
Risk Management Culture:
The Linkage Between Ethics & Compliance and ERM
September 14, 2009
2009 Compliance and Ethics...
Table of contents
Section Page
1 Learning objectives 3
2 Why measure risk culture 5
3 Risk management concepts 8
4 Definin...
3PricewaterhouseCoopers
Section 1 Learning objectives
Section 2 Why measure risk culture
Section 3 Risk management concept...
4PricewaterhouseCoopers
Objectives
At the conclusion of this session, you will learn:
• How a strong risk culture supports...
5PricewaterhouseCoopers
Section 1 Learning objectives
Section 2 Why measure risk culture
Section 3 Risk management concept...
6PricewaterhouseCoopers
What CEOs are saying about risk
Section 2 – Why measure risk culture
CEOs recognize the importance...
7PricewaterhouseCoopers
Why measure risk culture
Manage change
• Increasingly difficult economic climate
• Increased press...
8PricewaterhouseCoopers
Section 1 Learning objectives
Section 2 Why measure risk culture
Section 3 Risk management concept...
9PricewaterhouseCoopers
Defining enterprise risk management (ERM)
Section 3 – Risk management concepts
Enterprise risk man...
10PricewaterhouseCoopers
ERM concepts
Section 3 – Risk management concepts
2
Enterprise Risk Management – Integrated Frame...
11PricewaterhouseCoopers
ERM supports the achievement of entity objectives
Section 3 – Risk management concepts
Enterprise...
12PricewaterhouseCoopers
Components of ERM
Section 3 – Risk management concepts
Enterprise Risk Management – Integrated Fr...
13PricewaterhouseCoopers
Monitoring
Information and communication
Control activities
Risk response
Risk assessment
Event i...
14PricewaterhouseCoopers
Section 1 Learning objectives
Section 2 Why measure risk culture
Section 3 Risk management concep...
15PricewaterhouseCoopers
It’s important to measure culture – But which one
Section 4 – Defining “Risk Culture”
Risk cultur...
16PricewaterhouseCoopers
Organizational culture
Section 4 – Defining “Risk Culture”
Addresses a broad variety of employee ...
17PricewaterhouseCoopers
Ethical culture
Section 4 – Defining “Risk Culture”
Typically covers:
• Observed behaviors
• Know...
18PricewaterhouseCoopers
Risk culture
Section 4 – Defining “Risk Culture”
Risk culture is the way all members of an organi...
19PricewaterhouseCoopers
Risk culture
Section 4 – Defining “Risk Culture”
• Risk culture is related to, but distinctly dif...
20PricewaterhouseCoopers
Section 1 Learning objectives
Section 2 Why measure risk culture
Section 3 Risk management concep...
21PricewaterhouseCoopers
Benefits of measuring risk culture
Section 5 – Measuring risk culture
• Can help to streamline GR...
22PricewaterhouseCoopers
ERM and S&P ratings
Section 5 – Measuring risk culture
S&P ratings criteria
ERM
Liquidity
Earning...
23PricewaterhouseCoopers
How are leading companies measuring their risk
management culture
Section 5 – Measuring risk cult...
24PricewaterhouseCoopers
Key attributes and sub-attributes of effective
risk management
Section 5 – Measuring risk culture...
25PricewaterhouseCoopers
Key attributes, sub-attributes and key indicators of effective
risk management
Section 5 – Measur...
26PricewaterhouseCoopers
Risk culture survey questionnaire design
Section 5 – Measuring risk culture
27PricewaterhouseCoopers
Risk culture survey questionnaire design
Section 5 – Measuring risk culture
28PricewaterhouseCoopers
Risk culture survey questionnaire design
Section 5 – Measuring risk culture
29PricewaterhouseCoopers
Section 1 Learning objectives
Section 2 Why measure risk culture
Section 3 Risk management concep...
30PricewaterhouseCoopers
Leveraging the output of the risk culture assessment
Section 6 – Leveraging risk culture results
...
31PricewaterhouseCoopers
Measuring risk culture – Some keys to effectiveness
Section 6 – Leveraging risk culture results
•...
32PricewaterhouseCoopers
Key themes
Section 6 – Leveraging risk culture results
• Given this economic environment, it's mo...
33PricewaterhouseCoopers
Next steps
Section 6 – Leveraging risk culture results
• Know what vehicles are already in place ...
34PricewaterhouseCoopers
Resources
Bobby Kipp
PricewaterhouseCoopers LLP
617-530-4602
barbara.h.kipp@us.pwc.com
Colby Ton
...

© 2009 PricewaterhouseCoopers LLP. All rights reserved. "PricewaterhouseCoopers" refers to
PricewaterhouseCoopers LLP ...
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Risk Management Culture: The Linkage Between Ethics & Compliance and ERM (2009 Compliance & Ethics Institute 103)

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The presentation includes: what constitutes an effective risk management culture and why it is a key foundation of a sustainable ERM program, how risk management culture relates to and reinforces the organization's ethics and compliance objectives as well as broader objectives, and how risk management culture will factor into addressing S&P's upcoming ratings process

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  • Also – in this world where it’s really hard to get resources, you need to find ways to leverage other efforts, and collaborate
  • Research shows that during times of change, incentives and pressures increase, so therefore fraud and misconduct increases
    Companies are being asked to do more with less, which causes strain on resources
    2008 concluded, and 2009 began, with corporate fraud once again dominating newspaper headlines. These teach, if there was any doubt, that fraud, corruption, waste and abuse soar in bad times.
    Economic turmoil can expose past fraud and, perhaps more importantly, hatch new ones. Incentive, pressure and opportunity abound. Even "good" people can become ensnared, perhaps simply for concealing a mistake out of fear of losing their job in a time of high employment.
    The ACFE, which surveys perception of fraud, estimates that U.S. organizations annually lose U.S. $1 trillion or about 7% of revenue to fraud. The Economist Intelligence Unit surveys, which surveys actual detection of fraud, reports that 85% of companies suffered a major fraud over the past 3 years. For large companies, the average was $23._ million, although over 10% reported losses of more than $100 million.
  • Key point here is:
    Lots of attention on importance of culture in E&C programs…and importance of E&C programs in culture
    So, which elements of culture can and should be assessed in your company?
    This model (depicted on slide) suggests that E&C culture is a subset of risk culture. And that risk culture is a subset of org culture
    Or otherwise said, org culture includes risk culture which includes E&C culture
    We’re going to talk about all 3 now
  • Organizational culture assessments typically focus on human resource issues, such as whether employees feel their compensation is fair, whether they receive timely evaluations, or whether they have the proper supervision and development.
    Organizational culture assessments usually measure risk or ethical culture at a very high-level, if at all.
  • Ethics culture – at the center of the circles – this group is familiar with these
    Observed behaviors: of leaders, supervisors, co-workers – Questions like perception of internal vs external integrity
    Knowledge and comfort: knowledge of resources for expressing concerns, comfort in reporting
    Responsibilities: not only perception of responsibility to follow standards but also responsibilties to report, help others, etc
    Organization’s response : do they believe the company takes misconduct seriously, etc.
  • Risk culture is related to, but distinctly different from, organizational culture and ethical culture. Measuring risk culture addresses control and risk management principles more directly than tools that measure organizational culture, and encompasses a broader base of issues pertinent to governance, risk and compliance.
    While E&C culture assessments tend to focus very specifically in individual behavior and direct drivers
    And organization culture get all things the institution does and the overall work experience and environment
    Risk culture bridges both
    Risk culture assessments generally delve into a much more explicit evaluation of attitudes, such as how well management assesses and measures risk, or how well it establishes processes and controls to mitigate that risk.
    By taking that deeper dive to assess their risk culture, companies can glean information that can help them tie together key elements of governance, such as tone at the top, strategy, and attitudes toward risk-taking.
    Analyzing and monitoring the results of risk culture assessments can help companies identify specific points of focus, such as issues, sites or business units that do not align with its governance, risk and compliance (GRC) objectives.
    A strong risk and control environment can help streamline a company's overall SOX effort by giving the company tools to both take credit for strong company-level controls (CLCs), and to make improvements in CLCs, as necessary.
  • Risk culture is related to, but distinctly different from, organizational culture and ethical culture. Measuring risk culture addresses control and risk management principles more directly than tools that measure organizational culture, and encompasses a broader base of issues pertinent to governance, risk and compliance.
    While E&C culture assessments tend to focus very specifically in individual behavior and direct drivers
    And organization culture get all things the institution does and the overall work experience and environment
    Risk culture bridges both
    Risk culture assessments generally delve into a much more explicit evaluation of attitudes, such as how well management assesses and measures risk, or how well it establishes processes and controls to mitigate that risk.
    By taking that deeper dive to assess their risk culture, companies can glean information that can help them tie together key elements of governance, such as tone at the top, strategy, and attitudes toward risk-taking.
    Analyzing and monitoring the results of risk culture assessments can help companies identify specific points of focus, such as issues, sites or business units that do not align with its governance, risk and compliance (GRC) objectives.
    A strong risk and control environment can help streamline a company's overall SOX effort by giving the company tools to both take credit for strong company-level controls (CLCs), and to make improvements in CLCs, as necessary.
  • In today’s business environment of transparency, companies often establish governance, risk and compliance oversight functions of departments, regions, and processes in isolation, giving each function a separate mission, scope and procedures, creating a lot of waste and duplication.
    Measuring risk culture can be a critical component in developing and enhancing an integrated approach to governance, risk and compliance.
    The information gained from a risk culture assessment can be used to drive value beyond just the ethics and compliance organization to the broader risk and organizational culture.
    Results of the risk culture survey can encourage collaboration between organizational units by sharing feedback that is also useful for senior management, internal audit, risk management, and others involved in establishing and maintaining strong controls.
  • Standard & Poor’s recently announced that the effectiveness of Enterprise Risk Management will be considered in evaluating credit ratings of non-financials.
    As a part of S&P’s approach, the risk governance and culture of the organization will be considered. This includes all lines of reporting, internal and external risk management communications and policies that reinforce risk management.
    S&P’s ERM review for nonfinancial companies will be based primarily on information provided by issuers in public disclosures and through discussions with S&P analysts. Sample discussion topics may include:
    What are the company’s top 5 risks, how big are they, and how often are they likely to occur? How often is the list of top risks updated?
    What is management doing about top risks?
    What size quarterly operating or cash loss has management and the board agreed is tolerable?
    Describe the staff responsible for risk management programs and their place in the organization chart. How do you measure success of risk management activities?
    How would a loss from a key risk impact incentive compensation of top management and on planning/budgeting?
    Tell us about discussions about risk management that have taken place at board level or among top management when making strategic decisions.
    Give an example of how your company responded to a recent “surprise” in your industry and describe whether the surprise affected your company and others differently.
  • Discuss pros and cons of each method.
    For example, automated survey is anonymous; easy to aggregate/summarize data; quick to complete; reaches a broad sampling of people, etc.
    Examples of other existing data which can provide indications of risk culture include:
    Absenteeism statistics
    Time sheets/expense reports - percent completed on time?
    Participation rates on surveys
    Analysis of Hotline/Help Desk calls logged
    Annual compliance confirmations - percent completed on time?
    Tracking what percent of staff are reading company communications/newsletters
    Mandatory training courses – percent completed on time?
    Employee performance evaluations – percent completed on time?
    What does this say about your organization?
  • Our research (MONICA – is this correct? What research did we do?) Not sure how much you want to say of this, but for your own knowledge…back when the RCS was first established in ’94/’95 there was a team of partners – including Brian Kinman, Rick Steinberg and others - who designed these analysis categories, using the COSO framework as a guide, and also based on studying a broad range of successful companies and determining what key elements are necessary for an organization to be considered a ‘well controlled company’) has found that four key attributes contribute most to effective organizational risk management
    Cover the 4 on next slide
  • The Risk Culture Survey questions are categorized and analyzed along the following framework, a hierarchy of risk categories known as the Key Attributes, Sub-Attributes and Key Indicators of effective risk management and control.
    Many of these indicators – for ex personal ethical practices, incentives, discipline – are things you are currently looking at in the context of your E&C program
    What we suggest is to look broader
    Note areas on communication (w/in leadership and also within people& comm) – you may be familiar with ERC’s research on ERA’s (ethics-related actions) of managers, supervisors and co-workers – well, one of these ERA’s is keeping employees informed about what’s going on in the org – how many of you are measuring your employees perception of this?
  • The next three slides depict real questions from the RCS, primarily falling into the E&C space.
  • What’s in a name? – if you call it an “ethics survey” will you get skewed responses (rose colored glasses)?
    Slice & dice – look for pockets of excellence or the opposite – understand them in the context of the business. Just because some lower than others does not mean a problem (for ex, country cultural differences – for ex PwC Germany example and PwC Nigeria example)
    Sell benefits outside E&C – i.e. this stuff also helps HR (driving employee engagement), BU leadership, IA,
  • If companies are thinking about implementing and/or enhancing their ERM program, we recommend to keep it simple and practical, as oftentimes companies will get too wrapped up in the process and buried in information overload. Sometimes a more simple program = a more effective program.
  • Risk Management Culture: The Linkage Between Ethics & Compliance and ERM (2009 Compliance & Ethics Institute 103)

    1. 1.  Risk Management Culture: The Linkage Between Ethics & Compliance and ERM September 14, 2009 2009 Compliance and Ethics Institute
    2. 2. Table of contents Section Page 1 Learning objectives 3 2 Why measure risk culture 5 3 Risk management concepts 8 4 Defining “Risk Culture” 14 5 Measuring risk culture 20 6 Leveraging risk culture results 29
    3. 3. 3PricewaterhouseCoopers Section 1 Learning objectives Section 2 Why measure risk culture Section 3 Risk management concepts Section 4 Defining “Risk Culture” Section 5 Measuring risk culture Section 6 Leveraging risk culture results
    4. 4. 4PricewaterhouseCoopers Objectives At the conclusion of this session, you will learn: • How a strong risk culture supports a successful ethics, compliance and Enterprise Risk Management (ERM) program • What is “Risk Culture” and how it is different from organizational culture and ethics culture • What constitutes an effective risk management culture • How risk management culture impacts your S&P credit rating and cost of capital • How leading companies are measuring risk management culture Section 1 – Learning objectives
    5. 5. 5PricewaterhouseCoopers Section 1 Learning objectives Section 2 Why measure risk culture Section 3 Risk management concepts Section 4 Defining “Risk Culture” Section 5 Measuring risk culture Section 6 Leveraging risk culture results
    6. 6. 6PricewaterhouseCoopers What CEOs are saying about risk Section 2 – Why measure risk culture CEOs recognize the importance of risk information to the success of their organizations… 92% Agree that information about risk is either important or critical to their long-term success 23% But only 23% of them believe they have comprehensive information about risk to their business. …but lack actionable information to allow for effective risk decisions with clarity and confidence Source: PricewaterhouseCoopers’ 2009 CEO Survey
    7. 7. 7PricewaterhouseCoopers Why measure risk culture Manage change • Increasingly difficult economic climate • Increased pressure to reduce costs and “do more with less” Improve risk management • Create a consistent culture of effective risk management • Reduce risk management costs • Avoid duplication of risk management effort • Proactively manage S&P credit ratings Avoid fraud & misconduct • Economic pressures can encourage fraud and misconduct Become more “Risk Resilient” • Informed business decisions with confidence and clarity • The ability to sustain growth regardless of business condition or economic climate by leveraging risk to avoid hazard, manage uncertainty and capitalize on opportunity Section 2 – Why measure risk culture
    8. 8. 8PricewaterhouseCoopers Section 1 Learning objectives Section 2 Why measure risk culture Section 3 Risk management concepts Section 4 Defining “Risk Culture” Section 5 Measuring risk culture Section 6 Leveraging risk culture results
    9. 9. 9PricewaterhouseCoopers Defining enterprise risk management (ERM) Section 3 – Risk management concepts Enterprise risk management is a process, effected by an entity’s board of directors, management and other personnel, applied in strategy setting and across the enterprise, designed to identify potential events that may affect the entity, and manage risk to be within its risk appetite, to provide reasonable assurance regarding the achievement of entity objectives.1 1 Enterprise Risk Management – Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission (COSO); ©2004
    10. 10. 10PricewaterhouseCoopers ERM concepts Section 3 – Risk management concepts 2 Enterprise Risk Management – Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission (COSO); ©2004 Enterprise risk management is: • A process, ongoing and flowing through an entity • Effected by people at every level of an organization • Applied in strategy setting • Applied across the enterprise, at every level and unit, and includes taking an entity level portfolio view of risk • Designed to identify potential events that, if they occur, will affect the entity and to manage risk within its risk appetite • Able to provide reasonable assurance to an entity’s management and board of directors • Geared to achievement of objectives in one or more separate but overlapping categories.2
    11. 11. 11PricewaterhouseCoopers ERM supports the achievement of entity objectives Section 3 – Risk management concepts Enterprise Risk Management – Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission (COSO); ©2004 Strategic High-level goals, aligned with and supporting the entity’s mission Operations Effective and efficient use of entity resources Reporting Reliability of reporting Compliance Compliance with applicable laws and regulations Monitoring Information and communication Control activities Risk response Risk assessment Event identification Objective setting Internal environment
    12. 12. 12PricewaterhouseCoopers Components of ERM Section 3 – Risk management concepts Enterprise Risk Management – Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission (COSO); ©2004 • Eight interrelated components • Derived from the way management runs an enterprise • Integrated into management processes Monitoring Information and communication Control activities Risk response Risk assessment Event identification Objective setting Internal environment
    13. 13. 13PricewaterhouseCoopers Monitoring Information and communication Control activities Risk response Risk assessment Event identification Objective setting Internal environment Components of ERM – Internal environment Section 3 – Risk management concepts Enterprise Risk Management – Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission (COSO); ©2004 The internal environment encompasses the tone of an organization, and sets the basis for how risk is viewed and addressed by an entity’s people, including risk management philosophy and risk appetite, integrity and ethical values, and the environment in which they operate.
    14. 14. 14PricewaterhouseCoopers Section 1 Learning objectives Section 2 Why measure risk culture Section 3 Risk management concepts Section 4 Defining “Risk Culture” Section 5 Measuring risk culture Section 6 Leveraging risk culture results
    15. 15. 15PricewaterhouseCoopers It’s important to measure culture – But which one Section 4 – Defining “Risk Culture” Risk culture is related to, but distinctly different from, organizational culture and ethical culture. Organizational culture Risk culture Ethical culture
    16. 16. 16PricewaterhouseCoopers Organizational culture Section 4 – Defining “Risk Culture” Addresses a broad variety of employee attitudes on topics such as: • Compensation • Strategy • People issues • Processes • Management • Job satisfaction • Job responsibilities
    17. 17. 17PricewaterhouseCoopers Ethical culture Section 4 – Defining “Risk Culture” Typically covers: • Observed behaviors • Knowledge and comfort • Responsibilities • Organization’s response
    18. 18. 18PricewaterhouseCoopers Risk culture Section 4 – Defining “Risk Culture” Risk culture is the way all members of an organization feel and behave about risk, including employees' attitudes toward risk as it relates to their daily operating activities and management’s view of risk in relation to decision-making processes.
    19. 19. 19PricewaterhouseCoopers Risk culture Section 4 – Defining “Risk Culture” • Risk culture is related to, but distinctly different from, organizational and ethical culture. • Addresses control and risk management principles more directly • Encompasses a broader base of issues pertinent to governance, risk and compliance (GRC)
    20. 20. 20PricewaterhouseCoopers Section 1 Learning objectives Section 2 Why measure risk culture Section 3 Risk management concepts Section 4 Defining “Risk Culture” Section 5 Measuring risk culture Section 6 Leveraging risk culture results
    21. 21. 21PricewaterhouseCoopers Benefits of measuring risk culture Section 5 – Measuring risk culture • Can help to streamline GRC processes • Reduces duplication of efforts • A critical component in developing and enhancing an integrated approach to governance, risk and compliance • The information gathered provides value to the broader risk and organizational culture • Encourages collaboration between organizational units and functions
    22. 22. 22PricewaterhouseCoopers ERM and S&P ratings Section 5 – Measuring risk culture S&P ratings criteria ERM Liquidity Earnings Financial flexibility Management strategy Capital adequacy Market position Investments Over the past two years,10% of financial institutions analyzed had their rating either downgraded or upgraded due to their ERM score. Risk Management Culture Risk controls Emerging risk management Strategic risk management Risk and capital models Risk management culture governance Risk controls Emerging risk preparedness Strategic risk management PIM Liquidity Capital adequacy Financial sector Energy/Commodity sector Non-Financial sector
    23. 23. 23PricewaterhouseCoopers How are leading companies measuring their risk management culture Section 5 – Measuring risk culture • Surveys • Interviews • Focus groups • Other existing data which can provide indications of risk culture
    24. 24. 24PricewaterhouseCoopers Key attributes and sub-attributes of effective risk management Section 5 – Measuring risk culture The Risk Culture Survey is designed to help an organization identify their key strengths and potential issues related to the risk and control environment, categorized along PwC’s four key attributes for effective risk management:
    25. 25. 25PricewaterhouseCoopers Key attributes, sub-attributes and key indicators of effective risk management Section 5 – Measuring risk culture Leadership & strategy Accountability & reinforcement • Integrity & Ethical Values - Tone at the Top - Personal ethical practices • Communicate Mission & Objectives - Policies & procedures - Top-down alignment of strategy • Assignment of Authority & Responsibility - Assignment of ownership - Demonstrated accountability • HR Polices & Practices & Performance Measurement - Performance indicators - Incentives & discipline People & communication Risk management & infrastructure • Commitment to Competence - Employee competence - Training • Information & Communication - Information quality - Top-down communication • Identify & Assess Risk - Risk assessment practices - Risk tools & processes • Establish Processes & Controls - Process reliability & efficiency - Control effectiveness & efficiency
    26. 26. 26PricewaterhouseCoopers Risk culture survey questionnaire design Section 5 – Measuring risk culture
    27. 27. 27PricewaterhouseCoopers Risk culture survey questionnaire design Section 5 – Measuring risk culture
    28. 28. 28PricewaterhouseCoopers Risk culture survey questionnaire design Section 5 – Measuring risk culture
    29. 29. 29PricewaterhouseCoopers Section 1 Learning objectives Section 2 Why measure risk culture Section 3 Risk management concepts Section 4 Defining “Risk Culture” Section 5 Measuring risk culture Section 6 Leveraging risk culture results
    30. 30. 30PricewaterhouseCoopers Leveraging the output of the risk culture assessment Section 6 – Leveraging risk culture results • Internal audit plan • Broader ERM assessment • Strategic planning • S&P evaluation • Component of SOX/Entity level controls • HR employee engagement initiatives • Ethics and compliance initiatives
    31. 31. 31PricewaterhouseCoopers Measuring risk culture – Some keys to effectiveness Section 6 – Leveraging risk culture results • Longitudinal view • External comparability • What’s in a name? • Slice and dice it • Sell the benefits outside E&C
    32. 32. 32PricewaterhouseCoopers Key themes Section 6 – Leveraging risk culture results • Given this economic environment, it's more important than ever to have a strong risk management culture • Risk management culture is an integral component to an effective and sustainable ERM program • Get to know your risk management culture well • Find out who else is interested in getting involved in assessing your risk management culture • Be proactive rather than reactive • Don’t overcomplicate
    33. 33. 33PricewaterhouseCoopers Next steps Section 6 – Leveraging risk culture results • Know what vehicles are already in place to assess current risk culture - E.g. employee attitude survey, ERM related measures • Take inventory of other risk management activities inside the organization, such as Internal Audit, ERM, strategic planning, regulatory, and compliance • Leverage and collaborate with these resources to perform an assessment of your risk management culture • Evaluate and communicate results to appropriate parties • Develop action plan, accountability and ongoing monitoring to strengthen known problem areas
    34. 34. 34PricewaterhouseCoopers Resources Bobby Kipp PricewaterhouseCoopers LLP 617-530-4602 barbara.h.kipp@us.pwc.com Colby Ton PricewaterhouseCoopers LLP 214-981-7144 colby.g.ton@us.pwc.com
    35. 35.  © 2009 PricewaterhouseCoopers LLP. All rights reserved. "PricewaterhouseCoopers" refers to PricewaterhouseCoopers LLP (a Delaware limited liability partnership) or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. Thank You 2009 Compliance and Ethics Institute

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