Como você avalia e gerencia os eventos de risco operacional associados a fornecedores e parceiros terceirizados?

Defining the scope and objectives of the Operational Risk Management (ORM) program is foundational in assessing and managing risks linked to third-party vendors and partners. This involves identifying key stakeholders, roles, and responsibilities, along with criteria and methods for selecting, monitoring, and evaluating third-party performance and risk. The established scope and objectives must align seamlessly with the organization's overall strategy, risk appetite, and governance structure. Documentation and clear communication to all relevant parties are imperative, ensuring a shared understanding of the goals and parameters of the ORM program in relation to third-party engagements.

I've also found that classifying your vendors or third party partners is an important process. Classification could be based on the criticality of the services/ products provided to the business, the financial exposure, etc.

When assessing and managing operational risk events linked to third-party vendors and partners, it's vital to clearly define the scope and objectives of the engagement. For instance, if outsourcing IT services, the scope may include data security and system uptime objectives, ensuring alignment with organizational goals.

This should be done through the lens of your own risk appetite. What levels of risk are you willing to accept? It will tailor the results.

Prior to engaging with a third-party, thorough due diligence and risk assessment are crucial. This involves evaluating the vendor's financial stability, regulatory compliance, and potential impact on your organization. For instance, before partnering with a software provider, assess their cybersecurity measures to mitigate data breach risks.

After the definition of scope and objectives, the next step in managing operational risk events related to third-party vendors is conducting due diligence and risk assessment. This entails gathering and verifying information about their background, reputation, financial stability, capabilities, security measures, compliance adherence, and contingency plans. The risk assessment considers the nature, scope, and complexity of the services or products offered by the third-party, evaluating the potential impact and likelihood of operational risk events. Additionally, it accounts for interdependencies and interactions among different third-parties and factors in the external environment and emerging threats to ensure a comprehensive evaluation.

The third step in managing third-party vendors and partners is establishing contracts and service level agreements (SLAs). These documents should clearly define expectations, obligations, and deliverables for both parties, along with metrics and indicators for measuring and reporting performance and risk. Additionally, contracts and SLAs should outline rights and remedies in case of disputes, breaches, or failures, as well as termination and exit clauses. Regular reviews and updates of these agreements are crucial to ensure they reflect changes in the scope, objectives, or risk profile of the third-party relationship. This helps maintain a clear understanding and alignment between both parties throughout the collaboration.

Once due diligence is complete, it's essential to establish comprehensive contracts and service level agreements (SLAs). Clearly outline expectations, responsibilities, and performance metrics. For example, a manufacturing company may include specific quality standards and delivery timelines in contracts with suppliers to mitigate production delays.

Something that I find important is to regularly evaluate and update the risk management practices based on feedback, emerging trends, and changing business needs. Push your teams to stay ahead of new technology, regulations changes and industry best practices. Don’t let your policies get stale.

The fourth step in managing third-party vendors and partners involves continuous monitoring and review of their performance and risk. This entails collecting and analysing data and feedback from diverse sources such as audits, surveys, incidents, complaints, or benchmarks. The process assesses the quality, timeliness, efficiency, and effectiveness of the services or products provided by the third-party, alongside compliance with contracts and SLAs. Additionally, it identifies and evaluates any operational risk events or issues, promptly reporting them to relevant stakeholders for appropriate action. This ongoing monitoring ensures transparency, accountability, and proactive risk management throughout the vendor or partner relationship.

Continuous monitoring of vendor performance and risk factors is key. Utilize key performance indicators (KPIs) and regular reviews to ensure adherence to SLAs. For instance, a retail business may monitor inventory levels and delivery times to detect any deviations from agreed-upon standards.

The fifth step entails implementing corrective actions and improvements based on the results of the monitoring and review process. This involves addressing any identified gaps, weaknesses, or issues affecting the performance or risk of the relationship. Additionally, it includes enhancing or optimising processes, systems, or controls to improve outcomes or reduce risks. Prioritising, assigning, tracking, and verifying corrective actions and improvements according to urgency, impact, and feasibility is crucial. Communication and coordination with both external vendors and internal stakeholders are essential throughout this process to ensure alignment and effectiveness in addressing concerns and driving positive outcomes.

In the event of identified issues, swift corrective actions are necessary. Establish protocols for addressing non-compliance and implementing improvements. For instance, if a logistics partner consistently fails to meet delivery timelines, collaborative problem-solving initiatives may be implemented to enhance efficiency.

Promote a culture of continuous improvement by learning from experiences. Regularly share best practices and lessons learned within the organization. For example, if a financial institution successfully navigates a regulatory challenge with a third-party provider, disseminate the insights to enhance overall risk management.

1. Assess: Define critical vendors, conduct risk assessments (questionnaires,audits) to identify potential issues (data breaches, outages, financial instability) 2.Mitigate:Negotiate clear contracts and SLAs with risk mitigation clauses (penalties, termination rights). Diversify vendors to avoid single points of failure 3.Monitor:Regularly review vendor performance,security posture, and industry news.Conduct periodic reassessments to adapt to changing risks 4.Improve:Implement incident response plans for vendor-related disruptions.Share best practices and encourage continuous improvement from vendors This approach,combining assessment, mitigation,monitoring,and improvement,helps manage operational risks with third-party vendors and partners

Given the inability to easily learn who are the beneficial owners of most third-party vendors, it is suggested that Enhanced Due Diligence be conducted on their identification, to assure your that you are not dealing with fraudsters, sanctioned individuals, or otherwise unsuitable companies involved in financial crime, especially bust-out operations, where they run up debt and then disappear.

In addition to the outlined steps, consider regular audits, staying abreast of industry trends, and fostering open communication channels with vendors. Periodically reassess the risk landscape and adapt strategies accordingly. For instance, in a rapidly evolving technology environment, regularly reassessing cybersecurity protocols can be critical to staying ahead of potential threats.