ESG
Implementing Double Materiality
Double materiality is a foundational principle in successful ESG programs.
Jason Doel
January 8, 2024
8 best practices for getting the most out of incident management programs and for linking them to ERM programs.
One of the biggest benefits of incident tracking comes from tapping into the real-time experiences and insights of your team members on the front lines.
Often, incident tracking starts as a centralized exercise, in which a small group of users input incidents on behalf of other staff members. While this can be a valid way to get a program off the ground quickly, it is important to roll the process out widely across your organization as soon as possible.
Leaving incident tracking in the hands of a few reporters may lead to the perception that preventing incidents and managing risks is someone else’s job.
In contrast, empowering and expecting everyone in your organization to report incidents reinforces a positive culture of accountability and transparency for risk management.
Casting a broader net also increases the chances that you will catch incidents that otherwise may have fallen through the cracks. By responding and recovering quickly, you will limit damage that could have otherwise gone unchecked and reduce repeat incidents. A widely operationalized process also serves as a live early warning system, as smaller incidents may indicate that conditions are changing and that larger risks are materializing.
Programs are more successful when they start simple and iterate over time. There is a tradeoff between complexity and user acceptance. It does not matter how robust a process is if not enough people follow it. You will get further in the long run starting with a simple process and securing high user acceptance right from the start.
In practice, this means keeping your initial reporting template short and your process simple. Once users become comfortable and engaged in the process, you can add additional depth as needed - although we recommend doing so selectively and only when it adds clear business value.
In fact, the best programs are so easy and intuitive that end users can start following them right away with no (or minimal) training. This is an area where software can help. An intuitive and accessible incident portal will make the process faster, easier and more enjoyable for your users than giving them another boring spreadsheet to fill out.
An extension of making incident tracking available for everyone is making it available everywhere. An easy intake form that can be completed on a mobile device or tablet will lead to higher and faster reporting rates, by allowing users to report incidents and hazards when they are freshly observed and top of mind.
This is another reason to think twice about using spreadsheets. Doing so will require users to remember to fill out an incident report later when they return to their computer. The longer the delay between an incident occurring and an observer getting a chance to report it, the greater the chance they will forget or otherwise choose not to report it.
Maintaining user engagement in your incident tracking program over the long term requires transparency and a closed loop process that consistently gives feedback to incident reporters on investigation status and corrective measures.
If the people reporting incidents do not receive feedback, they will lose their incentive to continue reporting. Why would a user provide input if they think no one is listening and nothing will change? You can mandate users to fill in reports without providing feedback, but then it becomes a perfunctory compliance exercise that undermines the very culture of accountability and transparency that risk managers are typically trying to build in the first place.
While the concept of closing the loop may seem obvious, it is hard to do without an automated system. Spreadsheet-based systems require continual manual effort to provide updates. While this may be possible in the beginning when program enthusiasm is high, spreadsheet systems quickly become stagnant as priorities shift and staff changes occur.
If you plan to provide closed-loop feedback and your objective is to engage your end users, then you may benefit by incorporating principles of gamification.
Gamification, simply put, is making use of the fun and compelling elements of games in other activities, as a means of increasing user engagement and enjoyment. Potential examples include granting users badges and levels based on the value of their input and their responsiveness, as well as point systems and rewards (monetary and non-monetary). Again, this is an area where automated systems can help and you may need to engage your HR team, depending on how much you want to align your incentives with staff objectives and compensation plans.
Incident tracking programs provide valuable data for ERM and strategy management processes. The challenge, however, is that incident tracking can generate large volumes of data, making it difficult to separate the “signal from the noise” to derive actionable insights.
One easy, yet effective way to structure your incident data for better analysis, is to map each incident to the key elements of your enterprise risk program, including risks and their related root causes, controls/mitigations and consequences.
This may be a step that is reserved for appointed incident managers. For example, an end user may report an incident and provide their input on what they perceive to be the root causes and consequences of an incident. Then, in a second step, an authorized incident manager may map each incident to risks, root causes, mitigations, consequences, and KRI/KPIs in your ERM program.
Example incident mapped to root causes and risks in the Essential Incidents™ and Essential ERM® systems.
Bow tie diagrams likely this example from the Essential ERM® system are enhanced when elements are linked to historical data and provide a natural data visualization model.
How many times have you heard the expression “that’s an accident waiting to happen?” Health and safety managers have long observed that dealing with hazards and minor incidents early can reduce serious incidents later.
The same holds true of other types of business incidents as well - and from a financial perspective, it is much less expensive to prevent issues than it is to respond to them later.
Importantly, including the capture of near misses in your incident program also helps to promote a culture of transparency, accountability, and quality management. It signals to your staff that everyone is responsible for identifying and helping to fix hazards before they become larger problems. It focuses your people on continuous improvement and proactive
The concept of the Heimlich Pyramid is that serious incidents in the top tier are preceded by higher numbers of less serious incidents and near misses in the lower tiers.
Finally, a major benefit of incident tracking processes is the opportunity to learn from past events and near misses and to make continuous improvements that will improve your organization and reduce risk levels in the future.
This is another area where using an automated software package can help. Spreadsheet-based processes can be designed to include steps for lessons learned and corrective actions but they break down when it comes to follow through. The manual work required to ensure the loop is always closed, especially after the initial incident has been resolved and the pressure is off, is too much to be sustained over time. Manual processes may start off with enthusiasm, but they quickly break down through staff changes and shifting priorities.
