Operational Risk Management
Identification, assessment, and management of operational risks in your organization
- Process Risk Management
- Business Continuity Management
- Outsourcing Risk Management
Effective Management of Non-Financial Risks
Non-Financial Risk Management
Comprehensive consulting for the identification, assessment, and management of non-financial risks in your organization.
- 01Regulatory Compliance
- 02Improved Risk Resilience
- 03Optimized Business Processes
11+Years of experience
120+Employees
540+Projects
ISO 27001certified
Comprehensive Non-Financial Risk Management
We support you in developing and implementing effective strategies and processes for managing non-financial risks that meet regulatory requirements while supporting your business objectives.
Our consulting services in Non-Financial Risk Management include the identification and assessment of non-financial risks, the development of tailored risk management frameworks, and the implementation of effective control and monitoring systems. We support you in adapting to regulatory requirements such as the 5th MaRisk amendment and the EBA Guidelines on ICT Risk Assessment, and in integrating non-financial risks into your overall risk management.
3 service modules
Service scope
Cyber and IT Risk Management
Protection of your IT infrastructure and data from cyber threats
- IT Risk Assessment and Management
- Cyber Security Concepts
- Data Protection and Information Security
Compliance and Anti-Financial Crime
Compliance with regulatory requirements and combating financial crime
- Anti-Money Laundering and KYC
- Compliance Management Systems
- Fraud Prevention and Forensics
3 phases
Our Approach
We guide you with a structured approach in developing and implementing your Non-Financial Risk Management.
Analysis of existing risk situation and processes
Development of tailored risk management frameworks
Implementation, training, and continuous improvement
Your contact
Melanie Düring
Head of Risk Management
Our Strengths
- 01Deep expertise in regulatory requirements (BaFin, EBA)
- 02Experience with advanced risk management methods
- 03Proven implementation strategies with demonstrable success
Expert Tip
Organizations with integrated NFR management systems experience 37% lower regulatory penalties and respond 28% faster to market disruptions.
20 QUESTIONS, BRIEFLY ANSWERED
Frequently asked questions about Non-Financial Risk
What are non-financial risks and why are they important?
Non-Financial Risks (NFR) encompass all risks that are not directly related to financial market movements or credit defaults, but can still have significant financial and reputational impacts:
🔍 **Definition and Delineation**
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**Operational Risk**: Risks from internal processes, systems, human error, or external events
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**Compliance Risks**: Risks from non-compliance with laws, regulations, and internal policies
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**Cyber and IT Risks**: Threats to IT infrastructure, data security, and system availability
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**Reputation Risks**: Potential damage to the organization's reputation and brand
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**ESG Risks**: Risks related to environmental, social, and governance factors
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**Conduct Risk**: Risks from inappropriate behavior by employees or business partners
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**Strategic Risks**: Risks from poor decisions in business model development
📊 **Significance for Organizations**
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**Financial Impact**: NFR can lead to significant financial losses (e.g., business interruptions, fines, legal costs)
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**Regulatory Focus**: Increasing supervisory requirements for managing non-financial risks
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**Reputation Damage**: Long-term negative effects on customer trust and market position
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**Strategic Implications**: Influence on business decisions, product development, and market expansion
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**Competitive Advantage**: Effective NFR management as a market differentiator
⚙ ️ **Management Challenges**
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**Quantification**: Difficulty in measuring and assessing qualitative risks
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**Data Quality**: Limited historical data for risk modeling and forecasting
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**Interdependencies**: Complex interactions between different risk types
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**Risk Transfer**: Limited options for hedging or transferring non-financial risks
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**Cultural Aspects**: Need for enterprise-wide risk culture and awareness
What are the regulatory requirements for Non-Financial Risk Management?
Regulatory requirements for Non-Financial Risk Management have increased significantly in recent years and include various regulations and standards: **BaFin and MaRisk** **5th MaRisk Amendment 2023**: Explicit requirements for integrating NFR into risk-bearing capacity calculations **Three-Lines-of-Defense Model**: Mandatory implementation with central NFR management unit **Risk Capital Quantification**: Requirement to use advanced scenario analysis methods **Annual Stress Tests**: Mandatory execution for critical NFR categories such as cyber resilience or ESG compliance
🇪 🇺 **European Banking Authority (EBA)** **EBA Guidelines on ICT Risk Assessment (2024)**: Standardized KRIs (Key Risk Indicators) for IT system disruptions **EBA NFR Reporting Standard v2.1**: 78 mandatory data elements for risk disclosure **SREP Process**: Integration of NFR into the supervisory review and evaluation process **Proportionality Principle**: Requirements dependent on size, complexity, and risk profile of the institution **International Standards** **Basel Committee on Banking Supervision**: Guidelines for operational risk management **ISO 31000:2024**: Risk management standard with expanded focus on AI-based risk early detection **COSO ERM 2023.
How do you develop an effective Non-Financial Risk Management Framework?
Developing an effective Non-Financial Risk Management Framework requires a structured approach and integration of various components: **Fundamental Architecture** **Governance Structure**: Clear definition of roles, responsibilities, and reporting lines **Three-Lines-of-Defense Model**:
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First Line: Business units with risk identification obligation via Embedded Risk Controls
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Second Line: Central NFR unit for methodology development and risk aggregation
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Third Line: Independent risk audits by internal audit **Risk Taxonomy**: Development of organization-specific NFR taxonomy with at least 150 risk drivers **Risk Appetite**: Definition of quantitative and qualitative risk appetite statements for all NFR categories **Methodological Components** **Risk Assessment Methodology**: Combination of qualitative and quantitative approaches **Scenario Analysis**: Development of plausible worst-case scenarios for critical risks **Key Risk Indicators (KRIs)**: Definition of early warning indicators with thresholds **Control Framework**: Systematic capture and assessment of controls **Loss Data Collection**: Systematic capture and analysis of loss events **Technology Support** **GRC Platforms**: Integrated Governance, Risk & Compliance systems **Automated Control Testing**: Continuous.
What role does the Three-Lines-of-Defense Model play in NFR management?
The Three-Lines-of-Defense Model forms the organizational backbone of effective NFR management and defines clear responsibilities:
🏢 **First Line of Defense**
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Business units with direct risk identification obligation
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Embedded Risk Controls in business processes
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Daily risk management activities
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Responsibility for risk mitigation measures
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Regular self-assessments (Risk Control Self Assessments)
🔍 **Second Line of Defense**
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Central NFR unit for methodology development
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Risk aggregation and reporting
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Monitoring compliance with policies
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Development of risk management frameworks
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Support for First Line on complex risk issues
🔎 **Third Line of Defense**
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Independent risk audits by internal audit
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Review of risk management effectiveness
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Reporting to board and supervisory board
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Identification of improvement opportunities
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Independent assessment of risk situation
⚙ ️ **Implementation Aspects**
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Clear delineation of responsibilities
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Avoidance of duplication and control gaps
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Establishment of effective communication channels
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Regular review of model effectiveness
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Adaptation to organizational changes
How can non-financial risks be quantified?
Quantifying non-financial risks requires advanced methods that combine qualitative and quantitative approaches:
📊 **Statistical Modeling Approaches**
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Monte Carlo simulations for reputation risk quantification
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Bayesian Belief Networks for modeling cascading risk effects
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Extreme Value Theory for tail-risk events
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Multivariate regression models for risk driver analysis
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Copula functions for modeling risk dependencies
🔢 **Scenario Analysis Techniques**
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Structured expert workshops for scenario development
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Reverse Stress Testing for critical risk scenarios
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Multi-factor scenarios with correlation analyses
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Historical simulation based on loss data
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Forward-Looking Assessments with future projections
📱 **Data-Driven Approaches**
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Natural Language Processing for text data analysis
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Social Media Sentiment Analysis for reputation risks
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Machine Learning for anomaly detection
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Process Mining for identifying process risks
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Big Data Analytics for pattern recognition
🧮 **Risk Metrics and KRIs**
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Risk Exposure Reduction Rate (annual reduction of risk profile)
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Control Effectiveness Index (effectiveness of implemented controls)
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Regulatory Gap Closure Velocity (time to close compliance gaps)
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Risk-Weighted Asset Equivalent for NFR capital allocation
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Expected Loss vs. Unexpected Loss modeling
What role do ESG risks play in Non-Financial Risk Management?
ESG risks (Environmental, Social, Governance) have evolved into a central component of NFR management:
🌍 **Environmental Risks**
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Climate change risks (physical and transition risks)
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Resource scarcity and biodiversity loss
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Environmental pollution and waste management
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Energy efficiency and renewable energy
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Carbon footprint and emissions reduction
👥 **Social Risks**
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Labor standards and human rights
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Diversity and inclusion
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Health and safety in the workplace
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Data protection and information security
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Community relations and social impacts
🏛 ️ **Governance Risks**
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Corporate ethics and compliance
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Board structure and compensation
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Transparency and disclosure
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Anti-corruption and bribery
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Risk management and internal controls
📋 **Regulatory Requirements**
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EU Taxonomy for sustainable activities
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Corporate Sustainability Reporting Directive (CSRD)
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Sustainable Finance Disclosure Regulation (SFDR)
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Task Force on Climate-related Financial Disclosures (TCFD)
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Supply Chain Act and Due Diligence requirements
How do you integrate cyber risks into NFR management?
Integrating cyber risks into NFR management requires a specialized approach:
🔒 **Cyber Risk Taxonomy**
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Data theft and loss
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System failures and business interruptions
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Ransomware and malware attacks
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Social engineering and phishing
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Advanced Persistent Threats (APTs)
🛡 ️ **Cyber Risk Assessment**
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Threat Intelligence and Vulnerability Scanning
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Penetration testing and Red Team exercises
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Cyber Risk Scoring and quantification
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Attack Surface Management
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Third-Party Cyber Risk Assessment
📊 **Cyber KRIs and Metrics**
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Mean Time to Detect (MTTD) for security incidents
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Mean Time to Respond (MTTR) for Incident Response
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Patch Management Compliance Rate
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Security Awareness Training Completion Rate
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Successful Phishing Simulation Rate
🔄 **Cyber Resilience**
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Incident Response Planning and Testing
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Cyber Crisis Management
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Backup and Recovery strategies
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Cyber insurance and risk transfer
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Cyber emergency exercises and simulations
What role does AI play in modern NFR management?
Artificial Intelligence is revolutionizing NFR management through effective applications:
🔍 **Risk Identification and Early Detection**
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Natural Language Processing for analyzing regulatory changes
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Anomaly detection in transaction and behavioral data
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Automated identification of new risk sources
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Predictive Analytics for emerging risks
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Sentiment Analysis for reputation risks
📊 **Risk Assessment and Quantification**
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Machine Learning for risk assessment models
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Deep Learning for complex risk patterns
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Automated scenario analysis and simulation
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AI-supported correlation analysis between risk factors
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Reinforcement Learning for risk mitigation strategies
🛠 ️ **Risk Control and Monitoring**
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Continuous Control Monitoring with AI support
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Automated compliance checks
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AI-supported fraud detection
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Robotic Process Automation for control testing
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Computer Vision for physical security controls
⚠ ️ **Challenges and Risks**
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Explainability and transparency of AI decisions
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Data quality and availability
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Model risks and Algorithmic Bias
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Ethical implications of AI applications
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Regulatory requirements for AI systems
How do you measure the success of NFR management?
Measuring success in NFR management requires a differentiated system of metrics:
📉 **Risk Reduction Metrics**
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Risk Exposure Reduction Rate (annual reduction of risk profile)
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Incident Frequency Reduction (reduction in incident frequency)
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Loss Event Reduction (reduction in loss amounts)
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Near-Miss Reporting Rate (reporting of near-miss incidents)
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Risk Mitigation Completion Rate (completion of risk mitigation measures)
🎯 **Control Effectiveness Metrics**
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Control Effectiveness Index (effectiveness of implemented controls)
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Control Testing Coverage (coverage through control testing)
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Control Deficiency Remediation Time (time to remediate control weaknesses)
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Automated vs. Manual Controls Ratio (ratio of automated to manual controls)
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Control Self-Assessment Completion Rate (completion of self-assessments)
💼 **Business Value Metrics**
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Regulatory Fine Avoidance (avoided regulatory penalties)
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Capital Requirement Reduction (reduction in capital requirements)
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Operational Efficiency Gains (efficiency improvements)
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Insurance Premium Reduction (reduction in insurance premiums)
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Reputation Value Protection (protection of reputation value)
🔄 **Process Metrics**
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Issue Resolution Time (time to resolve issues)
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Regulatory Gap Closure Velocity (time to close compliance gaps)
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Risk Assessment Completion Rate (completion of risk assessments)
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Training Completion Rate (completion of training)
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Reporting Timeliness and Accuracy (timeliness and accuracy of reporting)
How do you integrate NFR management into corporate strategy?
Strategic integration of NFR management requires a comprehensive approach:
🎯 **Strategic Alignment**
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Alignment with corporate goals and strategy
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Integration into strategic planning processes
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Consideration in business decisions
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Risk-oriented resource allocation
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Strategic risk tolerance definition
🏛 ️ **Governance Integration**
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Board responsibility for NFR management
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Regular reporting to supervisory bodies
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Integration into decision-making processes
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Risk-oriented compensation systems
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Clear responsibilities at all levels
💼 **Business Process Integration**
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Embedding risk controls in core processes
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Risk assessment in product development
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Integration into project management methods
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Risk-oriented budgeting
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Consideration in outsourcing decisions
🌱 **Cultural Integration**
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Promotion of positive risk culture
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Risk awareness at all levels
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Open communication about risks
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Learning from mistakes and incidents
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Continuous improvement of risk management
What role do reputation risks play in NFR management?
Reputation risks present a special challenge in NFR management:
🔍 **Characteristics of Reputation Risks**
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Difficult to quantify and often subjective
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Rapid spread through social media
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Long-term effects on brand and trust
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Often secondary effect of other risk types
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High relevance for all stakeholders
📊 **Assessment Approaches**
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Social Media Sentiment Analysis
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Reputation Scorecards and Indices
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Stakeholder Perception Surveys
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Media Coverage Analysis
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Brand Value Assessment
🛡 ️ **Preventive Measures**
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Proactive stakeholder management
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Transparent communication strategy
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Ethical business practices
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Corporate Social Responsibility
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Crisis management preparation
🔄 **Reactive Measures**
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Fast and transparent crisis communication
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Stakeholder engagement in crisis situations
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Remediation and compensation
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Lessons Learned and process improvements
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Long-term reputation recovery
How does NFR management differ across industries?
NFR management has industry-specific characteristics:
🏦 **Financial Services Sector**
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Strict regulatory requirements (MaRisk, BAIT, EBA Guidelines)
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Focus on Operational Risk and Compliance
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Quantitative capital requirements for operational risks
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High importance of cyber and fraud risks
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Comprehensive reporting obligations to supervisory authorities
🏭 **Industrial Sector**
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Focus on supply chain and production risks
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High relevance of ESG and sustainability risks
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Integration into quality and safety management
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Technology risks in Industry 4.0• Product liability and product safety risks
🏥 **Healthcare**
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Patient safety as top priority
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Strict data protection requirements
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Regulatory compliance for medical devices
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Risks in clinical trials
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Ethical risks in medical decisions
🛒 **Retail and Consumer Goods**
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Focus on supply chain and reputation risks
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Product safety and recall management
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Data protection for customer data
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E-commerce-specific risks
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Sustainability and ethical sourcing
How do you develop effective Key Risk Indicators (KRIs)?
Developing effective Key Risk Indicators (KRIs) follows a structured process:
🎯 **Characteristics of Effective KRIs**
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Relevance for specific risks
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Measurability and quantifiability
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Predictive character (early warning indicators)
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Action-oriented and controllable
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Cost-effective data collection
📊 **Development Process**
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Identification of relevant risk drivers
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Definition of thresholds and escalation levels
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Determination of data sources and collection methods
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Validation through historical data and expert assessments
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Regular review and adjustment
🔢 **KRI Types by Risk Categories**
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Operational Risk: Process error rates, system downtime
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Compliance Risk: Training rates, compliance violations
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Cyber Risk: Security incidents, patch management metrics
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Conduct Risk: Customer complaints, employee turnover
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ESG Risk: CO2 emissions, diversity metrics
📈 **Reporting and Monitoring**
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Integration into risk dashboards
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Trend analyses and benchmarking
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Correlation analyses between KRIs
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Automated alerting mechanisms
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Regular reporting to management
How do you implement effective incident management for non-financial risks?
Effective incident management for non-financial risks includes several key components:
🔍 **Incident Identification and Classification**
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Clear definition of incidents and near-misses
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Multi-layered classification by severity and risk type
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Low-threshold reporting options for employees
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Automated detection through monitoring systems
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Timely escalation of critical incidents
🛠 ️ **Incident Response and Management**
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Defined incident response processes
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Clear responsibilities and escalation paths
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Cross-functional incident response teams
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Documentation of all measures and decisions
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Communication strategies for internal and external stakeholders
📊 **Root Cause Analysis and Lessons Learned**
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Structured methods for cause analysis (5-Why, Fishbone)
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Identification of system weaknesses and control deficiencies
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Development of sustainable corrective measures
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Knowledge transfer and organizational learning
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Follow-up and effectiveness review of measures
📈 **Incident Reporting and Analysis**
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Central incident database
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Trend analyses and pattern recognition
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Quantification of losses and impacts
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Regular reporting to management
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Integration into overall risk management
How do you integrate outsourcing risks into NFR management?
Integrating outsourcing risks requires a specialized approach in NFR management:
🔍 **Risk Assessment Before Outsourcing**
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Due diligence review of potential service providers
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Criticality assessment of the function to be outsourced
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Analysis of country and jurisdictional risks
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Assessment of information security and data protection measures
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Review of Business Continuity provisions
📋 **Contractual Safeguards**
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Service Level Agreements (SLAs) with clear performance metrics
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Audit and access rights for controls
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Data protection and information security clauses
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Exit strategies and transition arrangements
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Liability and indemnification provisions
🔄 **Ongoing Monitoring**
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Regular performance reviews
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Continuous risk assessment
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Monitoring of key indicators
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Regular audits and controls
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Monitoring of sub-outsourcing activities
🛡 ️ **Governance and Oversight**
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Clear responsibilities for outsourcing management
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Regular reporting to management
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Escalation paths for issues and incidents
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Coordination with other risk functions
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Regular review of outsourcing strategy
How do you integrate compliance risks into NFR management?
Integrating compliance risks into NFR management requires a systematic approach:
📋 **Compliance Risk Assessment**
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Regulatory Mapping and gap analysis
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Compliance Risk Assessment methodology
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Prioritization based on impact and probability
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Consideration of reputational and financial impacts
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Assessment of control effectiveness
🔍 **Compliance Monitoring**
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Continuous Compliance Monitoring
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Regulatory Change Management
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Compliance Testing and Reviews
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Whistleblowing systems and complaint management
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Compliance Incident Tracking
📊 **Compliance Reporting**
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Integrated compliance dashboards
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Escalation of critical compliance risks
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Regular reporting to management and supervisory bodies
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Regulatory Reporting to supervisory authorities
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Transparent communication of compliance topics
🛠 ️ **Compliance Controls**
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Preventive controls (policies, training)
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Detective controls (monitoring, testing)
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Corrective controls (remediation, sanctions)
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Automation of compliance controls
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Integration into business processes
What role does Business Continuity Management play in the NFR framework?
Business Continuity Management (BCM) is an integral part of the NFR framework:
🔄 **BCM Lifecycle**
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Business Impact Analysis (BIA)
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Risk assessment and scenario analysis
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Development of continuity strategies
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Implementation of Business Continuity plans
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Testing, exercises, and continuous improvement
🎯 **Key Components**
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Recovery Time Objectives (RTOs) and Recovery Point Objectives (RPOs)
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Critical business functions and processes
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IT Disaster Recovery Planning
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Crisis management and emergency plans
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Alternative workplaces and remote work
📊 **BCM Metrics and KRIs**
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BCM maturity measurement
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Test and exercise effectiveness
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Recovery times in tests and real incidents
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Plan update frequency
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Employee awareness and training
🔗 **Integration into NFR Framework**
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Alignment with operational risk assessments
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Coordination with cyber resilience
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Consideration in outsourcing management
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Integration into crisis management
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Reporting within NFR reporting
How do you develop a positive risk culture for NFR management?
Developing a positive risk culture is crucial for effective NFR management:
👥 **Cultural Fundamentals**
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Tone from the Top: Leadership role modeling
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Open communication about risks without blame
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Appreciation of risk awareness and proactive action
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Transparency about risks and incidents
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Continuous learning from mistakes and near-misses
🎓 **Training and Awareness**
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Regular risk management training for all employees
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Role-specific training for risk officers
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Practical case studies and simulations
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Communication campaigns on risk topics
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Integration into onboarding processes
🎯 **Incentive Systems and Performance Management**
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Integration of risk management in performance evaluations
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Recognition for proactive risk management
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Avoidance of incentives for excessive risk-taking
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Consequences for non-compliance with risk policies
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Rewards for reporting risks and near-misses
📊 **Culture Measurement and Development**
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Regular risk culture surveys
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Culture indicators and metrics
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Targeted measures for culture development
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Benchmarking with other organizations
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Continuous improvement of risk culture
How do you integrate NFR management into mergers and acquisitions (M&A)?
Integrating NFR management into M&A processes is crucial for transaction success:
🔍 **Due Diligence Phase**
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Assessment of target company's NFR profile
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Identification of risk hotspots and compliance gaps
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Assessment of risk management maturity
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Analysis of historical incidents and losses
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Assessment of risk culture and governance
💰 **Valuation and Negotiation Phase**
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Quantification of identified risks
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Pricing of risks into valuation
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Negotiation of warranties and guarantees
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Development of risk mitigation strategies
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Planning of post-merger integration from risk perspective
🔄 **Integration Phase**
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Harmonization of risk management frameworks
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Integration of risk processes and systems
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Cultural integration and change management
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Training and knowledge transfer
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Monitoring of integration risks
📊 **Post-Integration Monitoring**
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Monitoring of risk indicators
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Assessment of integrated control effectiveness
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Identification of new or changed risks
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Adaptation of NFR framework to new organization
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Lessons Learned for future transactions
What does the future of NFR management look like?
The future of NFR management will be shaped by several trends and developments:
🤖 **Technological Innovations**
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AI and Machine Learning for risk early detection
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Quantum Computing for complex risk simulations
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Blockchain for transparent and tamper-proof risk data
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Internet of Things for real-time risk monitoring
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Automation and Robotics for control testing
🌐 **Regulatory Developments**
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Increasing integration of ESG into risk management requirements
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Enhanced requirements for cyber resilience
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Harmonization of international standards
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Focus on non-financial reporting
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Regulation of AI and algorithmic decisions
📊 **Methodological Advancements**
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Integration of behavioral economics into risk models
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Dynamic and adaptive risk modeling
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Real-time risk assessment and management
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Improved quantification methods for qualitative risks
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Integrated consideration of risk and opportunity
🔄 **Organizational Trends**
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Stronger integration into strategic decision processes
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Agile risk management approaches
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Decentralization of risk responsibility
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Enhanced collaboration between risk functions
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Development of specialized NFR competence centers
