’ data and the
confidentiality and privacy of the information processed by these systems.

The SOC 1 related international standards (like SSAE 16 or ISAE 3402) require management of the service
organization to provide a description of its “system” along with a written assertion to the service auditor,
both of which require careful attention and preparation by management themselves.

The framework for documenting a service organization’s system for purposes of SOC 1 engagement should
include a comprehensive discussion of the following components:

• The services provided along with the classes of transactions processed.

• The procedures used, from beginning to end, both automated and manual, for the transactions (i.e.,
the flow of the transactions and all activities, from initiation to correction of errors, as necessary).

• How the system captures addresses significant events and conditions along with what processes
and procedures are used to prepare and report information as necessary to user entities.

• The control objectives, related controls and user control considerations

• The service organizations elements of internal control, which are generally based on the COSO
framework consisting of the following: 1. Control Environment. 2. Control Activities. 3.
Information and Communication. 4. Risk Assessment. 5. Monitoring

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 20/169

Management of the service organization must also produce a "written assertion" for purposes of SOC 1
reporting, which is to "assert" that (1) management description of the service organization's "system" is fairly
presented, (2) that the controls and related control objectives were suitably designed and were operating
effectively.

In a SOC 2 engagement, management of the service organization selects the Trust Services Principles [13]
that will be covered by the SOC 2 report. The trust services criteria for the principle(s) covered by the report
are referred to as the applicable trust services criteria.

The following are the five attributes of a reliable system, which are also referred as the Trust Services
Principles:

• Security. The system is protected against unauthorized access (both physical and logical).

• Availability. The system is available for operation and use as committed or agreed.

• Processing integrity. System processing is complete, accurate, timely, and authorized.

• Confidentiality. Information designated as confidential is protected as committed or agreed.

• Privacy. Personal information is collected, used, retained, disclosed, and disposed of in conformity
with the commitments in the entity’s privacy notice and criteria set forth in Generally Accepted
Privacy Principles (GAPP) issued jointly by the AICPA and the Canadian Institute of Chartered
Accountants.

Service organization management implements controls over its systems to prevent adverse events from
occurring or detect such events as errors, privacy breaches, and theft or loss of information. Management of
the service organization may engage an external auditor to report on the design and operating effectiveness
of controls over its systems. Controls that are suitably designed are able to meet the criteria they were
designed to meet if they operate effectively. Controls that operate effectively actually do meet the criteria
they were designed to meet over a period of time.

The Governance Model for Trusted Businesses offers sufficient set of practices to determine the enterprise
specific control objectives. The service organization management can easily select and communicate those
minimum requirements which are considered as crucial for running business on the specific market (composing the
risk appetite considering specific business objectives and real expectations of the business environment). This
decision is a clear message to all stakeholders, including user entities and all potential customers, that which
operational risks are planned to be mitigated by the service organization management, and which risks remain
unattended.

The business process management solutions, like workflow systems, project toolkits, reporting tools, etc. can
be configured for automatically collecting and providing performance information both about the process-
level and entity-level controls, based on the manually and/or electronically processed business activities.
Tracking of the evidences for governance process performance by a process management suite, which is
also able to map these evidences to process assessment models, provides solution to automate formal
assessment of governance capability over a period of time. These assessment results certified by a qualified
issuer can be published directly by the assessed enterprise, or via a “trusted business” promotion portal.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 21/169

3. Integrated Risk Management Scenarios supporting Enterprise


Governance
3.1 Comments for Implementing Integrated Risk Management Scenarios

In this handbook the Integrated Risk Management Scenarios supporting the application of the Governance
Model for Trusted Businesses are presented. Even in the case of SMEs the business environment might
have internationally standardized (like SOC 1 and SOC 2) requirements which should be carefully
considered by small business companies providing local services to big firms or multinational clients, whose
compliance managers, internal and external auditors are making great demands on local service providers
and raising difficulties for these companies by increasing requested control and audit efforts and costs. At
most cases these demands are driven by the multinational organizations’ global compliance or audit
requirements, so they are not really intended to be ”customized” for local conditions.

The Integrated Risk Management scenarios of this handbook present how even local small business
organization can efficiently implement compliant governance/control frameworks with respect of its real
business needs and risks, and how the implementation results can be exhibited for external evaluation or
audit in a cost effective way.

Figure 5: Integrated Risk Management Scenarios with Enabling Governance Processes

By changing from the traditional model based compliance to enterprise goals driven integrated risk
management, the management assertions (the links between business activities and governance practices)
are implemented by applying significantly different scoping approach. The key business processes are
viewed as instances of business performance at different operational and organizational levels, so the
Integrated Risk Management scenarios are enhancing the meaning of “compliance” as in what extent the
model based governance/control practices are relevant for really supporting the achievement of enterprise
goals within their acceptable tolerance levels. The proposed Integrated Risk Management scenarios help to

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 22/169

select and apply model based control practices by considering the operational and organizational
performance levels and their adequate time-horizons for setting enterprise objectives. The term of
“Integrated Risk Management” also refers to how the governance capability assessment model is adapted,
understood and used by the assurance providers of all organizational and operational levels, including the
oversight board (if exits), the executive and line management, the internal and external auditors, and other
roles relevant in governance, risk management, control system and compliance related works.

Capability profiles of the business processes together with the enabling governance and control processes
are representing “reverse”, but well understandable measures of management’s risk appetite as the higher
capability levels indicate the more robust risk treatment for achieving relevant business objectives:

Figure 6: ISO/IEC 15504 Process Capability Levels and Attributes applicable for Risk Appetite Statements

At the Managing Operational Performance scenario, the capability profiles of the baseline business
processes will show how the management keeps under control of these processes. Normally the
Performance Management and Work Product Management process attributes of the Managed (level 2)
capability are sufficient to provide reasonable assurance to achieve the performance objectives of the
business operation - like fulfilling service or product specification and delivery time requirements. Targeting
higher capability levels for a business process is also reasonable when its performance objectives are
directly linked to customer satisfaction, operational effectiveness or even to strategic objectives. For example
SME service/production business process related performance metrics (e.g. delivery volumes, resource
usage, error rates, missed deadlines, etc.) are also applicable indicators of business reliability, operational
effectiveness and market recognition within the different time horizons of the specific enterprise goals. The
higher process capability of the business processes means the more extended management and risk
treatment practices concerning to the objectives of customer satisfaction, pay-off and order renewal in
shorter periods, and of economical sustainability in longer terms. Quantitative measures of key product or

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 23/169

service deliveries at recognized quality level are applicable to establish risk tolerance indicators. For example
increasing error rates should indicate management actions to improve integrity of the service/production
delivery process, technology support and human skills. Unsatisfactory volume (or growth) of monthly
transactions should force management to implement changes not only in resource allocation, but also to
reorganize business processes and human capacity, or even reconsider business scope, strategy and
company structures.

At the Managing Performance Reliability scenario the Satisfaction, Accuracy and Data Protection
objectives related governance practices are selected for implementation and improvement in order to enable
achievement of pay-off cycle related business objectives, like customer retention and capacity utilization.
These practices are also supporting the achievement of Performance Management and Work Product
Management process attributes of the Managed (level 2) capability for the baseline business processes. For
example Accuracy and Data Protection objectives are helping to identify Work Products related
requirements in specific IT-enabled business environments.

The risk appetite at this operational level can be identified as the coverage of business processes by the
Satisfaction, Accuracy and Data Protection objectives related governance processes. This means that not
all, but the relevant set of the business activities should be covered and there is an interrelation between the
capability profiles. The wider coverage of business processes has been achieved, the more reasons appear
to investigate capability profiles of the related governance processes. The achievement of the - level 2 -
Performance Management and Work Product Management attributes for the business processes will be
evidenced by the outcomes of the Satisfaction, Accuracy and Data Protection objectives related
governance processes. And vice versa, for example the performance of the “Ensure Systems Security” IT
governance/control process (from COBIT) is better evidenced by the coverage of operational business
processes, than by simple checking the related IT projects or functions. The base practices and work
products of the governance processes should be evidenced by the underlying business operation. E.g.
avoiding system security incidents has to be proved by the running business operation. A business
service/production delivery process at Managed capability level will provide more systematic evidences for
the Process Performance attribute of the “Ensure Systems Security” IT control process by setting the
relevant performance objectives and work product requirements for automated business processes.

At the Managing Operational Effectiveness scenario the Exploitability, Process Integrity and
Competency objectives related governance practices are selected for implementation and improvement in
order to enable achievement of (quarterly or yearly) reporting period specific business objectives, like
profitability and agile resource allocation. As these practices provide business unit level framework for
effective development and deployment of resources, process control and competency, the achievement of
Process Definition and Process Deployment attributes of the Established (level 3) capability profiles for the
business processes can be evidenced by them. It is also important to avoid unnecessary or over regulation
of business processes: the business unit (or entity) level controls should be implemented not just in
compliance with generic control models, but by keeping in mind the business unit level “Usefulness” and
“Efficiency” objectives – especially at SME business environment. It is not reasonable to maintain business
unit level documentation of those procedures which are not aligned with the business objectives.
Documenting, implementing and auditing those procedures which are in conflict either with operational
efficiency or simply with process performance objectives, have no value for the organization. Most of those
model based compliance works which are not driven by the business unit’s specific objectives are just waste
of time and efforts. For example scope of business or quality procedures (manuals) should be determined by
keeping the impact on business unit goals in mind, otherwise management and staff will continuously
override these internal rules. Internal rules and guidelines such as for investment or procurement procedures
should also have deployment or tailoring guidance allowing customization based on business conditions.

The risk appetite at this organizational level can be identified as the coverage of business processes by the
Exploitability, Process Integrity and Competency objectives related governance processes. For example
the internal rules and tailoring guidance for managing business unit level resources, quality procedures,
process descriptions and human skills are kept by the operational manager in supervising how service staff
follows them in individual service projects. Therefore the Managed (level 2) capability profiles for the

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 24/169

Satisfaction, Accuracy, Data Protection, Exploitability, Process Integrity and Competency objectives
related governance/control processes will enable the business processes to achieve Established capability
(level 3), when the lower risk level is reasonable for achieving profitability and agile resource allocation
targets. The Managed level of the referred governance processes emphasizes the management’s
awareness of performance objectives and documentation criteria for implementing business unit (or entity)
level operational rules. In smaller organizations or in case of less rule-sensitive services (like reacting to ad
hoc advisory requests), there is no need to overregulate all business activities. Performed - level 1 - profiles
of the governance processes related to key business activities might be also sufficient, when management
considers the higher risk exposure with control cost savings adequately.

Management’s attitude towards control risk taking should be validated by the Managing Operational Risks
scenario, where the Risk Awareness and Control Efficiency objectives related governance practices are
selected for implementation and improvement. Quantitative Performance Measurement is necessary at
each operational and organizational level by considering specific time-horizons of the business objectives.
The Predictable - level 4 - profiles of the relevant business processes are enabled by the Managed (level 2)
capability profiles for the Satisfaction, Accuracy, Data Protection, Exploitability, Process Integrity,
Competency, Risk Awareness and Control Efficiency objectives related governance/control processes.
The Predictable process capability ensures that the performance of the business service/production delivery
process supports the achievement of the related business goals within tolerable limits. For example, if the
reasonable business revenue, cash flow, operating margin and unit cost targets were achievable by
performing ca. 10.000 transactions per month with a tolerable limit of 500 less or unpaid, then the
Predictable level of operational processes will provide high level of assurance, that in case of the forthcoming
customer orders, the business unit will provide the business performance in alignment with the stakeholders’
needs.

Measurable Risk Management performance objectives can be established by the capability targets of the
business and governance processes, and by the tolerance levels (control limits around Enterprise Goals)
used by the risk treatment cycles. However, the consulting, improvement and assurance efforts and costs
might differ e.g. at Managing Operational Performance or at Managing Operational Effectiveness
scenarios. Where the risk treatment cycle is more frequent, there the less consulting or assurance cost
would gain faster benefit return. For example a simple improvement - like better technology support - in IT
enabled business process will cause immediate and repeatable benefits. Implementing, assessing and
improving processes at Established capability level might take more effort and slower, but potentially higher
return on investment. Automating an activity level control within a recurring business process (e.g. evaluating
differences from previous performance results) might have relatively low costs, but immediate benefits of
less personal effort, while changing client’s data exchange rules and procedures definitely requests more
implementation time and effort with slower return, but will evidently improve data processing integrity, client
satisfaction, resource utilization and profitability.

At the Managing Strategic Directions scenario the Competitiveness, Accountability and Commitment
objectives related governance practices are selected for implementation and improvement in order to enable
achievement of strategic planning period specific business objectives, like revenues and cash flow. As these
practices provide the enterprise level framework for setting business strategy and market positioning,
management’s accountability and commitment towards internal and external stakeholders, they also support
the achievement of Process Definition and Process Deployment attributes of the Established (level 3)
capability profiles for all relevant governance processes. Theoretically above the achieved level 3 profiles the
Risk Management practices with applicable Quantitative Performance Measurement - like process
capability gaps based risk assessment - would enable the achievement of Predictable (level 4) attributes of
governance processes; however this would be reasonable only when measurable links between the
capability level of governance processes and the achievement of business goals were evident. As Risk
Management and Internal Control systems do not provide absolute assurance for achieving business goals
due to their inherent limitations (like management’s bad decisions or override of controls), setting Predictable
capability level target for governance processes is generally not reasonable.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 25/169

In case of public or listed companies, the high level information about Competitiveness, Accountability
and Commitment objectives related governance practices are available in company institutional documents,
governance reports and other disclosure statements; however their format and content are typically less
informative than would be needed by the external stakeholders. Furthermore the prevalent “comply or
explain” format of governance reports doesn’t help to understand what is really going on. There are
explanations of why criteria are missing, but no information available how and in what extent the “compliant”
items work, which is more or less in conflict with the transparency requirements.

For all the 11 governance objectives the Governance Model for Trusted Businesses provides application
practices with reference to governance processes offered by recognized reference models (COSO, COBIT,
ESPICE) or generally accepted (e.g. privacy) principles. The full coverage of the governance objectives
related processes - by implementing the above mentioned Integrated Risk Management scenarios - lets -
even SME - organizations to qualify their business units. The qualification process of a business unit’s
compliance to its unique governance objectives - defined by the specific scoping of the governance
practices from the Governance Model - should cover all those business processes and information sources,
which provide the sufficient evidences for management assertions concerning to the effective and efficient
implementation.

ISO/IEC 15504 process capability assessments (or similar audit approaches) are widely used in specific
industries and sectors, like automotive, medical, space, finance, etc. Most of these assessments are
performed only at operational levels aiming up to level 2 targets by using domain specific process
assessment models adapting generic standards or recommendations, like ISO 12207, ITIL, COBIT, etc. The
coverage of the 11 governance objectives referred by the enabling processes of the Governance Model for
Trusted Businesses helps to use the industry and sector specific process assessment models by
establishing the applicable organizational contexts of level 3 and level 4 process attributes concerning to the
operational and supporting business processes.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 26/169

3.2 Managing Operational Performance

3.2.1 Context and Specific Learning Objectives of Managing Operational Performance

The following figure presents role of the Managing Operational Performance scenario in supporting of
Enterprise Governance:

Figure 7: Role of the Managing Operational Performance scenario in Enterprise Governance

In the context of Managing Operational Performance, Enterprise Governance should focus on those
issues which are considered as relevant for the following sample management problems:

1. My organization (business unit) provides services or products according to internal or external


specifications, however by not keeping delivery deadlines and quality requirements in all cases.

2. Quality issues in product or service delivery request extra effort and/or waste resources.

3. Missing deadlines cause customer claims and unaccepted performance.

4. Frequent overwork times cause extra production costs and/or employees’ dissatisfaction

5. Insufficient resources set back of achieving production or service targets.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 27/169

Normally these issues are occurring and being managed in different time-scale than of the
other Integrated Risk Management scenarios. Managing Operational Performance is
limited to the individual instances of the business processes and activities by considering
service or product delivery requirements and schedule. Managing Performance Reliability
considers contractual pay-off cycles with parallel or reoccurring business operational cycles,
while Managing Operational Effectiveness typically has the time-horizon of the budgeting
or reporting periods. Managing Strategic Directions is focusing on longer perspectives.
Operational Risk Management takes each governance objective into its specific time-
horizon when setting risk criteria and measurable risk levels for selecting treatment options
and evaluating their effectiveness.

Any reoccurring deviation from performance objectives like rate of performed errorless business transactions
to planned or scheduled and rate of used capacity to planned (rates per month) will call the management’s
attention to check whether Operational Performance objectives are adequately established. Furthermore
some operational performance metrics - like more than planned resource usage or frequent corrective
actions within operational life-cycles - are going to be early indicators of reliability problems coming to
surface only by pay-off with the customer. So solving problems of Operational Performance will limit the
potential root causes of Performance Reliability issues.

For detecting root causes of Operational Performance failures we should focus on operational and
supporting business processes. As a business operation incorporates processes and activities in order to
achieve enterprise goals set for operational and organizational levels (by creating or protecting values of the
organization), the target capability levels of these processes have to be established in accordance to these
goals. At lower operational level like performing a service/production delivery task based on requirements
and schedule agreed with the customer, the adequacy of the performed business operation against specific
processing or compliance requirements and against generic performance management criteria should be
assessed. To systematically assure the achievement of Operational Performance objectives, the business
activities should be formally described according to the process description requirements of ISO/IEC 15504
(by setting relevant purpose statement together with those outcomes which are sufficient and necessary to
fulfil process purpose). For these processes the - level 2 - Managed capability requirements of the ISO/IEC
15504 measurement framework are applicable.

Reoccurring deviations from Operational Performance objectives maybe rooted from the capability gaps of
performed business processes in scope. Assurance providers should consider whether the operational
management supports the employment of ISO/IEC 15504 conformant business processes, and whether the
Process Performance, Performance Management and Work Product Management attributes are
assessable.

Management actions taken during a reporting period (e.g. covered by quarterly or yearly financial or
management statements) to achieve - level 2 - Managed capability for all relevant operational and supporting
processes should be monitored by the board or other supervisory bodies (or by equivalent functions of the
entity), and adequate level of transparency to all of the stakeholders should be provided by management
disclosures.

This part of the handbook is focusing on the Managing Operational Performance scenario, which enables
achievement of performance goals such as keeping product or service requirements and schedule and
using resources as planned.

The Managed - level 2 - capability of the implemented business processes enables the organization:

• establishing operational plans for the performance of the relevant set of business processes
supporting organization’s business operation;

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 28/169

• acting to ensure effective communication regarding the performance of the business processes,
through clear assignment of responsibilities and authorities to involved parties;

• allocating adequate resources and information to ensure implementation of the operational plans;

• monitoring performance of the business processes against plans in the individual operational
instances;

• taking action to address deviation from planned performance of the business processes;

• identifying compliance requirements for the management of outputs developed or maintained by the
processes;

• taking action through appropriate reviews and control mechanisms to ensure that the compliance
requirements for output management are satisfied.

The enabling business practices are derived from ISO/IEC 15504 process attributes:

• The Process Performance attribute is a measure of the extent to which the process purpose is
achieved.

• The Performance Management attribute is a measure of the extent to which the performance of the
process is managed.

• The Work Product Management attribute is a measure of the extent to which the work products
produced by the process are appropriately managed.

Applicable measures:

• Performance (”usefulness”)
- Indicator: Performance Rate (e.g. actual errorless transactions/planned transactions)
- Time-horizon: operating cycles (e.g. a month of service/production delivery)

• Expenditure (”efficiency”)
- Indicator: Operating Costs (e.g. hourly rate of service/production workforce)
- Time-horizon: operating cycles (e.g. a month of service/production delivery)

In this part of the handbook related to Managing Operational Performance scenario, the Process
Performance, Performance Management and Work Product Management attributes are selected to
provide applicable use cases for the following learning objectives:

• Which key risk and risk factors are mitigated by the objectives referred by

o The Process Definition of the operational and supporting processes in context of the business
environment and stakeholders’ expectations

o The Performance Management attribute measuring of the extent to which the performance of the
process is managed

o The Work Product Management attribute measuring of the extent to which the work products
produced by the process are appropriately managed

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 29/169

• How to define business processes for assessing Process Capability in operational and organizational
contexts by achieving - ESPICE SUP.10 - Process Definition outcomes:

o Standard processes, needed to accomplish business objectives, are established and maintained,
including responsibilities, accountability and authority for its management.

o Detailed tasks, activities, input/output work products of the standard processes are identified,
together with expected performance characteristics.

o Allowed modifications and approval mechanisms are established and maintained for the standard
processes from which approved processes are tailored and established for projects, programs,
services, organizations, or the enterprise.

o Goals, performance data, and other assets that support the processes are collected, maintained
and communicated.

o Process assets (processes, allowed tailoring, approval mechanisms, process objectives,


measures of process performance) are collected, maintained, and communicated.

o The implemented processes are approved as well-defined derivatives of the standard processes,
including support processes, whose purposes and interrelationships are coordinated.

• How to implement and evaluate generic practices evidencing achievement of Performance


Management attribute through the following outcomes:

o objectives for the performance of the process are identified;

o performance of the process is planned and monitored;

o performance of the process is adjusted to meet plans;

o responsibilities and authorities for performing the process are defined, assigned and
communicated;

o resources and information necessary for performing the process are identified, made available,
allocated and used;

o interfaces between the involved parties are managed to ensure both effective communication and
also clear assignment of responsibility.

• How to implement and evaluate generic practices evidencing achievement of Work Product
Management attribute through the following outcomes:

o requirements for the work products of the process are defined;

o requirements for documentation and control of the work products are defined;

o work products are appropriately identified, documented, and controlled;

o work products are reviewed in accordance with planned arrangements and adjusted as necessary
to meet requirements.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 30/169

3.2.2 Selecting the Scope of the Management Assertions for Managing Operational
Performance

A consistent risk assessment should be performed as the first step to establish management
assertions by linking business activities to applicable governance practices and capability
profiles for supporting the relevant governance objectives.

In case of lower level operational performance objectives, the applicable governance practices are those
which help to establish organizational context and assessable format of business activities. This is important
because we use business process descriptions derived from the specific organizational and business
environment, as they are typically not covered by generic reference models. Therefore the ESPICE SUP.10
Process Definition requirements may be applied as assertion criteria for presenting the specific business
operation. By this way the formalized business processes will be assessable against capability level
attributes according to the ISO/IEC15504 measurement framework.

By using the definition of risk as “effect of uncertainties on objectives”, during the Managing Operational
Performance scenario we have to identify the risk criteria (tolerances and appetite) for governance
objectives which are related to the Performance goals. In terms of performance objectives we use the
“Usefulness” and “Efficiency” measures for setting metrics in time-horizon of operating cycles (e.g. a month
of outsourcing service operation), for example:

• Performance measured by actual performance figures (indicators)

• Expenditures measured by operating costs

For ensuring risk optimisation we need targets and tolerances e.g. measured by:

• Percentage of accepted performance figures compared to planned (e.g. actual errorless


transactions/planned transactions) for service cycles and

• Rates of used effort and resources against planned (e.g. staff hours for a monthly service).

The business operation should have such risk criteria which are applicable to measure effective risk
treatment for achieving performance and expenditure related goals by applying enabler practices in
achievement of process attributes of the capability level targets. Generally the minimum requirement is
achieving fully (over 85%) of the outcomes specified for the assessed business process and largely (over
50%) of the generic outcomes of both the Performance Management and Work Product Management - level
2 - attributes.

When precisely given regulatory or customer (e.g. supply chain management, safety, healthy or ethical)
requirements should be kept, then either applicable processes from a proposed/recognized reference model
can be adapted as part of the business operation (e.g. industry specific SPICE processes) or these
requirements should be set as compulsory outcomes of the defined business processes in scope.

These compliance requirements are normally established by parties during contracting. For example Service
Level Agreements may consist of detailed references to applicable processes and capability profiles;
however implementation will be highly dependent on both sides, especially when business processes involve
roles and activities with shared responsibilities.

For supporting risk assessment the following risk table for the Operational Performance related objectives
can be used to understand key risk areas and applicable practices as risk responses:

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 31/169

Applicable
Key Risk Risk Factors Responses Application Practices
Requirements

Operational and The organization applies


supporting practices to identify, define and
Operational and
processes are maintain a standard set of
supporting Process
established in processes and description of
processes are Definition
context of the allowed tailoring that can be
Losses due to not established (ESPICE)
organization and used to establish the processes
performance adequately
in assessable that are used in execution of
failures, such format business operation.
non-
compliance to
service or Operational and
product supporting
Operational and
requirements, process The organization applies
supporting Performance
missed performance is generic practices for achieving
processes are Management
delivery planned, capability level 2 Performance
not performed in (ISO/IEC 15504)
deadlines, monitored and Management process attributes.
a managed way
wasted efforts adjusted during
and other execution
resources
Work Products
Inputs and The organization applies
are appropriately Work Product
outputs are not generic practices for achieving
established, Management
managed capability level 2 Work Product
controlled and (ISO/IEC 15504)
effectively Management process attributes.
maintained

Table 1: Operational Performance related risk areas

Performance failures have both immediate and longer term effects. Immediate effect is missing the
operational targets measured by performance indicators and ineffective usage of resources. The longer term
effects are the recurring customer dissatisfaction, the higher than planned operational costs or unpaid
overtime works, and even non-compliance penalties or customer claims.

Increasing or recurring performance defaults and unexpected expenditures will lead to losses in business.
The implemented governance practices are tools for improving operational performance to minimize potential
losses and to increase effectiveness.

The business processes defined in context of organizational goals and in applicable format for ISO/IEC 15504
process assessment provide implementation instances for assessing - level 2 - Managed capability attributes for
purpose of process improvement and/or capability determination (assurance) to enable the organization:

• establishing operational plans for the performance of the relevant set of business processes
supporting organization’s business operation;

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 32/169

• acting to ensure effective communication regarding the performance of the business processes,
through clear assignment of responsibilities and authorities to involved parties;

• allocating adequate resources and information to ensure implementation of the operational plans;

• monitoring performance of the business processes against plans in the individual operational
instances;

• taking action to address deviation from planned performance of the business processes;

• identifying compliance requirements for the management of outputs developed or maintained by the
processes;

• taking action through appropriate reviews and control mechanisms to ensure that the compliance
requirements for output management are satisfied.

Of course the higher than level 2 capability targets of the business processes in scope of the business
operation might be also reasonable for providing higher assurance, but evidently at higher cost.

The ESPICE SUP.10 - Process Definition outcomes used as assertion criteria make the Governance
Capability Assessment methodology applicable for evaluating business processes even against Established
(level 3) or higher capability. Without the organizational contexts driven by ESPICE SUP.10 - Process
Definition outcomes, only the operational instances (e.g. single or recurring service or product delivery
projects) would be assessable.

The set of defined business processes and the target Process Capability Attributes comprise those risk
criteria against the business performance should be assessed. Evaluation of Process Attribute Gaps
(between target and assessed capability) provides measurement of residual risk status.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 33/169

3.2.3 Defining Process Outcomes for Managing Operational Performance

The following example shows capability level 2 scoping for a Monthly Payroll Calculation (outsourcing)
business process. The process description comprises the purpose statement and relevant outcomes as
follows:

Purpose statement: The purpose of the Monthly Payroll Calculation process is to perform monthly
payroll calculation tasks on behalf of an entity by processing employment data changes, working and
absence time information, ad hoc payments or deductions, legal or regulatory changes and other
relevant information as inputs for preparing outputs according to the regulatory and contractual
requirements concerning their content, format, delivery methods and deadlines with expected
professional diligence.

Outcomes as defined by activity goals:

1. Setting up and preparing for the payroll cycle

2. Collecting and recording clients' monthly payroll information based on agreed data-handling
rules

3. Input data control and processing for payroll calculation with Client's control

4. Checks and verifications of payroll calculation processing information

5. Submission of all monthly payroll calculation outputs based on regulatory and agreed client's
requirements

6. Regulatory monthly reporting and documenting monthly payroll calculation process

The process activities relevant for these outcomes together with their input and output work products are
used as process performance - level 1 - indicators.

“Assessors will try to verify that the people performing the process understand the purpose
of the process itself and perform the necessary actions. The work products resulting from
performing the activities, together with input work products, are further evidence of process
performance. However, the simple existence of these work products is not sufficient; it
should be evident that they contribute to achieving the process purpose.” (ISO/IEC 15504-
3:2004)

For careful consideration of process performance related risk criteria, management should set and present
metrics. Where current metrics show significant deviation from management’s expectations (risk appetite),
the related activities (maybe also in other processes) should be redesigned and improved. Where current
metrics are available and satisfactory to reasonable risk appetite, the process activities are applicable as
process performance indicators for rating achievement of Process Performance (level 1) attribute.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 34/169

The sample scope setting is targeting - level 2 - Managed capability by fully (more than 85%) achievement of
Process Performance (level 1) attribute, and largely (over 50%) achievement of Performance Management
and Work Product Management (level 2) attributes according to ISO/IEC 15504 (SPICE) measurement
framework. Achievement is measured by using a four point ordinal scale:

Figure 8: Four point ordinal scale for evaluating the achievement of process attribute

According to ISO/IEC 15504, each process attribute must be rated on a scale from “Not” achieved through
“Fully” achieved as follows:

• Not (little or no evidence of the attribute in the process)

• Partially (some evidence of the attribute in the process, though some aspects may be unpredictable)

• Largely (significant evidence of the attribute in the process, though some variation may exist)

• Fully (the attribute is completely and consistently found in the process with no significant weakness
in process performance detected)

Using such a scale, the difference between “Partially” and “Largely” is significant since, to achieve a given
level, all attributes at that level must be “Fully” or “Largely” achieved (with all attributes at lower levels “Fully”
achieved). One goal of the scale was to avoid an “average” rating, either disguising the need for or creating
an arbitrary need for improvement.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 35/169

3.2.4 Applying Generic - Level 2 - Managed Capability Indicators as Risk Criteria for
Performance Goals

Managed (level 2) process capability requests that (above of “Fully” achievement of the Process
Performance attribute) the Performance Management and Work Product Management attributes are
minimum largely achieved (while Process Performance attribute is fully achieved). The following generic
outcomes should be evidenced for the selected business processes in scope of the business operation:

• for Performance Management attribute:

o Objectives for the performance of the process are identified;

o Performance of the process is planned and monitored;

o Performance of the process is adjusted to meet plans;

o Responsibilities and authorities for performing the process are defined, assigned and
communicated;

o Resources and information necessary for performing the process are identified, made available,
allocated and used;

o Interfaces between the involved parties are managed to ensure both effective communication and
also clear assignment of responsibility.

• for Work Product Management attribute:

o Requirements for the work products of the process are defined;

o Requirements for documentation and control of the work products are defined;

o Work products are appropriately identified, documented, and controlled;

o Work products are reviewed in accordance with planned arrangements and adjusted as
necessary to meet requirements.

The above requirements are generic to all governance and business processes in scope. The mapping
between Managed process capability (level 2) generic outcomes and enabling governance practices
provides additional insight to the enterprise governance framework. The level 2 outcomes of managing
process performance are aimed by the Project and Quality Management related practices of the Exploitable
Operation governance process. However this process is defined as an enabler of the Managing
Operational Effectiveness - a business unit level - scenario. This observation is evidently reasonable, as
the Managed capability level of a business or a governance process indicates that business unit
management is committed to use the applicable governance practices - supporting business operation - in
alignment with business unit level goals, such as profitability and agile resource allocation.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 36/169

3.3 Managing Performance Reliability

3.3.1 Context and Specific Learning Objectives of Managing Performance Reliability

The following figure presents role of the Managing Performance Reliability scenario in supporting of
Enterprise Governance:

Figure 9: Role of the Managing Performance Reliability scenario in Enterprise Governance

In the context of Managing Performance Reliability, Enterprise Governance should focus on those issues
which are considered as relevant for the following sample management problems:

1. My organization (business unit) provides services or products according to internal or external


specifications by keeping delivery deadlines and quality requirements, however my customer is not
fully satisfied, there are complains or indemnity claims during discussions for acceptance or even
refusal of invoices.

2. My customer is ready to approve delivery of services or products if only additional performance is


provided referring to changes of external conditions (e.g. additional work to satisfy new regulatory
requirements not considered during contracting).

3. My customer is satisfied and happy, but service or product delivery takes significantly more overall
capacity from my organization than planned during resource allocation.

4. Customer requests extensive changes of documentation over product or service delivery which
might be incompatible with my organization’s information system or capacity (e.g. changing to new
specific formatting or reporting requirements after contracting).

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 37/169

5. Customer needs additional assurance over integrity, security, confidentiality and privacy of client’s
information used, processed and stored during or after service and product delivery (e.g. availability
and cooperation during regulatory audits or control assessments within or after contracting period).

Normally these issues are occurring and being managed in different time-scale than of the
other Integrated Risk Management scenarios. Managing Operational Performance is
limited to the individual instances of the business processes and activities by considering
service or product delivery requirements and schedule. Managing Performance Reliability
considers contractual pay-off cycles with parallel or reoccurring business operational cycles,
while Managing Operational Effectiveness typically has the time-horizon of the budgeting
or reporting periods. Managing Strategic Directions is focusing on longer perspectives.
Operational Risk Management takes each governance objective into its specific time-
horizon when setting risk criteria and measurable risk levels for selecting treatment options
and evaluating their effectiveness.

Any reoccurring deviation from reliability objectives like customer retention and capacity utilization (rates per
pay-off cycles) will call the management’s attention to check whether lower level Operational Performance
objectives are adequately fulfilled as operational performance failures might also cause customer
dissatisfaction. Furthermore some operational performance metrics - like more than planned resource usage
or frequent corrective actions within operational life-cycles - are going to be early indicators of reliability
problems. Most of the reliability issues are coming to surface only by pay-off with the customer, so early
indicators from Operational Performance will help management to be more prepared.

In case of no root cause having been found at Managing Operational Performance, then Satisfaction,
Accuracy and Data Protection objectives and related governance practices should be assessed whether
the selection of practices and their capability targets are aligned with the Reliability Goals or the implemented
practices are achieving their target capability levels.

Reoccurring deviations from customer retention and capacity utilization objectives are early indicators of
those Operational Effectiveness issues which might be identical only by closures of budgeting or reporting
periods. Assessment and improvement of Satisfaction, Accuracy and Data Protection objectives related
process capability profiles are necessary risk management actions not just enabling overall customer
satisfaction but also driving to better Operational Effectiveness.

Management actions taken during a reporting period (e.g. covered by quarterly or yearly financial or
management statements) to achieve Satisfaction, Accuracy and Data Protection objectives - together with
the other governance objectives - should be monitored by the board or other supervisory bodies (or by
equivalent functions of the entity), and adequate level of transparency to all of the stakeholders should be
provided by management disclosures.

This part of the handbook is focusing on the Managing Performance Reliability scenario, which enables
achievement of Reliability Goals such as satisfaction and trust of users/customers over operational
performance.

By the support of this Integrated Risk Management scenario, the organization:

• ensures user/customer satisfaction based on agreed levels of business operation;

• ensures the accuracy and consistency in data architecture and disclosure elements relevant for
business operation, and for supporting data processing integrity;

• is committed to security, confidentiality and privacy principles to avoid unauthorized access to and
misuse of confidential data effected by business operation.

The enabling governance processes are:

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 38/169

• Satisfactory Operation, adapting practices from Enterprise SPICE

• Information Reliability, adapting practices from COBIT and COSO

• Data Protection, adapting practices from COSO, COBIT and GAPP

Applicable measures:

• Customer Retention (”usefulness”)


- Indicator: Order Renewals
- Time-horizon: contracting/pay-off periods

• Capacity Utilization (”efficiency”)


- Indicator: Capacity Utilization Rate
- Time-horizon: contracting/pay-off periods

In this part of the handbook related to Managing Performance Reliability scenario, the Satisfaction, Accuracy
and Data Protection governance objectives are selected to provide applicable use cases for the following learning
objectives:

• Which key risk and risk factors are mitigated by the governance objectives referred by

o The Satisfactory Operation application area aiming to ensure customer satisfaction based on
agreed levels of business operation.

o The Information Reliability (Accuracy) application area aiming to ensure the accuracy and
consistency in data architecture and disclosure elements relevant for financial reporting objectives
and trusted business operation, and for supporting data processing integrity.

o The Data Protection application area aiming to ensure that the organization and its staff are
committed to security, confidentiality and privacy principles to avoid unauthorized access to and
misuse of confidential data effected by business operation.

• How to implement and evaluate application practices evidencing achievement of Satisfaction governance
objective through the following outcomes:

o Requirements are established and maintained based on customer needs and expectations.

o Business relationship management is effective.

o Business operation supports its customers by achievement of agreed service level requirements.

• How to implement and evaluate application practices evidencing achievement of Accuracy governance
objective through the following outcomes:

o Effective information architecture and data model are maintained.

o Information is systematically collected and assessed to detect compliance issues, privacy


problems and fraud.

o Control information for automated process settings, data manipulations and calculations are
maintained systematically.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 39/169

• How to implement and evaluate application practices evidencing achievement of Data Protection
governance objective through the following outcomes:

o Preventive controls are maintained to avoid system security incidents.

o Anti-fraud management program is maintained.

o Privacy requirements are kept.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 40/169

3.3.2 Selecting the Scope of the Management Assertions for Managing Performance
Reliability

A consistent risk assessment should be performed as the first step to establish management
assertions by linking business activities to applicable governance practices and capability
profiles for supporting the relevant governance objectives.

By using the definition of risk as “effect of uncertainties on objectives”, during the Managing Reliable
Operation scenario we have to identify the risk criteria (tolerances and appetite) for governance objectives
which are related to the Reliability Goals. In terms of reliability we use the “Usefulness” and “Efficiency”
measures for setting metrics in time-horizon of contracting payoff periods, for example:

• Customer retention measured by order renewal

• Capacity utilization measured by resource utilization rate

For ensuring risk optimisation we need targets and tolerances e.g. measured by:

• Percentage of successful order renewals for service/production periods and

• Utilization rates for engaged human resources and infrastructure.

The reliable business operation related Satisfaction, Accuracy and Data Protection governance objectives
should have such risk criteria which are applicable to measure effective risk treatment for achieving customer
retention and capacity utilization goals by applying governance practices. Applicable governance practices
should be selected and implemented by considering their relevance to the above “Usefulness” and
“Efficiency” measures.

If a lower level governance practice offered by the Governance Model has no significant relevance for the
established Reliability Goals, then there will be no need to apply that. If management specifies a governance
practice as relevant for managing reliable business operation within the context of stakeholders’ needs, then
the target capability profile for implementing the governance process will include it and will be used as risk
criteria (risk appetite). Capability level target should be set aligned with the relevant Enterprise Goals, as in
this case in accordance with Reliability Goals.

When the stakeholders’ expectations for Service Organization’s Control (SOC) determining high level
Accuracy and Data Protection requirements, the capability profiles of Information Reliability and Data
Protection processes shall be set by the optimal (meaningful) coverage of offered governance practices,
together with a capability profile aiming higher (e.g. Level 2 - Managed or Level 3 - Established)
requirements. The management assertions, monitoring and assurance reports should present how these
criteria are kept by managing operational activities and processes. For a small service organization these
criteria might be exaggerated, but failure of attestation would cause leaving of major clients. However
exaggerated application of governance practices could also cause worse utilization of resources. That is why
selecting applicable governance practices and targeting capability profiles of their implementing processes
need mature risk management performed by organizational governance.

Satisfactory Service requirements are normally established by parties during contracting. Service Level
Agreements may consist of detailed references to applicable governance practices and capability profiles;
however implementation will be highly dependent on both sides, especially when business processes involve
roles and activities with shared responsibilities.

For supporting risk assessment the following risk tables for the Satisfaction, Accuracy and Data
Protection objectives can be used to understand key risk areas and applicable practices as risk responses:

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 41/169

Applicable
Enterprise
Key Risk Risk Factors Responses Application Practices
SPICE
processes

The organization applies


practices to develop a detailed
Requirements Requirements
and precise set of requirements
are not are established Requirements
that meet customer needs and
established based on (ESPICE)
expectations and manage those
adequately customer needs
requirements throughout the life
cycle.

The organization applies


Losses due to practices to establish and
customer Ineffective Business Business maintain a mutually satisfying
dissatisfaction business relationship Relationship relationship between the product
relationship management is Management or service supplier and the
management maintained (ESPICE) business partner based on
understanding the business
partner and its business drivers.

The organization applies


Product or Monitoring based Operation and
practices to operate the product
service delivery on agreed Support
or service at agreed service
default service levels (ESPICE)
levels and support its users.

Table 2: Satisfaction related risk areas

Customer dissatisfaction has both immediate and longer term effects. Immediate effect is the worse resource
utilization (unpaid service or overwork). The longer term effects of leaving clients and less income are also
predictable in repeating failure cases.

Decreasing number of order renewal and lower resource utilization rate per customer will lead to losses in
business. The implemented governance practices are tools for improving customer satisfaction to minimize
potential losses and to increase possibilities of order renewals or new contracts. The selected governance
practices provide implementation instances of the Satisfactory Operation governance process enabling the
achievement of the following outcomes:

• Requirements are established and maintained based on user/customer needs and expectations.

• Business relationship management is effective.

• Business operation supports its user entities by achievement of agreed service level requirements.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 42/169

Applicable
Key Risk Risk Factors Responses COSO&COBIT Application Practices
processes

Satisfy the business requirement


Information Maintaining
Define the of being agile in responding to
architecture is effective
Information requirements; provide reliable,
inconsistent with information
Architecture consistent information, and
processing architecture and
(COBIT) seamlessly integrate applications
requirements data model
into business processes.

Information is
Pertinent information is identified,
systematically
captured, used at all levels of the
Inconsistency Non-compliance collected and Governance
organisation, and distributed in a
in data with rules and assessed to (Financial
form and timeframe that supports
architecture regulations are detect Reporting)
the achievement of the
and not detected in compliance Information
organization’s financial reporting
disclosure time issues, privacy (COSO)
and trusted business operation
elements problems and
objectives.
fraud
Control
information for Information used to execute
automated other control components is
Availability and
process settings, Internal Control identified, captured, and
quality of control
data Information distributed in a form and
information are
manipulations (COSO) timeframe that enables personnel
not sufficient
and calculations to carry out their internal control
are maintained responsibilities.
systematically
Table 3: Accuracy related risk areas

Reliable information is the precondition of data processing and reporting. Furthermore collecting of control
information is also needed for ensuring quality of data processing. Unreliable information will cause extra
processing and time and resources followed by manual controls and corrections. Agreed input data
architecture and output formats are necessary elements of ensuring customer satisfaction in IT-enabled
service environment. The service providers always remain responsible for the errors detected in service
outputs by customers or authorities, so data, processing and reporting inconsistencies have to be avoided as
much as possible, otherwise extra manual work will be needed. As deadlines and service fees are normally
calculated by presuming effective data processing, the accuracy problems have negative effects on
customer retention and resource utilization.

Frequent output errors or missed deadlines lead to extra indemnity or compensation costs and general
customer dissatisfaction. The implemented governance practices are tools for minimizing manual processing
and controls to ensure effective and reliable data processing. The selected governance practices provide
implementation instances of the Information Reliability governance process enabling the achievement of
the following outcomes:

• Effective information architecture and data model are maintained.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 43/169

• Information is systematically collected and assessed to detect compliance issues, privacy problems
and fraud.

• Control information for automated process settings, data manipulations and calculations are
maintained systematically.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 44/169

Applicable
COSO&COBIT
Key Risk Risk Factors Responses Application Practices
processes and
GAPP
Satisfy the business
requirement of maintaining
Preventive the confidentiality, integrity
System security and availability of
controls
and Ensure Systems information and the
maintained to
confidentiality Security (COBIT)
avoid system processing infrastructure
failures
security incidents aligned to business needs
and minimising the impact
of security vulnerabilities.
The potential for material
misstatement due to fraud is
Unauthorized Anti-fraud explicitly considered in
access to and Intentional management Fraud Risks assessing risks to the
misuse of misuse of data program (COSO) achievement of financial
confidential data maintained reporting and trusted
business operation
objectives.
Personal information is
collected, used, retained,
Active policies disclosed, and destroyed in
Generally
Breaching and procedures conformity with the
Accepted Privacy
privacy are in place to commitments in the entity’s
Principles
requirements ensure privacy privacy notice and with
(AICPA/CICA)
requirements criteria set forth in generally
accepted privacy principles
(GAPP).
Table 4: Data Protection related risk areas

Ensuring information security for confidential and privacy data is a strict regulatory and customer requirement
especially in outsourcing business environment. Any serious breach might cause indemnity or immediate
contract notice. Furthermore this type of dissatisfaction has the biggest damage on reputation of the service
provider affecting other contracts as well. In case of using web-based or e-commerce systems, adequate
management of data protection issues is even more critical to satisfactory business operation.

The implemented governance practices are tools for minimizing unauthorized access to and misuse of
confidential service data. The selected governance practices provide implementation instances of the Data
Protection governance process enabling the achievement of the following outcomes:

• Preventive controls are maintained to avoid system security incidents.

• Anti-fraud management program is maintained.

• Privacy requirements are kept.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 45/169

The set of applied governance practices and the target Process Capability Attributes
comprise those risk criteria against the business performance should be assessed.
Evaluation of Process Attribute Gaps (between target and assessed capability) provides
measurement of residual risk status.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 46/169

3.3.3 Applying Management Assertions for Managing Performance Reliability

Management assertions are setting links between the business processes (and activities)
and the governance objective-driven processes (and base practices) offered by recognized
reference models (like COSO, COBIT and Enterprise SPICE). Management should reflect to
their own business goals and business environment’s expectations by setting target
capability profiles for the customized governance objectives (risk appetite) and adequate
quantitative control limits of tolerable deviations from Enterprise Goals (risk tolerance).
Governance Capability Assessment (Governance SPICE) methodology provides
measurement framework for targeting and assessing effectiveness of governance processes
(defined by ISO/IEC 15504 compliant reference models) in achievement of governance
objectives, however it should be carefully considered at the assessment scope definition,
that a governance process might be implemented and applied by more than one business
processes (and their instances) within a business operational unit.

For example in the case of Accuracy objective concerning to an IT-enabled business process, the
management should determine the management and control activities necessary and sufficient to limit the
negative consequences of the inherent business risk related to inconsistency in processing data architecture
and disclosure elements.

Theoretically the management should apply a measure for determining direct impact on
specific business goals, however at business process level this measure can’t derived
directly from “natural” business measures like income, profitability, stock listing rate, market-
share, etc. This problem could be resolved by targeting application of governance practices
by the business process activities. The more relevant governance practices are applied; the
negative consequences are the more likely minimized.

However the adequate structure of performance measurement helps to navigate over


applicable governance practices (see Figure 4: Linking Governance Objectives to Enterprise
Goals & Measures). The governance practices are enabling achievement of Enterprise
Goals, so measurement related to achievement of governance objectives should support in-
time status information regarding overall business performance. Furthermore the lower level
operational or organizational goals and metrics should be established as enabling indicators
for the above governance level.

By this way the appearing deficiencies to target measures of Managing Operation Performance - e.g.
delays, errors, overworks in a monthly data processing cycle - might be early indicators of possible failures at
Managing Performance Reliability level - e.g. client complains and claims or capacity utilization issues by
closing contractual settlement periods. Similarly the metrics indicating deviation from Reliability Goals call the
attention for possible consequences in achievement of Organizational Goals at Managing Operational
Effectiveness level - e.g. decreasing profitability of the business unit in a reporting period.

For selecting and prioritizing governance practices offered by the reference models, the Managing
Performance Reliability scenario offers “Usefulness” and “Efficiency” aspects of business performance. In
case of a service/production delivery business process, the performance reliability should enable customer
retention (measured by order renewal per contracting payoff periods) and capacity utilization (measured
by infrastructure and human resource utilization rates).

These two types of metrics help to identify relevance and weight of applicable governance
practices in supporting performance objectives. If lack or failure of a governance practice -
by considering together with other existing governance practices - represents undesirable
uncertainty on keeping “Usefulness” or “Efficiency” goals, then implementation or
improvement of the practice will be an adequate risk treatment option. If the lack or failure of
a governance practice has no significant effect on Enterprise Goals - by considering together

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 47/169

with other existing governance practices – this practice will be out of the scope of
implementation and assurance. Performance measurement is needed to establish the
concerning risk criteria and tolerance levels triggering immediate or scheduled management
actions.

For example: a failure (performance gap) of COBIT 4.1 PO2.4 Managing Data Integrity practices for
Accuracy governance objective in an IT-enabled outsourcing service - using automated data processing -
causes undesirable uncertainty in achievement of performance reliability. “Unusual” calculation errors or
overtime works already detected during a processing cycle (e.g. monthly calculation) might indicate potential
danger of serious client claims or unpaid resource consumption (more than planned capacity usage) during
next invoicing also effecting overall satisfaction (future client retention) and service capacity utilization. Client
dissatisfaction or capacity utilization problems are early indicators of effectiveness problems at Business Unit
level. In this case an identified performance gap at Managing Data Integrity practice triggers the
management actions for process improvement related to the Accuracy governance objective. Even if the
rd
data processing is supported by external IT solution (e.g. 3 party software), the relevance and importance
of Managing Data Integrity will remain within the service provider’s responsibility, however usage of well-
reputed or certified IT product or service will simplify the implementation of this governance practice.

For protecting own market position even smaller service providers use in-house IT solutions by considering
cost and effort of implementing governance practices against benefit for better performance reliability of
business operation.

The lower level metrics like error rate and human overtime work per operation cycle should be assessed
against company targets (or other reasonable benchmark) and measures over pre-established tolerances
should trigger the (re)assessment of Managing Data Integrity governance practices. If the assessed
performance gap is significant as effecting customer retention or capacity utilization by exceeding their
tolerances, then improvement action should be planned and implemented by the management. If detected
performance gaps were not affecting significantly the Reliability Goals of a service or production, then either
the triggering tolerances of lower level performance metrics might be reset, or - more likely - other related
governance practices should be also assessed. Relevance and weight of a governance practice should be
considered not just as an enabler of the related governance objective (e.g. Managing Data Integrity enables
achievement of Reliability Goals), but also as whether its implementation would have effect on the next level
Enterprise Goals. E.g. Managing Data Integrity shouldn’t cost more than reasonable in context of
Organizational Goals at Managing Operational Effectiveness level (might be measured by operating
margin and unit cost).

At corporate entity level the governance objectives related set of practices comprising
ISO/IEC 15504 compliant governance processes - as defined by the Governance Model -
are applicable for targeting and assessing them for even higher (e.g. level 2 or above)
governance capability. However from the selected business process view, as in the normal
cases of SME service or production delivery, the assessment target is mostly limited to
Compliance (1 - Performed) level, as this is the level where the application of specific
process outcomes and practices are investigated.

Targeting the Managed (level 2) or even higher level for the governance processes is applicable in the case
when capability target of the Managing Performance Reliability scenario were pre-established accordingly
(e.g. in compliance with strict regulatory requirements). The higher capability request for Managing
Performance Reliability should be determined by the Operational Risk Management function and also takes
other effected business processes into the same capability level context.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 48/169

3.3.4 Selecting Specific Application Practices as Risk Criteria for Reliability Goals

For fully achieving Process Performance attribute, the following specific outcomes should be evidenced
concerning to the governance processes supporting Performance Reliability:

• for Satisfactory Operation governance process:

o Requirements are established and maintained based on customer needs and expectations.

o Business relationship management is effective.

o Business operation supports its customers by achievement of agreed service level requirements.

• for Information Reliability governance process:

o Effective information architecture and data model are maintained.

o Information is systematically collected and assessed to detect compliance issues, privacy


problems and fraud.

o Control information for automated process settings, data manipulations and calculations are
maintained systematically.

• for Data Protection governance process:

o Preventive controls are maintained to avoid system security incidents.

o Anti-fraud management program is maintained.

o Privacy requirements are kept.

The applied Governance Model for Trusted Businesses offers recognized best practices supporting these
outcomes, however not all of them are necessary in context of the specific Enterprise Goals of the
organization. Management should select only those practices as assertions, which have evidential link to
“Usefulness” and “Efficiency” goals at this operational level. For Managing Performance Reliability these
goals might be: reasonable client retention and effective capacity utilization.

For careful consideration, management should set metrics like described in the sample Table 13: Application
Practices of Satisfactory Operation with possible metrics.

Where current metrics show significant deviation from management’s expectations (risk
appetite), the related practice should be implemented or improved. Where current metrics
are available and satisfactory to reasonable risk appetite, the application practice can be set
for management assertion.

The elaborated “Usefulness” and “Efficiency” metrics for the Satisfactory Operation, Information Integrity and
Data Protection governance practices can help management to develop management assertions by
selecting governance practices as risk criteria for the Reliability Goals.

By this way only those governance practices are scoped as capability indicators evidencing
achievement of specific governance outcomes (Process Performance attribute), which are
considered by the management as relevant based on its risk appetite. This consideration

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 49/169

might be “instinctive” or even “conscious” by following the Managing Operational Risks


scenario.

Managed capability (level 2) scoping takes client’s pay-off or contractual period based metrics into context of
longer term budget planning or reporting periods, which allows to perform trend analysis of historical data
sourcing from multiple operational instances and periods.

Significant or dramatic (material) deviations from statistical trends indicate that internal or external risk
factors should be reconsider followed by necessary actions in order to keep enterprise governance
framework effective. This is why Managed capability - level 2 - scoping for governance processes is valid, as
the wider/extended time-horizon and related objectives let management to use the performance metrics of
the Managing Performance Reliability scenario as early success or failure indicators of achieving business
unit or organization level operational effectiveness goals.

For example the trend for increasing volume of unsolved problems raised by customers during pay-off
periods may indicate lower overall client satisfaction rate in the future jeopardizing operational effectiveness
of the business unit or organization. However, handling only individual instances of deviations may take
potential seasonal or unique reasons out of consideration.

Typically a governance process - as defined by the Governance Model for Trusted Businesses - is not
performed as an individual project. For example Satisfactory Operation is incorporated into lower level
operational management of a service or product delivery (e.g. of an on-going service project); Information
Reliability and Data Protection are performed through external or internal IT service activities directly
supporting the business operation. Therefore the Managed (level 2) capability of these governance
processes is normally evidenced by Managing Operational Performance of core business processes and
their supporting projects. Of course it is not a “must” to cover any governance objective by the Managing
Operational Performance scenario (e.g. of a service project), as it depends on management’s decision on
scoping of governance capability levels.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 50/169

3.4 Managing Operational Effectiveness

3.4.1 Context and Specific Learning Objectives of Managing Operational Effectiveness

The following figure presents role of the Managing Operational Effectiveness scenario in supporting of
Enterprise Governance:

Figure 10: Role of the Managing Operational Effectiveness scenario in Enterprise Governance

In the context of Managing Operational Effectiveness, Enterprise Governance should focus on those
issues which are considered as relevant for the following sample management problems:

1. My organization (business unit) provides services or products according to internal or external


specifications by keeping delivery deadlines and quality requirements and satisfying customer
needs, however with lower than expected profitability.

2. Investment and development projects are not effective at business unit level. Delays and extra
efforts cause higher expenditures than planned for the reporting periods.

3. Overheads and general expenses of business operation are too high.

4. Unexpected losses due to missing or redundant controls over operation.

5. Applied IT system is not aligned with quantitative and qualitative performance objectives of business
operation.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 51/169

6. Human resource competencies and their utilization are not sufficient in supporting business
operation.

7. Design and operation of quality and control systems are not useful and/or effective.

Normally these issues are occurring and being managed in different time-scale than of the
other Integrated Risk Management scenarios. Managing Operational Performance is
limited to the individual instances of the business processes and activities by considering
service or product delivery requirements and schedule. Managing Performance Reliability
considers contractual pay-off cycles with parallel or reoccurring business operational cycles,
while Managing Operational Effectiveness typically has the time-horizon of the budgeting
or reporting periods. Managing Strategic Directions is focusing on longer perspectives.
Operational Risk Management takes each governance objective into its specific time-
horizon when setting risk criteria and measurable risk levels for selecting treatment options
and evaluating their effectiveness.

Any reoccurring deviation from entity (business unit) level operational effectiveness objectives like
profitability and agile resource allocation (rates per reporting periods) will call the management’s attention to
check whether lower level Operational Performance and Reliable Operation objectives are adequately
fulfilled as operational performance and reliability failures might also cause organizational level effectiveness
problems. Furthermore some operational performance and reliability metrics - like more than planned
resource usage, frequent corrective actions, customer dissatisfaction or low capacity utilization within
operational life-cycles - are going to be early indicators of effectiveness problems at entity (business unit)
level. Most of the operational effectiveness issues are coming to surface only by closures of budgeting or
reporting periods, so early indicators of Operational Performance and Reliable Operation will help
management and the boards (where they exist) to be more proactively prepared.

In case of no root cause having been found at Managing Operational Performance and Managing
Performance Reliability, then Exploitability, Process Integrity and Competency objectives and related
governance practices should be assessed whether the selection of practices and their capability targets are
aligned with the entity (business unit) level effectiveness goals or the implemented practices are achieving
their target capability levels.

Reoccurring deviations from profitability and agile resource allocation objectives are early indicators of those
Strategic Direction issues which might be identical only by reviewing strategic planning periods. Assessment
and improvement of Exploitability, Process Integrity and Competency objectives related process
capability profiles are necessary risk management actions not just enabling entity (business unit) level
operational effectiveness but also driving to better alignment to Strategic Directions.

Management actions taken during even longer than a reporting period (e.g. covering more quarterly or yearly
financial or management statements) to achieve Exploitability, Process Integrity and Competency
objectives - together with the other governance objectives - should be monitored by the board or other
supervisory bodies (or by equivalent functions of the entity), and adequate level of transparency to all of the
stakeholders should be provided by management disclosures.

This part of the handbook is focusing on the Managing Operational Effectiveness scenario, which enables
achievement of organizational goals such as profitability and agile resource allocation over operational
performance.

By the support of this Integrated Risk Management scenario, the organization:

• realizes optimal value from business operation;

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 52/169

• effectively designs and operates process-level controls relevant to the objectives of business
operation, and processing integrity principle;

• makes sufficient skills and knowledge relevant for the objectives of business operation available and
effectively used.

The enabling governance processes are:

• Exploitable Operation, adapting practices from Enterprise SPICE

• Process Control, adapting practices from COSO

• Control Competency, adapting practices from COSO

Applicable measures:

• Profitability (”usefulness”)
- Indicator: Operating Margin
- Time-horizon: reporting or budget planning periods

• Agile Resource Allocation (”efficiency”)


- Indicator: Unit Cost
- Time-horizon: reporting or budget planning periods

In this part of the handbook related to Managing Operational Effectiveness scenario, the Exploitability,
Process Integrity and Competency governance objectives are selected to provide applicable use cases for the
following learning objectives:

• Which key risk and risk factors are mitigated by the governance objectives referred by

o The Exploitable Operation application area aiming to ensure that organization realizes optimal
value from business operation.

o The Process Control (Integrity) application area aiming to ensure effective design and operation of
process-level controls relevant to the objectives of financial reporting and trusted business
operation, and processing integrity principle.

o The Control Competence application area aiming to ensure the availability and usage of sufficient
skills and knowledge relevant for the objectives of internal control over financial reporting and
trusted business operation.

• How to implement and evaluate application practices evidencing achievement of Exploitability


governance objective through the following outcomes:

o Investments for business operation needs and business potentials are performed deliberately.

o Project management practices are applied for business operation.

o Quality management practices are applied for business operation.

• How to implement and evaluate application practices evidencing achievement of Process Integrity
governance objective through the following outcomes:

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 53/169

o Control activities over access, amendments, adjustments and other usage of business information
are maintained systematically.

o Application and general IT controls are maintained.

o Process performance metrics are collected and evaluated.

• How to implement and evaluate application practices evidencing achievement of Competency


governance objective through the following outcomes:

o Recruitment, compensation and training activities are performed systematically.

o Staff members are continually informed, feedbacks are periodically reviewed.

o Competent individuals are retained in relation to the business operation, financial reporting and
related oversight roles.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 54/169

3.4.2 Selecting the Scope of the Management Assertions for Managing Operational
Effectiveness

A consistent risk assessment should be performed as the first step to establish management
assertions by linking business activities to applicable governance practices and capability
profiles for supporting the relevant governance objectives.

By using the definition of risk as “effect of uncertainties on objectives”, during the Managing Operational
Effectiveness scenario we have to identify the risk criteria (tolerances and appetite) for governance
objectives which are related to the entity (business unit) level Operational Effectiveness goals. In terms of
operational effectiveness we use the ”Usefulness” and “Efficiency” measures for setting metrics in time-
horizon of reporting (or budget planning) periods, for example:

• Profitability measured by operating margin

• Agile resource allocation measured by unit cost

For ensuring risk optimisation we need targets and tolerances e.g. measured by:

• Percentage of achieving operating margin for reporting periods and

• Variance from planned unit cost.

The effective business operation related Exploitability, Process Integrity and Competency governance
objectives should have such risk criteria which are applicable to measure effective risk treatment for
achieving profitability and agile resource allocation goals by applying governance practices. Applicable
governance practices should be selected and implemented by considering their relevance to the above
“Usefulness” and “Efficiency” measures.

If a lower level governance practice offered by the Governance Model has no significant relevance for the
established entity (business unit) level Operational Effectiveness goals, then there will be no need to apply
that. If management specifies a governance practice as relevant for managing effective business operation
within the context of stakeholders’ needs, then the target capability profile for implementing the governance
process will include it and will be used as risk criteria (risk appetite). Capability level target should be set
aligned with the relevant Enterprise Goals, as in this case in accordance with entity (business unit) level
Operational Effectiveness goals.

Entity (business unit) level Operational Effectiveness objectives (Organizational Goals) are common in each
type of business operation. However related governance practices and their capability levels might differ in
wide range. Effective small business units might run their operation without extensive implementation of
project and quality management, process control or human resource management practices as the much
lower overhead costs ensure either higher profitability or advantage of more competitive pricing. When
business volume is growing with facing to new customer requirements and organizational changes, then the
need for organizational investments and projects like applying new IT platforms, skills, and procedures, etc.
will emerge. Managing these organizational assets is a challenge even for the more matured enterprises.
Most of these efforts are very expensive and normally the success rate of organizational development
investments and projects are far away from expectations. By using of the Managing Operational
Effectiveness Integrated Risk Management scenario, the management will be able to select and apply
those governance practices which are relevant for improving or ensuring better entity (business unit) level
operational effectiveness based on the reliable performance of the well-established business operations.

Either well running operational practices are used to define standard processes or designing new processes
can help to improve operational performance at entity (business unit) level. Exploitability, Process Integrity
and Competency objectives related governance practices contribute to develop - level 3 - Established

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 55/169

capability of those core and supporting business processes which constitute baseline business operation by
establishing their organizational contexts.

Selection and implementation of those governance practices which are offered by the Governance Model
for Trusted Businesses for Exploitability, Process Integrity and Competency objectives should be
driven by the management’s usefulness and efficiency considerations. Therefore the optimal (meaningful)
coverage of offered governance practices, together with a capability profile aiming higher (e.g. Level 2 -
Managed or Level 3 - Established) requirements should be concluded by performing mature risk
management practices.

For supporting risk assessment the following risk tables for the Exploitability, Process Integrity and
Competency objectives can be used to understand key risk areas and applicable practices as risk
responses:

Applicable
Enterprise
Key Risk Risk Factors Responses Application Practices
SPICE
processes

The organization applies


Investment practices to ensure that
Necessary needs and Investment organization realize optimal
investments are potentials are Management value from strategically aligned
not taken considered (ESPICE) business investments at an
systematically affordable cost with a known
and acceptable level of risk.

The management applies


practices to ensure the
business projects achieve their
Opportunities Systematic
Management Project objectives within given
are not project
inefficiently use Management resource constraints by
exploited management
resources (ESPICE) initiating, planning, executing,
practices applied
monitoring, controlling and
closing the project activities
and resources.
The organization applies
practices to assure the quality
Systematic Quality
Product or of the product or service and of
quality Assurance and
service quality is the processes used, and
management Management
not ensured provide management with
practices applied (ESPICE)
appropriate visibility into all
relevant quality aspects.
Table 5: Exploitability related risk areas

Missing opportunities when business might be growing means losses in competitiveness. However even in
circumstances of sharp competition or market downturn, those practices which are supporting the right
balance of costs and benefits related to entity (business unit) level management of investments, projects and
quality assurance should be applied to keep sustainability.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 56/169

The implemented governance practices are tools for improving ability of the entity (business unit) to optimize
allocation and usage of available resources for running business operation in expected quality. The selected
governance practices provide implementation instances of the Exploitable Operation governance process
enabling the achievement of the following outcomes:

• Investments for business operation needs and business potentials are performed deliberately.

• Project management practices are applied for business operation.

• Quality management practices are applied for business operation.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 57/169

Applicable
Key Risk Risk Factors Responses Application Practices
COSO processes

Control activities
over access, Control activities are selected
amendments, and developed considering
Process Selection and
adjustments and their cost and their potential
performance is Development of
other usage of effectiveness in mitigating
wholly dependent Control Activities
business risks to the achievement of
on key staff (COSO)
information are financial reporting and trusted
maintained business operation objectives.
systematically
Application and Information technology
Defective Data processing
general IT controls, where applicable, are
process level and process Information
controls are designed and implemented to
controls automation Technology
maintained and support the achievement of
controls (COSO)
evaluated financial reporting and trusted
malfunction
systematically business operation objectives.

Ongoing and/or separate


Process evaluations enable
Failures of Ongoing and
performance management to determine
detecting errors Separate
metrics are whether internal control over
and reacting to Evaluations
collected and financial reporting and trusted
incidents (COSO)
evaluated business operation is present
and functioning.
Table 6: Process Integrity related risk areas

Internal controls built in business processes and supporting systems are important elements of ensuring
operational effectiveness by mitigating the downside risks (uncertainties having negative impact on business
objectives). However these controls and control activities should be carefully designed, implemented and
evaluated in context of the organizational goals. Some of them are defined as necessary outcomes of
business process descriptions to fulfil regulatory or other compliance requirements. Entity level controls
might be also defined as processes by applying COSO or COBIT reference models, which make ISO/IEC
15504 process assessment method applicable to evaluate effectiveness of control design (by determining
capability gaps between target and assessed process profiles) and effectiveness of control operation (by
determining control risk levels based on gap occurrences).

The selected governance practices provide implementation instances of the Process control governance
process enabling the achievement of the following outcomes:

• Control activities over access, amendments, adjustments and other usage of business information
are maintained systematically.

• Application and general IT controls are maintained.

• Process performance metrics are collected and evaluated.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 58/169

Applicable
COSO&COBIT
Key Risk Risk Factors Responses Application Practices
processes and
GAPP

Human resource policies and


Recruitment,
compensation practices are designed and
Human implemented to facilitate
Lack of skilled and training
Resources
staff activities are effective internal control over
(COSO)
performed financial reporting and trusted
systematically business operation.

Communications enable and


Staff members
Staff members support understanding and
Staff is unable are continually Internal
do not know execution of internal control
to perform informed, Communication
procedures and
control tasks feedbacks are (COSO) objectives, processes, and
processing
periodically individual responsibilities at all
requirements
reviewed levels of the organization.
The organization retains
Adequate human Governance
individuals competent in
resource (Financial
Changes of Skills relation to the organization’s
practices are Reporting)
Requirements business operation, financial
determined and Competencies
reporting and related oversight
used (COSO)
roles.
Table 7: Competency related risk areas

Management of human resources for ensuring availability of skilled staff supported by effective internal
communication and skills development options is an indispensable element of achieving entity (business
unit) level business goals. Lack of well-trained and adequately informed people will interfere to exploit
business opportunities, cause less flexibility in allocation of human capacity or request extra control efforts by
the management.

The selected governance practices provide implementation instances of the Control Competency
governance process enabling the achievement of the following outcomes:

• Recruitment, compensation and training activities are performed systematically.

• Staff members are continually informed, feedbacks are periodically reviewed.

• Competent individuals are retained in relation to the business operation, financial reporting and
related oversight roles.

The set of applied governance practices and the target Process Capability Attributes
comprise those risk criteria against the business performance should be assessed.
Evaluation of Process Attribute Gaps (between target and assessed capability) provides
measurement of residual risk status.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 59/169

3.4.3 Applying Management Assertions for Managing Operational Effectiveness

Management assertions are setting links between the business processes (and activities)
and the governance objective-driven processes (and base practices) offered by recognized
reference models (like COSO, COBIT and Enterprise SPICE). Management should reflect to
their own business goals and business environment’s expectations by setting target
capability profiles for the customized governance objectives (risk appetite) and adequate
quantitative control limits of tolerable deviations from Enterprise Goals (risk tolerance).
Governance Capability Assessment (Governance SPICE) methodology provides
measurement framework for targeting and assessing effectiveness of governance processes
(defined by ISO/IEC 15504 compliant reference models) in achievement of governance
objectives, however it should be carefully considered at the assessment scope definition,
that a governance process might be implemented and applied by more than one business
processes (and their instances) within a business operational unit.

For example in the case of Process Integrity objective concerning to the service/production delivery
business process, the management should determine the management and control activities necessary and
sufficient to limit the negative consequences of the inherent business risk related to failures in manual or
automatic processing of service/production related data and information.

Theoretically the management should apply a measure for determining direct impact on
specific business goals, however at business process level this measure can’t derived
directly from “natural” business measures like income, profitability, stock listing rate, market-
share, etc. This problem could be resolved by targeting application of governance practices
by the business process activities. The more relevant governance practices are applied; the
negative consequences are the more likely minimized.

However the adequate structure of performance measurement helps to navigate over


applicable governance practices (see Figure 4: Linking Governance Objectives to Enterprise
Goals & Measures). The governance practices are enabling achievement of Enterprise
Goals, so measurement related to achievement of governance objectives should support in-
time status information regarding overall business performance. Furthermore the lower level
operational or organizational goals and metrics should be established as enabling indicators
for the above governance level.

By this way the appearing deficiencies to target measures of Managing Performance Reliability - e.g. bad
satisfaction or capacity utilization rates in a service or production payoff period - might be early indicators of
possible failures at Managing Operational Effectiveness level - e.g. decreasing operating margin or
increasing unit cost detected by closing reporting periods. Similarly the metrics indicating deviation from
Organizational Goals call the attention for possible consequences in achievement of Strategic Business
Goals at Managing Strategic Directions level - e.g. missing revenue and cash flow targets of the
organization in longer perspective than the current reporting period.

For selecting and prioritizing governance practices offered by the reference models, the Managing
Operational Effectiveness scenario offers “Usefulness” and “Efficiency” aspects of business performance.
In case of a service or production delivery business process, the operational effectiveness should enable
profitability (measured by operating margin for reporting periods) and agile resource allocation (measured
by unit cost).

These two types of metrics help to identify relevance and weight of applicable governance
practices in supporting performance objectives. If lack or failure of a governance practice -
by considering together with other existing governance practices - represents undesirable
uncertainty on keeping “Usefulness” or “Efficiency” goals, then implementation or
improvement of the practice will be an adequate risk treatment option. If the lack or failure of

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 60/169

a governance practice has no significant effect on Enterprise Goals - by considering together


with other existing governance practices – this practice will be out of the scope of
implementation and assurance. Performance measurement is needed to establish the
concerning risk criteria and tolerance levels triggering immediate or scheduled management
actions.

For example: a failure (performance gap) of COSO IFC.CA.IT Information Technology practices for Process
Integrity governance objective in an outsourcing service – extensively using IT-enabled solutions - causes
undesirable uncertainty in achievement of expected operational effectiveness. Failures in e.g. IT operation,
change management, security management, etc. might cause less effective staff performance (double
entries, repeating activities, manual works or corrections) or other wasted resources and extra overhead
costs. Lower profitability and extra need for resource allocation are early indicators of potential deviation from
strategic business targets of the organization. In this case an identified performance gap at maintaining
Information Technology controls triggers the management actions for process improvement related to the
Process Integrity governance objective. Even if the data processing is supported by external IT solution (e.g.
rd
3 party software, IT infrastructure), the relevance and importance of maintaining Information Technology
controls will remain within the service provider’s responsibility. Even usage of well-reputed or certified IT
service will not simplify the implementation of this governance practice, as access controls and end-user
computing issues, data backups will remain in shared responsibility.

The lower level metrics like actual operational incomes and costs of used resources per reporting period
should be assessed against company targets (or other reasonable benchmark) and measures over pre-
established tolerances should trigger the (re)assessment of maintaining Information Technology governance
practices. If the assessed performance gap is significant as effecting profitability or resource utilization by
exceeding their tolerances, then improvement action should be planned and implemented by the
management. If detected performance gaps were not affecting significantly the Operational Effectiveness
goals of the service unit, then either the triggering tolerances of lower level performance metrics might be
reset, or - more likely - other related governance practices should be also assessed. Relevance and weight
of a governance practice should be considered not just as an enabler of the related governance objective
(e.g. maintaining Information Technology controls enables achievement of Operational Effectiveness goals),
but also as whether its implementation would have effect on the next level Enterprise Goals. E.g. Maintaining
Information Technology controls shouldn’t cost more than reasonable in context of Strategic Business Goals
at Managing Strategic Directions level (might be measured by business revenue and cash flow figures).

At corporate level the governance objectives related set of practices comprising ISO/IEC
15504 compliant governance processes - as defined by the Governance Model - are
applicable for targeting and assessing them for even higher (e.g. level 2 or above)
governance capability. However from the selected business process view, as in the normal
cases of SME service or production delivery, the assessment target is mostly limited to
Compliance (1 - Performed) level, as this is the level where the application of specific
process outcomes and practices are investigated.

Targeting the Managed (level 2) or even higher level for the governance processes is applicable in the case
when capability target of the Managing Operational Effectiveness scenario were pre-established
accordingly (e.g. in compliance with strict regulatory requirements). The higher capability request for
Managing Operational Effectiveness should be determined by the Operational Risk Management function
and also takes other effected business units (e.g. not just the Service Unit, but others like the Sales, IT
Development, etc. units) into the same capability level context.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 61/169

3.4.4 Selecting Specific Application Practices as Risk Criteria for Operational


Effectiveness Goals

For fully achieving Process Performance attribute, the following specific outcomes should be evidenced
concerning to the governance processes supporting Operational Effectiveness at business unit level:

• for Exploitable Operation governance process:

o Investments for business operation needs and business potentials are performed deliberately.

o Project management practices are applied for business operation.

o Quality management practices are applied for business operation.

• for Process Control governance process:

o Control activities over access, amendments, adjustments and other usage of business information
are maintained systematically.

o Application and general IT controls are maintained.

o Process performance metrics are collected and evaluated.

• for Control Competence governance process:

o Recruitment, compensation and training activities are performed systematically.

o Staff members are continually informed, feedbacks are periodically reviewed.

o Competent individuals are retained in relation to the business operation, financial reporting and
related oversight roles.

The applied Governance Model for Trusted Businesses offers recognized best practices supporting these
outcomes, however not all of them are necessary in context of the specific Enterprise Goals of the
organization. Management should select only those practices as assertions, which have evidential link to
“Usefulness” and “Efficiency” goals at this operational level. For Managing Operational Effectiveness
these goals might be: reasonable profitability and effective resource allocation.

For careful consideration, management should set metrics like described in the sample Table 14: Application
Practices of Exploitable Operation with possible metrics.

Where current metrics show significant deviation from management’s expectations (risk
appetite), the related practice should be implemented or improved. Where current metrics
are available and satisfactory to reasonable risk appetite, the application practice can be set
for management assertion.

The elaborated “Usefulness” and “Efficiency” metrics for the Exploitable Operation, Process Control and
Control Competence governance practices can help management to develop management assertions by
selecting governance practices as risk criteria for the Operational Effectiveness goals.

By this way only those governance practices are scoped as capability indicators evidencing
achievement of specific governance outcomes (Process Performance attribute), which are
considered by the management as relevant based on its risk appetite. This consideration

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 62/169

might be “instinctive” or even “conscious” by following the Managing Operational Risks


scenario.

Managed capability (level 2) scoping takes budget planning or reporting period based metrics into context of
longer strategic planning periods, which allows performing trend analysis of historical data sourcing from
multiple reporting data and periods.

Significant or dramatic (material) deviations from strategic plans indicate that internal or external risk factors
should be reconsider followed by necessary actions in order to keep enterprise governance framework
effective. This is why Managed capability - level 2 - scoping for governance processes is valid, as the
wider/extended time-horizon and related objectives let management to use the performance metrics of the
Managing Operational Effectiveness scenario as early success or failure indicators of achieving strategic
business goals.

For example the trend for decreasing operating margin or increasing unit cost may indicate lower operational
effectiveness of the business unit or organization in the future jeopardizing business sustainability. However,
handling only individual instances of deviations may take potential seasonal or unique reasons out of
consideration.

Typically a governance process - as defined by the Governance Model for Trusted Businesses - is not
performed as an individual project. For example Exploitable Operation is incorporated into organizational
management of a business unit; Process Control and Control Competence are performed through business
unit management activities directly supporting the business operation. Therefore the Managed (level 2)
capability of these governance processes is normally evidenced by business unit management activities and
their supporting projects.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 63/169

3.5 Managing Strategic Directions

3.5.1 Context and Specific Learning Objectives of Managing Strategic Directions

The following figure presents role of the Managing Strategic Directions scenario in supporting of Enterprise
Governance:

Figure 11: Role of the Managing Strategic Directions scenario in Enterprise Governance

In the context of Managing Strategic Directions, Enterprise Governance should focus on those issues
which are considered as relevant for the following sample management problems:

1. My company runs successful business operation(s) with expected profitability; however the
organization is not proactive enough to react well to the rapidly changing business environment and
market demands.

2. Due to changing or new client requirements and growing competition our business offers and
proposals are not received as well as in past.

3. New business operation (service or product) start-up is in progress which requests new
organizational structures and procedures.

4. Increasing volume of business operation request more robust business continuity planning.

5. Changes in business volume need to explore new funding solutions by extensive communications
with external parties.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 64/169

6. New shareholders, investors request more transparency and management accountability over
running business operation(s).

7. Stakeholders request attestation and public disclosures of business excellence.

Normally these issues are occurring and being managed in different time-scale than of the
other Integrated Risk Management scenarios. Managing Operational Performance is
limited to the individual instances of the business processes and activities by considering
service or product delivery requirements and schedule. Managing Performance Reliability
considers contractual pay-off cycles with parallel or reoccurring business operational cycles,
while Managing Operational Effectiveness typically has the time-horizon of the budgeting
or reporting periods. Managing Strategic Directions is focusing on longer perspectives.
Operational Risk Management takes each governance objective into its specific time-
horizon when setting risk criteria and measurable risk levels for selecting treatment options
and evaluating their effectiveness.

Any reoccurring deviation from company level strategic business objectives like achieving business goals
and availability of funding resources (indicators for strategic planning periods) will call the management’s
attention to check whether lower level Operational Performance, Reliable Operation and Operational
Effectiveness objectives are adequately fulfilled as operational performance, reliability and entity/business
unit level effectiveness failures might also cause problems in achieving strategic objectives. Furthermore
some operational performance, reliability and effectiveness metrics - like more than planned resource usage,
frequent corrective actions, customer dissatisfaction, low capacity utilization within operational life-cycles and
decreasing operating margin or increasing unit costs during reporting periods - are going to be early
indicators of problems in achieving strategic business objectives at company level. Most of the strategic
issues are coming to surface only by reviewing or closing strategic planning periods, so early indicators of
Operational Performance, Reliable Operation and Operational Effectiveness will help management and the
boards (where they exist) to be more proactively prepared to strategic challenges.

In case of no root cause having been found at Managing Operational Performance, Managing
Performance Reliability and Managing Operational Effectiveness, then Competitiveness,
Accountability and Commitment objectives and related governance practices should be assessed whether
the selection of practices and their capability targets are aligned with the company level strategic goals or the
implemented practices are achieving their target capability levels.

Reoccurring deviations from profitability and agile resource allocation objectives are early indicators of those
Strategic Direction issues which might be identical only by reviewing strategic planning periods. Assessment
and improvement of Competitiveness, Accountability and Commitment objectives related process
capability profiles are necessary risk management actions enabling better alignment to Strategic Directions.

Management actions taken during strategic planning period to achieve Competitiveness, Accountability
and Commitment objectives - together with the other governance objectives - should be monitored by the
board or other supervisory bodies (or by equivalent functions of the entity), and adequate level of
transparency to all of the stakeholders should be provided by management disclosures.

This part of the handbook is focusing on the Managing Strategic Directions scenario, which enables
achievement of strategic objectives such as achieving business goals and availability of funding resources.

By the support of this Integrated Risk Management scenario, the organization is enabled:

• to ensure market recognition of the business operation;

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 65/169

• to ensure that the management of the organization is able to control business processes in a way
which is adequate to the objectives of internal control over financial reporting and trusted business
operation;

• to ensure that the organization and its staff are committed to comply with ethical and integrity
requirements relevant to the objectives of financial reporting and trusted business operation, and
availability principle.

The enabling governance processes are:

• Competitive Operation, adapting practices from Enterprise SPICE

• Control Management, adapting practices from COSO

• Integrity Assurance, adapting practices from COSO and COBIT

Applicable measures:

• Business Goals (”usefulness”)


- Indicator: Revenues
- Time-horizon: strategic planning periods

• Funding Resources (”efficiency”)


- Indicator: Cash Flow
- Time-horizon: strategic planning periods

In this part of the handbook related to Managing Strategic Directions scenario, the Competitiveness,
Accountability and Commitment governance objectives are selected to provide applicable use cases for the
following learning objectives:

• Which key risk and risk factors are mitigated by the governance objectives referred by

o The Competitive Operation application area aiming to ensure market recognition of the business
operation.

o The Control Management (Accountability) application area aiming to ensure that the management
of the organization is able to control business processes in a way which is adequate to the
objectives of internal control over financial reporting and trusted business operation.

o The Integrity Assurance (Commitment) application area aiming to ensure that the organization and
its staff are committed to comply with ethical and integrity requirements relevant to the objectives
of financial reporting and trusted business operation, and availability principle.

• How to implement and evaluate application practices evidencing achievement of Competitiveness


governance objective through the following outcomes:

o Business goals and targets are systematically maintained.

o Customers and other stakeholder needs and expectations are considered for improvement of
product or service features.

o Effective proposal preparation practices are maintained.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 66/169

• How to implement and evaluate application practices evidencing achievement of Accountability


governance objective through the following outcomes:

o Policies and procedures relevant for the governance objectives of financial reporting and trusted
business operation are consistently implemented and communicated.

o Management structure is adequate to internal control over financial reporting and trusted business
operation.

o Management takes stimulating behavior for supporting internal control over financial reporting and
trusted business operation.

• How to implement and evaluate application practices evidencing achievement of Commitment


governance objective through the following outcomes:

o Ethical values are articulated and kept.

o Active policies and procedures are in place to ensure business continuity.

o Information from external parties are collected and reviewed systematically.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 67/169

3.5.2 Selecting the Scope of the Management Assertions for Managing Strategic
Directions

A consistent risk assessment should be performed as the first step to establish management
assertions by linking business activities to applicable governance practices and capability
profiles for supporting the relevant governance objectives.

By using the definition of risk as “effect of uncertainties on objectives”, during the Managing Strategic
Directions scenario we have to identify the risk criteria (tolerances and appetite) for governance objectives
which are related to the company level Strategic Directions. In terms of strategic directions we use the
”Usefulness” and “Efficiency” measures for setting metrics in time-horizon of strategic planning periods, for
example:

• Business goals measured by revenues

• Funding resources measured by cash flow

For ensuring risk optimisation we need targets and tolerances e.g. measured by:

• Percentage of achieving revenue targets for strategic planning periods and

• Variance from planned cash flow.

The strategic directions related Exploitability, Process Integrity and Competency governance objectives
should have such risk criteria which are applicable to measure effective risk treatment for achieving business
goals and funding resources by applying governance practices. Applicable governance practices should be
selected and implemented by considering their relevance to the above “Usefulness” and “Efficiency”
measures.

If a lower level governance practice offered by the Governance Model has no significant relevance for the
established company level Strategic Directions, then there will be no need to apply that. If management
specifies a governance practice as relevant for managing strategic directions within the context of
stakeholders’ needs, then the target capability profile for implementing the governance process will include it
and will be used as risk criteria (risk appetite). Capability level target should be set aligned with the relevant
Enterprise Goals, as in this case in accordance with company level Strategic Business goals.

Settings of Strategic Directions (Strategic Business Goals) are similar in each type of business organization.
However related governance practices and their capability levels might differ in wide range. Effective small
enterprises might run their business operation without extensive implementation of strategic planning, control
management or integrity assurance practices. When business volume is growing with facing to new
customer requirements and organizational changes, then the need for more formal strategic thinking, higher
level of transparency and accountability together with commitment to business integrity and availability
principles will emerge. Managing these needs according to expectations of the business environment and
the stakeholders is a challenge even for the more matured enterprises. By using of the Managing Strategic
Directions Integrated Risk Management scenario, the management will be able to select and apply those
governance practices which are relevant for improving or ensuring better market recognition, transparency
and accountability of company management and commitment to business excellence.

Either well running management practices are used to define policies and procedures or designing new
management processes can help to improve governance at company level. Competitiveness,
Accountability and Commitment objectives related governance practices contribute to develop - level 3 -
Established capability of those management processes which constitute management of business operation
by establishing their organizational contexts.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 68/169

Selection and implementation of those governance practices which are offered by the Governance Model
for Trusted Businesses for Competitiveness, Accountability and Commitment objectives should be
driven by the management’s usefulness and efficiency considerations. Therefore the optimal (meaningful)
coverage of offered governance practices, together with a capability profile aiming higher (e.g. Level 2 -
Managed or Level 3 - Established) requirements should be concluded by performing mature risk
management practices.

For supporting risk assessment the following risk tables for the Competitiveness, Accountability and
Commitment objectives can be used to understand key risk areas and applicable practices as risk
responses:

Applicable
Enterprise
Key Risk Risk Factors Responses Application Practices
SPICE
processes

Business The organization applies


objectives are Business goals practices to establish
Enterprise
not reflecting to and targets are strategic enterprise direction
Governance
the changes of systematically and ensure the enterprise
(ESPICE)
economic maintained achieves its goals and
environment objectives.
The organization applies
Improvement of
practices to elicit, analyze,
product or
Market needs are clarify, and document
service features Needs (ESPICE)
not respected evolving customer and other
are considered
stakeholder needs and
Loosing market periodically
expectations.
The organization applies
practices to identify, select
and bid for acquirer requests
Business Improvement of for information, quotations
Tendering
proposals are not proposal and proposals based on
(ESPICE)
convincing preparation decisions that appropriately
consider customer needs,
risks, organizational abilities
and competitor capabilities.
Table 8: Competitiveness related risk areas

Loosing market during strategic time-horizon means danger for business sustainability. A short term impact
is the decreasing value of the company (stock) jeopardizing working conditions of the management and the
employees. For longer term the ownership structure of the company or the legal entity owning the business
operation might be dramatically changed, or at worst case the business operation might be terminated.

The implemented governance practices are tools for improving ability of the company to refine its strategy
and aligned business goals according to the changeable business environment and clients’ needs and to
maintain successful proposal preparation practices to achieve sales targets. The selected governance
practices provide implementation instances of the Competitive Operation governance process enabling the
achievement of the following outcomes:

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 69/169

• Business goals and targets are systematically maintained.

• Customers and other stakeholder needs and expectations are considered for improvement of
product or service features.

• Effective proposal preparation practices are maintained.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 70/169

Applicable
Key Risk Risk Factors Responses Application Practices
COSO processes

Governance policies related to


reliable financial reporting and
No consistent or trusted business operation are
Policies and
properly Policies and established and communicated
procedures are
communicated Procedures
maintained and throughout the organisation,
policies and (COSO)
used in operation with corresponding procedures
procedures
resulting in management
directives being carried out.
Management is Management and employees
unable to are assigned appropriate levels
control Management Roles and Authority and of authority and responsibility
business structure is responsibilities Responsibility to facilitate effective internal
processes
inadequate are identified (COSO) control over financial reporting
and trusted business
operation.
Management’s philosophy and
Management’s operating style support
Management Management
Philosophy and achieving effective internal
attitude is not takes stimulating
Operating Style control over financial reporting
exemplary behaviour
(COSO) and trusted business
operation.
Table 9: Accountability related risk areas

Accountability of the management is evidently important for all stakeholders of the company. Normally the
legal documents and the company law extended with the internal policies and procedures constitute the
static environment for management accountability, however this should be also dynamic to effectively
respond to the current needs or changes of the running business operation. Therefore the governance
practices enabling effective management control of business operation should be selected and implemented
not just according to legal requirements, but also in alignment with the strategic business objectives, the
clients’ needs and the expectations of business environment.

The selected governance practices provide implementation instances of the Control Management
governance process enabling the achievement of the following outcomes:

• Policies and procedures relevant for the governance objectives of financial reporting and trusted
business operation are consistently implemented and communicated.

• Management structure is adequate to internal control over financial reporting and trusted business
operation.

• Management takes stimulating behavior for supporting internal control over financial reporting and
trusted business operation.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 71/169

Applicable
Key Risk Risk Factors Responses COSO&COBIT Application Practices
processes

Sound integrity and ethical


values, particularly of top
Ethical values Integrity and
No commitment management, are developed and
are articulated Ethical Values
to ethical values understood and set the standard
and followed (COSO)
of conduct for financial reporting
and trusted business operation.

Active policies Satisfy the business requirement


Interruption of
Business and procedures Ensure of ensuring minimal business
information and
integrity is not are in place to Continuous
communication impact in the event of an IT
respectable ensure business Service (COBIT)
systems service interruption.
continuity
Matters affecting the
Information from
External achievement of the financial
external parties External
feedbacks and reporting and trusted business
are collected and Communication
opinions are not operation objectives are
reviewed (COSO)
considered communicated with outside
systematically
parties.
Table 10: Commitment related risk areas

Commitment to business ethics, integrity and availability (business continuity) principles is an important
message to the market that the company management is aware of and manage reputation risks. The
implementation of these principles are embedded in the effectively managed, reliable business operations,
however company level attestation and communication of business excellence have additional value for the
stakeholders. Companies might get advantages from not only mitigating reputation risks, but even increase
their competitiveness by qualifying and presenting their strengths in governance and high capability profiles
for trusted business operation.

The selected governance practices provide implementation instances of the Integrity Assurance
governance process enabling the achievement of the following outcomes:

• Ethical values are articulated and kept.

• Active policies and procedures are in place to ensure business continuity.

• Information from external parties are collected and reviewed systematically.

The set of applied governance practices and the target Process Capability Attributes
comprise those risk criteria against the business performance should be assessed.
Evaluation of Process Attribute Gaps (between target and assessed capability) provides
measurement of residual risk status.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 72/169

3.5.3 Applying Management Assertions for Managing Strategic Directions

Management assertions are setting links between the business processes (and activities)
and the governance objective-driven processes (and base practices) offered by recognized
reference models (like COSO, COBIT and Enterprise SPICE). Management should reflect to
their own business goals and business environment’s expectations by setting target
capability profiles for the customized governance objectives (risk appetite) and adequate
quantitative control limits of tolerable deviations from Enterprise Goals (risk tolerance).
Governance Capability Assessment (Governance SPICE) methodology provides
measurement framework for targeting and assessing effectiveness of governance processes
(defined by ISO/IEC 15504 compliant reference models) in achievement of governance
objectives, however it should be carefully considered at the assessment scope definition,
that a governance process might be implemented and applied by more than one business
processes (and their instances) within a business operational unit.

For example in the case of Accountability objective concerning to the service/production delivery business
process, the management should determine the management and control activities necessary and sufficient
to limit the negative consequences of the inherent business risk related to the missing or inadequately
defined company level policies and procedures, authorities and responsibilities over business operation; and
related to the equivocal management behaviour. These organizational contexts of the specific process
performance are enabled by fulfilling the Established - level 3 - capability requirements.

Theoretically the management should apply a measure for determining direct impact on
specific business goals, however at business process level this measure can’t derived
directly from “natural” business measures like income, profitability, stock listing rate, market-
share, etc. This problem could be resolved by targeting application of governance practices
by the business process activities. The more relevant governance practices are applied; the
negative consequences are the more likely minimized.

However the adequate structure of performance measurement helps to navigate over


applicable governance practices (see Figure 4: Linking Governance Objectives to Enterprise
Goals & Measures). The governance practices are enabling achievement of Enterprise
Goals, so measurement related to achievement of governance objectives should support in-
time status information regarding overall business performance. Furthermore the lower level
operational or organizational goals and metrics should be established as enabling indicators
for the above governance level.

By this way the appearing deficiencies to target measures of Managing Operational Effectiveness - e.g.
decreasing operating margin or increasing unit costs in a reporting period - might be early indicators of
possible failures at Managing Strategic Directions level - e.g. missing the revenue targets or unbalanced
cash flow detected by reviewing or closing strategic planning periods.

For selecting and prioritizing governance practices offered by the reference models, the Managing Strategic
Directions scenario offers “Usefulness” and “Efficiency” aspects of business performance. In case of
service/production operation, the alignment to strategic directions should enable achievement of business
goals (measured by revenues for strategic planning periods) and availability of funding resources
(measured by cash flow).

These two types of metrics help to identify relevance and weight of applicable governance
practices in supporting performance objectives. If lack or failure of a governance practice -
by considering together with other existing governance practices - represents undesirable
uncertainty on keeping “Usefulness” or “Efficiency” goals, then implementation or
improvement of the practice will be an adequate risk treatment option. If the lack or failure of
a governance practice has no significant effect on Enterprise Goals - by considering together

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 73/169

with other existing governance practices – this practice will be out of the scope of
implementation and assurance. Performance measurement is needed to establish the
concerning risk criteria and tolerance levels triggering immediate or scheduled management
actions.

For example: a failure (performance gap) of COSO IFC.CE.AR Authority and Responsibility practices for
Accountability governance objective in a company running outsourcing service – with sharing responsibilities
over user organizations’ internal control - causes undesirable uncertainty in achievement of recognition as
excellent and trusted business partner. Failures in e.g. in defining management and staff responsibilities,
authorities and empowerment might cause reputational damages and loosing competitiveness leading to
potential deviation from strategic business targets of the organization. In this case an identified performance
gap at maintaining Authority and Responsibility controls triggers the management actions for process
improvement related to the Accountability governance objective. External requirements for the service
organizations controls over an outsourcing service - like SOC 1 and SOC 2 – emphasize the relevance and
importance of maintaining Authority and Responsibility controls.

The lower level metrics like coverage of business operation (relevant for achieving business goals and
effectively using funding resources) by defined and assigned authorities and responsibilities should be
assessed against company targets (or other reasonable benchmark) and measures over pre-established
tolerances should trigger the (re)assessment of Authority and Responsibility governance practices. If the
assessed performance gap is significant as effecting revenue or cash flow targets by exceeding their
tolerances, then improvement action should be planned and implemented by the management. If detected
performance gaps were not affecting significantly the Strategic Business Goals of the company running
outsourcing service, then either the triggering tolerances of lower level performance metrics might be reset,
or - more likely - other related governance practices should be also assessed. Relevance and weight of a
governance practice should be considered as an enabler of the related governance objective (like
maintaining Authority and Responsibility controls enables achievement of Accountability objective supporting
Strategic Business Goals).

At corporate level the governance objectives related set of practices comprising ISO/IEC
15504 compliant governance processes - as defined by the Governance Model - are
applicable for targeting and assessing them for even higher (e.g. level 2 or above)
governance capability. However from the selected business process view, as in the normal
cases of SME service or production delivery, the assessment target is mostly limited to
Compliance (1 - Performed) level, as this is the level where the application of specific
process outcomes and practices are investigated.

Targeting the Managed (level 2) or even higher level for the governance processes is applicable in the case
when capability target of the Managing Strategic Directions scenario were pre-established accordingly
(e.g. in compliance with strict regulatory requirements). The higher capability request for Managing Strategic
Directions should be determined by the Operational Risk Management function and also takes other effected
business units (e.g. not just the Service Unit, but others like the Sales, IT Development, etc. units) into the
same capability level context.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 74/169

3.5.4 Selecting Specific Application Practices as Risk Criteria for Strategic Directions

For fully achieving Process Performance attribute, the following specific outcomes should be evidenced
concerning to the governance processes supporting Strategic Directions at company level:

• for Competitive Operation governance process:

o Business goals and targets are systematically maintained.

o Customers and other stakeholder needs and expectations are considered for improvement of
product or service features.

o Effective proposal preparation practices are maintained.

• for Control Management governance process:

o Policies and procedures relevant for the governance objectives of financial reporting and trusted
business operation are consistently implemented and communicated.

o Management structure is adequate to internal control over financial reporting and trusted business
operation.

o Management takes stimulating behavior for supporting internal control over financial reporting and
trusted business operation.

• for Integrity Assurance governance process:

o Ethical values are articulated and kept.

o Active policies and procedures are in place to ensure business continuity.

o Information from external parties are collected and reviewed systematically.

The applied Governance Model for Trusted Businesses offers recognized best practices supporting these
outcomes, however not all of them are necessary in context of the specific Enterprise Goals of the
organization. Management should select only those practices as assertions, which have evidential link to
“Usefulness” and “Efficiency” goals at this operational level. For Managing Strategic Directions these goals
might be: achieving revenue target and available funding resources.

For careful consideration, management should set metrics like described in the sample Table 15: Application
Practices of Competitive Operation with possible metrics.

Where current metrics show significant deviation from management’s expectations (risk
appetite), the related practice should be implemented or improved. Where current metrics
are available and satisfactory to reasonable risk appetite, the application practice can be set
for management assertion.

The elaborated “Usefulness” and “Efficiency” metrics for the Competitive Operation, Control Management
and Integrity Assurance governance practices can help management to develop management assertions by
selecting governance practices as risk criteria for the Strategic Business Goals.

By this way only those governance practices are scoped as capability indicators evidencing
achievement of specific governance outcomes (Process Performance attribute), which are

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 75/169

considered by the management as relevant based on its risk appetite. This consideration
might be “instinctive” or even “conscious” by following the Managing Operational Risks
scenario.

Managed capability (level 2) scoping takes reporting period based metrics into context of longer strategic
planning periods, which allows performing trend analysis of historical data sourcing from multiple reporting
data and periods.

Significant or dramatic (material) deviations from strategic plans indicate that internal or external risk factors
should be reconsider followed by necessary actions in order to keep enterprise governance framework
effective. This is why Managed capability - level 2 - scoping for governance processes is valid, as the
wider/extended time-horizon and related objectives let management to use the performance metrics of the
Managing Strategic Directions scenario as success or failure indicators of achieving longer term strategic
business goals.

For example the trend for decreasing success rate of proposals may indicate lower competitiveness of the
company jeopardizing business sustainability. However, handling only individual instances of deviations may
take potential seasonal or unique reasons out of consideration.

Typically a governance process - as defined by the Governance Model for Trusted Businesses - is not
performed as an individual project. For example Competitive Operation is incorporated into executive
management of the company; Control Management and Integrity Assurance are under the direct supervision
of the board. Therefore the Managed (level 2) capability of these governance processes is normally
evidenced at executive and board level management, supervision and their supporting (e.g. sales, internal
audit, etc.) activities.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 76/169

3.6 Managing Operational Risks

3.6.1 Context and Specific Learning Objectives of Managing Operational Risks

The following figure presents role of the Managing Operational Risks scenario in supporting of Enterprise
Governance:

Figure 12: Role of the Managing Operational Risks scenario in Enterprise Governance

In the context of Managing Operational Risks, Enterprise Governance should focus on those issues which
are considered as relevant for the following sample management problems:

1. My company, which is well established and recognized by the target market, is running effective
business operation(s) according to the stakeholder needs and expectations of the business
environment; however increasing uncertainties - related to the market needs, the competitors, the
technologies, the labour market, the regulatory environment and the funding conditions, etc. -
request to implement a more robust risk management system.

2. We have several compliance audit reports (for financial controls, quality assurance, technical and
environmental requirements, etc.); however they are not providing convincing evidences in
assurance of achieving our business targets and avoiding failures.

3. We would like to measure effectiveness of our compliance, internal control and audit functions and
efforts by their contribution to business success.

4. Stakeholders request more transparency over risk management and control of business operations.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 77/169

5. We would like to qualify our business operations as according to the Governance Model for Trusted
Businesses by presenting implementation of the governance processes in measurable and
comparable forms.

Normally these issues are occurring and being managed in different time-scale than of the
other Integrated Risk Management scenarios. Managing Operational Performance is
limited to the individual instances of the business processes and activities by considering
service or product delivery requirements and schedule. Managing Performance Reliability
considers contractual pay-off cycles with parallel or reoccurring business operational cycles,
while Managing Operational Effectiveness typically has the time-horizon of the budgeting
or reporting periods. Managing Strategic Directions is focusing on longer perspectives.
Operational Risk Management takes each governance objective into its specific time-
horizon when setting risk criteria and measurable risk levels for selecting treatment options
and evaluating their effectiveness.

As presented at the other four Integrated Risk Management scenarios, the reoccurring deviations from
operational and organizational level Enterprise Goals call the management’s attention to check whether
lower level governance objectives are adequately fulfilled. Lower level performance gaps might indicate
longer term and higher level consequences, so they play early signalling role for management and
supervision bodies. In case of no root cause having been found at lower levels then the governance
objectives and related practices at the level where the deviation is identified should be carefully investigated.

The governance objectives are mediators between business goals and operational and organizational
capabilities by keeping management directions aligned with the expectations of the stakeholders and the
business environment. Therefore boards and other supervision bodies should be aware of and competent in
how the overarching governance structure of the business entity is in compliance with the stakeholders
needs. The Managing Operational Risks scenario provides the tools for overseeing operational and
organizational management levels. Direct benefits of effective risk management are often not appearing in
business success indicators, and mitigating controls or risk sharing methods might take significant efforts
and costs. However risk management should make balance between costs and rewards for the overall
benefit of the business stakeholders. Risk Awareness and Control Efficiency governance objectives and
related governance practices together with Quantitative Performance Management are used to drive all
the Enterprise Goals driven Integrated Risk Management scenarios by adequately setting risk appetite and
risk tolerances as risk criteria for measuring effectiveness of the more or less formulized risk treatment
cycles performed by management activities.

Management actions taken to achieve governance objectives by implementing the Integrated Risk
Management scenarios under risk treatment cycles should be monitored by the board or other supervisory
bodies (or by equivalent functions of the entity), and adequate level of transparency to all of the stakeholders
should be provided by management disclosures.

This part of the handbook is focusing on the Managing Operational Risks scenario, which supports the
achievement of strategic, operational effectiveness, reliability and performance objectives.

By the support of this Integrated Risk Management scenario, the organization is enabled:

• to ensure that the organization and its staff adequately address risks to the governance objectives
relevant for financial reporting and trusted business operation and consider those risks in
management of business operation;

• to ensure efficient usage of control resources relevant to the objectives of financial reporting and
trusted business operation;

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 78/169

• to ensure that performance of the organization’s implemented governance processes support the
achievement of the organization’s relevant business goals.

The enabling governance processes are:

• Control Risks, adapting practices from COSO

• Control Efficiency, adapting practices from COSO

• Quantitative Performance Management, adapting practices from ISO/IEC TR 15504-7

Applicable measures:

• Governance Capability - Risk Appetite (”usefulness”)


- Indicator: specific and generic practices for governance processes
- Time-horizon: as of related Integrated Risk Management scenarios
• Alignment to Enterprise Goals - Risk Tolerance (”efficiency”)
- Indicator: variance from established limits of Enterprise Goals
- Time-horizon: as of related Integrated Risk Management scenarios

In this part of the handbook related to Managing Operational Risks scenario, the Risk Awareness and Control
Efficiency governance objectives together with the Quantitative Performance Management practices are
selected to provide applicable use cases for the following learning objectives:

• Which key risk and risk factors are mitigated by the governance objectives referred by

o The Control Risks application area aiming to ensure that the organization and its staff adequately
address risks to the governance objectives relevant for financial reporting and trusted business
operation and consider those risks in management of business operation.

o The Control Efficiency application area aiming to ensure efficient usage of control resources
relevant to the objectives of financial reporting and trusted business operation.

o The Quantitative Performance Management application area aiming to establish and maintain a
quantitative understanding of the performance of the organization’s processes through
measurement and the use of appropriate quantitative techniques to ensure that performance of
the organization’s implemented processes support the achievement of the organization’s relevant
business goals.

• How to implement and evaluate application practices evidencing achievement of Risk Awareness
governance objective through the following outcomes:

o Governance objectives relevant for financial reporting and trusted business operation are
established.

o Risk assessments are performed consistently.

o Organization’s internal controls are integrated with risks to achievement of organization’s


objectives relevant for financial reporting and trusted business operation.

• How to implement and evaluate application practices evidencing achievement of Control Efficiency
governance objective through the following outcomes:

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 79/169

o Adequate organizational structure and reporting lines are maintained.

o Oversight of internal controls is effective.

o Control deficiencies are reviewed and necessary actions are taken.

• How to implement and evaluate application practices evidencing achievement of Quantitative


Performance Management objective through the following outcomes:

o Processes or process elements are selected for quantitative management on the basis of their
relevance and significance to the achievement of business goals;

o Measures and analytical techniques to be used in statistically managing the processes or process
elements are established and maintained;

o Process performance data is collected and analyzed using appropriate statistical or other
quantitative techniques to establish an understanding of the variation of the selected processes or
process elements;

o Results of data analysis are used to identify special causes of variation (assignable causes) in
process performance;

o Corrective and preventive actions are implemented to address the special and other causes of
variation; and

o Performance of the selected processes or process elements is monitored and controlled to


establish stable, capable and predictable processes within control limits.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 80/169

3.6.2 Selecting the Scope of the Management Assertions for Managing Operational
Risks

A consistent risk assessment should be performed as the first step to establish management
assertions by linking business activities to applicable governance practices and capability
profiles for supporting the relevant governance objectives.

By using the definition of risk as “effect of uncertainties on objectives”, during the Managing Operational
Risks scenario we have to identify the risk criteria (tolerances and appetite) for not only those governance
objectives which are enabling Risk Management, but also for all the others which are related to the other 4
Integrated Risk Management scenarios as being under the scope of the Operational Risk Management. In
terms of risk management related governance objectives we use the ”Usefulness” and “Efficiency” measures
for setting metrics in the specific time-horizons of the Integrated Risk Management scenarios, for example:

• Risk Appetite measured by capability levels of governance processes enabling Integrated Risk
Management scenarios

• Risk Tolerance measured by variance from Enterprise Goals used by the Integrated Risk
Management scenarios.

For ensuring risk optimisation we need targets and tolerances e.g. measured by:

• Capability attribute ratings of governance processes (capability profiles), and

• Control limits of Enterprise Goals within the specific time-horizons of the Integrated Risk
Management scenarios.

The risk management related Risk Awareness and Control Efficiency governance objectives should also
have such risk criteria which are applicable to measure effective risk treatment for achieving business goals
and funding resources by applying governance practices. However these business goals and funding
requirements are derived from those which have been used by the other Integrated Risk Management
scenarios. Applicable risk management related governance practices should be selected and implemented
by considering their relevance to the above “Usefulness” and “Efficiency” measures.

If a lower level governance practice offered by the Governance Model has no significant relevance for the
established operational and business unit/entity level Enterprise Goals, then there will be no need to apply
that. If management specifies a governance practice as relevant for managing risks related to Enterprise
Goals applied by the Integrated Risk Management scenarios, then the target capability level for
implementing this governance process will include it and will be also used as risk criteria (risk appetite).
Capability level targets should be set aligned with all Integrated Risk Management scenarios supporting
achievement of their relevant Enterprise Goals.

Principles of Enterprise Risk Management are similar in each type of business organization. However related
governance practices and their capability levels might differ in wide range. Effective small enterprises might
run their business operation without extensive implementation of risk management practices. When business
environment is changing, then the need for more formal and robust risk management will emerge. Managing
risks is a challenge even for the more matured enterprises. By using of the Managing Operational Risks
(Integrated Risk Management) scenario, the management will be able to select and apply those governance
practices which are relevant for improving overall enterprise governance.

Risk Awareness and Control Efficiency objectives related governance practices together with
Quantitative Performance Measurement contribute to develop - level 4 - Predictable capability of those
management processes which constitute management of business operation by establishing their
organizational contexts.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 81/169

Selection and implementation of those governance practices which are offered by the Governance Model
for Trusted Businesses for Risk Awareness and Control Efficiency objectives should be driven by the
management’s usefulness and efficiency considerations. Therefore the optimal (meaningful) coverage of
offered governance practices, together with a capability profile aiming higher (e.g. Level 2 - Managed or
Level 3 - Established) requirements should be concluded by performing mature risk management practices.

For supporting risk assessment the following risk tables for the Risk Awareness and Control Efficiency
objectives can be used to understand key risk areas and applicable practices as risk responses:

Applicable
Key Risk Risk Factors Responses Application Practices
COSO processes

Management specifies
governance objectives relevant
Management
for financial reporting and trusted
Governance sets clearly
Governance business operation with sufficient
objectives for defined
(Financial clarity and criteria to enable the
business objectives for
Reporting)
processes are governance identification of risks to the
Objectives
inadequately including risk achievement of the governance
(COSO)
established tolerance and objectives relevant for financial
risk appetite
reporting and trusted business
operation.
Risk
assessments are The organization identifies and
Relevant periodically analyses risks to the
governance performed by Governance achievement of governance
risks are not Inconsistency in considering the (Financial objectives relevant for the
considered risk assessment time horizon of Reporting) Risks organization’s financial reporting
the governance (COSO) and trusted business operation
objectives, risk as a basis for determining how
tolerance and the risks should be managed.
risk appetite
Control activities
developed by
Risks relevant for Actions are taken to address
reflecting to all
organizations’ Integration with risks to the achievement of
assertions
internal control Risk Assessment governance objectives relevant
relevant for
system are not (COSO) for financial reporting and trusted
organization’s
addressed business operation.
internal control
system
Table 11: Risk Awareness related risk areas

How the governance objectives related risks are considered generally presents the risk culture of the
organization. Through implementation of the Integrated Risk Management scenarios - as presented in the
previous chapters of this handbook - the governance objectives are customized in contexts and time-
horizons of operational and organizational level Enterprise Goals. The target capability profiles of the
governance processes being enabled by the selected specific and generic practices constitute the risk

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 82/169

appetite for achieving these goals within established control limits (risk tolerances). For setting meaningful
risk tolerances as control limits the Quantitative Performance Measurement process should be applied for
indicating usefulness and efficiency measures used by the management assertions which present the
linkage between business activities and governance practices. As the governance practices generally have
wider scope than just mitigating downside of risks (as of the control activities), Quantitative Performance
Management also supports to identify benefits from exploitation of business opportunities.

The implemented governance practices are tools for improving ability of the company to determine adequate
risk appetite. Using of target governance capability profiles as risk appetite and quantitative control limits
around Enterprise Goals as risk tolerances compose risk criteria applied by the risk treatment cycles (over
Integrated Risk Management scenarios) to measure residual status of risks. The selected governance
practices provide implementation instances of the Control Risks governance process enabling the
achievement of the following outcomes:

• Governance objectives relevant for financial reporting and trusted business operation are
established.

• Risk assessments are performed consistently.

• Organization’s internal controls are integrated with risks to achievement of organization’s objectives
relevant for financial reporting and trusted business operation.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 83/169

Applicable COSO
Key Risk Risk Factors Responses Application Practices
processes

Management
The entity’s organizational
Inadequate maintains
structure supports effective
structures for adequate Organizational
internal control over financial
control operation organizational Structure (COSO)
reporting and trusted
and reporting structure and
business operation.
reporting lines

Operation and
reporting of
Oversight The oversight board
controls don’t
activities ensure understands and exercises
provide sufficient
periodic Oversight Board oversight responsibility
Inefficient evidences to
assessment on (COSO) related to trusted business
usage of assess
governance operation, financial reporting
control effectiveness of
resources capabilities and related internal control.
the internal
control system
Internal control deficiencies
are identified and
communicated in a timely
Necessary Management
Reporting manner to those parties
corrective actions reviews control
Deficiencies responsible for taking
are not taken in deficiencies and
(COSO) corrective action, and to the
time actions taken
management and the
oversight board as
appropriate.
Table 12: Control Efficiency related risk areas

By selecting and implementing Control Efficiency related governance practices for ensuring adequate
governance (reporting and supervision) structure with sufficient management of reported control deficiencies
for improvement, the risks and potential rewards should be compared to the increasing costs of improved
controls (capability profiles) over business and governance processes. These considerations are applicable
for all operational and organizational levels by following the Integrated Risk Management scenarios.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 84/169

Figure 13: Control Efficiency considerations in context of risk treatment costs

The selected governance practices provide implementation instances of the Control Efficiency governance
process enabling the achievement of the following outcomes:

• Adequate organizational structure and reporting lines are maintained.

• Oversight of internal controls is effective.

• Control deficiencies are reviewed and necessary actions are taken.

The set of applied governance practices and the target Process Capability Attributes
comprise those risk criteria against the business performance should be assessed.
Evaluation of Process Attribute Gaps (between target and assessed capability) provides
measurement of residual risk status.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 85/169

3.6.3 Applying Management Assertions for Managing Operational Risks

Management assertions are setting links between the business processes (and activities)
and the governance objective-driven processes (and base practices) offered by recognized
reference models (like COSO, COBIT and Enterprise SPICE). Management should reflect to
their own business goals and business environment’s expectations by setting target
capability profiles for the customized governance objectives (risk appetite) and adequate
quantitative control limits of tolerable deviations from Enterprise Goals (risk tolerance).
Governance Capability Assessment (Governance SPICE) methodology provides
measurement framework for targeting and assessing effectiveness of governance processes
(defined by ISO/IEC 15504 compliant reference models) in achievement of governance
objectives, however it should be carefully considered at the assessment scope definition,
that a governance process might be implemented and applied by more than one business
processes (and their instances) within a business operational unit.

For example in the case of Risk Awareness objective concerning to the service/production delivery
business process, the management should determine the management and control activities necessary and
sufficient to limit the negative consequences of the inherent business risks related to the missing or
inadequately defined governance objectives, inconsistent risk assessment and management assertions for
implementing internal controls. These organizational contexts of the specific process performance are
enabled by fulfilling the Predictable - level 4 - capability requirements.

Theoretically the management should apply a measure for determining direct impact on
specific business goals, however at business process level this measure can’t derived
directly from “natural” business measures like income, profitability, stock listing rate, market-
share, etc. This problem could be resolved by targeting application of governance practices
by the business process activities. The more relevant governance practices are applied; the
negative consequences are the more likely minimized.

However the adequate structure of performance measurement helps to navigate over


applicable governance practices (see Figure 4: Linking Governance Objectives to Enterprise
Goals & Measures). The governance practices are enabling achievement of Enterprise
Goals, so measurement related to achievement of governance objectives should support in-
time status information regarding overall business performance. Furthermore the lower level
operational or organizational goals and metrics should be established as enabling indicators
for the above governance level.

Quantitative Performance Measurement is not only used for setting and evaluating metrics of achieving
operational and organizational level Enterprise Goals, but also for establishing links among these
governance levels. As normally the different level Enterprise Goals and their control limits are not directly
comparable due to altering time-horizons and measurement units (like an individual process performance
delay or error rate cannot be comparable with a missing yearly revenue target) the applied analytical
evaluation techniques should support effective monitoring over different operational and organizational levels
and time scales.

For selecting and prioritizing governance practices offered by the reference models, the Managing
Operational Risks scenario offers “Usefulness” and “Efficiency” aspects of business performance. The
alignment to effective risk management should enable to define and implement Risk Appetite (measured by
capability levels of governance processes enabling Integrated Risk Management scenarios) and Risk
Tolerance (measured by variance from Enterprise Goals used by the Integrated Risk Management
scenarios).

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 86/169

These two types of metrics help to identify relevance and weight of applicable governance
practices in supporting performance objectives. If lack or failure of a governance practice -
by considering together with other existing governance practices - represents undesirable
uncertainty on keeping “Usefulness” or “Efficiency” goals, then implementation or
improvement of the practice will be an adequate risk treatment option. If the lack or failure of
a governance practice has no significant effect on Enterprise Goals - by considering together
with other existing governance practices – this practice will be out of the scope of
implementation and assurance. Performance measurement is needed to establish the
concerning risk criteria and tolerance levels triggering immediate or scheduled management
actions.

For example: a failure (performance gap) of COSO IFC.CA.IRA Integration with Risk Assessment practices
for Risk Awareness governance objective in a company running outsourcing service – with sharing
responsibilities over user organizations’ internal control - causes undesirable uncertainty in achievement of
addressing risks relevant for both user and service organizations’ internal control system. Failures in e.g.
mapping controls to relevant risks might cause overlapping or missing risk treatment actions leading to
unpredictable performance of business operation. In this case an identified performance gap at maintaining
Integration with Risk Assessment controls triggers the management actions for process improvement related
to the Risk Awareness governance objective. External requirements for the service organizations controls
over outsourcing service - like SOC 1 and SOC 2 – emphasize the relevance and importance of maintaining
Integration with Risk Assessment controls.

The operational and organizational level “Usefulness” and “Efficiency” metrics used by the Integrated Risk
Management scenarios should be assessed against company targets (or other reasonable benchmark) and
measures over pre-established tolerances should also trigger the (re)assessment of the Integration with Risk
Assessment governance practices. If the assessed performance gap is significant as effecting one or more
Enterprise Goal targets by exceeding their tolerances, then improvement action should be planned and
implemented by the management. If detected performance gaps were not affecting significantly the Strategic,
Operational Effectiveness, Reliability or Operational Performance related Enterprise Goals of the company
running outsourcing service, then either the triggering tolerances of lower level performance metrics might be
reset or - more likely - other related governance practices should be also assessed. Relevance and weight of
a governance practice should be considered as an enabler of the related governance objective (like
maintaining Integration with Risk Assessment controls enables achievement of Risk Awareness objective
supporting Enterprise Goals at all operational and organizational levels).

At corporate level the governance objectives related set of practices comprising ISO/IEC
15504 compliant governance processes - as defined by the Governance Model - are
applicable for targeting and assessing them for even higher (e.g. level 2 or above)
governance capability. However from the selected business process view, as in the normal
cases of SME service or production delivery, the assessment target is mostly limited to
Compliance (1 - Performed) level, as this is the level where the application of specific
process outcomes and practices are investigated.

Targeting the Managed (level 2) or even higher level for the governance processes is applicable in the case
when capability target of the Managing Operational Risks scenario were pre-established accordingly (e.g.
in compliance with strict regulatory requirements). The higher capability request for Managing Operational
Risks should be determined by the risk oversight bodies and also takes other effected business units (e.g.
not just the Service Unit, but others like the Sales, IT Development, etc. units) into the same capability level
context.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 87/169

3.6.4 Selecting Specific Application Practices as Risk Criteria for Managing Operational
Risks

For fully achieving Process Performance attribute, the following specific outcomes should be evidenced
concerning to the governance processes supporting Operational Risk Management:

• for Control Risks governance process:

o Governance objectives relevant for financial reporting and trusted business operation are
established.

o Risk assessments are performed consistently.

o Organization’s internal controls are integrated with risks to achievement of organization’s


objectives relevant for financial reporting and trusted business operation.

• for Control Efficiency governance process:

o Adequate organizational structure and reporting lines are maintained.

o Oversight of internal controls is effective.

o Control deficiencies are reviewed and necessary actions are taken.

• for Quantitative Performance Measurement process:

o Processes or process elements are selected for quantitative management on the basis of their
relevance and significance to the achievement of business goals;

o Measures and analytical techniques to be used in statistically managing the processes or process
elements are established and maintained;

o Process performance data is collected and analyzed using appropriate statistical or other
quantitative techniques to establish an understanding of the variation of the selected processes or
process elements;

o Results of data analysis are used to identify special causes of variation (assignable causes) in
process performance;

o Corrective and preventive actions are implemented to address the special and other causes of
variation; and

o Performance of the selected processes or process elements is monitored and controlled to


establish stable, capable and predictable processes within control limits.

The applied Governance Model for Trusted Businesses offers recognized best practices supporting these
outcomes, however not all of them are necessary in context of the specific Enterprise Goals of the
organization. Management should select only those practices as assertions, which have evidential link to
“Usefulness” and “Efficiency” goals at this operational level. For Managing Operational Risks these goals
might be: definition and implementation of risk appetite and keeping risk tolerances for the operational and
organizational levels aimed by the Integrated Risk Management scenarios.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 88/169

For careful consideration, management should set metrics like described in the sample Table 16: Application
Practices of Control Risks with possible metrics and Table 17: Application Practices of Control Efficiency with
possible metrics.

Where current metrics show significant deviation from management’s expectations (risk
appetite), the related practice should be implemented or improved. Where current metrics
are available and satisfactory to reasonable risk appetite, the application practice can be set
for management assertion.

The elaborated “Usefulness” and “Efficiency” metrics for the Control Risks and Control Efficiency governance
practices can help management to develop management assertions by selecting governance practices as
risk criteria for the effective Operational Risk Management.

Quantitative Performance Measurement provides tools for the management to apply “Usefulness” and
“Efficiency” metrics determined for all Integrated Risk Management scenarios. Control limits of these metrics
will drive necessary corrective and/or improvement actions enabling better achievement of Enterprise Goals.
As all of the controls and other risk treatment actions should be considered in the context of Enterprise
Goals, the “Usefulness” and “Efficiency” metrics related to governance practices have multiple functions. At
first, they show residual risk status to be compared with established risk appetite, and at second, they
establish links between governance objectives and Enterprise Goals by using control limits as risk
tolerances. By applying the Managing Operational Risks scenario the capability level attribute ratings of the
governance objectives related processes provide metrics for measuring risk tolerances in context of
operational and organizational governance levels.

This observation is also valid for the Risk Awareness and Control Efficiency objectives. While
management assertions determine applicable risk management practices as “reversed” risk appetite
statements for operational risk management, the capability attribute ratings may be used as metrics for that.
However Managing Operational Risks scenario is different from the other 4 Integrated Risk Management
scenarios as also using target capability profiles related to all governance objectives for setting the tolerance
levels around Enterprise Goal concerning Operational Risk Management.

By this way only those governance practices are scoped as capability indicators evidencing
achievement of specific governance outcomes (Process Performance attribute), which are
considered by the management as relevant based on its risk appetite. This consideration
might be “instinctive” or even “conscious” by following the Managing Operational Risks
scenario.

Managed capability (level 2) scoping takes metrics of altering time-horizons from different Integrated Risk
Management scenarios into the context of risk management planning. Risk evaluation and treatment cycles
should follow the different characteristics of the covered Integrated Risk Management scenarios, as
applicable risk criteria are derived from the metrics of risk appetite (governance capability profiles) and risk
tolerances (control limits for Enterprise Goals) within specific time-horizons.

Significant or dramatic (material) capability gaps or deviations out of control limits indicate that internal or
external risk factors should be reconsider followed by necessary actions in order to keep enterprise
governance framework effective. This is why Managed capability - level 2 - scoping for governance
processes is valid, as the wider/extended time-horizon and related objectives let management to use the
performance metrics of the Managing Operational Risks scenario as success or failure indicators of
achieving Enterprise Goals covered by the other Integrated Risk Management scenarios.

For example the trend for not keeping control limits for important enterprise goals may indicate either that the
related goals are not realistically established or the governance processes are not adequately implemented
or maintained (for managing internal or external uncertainties affecting achievement of these goals).
Managing Operational Risks scenario covering all the governance objectives may put those operational
business processes into the organizational contexts of Predictable (level 4) process capability, which already

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 89/169

“Fully achieved” the process attributes up to Established (level 3) capability by the support of the governance
objectives related processes and practices covered by the other Integrated Risk Management scenarios.

Typically a governance process - as defined by the Governance Model for Trusted Businesses - is not
performed as an individual project. For example Control Risks governance process related practices are
incorporated into risk or compliance management functions of the company; Control Efficiency governance
process related practices are under the direct supervision of the board. Therefore the Managed (level 2)
capability of these governance processes is normally evidenced at executive and board level supervision
and their supporting (e.g. compliance, risk management, internal audit, etc.) activities.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 90/169

4. Governance Process Descriptions Referred by the Integrated


Risk Management Scenarios
The Governance Model for Trusted Businesses is a public deliverable of the BPM-GOSPEL project. The
following parts present the ISO/IEC 15504 conformant process descriptions aiming at the following 11
governance objectives of the model:

• Supporting Organization’s Internal Control System


– Risk Awareness
– Accountability
– Competency
– Accuracy
– Process Integrity
– Data Protection
– Commitment
– Control Efficiency

• Supporting Business Sustainability


– Competitiveness
– Exploitability
– Satisfaction

Governance Capability Levels and related Process Attributes for processes supporting the above objectives as
application practices can be applied as qualitative and quantitative measures for setting affordable enterprise
specific requirements (risk appetite) relevant for achieving the business goals within a tolerable deviation (risk
tolerance).

The Governance Model provides descriptions and application practices of governance processes for management
assertions and audit reports on design and operation effectiveness of internal controls over financial reporting and
for providing assurance of trusted and sustainable business operation.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 91/169

4.1 Governance of Controlled Business Operation - Application Category

The Governance of Controlled Business Operation application category has the focus on how effectively
enterprise governance applies the Internal Control (COSO 2006) Principles together with the Security,
Availability, Processing Integrity, Confidentiality and Privacy Principles.

Eight processes relate to the Governance of Controlled Business Operation application category:

• Control Risks – The organization and its staff adequately address risks to the governance objectives
relevant for financial reporting and trusted business operation and consider those risks in
management of business operation.

• Control Management – The management of the organization is able to control business processes in
a way which is adequate to the objectives of internal control over financial reporting and trusted
business operation.

• Control Competence – Sufficient skills and knowledge relevant for the objectives of internal control
over financial reporting and trusted business operation are available and used.

• Information Reliability – Data architecture and disclosure elements relevant for financial reporting
objectives and trusted business operation, and for supporting data processing integrity are accurate
and consistent.

• Process Control – Design and operation of process-level controls relevant to the objectives of
financial reporting and trusted business operation, and processing integrity principle are effective.

• Data Protection – The organization and its staff are committed to security, confidentiality and privacy
principles to avoid unauthorized access to and misuse of confidential data effected by business
operation.

• Integrity Assurance – The organization and its staff are committed to comply with ethical and
business integrity requirements relevant to the objectives of financial reporting and trusted business
operation, and availability principle.

• Control Efficiency – Efficient usage of control resources relevant to the objectives of financial
reporting and trusted business operation.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 92/169

4.1.1 Control Risks

Process ID GOV.CR
Process Name Control Risks
Process Purpose The purpose of the Control Risks process is to ensure that the organization and its
staff adequately address risks to the governance objectives relevant for financial
reporting and trusted business operation and consider those risks in management of
business operation.
NOTE1: The Control Risks process is a special application of the COSO 2006 model
in the context of the “Risk Awareness” governance objective. Thus this process is
denoted an “Application Area”. The practices, called “application practices”, are
implemented using selected processes based on the COSO 2006 principles in the
context of this special application. This facilitates the re-use of the elements of the
COSO 2006 based reference model without recreating processes that are already
well established.
NOTE2: The descriptions of the COSO 2006 Principles are applicable to define
ISO/IEC 15504 conformant process reference model and process performance
indicators for assessing process capability according to the ISO/IEC 15504 standard.
Process As a result of successful implementation of the Control Risks process:
Outcomes
1) Governance objectives relevant for financial reporting and trusted business
operation are established.
2) Risk assessments are performed consistently.
3) Organization’s internal controls are integrated with risks to achievement of
organization’s objectives relevant for financial reporting and trusted business
operation.
Application BP1 Establish governance objectives for financial reporting and trusted
practices business operation. Management specifies governance objectives relevant for
financial reporting and trusted business operation with sufficient clarity and criteria to
enable the identification of risks to the achievement of the governance objectives
relevant for financial reporting and trusted business operation. [Outcome: 1]
NOTE1: This practice is implemented by performing practices of the COSO 2006
Financial Reporting Objectives process with a specific focus on how enterprise
governance supports internal control over financial reporting and trusted business
operation:
IFC.RA.FRO.BP1 Identify Management assertions. To identify relevant
management assertions, management starts with the governance reports,
including disclosures, and identifies significant governance objectives, based
on management’s estimate of materiality. For each governance report and
disclosure management then identifies relevant assertions, underlying
transactions and events, and processes supporting these governance
objectives.
IFC.RA.FRO.BP2 Consider the Range of Assessment Activities.
Management, with oversight board review, considers the range of the
organization’s activities to assess whether all are appropriately captured in
the governance reports, and considers whether the governance reports
appropriately communicate to readers economic reality in a useful form.
IFC.RA.FRO.BP3 Compare Governance Policies. Management compares
the governance principles adopted for the organization to those used by
companies of similar size and industry. Management also compares the

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 93/169

content and level of detail in the organization’s governance reports to those


organizations’ reports. Significant variations are considered by management
and summarized for board review.

BP2 Perform consistent risk assessment. The organization identifies and analyses
risks to the achievement of governance objectives relevant for the organization’s
financial reporting and trusted business operation as a basis for determining how the
risks should be managed. [Outcome: 2]
NOTE2: This practice is implemented by performing practices of the COSO 2006
Financial Reporting Risks process with a specific focus on how enterprise
governance supports internal control over financial reporting and trusted business
operation:
IFC.RA.FRR.BP1 Apply Risk Identification Process. Management’s risk
identification process includes identifying:
• Relevant management assertions for each significant governance
objectives.
• Business processes and business units supporting governance
objectives and disclosures.
• Information technology (IT) systems supporting key business
processes relevant to governance objectives.
IFC.RA.FRR.BP2 Map Controls. Management maps its controls to the five
internal control components, with headers that list the activity's control
objectives and risks. This approach targets activities that might generate
governance errors.
IFC.RA.FRR.BP3 Interact with External Parties. As part of an
organisation’s risk identification, management interacts with external parties
that may affect the reliability of governance reporting, including suppliers,
investors, creditors, shareholders, employees, customers, intermediaries, and
industry peers.
IFC.RA.FRR.BP4 Consider External Factors. Management considers
external factors that impact its ability to achieve its governance objectives,
such as economic, competitive, and industry conditions; regulatory and
political environment; and changes in technology, supply sources, customer
demands, or creditor requirements. Management also considers how internal
factors and changes in them impact the organisation’s ability to achieve its
governance objectives. These include governance report characteristics,
business process characteristics, and entity-wide factors.
IFC.RA.FRR.BP5 Update Risk Assessments. Management updates risk
assessments periodically (e.g. on a quarterly basis), considering:
• Newly identified risks determined to be significant.
• Escalation of previously identified risks to higher relevance.
• The status of action plans to mitigate significant risks.
This risk assessment evaluates risk based on potential impact and likelihood
of risks. The resulting assessment is used as a key input in determining
required control activities.
IFC.RA.FRR.BP6 Meet with Relevant Personnel. Key governance
personnel meet on a regular basis with:
• Executive management to identify new initiatives, commitments, and
activities affecting risks to financial reporting and trusted business
operation.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 94/169

• Information technology personnel to monitor changes in information


technology that may affect risks related to financial reporting and
trusted business operation.
• Human resources staff to identify and assess how changes in the
workforce may affect competencies needed for internal control over
financial reporting and trusted business operation.
• Legal counsel to stay abreast of legal/regulatory changes.

BP3 Address risks relevant for financial reporting and trusted business
operation. Actions are taken to address risks to the achievement of the governance
objectives relevant for financial reporting and trusted business operation. [Outcome:
3]
NOTE3: This practice is implemented by performing practices of the COSO 2006
Integration with Risk Assessment process with a specific focus on how enterprise
governance supports internal control over financial reporting and trusted business
operation:
IFC.CA.IRA.BP1 Consider Entity-Wide Controls. Management considers
entity-wide controls that are pervasive across the organisation when
considering whether control activities are sufficient to address identified risks.
IFC.CA.IRA.BP2 Use Workshops to Identify and Evaluate Controls.
Management uses workshops to identify appropriate control activities for
each identified risk to a governance objective and to train its employees in
proper implementation of control activities.
IFC.CA.IRA.BP3 Use Matrices to Identify and Evaluate Controls.
Management uses risk/control matrices developed in the process of
assessing risks and designing controls in each business process to perform a
“gap analysis” to evaluate the need for any additional controls that might be
needed to mitigate risks to the achievement of governance objectives.
IFC.CA.IRA.BP4 Use an Inventory of Controls to Identify and Evaluate
Controls. Management uses register or software that provides an inventory
of controls typically aligned to specified risks to financial reporting and trusted
business operation.
IFC.CA.IRA.BP5 Use independent assessment of outsourcing service
provider’s internal control over processing transactions for user
organization. When outsourcing all or a portion of its function related to
financial reporting and trusted business operation, the CFO or CGO obtains
an independent assessment report (like SOC 1 Type II) or undertakes
procedures to assess controls in place for the initiation, recording, and
processing of significant classes of transactions at the third-party outsourcer.
Relationship The relationships between the Control Risks process and application practices, and
Notes other processes in COSO 2006 model, have been noted for each practice above.
This innovative concept of including “Application Areas” in a process assessment
model instantiates the idea of using already established processes with respect to a
particular application.
Sources COSO 2006: IFC.RA.FRO Financial Reporting Objectives, IFC.RA.FRR Financial
Reporting Risks, IFC.CA.IRA Integration with Risk Assessment
References Internal Control over Financial Reporting — Guidance for Smaller Public
Companies
Copyright © 2006 by The Committee of Sponsoring Organization, C/O
AICPA, Harborside Financial Center, 201 Plaza Three, Jersey City, NJ 07311

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 95/169

– 3881, USA. All rights reserved.

Work Products
Inputs Outputs
Governance Policies and Procedures [Outcomes: 1, Governance Objectives [Outcome: 1]
2]
Governance Objectives [Outcome: 1] Related Business Activities [Outcome: 1]
Governance Reports [Outcome: 1, 2] Review Records [Outcome: 1]
Management assertions [Outcome: 2] Governance Objectives [Outcome: 1]
Organizational Structure [Outcome: 2] Management assertions [Outcome: 1]
Related Business Activities [Outcome: 2] Risk and Control Documentation [Outcomes: 2, 3]
Related IT Systems [Outcome: 2] Risk Assessment Reports [Outcome: 2]
Governance Competencies [Outcome: 2] Inventory of Controls [Outcome: 3]
Skill Assessment Reports [Outcome: 2]
Risk and Control Documentation [Outcomes: 2,3]
Outsourcing Assessment Report [Outcome: 3]

Note: Above performance indicators driven by the COSO 2006 model are applicable for assessing the
effectiveness of controls in relation to objectives of financial reporting and trusted business operation.
However they should be considered as a starting point for judgment whether, given the application context,
they are contributing to the intended purpose of the process, not as a compulsory check-list of what every
organization must have.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 96/169

4.1.2 Control Management

Process ID GOV.CM
Process Name Control Management
Process Purpose The purpose of the Control Management process is to ensure that the management
of the organization is able to control business processes in a way which is adequate
to the objectives of internal control over financial reporting and trusted business
operation.
NOTE1: The Control Management process is a special application of the COSO
2006 model in the context of the “Accountability” governance objective. Thus this
process is denoted an “Application Area”. The practices, called “application
practices”, are implemented using selected processes based on the COSO 2006
principles in the context of this special application. This facilitates the re-use of the
elements of the COSO 2006 based reference model without recreating processes
that are already well established.
NOTE2: The descriptions of the COSO 2006 Principles are applicable to define
ISO/IEC 15504 conformant process reference model and process performance
indicators for assessing process capability according to the ISO/IEC 15504 standard.
Process As a result of successful implementation of the Control Management process:
Outcomes
1) Policies and procedures relevant for the governance objectives of financial
reporting and trusted business operation are consistently implemented and
communicated.
2) Management structure is adequate to internal control over financial reporting and
trusted business operation.
3) Management takes stimulating behavior for supporting internal control over
financial reporting and trusted business operation.
Application BP1 Establish governance policies and procedures relevant for the governance
practices objectives of financial reporting and trusted business operation. Governance
policies related to reliable financial reporting and trusted business operation are
established and communicated throughout the organisation, with corresponding
procedures resulting in management directives being carried out. [Outcome: 1]
NOTE1: This practice is implemented by performing practices of the COSO 2006
Policies and Procedures process with a specific focus on how enterprise governance
supports internal control over financial reporting and trusted business operation:
IFC.CA.PP.BP1 Develop and Document Policies and Procedures.
Management develops and documents policies and procedures for all
significant financial reporting and trusted business operation related activities
using various formats such as narratives, flowcharts, and control matrices.
IFC.CA.PP.BP2 Consider Preventative and Detective Controls.
Management includes both preventative and detective controls within each
process, using process maps, narratives, spreadsheets, or other mechanisms
to document and communicate the control activities.
IFC.CA.PP.BP3 Develop Policies for Entity-Wide Application. Central
management develops policies for areas that have entity-wide application,
such as its code of conduct, delegation of authority, safeguarding of assets,
and so forth. In addition, management develops policies at the business unit
level that support and align with entity-wide policies.

BP2 Assign governance roles and responsibilities. Management and employees

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 97/169

are assigned appropriate levels of authority and responsibility to facilitate effective


internal control over financial reporting and trusted business operation. [Outcome: 2]
NOTE2: This practice is implemented by performing practices of the COSO 2006
Authority and Responsibility process with a specific focus on how enterprise
governance supports internal control over financial reporting and trusted business
operation:
IFC.CE.AR.BP1 Define Objectives and Responsibilities. Management
sets forth clear business and management objectives and position
descriptions to reinforce management’s responsibility for effective internal
control over financial reporting and trusted business operation.
IFC.CE.AR.BP2 Review Key Positions. For key financial reporting and
trusted business operation positions, the oversight board reviews
management’s descriptions of the positions’ responsibilities and authorities,
and considers how those positions affect the strength of internal control over
financial reporting and trusted business operation, calling for re-evaluation
where needed.
IFC.CE.AR.BP3 Assign Authorities and Responsibilities. In assigning
authorities and responsibilities, management considers the impact on the
effectiveness of the control environment and importance of maintaining
effective segregation of duties. Management establishes an appropriate
balance between the authority needed to “get the job done” and the need to
maintain adequate internal control over key processes.
IFC.CE.AR.BP4 Empower Employees. Management empowers employees
to correct problems or implement improvements in their assigned business
processes as necessary, balanced with appropriate monitoring of
performance.
IFC.CE.AR.BP5 Align Positions with Responsibilities and Authorities.
Management considers the nature of employee positions within the
organization when assigning responsibilities to individuals or determining
certain levels of authority for positions.

BP3 Management takes stimulating behaviour. Management’s philosophy and


operating style support achieving effective internal control over financial reporting and
trusted business operation. [Outcome: 3]
NOTE3: This practice is implemented by performing practices of the COSO 2006
Management’s Philosophy and Operating Style process with a specific focus on how
enterprise governance supports internal control over financial reporting and trusted
business operation:
IFC.CE.MPO.BP1 Emphasize Risk Mitigation. Management emphasizes
the importance of minimizing risks related to financial reporting and trusted
business operation in its interactions with others involved in the financial
reporting and trusted business operation process, and through its dealings
with customers, suppliers or distributors, and employees.
IFC.CE.MPO.BP2 Emphasize Processing Requirements. The
organisation’s operating philosophy requires that all journal entries, including
those reflecting assumptions and estimates, be properly authorized,
supported by adequate documentation and subject to review by an
appropriate senior financial executive.
IFC.CE.MPO.BP3 Emphasize Importance of Diligence. Management
provides sufficient direction such that employees recognize the importance of
applying appropriate diligence and business judgment in the performance of
assigned job responsibilities.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 98/169

IFC.CE.MPO.BP4 Establish and Articulate Governance Objectives.


Management establishes and articulates governance objectives, including
those relating to complete, accurate and fair financial reporting and trusted
business operation, with personnel involved in the financial reporting and
trusted business operation process.
Relationship The relationships between the Control Management process and application
Notes practices, and other processes in COSO 2006 model, have been noted for each
practice above. This innovative concept of including “Application Areas” in a process
assessment model instantiates the idea of using already established processes with
respect to a particular application.
Sources COSO 2006: IFC.CA.PP Policies and Procedures, IFC.CE.AR Authority and
Responsibility, IFC.CE.MPO Management’s Philosophy and Operating Style
References Internal Control over Financial Reporting — Guidance for Smaller Public
Companies
Copyright © 2006 by The Committee of Sponsoring Organization, C/O
AICPA, Harborside Financial Center, 201 Plaza Three, Jersey City, NJ 07311
– 3881, USA. All rights reserved.

Work Products
Inputs Outputs
Inventory of Controls [Outcome: 1] Governance Policies and Procedures [Outcome:
1]
Related Business Activities [Outcomes: 1, 3] Review Records [Outcomes: 1, 2]
Organizational Structure [Outcomes: 1, 2] Roles and Responsibilities [Outcome: 2]
Roles and Responsibilities [Outcomes: 1] Nomination Records [Outcome: 2]
Job Descriptions [Outcome: 2] Governance Objectives [Outcome: 3]
Code of Conduct [Outcome: 3] Management Records [Outcome: 3]
Governance Objectives [Outcome: 3]

Note: Above performance indicators driven by the COSO 2006 model are applicable for assessing the
effectiveness of controls in relation to objectives of financial reporting and trusted business operation.
However they should be considered as a starting point for judgment whether, given the application context,
they are contributing to the intended purpose of the process, not as a compulsory check-list of what every
organization must have.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 99/169

4.1.3 Control Competence

Process ID GOV. CC
Process Name Control Competence
Process Purpose The purpose of the Control Competence process is to ensure the availability and
usage of sufficient skills and knowledge relevant for the objectives of internal control
over financial reporting and trusted business operation.
NOTE1: The Control Competence process is a special application of the COSO
2006 model in the context of the “Competency” governance objective. Thus this
process is denoted an “Application Area”. The practices, called “application
practices”, are implemented using selected processes based on the COSO 2006
principles in the context of this special application. This facilitates the re-use of the
elements of the COSO 2006 based reference model without recreating processes
that are already well established.
NOTE2: The descriptions of the COSO 2006 Principles are applicable to define
ISO/IEC 15504 conformant process reference model and process performance
indicators for assessing process capability according to the ISO/IEC 15504 standard.
Process As a result of successful implementation of the Control Competence process:
Outcomes
1) Recruitment, compensation and training activities are performed systematically.
2) Staff members are continually informed, feedbacks are periodically reviewed.
3) Competent individuals are retained in relation to the business operation, financial
reporting and related oversight roles.
Application BP1 Use human resource policies and practices relevant for financial reporting
practices and trusted business operation objectives. Human resource policies and practices
are designed and implemented to facilitate effective internal control over financial
reporting and trusted business operation. [Outcome: 1]
NOTE1: This practice is implemented by performing practices of the COSO 2006
Human Resources process with a specific focus on how enterprise governance
supports internal control over financial reporting and trusted business operation:
IFC.CE.HR.BP1 Develop and Maintain Position Descriptions.
Management develops and maintains position descriptions that reflect its
values and the competencies needed to execute position requirements.
IFC.CE.HR.BP2 Develop and Maintain Human Resource Policies and
Procedures. The human resource function develops and periodically
updates materials outlining the organisation’s human resource policies and
procedures.
IFC.CE.HR.BP3 Review Resumes and Perform Reference Checks.
Management reviews resumes and performs reference checks in considering
candidates for key financial reporting and trusted business operation
positions. For positions with high level responsibility and authority, the
organisation also performs background checks.
IFC.CE.HR.BP4 Provide Training and Awareness. The human resource
function provides training and awareness programs to promote ethical
behaviour throughout the organization. Additional training programs related to
financial reporting and trusted business operation are provided to all
employees with direct and indirect involvement in financial reporting and
trusted business operation.
IFC.CE.HR.BP5 Establish a Review and Appraisal Process. Management
establishes a review and appraisal process that confirms knowledge of each

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 100/169

employee’s progress and status within the organization.


IFC.CE.HR.BP6 Perform Exit Interviews. An organization’s process for
performing exit interviews includes inquiries about any concerns related to
the organization’s governance and internal control.
IFC.CE.HR.BP7 Design Compensation Plans. Compensation plans for
senior executives include a significant element tied to achievement of non-
financial goals (for example, customer satisfaction, employee retention, and
successful systems implementation) and is not excessively tied to short-term
results as reflected in governance reports.
IFC.CE.HR.BP8 Review Compensation Plans. The oversight board reviews
management compensation plans, including bonus and stock compensation
components, to determine whether the plans create inappropriately high risk
of financial reporting and trusted business operation misstatements and
implements controls as needed to reduce risk to an acceptable level.
IFC.CE.HR.BP9 Evaluate Competency of Personnel. Management
evaluates the sufficiency and competency of personnel involved in recording
and reporting financial information.

BP2 Provide effective internal communication over control requirements


relevant for financial reporting and trusted business operation objectives.
Communications enable and support understanding and execution of internal control
objectives, processes, and individual responsibilities at all levels of the organization.
[Outcome: 2]
NOTE2: This practice is implemented by performing practices of the COSO 2006
Internal Communication process with a specific focus on how enterprise governance
supports internal control over financial reporting and trusted business operation:
IFC.IC.IC.BP1 Communicate Information Regarding Governance
Objectives. Management communicates information about the organisation’s
governance objectives, relevant internal control policies and procedures and
how they work, and related individual responsibilities.
IFC.IC.IC.BP2 Communicate Through an Intranet Site. Management
develops and maintains an intranet site, accessible to all appropriate
personnel, for disseminating information regarding the organisation’s internal
control processes over financial reporting and trusted business operation.
IFC.IC.IC.BP3 Review Financial Information with the Oversight Board. At
regular oversight board meetings, the CFO reviews financial information,
analysis and related internal control, and enters into open discussion on all
matters of directors’ interest.
IFC.IC.IC.BP4 Communicate Between the Board and Internal Auditor.
The oversight board and the chief internal auditors meet periodically and
whenever events or circumstances warrant.
IFC.IC.IC.BP5 Communicate the Whistle-blower Program to Staff. The
organisation maintains a “whistle-blower” process that enables employees to
communicate misconduct, including matters relating to reliable governance.
IFC.IC.IC.BP6 Communicate Alternative Reporting Channels.
Management provides an alternative to reporting to a line manager – either a
coaching or mentoring program or a professional or technical reporting
channel – so that employees are confident that they will be heard.
IFC.IC.IC.BP7 Develop Guidelines for Communication to the Oversight
Board. The oversight board develops guidelines for materials it expects to
receive.
IFC.IC.IC.BP8 Consult with Outside Advisors. The oversight board

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 101/169

consults with outside advisors whenever committee members feel


management might lack the capability to adequately address an important
issue.

BP3 Retain competent individuals. The organization retains individuals competent


in relation to the organization’s business operation, financial reporting and related
oversight roles. [Outcome: 3]
NOTE3: This practice is implemented by performing practices of the COSO 2006
Financial Reporting Competences process with a specific focus on how enterprise
governance supports internal control over financial reporting and trusted business
operation:
IFC.CE.FRC.BP1 Establish Required Knowledge, Skills and Abilities.
Before hiring for key financial positions, management establishes and agrees
on the knowledge, skills, and abilities (and related credentials) needed to
effectively carry out the associated responsibilities.
IFC.CE.FRC.BP2 Supplement Competencies. The organization
supplements in-house financial reporting and trusted business operation
competencies as needed by establishing arrangements with outside
specialists.
IFC.CE.FRC.BP3 Provide Training. Management provides training for
employees involved in financial reporting and trusted business operation
processes, either in-house or through outside service providers.
IFC.CE.FRC.BP4 Evaluate Competencies in Key Governance Roles. The
oversight board (board of directors and/or audit committee) evaluates the
competencies of individuals serving in key governance roles, such as CEO,
CGO or CFO.
IFC.CE.FRC.BP5 Review and Evaluate Competencies. Management
periodically reviews and evaluates employees relative to their assigned roles
to determine whether the employees’ skills are appropriate for their current
job responsibilities.

Relationship The relationships between the Control Competence process and application
Notes practices, and other processes in COSO 2006 model, have been noted for each
practice above. This innovative concept of including “Application Areas” in a process
assessment model instantiates the idea of using already established processes with
respect to a particular application.
Sources COSO 2006: IFC.CE.HR Human Resources, IFC.IC.IC Internal Communication,
IFC.CE.FRC Financial Reporting Competencies
References Internal Control over Financial Reporting — Guidance for Smaller Public
Companies
Copyright © 2006 by The Committee of Sponsoring Organization, C/O
AICPA, Harborside Financial Center, 201 Plaza Three, Jersey City, NJ 07311
– 3881, USA. All rights reserved.

Work Products
Inputs Outputs
Code of Conduct [Outcome: 1] Job Descriptions [Outcome: 1]

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 102/169

Job Descriptions [Outcome: 1] HR Policies and Procedures [Outcome: 1]


Roles and Responsibilities [Outcome: 1] HR Records [Outcome: 1]
Nomination Records [Outcome: 1] Training Plans [Outcomes: 1, 3]
Training Plans [Outcomes: 1, 3] Periodic Staff Information [Outcome: 1]
Periodic Staff Information [Outcomes: 1, 2] Review and Appraisal Process [Outcome: 1]
Governance Competencies [Outcome: 1] Compensation Plans [Outcome: 1]
Skill Assessment Reports [Outcomes: 1, 3] Review Records [Outcomes: 1, 2]
Governance Information Repository [Outcome: 2] Skill Assessment Reports [Outcomes: 1, 3]
Financial Control Information Repository [Outcome: Guidelines for Communication to the Oversight
2] Board [Outcome: 2]
Oversight Agenda [Outcome: 2] Governance Competencies [Outcome: 3]
Audit Files [Outcome: 2] Outsourcing Arrangements [Outcome: 3]
Operating and Compliance Information [Outcome: 2]

Note: Above performance indicators driven by the COSO 2006 model are applicable for assessing the
effectiveness of controls in relation to objectives of financial reporting and trusted business operation.
However they should be considered as a starting point for judgment whether, given the application context,
they are contributing to the intended purpose of the process, not as a compulsory check-list of what every
organization must have.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 103/169

4.1.4 Information Reliability

Process ID GOV.IR
Process Name Information Reliability
Process Purpose The purpose of the Information Reliability process is to ensure the accuracy and
consistency in data architecture and disclosure elements relevant for financial
reporting objectives and trusted business operation, and for supporting data
processing integrity.
NOTE1: The Information Reliability process is a special application of the COSO
2006 and COBIT 4.1 models in the context of the “Accuracy” governance objective.
Thus this process is denoted an “Application Area”. The practices, called “application
practices”, are implemented using selected processes based on the COSO 2006
principles and the COBIT 4.1 framework in the context of this special application. This
facilitates the re-use of the elements of the COSO 2006 and COBIT 4.1 based
reference models without recreating processes that are already well established.
NOTE2: The descriptions of the COBIT 4.1 processes and the COSO 2006
Principles are applicable to define ISO/IEC 15504 conformant process reference
models and process performance indicators for assessing process capability
according to the ISO/IEC 15504 standard.
Process As a result of successful implementation of the Information Reliability process:
Outcomes
1) Effective information architecture and data model are maintained.
2) Information is systematically collected and assessed to detect compliance issues,
privacy problems and fraud.
3) Control information for automated process settings, data manipulations and
calculations are maintained systematically.
Application BP1 Ensure the integrity and consistency of all data stored in electronic form.
practices Satisfy the business requirement of being agile in responding to requirements;
provide reliable, consistent information, and seamlessly integrate applications into
business processes. [Outcome: 1]
NOTE1: This practice is implemented by performing practices (control objectives) of
the COBIT 4.1 Define the Information Architecture process with a specific focus on
how enterprise governance supports internal control over financial reporting and
trusted business operation:
PO2.1 Create and maintain enterprise information model. Establish and
maintain an enterprise information model to enable applications development
and decision-supporting activities, consistent with IT plans. The model should
facilitate the optimal creation, use and sharing of information by the business
in a way that maintains integrity and is flexible, functional, cost-effective,
timely, secure and resilient to failure.
PO2.2 Create and maintain enterprise data dictionary (ies). Maintain an
enterprise data dictionary that incorporates the organisation’s data syntax
rules. This dictionary should enable the sharing of data elements amongst
applications and systems, promote a common understanding of data
amongst IT and business users, and prevent incompatible data elements
from being created.
PO2.3 Establish and maintain data classification scheme. Establish a
classification scheme that applies throughout the enterprise, based on the
criticality and sensitivity (e.g., public, confidential, top secret) of enterprise
data. This scheme should include details about data ownership; definition of

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 104/169

appropriate security levels and protection controls; and a brief description of


data retention and destruction requirements, criticality and sensitivity. It
should be used as the basis for applying controls such as access controls,
archiving or encryption.
PO2.4 Manage data integrity. Define and implement procedures to ensure
the integrity and consistency of all data stored in electronic form, such as
databases, data warehouses and data archives.

BP2 Manage processing information. Pertinent information is identified, captured,


used at all levels of the organisation, and distributed in a form and timeframe that
supports the achievement of the organization’s financial reporting and trusted
business operation objectives. [Outcome: 2]
NOTE2: This practice is implemented by performing practices of the COSO 2006
Financial Reporting Information process with a specific focus on how enterprise
governance supports internal control over financial reporting and trusted business
operation:
IFC.IC.FRI.BP1 Use Matrices to Detail Information Flows. Process owners
maintain matrices that, for each process impacting financial reporting and
trusted business operation, detail the flow of information from the point of
capture through reporting.
IFC.IC.FRI.BP2 Obtain Information from External Sources. Management
obtains information from external sources, such as industry publications,
trade associations and conferences to identify events affecting industry
trends, suppliers, customers, competitors, and the economic climate.
IFC.IC.FRI.BP3 Meet with Personnel from Other Business Area.
Management in charge of governance meets periodically with personnel from
other areas of the business – such as operations, compliance, human
resources, or product development – to obtain information that may affect
financial reporting and trusted business operation.

BP3 Manage control information. Information used to execute other control


components is identified, captured, and distributed in a form and timeframe that
enables personnel to carry out their internal control responsibilities. [Outcome: 3]
NOTE3: This practice is implemented by performing practices of the COSO 2006
Internal Control Information process with a specific focus on how enterprise
governance supports internal control over financial reporting and trusted business
operation:
IFC.IC.ICI.BP1 Develop and Maintain Internal Control Information Maps.
Process owners develop and maintain information maps.
IFC.IC.ICI.BP2 Identify Internal Control Information through Discussion.
In assessing information needs, management identifies through discussions
with various personnel information used to manage and control day-to-day
operations and how this information relates to governance and reporting.
Relationship The relationships between the Information Reliability process and application
Notes practices, and other processes in COSO 2006 and COBIT 4.1 models, have been
noted for each practice above. This innovative concept of including “Application
Areas” in a process assessment model instantiates the idea of using already
established processes with respect to a particular application.
Sources COBIT 4.1: PO2 Define the Information Architecture
COSO 2006: IFC.IC.FRI Financial Reporting Information, IFC.IC.ICI Internal Control

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 105/169

Information
References Control Objectives for Information and related Technology - COBIT® 4.1
Copyright © 2007 by the IT Governance Institute. 3701 Algonquin Road,
Suite 1010 Rolling Meadows, IL 60008 USA. All rights reserved.
Internal Control over Financial Reporting — Guidance for Smaller Public
Companies
Copyright © 2006 by The Committee of Sponsoring Organization, C/O
AICPA, Harborside Financial Center, 201 Plaza Three, Jersey City, NJ 07311
– 3881, USA. All rights reserved.

Work Products
Inputs Outputs
Strategic IT plan [Outcome: 1] Data classification scheme [Outcome: 1]
Tactical IT plan [Outcome: 1] Optimised business systems plan [Outcome: 1]
Business requirements feasibility study [Outcome: 1] Data dictionary [Outcome: 1]
Post-implementation review [Outcome: 1] Information architecture [Outcome: 1]
Performance and capacity information [Outcome: 1] Assigned data classifications [Outcome: 1]
Performance input to IT planning [Outcome: 1] Classification procedures and tools [Outcome: 1]
Related Business Activities [Outcome: 2] Governance Information Maps [Outcomes: 2, 3]
Related IT Systems [Outcome: 2] Meeting Minutes [Outcome: 2]
Organizational Structure [Outcome: 2] Governance Information Repository [Outcomes: 2,
3]
Operating and Compliance Information [Outcomes: 2, Reporting Triggers [Outcome: 3]
3]
Management Records [Outcome: 2] Review Records [Outcome: 3]
Governance Information Maps [Outcome: 3]

Note: Above performance indicators driven by the COBIT 4.1 and COSO 2006 models are applicable for
assessing the effectiveness of controls in relation to objectives of financial reporting and trusted business
operation. However they should be considered as a starting point for judgment whether, given the application
context, they are contributing to the intended purpose of the process, not as a compulsory check-list of what
every organization must have.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 106/169

4.1.5 Process Control

Process ID GOV.PC
Process Name Process Control
Process Purpose The purpose of the Process Control process is to ensure effective design and
operation of process-level controls relevant to the objectives of financial reporting and
trusted business operation, and processing integrity principle.
NOTE1: The Process Control process is a special application of the COSO 2006
model in the context of the “Process Integrity” governance objective. Thus this
process is denoted an “Application Area”. The practices, called “application
practices”, are implemented using selected processes based on the COSO 2006
principles in the context of this special application. This facilitates the re-use of the
elements of the COSO 2006 based reference model without recreating processes
that are already well established.
NOTE2: The descriptions of the COSO 2006 Principles are applicable to define
ISO/IEC 15504 conformant process reference models and process performance
indicators for assessing process capability according to the ISO/IEC 15504 standard.
NOTE3: Processing integrity principle is referred by AICPA’s guide of Reporting on
Controls at a Service Organization Relevant to Security, Availability, Processing
Integrity, Confidentiality, or Privacy (SOC 2). This reference material is not directly
applicable to define ISO/IEC 15504 conformant process reference model and
process performance indicators for assessing process capability according to the
ISO/IEC 15504 standard, however provide detailed criteria for implementing these
principles.
Process As a result of successful implementation of the Process Control process:
Outcomes
1) Control activities over access, amendments, adjustments and other usage of
business information are maintained systematically.
2) Application and general IT controls are maintained.
3) Process performance metrics are collected and evaluated.
Application BP1 Maintain control activities. Control activities are selected and developed
practices considering their cost and their potential effectiveness in mitigating risks to the
achievement of financial reporting and trusted business operation objectives.
[Outcome: 1]
NOTE1: This practice is implemented by performing practices of the COSO 2006
Selection and Development of Control Activities process with a specific focus on how
enterprise governance supports internal control over financial reporting and trusted
business operation:
IFC.CA.SD.BP1 Separate Incompatible Activities. Management separates
incompatible activities by assigning them to different personnel or through
implementation of information technology applications.
IFC.CA.SD.BP2 Monitor When Restricting Access Is not Practical. Where
limiting access to transaction records is not practical, management, process
owners, or internal auditors monitor the records closely for potential
misstatements.
IFC.CA.SD.BP3 Provide Outsourcing Assessment Report. Management
is outsourcing some of its operations to a third party, which is contractually
obligated to report to the organisation on relevant controls, and provides an
independent assessment report (e.g. SOC 1 Report).
IFC.CA.SD.BP4 Assess the Cost vs Benefit of Various Control

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 107/169

Approaches. Management assesses the costs of addressing identified risks


using various control approaches, and weighs the costs against effectiveness
of the controls in mitigating the respective risks.
IFC.CA.SD.BP5 Use Organizational Charts to Identify Incompatible
Functions. Using organization charts, process flowcharts or other means by
which activities are documented, management identifies any incompatibilities
in functions and maintains appropriate segregation of duties.
IFC.CA.SD.BP6 Consider Compensating Controls. Where resource
constraints compromise the ability to segregate duties to achieve governance
objectives effectively, management considers compensating control activities.

BP2 Maintain information technology controls. Information technology controls,


where applicable, are designed and implemented to support the achievement of
financial reporting and trusted business operation objectives. [Outcome: 2]
NOTE2: This practice is implemented by performing practices of the COSO 2006
Information Technology process with a specific focus on how enterprise governance
supports internal control over financial reporting and trusted business operation:
IFC.CA.IT.BP1 Apply Systems Development Controls. These controls
over design and implementation of systems help to ensure that systems are
appropriately developed, configured, approved, and migrated into production.
IFC.CA.IT.BP2 Apply Change Management Controls. These controls over
modifications to systems – whether applications, supporting databases or
operating systems – help to ensure that changes are approved and properly
tested and implemented.
IFC.CA.IT.BP3 Apply Security and Access Controls. These controls over
critical applications, supporting databases, and networks help management
to ensure that access is properly authorized and data is appropriately used,
maintained and reported.
IFC.CA.IT.BP4 Apply Computer Operations Controls. Management
applies these controls over day-to-day operations to ensure that processing
errors or improprieties are identified and corrected in a timely manner.
IFC.CA.IT.BP5 Apply Application Controls. Management implements
controls over data input to determine whether transactions are authorized,
and transactions are processed correctly and completely, with rejected items
captured and followed-up
IFC.CA.IT.BP6 Identify and Secure End-User Computing Applications.
Management identifies significant end-user applications, including
spreadsheets and other user-developed programs.
IFC.CA.IT.BP7 Review Outsourced Operations. Management reviews
general computer controls of critical third party vendors that host and/or
support critical financial applications and/or information technology support
functions.

BP3 Evaluate effectiveness of internal controls. Ongoing and/or separate


evaluations enable management to determine whether internal control over financial
reporting and trusted business operation is present and functioning. [Outcome: 3]
NOTE3: This practice is implemented by performing practices of the COSO 2006
Ongoing and Separate Evaluations process with a specific focus on how enterprise
governance supports internal control over financial reporting and trusted business
operation:
IFC.MO.OSE.BP1 Use Metrics to Track performance. Management

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 108/169

establishes supervisory activities, consisting of recording metrics about


control in processes so that current performance can be tracked and
compared with target performance.
IFC.MO.OSE.BP2 Develop and Implement Control Charts. Management
develops and implements control charts for reviewers – usually supervisors of
those with first-level accountability for processes and activities and their
controls – to use in considering whether control performance is on track, the
right metrics are being monitored, and deviations are being investigated and
resolved.
IFC.MO.OSE.BP3 Relate Metrics to Governance Objectives. Management
confirms that operations metrics that are monitored have reasonable
correlation to financial reports and thus can be used as an indicator of
potential deficiencies in financial reporting and trusted business operation.
IFC.MO.OSE.BP4 Use Self-Assessments. Management develops a self-
assessment questionnaire for a business process for use by personnel
involved in executing controls.
IFC.MO.OSE.BP5 Use Computer Network Testing. Management
periodically tests its computer network by performing a penetration review to
identify weaknesses in internal controls regarding external connectivity.
IFC.MO.OSE.BP6 Use Internal Audit. Management uses an internal audit
function to provide an objective perspective on key elements of the internal
control system.
IFC.MO.OSE.BP7 Determine Scope and Frequency of Separate
Evaluations. Management sets a schedule for conducting separate
evaluations of specific processes and control activities, with higher risk
processes reviewed by the internal audit function.
Relationship The relationships between the Process Control process and application practices,
Notes and other processes in COSO 2006 model, have been noted for each practice above.
This innovative concept of including “Application Areas” in a process assessment
model instantiates the idea of using already established processes with respect to a
particular application.
Sources COSO 2006: IFC.CA.SD Selection and Development of Control Activities, IFC.CA.IT
Information Technology, IFC.MO.OSE Ongoing and Separate Evaluations
References Internal Control over Financial Reporting — Guidance for Smaller Public
Companies
Copyright © 2006 by The Committee of Sponsoring Organization, C/O
AICPA, Harborside Financial Center, 201 Plaza Three, Jersey City, NJ 07311
– 3881, USA. All rights reserved.
Reporting on Controls at a Service Organization Relevant to Security,
Availability, Processing Integrity, Confidentiality, or Privacy (SOC 2)
Copyright © 2011, American Institute of Certified Public Accountants, Inc. All
Rights Reserved.

Work Products
Inputs Outputs

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 109/169

Inventory of Controls [Outcome: 1] Risk and Control Documentation [Outcome: 1]


Organizational Charts [Outcome: 1] Cost vs. Benefit Analysis [Outcome: 1]
Risk and Control Documentation [Outcomes: 1, 2, 3] Review Records [Outcomes: 1, 2, 3]
Outsourcing Arrangements [Outcome: 1] Outsourcing Assessment Report [Outcome: 1]
Related IT Systems [Outcome: 2] IT Controls Documentation [Outcome: 2]
Outsourcing Assessment Report [Outcomes: 2, 3] Operational Metrics [Outcome: 3]
Operating and Compliance Information [Outcome: 3] Assessment Control Charts [Outcome: 3]
Audit Files [Outcome: 3] Self-Assessment Files [Outcome: 3]
Computer Network Test Files [Outcome: 3]
Assessment Plan [Outcome: 3]

Note: Above performance indicators driven by the COSO 2006 model are applicable for assessing the
effectiveness of controls in relation to objectives of financial reporting and trusted business operation.
However they should be considered as a starting point for judgment whether, given the application context,
they are contributing to the intended purpose of the process, not as a compulsory check-list of what every
organization must have.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 110/169

4.1.6 Data Protection

Process ID GOV.DP
Process Name Data Protection
Process Purpose The purpose of the Data Protection process is to ensure that the organization and its
staff are committed to security, confidentiality and privacy principles to avoid
unauthorized access to and misuse of confidential data effected by business
operation.
NOTE1: The Data Protection process is a special application of the COSO 2006 and
COBIT 4.1 models in the context of the “Data Protection” governance objective. Thus
this process is denoted an “Application Area”. The practices, called “application
practices”, are implemented using selected processes based on the COSO 2006
principles and the COBIT 4.1 framework in the context of this special application. This
facilitates the re-use of the elements of the COSO 2006 and COBIT 4.1 based
reference models without recreating processes that are already well established.
NOTE2: The descriptions of the COBIT 4.1 processes and the COSO 2006
Principles are applicable to define ISO/IEC 15504 conformant process reference
models and process performance indicators for assessing process capability
according to the ISO/IEC 15504 standard.
NOTE3: Security, confidentiality and privacy principles are referred by AICPA’s guide
of Reporting on Controls at a Service Organization Relevant to Security, Availability,
Processing Integrity, Confidentiality, or Privacy (SOC 2). This reference material is
not directly applicable to define ISO/IEC 15504 conformant process reference model
and process performance indicators for assessing process capability according to the
ISO/IEC 15504 standard, however provide detailed criteria for implementing these
principles.
Process As a result of successful implementation of the Data Protection process:
Outcomes
1) Preventive controls are maintained to avoid system security incidents.
2) Anti-fraud management program is maintained.
3) Privacy requirements are kept.
Application BP1 Maintain policies and procedures to avoid system security incidents.
practices Satisfy the business requirement of maintaining the confidentiality, integrity and
availability of information and the processing infrastructure aligned to business needs
and minimising the impact of security vulnerabilities. [Outcome: 1]
NOTE1: This practice is implemented according to the security and confidentiality
principles and related criteria referred by AICPA’s guide of Reporting on Controls at a
Service Organization Relevant to Security, Availability, Processing Integrity,
Confidentiality, or Privacy (SOC 2).
NOTE2: This practice is implemented by performing practices (control objectives) of
the COBIT 4.1 Ensure Systems Security process with a specific focus on how
enterprise governance supports internal control over financial reporting and trusted
business operation:
DS5.1 Management of IT Security. Manage IT security at the highest
appropriate organisational level, so the management of security actions is in
line with business requirements.
DS5.2 IT Security Plan. Translate business, risk and compliance
requirements into an overall IT security plan, taking into consideration the IT
infrastructure and the security culture. Ensure that the plan is implemented in
security policies and procedures together with appropriate investments in

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 111/169

services, personnel, software and hardware. Communicate security policies


and procedures to stakeholders and users.
DS5.3 Identity Management. Ensure that all users (internal, external and
temporary) and their activity on IT systems (business application, IT
environment, system operations, development and maintenance) are
uniquely identifiable. Enable user identities via authentication mechanisms.
Confirm that user access rights to systems and data are in line with defined
and documented business needs and that job requirements are attached to
user identities. Ensure that user access rights are requested by user
management, approved by system owners and implemented by the security-
responsible person. Maintain user identities and access rights in a central
repository. Deploy cost-effective technical and procedural measures, and
keep them current to establish user identification, implement authentication
and enforce access rights.
DS5.4 User Account Management. Address requesting, establishing,
issuing, suspending, modifying and closing user accounts and related user
privileges with a set of user account management procedures. Include an
approval procedure outlining the data or system owner granting the access
privileges. These procedures should apply for all users, including
administrators (privileged users) and internal and external users, for normal
and emergency cases. Rights and obligations relative to access to enterprise
systems and information should be contractually arranged for all types of
users. Perform regular management review of all accounts and related
privileges.
DS5.5 Security Testing, Surveillance and Monitoring. Test and monitor
the IT security implementation in a proactive way. IT security should be
reaccredited in a timely manner to ensure that the approved enterprise’s
information security baseline is maintained. A logging and monitoring function
will enable the early prevention and/or detection and subsequent timely
reporting of unusual and/or abnormal activities that may need to be
addressed.
DS5.6 Security Incident Definition. Clearly define and communicate the
characteristics of potential security incidents so they can be properly
classified and treated by the incident and problem management process.
DS5.7 Protection of Security Technology. Make security- related
technology resistant to tampering, and do not disclose security
documentation unnecessarily.
DS5.8 Cryptographic Key Management. Determine that policies and
procedures are in place to organise the generation, change, revocation,
destruction, distribution, certification, storage, entry, use and archiving of
cryptographic keys to ensure the protection of keys against modification and
unauthorised disclosure.
DS5.9 Malicious Software Prevention, Detection and Correction. Put
preventive, detective and corrective measures in place (especially up-to-date
security patches and virus control) across the organisation to protect
information systems and technology from malware (e.g., viruses, worms,
spyware, spam).
DS5.10 Network Security. Use security techniques and related management
procedures (e.g., firewalls, security appliances, network segmentation,
intrusion detection) to authorise access and control information flows from
and to networks.
DS5.11 Exchange of Sensitive Data. Exchange sensitive transaction data
only over a trusted path or medium with controls to provide authenticity of

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 112/169

content, proof of submission, proof of receipt and non-repudiation of origin.

BP2 Manage fraud risks. The potential for material misstatement due to fraud is
explicitly considered in assessing risks to the achievement of financial reporting and
trusted business operation objectives. [Outcome: 2]
NOTE3: This practice is implemented by performing practices of the COSO 2006
Fraud Risks process with a specific focus on how enterprise governance supports
internal control over financial reporting and trusted business operation:
IFC.RA.FR.BP1 Review Incentives and Pressures Related to
Compensation Programs. The oversight board and management review the
organization’s compensation programs and organization’s performance
evaluation process to identify potential incentives and pressures for
employees to commit fraud.
IFC.RA.FR.BP2 Conduct Fraud Risk Assessments. Management conducts
a comprehensive fraud risk assessment to identify the various ways that
fraud and misconduct can occur.
IFC.RA.FR.BP3 Consider Approaches to Circumvent or Override
Controls. In identifying, evaluating, and testing the design and operating
effectiveness of entity-wide controls that address fraud, management
considers how individuals might seek to circumvent or override controls
intended to prevent or detect fraud.
IFC.RA.FR.BP4 Use Information Technology Tools. Management uses,
where practical, information technology tools including security systems,
fraud detection and monitoring tools, and incident tracking systems to identify
and manage fraud risk.
IFC.RA.FR.BP5 Develop Incident Investigation and Remediation
Processes. Management develops a structured process for incident
investigation and remediation. Investigation roles and responsibilities are
clearly delineated, and the processes include a tracking mechanism that
allows management to report on material fraud events.
IFC.RA.FR.BP6 Consider Fraud Risk by Internal Audit. The person
responsible for the internal audit function incorporates results of the fraud risk
assessment into the internal audit plan. Management reviews and confirms
that the internal audit plan addresses relevant risks.

BP3 Maintain policies and procedures to ensure privacy requirements. Personal


information is collected, used, retained, disclosed, and destroyed in conformity with
the commitments in the entity’s privacy notice and with criteria set forth in generally
accepted privacy principles (GAPP). [Outcome: 3]
NOTE4: This practice is implemented according to the privacy principle and related
criteria referred by AICPA’s guide of Reporting on Controls at a Service Organization
Relevant to Security, Availability, Processing Integrity, Confidentiality, or Privacy
(SOC 2).
NOTE5: The generally accepted privacy principles (GAPP) are based on
internationally known fair information practices included in many privacy laws and
regulations of various jurisdictions around the world and recognized good privacy
practices. The following are the 10 GAPPs:
GAPP01. Management. The entity defines, documents, communicates, and
assigns accountability for its privacy policies and procedures.
GAPP02. Notice. The entity provides notice about its privacy policies and
procedures and identifies the purposes for which personal information is

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 113/169

collected, used, retained, and disclosed.


GAPP03. Choice and consent. The entity describes the choices available to
the individual and obtains implicit or explicit consent with respect to the
collection, use, and disclosure of personal information.
GAPP04. Collection. The entity collects personal information only for the
purposes identified in the notice.
GAPP05. Use and retention. The entity limits the use of personal
information to the purposes identified in the notice and for which the
individual has provided implicit or explicit consent. The entity retains personal
information for only as long as necessary to fulfil the stated purposes.
GAPP06. Access. The entity provides individuals with access to their
personal information for review and update.
GAPP07. Disclosure to third parties. The entity discloses personal
information to third parties only for the purposes identified in the notice and
with the implicit or explicit consent of the individual.
GAPP08. Security for privacy. The entity protects personal information
against unauthorized access (both physical and logical).
GAPP09. Quality. The entity maintains accurate, complete, and relevant
personal information for the purposes identified in the notice.
GAPP10. Monitoring and enforcement. The entity monitors compliance
with its privacy policies and procedures and has procedures to address
privacy-related complaints and disputes.
Relationship The relationships between the Data Protection process and application practices, and
Notes other processes in COSO 2006 and COBIT 4.1 models, have been noted for each
practice above. This innovative concept of including “Application Areas” in a process
assessment model instantiates the idea of using already established processes with
respect to a particular application.
Sources COBIT 4.1: DS5 Ensure Systems Security
COSO 2006: IFC.RA.FR Fraud Risks
Generally Accepted Privacy Principles
References Control Objectives for Information and related Technology - COBIT® 4.1
Copyright © 2007 by the IT Governance Institute. 3701 Algonquin Road,
Suite 1010 Rolling Meadows, IL 60008 USA. All rights reserved.
Internal Control over Financial Reporting — Guidance for Smaller Public
Companies
Copyright © 2006 by The Committee of Sponsoring Organization, C/O
AICPA, Harborside Financial Center, 201 Plaza Three, Jersey City, NJ 07311
– 3881, USA. All rights reserved.
Reporting on Controls at a Service Organization Relevant to Security,
Availability, Processing Integrity, Confidentiality, or Privacy (SOC 2)
Copyright © 2011, American Institute of Certified Public Accountants, Inc. All
Rights Reserved.

Work Products
Inputs Outputs
Information architecture; assigned data Security incident definition [Outcome: 1]
classifications [Outcomes: 1, 2, 3]

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 114/169

Technology standards [Outcome: 1] Specific training requirements on security


awareness [Outcome: 1]
Risk assessment [Outcome: 1, 2, 3] Process performance reports [Outcome: 1]
Application security controls specification [Outcome: Required security changes [Outcome: 1]
1]
OLAs [Outcome: 1] Security threats and vulnerabilities [Outcome: 1]
Compensation Plans [Outcome: 2] IT security plan and policies [Outcome: 1]
Business Policies [Outcome: 2] Fraud Risk Assessment Report [Outcome: 2]
Transaction data [Outcome: 2, 3] Anti-Fraud Policies and Procedures [Outcome: 2]
Audit Files [Outcome: 2, 3] Anti-Fraud Management Plan [Outcome: 2]
Identified Personal Information [Outcome: 3] Review Records [Outcome: 2, 3]
Applicable Privacy Laws [Outcome: 3] Privacy policies [Outcome: 3]
Privacy procedures and controls [Outcome: 3]
Privacy Incident Reports [Outcome: 3]

Note: Above performance indicators driven by the COBIT 4.1 and COSO 2006 models and the generally
accepted privacy principles are applicable for assessing the effectiveness of controls in relation to objectives
of financial reporting and trusted business operation. However they should be considered as a starting point
for judgment whether, given the application context, they are contributing to the intended purpose of the
process, not as a compulsory check-list of what every organization must have.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 115/169

4.1.7 Integrity Assurance

Process ID GOV.IA
Process Name Integrity Assurance
Process Purpose The purpose of the Integrity Assurance process is to ensure that the organization and
its staff are committed to comply with ethical and integrity requirements relevant to
the objectives of financial reporting and trusted business operation, and availability
principle.
NOTE1: The Integrity Assurance process is a special application of the COSO 2006
and COBIT 4.1 models in the context of the “Commitment” governance objective.
Thus this process is denoted an “Application Area”. The practices, called “application
practices”, are implemented using selected processes based on the COSO 2006
principles and the COBIT 4.1 framework in the context of this special application. This
facilitates the re-use of the elements of the COSO 2006 and COBIT 4.1 based
reference models without recreating processes that are already well established.
NOTE2: The descriptions of the COBIT 4.1 processes and the COSO 2006
Principles are applicable to define ISO/IEC 15504 conformant process reference
models and process performance indicators for assessing process capability
according to the ISO/IEC 15504 standard.
NOTE3: Availability principle is referred by AICPA’s guide of Reporting on Controls
at a Service Organization Relevant to Security, Availability, Processing Integrity,
Confidentiality, or Privacy (SOC 2). This reference material is not directly applicable
to define ISO/IEC 15504 conformant process reference model and process
performance indicators for assessing process capability according to the ISO/IEC
15504 standard, however provide detailed criteria for implementing these principles.
Process As a result of successful implementation of the Integrity Assurance process:
Outcomes
1) Ethical values are articulated and kept.
2) Active policies and procedures are in place to ensure business continuity.
3) Information from external parties are collected and reviewed systematically.
Application BP1 Ensure commitment to sound integrity and ethical values. Sound integrity
practices and ethical values, particularly of top management, are developed and understood
and set the standard of conduct for financial reporting and trusted business operation.
[Outcome: 1]
NOTE1: This practice is implemented by performing practices of the COSO 2006
Integrity and Ethical Values process with a specific focus on how enterprise
governance supports internal control over financial reporting and trusted business
operation:
IFC.CE.IEV.BP1 Articulate and Demonstrate Integrity and Ethics. The
key members of management articulate and demonstrate the importance of
sound integrity and ethical values to employees.
IFC.CE.IEV.BP2 Inform Employees about Integrity and Ethics.
Management implements mechanisms to inform new employees and remind
current personnel of the organisation’s objectives related to integrity and
ethics and related corporate values.
IFC.CE.IEV.BP3 Demonstrate Commitment to Integrity and Ethics.
Management demonstrates its commitment to sound integrity and ethical
values by following a prescribed investigation process and taking appropriate,
timely corrective action when possible violations are identified.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 116/169

BP2 Ensure business continuity. Satisfy the business requirement of ensuring


minimal business impact in the event of an IT service interruption. [Outcome: 2]
NOTE2: This practice is implemented according to the availability principle and
related criteria referred by AICPA’s guide of Reporting on Controls at a Service
Organization Relevant to Security, Availability, Processing Integrity, Confidentiality, or
Privacy (SOC 2).
NOTE3: This practice is implemented by performing practices (control objectives) of
the COBIT 4.1 Ensure Continuous Service process with a specific focus on how
enterprise governance supports internal control over financial reporting and trusted
business operation:
DS4.1 IT Continuity Framework. Develop a framework for IT continuity to
support enterprise-wide business continuity management using a consistent
process. The objective of the framework should be to assist in determining
the required resilience of the infrastructure and to drive the development of
disaster recovery and IT contingency plans. The framework should address
the organisational structure for continuity management, covering the roles,
tasks and responsibilities of internal and external service providers, their
management and their customers, and the planning processes that create the
rules and structures to document, test and execute the disaster recovery and
IT contingency plans. The plan should also address items such as the
identification of critical resources, noting key dependencies, the monitoring
and reporting of the availability of critical resources, alternative processing,
and the principles of backup and recovery.
DS4.2 IT Continuity Plans. Develop IT continuity plans based on the
framework and designed to reduce the impact of a major disruption on key
business functions and processes. The plans should be based on risk
understanding of potential business impacts and address requirements for
resilience, alternative processing and recovery capability of all critical IT
services. They should also cover usage guidelines, roles and responsibilities,
procedures, communication processes, and the testing approach.
DS4.3 Critical IT Resources. Focus attention on items specified as most
critical in the IT continuity plan to build in resilience and establish priorities in
recovery situations. Avoid the distraction of recovering less-critical items and
ensure response and recovery in line with prioritised business needs, while
ensuring that costs are kept at an acceptable level and complying with
regulatory and contractual requirements. Consider resilience, response and
recovery requirements for different tiers, e.g., one to four hours, four to 24
hours, more than 24 hours and critical business operational periods.
DS4.4 Maintenance of the IT Continuity Plan. Encourage IT management
to define and execute change control procedures to ensure that the IT
continuity plan is kept up to date and continually reflects actual business
requirements. Communicate changes in procedures and responsibilities
clearly and in a timely manner.
DS4.5 Testing of the IT Continuity Plan. Test the IT continuity plan on a
regular basis to ensure that IT systems can be effectively recovered,
shortcomings are addressed and the plan remains relevant. This requires
careful preparation, documentation, reporting of test results and, according to
the results, implementation of an action plan. Consider the extent of testing
recovery of single applications to integrated testing scenarios to end-to-end
testing and integrated vendor testing.
DS4.6 IT Continuity Plan Training. Provide all concerned parties with
regular training sessions regarding the procedures and their roles and
responsibilities in case of an incident or disaster. Verify and enhance training

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 117/169

according to the results of the contingency tests.


DS4.7 Distribution of the IT Continuity Plan. Determine that a defined and
managed distribution strategy exists to ensure that plans are properly and
securely distributed and available to appropriately authorised interested
parties when and where needed. Attention should be paid to making the
plans accessible under all disaster scenarios.
DS4.8 IT Services Recovery and Resumption. Plan the actions to be taken
for the period when IT is recovering and resuming services. This may include
activation of backup sites, initiation of alternative processing, customer and
stakeholder communication, and resumption procedures. Ensure that the
business understands IT recovery times and the necessary technology
investments to support business recovery and resumption needs.
DS4.9 Offsite Backup Storage. Store offsite all critical backup media,
documentation and other IT resources necessary for IT recovery and
business continuity plans. Determine the content of backup storage in
collaboration between business process owners and IT personnel.
Management of the offsite storage facility should respond to the data
classification policy and the enterprise’s media storage practices. IT
management should ensure that offsite arrangements are periodically
assessed, at least annually, for content, environmental protection and
security. Ensure compatibility of hardware and software to restore archived
data, and periodically test and refresh archived data.
DS4.10 Post-resumption Review. Determine whether IT management has
established procedures for assessing the adequacy of the plan in regard to
the successful resumption of the IT function after a disaster, and update the
plan accordingly.

BP3 Utilize external opinions. Matters affecting the achievement of the financial
reporting and trusted business operation objectives are communicated with outside
parties. [Outcome: 3]
NOTE4: This practice is implemented by performing practices of the COSO 2006
External Communication process with a specific focus on how enterprise governance
supports internal control over financial reporting and trusted business operation:
IFC.IC.EC.BP1 Communicate the Whistle-blower Program to Outside
Parties. Management enables receipt of important information from parties
doing business with the organisation, such as vendors who feel they have not
been treated fairly, receive pressure for kickbacks, are subject to other
improprieties, or are aware of improper financial reporting and trusted
business operation.
IFC.IC.EC.BP2 Survey Outside Parties. Management surveys customers,
vendors and others on their perception of the integrity and ethical values.
IFC.IC.EC.BP3 Review External Audit Communications. Following the
external auditor’s review of management’s certification process and
independent evaluation of internal control effectiveness, management
receives a memorandum on significant matters identified during the course of
the work.
Relationship The relationships between the Integrity Assurance process and application practices,
Notes and other processes in COSO 2006 and COBIT 4.1 models, have been noted for
each practice above. This innovative concept of including “Application Areas” in a
process assessment model instantiates the idea of using already established
processes with respect to a particular application.
Sources COBIT 4.1: PO2 Ensure Continuous Service

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 118/169

COSO 2006: IFC.CE.IEV Integrity and Ethical Values, IFC.IC.EC External


Communication
References Control Objectives for Information and related Technology - COBIT® 4.1
Copyright © 2007 by the IT Governance Institute. 3701 Algonquin Road,
Suite 1010 Rolling Meadows, IL 60008 USA. All rights reserved.
Internal Control over Financial Reporting — Guidance for Smaller Public
Companies
Copyright © 2006 by The Committee of Sponsoring Organization, C/O
AICPA, Harborside Financial Center, 201 Plaza Three, Jersey City, NJ 07311
– 3881, USA. All rights reserved.
Reporting on Controls at a Service Organization Relevant to Security,
Availability, Processing Integrity, Confidentiality, or Privacy (SOC 2)
Copyright © 2011, American Institute of Certified Public Accountants, Inc. All
Rights Reserved.

Work Products
Inputs Outputs
Remediation Plans [Outcome: 1] Code of Conduct [Outcome: 1]
Periodic Staff Information [Outcome: 1] Monitoring Reports [Outcome:1]
Assigned data classifications [Outcome: 2] Remediation Plans [Outcome: 1]
Risk assessment Availability, continuity and recovery Periodic Staff Information [Outcome: 1]
specification [Outcome: 2]
User, operational, support, technical and Contingency test results [Outcome: 2]
administration manuals [Outcome: 2]

SLAs and OLAs [Outcome: 2] Criticality of IT configuration items [Outcome: 2]


Operating and Compliance Information [Outcome: 3] Backup storage and protection plan [Outcome: 2]
Oversight Agenda [Outcome: 3] Incident/disaster thresholds [Outcome: 2]
Audit Files [Outcome: 3] Disaster service requirements, including roles and
responsibilities [Outcome: 2]
Process performance reports [Outcome: 2]
Outside Parties Survey [Outcome: 3]
Review Records [Outcome: 3]

Note: Above performance indicators driven by the COBIT 4.1 and COSO 2006 models are applicable for
assessing the effectiveness of controls in relation to objectives of financial reporting and trusted business
operation. However they should be considered as a starting point for judgment whether, given the application
context, they are contributing to the intended purpose of the process, not as a compulsory check-list of what
every organization must have.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 119/169

4.1.8 Control Efficiency

Process ID GOV.CE
Process Name Control Efficiency
Process Purpose The purpose of the Control Efficiency process is to ensure efficient usage of control
resources relevant to the objectives of financial reporting and trusted business
operation.
NOTE1: The Control Efficiency process is a special application of the COSO 2006
model in the context of the “Control Efficiency” governance objective. Thus this
process is denoted an “Application Area”. The practices, called “application
practices”, are implemented using selected processes based on the COSO 2006
principles in the context of this special application. This facilitates the re-use of the
elements of the COSO 2006 based reference model without recreating processes
that are already well established.
NOTE2: The descriptions of the COSO 2006 Principles are applicable to define
ISO/IEC 15504 conformant process reference models and process performance
indicators for assessing process capability according to the ISO/IEC 15504 standard.
Process As a result of successful implementation of the Control Efficiency process:
Outcomes
1) Adequate organizational structure and reporting lines are maintained.
2) Oversight of internal controls is effective.
3) Control deficiencies are reviewed and necessary actions are taken.
Application BP1 Ensure adequate organizational structure. The entity’s organizational
practices structure supports effective internal control over financial reporting and trusted
business operation. [Outcome: 1]
NOTE1: This practice is implemented by performing practices of the COSO 2006
Organizational Structure process with a specific focus on how enterprise governance
supports internal control over financial reporting and trusted business operation:
IFC.CE.OS.BP1 Develop Organizational Charts. Management develops an
organizational chart, which sets forth roles and respective reporting lines for
all employees, including those involved in financial reporting and trusted
business operation.
IFC.CE.OS.BP2 Align Roles to Processes. Each unit or function within the
organization aligns roles to key processes supporting governance objectives.
IFC.CE.OS.BP3 Maintain Job Descriptions. Management maintains job
descriptions for key positions and updates them as conditions and
circumstances warrant.
IFC.CE.OS.BP4 Establish Organizational Structures. Management adopts
a structure whereby there are adequate staff layers between the Chief
Governance Officer (CGO) and personnel directly involved in the financial
reporting and trusted business operation process.
IFC.CE.OS.BP5 Establish Structure for Internal Audit. An internal audit
function reports directly to the Chief Executive Officer (CEO), with direct
access to the oversight board (e.g. audit committee), to maintain
independence over financial reporting and trusted business operation.

BP2 Supervise internal controls. The oversight board understands and exercises
oversight responsibility related to trusted business operation, financial reporting and
related internal control. [Outcome: 2]

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 120/169

NOTE2: This practice is implemented by performing practices of the COSO 2006


Oversight Board process with a specific focus on how enterprise governance
supports internal control over financial reporting and trusted business operation:
IFC.CE.OB.BP1 Establish Content for Board Meetings. The oversight
board establishes a formal policy for specific decisions or events that require
discussion with or approval from the board, as well as a calendar for the
timing of these discussions.
IFC.CE.OB.BP2 Identify Independent Board Members. Independent
oversight board and/or audit committee members are identified.
IFC.CE.OB.BP3 Establish Boards Roles and Responsibilities. The
oversight board through the corporate bylaws, and the audit committee
through its charter, set forth their roles and responsibilities.
IFC.CE.OB.BP4 Consider Effectiveness of Internal Control. The oversight
board regularly considers the effectiveness of internal control over financial
reporting and trusted business operation, including risks, significant
deficiencies, and material weaknesses (if any).
IFC.CE.OB.BP5 Meet with Auditors. The oversight board meets regularly
with the internal and external auditors, including in private meetings. The
board reviews audit scope and testing plans, resources and staffing, and
significant audit findings.
IFC.CE.OB.BP6 Review Policies and Procedures. The oversight board
reviews governance policies and procedures used by management for
determining significant expectations, including key assumptions.
IFC.CE.OB.BP7 Maintain Scepticism. The oversight board maintains an
appropriate level of scepticism regarding management’s assertions and
judgments affecting governance reporting, asking probing and challenging
questions of management.
IFC.CE.OB.BP8 Consider Whistle-blower Information. The oversight
board considers information obtained from the whistle-blower program and
the organisation’s anti-fraud and similar processes to monitor the risks of
misstatements in governance reporting, including risks of inappropriate acts
by staff and management override of controls. The board reviews reports of
significant matters, considering the potential impact on governance reporting
and need for corrective action.
IFC.CE.OB.BP9 Review Board Candidates. The oversight board conducts
due diligence on board and audit committee candidates to confirm
appropriate independence from the organisation and management and
his/her ability to be an effective board member.
IFC.CE.OB.BP10 Certify Compliance. The oversight board members certify
annually their compliance with the organisation’s ethics guidelines and
independence rules.
IFC.CE.OB.BP11 Meet with Management. The oversight board allocate a
portion of every meeting for discussions of issues without management
present, including separate time with external advisors, internal audit, the
external auditor and outside legal counsel.

BP3 Manage internal control deficiencies. Internal control deficiencies are


identified and communicated in a timely manner to those parties responsible for
taking corrective action, and to the management and the oversight board as
appropriate. [Outcome: 3]
NOTE3: This practice is implemented by performing practices of the COSO 2006
Reporting Deficiencies process with a specific focus on how enterprise governance

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 121/169

supports internal control over financial reporting and trusted business operation:
IFC.MO.RD.BP1 Report Information from Alternative Channels.
Management establishes an alternative channel for reporting deficiencies
sensitive in nature, such as illegal or improper acts.
IFC.MO.RD.BP2 Report Deficiencies to Various Levels in the
Organisation. Management establishes a practice where all financial
reporting and trusted business operation deficiencies regardless of materiality
are reported to the responsible manager and at least one level of
management above, both of whom are positioned to take corrective action.
IFC.MO.RD.BP3 Develop Guidelines for Reporting Deficiencies.
Management develops a list of control deficiencies that seriously threaten the
reliability of governance reporting, which if they occur are required to be
reported to senior management and the board.
Relationship The relationships between the Control Efficiency process and application practices,
Notes and other processes in COSO 2006 model, have been noted for each practice above.
This innovative concept of including “Application Areas” in a process assessment
model instantiates the idea of using already established processes with respect to a
particular application.
Sources COSO 2006: IFC.CE.OS Organizational Structure, IFC.CE.OB Oversight Board,
IFC.MO.RD Reporting Deficiencies
References Internal Control over Financial Reporting — Guidance for Smaller Public
Companies
Copyright © 2006 by The Committee of Sponsoring Organization, C/O
AICPA, Harborside Financial Center, 201 Plaza Three, Jersey City, NJ 07311
– 3881, USA. All rights reserved.

Work Products
Inputs Outputs
Whistle-blower Information [Outcome: 2] Organizational Structure [Outcome: 1]
Governance Policies and Procedures [Outcome: 2] Organizational Charts [Outcome: 1]
Management Reports [Outcome: 2] Job Descriptions [Outcomes: 1]
Audit Files [Outcome: 2] Audit Charter [Outcome: 2]
Periodic Staff Information [Outcome: 3] Oversight Agenda [Outcome: 2]
Audit Files [Outcome: 3] Board Members File [Outcome: 2]
Remediation Plans [Outcome: 3] Meeting Minutes [Outcome: 2]
Review Records [Outcome: 2]
Periodic Oversight Report [Outcome: 2]
Internal Control Deficiencies Records [Outcome:
3]
Governance Deficiencies and Resolutions
Reports [Outcome: 3]
Remediation Plans [Outcome: 3]

Note: Above performance indicators driven by the COSO 2006 model are applicable for assessing the
effectiveness of controls in relation to objectives of financial reporting and trusted business operation.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 122/169

However they should be considered as a starting point for judgment whether, given the application context,
they are contributing to the intended purpose of the process, not as a compulsory check-list of what every
organization must have.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 123/169

4.2 Governance of Sustainable Business Operation - Application Category

The Governance of Sustainable Business Operation application category has the focus on keeping business
operation economically effective.

Three processes relate to the Governance of Sustainable Business Operation application category:

• Competitive Operation – Ensuring market recognition of the business operation.

• Exploitable Operation – Organization realizes optimal value from business operation.

• Satisfactory Operation – Ensuring user/customer satisfaction based on agreed levels of business


operation.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 124/169

4.2.1 Competitive Operation

Process ID GOV. COP


Process Name Competitive Operation
Process Purpose The purpose of the Competitive Operation process is to ensure market recognition of
the business operation.
NOTE: The Competitive Operation process is a special application of the Enterprise
SPICE model in the context of the “Competitiveness” governance objective. Thus this
process is denoted an “Application Area”. The practices, called “application
practices”, are implemented using selected processes based on the Enterprise
SPICE model in the context of this special application. This facilitates the re-use of
the model without recreating processes that are already well established.
Process As a result of successful implementation of the Competitive Operation process:
Outcomes
1) Business goals and targets are systematically maintained.
2) Customers and other stakeholder needs and expectations are considered for
improvement of product or service features.
3) Effective proposal preparation practices are maintained.
Application BP1 Establish and maintain business goals and targets. The organization applies
practices practices to establish strategic enterprise direction and ensure the enterprise
achieves its goals and objectives. [Outcome: 1]
NOTE1: This practice is implemented by performing practices of the Enterprise
SPICE Enterprise Governance process with a specific focus on business
sustainability:
GVM.1.BP1: Establish and Maintain Strategic Vision. Establish, maintain,
and communicate a strategic vision that identifies long-term goals, values,
performance expectations, and core activities.
GVM.1.BP2: Establish and Maintain Policies. Establish, maintain and
communicate policies and directives.
GVM.1.BP3: Align to Achieve the Vision. Align the enterprise to operate
efficiently and consistently to achieve the vision. Establish leadership
systems and structures for decision making, empowerment, and conflict
resolution. Provide incentives for contributing to enterprise vision and
strategy.
GVM.1.BP4: Ensure sharing of common vision. Ensure that individuals in
the enterprise share a common culture, understand the common vision, and
are committed and empowered to perform their functions effectively.
GVM.1.BP5: Establish and Maintain Strategy. Establish and maintain the
enterprise strategic plans that identify business objectives to be achieved,
areas of business to be pursued and their interrelationships, and the
significant goals to be accomplished.
GVM.1.BP6: Formulate and align enterprise budgets. Formulate
enterprise budgets to ensure alignment with strategic goals. Ensure
congruency with action plans.
GVM.1.BP7: Develop and Deploy Action Plans. Establish, integrate, and
deploy tactical action plans to accomplish strategic objectives.
GVM.1.BP8: Review Performance. Review performance relative to goals
and changing needs across the enterprise.
GVM.1.BP9: Act on Results of Review. Translate performance review

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 125/169

findings into action.


GVM.1.BP10: Fulfill Public Responsibility. Address the impacts on society
of planned activities, products, services, and operations, considering
regulatory and legal requirements and risks associated with products,
services, and operations.
GVM.1.BP11: Inform employees regarding enterprise performance.
Inform employees regarding enterprise performance.

BP2 Evolve customer and other stakeholder needs and expectations. The
organization applies practices to elicit, analyze, clarify, and document evolving
customer and other stakeholder needs and expectations. [Outcome: 2]
NOTE2: This practice is implemented by performing practices of the Enterprise
SPICE Needs process with a specific focus on business sustainability:
LFC.1.BP1: Identify customers and stakeholders: Identify customers and
stakeholders.
LFC.1.BP2: Elicit needs: Elicit customer and other stakeholders’ needs,
expectations, and measures of effectiveness.
LFC.1.BP3: Analyze needs: Analyze needs and expectations in the context
of the intended operational environment.
LFC.1.BP4: Establish and maintain a statement of need: Establish and
maintain a statement of customer and other stakeholder needs and
expectations that is understood and agreed upon by the customer and other
stakeholders.
LFC.1.BP5: Communicate with customers: Communicate and interact with
customers and other stakeholders throughout the life cycle to assure a
common understanding of the status and disposition of needs, expectations,
and measures of effectiveness.
LFC.1.BP6: Determine customer satisfaction: Determine customer
satisfaction with products and services.

BP3 Keep proposal preparation practices effective. The organization applies


practices to identify, select and bid for acquirer requests for information, quotations
and proposals based on decisions that appropriately consider customer needs, risks,
organizational abilities and competitor capabilities. [Outcome: 3]
NOTE3: This practice is implemented by performing practices of the Enterprise
SPICE Tendering process with a specific focus on business sustainability:
GVM.7.BP1: Evaluate Organizational Skills, Services and Products.
Examine and document the organizational goals, service catalog, resumes
and existing products to determine what target markets to pursue or develop.
GVM.7.BP2: Establish Criteria and Risk Analysis for Submission.
Document the basis for determining a bid or no bid decision for responding to
requests for proposals.
GVM.7.BP3: Evaluate Acquirer Requests for Proposals and Inquiries.
Determine that proposed effort is in accordance with potential targets
identified in organizational goals. Determine if the requested task is in line
with existing organizational skills and talents or if these skills will have to be
acquired. Review overall requirements to determine if they are consistent,
concise and clearly defined. Document any questions that need to be posed
to the acquirer for clarification. Determine the probability that the organization
can be successful in this bid according to established criteria. Identify the

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 126/169

logical contenders for the proposal and their advantages.


GVM.7.BP4: Perform any Preliminary Research and Development,
Surveys or Trade Studies. Determine if the request requires investigation of
key product or service components that may prove to be high risk when
providing the requested product or service. Investigate trade studies or
surveys covering the expected work involved.
GVM.7.BP5: Make a Go/No Go Decision. Based on established criteria and
risk analysis, including preliminary research, decide whether to pursue or not
pursue a request for a proposal.
GVM.7.BP6: Identify Resources to Perform Proposed Work and Form
Proposal Team. Identify needed skills and form a qualified team to develop
the proposal, and to perform the proposed work.
GVM.7.BP7: Establish and Maintain Supplier/acquirer Communications
Interface. Assign an individual or organizational entity to establish a
communications interface with the potential acquirers. Review the acquirer’s
schedule of events and point of contact to assure adherence to proposal
preparation and delivery schedule.
GVM.7.BP8: Perform Estimation. Estimate costs and resources needed to
satisfy the request.
GVM.7.BP9: Prepare and Submit Proposal in Response to Acquirer
Request. Prepare proposal in accordance with guidelines in the acquirer’s
request document or request.
GVM.7.BP10: Negotiate and Confirm Agreement. Negotiate relevant
aspects of the agreement and formally confirm the agreement.
Relationship The relationships between the Competitive Operation process and application
Notes practices, and other processes in Enterprise SPICE model, have been noted for each
practice above. This innovative concept of including “Application Areas” in a process
assessment model instantiates the idea of using already established processes with
respect to a particular application.
Sources Enterprise SPICE: GVM.1 Enterprise Governance, LFC.1 Needs, GVM.7 Tendering
References Enterprise SPICE® - An Integrated Model for Enterprise-wide Assessment and
Improvement
Technical Report – Issue 1 September 2010, Copyright © The SPICE User
Group 2010.

Note1: Above base practices referred by the Enterprise SPICE model are applicable for assessing
governance effectiveness related to the sustainability objectives of the business operation. However they
should be considered as a starting point for judgment whether, given the application context, they are
contributing to the intended purpose of the process, not as a compulsory check-list of what every
organization must have.

Note2: The Enterprise SPICE model does not contain the capability dimension of the Process Assessment
Model beyond capability level 1. As not targeting higher process capability levels during this special
application, this material does not include the list of specific work products as referred by the process
performance indicators of the Enterprise SPICE processes. Therefore the judgment of governance
effectiveness related to the sustainability objectives of the business operation is based on assessment of
organization’ governance practices by considering the listed base practices.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 127/169

4.2.2 Exploitable Operation

Process ID GOV.EOP
Process Name Exploitable Operation
Process Purpose The purpose of the Exploitable Operation process is to ensure that organization
realizes optimal value from business operation.
NOTE: The Exploitable Operation process is a special application of the Enterprise
SPICE model in the context of the “Exploitability” governance objective. Thus this
process is denoted an “Application Area”. The practices, called “application
practices”, are implemented using selected processes based on the Enterprise
SPICE model in the context of this special application. This facilitates the re-use of
the model without recreating processes that are already well established.
Process As a result of successful implementation of the Exploitable Operation process:
Outcomes
1) Investments for business operation needs and business potentials are performed
deliberately.
2) Project management practices are applied for business operation.
3) Quality management practices are applied for business operation.
Application BP1 Manage investments supporting business goals and targets. The
practices organization applies practices to ensure that organization realize optimal value from
strategically aligned business investments at an affordable cost with a known and
acceptable level of risk. [Outcome: 1]
NOTE1: This practice is implemented by performing practices of the Enterprise
SPICE Investment Management process with a specific focus on business
sustainability:
GVM.2.BP1: Establish Criteria. Establish and maintain criteria for selecting
and evaluating potential investments.
GVM.2.BP2: Identify Investment Proposals. Collect business cases,
identifying and describing investment proposals.
GVM.2.BP3: Categorize Proposals. Define investment categories,
categorization criteria, and categorize proposals.
GVM.2.BP4: Prioritize and Evaluate Investment Proposals. Evaluate and
prioritize investment proposals.
GVM.2.BP5: Establish and Maintain the Investment Portfolio. Select
proposals to be included in the investment portfolio. Establish and maintain
the investment portfolio.
GVM.2.BP6: Identify and Allocate Resources. Allocate resources to
execute selected investments. Reallocate resources from deactivated and
terminated investments.
GVM.2.BP7: Review/evaluate Performance. Review and evaluate ongoing
investments versus stated criteria to determine whether to continue with, add
to, or terminate specific investments.
GVM.2.BP8: Adjust Investment Portfolio. Adjust the investment portfolio in
response to actual portfolio performance.
GVM.2.BP9: Communicate Portfolio Adjustment. Communicate results of
portfolio adjustment to relevant stakeholders.
GVM.2.BP10: Monitor Changes. Monitor changes in strategy, risk levels,
and resource constraints to assure appropriate alignment.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 128/169

BP2 Manage business project activities and resources. The management apply
practices to ensure the business projects achieve their objectives within given
resource constraints by initiating, planning, executing, monitoring, controlling and
closing the project activities and resources. [Outcome: 2]
NOTE2: This practice is implemented by performing practices of the Enterprise
SPICE Project Management process with a specific focus on business sustainability:
GVM.8.BP1: Define Project Objectives, Scope, and Outputs. Define
project objectives, scope, and the work products and services that are to be
provided by the project.
GVM.8.BP2: Define the Life-Cycle Approach and Activities. Define the
life-cycle approach that will be used and define and sequence the activities
needed to achieve project outputs.
GVM.8.BP3: Define Stakeholders. Identify stakeholders and interfaces
between project elements and with other project and organizational units.
GVM.8.BP4: Estimate Planning Parameters. Estimate and document the
work product and task planning parameters that provide a basis for resource
estimates.
GVM.8.BP5: Estimate Project Resource Requirements. Estimate the
project effort, cost, schedule and other resource requirements.
GVM.8.BP6: Establish Schedules. Develop schedules for the project.
GVM.8.BP7: Establish Budget. Develop a budget for the project.
GVM.8.BP8: Plan the Quality. Identify the quality requirements and/or
standards for the project or product and document how the project will
demonstrate compliance.
GVM.8.BP9: Develop the Human Resource Plan. Identify the experience,
knowledge and skill requirements for the project and apply them to the
selection of individuals and teams. Identify the specific individuals and groups
contributing to, and impacted by, the project, allocate their specific
responsibilities, and ensure that commitments are understood, accepted,
funded and achievable.
GVM.8.BP10: Plan Communications. Determine project stakeholder
information needs and define a communication approach.
GVM.8.BP11: Plan Risks. Identify and analyze risks which may affect the
project. Develop alternatives and actions in order to enhance opportunities
and to reduce threats to the project objectives.
GVM.8.BP12: Plan Procurements. Plan and document project purchasing
decisions.
GVM.8.BP13: Establish and Maintain Plans. Establish and maintain a
complete set of plans for providing the products and services throughout the
project life cycle.
GVM.8.BP14: Establish Commitment. Establish and maintain commitment
of affected groups and individuals to project objectives and plans and
commitment of resources as identified in the plan.
GVM.8.BP15: Acquire, Develop and Manage Project Team. Identify
individuals or teams that will be assigned the resources and responsibilities
for meeting project objectives. Improve the competencies of the team. Track
team member performance, provide feedback, resolve issues and manage
changes to optimize project performance.
GVM.8.BP16: Direct and Manage Project Execution. Perform the work
defined in the project plan to achieve the project’s objectives.
GVM.8.BP17: Distribute Information. Make relevant or established

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 129/169

information available to project stakeholders as planned.


GVM.8.BP18: Manage Stakeholder Expectations. Communicate and work
with stakeholders to meet their needs and address issues as they occur.
GVM.8.BP19: Monitor Project Performance. Monitor and track project
activities and results against plans and baseline.
GVM.8.BP20: Review and Analyze Project Performance. Conduct formal
and informal reviews of project performance and analyze variances from the
plans.
GVM.8.BP21: Take Corrective Action. Take corrective actions to address
problems.
GVM.8.BP22: Close Project. Close the project formally using appropriate
organizational mechanisms and update organizational process assets.

BP3 Provide quality management and assurance for business operation. The
organization applies practices to assure the quality of the product or service and of
the processes used, and provide management with appropriate visibility into all
relevant quality aspects. [Outcome: 3]
NOTE3: This practice is implemented by performing practices of the Enterprise
SPICE Quality Assurance and Management process with a specific focus on
business sustainability:
SUP.3.BP1: Establish a Quality Management System. Establish,
document, implement, and maintain a quality management system.
SUP.3.BP2: Monitor Process Compliance. Objectively monitor compliance
of performed activities with the established processes.
SUP.3.BP3: Monitor Product and Service Quality. Objectively compare,
measure and evaluate work products and services against the requirements
and standards that define them.
SUP.3.BP4: Monitor Noncompliance Issues. Monitor and track
noncompliance issues and support their resolution via escalation to senior
management if necessary.
SUP.3.BP5: Record and Report Results. Record and report the results of
quality assurance activities and customer satisfaction data to applicable
stakeholders.
SUP.3.BP6: Analyze Quality. Analyze quality records and measurements to
detect the need for corrective action and develop recommendations for
quality improvement or corrective and preventive actions.
SUP.3.BP7: Initiate Quality Improvement. Initiate activities that address
identified quality issues or quality improvement opportunities.
SUP.3.BP8: Monitor and Evaluate the Effect of Changes. Monitor the
status of quality improvements on products and services and evaluate the
effect of changes after they have been implemented.
Relationship The relationships between the Exploitable Operation process and application
Notes practices, and other processes in Enterprise SPICE model, have been noted for each
practice above. This innovative concept of including “Application Areas” in a process
assessment model instantiates the idea of using already established processes with
respect to a particular application.
Sources Enterprise SPICE: GVM.2 Investment Management, GVM.8 Project Management,
SUP.3 Quality Assurance and Management
References Enterprise SPICE® - An Integrated Model for Enterprise-wide Assessment and

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 130/169

Improvement
Technical Report – Issue 1 September 2010, Copyright © The SPICE User
Group 2010.

Note1: Above base practices referred by the Enterprise SPICE model are applicable for assessing
governance effectiveness related to the sustainability objectives of the business operation. However they
should be considered as a starting point for judgment whether, given the application context, they are
contributing to the intended purpose of the process, not as a compulsory check-list of what every
organization must have.

Note2: The Enterprise SPICE model does not contain the capability dimension of the Process Assessment
Model beyond capability level 1. As not targeting higher process capability levels during this special
application, this material does not include the list of specific work products as referred by the process
performance indicators of the Enterprise SPICE processes. Therefore the judgment of governance
effectiveness related to the sustainability objectives of the business operation is based on assessment of
organization’ governance practices by considering the listed base practices.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 131/169

4.2.3 Satisfactory Operation

Process ID GOV.SOP
Process Name Satisfactory Operation
Process Purpose The purpose of the Satisfactory Operation process is to ensure user/customer
satisfaction based on agreed levels of business operation.
NOTE: The Satisfactory Operation process is a special application of the Enterprise
SPICE model in the context of the “Satisfaction” governance objective. Thus this
process is denoted an “Application Area”. The practices, called “application
practices”, are implemented using selected processes based on the Enterprise
SPICE model in the context of this special application. This facilitates the re-use of
the model without recreating processes that are already well established.
Process As a result of successful implementation of the Satisfactory Operation process:
Outcomes
1) Requirements are established and maintained based on user/customer needs and
expectations.
2) Business relationship management is effective.
3) Business operation supports its user entities by achievement of agreed service
level requirements.
Application BP1 Establish and maintain requirements that meet customer needs and
practices expectations. The organization applies practices to develop a detailed and precise
set of requirements that meet user/customer needs and expectations and manage
those requirements throughout the life cycle. [Outcome: 1]
NOTE1: This practice is implemented by performing practices of the Enterprise
SPICE Requirements process with a specific focus on business sustainability:
LFC.2.BP1: Identify Requirements. Identify all types of requirements
applicable to customer needs and expectations.
LFC.2.BP2: Derive Requirements. Derive requirements that may be
identified as necessary implications of the identified requirements.
LFC.2.BP3: Analyze Requirements. Analyze requirements to ensure that
they satisfy established quality criteria, including unambiguity, completeness,
traceability, feasibility, and verifiability.
LFC.2.BP4: Baseline Requirements. Record, approve, baseline, and place
under change control all requirements.
LFC.2.BP5: Analyze Requirements Risks. Document and analyze risks
associated with the requirements.
LFC.2.BP6: Manage Requirements Changes. Analyze all requirements
change requests for impact on the product or service and, upon approval,
incorporate the approved changes into the requirements baseline.
LFC.2.BP7: Ensure and Maintain Requirements Traceability across the
Life Cycle. Maintain traceability among requirements and between
requirements and plans, work products, and activities initiating corrective
action if inconsistencies are identified.

BP2 Manage relationship among business stakeholders. The organization


applies practices to establish and maintain a mutually satisfying relationship between
the product or service supplier and the business partner based on understanding the
business partner and its business drivers. [Outcome: 2]
NOTE2: This practice is implemented by performing practices of the Enterprise

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 132/169

SPICE Business Relationship Management process with a specific focus on business


sustainability:
GVM.5.BP1: Develop Relationships. Develop and document contacts and
relationships with the business, customers and stakeholders.
GVM.5BP2: Establish Interactive Communication Methodologies and
Structures with Stakeholders and Partners. Name an individual or
individuals who are responsible for collaboratively managing customer
satisfaction and the whole Business Relationship Management process.
GVM.5BP3: Identify Relationship Attributes. Identify and manage cultural,
market, loyalty and beneficiaries attributes.
GVM.5.BP4: Identify Value Creation Opportunities. Proactively identify
value creation opportunities and communicate them to the customer.
GVM.5.BP5: Manage Complaints and Compliments. Log and manage all
complaints and compliments by analyzing existing information, obtaining
feedback from customers and performing service reviews.
GVM.5.BP6: Create Service Level Agreements. Create Service Level
Agreements between the business owner and the product/service supplier.
GVM.5.BP7: Establish a Service Catalog. Establish and maintain a service
catalog for communicating with the business.

BP3 Operate according to agreed service levels. The organization applies


practices to operate the product or service at agreed service levels and support its
users/customers. [Outcome: 3]
NOTE3: This practice is implemented by performing practices of the Enterprise
SPICE Operation and Support process with a specific focus on business
sustainability:
LFC.8.BP1: Operate the Product or Service. Operate the product or
service in its intended environment according to agreed service levels.
LFC.8.BP2: Establish Methods. Establish methods for monitoring and
sustaining required product or service levels.
LFC.8.BP3: Monitor and Evaluate Capacity, Service, and Performance.
Monitor and evaluate capacity, service, and performance of the product or
service.
LFC.8.BP4: Confirm Availability of Resources. Confirm availability of
required resources (e.g., personnel, parts) to ensure service levels can be
sustained.
LFC.8.BP5: Perform Corrective and/or Preventive Maintenance. Perform
corrective and/or preventive maintenance by replacing or servicing product or
service elements prior to failure.
LFC.8.BP6: Analyze Failures. Perform failure identification and analysis
activities when problems or interruptions occur in the product or delivered
service.
LFC.8.BP7: Take or Initiate Corrective Action. Take corrective action when
appropriate (e.g., defective part, human error), or initiate corrective action for
product or service modification.
LFC.8.BP8: Provide Customer Support. Answer customer and user
questions and help resolve problems they encounter.
Relationship The relationships between the Satisfactory Operation process and application
Notes practices, and other processes in Enterprise SPICE model, have been noted for each
practice above. This innovative concept of including “Application Areas” in a process
assessment model instantiates the idea of using already established processes with

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 133/169

respect to a particular application.


Sources Enterprise SPICE: LFC.2 Requirements, GVM.5 Business Relationship
Management, LFC.8 Operation and Support
References Enterprise SPICE® - An Integrated Model for Enterprise-wide Assessment and
Improvement
Technical Report – Issue 1 September 2010, Copyright © The SPICE User
Group 2010.

Note1: Above base practices referred by the Enterprise SPICE model are applicable for assessing
governance effectiveness related to the sustainability objectives of the business operation. However they
should be considered as a starting point for judgment whether, given the application context, they are
contributing to the intended purpose of the process, not as a compulsory check-list of what every
organization must have.

Note2: The Enterprise SPICE model does not contain the capability dimension of the Process Assessment
Model beyond capability level 1. As not targeting higher process capability levels during this special
application, this material does not include the list of specific work products as referred by the process
performance indicators of the Enterprise SPICE processes. Therefore the judgment of governance
effectiveness related to the sustainability objectives of the business operation is based on assessment of
organization’ governance practices by considering the listed base practices.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 134/169

4.3 Linking Governance Processes to Sustainable Value Creation

Governance capability issues have come into the view of the management as the huge cost of regulatory
compliance activities request consideration of sustainability and added business value of such efforts. This
challenge has been answered by utilizing the ISO/IEC 15504 standard based Governance Capability
Assessment (Governance SPICE) concept applicable for the executive managers, the boards of directors,
the audit committees, the internal and external auditors and the supervisory bodies for assessing the
effectiveness of internal controls even in different business units and activities, IT management and financial
reporting processes.

Major governance scandals, independently from the recent global financial and economic crisis, call the
attention that not only the basic business operations (production, sales, supply chain, etc.) need to be
assessed, audited or certified to the conformance with specific standards, but all the governance related
processes. The cases of the most newsworthy scandals showed that even those big multinational
companies, which are committed to quality and process improvement issues, can fail to avoid governance
breakdowns such as fraudulent financial reporting.

In these circumstances the term of “trusted business” has got additional attention by the customers in any
type of business relationship. Beyond the traditional marketing methods, the product and service providers
need to distinguish themselves from their market competitors not just with higher quality or excellence level,
faster market response or better pricing, but they are also enforced to present themselves as reliable and
sustainable business partners. Customers respect those business partners in long term relationship, whose
corporate culture is at similar or even at higher level than theirs.

Regulatory requirements like the Sarbanes-Oxley Act for US SEC registrants and their affiliates (all over the
world), the Basel framework, the Company Law in the EU, the European and national directives for
governmental and public sector organizations, etc. require not just the implementation of risk management
and internal control systems based on internationally recognized frameworks, but also the periodic disclosure
of effectiveness conclusion performed by the executive management. However some of these regulations
are still limited to financial reporting, the global crisis showed that wider focus of risk management and
internal controls has real business value. During the last decades many-many thousands of such periodic
assessments were performed worldwide in industry, financial and governmental sectors and the regulators
are keen to further develop mandatory rules and guidelines increasing stakeholder’s benefit from
disclosures.

The global crisis also reminds that many former periodic assessments concluding positive opinion on
effectiveness of internal controls were failed at those companies, where the insularly used economic models
for risk assessment were not aligned with the time horizon of the strategic business objectives. Accountability
of executive management and oversight boards should be established and supported by using integrated
assessment models applicable for both operational and financial processes. Those assessment models
which can cover the most activity areas relevant for strategic objectives have added value to line managers,
executive management, internal and external auditors and oversight bodies, as they help to optimize
monitoring efforts of different operations based on a common measurement model of achieving objectives.

Using the Governance Model for Trusted Businesses provides ready to use structure for implementing
selected or all elements of the recognized control frameworks and generic enterprise models. Regulatory or
voluntary compliance requirements could be looked through clear business driven governance objectives
helping better understanding and meaningful design and operation by enterprise management. Besides the
less implementation efforts, this structure unburdens the internal and external audit activities in concluding
opinion about the fulfilment of compliance requirements.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 135/169

Annex A: Sample Metrics of Application Practices for Setting Risk


Criteria

A1. Sample metrics for application practices supporting Satisfaction governance objective
Table 13: Application Practices of Satisfactory Operation with possible metrics

Application Practices for Satisfaction Usefulness Efficiency related


Governance Objective related metrics metrics

Establish and maintain requirements that meet Coverage of service Coverage of approved
customer needs and expectations. The elements/products by capacity allocation for
organization applies practices to develop a detailed approved requirement infrastructure, skills,
and precise set of requirements that meet specification (e.g. only material and human
user/customer needs and expectations and manage 80% of service resources (e.g. only
those requirements throughout the life cycle. elements have 75% of necessary
approved requirement capacity allocation is
specification) admitted by the client)
LFC.2.BP1: Identify Requirements. Identify Ratio of non-standard Ratio of flexible capacity
all types of requirements applicable to requirements (e.g. allocation (e.g. ad hoc
customer needs and expectations. 40% of requirements effort hours)
are related to ad hoc
requests)
LFC.2.BP2: Derive Requirements. Derive Ratio of derived Ratio of derived capacity
requirements that may be identified as requirements (e.g. allocation for the
necessary implications of the identified 40% of requirements contracting period (e.g.
requirements. are related to client supporting IT capacity
specific reporting for specific client needs)
formats)
LFC.2.BP3: Analyze Requirements. Ratio of analysed Ratio of analysed
Analyze requirements to ensure that they requirements (e.g. only capacity allocation (e.g.
satisfy established quality criteria, including 30% of requirements 25% of resources
unambiguity, completeness, traceability, have pre-established allocated without
feasibility, and verifiability. criteria) analysis)
LFC.2.BP4: Baseline Requirements. Ratio of requirements Ratio of non-controlled
Record, approve, baseline, and place under under change control changes in capacity
change control all requirements. (e.g. 80% of allocation requirements
requirements are not (e.g. 40% of changes in
followed resource allocation are
systematically) not followed)
LFC.2.BP5: Analyze Requirements Risks. Frequency of formal Coverage of capacity
Document and analyze risks associated with risk assessment of requirements by formal
the requirements. requirements (e.g. no risk assessment (e.g.
documented risk only infrastructure
assessment for the capacity requirements
requirements) are considered)
LFC.2.BP6: Manage Requirements Ratio of analysed and Ratio of approved
Changes. Analyze all requirements change approved requirement changes in capacity
requests for impact on the product or service changes (e.g. 80% of allocation requirements
and, upon approval, incorporate the requirement changes (e.g. 40% of changes in

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 136/169

Application Practices for Satisfaction Usefulness Efficiency related


Governance Objective related metrics metrics

approved changes into the requirements are not approved internal control resource
baseline. formally) allocation are not
approved formally)
LFC.2.BP7: Ensure and Maintain Coverage of Coverage of capacity
Requirements Traceability across the Life traceability during allocation traceability
Cycle. Maintain traceability among operation (30% of during operation (e.g.
requirements and between requirements and requirements are not only human capacity
plans, work products, and activities initiating identical during allocation requirements
corrective action if inconsistencies are operation) are traceable)
identified.
Manage relationship among business Coverage of Allocated time and
stakeholders. The organization applies practices to relationship types (e.g. resources per
establish and maintain a mutually satisfying contracting, marketing, relationship types (e.g.
relationship between the product or service supplier operational meeting frequency and
and the business partner based on understanding the supervision and day- durations for each
business partner and its business drivers. to-day contact levels) contact levels)
GVM.5.BP1: Develop Relationships. Number and types of Availability of contact
Develop and document contacts and contacts (e.g. 1-1 types (e.g. during and
relationships with the business, customers dedicated contacts for over business hours for
and stakeholders. each level) each type)
GVM.5.BP2: Establish Interactive Number of dedicated Allocated resources for
Communication Methodologies and contact positions (e.g. contact positions (e.g. 1
Structures with Stakeholders and one dedicated person hour per month for
Partners. Name an individual or individuals for regular customer discussing satisfaction
who are responsible for collaboratively satisfaction surveys) survey results with
managing customer satisfaction and the customer)
whole Business Relationship Management
process.
GVM.5.BP3: Identify Relationship Number of relationship Coverage of relationship
Attributes. Identify and manage cultural, attributes (e.g. attributes by allocated
market, loyalty and beneficiaries attributes. position, skills, resources (e.g. English
communication speaking in
language, formality, communication of day-
etc.) to-day operation)
GVM.5.BP4: Identify Value Creation Number of value Allocated resources for
Opportunities. Proactively identify value creation opportunities communicating value
creation opportunities and communicate per contracting period creation opportunities
them to the customer. (e.g. providing regular (e.g. number of working
newsletter and hours per pay-off period
consultancy on for advising client)
regulatory obligations
or changes, new
product or service
features, etc.)
GVM.5.BP5: Manage Complaints and Number and ratio of Allocated resources for
Compliments. Log and manage all managed complaints managing complaints
complaints and compliments by analyzing and compliments (e.g. and compliments (e.g.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 137/169

Application Practices for Satisfaction Usefulness Efficiency related


Governance Objective related metrics metrics

existing information, obtaining feedback from only 4 from 5 operational line


customers and performing service reviews. complaints of the pay- manager spends 1 hour
off period are per pay-off period to
managed) review complaints and
compliments)
GVM.5.BP6: Create Service Level Coverage of service Allocated resources for
Agreements. Create Service Level elements (e.g. SLA creating and maintaining
Agreements between the business owner might not cover ad hoc SLA (e.g. 1 working day
and the product/service supplier. consultancy on upon contracting or
regulatory changes) significant modification
and 1 hour review per
pay-off period)
GVM.5.BP7: Establish a Service Catalog. Ratio of standard Allocated resources per
Establish and maintain a service catalog for service elements (e.g. pay-off period (1
communicating with the business. 90% of service working hour check for
elements are update requests in each
standardized) month)
Operate according to agreed service levels. The Satisfaction rate per Deviation (range) from
organization applies practices to operate the product pay-off period (e.g. planned resources (e.g.
or service at agreed service levels and support its 100% coverage of 15% staff overwork)
users/customers. agreed service level)
LFC.8.BP1: Operate the Product or Operational outcome Operational resource
Service. Operate the product or service in its metrics (e.g. number usage metrics (e.g.
intended environment according to agreed of transactions per working hours,
service levels. month) processing time, used
materials or external
services)
LFC.8.BP2: Establish Methods. Establish Coverage of service Coverage of resource
methods for monitoring and sustaining elements (e.g. non types (e.g.
required product or service levels. standardized service administrative effort
elements are not supporting business line
covered) management is not
included)
LFC.8.BP3: Monitor and Evaluate Frequency of Resource usage for
Capacity, Service, and Performance. evaluation (e.g. only monitoring and
Monitor and evaluate capacity, service, and once per pay-off evaluation (e.g.
performance of the product or service. period) management review
effort)
LFC.8.BP4: Confirm Availability of Coverage of service Coverage of resource
Resources. Confirm availability of required elements (e.g. only for types (e.g. no
resources (e.g., personnel, parts) to ensure standard service confirmation for
service levels can be sustained. elements) advisory or
administrative
resources)
LFC.8.BP5: Perform Corrective and/or Number of replacing Additional effort and
Preventive Maintenance. Perform corrective product or service resources used (e.g.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 138/169

Application Practices for Satisfaction Usefulness Efficiency related


Governance Objective related metrics metrics

and/or preventive maintenance by replacing elements prior to additional processing


or servicing product or service elements prior failure (e.g. time and working hours
to failure. repeated/corrected for repeating/correcting
processing outputs) service process)
LFC.8.BP6: Analyze Failures. Perform Failure root detection Effort and resource
failure identification and analysis activities rate per service usage (e.g. 10 working
when problems or interruptions occur in the elements (e.g. 99% for hours for detecting new
product or delivered service. data processing hardware or software
errors) incompatibility
problems)
LFC.8.BP7: Take or Initiate Corrective Number of corrective Resource used for
Action. Take corrective action when actions per service corrective actions during
appropriate (e.g., defective part, human elements during pay- pay-off period (e.g.
error), or initiate corrective action for product off period (e.g. 1 working time for
or service modification. software update due to software maintenance
regulatory changes) and deployment)
LFC.8.BP8: Provide Customer Support. Ratio of answered Resource used to
Answer customer and user questions and questions and provide customer
help resolve problems they encounter. resolved problems support (e.g. used help-
(e.g. 100% of desk working time)
questions have been
answered, 10%
problems have
remained unsolved
during pay-off period)

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 139/169

A2. Sample metrics for application practices supporting Exploitability governance


objective:
Table 14: Application Practices of Exploitable Operation with possible metrics

Application Practices for Exploitability Usefulness Efficiency related


Governance Objective related metrics metrics

Manage investments supporting business goals Income or savings Return of investment per
and targets. The organization applies practices to generated by investment types (e.g.
ensure that organization realize optimal value from investment activities return on cash savings,
strategically aligned business investments at an made with surplus shares, securities,
affordable cost with a known and acceptable level of cash (e.g. earnings on assets, etc. or projects
risk. accounts, shares, being out of the usual
securities, assets, etc. line of business)
or benefits from other
projects being out of
the usual line of
business)
GVM.2.BP1: Establish Criteria. Establish Coverage of Coverage of investment
and maintain criteria for selecting and investment types by types by ROI targets
evaluating potential investments. income/savings targets (e.g. criteria for interest
(e.g. criteria for rates, return on shares,
accounts, shares, securities, assets,
securities, assets, projects, etc.)
projects, etc.)
GVM.2.BP2: Identify Investment Coverage of Coverage of investment
Proposals. Collect business cases, investment types by types by business case
identifying and describing investment comparable proposals evaluations (e.g.
proposals. (e.g. options of industry benchmark for
accounts, shares, interest rate, return on
securities, assets, shares, securities,
projects, etc.) assets, projects, etc.)
GVM.2.BP3: Categorize Proposals. Define Coverage of Coverage of investment
investment categories, categorization criteria, investment types by types by formal
and categorize proposals. categorization criteria categorization (e.g.
(e.g. categorization number of used
criteria for accounts, categories for interest
shares, securities, rate, return on shares,
assets, projects, etc.) securities, assets,
projects, etc.)
GVM.2.BP4: Prioritize and Evaluate Coverage of Coverage of investment
Investment Proposals. Evaluate and investment types by types by formal
prioritize investment proposals. prioritization (e.g. evaluation (e.g.
frequency of frequency for evaluating
prioritization for options for interest rate,
accounts, shares, return on shares,
securities, assets, securities, assets,
projects, etc.) projects, etc.)

GVM.2.BP5: Establish and Maintain the Coverage of Coverage of investment

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 140/169

Application Practices for Exploitability Usefulness Efficiency related


Governance Objective related metrics metrics

Investment Portfolio. Select proposals to be investment types by types by portfolio


included in the investment portfolio. Establish investment portfolio maintenance (e.g.
and maintain the investment portfolio. (e.g. coverage of frequency of portfolio
accounts, shares, maintenance per
securities, assets, investment types)
projects, etc.)
GVM.2.BP6: Identify and Allocate Coverage of Unexpected expenses
Resources. Allocate resources to execute investment types by or losses due to
selected investments. Reallocate resources resource allocation resource allocation or
from deactivated and terminated and reallocation (e.g. reallocation (e.g.
investments. frequency of allocating resource allocation
or reallocating expenses or losses per
resources per investment types)
investment types)
GVM.2.BP7: Review/evaluate Coverage of Unexpected costs of
Performance. Review and evaluate ongoing investment types by evaluations (e.g.
investments versus stated criteria to formal performance extraordinary consulting
determine whether to continue with, add to, evaluations (e.g. or audit fees per
or terminate specific investments. frequency of investment types)
evaluation per
investment types)
GVM.2.BP8: Adjust Investment Portfolio. Coverage of Unexpected expenses
Adjust the investment portfolio in response to investment types by or losses due to portfolio
actual portfolio performance. portfolio adjustment adjustment (e.g.
(e.g. frequency of portfolio adjustment
portfolio adjustment expenses or losses per
per investment types) investment types)
GVM.2.BP9: Communicate Portfolio Coverage of Unexpected costs due
Adjustment. Communicate results of investment types by to communication of
portfolio adjustment to relevant stakeholders. communicating portfolio adjustments
portfolio adjustments (e.g. extraordinary costs
(e.g. frequency of of portfolio adjustment
portfolio adjustment communication per
communication per investment types)
investment types)
GVM.2.BP10: Monitor Changes. Monitor Coverage of Unexpected costs of
changes in strategy, risk levels, and resource investment types by monitoring (e.g. extra
constraints to assure appropriate alignment. monitoring (e.g. monitoring efforts and
number of monitoring costs per investment
indicators per types)
investment types)
Manage business project activities and Coverage of business Coverage of business
resources. The management apply practices to unit level profitability unit level resource
ensure the business projects achieve their objectives goals by managed allocation by managed
within given resource constraints by initiating, business activities/ business
planning, executing, monitoring, controlling and projects (e.g. rate of activities/projects (e.g.
closing the project activities and resources. business unit rate of resources
operating profit coming allocated to business

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 141/169

Application Practices for Exploitability Usefulness Efficiency related


Governance Objective related metrics metrics

from activities without operation without project


project management management controls)
controls)
GVM.8.BP1: Define Project Objectives, Coverage of business Coverage of business
Scope, and Outputs. Define project unit level profitability unit level resource
objectives, scope, and the work products and goals by all projects’ allocation by all projects’
services that are to be provided by the objectives (e.g. rate of objectives (e.g. rate of
project. organizational goals staff resources allocated
not supported by without mapping to
project objectives) project objectives)
GVM.8.BP2: Define the Life-Cycle Coverage of business Coverage of business
Approach and Activities. Define the life- unit level profitability unit level resource
cycle approach that will be used and define goals by all projects’ allocation by all projects’
and sequence the activities needed to life-cycle life-cycle considerations
achieve project outputs. considerations (e.g. (e.g. year-end closing
year-end closing project resources are in
project are not conflict with parallel
considered) monthly services)
GVM.8.BP3: Define Stakeholders. Identify Coverage of business Coverage of business
stakeholders and interfaces between project unit level profitability unit level resource
elements and with other project and goals by all projects’ allocation by considering
organizational units. stakeholder all projects’ stakeholders
identification (e.g. IT needs (e.g. stakeholders
support is not involvement on other
identified as projects are not
stakeholder) considered)
GVM.8.BP4: Estimate Planning Coverage of business Coverage of business
Parameters. Estimate and document the unit level profitability unit level resource
work product and task planning parameters goals by all projects’ allocation by considering
that provide a basis for resource estimates. planning parameters all projects’ planning
(e.g. parameters of parameters (e.g.
work products and resource estimates are
work flows are only partially used)
mapped to
organizational
profitability goals)
GVM.8.BP5: Estimate Project Resource Coverage of business Coverage of business
Requirements. Estimate the project effort, unit level profitability unit level resource
cost, schedule and other resource goals by all projects’ allocation by all projects’
requirements. resource requirements resource requirements
(e.g. profitability goals (e.g. rate of allocated
are considered based resources per running
on estimating resource projects’ needs)
requirements by
projects)
GVM.8.BP6: Establish Schedules. Develop Coverage of business Coverage of business
schedules for the project. unit level profitability unit level resource
goals by all projects’ allocation by all projects’

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 142/169

Application Practices for Exploitability Usefulness Efficiency related


Governance Objective related metrics metrics

schedules (e.g. schedules (e.g. rate of


profitability goals and available resources
schedule of all according to all projects’
projects’ results are schedules)
aligned)
GVM.8.BP7: Establish Budget. Develop a Coverage of business Coverage of business
budget for the project. unit level profitability unit level resource
goals by all projects’ allocation by all projects’
budgets (e.g. budgets (e.g. rate of
profitability goals and available resources
project budgets are according to project
aligned) budgets)
GVM.8.BP8: Plan the Quality. Identify the Coverage of business Coverage of business
quality requirements and/or standards for the unit level profitability unit level resource
project or product and document how the goals by all projects’ allocation by all projects’
project will demonstrate compliance. quality/compliance quality/compliance
requirements (e.g. requirements (e.g. rate
profitability goals and of available qualified
all projects’ resources according to
quality/compliance all projects’
requirements are quality/compliance
aligned) requirements)
GVM.8.BP9: Develop the Human Resource Coverage of business Coverage of business
Plan. Identify the experience, knowledge and unit level profitability unit level resource
skill requirements for the project and apply goals by all projects’ allocation by all projects’
them to the selection of individuals and human resource human resource
teams. Identify the specific individuals and requirements (e.g. requirements (e.g. rate
groups contributing to, and impacted by, the profitability goals and of available skills and
project, allocate their specific responsibilities, all projects’ human competencies according
and ensure that commitments are resources to all projects’
understood, accepted, funded and requirements are requirements)
achievable. aligned)
GVM.8.BP10: Plan Communications. Coverage of business Coverage of business
Determine project stakeholder information unit level profitability unit level resource
needs and define a communication goals by all projects’ allocation by all projects’
approach. communication communication
requirements (e.g. requirements (e.g. rate
profitability goals and of available
all projects’ communication
communication resources according to
requirements are all projects’
aligned) requirements)

GVM.8.BP11: Plan Risks. Identify and Coverage of business Coverage of business


analyze risks which may affect the project. unit level profitability unit level resource
Develop alternatives and actions in order to goals by all projects’ allocation by all projects’
enhance opportunities and to reduce threats risk considerations risk considerations (e.g.
to the project objectives. (e.g. profitability goals rate of available risk

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 143/169

Application Practices for Exploitability Usefulness Efficiency related


Governance Objective related metrics metrics

and all projects’ risk management resources


considerations are according to all projects’
aligned) needs)
GVM.8.BP12: Plan Procurements. Plan and Coverage of business Coverage of business
document project purchasing decisions. unit level profitability unit level resource
goals by all projects’ allocation by all projects’
procurements needs procurement needs (e.g.
(e.g. profitability goals rate of available
and all projects’ purchasing resources
procurement needs according to all projects’
are aligned) needs)
GVM.8.BP13: Establish and Maintain Coverage of business Coverage of business
Plans. Establish and maintain a complete set unit level profitability unit level resource
of plans for providing the products and goals by all projects’ allocation by all projects’
services throughout the project life cycle. plans (e.g. profitability plans (e.g. rate of
goals and all projects’ available resources
plans are aligned) according to all projects’
needs)
GVM.8.BP14: Establish Commitment. Coverage of business Coverage of business
Establish and maintain commitment of unit level profitability unit level resource
affected groups and individuals to project goals by all projects’ allocation by all projects’
objectives and plans and commitment of commitment commitment scopes
resources as identified in the plan. statements (e.g. (e.g. rate of resources
profitability goals and under scope of all
all projects’ projects’ commitment
commitment statements)
statements are
aligned)
GVM.8.BP15: Acquire, Develop and Coverage of business Coverage of business
Manage Project Team. Identify individuals or unit level profitability unit level resource
teams that will be assigned the resources goals by all projects’ allocation by all projects’
and responsibilities for meeting project authorisations and authorisations and
objectives. Improve the competencies of the responsibilities (e.g. responsibilities (e.g. rate
team. Track team member performance, profitability goals and of fulfilled positions and
provide feedback, resolve issues and all projects’ responsibilities
manage changes to optimize project authorisation and according to all projects’
performance. responsibilities are requirements)
aligned)
GVM.8.BP16: Direct and Manage Project Coverage of business Coverage of business
Execution. Perform the work defined in the unit level profitability unit level resource
project plan to achieve the project’s goals by all projects’ allocation by all projects’
objectives. executions (e.g. executions (e.g. rate of
profitability goals and available resources
all projects’ executions according to all projects’
are aligned) executions)
GVM.8.BP17: Distribute Information. Make Coverage of business Coverage of business
relevant or established information available unit level profitability unit level resource
goals by all projects’ allocation by all projects’

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 144/169

Application Practices for Exploitability Usefulness Efficiency related


Governance Objective related metrics metrics

to project stakeholders as planned. information needs (e.g. information needs (e.g.


profitability goals and rate of available
all projects’ information resources according to
needs are aligned) satisfy all projects’
information needs)
GVM.8.BP18: Manage Stakeholder Coverage of business Coverage of business
Expectations. Communicate and work with unit level profitability unit level resource
stakeholders to meet their needs and goals by all projects’ allocation by all projects’
address issues as they occur. stakeholder needs stakeholder needs (e.g.
(e.g. profitability goals rate of available
and all projects’ resources according to
stakeholder needs are satisfy all projects’
aligned) stakeholder needs)
GVM.8.BP19: Monitor Project Coverage of business Coverage of business
Performance. Monitor and track project unit level profitability unit level resource
activities and results against plans and goals by all projects’ allocation by all projects’
baseline. performance performance monitoring
monitoring (e.g. needs (e.g. rate of
profitability goals and available resources
all projects’ according to all projects’
performance performance monitoring
monitoring are aligned) needs)
GVM.8.BP20: Review and Analyze Project Coverage of business Coverage of business
Performance. Conduct formal and informal unit level profitability unit level resource
reviews of project performance and analyze goals by all projects’ allocation by all projects’
variances from the plans. performance reviews performance review
(e.g. profitability goals needs (e.g. rate of
and all projects’ available resources
performance reviews according to all projects’
are aligned) performance review
needs)
GVM.8.BP21: Take Corrective Action. Take Coverage of business Coverage of business
corrective actions to address problems unit level profitability unit level resource
goals by all projects’ allocation by all projects’
corrective actions (e.g. corrective actions (e.g.
profitability goals and rate of available
all projects’ corrective resources according to
actions are aligned) all projects’ correction
needs)
GVM.8.BP22: Close Project. Close the Coverage of business Coverage of business
project formally using appropriate unit level profitability unit level resource
organizational mechanisms and update goals by all projects’ allocation by all projects’
organizational process assets closures (e.g. closures (e.g. rate of
profitability goals and available resources
all projects’ closure according to all projects’
mechanism are closure activities)
aligned)
Provide quality management and assurance for Coverage of business Coverage of business

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 145/169

Application Practices for Exploitability Usefulness Efficiency related


Governance Objective related metrics metrics

business operation. The organization applies unit level profitability unit level resource
practices to assure the quality of the product or goals by quality allocation by quality
service and of the processes used, and provide management and management and
management with appropriate visibility into all assurance of business assurance of business
relevant quality aspects. operation (e.g. rate of operation (e.g. rate of
business unit resources allocated to
operating profit coming business operation
from activities without without project
quality management management controls)
controls)
SUP.3.BP1: Establish a Quality Coverage of business Coverage of business
Management System. Establish, document, unit level profitability unit level resource
implement, and maintain a quality goals by quality allocation by quality
management system. management (e.g. rate management (e.g. rate
of profitability goals of available resources
aligned with quality according to quality
management management needs)
objectives)
SUP.3.BP2: Monitor Process Compliance. Coverage of business Coverage of business
Objectively monitor compliance of performed unit level profitability unit level resource
activities with the established processes. goals by compliance allocation by compliance
monitoring (e.g. monitoring needs (e.g.
profitability goals and rate of available
compliance monitoring resources according to
are aligned) compliance monitoring
needs)
SUP.3.BP3: Monitor Product and Service Coverage of business Coverage of business
Quality. Objectively compare, measure and unit level profitability unit level resource
evaluate work products and services against goals by monitoring allocation by quality
the requirements and standards that define product and service monitoring needs (e.g.
them. quality (e.g. profitability rate of available
goals and quality resources according to
monitoring are aligned) quality monitoring
needs)
SUP.3.BP4: Monitor Noncompliance Coverage of business Coverage of business
Issues. Monitor and track noncompliance unit level profitability unit level resource
issues and support their resolution via goals by monitoring allocation by monitoring
escalation to senior management if noncompliance issues noncompliance issues
necessary. (e.g. profitability goals (e.g. rate of available
and resolution of resources according to
noncompliance issues resolution of
are aligned) noncompliance issues)
SUP.3.BP5: Record and Report Results. Coverage of business Coverage of business
Record and report the results of quality unit level profitability unit level resource
assurance activities and customer goals by quality allocation by quality
satisfaction data to applicable stakeholders. records and reports assurance (e.g. rate of
(e.g. profitability goals available resources
and quality assurance according to quality

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 146/169

Application Practices for Exploitability Usefulness Efficiency related


Governance Objective related metrics metrics

results are aligned) assurance needs)


SUP.3.BP6: Analyze Quality. Analyze Coverage of business Coverage of business
quality records and measurements to detect unit level profitability unit level resource
the need for corrective action and develop goals by quality allocation by quality
recommendations for quality improvement or analysis (e.g. analysis (e.g. rate of
corrective and preventive actions. profitability goals and available resources
quality analysis are according to quality
aligned) analysis needs)
SUP.3.BP7: Initiate Quality Improvement. Coverage of business Coverage of business
Initiate activities that address identified unit level profitability unit level resource
quality issues or quality improvement goals by quality allocation by quality
opportunities. improvement (e.g. improvements (e.g. rate
profitability goals and of available resources
quality improvement according to quality
actions are aligned) improvement needs)
SUP.3.BP8: Monitor and Evaluate the Coverage of business Coverage of business
Effect of Changes. Monitor the status of unit level profitability unit level resource
quality improvements on products and goals by monitoring of allocation by monitoring
services and evaluate the effect of changes quality improvement of quality improvements
after they have been implemented. (e.g. profitability goals (e.g. rate of available
and monitoring of resources according to
quality improvement monitoring needs of
actions are aligned) quality improvement)

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 147/169

A3. Sample metrics for application practices supporting Competitiveness governance


objective
Table 15: Application Practices of Competitive Operation with possible metrics

Application Practices for Usefulness Efficiency related


Competitiveness Governance Objective related metrics metrics

Establish and maintain business goals and Revenue targets per Availability of funding
targets. The organization applies practices to business operations in resources per business
establish strategic enterprise direction and ensure planning and reporting operations in planning
the enterprise achieves its goals and objectives. time horizons aligned and reporting time
with strategy (e.g. horizons aligned with
monthly, yearly, etc. strategy (e.g. monthly,
sales targets) yearly, etc. cash flow
targets)
GVM.1.BP1: Establish and Maintain Long term revenue Long term targets for
Strategic Vision. Establish, maintain, and targets per business operating and non-
communicate a strategic vision that identifies operations (e.g. sales operating cash flow (e.g.
long-term goals, values, performance target for the next 3 rate of operating cash
expectations, and core activities. years) flow within total funding
in the next 3 years)
GVM.1.BP2: Establish and Maintain Coverage of business Coverage of business
Policies. Establish, maintain and operations by operations by funding
communicate policies and directives. governance policies policies (e.g. no external
and directives (e.g. funding for
implementing 11 service/production
governance objectives operation planned in the
for service/production) next period)
GVM.1.BP3: Align to Achieve the Vision. Coverage of business Coverage of business
Align the enterprise to operate efficiently and units by governance units by funding policies
consistently to achieve the vision. Establish policies and directives (e.g. no external funding
leadership systems and structures for (e.g. implementing 11 for business units and
decision making, empowerment, and conflict governance objectives supporting IT
resolution. Provide incentives for contributing for all business units) department in the next
to enterprise vision and strategy. period)
GVM.1.BP4: Ensure sharing of common Coverage of key Coverage of key
vision. Ensure that individuals in the positions by positions by funding
enterprise share a common culture, governance policies policies (e.g. rate of
understand the common vision, and are and directives (e.g. remuneration and bonus
committed and empowered to perform their rate of job descriptions program expenditures in
functions effectively. related to operating cash flow)
implementing 11
governance
objectives)
GVM.1.BP5: Establish and Maintain Coverage of business Maintenance frequency
Strategy. Establish and maintain the operations by specific of funding resource
enterprise strategic plans that identify business objectives plans per business
business objectives to be achieved, areas of (e.g. all business operations (e.g. funding
business to be pursued and their operation has resource plans are
interrelationships, and the significant goals to customized business maintained quarterly)

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 148/169

Application Practices for Usefulness Efficiency related


Competitiveness Governance Objective related metrics metrics

be accomplished. and governance


objectives.)
GVM.1.BP6: Formulate and align Maintenance Maintenance frequency
enterprise budgets. Formulate enterprise frequency of budget of cash flow plans per
budgets to ensure alignment with strategic plans per business business operations
goals. Ensure congruency with action plans. operations (e.g. (e.g. monthly)
monthly)
GVM.1.BP7: Develop and Deploy Action Number of action Specific funding plans
Plans. Establish, integrate, and deploy plans per business per business operations
tactical action plans to accomplish strategic operations in planning in planning and
objectives. and reporting time reporting time horizons
horizons (e.g. one per (e.g. funding for IT
business operations) procurement in the next
year)
GVM.1.BP8: Review Performance. Review Performance review Efficiency review
performance relative to goals and changing frequency per frequency per business
needs across the enterprise. business operations operations (e.g.
(e.g. monthly) monthly)
GVM.1.BP9: Act on Results of Review. Number of corrective Unexpected funding
Translate performance review findings into action plans per requests per business
action. business operations in operations in planning
planning and reporting and reporting time
time horizons (e.g. one horizons (e.g.
in 3 month period) extraordinary funding
request for IT
procurement)
GVM.1.BP10: Fulfill Public Responsibility. Coverage of CSR plan CSR related funding
Address the impacts on society of planned by business operations plans per business
activities, products, services, and operations, in planning and operations in planning
considering regulatory and legal reporting time horizons and reporting time
requirements and risks associated with (e.g. number of CSR horizons (e.g. financial
products, services, and operations. programs) resources for yearly
CSR events)
GVM.1.BP11: Inform employees regarding Number of Communication
enterprise performance. Inform employees communications or expenditures per
regarding enterprise performance. events per business business operations in
operations in planning planning and reporting
and reporting time time horizons (e.g.
horizons (e.g. once per funding for year-end
year) celebration)
Evolve customer and other stakeholder needs Coverage of revenue Availability of funding
and expectations. The organization applies targets by service or resources for service or
practices to elicit, analyze, clarify, and document product design works product development
evolving customer and other stakeholder needs and per business per business operations
expectations. operations in planning in planning and
and reporting time reporting time horizons
horizons aligned with aligned with strategy

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 149/169

Application Practices for Usefulness Efficiency related


Competitiveness Governance Objective related metrics metrics

strategy (e.g. 10% of (e.g. 10% of total


revenue is resulted by funding is planned for
implementation of new development
service elements or expenditures or
products) products)
LFC.1.BP1: Identify customers and Revenue weights of Weights of different
stakeholders: Identify customers and identified customer funding scenarios per
stakeholders. and stakeholder types business operations
per business (e.g. specific payment
operations (e.g. ratio options for service
of different client delivery, external
categories by sector, funding requests, etc.)
size, activity, etc.)
LFC.1.BP2: Elicit needs: Elicit customer Number of identified Number of identified
and other stakeholders’ needs, expectations, customer and funding requests for
and measures of effectiveness. stakeholder needs per customer needs per
business operations business operations
(e.g. proposals for new (e.g. funding request
service elements or proposals for new
products) service elements or
products)
LFC.1.BP3: Analyze needs: Analyze needs Revenue weights of Funding weights of
and expectations in the context of the identified customer customer needs per
intended operational environment. and stakeholder needs business operations
per business (e.g. ratio of different
operations (e.g. ratio needs in expenditures)
of different needs in
sales)
LFC.1.BP4: Establish and maintain a Number of formulized Number of validated
statement of need: Establish and maintain a customer and funding requests for
statement of customer and other stakeholder stakeholder needs per customer needs per
needs and expectations that is understood business operations business operations
and agreed upon by the customer and other (e.g. new service (e.g. approved funding
stakeholders. elements/products) requests for new service
elements/products)
LFC.1.BP5: Communicate with customers: Number of Number of validated
Communicate and interact with customers communicated funding requests for
and other stakeholders throughout the life customer and communicated customer
cycle to assure a common understanding of stakeholder needs per needs per business
the status and disposition of needs, business operations operations (e.g.
expectations, and measures of effectiveness. (e.g. new approved funding
service/product requests of new
portfolio elements) service/product portfolio)
LFC.1.BP6: Determine customer Coverage of revenue Coverage of planned
satisfaction: Determine customer targets by customer expenditures by
satisfaction with products and services. satisfaction customer satisfaction
determination per determination per
business operations business operations

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 150/169

Application Practices for Usefulness Efficiency related


Competitiveness Governance Objective related metrics metrics

(e.g. there is only 50% (e.g. there is only 50%


coverage of revenue coverage of planned
targets by expenditures by
determination of determination of
customer satisfaction) customer satisfaction)
Keep proposal preparation practices effective. Coverage of revenue Availability of funding
The organization applies practices to identify, select targets by proposal resources for proposal
and bid for acquirer requests for information, preparation per preparation per
quotations and proposals based on decisions that business operations in business operations in
appropriately consider customer needs, risks, planning and reporting planning and reporting
organizational abilities and competitor capabilities. time horizons aligned time horizons aligned
with strategy (e.g. 80% with strategy (e.g. 5% of
of revenue is resulted total funding is planned
by proposal for sales activities)
preparation practices)
GVM.7.BP1: Evaluate Organizational Coverage of revenue Coverage of planned
Skills, Services and Products. Examine targets by service or expenditures by service
and document the organizational goals, product types per or product types per
service catalog, resumes and existing business operations in business operations
products to determine what target markets to planning and reporting (e.g. 70% coverage of
pursue or develop. time horizons aligned planned expenditures by
with strategy (e.g. 80% service/product portfolio)
of revenue is covered
by service/product
portfolio)
GVM.7.BP2: Establish Criteria and Risk Coverage of revenue Coverage of planned
Analysis for Submission. Document the targets by risk criteria expenditures by risk
basis for determining a bid or no bid decision per business criteria per business
for responding to requests for proposals. operations (e.g. 80% operations (e.g. 70%
percentage of revenue coverage of planned
is covered by risk expenditures by
criteria) service/product portfolio)
GVM.7.BP3: Evaluate Acquirer Requests Coverage of revenue Coverage of planned
for Proposals and Inquiries. Determine that targets by new expenditures by new
proposed effort is in accordance with requests for proposals requests for proposals
potential targets identified in organizational per business per business operations
goals. Determine if the requested task is in operations (e.g. 25% (e.g. 15% coverage of
line with existing organizational skills and of revenue is coming planned expenditures by
talents or if these skills will have to be from new requests for new requests for
acquired. Review overall requirements to proposals) proposals)
determine if they are consistent, concise and
clearly defined. Document any questions that
need to be posed to the acquirer for
clarification. Determine the probability that
the organization can be successful in this bid
according to established criteria. Identify the
logical contenders for the proposal and their
advantages.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 151/169

Application Practices for Usefulness Efficiency related


Competitiveness Governance Objective related metrics metrics

GVM.7.BP4: Perform any Preliminary Coverage of revenue Planned percentage of


Research and Development, Surveys or targets by scope of expenditures for
Trade Studies. Determine if the request preliminary sales preliminary sales
requires investigation of key product or research per business research per business
service components that may prove to be operations (e.g. 15% operations (e.g. 2% of
high risk when providing the requested of revenue is under the planned expenditures
product or service. Investigate trade studies scope of preliminary for preliminary sales
or surveys covering the expected work sales research) research)
involved.
GVM.7.BP5: Make a Go/No Go Decision. Percentage of No Go Percentage of No Go
Based on established criteria and risk decisions per business decisions due to funding
analysis, including preliminary research, operations (e.g. 40% criteria per business
decide whether to pursue or not pursue a of calls for proposal) operations (e.g. 15% of
request for a proposal. No Go decisions caused
by missing funding
criteria)
GVM.7.BP6: Identify Resources to Coverage of revenue Planned percentage of
Perform Proposed Work and Form targets by scope of expenditures for new
Proposal Team. Identify needed skills and proposal preparation proposal preparation
form a qualified team to develop the team per business per business operations
proposal, and to perform the proposed work. operations (e.g. 15% (e.g. 2% of planned
of revenue is under the expenditures for new
scope of proposal proposal preparation)
preparation team)
GVM.7.BP7: Establish and Maintain Coverage of revenue Planned percentage of
Supplier/acquirer Communications targets by scope of expenditures for
Interface. Assign an individual or communication communication interface
organizational entity to establish a interface per business per business operations
communications interface with the potential operations (e.g. 75% (e.g. 1% of planned
acquirers. Review the acquirer’s schedule of of revenue is under the expenditures for
events and point of contact to assure scope of proposal communication
adherence to proposal preparation and preparation team) interface)
delivery schedule.
GVM.7.BP8: Perform Estimation. Estimate Coverage of revenue Planned percentage of
costs and resources needed to satisfy the targets by scope of expenditures for cost
request. cost and resource and resource estimates
estimates per business per business operations
operations (e.g. 55% (e.g. 2% of planned
of revenue target is expenditures for cost
under the scope of and resource estimates)
cost and resource
estimates)
GVM.7.BP9: Prepare and Submit Proposal Percentage of Percentage of non-
in Response to Acquirer Request. Prepare submitted proposals submitted proposals due
proposal in accordance with guidelines in the per business to lack of resources per
acquirer’s request document or request operations (e.g. 40% business operations
of calls for proposal) (e.g. 15% of proposals
are not completed or

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 152/169

Application Practices for Usefulness Efficiency related


Competitiveness Governance Objective related metrics metrics

submitted due to lack of


resources)
GVM.7.BP10: Negotiate and Confirm Percentage of Percentage of failed
Agreement. Negotiate relevant aspects of successful proposals proposals due to funding
the agreement and formally confirm the per business problems per business
agreement operations (e.g. 40% operations (e.g. 15% of
of proposals) proposal are failed due
to funding problems)

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 153/169

A4. Sample metrics for application practices supporting Risk Awareness governance
objective
Table 16: Application Practices of Control Risks with possible metrics

Application Practices for Risk Usefulness related Efficiency related


Awareness Governance Objective metrics metrics

Establish governance objectives for financial Coverage of governance Coverage of governance


reporting and trusted business operation. objectives by capability objectives by
Management specifies governance objectives profiles - risk appetite Usefulness and
relevant for financial reporting and trusted business (e.g. Fully achieved level Efficiency metrics (e.g.
operation with sufficient clarity and criteria to 1 target for all) metrics established for
enable the identification of risks to the achievement all outcomes of related
of the governance objectives relevant for financial governance processes)
reporting and trusted business operation.
IFC.RA.FRO.BP1 Identify Management Coverage of governance Coverage of
assertions. To identify relevant objectives by management assertions
management assertions, management management assertions by Usefulness and
starts with the governance reports, (e.g. management Efficiency metrics (e.g.
including disclosures, and identifies assertions established metrics established for
significant governance objectives, based for all outcomes of all management
on management’s estimate of materiality. related governance assertions)
For each governance report and disclosure processes)
management then identifies relevant
assertions, underlying transactions and
events, and processes supporting these
governance objectives.
IFC.RA.FRO.BP2 Consider the Range of Coverage of business Coverage of business
Assessment Activities. Management, operation by governance operation by Usefulness
with oversight board review, considers the objectives (e.g. only and Efficiency metrics
range of the organization’s activities to mainstream business (e.g. only mainstream
assess whether all are appropriately processes covered business processes
captured in the governance reports, and excluding supporting covered excluding
considers whether the governance reports processes) supporting processes)
appropriately communicate to readers
economic reality in a useful form.
IFC.RA.FRO.BP3 Compare Governance Coverage of governance Coverage of Usefulness
Policies. Management compares the objectives by and Efficiency metrics
governance principles adopted for the comparison (e.g. only by comparison (e.g. no
organization to those used by companies generally published available metrics for
of similar size and industry. Management principles, like comparison)
also compares the content and level of Accountability and
detail in the organization’s governance Commitment)
reports to those organizations’ reports.
Significant variations are considered by
management and summarized for board
review.
Perform consistent risk assessment. The Coverage of governance Coverage of governance
organization identifies and analyses risks to the objectives by capability objectives by evaluating
achievement of governance objectives relevant for assessment (e.g. all Usefulness and
the organization’s financial reporting and trusted Integrated Risk Efficiency metrics (e.g.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 154/169

Application Practices for Risk Usefulness related Efficiency related


Awareness Governance Objective metrics metrics

business operation as a basis for determining how Management scenarios metrics used for
the risks should be managed. evaluated quarterly) evaluation based on
control limits for all
Integrated Risk
Management scenarios)
IFC.RA.FRR.BP1 Apply Risk Coverage of governance Coverage of governance
Identification Process. Management’s processes, business processes, business
risk identification process includes units and supporting units and supporting
identifying: technology by gap technology by
• Relevant management assertions assessment (e.g. all comparing capability
for each significant governance identified gaps at gaps and trends of
objectives. governance processes, Usefulness and
business units and Efficiency metrics (e.g.
• Business processes and business supporting technology all identified capability
units supporting governance evaluated quarterly) gaps compared to
objectives and disclosures. trends of related
• Information technology (IT) metrics)
systems supporting key business
processes relevant to governance
objectives.
IFC.RA.FRR.BP2 Map Controls. Coverage of Coverage of
Management maps its controls to the five management controls by management controls by
internal control components, with headers governance objectives Usefulness and
that list the activity's control objectives and (e.g. all management Efficiency metrics (e.g.
risks. This approach targets activities that controls covered) no additional - specific –
might generate governance errors. metrics needed)
IFC.RA.FRR.BP3 Interact with External Frequency of external Coverage of external
Parties. As part of an organisation’s risk interactions by interactions by
identification, management interacts with Integrated Risk evaluation of Usefulness
external parties that may affect the Management scenarios and Efficiency metrics
reliability of governance reporting, including (e.g. number and (e.g. customer survey
suppliers, investors, creditors, frequency of customer results compared to
shareholders, employees, customers, surveys) trends of Usefulness
intermediaries, and industry peers. and Efficiency metrics)
IFC.RA.FRR.BP4 Consider External Coverage of governance Coverage of external
Factors. Management considers external objectives by considering contexts by evaluation
factors that impact its ability to achieve its external contexts (e.g. of Usefulness and
governance objectives, such as economic, consideration of external Efficiency metrics (e.g.
competitive, and industry conditions; stakeholder needs for ratio of Usefulness and
regulatory and political environment; and capability targets) Efficiency metrics
changes in technology, supply sources, related to external
customer demands, or creditor stakeholder needs)
requirements. Management also considers
how internal factors and changes in them
impact the organisation’s ability to achieve
its governance objectives. These include
governance report characteristics,
business process characteristics, and

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 155/169

Application Practices for Risk Usefulness related Efficiency related


Awareness Governance Objective metrics metrics

entity-wide factors.
IFC.RA.FRR.BP5 Update Risk Frequency of Frequency of evaluating
Assessments. Management updates risk governance process Usefulness and
assessments periodically (e.g. on a related risk assessments Efficiency metrics per
quarterly basis), considering: per Integrated Risk Integrated Risk
• Newly identified risks determined Management scenarios Management scenarios
to be significant. (e.g. all Integrated Risk (e.g. metrics used for
Management scenarios evaluation based on
• Escalation of previously identified evaluated quarterly) control limits for all
risks to higher relevance. Integrated Risk
• The status of action plans to Management scenarios
mitigate significant risks. quarterly)
This risk assessment evaluates risk based
on potential impact and likelihood of risks.
The resulting assessment is used as a key
input in determining required control
activities.
IFC.RA.FRR.BP6 Meet with Relevant Frequency of meetings Frequency of meeting
Personnel. Key governance personnel per Integrated Risk for maintaining the
meet on a regular basis with: Management scenarios Usefulness and
• Executive management to identify for maintaining capability Efficiency metrics per
new initiatives, commitments, and targets (e.g. during Integrated Risk
activities affecting risks to financial evaluation of all Management scenarios
reporting and trusted business Integrated Risk (e.g. control limits are
operation. Management scenarios reviewed and updated
quarterly) by meetings for all
• Information technology personnel Integrated Risk
to monitor changes in information Management scenarios
technology that may affect risks quarterly)
related to financial reporting and
trusted business operation.
• Human resources staff to identify
and assess how changes in the
workforce may affect
competencies needed for internal
control over financial reporting and
trusted business operation.
• Legal counsel to stay abreast of
legal/regulatory changes.
Address risks relevant for financial reporting Coverage of governance Coverage of
and trusted business operation. Actions are objectives by improvement/risk
taken to address risks to the achievement of the improvement/risk treatment actions by
governance objectives relevant for financial treatment actions per referring to Usefulness
reporting and trusted business operation. Integrated Risk and Efficiency metrics
Management scenarios (e.g. metrics used as
(e.g. improvement improvement indicators
actions determined for all for all Integrated Risk
Integrated Risk Management scenarios)
Management scenarios

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 156/169

Application Practices for Risk Usefulness related Efficiency related


Awareness Governance Objective metrics metrics

quarterly)
IFC.CA.IRA.BP1 Consider Entity-Wide Coverage of governance Coverage of
Controls. Management considers entity- practices by improvement/risk
wide controls that are pervasive across the improvement/risk treatment actions per
organisation when considering whether treatment actions per governance objectives
control activities are sufficient to address governance objectives by referring to
identified risks. (e.g. improvement Usefulness and
actions determined for all Efficiency metrics (e.g.
governance objectives metrics used as
quarterly) improvement indicators
for all governance
practices implemented
by the governance
processes)
IFC.CA.IRA.BP2 Use Workshops to Frequency of workshops Frequency of assessing
Identify and Evaluate Controls. for evaluating residual risk impact by
Management uses workshops to identify effectiveness of using Usefulness and
appropriate control activities for each improvement/risk Efficiency metrics (e.g.
identified risk to a governance objective treatment actions per metrics used as
and to train its employees in proper governance objectives effectiveness indicators
implementation of control activities. (e.g. improvement for all governance
actions evaluated for all practices implemented
governance objectives by the governance
quarterly) processes quarterly)
IFC.CA.IRA.BP3 Use Matrices to Identify Coverage of governance Coverage of governance
and Evaluate Controls. Management processes and practices processes and practices
uses risk/control matrices developed in the by mapping to business by referring to
process of assessing risks and designing operation (e.g. full Usefulness and
controls in each business process to coverage of Efficiency metrics (e.g.
perform a “gap analysis” to evaluate the management assertions) full coverage of
need for any additional controls that might management assertions
be needed to mitigate risks to the by referring to metrics)
achievement of governance objectives.
IFC.CA.IRA.BP4 Use an Inventory of Coverage of governance Coverage of governance
Controls to Identify and Evaluate processes and practices processes and practices
Controls. Management uses register or by mapping to evidences by collecting Usefulness
software that provides an inventory of from business operation and Efficiency metrics
controls typically aligned to specified risks (e.g. coverage of (e.g. coverage of
to financial reporting and trusted business management assertions management assertions
operation. by evidences) by using metrics)
IFC.CA.IRA.BP5 Use independent Coverage of outsourced Coverage of outsourced
assessment of outsourcing service business operation by business operation by
provider’s internal control over assessing relevant referring to Usefulness
processing transactions for user governance objectives and Efficiency metrics
organization. When outsourcing all or a regularly (e.g. yearly for relevant governance
portion of its function related to financial assessment results are objectives (e.g. metrics
reporting and trusted business operation, evaluated for used as service level
the CFO or CGO obtains an independent Satisfaction, Accuracy indicators for

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 157/169

Application Practices for Risk Usefulness related Efficiency related


Awareness Governance Objective metrics metrics

assessment report (like SOC 1 Type II) or and Data Protection) Satisfaction, Accuracy
undertakes procedures to assess controls and Data Protection)
in place for the initiation, recording, and
processing of significant classes of
transactions at the third-party outsourcer.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 158/169

A5. Next table shows sample metrics for application practices supporting Control Efficiency
governance objective:
Table 17: Application Practices of Control Efficiency with possible metrics

Application Practices for Control Usefulness related Efficiency related


Efficiency Governance Objective metrics metrics

Ensure adequate organizational structure. The Coverage of operational Coverage of operational


entity’s organizational structure supports effective and organizational and organizational
internal control over financial reporting and trusted levels by governance levels by maintaining
business operation. objectives (e.g. Full and using Usefulness
coverage of key and and Efficiency metrics
supporting business (e.g. metrics established
processes at Business and used by key and
Unit and enterprise supporting business
level) processes Business Unit
and enterprise level)
IFC.CE.OS.BP1 Develop Organizational Coverage of Coverage of
Charts. Management develops an organizational levels by organizational levels by
organizational chart, which sets forth roles defined roles and defined roles for
and respective reporting lines for all reporting lines (e.g. Full reporting and using
employees, including those involved in coverage of key roles Usefulness and
financial reporting and trusted business and reporting lines at Efficiency metrics (e.g.
operation. Business Unit and all roles and
enterprise level) responsibilities defined
for reporting and using
metrics at Business
Unit and enterprise
levels)
IFC.CE.OS.BP2 Align Roles to Coverage of operational Coverage of operational
Processes. Each unit or function within the levels by defined roles levels by defined roles
organization aligns roles to key processes and reporting lines (e.g. for reporting and using
supporting governance objectives. Full coverage of key Usefulness and
roles and reporting lines Efficiency metrics (e.g.
in Service/Production all roles and
operation) responsibilities defined
for reporting and using
metrics in
Service/Production
operation)
IFC.CE.OS.BP3 Maintain Job Coverage of operational Coverage of operational
Descriptions. Management maintains job and organizational and organizational
descriptions for key positions and updates levels by job levels by job
them as conditions and circumstances descriptions (e.g. Full descriptions for
warrant. coverage of key and reporting and using
supporting business Usefulness and
processes at Business Efficiency metrics (e.g.
Unit and enterprise job descriptions include
level) responsibilities for
reporting and using
metrics of key and
supporting business

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 159/169

Application Practices for Control Usefulness related Efficiency related


Efficiency Governance Objective metrics metrics

processes at Business
Unit and enterprise
level)
IFC.CE.OS.BP4 Establish Organizational Coverage of operational Coverage of operational
Structures. Management adopts a and organizational and organizational
structure whereby there are adequate staff levels by Integrated Risk levels by Integrated Risk
layers between the Chief Governance Management scenarios Management scenarios
Officer (CGO) and personnel directly (e.g. 5 Integrated Risk using Usefulness and
involved in the financial reporting and Management scenarios Efficiency metrics (e.g. 5
trusted business operation process. covering Integrated Risk
Service/Production Management scenarios
operation) covering
Service/Production
operation)
IFC.CE.OS.BP5 Establish Structure for Coverage of operational Coverage of operational
Internal Audit. An internal audit function and organizational and organizational
reports directly to the Chief Executive levels by internal audit levels Usefulness and
Officer (CEO), with direct access to the scope (e.g. audit scope Efficiency metrics by
oversight board (e.g. audit committee), to of 5 Integrated Risk internal audit scope (e.g.
maintain independence over financial Management scenarios audit scope of 5
reporting and trusted business operation. covering Integrated Risk
Service/Production Management scenarios
operation) covering
Service/Production
operation)
Supervise internal controls. The oversight board Coverage of governance Coverage of Usefulness
understands and exercises oversight responsibility objectives by oversight and Efficiency metrics
related to trusted business operation, financial board activities (e.g. all by oversight board
reporting and related internal control. Integrated Risk activities (e.g. metrics
Management scenarios used for supervision
supervised quarterly) based on control limits
for all Integrated Risk
Management scenarios)
IFC.CE.OB.BP1 Establish Content for Coverage of governance Coverage of governance
Board Meetings. The oversight board processes by meeting processes, business
establishes a formal policy for specific schedules (e.g. all units and supporting
decisions or events that require discussion identified gaps at technology by
with or approval from the board, as well as governance processes, comparing capability
a calendar for the timing of these business units and gaps and trends of
discussions. supporting technology Usefulness and
discussed quarterly) Efficiency metrics (e.g.
supervision of all
identified capability gaps
compared to trends of
related metrics)

IFC.CE.OB.BP2 Identify Independent Percentage of Percentage of


Board Members. Independent oversight independent members independent members

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 160/169

Application Practices for Control Usefulness related Efficiency related


Efficiency Governance Objective metrics metrics

board and/or audit committee members are in supervision of in supervision of


identified. Integrated Risk Integrated Risk
Management scenarios Management scenarios
(e.g. 1/3 independent) (e.g. 1/3 independent)
IFC.CE.OB.BP3 Establish Boards Roles Coverage of Integrated Coverage of quantitative
and Responsibilities. The oversight board Risk Management performance
through the corporate bylaws, and the audit scenarios by oversight measurement
committee through its charter, set forth their roles (e.g. dedicated management by
roles and responsibilities. board member for Risk oversight roles (e.g.
Management oversight) dedicated board
member for quantitative
performance
measurement oversight)
IFC.CE.OB.BP4 Consider Effectiveness Frequency of meetings Frequency of evaluating
of Internal Control. The oversight board for evaluating residual risk impact by
regularly considers the effectiveness of effectiveness of using Usefulness and
internal control over financial reporting and improvement/risk Efficiency metrics (e.g.
trusted business operation, including risks, treatment actions per metrics used as
significant deficiencies, and material governance objectives effectiveness indicators
weaknesses (if any). (e.g. improvement for all governance
actions evaluated for all practices implemented
governance objectives by the governance
quarterly) processes quarterly)
IFC.CE.OB.BP5 Meet with Auditors. The Frequency of meetings Frequency of meeting
oversight board meets regularly with the with auditors for with auditors for
internal and external auditors, including in maintaining capability maintaining the
private meetings. The board reviews audit targets (e.g. during Usefulness and
scope and testing plans, resources and evaluation of all Efficiency metrics per
staffing, and significant audit findings. Integrated Risk Risk Management
Management scenarios scenarios (e.g. control
quarterly) limits are reviewed by
meetings for all
Integrated Risk
Management scenarios
quarterly)
IFC.CE.OB.BP6 Review Policies and Frequency of Risk Frequency of reviewing
Procedures. The oversight board reviews Management reviews the Usefulness and
governance policies and procedures used (e.g. during evaluation Efficiency metrics per
by management for determining significant of all Integrated Risk Integrated Risk
expectations, including key assumptions. Management scenarios Management scenarios
quarterly) (e.g. control limits are
reviewed by meetings
for all Integrated Risk
Management scenarios
quarterly)
IFC.CE.OB.BP7 Maintain Scepticism. Frequency of Frequency of
The oversight board maintains an questioning questioning control limits
appropriate level of scepticism regarding management assertions per Integrated Risk

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 161/169

Application Practices for Control Usefulness related Efficiency related


Efficiency Governance Objective metrics metrics

management’s assertions and judgments per Integrated Risk Management scenarios


affecting governance reporting, asking Management scenarios (e.g. quarterly)
probing and challenging questions of (e.g. quarterly)
management.
IFC.CE.OB.BP8 Consider Whistle-blower Frequency of Whistle- Frequency of Whistle-
Information. The oversight board blower Information blower Information
considers information obtained from the reviews (e.g. during reviews effecting the
whistle-blower program and the evaluation of all Usefulness and
organisation’s anti-fraud and similar Integrated Risk Efficiency metrics per
processes to monitor the risks of Management scenarios Integrated Risk
misstatements in governance reporting, quarterly) Management scenarios
including risks of inappropriate acts by staff (e.g. effect on control
and management override of controls. The limits are reviewed by
board reviews reports of significant matters, meetings for all
considering the potential impact on Integrated Risk
governance reporting and need for Management scenarios
corrective action. quarterly)
IFC.CE.OB.BP9 Review Board Coverage of governance Coverage of governance
Candidates. The oversight board conducts objectives by objectives by
due diligence on board and audit committee competence competence regarding
candidates to confirm appropriate certification/statements quantitative
independence from the organisation and (e.g. competence to performance
management and his/her ability to be an Accountability objective) measurement (e.g.
effective board member. competence of
Accountability
measurement)
IFC.CE.OB.BP10 Certify Compliance. Coverage of governance Coverage of governance
The oversight board members certify objectives by objectives by
annually their compliance with the compliance compliance
organisation’s ethics guidelines and certification/statements certification/statements
independence rules. (e.g. compliance to regarding quantitative
Commitment objective) performance
measurement (e.g.
competence of
Commitment
measurement)
IFC.CE.OB.BP11 Meet with Management. Frequency of meetings Frequency of meetings
The oversight board allocate a portion of without management without managers for
every meeting for discussions of issues per Integrated Risk maintaining the
without management present, including Management scenarios Usefulness and
separate time with external advisors, (e.g. during evaluation Efficiency metrics per
internal audit, the external auditor and of all Integrated Risk Integrated Risk
outside legal counsel. Management scenarios Management scenarios
quarterly) (e.g. control limits are
reviewed by meetings
for all Integrated Risk
Management scenarios
quarterly)

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 162/169

Application Practices for Control Usefulness related Efficiency related


Efficiency Governance Objective metrics metrics

Manage internal control deficiencies. Internal Number and frequency Coverage of


control deficiencies are identified and of improvement/risk improvement/risk
communicated in a timely manner to those parties treatment actions per treatment actions by
responsible for taking corrective action, and to the Integrated Risk using of Usefulness and
management and the oversight board as Management scenarios Efficiency metrics (e.g.
appropriate. (e.g. control metrics used as
improvement actions effectiveness and
determined for all efficiency indicators of
Integrated Risk control improvement
Management scenarios actions for all Integrated
quarterly) Risk Management
scenarios)
IFC.MO.RD.BP1 Report Information from Frequency of using Coverage of
Alternative Channels. Management information from management reviews by
establishes an alternative channel for alternative channels per considering of
reporting deficiencies sensitive in nature, Integrated Risk Usefulness and
such as illegal or improper acts. Management scenarios Efficiency metrics (e.g.
(e.g. monthly review of metrics used by
information from reviewing of information
alternative channels for from alternative
all Integrated Risk channels as measuring
Management scenarios) potential impact for all
Integrated Risk
Management scenarios)
IFC.MO.RD.BP2 Report Deficiencies to Coverage of operational Coverage of operational
Various Levels in the Organisation. and organizational and organizational
Management establishes a practice where levels where levels where control
all financial reporting and trusted business deficiencies are limits of Usefulness and
operation deficiencies regardless of systematically reported Efficiency metrics are
materiality are reported to the responsible (e.g. deficiencies are used for reporting
manager and at least one level of reported by using of all deficiencies (e.g.
management above, both of whom are Integrated Risk deficiencies are
positioned to take corrective action. Management scenarios) systematically measured
by using control limits of
Usefulness and
Efficiency metrics for all
Integrated Risk
Management scenarios)
IFC.MO.RD.BP3 Develop Guidelines for Coverage of operational Coverage of operational
Reporting Deficiencies. Management and organizational and organizational
develops a list of control deficiencies that levels where guidelines levels where guidelines
seriously threaten the reliability of of reporting deficiencies of using control limits of
governance reporting, which if they occur are established (e.g. Usefulness and
are required to be reported to senior guidelines of reporting Efficiency metrics are
management and the board. deficiencies are established for reporting
maintained for using all deficiencies (e.g.
Integrated Risk guidelines of using
Management scenarios) metrics for reporting
deficiencies are

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 163/169

Application Practices for Control Usefulness related Efficiency related


Efficiency Governance Objective metrics metrics

maintained for all


Integrated Risk
Management scenarios)

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 164/169

Annex B: Evaluating Residual Risk Status by using ISO/IEC 15504


Capability Assessment
The Process related Risk Assessment performed on ISO/IEC 15504 conformant process assessment
results, provides feedback to the management whether the existing gaps between the target and assessed
capability profiles represent acceptable residual risk levels for the sponsor (“the individual or entity, internal
or external to the organizational unit being assessed, who requires the assessment to be performed, and
provides financial or other resources to carry it out” - ISO/IEC 15504-1, 3.13).

This approach provides more flexible and customisable method to evaluate the system of governance and
internal controls as current (residual) status of enterprise level risk treatment actions, necessary to define the
coverage of the substantive examinations of the economy, efficiency and/or effectiveness of the
organizations, activities, programmes or functions concerned, in order to define the next risk treatment
activity plans.

ISO/IEC 15504 standard provides guidance on how to utilise conformant process assessment results for
determining residual risk status.

Step 1. Setting target capability profiles and performing conformant assessment


At first the sponsor should determine which processes from the selected Process Reference Model(s) are
(most) important for either the pre-defined requirements (scope of Process Capability
Determination/Assurance engagement) or business goals (scope of Process Improvement/Consulting
engagement). Also the sponsor should specify a target process profile, showing which process attributes are
required for each selected process. Also the necessary rating for each process attribute should be given.
Only ratings of “Fully achieved” or “Largely achieved” should be set. “Partially achieved” rating has no
meaning to set, as this would indicate that the achievement would be unpredictable in some aspects. “Not
required” should be noted for a process attribute taken to be unnecessary.

The set of target process profiles expresses the target capability, which the sponsor judges to be adequate
(to the organization’s business risk appetite and tolerance).

ISO/IEC 15504-3 provides detailed guidance on performing a conformant assessment for determining the
capability levels with attribute ratings for the processes in scope.

Next Figure presents example target and assessed process profiles for 5 selected sample Internal Financial
Control (COSO) processes:

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 165/169

Figure 14: Example target and assessed process capability profiles

Step 2: Performing Gap Assessment


Process related risk - representing residual status of risk treatment - can be inferred from the existence of
gaps between the target and the assessed process profiles.

The potential consequence of a gap depends on the capability level and the process attributes where the
gap identified. In the above example, some Internal Financial Control (COSO) related considerations and
conclusions might be taken (by using the above example process profiles):

Typical consequence of the gap at level 1 PA 1.1 Process performance attribute is that not all of the relevant
process outcomes (Attributes of COSO 2006 Principles) are achieved, and no recoverable documentation
exists to track the necessary control. E.g. Management communication to personnel in roles affecting
financial reporting is not adequately documented, so updates on internal or external finance matters are not
taken into consideration.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 166/169

At level 2 PA 2.1 Performance management gap, the typical consequences are the missing deadlines, lack
or inefficient use of resources, unclear responsibilities, uncontrolled decisions, etc. E.g. Management
communication with oversight board or personnel is not planned or scheduled; the related management does
not do deficiency disclosure in time; unauthorized decisions are done at period closing; policies and
procedures are not under revision on a timely base.

At level 2 PA 2.2. Work product management attribute, the gap can cause unpredictable quality of reports,
parallel entries and inconsistent documentation, increased rework cost, consolidation problems. E.g. Old
versions of policies and procedures are also in use; identified exceptions are not communicated; internal
communication is not filed in a systematic way.

At level 3 PA 3.1 Process definition gap, the consequences are that best practices and learnt lessons are not
taken into account during revision of policies and procedures or the outcomes of the related control
processes are not identical in the operational procedures. E.g. Missing or just formal description of internal
communication procedures withhold staff members to use alternative reporting lines informing oversight
board about material weaknesses or improvement suggestions.

At level 3, the PA 3.2 Process deployment gap can cause inconsistent applications of financial controls built
into the operational procedures. Identified opportunities are lost due to inefficient deployment effort. E.g. The
oversight board does not take the internal auditor’s consultative role and efforts seriously; the financial
statement assertions are not properly linked to the business processes during risk assessment; information
technology controls do not reflect adequately to the complexity of the IT environment.

At level 4 PA 4.1 Process measurement gap, the consequences are that the key controls are not properly
identified, designed or operating in order to achieve process performance objectives and business goals or
detect performance problems early. E.g. the resolution of key control exceptions is not covered in risk
assessment.

At level 4 PA 4.2 Process control gap, the consequences are that the quantitative performance objectives
and the defined business goals do not meet. E.g. Short monthly/yearly closing deadline can cause
unpredictable materiality of accruals, management estimates and reserves.

Step 3: Analysing Process related Risk based on Gap Assessment


ISO/IEC 15504-4 presents an example approach summarized below.

The process attribute gap can be categorized into “None”, “Minor” and “Major” categories based on the
distance of target and assessed ratings. E.g. one-step gap is evaluated as minor, two or more steps distance
deems major gap in case of “Fully achieved” attribute target. At “Largely achieved” target even the one step
distance (“Partially achieved”) means major gap.

The probability of problem occurrence is derived from the extent of process attribute gaps and from the
capability level where they occur. Capability level gaps are categorized as follows:

None - No major or minor gaps


Slight - No gap at level 1, and only minor gaps at higher levels
Significant - A minor gap at level 1, or a single major gap above
Substantial - A major gap at level 1, or more than one major gap above

The process related risk depends on both the probability of problem arising from the identified gap and the
potential consequence. In general the consequences depend on the capability levels where the gaps occur.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 167/169

As it is shown in Table 18, the high risk arises from a major gap at lower capability levels.

Consequence Probability

Indicated by capability Indicated by extent of capability level gap


level where gap occurs
Slight Significant Substantial
5 - Optimizing Low Risk Low Risk Low Risk
4 - Predictable Low Risk Low Risk Medium Risk
3 - Established Low Risk Medium Risk Medium Risk
2 - Managed Medium Risk Medium Risk High Risk
1 - Performed Medium Risk High Risk High Risk

Table 18: Risks associated with capability levels

If risks are identified at more capability levels, then the highest risk measure shall be considered as the
process related risk. Based on the presented approach risk analysis shall determine the residual risk level of
the scoped governance or control processes.

While the gaps between target and assessed profiles indicate the effectiveness of risk treatment planning
(control design), the process related risk measures the effectiveness of risk treatment action (control
operation). Residual risk status determined by process related risk level shows the extent of risk (e.g. that
material loss or deviation from business objectives cannot be prevented or detected in time by the normal
operation).

Audit literature identifies ranking of control deficiencies concerning their business impact:

• Control Deficiency: Controls are not in place, or inadequate, or not being used
• Significant Deficiency: Deficiency in a significant control, or aggregation of deficiencies that could
result consequential impact
• Material Weakness: Significant deficiency or an aggregation of significant deficiencies that preclude
the entity’s internal control from providing reasonable assurance that material misstatements or any
major ”loss” will be prevented or detected on a timely basis by employees in the normal course of
performing their assigned functions

High risk measure of an internal control process represents reportable “Material Weakness” of the control
system.

Based on the presented approach risk analysis shall determine which process or processes represent the
greatest degree of risk. Tables 19-21 present examples of Internal Financial Control (COSO) related risk
assessment using example process profiles from Figure 14, where the process profiles showed gap at 3
internal financial control processes:
• IFC.RA.FRO - Financial Reporting Objectives;
• IFC.CA.PP - Policies and Procedures; and
• IFC.IC.IC - Internal Communication

IFC.RA.FRO - Financial Reporting Objectives


Level 1 Level 2 Level 3 Level 4

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 168/169

PA 1.1 PA.2.1 PA 2.2 PA 3.1 PA 3.2 PA 4.1 PA 4.2


Target profile F F F F F L L
Assessed profile F F F F L L L
Process attribute gap - - - - minor - -
Capability level gap - - slight -
Capability level risk - - low -
Process related risk low

Table 19: Internal Financial Control process related risk assessment example - 1

IFC.CA.PP - Policies and Procedures


Level 1 Level 2 Level 3 Level 4
PA 1.1 PA.2.1 PA 2.2 PA 3.1 PA 3.2 PA 4.1 PA 4.2
Target profile F F F L L - -
Assessed profile F P L F L - -
Process attribute gap - major minor - - - -
Capability level gap - significant - -
Capability level risk - medium - -
Process related risk medium

Table 20: Internal Financial Control process related risk assessment example - 2

IFC.IC.IC - Internal Communication


Level 1 Level 2 Level 3 Level 4
PA 1.1 PA.2.1 PA 2.2 PA 3.1 PA 3.2 PA 4.1 PA 4.2
Target profile F F F F F - -
Assessed profile P N N N N - -
Process attribute gap major major major major major - -
Capability level gap subst. substantial substantial -
Capability level risk high high medium -
Process related risk high

Table 21: Internal Financial Control process related risk assessment example - 3

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.
HARBIF Version: 2
HOLISTIC APPROACH TO RISK – BASED Revision: 0
INTERNAL FINANCIAL CONTROL FOR SMEs Date: 11.10.2014
Applying Integrated Risk Management Scenarios Page: 169/169

Step 4: Planning next risk treatment actions


As presented in the previous examples, governance/internal control process related risk evaluation is based
on the gaps between the target and the assessed process attribute ratings. Setting lower target capability for
e.g. a financial control (COSO) process is theoretically explainable if the risk appetite related to the financial
reporting objectives is not so demanding or the current risk level of the financial reporting process is
acceptable to fulfil regulatory compliance requirements.

In more complex environment (featured by business type, size, sectoral regulations, etc.) the continual
improvement of the governance and control processes might be desirable. E.g. assessing internal controls,
together with the business processes where they are embedded, against up to level 3 process attributes is
reasonable for the complex or multinational organizations, publicly listed companies under SOX regulation,
financial institutes, and specific public service companies managing public funds.

For the core business processes even the level 4 (Predictable) capability targets might be reasonable
depending on the risk attitude determined by the sponsor (e.g. management, board or customer). As the
process related risk levels are contingent upon both the target (risk appetite) level and the assessed gaps
(deficiencies), the residual risk levels allow prioritizing where and how urgently improvement activities should
be defined by the next risk treatment plan(s). As part of the risk treatment planning the process scope and
capability targets should be also considered and might be reestablished.

This project has been funded with support from the European Commission. This publication [communication] reflects the views only of
the author, and the Commission cannot be held responsible for any use which may be made of the information contained therein.

You might also like