Risk Management • Banking & People Risk

People Risk Management at Banking and Financial Institutions

Journal: The Chartered Accountant, August 2021 (Vol. 70, No. 2) • Pages: 89–91 (Journal pp. 205–207)
KJ

Kirit Jain

The author is HR risk expert. He can be reached at kiritjain11.kj@gmail.com.

Risk management in banking and financial organisations of all shapes and sizes have been traditionally an integral part of their functioning. A large part of it is driven by banking regulatory requirement given the nature of business such organisations are in, i.e., money management. Hence, safe guarding a bank from unwanted incidents/accidents that can risk people’s money (and in turn economy at large in eventuality) takes as important a place as generating business and profits for financial institutions. No other industry is as vulnerable as the banking and financial industry when it comes to varied risks, having a potential to collapse even an excellent run organisation – big or small. Such is the strength of risk. When not managed well, it can cause havoc of any magnitude that can crash not only the organisation and the financial industry, but it can also lead to devastating effects to crumble a nation’s or the world’s economy in no time.

So, the question is, why do such risks play out in spite of robust risk management practices to manage critical risks such as Credit Risk, Market Risk, Liquidity Risks and Operational Risk in organisations? Today, world class statistical models, highly evolved control and governance mechanism, skilled expertise and superbly engaged Central Banks monitor the financial industry, enabling it to proactively manage these critical risks. Still, risks play out every now and then affecting the organisations’ reputation and finances.

So coming back to why these risks still take place? The answer lies in People Risk. Employees at all levels in an organisation carry out a variety of actions amidst facing a variety of choices, circumstances and impulses in their work every day, and their conduct can either help build the organization or lead it to risks.

What is People Risk or Human-Factor Risk?

Definition: People Risk, alternatively called human-factor risk or human resource risk, is a risk of loss to the organisation due to inadequate or inappropriate human behaviour, action or decisions.

Human-factor risk in any financial organisation is the root cause of failure for other risks. People risk precedes all other risks and is caused by people internally within the organisation or from outside. When people risk is inadequately understood and ineffectively managed, it causes other critical risks to snowball and avalanche. Some world class financial organisations have recognised the importance of managing people risk while others across the world are still at an emerging stage to determine how to incorporate people risk management in an overall framework of risk management within their organisation.

“Many historical financial crises such as rogue trading, credit defaults including the 2008 Lehman Brothers led financial meltdown are still alive in our minds and hearts. Most of these crises were the results of human-factor risks manifested in operational failure or through misaligned judgement.”

How Does People Risk Occur?

People Risk manifests through behaviour of people within or outside organisation i.e., action of employees and third-party partners, if error-clad or malicious, can lead to control and governance failure built around processes, systems and activities. In turn, a failed process or a system exposes the associated risks to take place leading an organisation to incur a loss of either financial, reputational, or regulatory nature or all of them. It is people who propel an organisation into the heights of success, but it is also people who can render it to fall like a towering pack of cards.

Barings Bank (UK) – Rogue Trading

A closest example is the Rogue Trading by a derivative trader whose actions led Barings Bank, UK’s oldest merchant bank, to bankruptcy due to fraudulent, unauthorized and speculative trades.

PNB & Gitanjali Gems (India) – System Bypass

The case of PNB Bank and jewellery company Gitanjali Gems in India is another stark example that led to massive losses for the bank as internal procedures and systems were bypassed by personnel.

Enron Bankruptcy (2001) – Accounting Fraud

The Enron Bankruptcy in 2001 is a classic demonstration of people’s misconduct in terms of fraudulent accounting practices and deliberate misrepresentation of financial statements.

Airlines & Indian Bank – Credit Policy Conspiracy

A recent alleged banking irregularity case involving officials of a reputed Indian bank and a prestigious airline conspiring to sanction and disburse loans of hundreds of crores in direct non-compliance to the bank’s credit policy.

Why Do People in Organisations Cause Risk?

Human errors, malicious actions or fraudulent intentions by people lead to loss or harm. While a lot of human errors can be caught, managed or prevented through organisation’s control, monitoring and governance mechanism, most malicious intentions and actions are often hard to identify, monitor or prove.

There are numerous examples across banks worldwide where losses were caused on the part of human errors with no malefic intentions. A lot of such people’s activities can be attributed to:

  • Lack of skills and inadequate professional training
  • Absence of sound standard operating procedures
  • Poorly defined roles and responsibilities
  • Chronic work overload and cognitive fatigue

More often, personal self-serving interest, inaccurate or flawed judgement or decisions, unhappy or disengaged employees, flawed internal organisation culture, greed, and lack of integrity in conducting one’s responsibilities are bigger behavioural misdemeanours that cause the greatest damages.

How Can Organisations Manage People Risks?

Clearly, organisations need to adopt a two-pronged approach to prevent and manage people risks:

Prong 1: Procedures and Systems

Deploy rigorous procedures, technical checks, and segregation of duties that can prevent (or correct) human errors from occurring in routine operational activities.

Prong 2: Cultural Response & Vigilance

Foster a robust cultural response and vigilance mechanism to deter people from engaging in wrong deeds, instilling deep behaviours of integrity, transparency, and personal responsibility.

A consistent high level of professional culture requires building of deep behaviours of integrity, transparency and responsibility among people. Any organisation’s long-term guard against people risks is hidden within these fortifying behaviours. The practice of these measures on a day-to-day basis by its people safeguards the organisation from any risks.

Instituting a People Risk Index

Organisations must institute a People Risk Index capable of showcasing real-time increasing or decreasing risk trends based on quantitative and qualitative human parameters, including:

• Knowledge and skills gap
• Control failure trend
• Fraudulent cases count
• Employee happiness level
• Development & growth opportunities
• Attrition / turnover trends
• Employee performance trend
• Incentive-evoked wrong doings
• Pay gaps among employees
• Manager-employee relationship

This index can then be complemented by risk-mitigating measures designed and applied consistently addressing each parameter. The composition of people parameters and their relative weightage over each other can vary for each organisation to ensure it remains dynamic and conducive to the progressing nature of the enterprise.

Information Technology and AI Can Help Prevent Much of People Risk

A robust People Risk Index which can deliver valuable information on people risk will require organisations to leverage or deploy IT-based capabilities. Appropriate IT intervention should be designed to bring together and analyze multitudes of people data from various internal systems, reports, applications as well as external environment.

Technologies such as Artificial Intelligence (AI) and Machine Learning (ML) can further make this complex data analysis more accurate, real-time, dynamic and relevant. These data will deliver people risk insights to senior management, people managers and HR through People Risk Index in real-time – enabling them to make informed, timely and impactful decisions in response to emerging or potential people risks and issues. Technology backed People Risk Index can enable organisations institute a culture of preventive measures to eliminate or mitigate high-impact people risks well in time.

Who Should Own People Risk in an Organisation? Role of the HR Function

The Board or Senior Management must consider People Risk as an accountable variable. However, the HR function in an organisation plays the vital role to drive management of People Risk given their influence and reach across the organisation. As People Risk is significantly associated with people behaviour, HR is best placed to take lead in this area and manage this by mobilizing resources, skills and systems with support from businesses and functions.

Strategic Initiatives for the HR Function:

  • Organisation-Wide Deployment: HR can develop a People Risk Index organisation-wide to assess, monitor and report People risks systematically.
  • Managerial Enablement: Training and awareness should be created among people managers on how to leverage the People Risk Index to proactively manage risk issues in their areas of responsibilities.
  • Incentive Realignment: Compensation and performance incentives for employees should be regularly aligned with findings of People Risk Index to ensure monetary rewards do not evoke risk-inducing or reckless behaviours among employees.
  • Culture & Ethics Enforcement: A culture of ethics and good conduct should be promoted, and individuals should be rewarded for consistently living these values in their daily roles and responsibilities.

To conclude, HR, from their position of strength in the organisation can regulate right behaviours, policies, procedures and systems by collaborating across all levels in the organisation in cohesive and synchronized manner – in support of making People Risk Management an inseparable cultural reality.

Conclusion

“People are Master Creators who can also act as ultimate destroyers.”

People Risk Management must be made an inseparable cultural reality within an organisation that manifests in every action and decision made by its people. Organisations must work continuously to nurture the Master Creator trait in their people.