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How To Avoid The Non-Compliance Speed Trap (A Cynical View) – Part 1

by Nick Picone, Trust Your Supplier VP of Advisory Practice

“Regulatory fines and penalties for non-compliance are steep. In 2018, non-compliant firms were subject to $3.945 billion in penalties and another $794 million in judgments related to SEC investigations and complaints, while FINRA imposed $61 million in fines.” – What’s the True Overall Cost of Non-Compliance?, complysci (2019)

As illustrated by the above excerpt from a 2019 article, compliance challenges were an issue even before the pandemic hit. But when you learn that there were $3.945 billion in penalties – which is a significant number, in my opinion, what does it really represent? Is it a call to action or such an incomprehensibly large figure that makes you think, “wow,” and move on to pressing “right in front of you” demands?

Let’s face it, with the pandemic, war in Ukraine, persistent inflation, and a myriad of other “challenges” that we are facing, if it doesn’t affect you directly, $3.945 billion is someone else’s problem.

Even when you break down the numbers and demonstrate how non-compliance costs firms “nearly three times the cost of being compliant,” it does little to create a sense of urgency beyond passing awareness. By the way, the actual dollar figure for non-compliance in fiscal 2017 was $14.82 million. Conversely, the estimated cost to ensure your organization was compliant with existing regulations at that time was $5.47 million.

The Lens of Inertia

Like high blood pressure, inflation, and the fact that Netflix seems to cancel great series for no apparent reason, we all know compliance is “important,” but we can’t do anything about it, can we? There are so many other, more granular things to worry about from a collective and personal standpoint.

For example, at one of the many conferences I have attended over the past two months, it was alarming to see firsthand how many people had name badges that said “former” or “looking for work.

“My point in all this is that we have to, first of all, recognize the realities of the general mindset in our industry. How can you expect a procurement team to worry about carbon footprint and conflict minerals when there is so much economic uncertainty? Even in good times, there is a long history of “risk recognition and inaction.” A McKinsey 2006 survey provides compelling evidence of how risk avoidance was more a state of mind than an actual event.

While not as acute, the challenges we faced in 2006 are no different from those we face today regarding compliance. The question is this: why will our response be different this time?

One reason I think it will be different this time is that the cost of non-compliance increased by 2,650% from 2017-2019, which is the definition of exponential growth.

Ideal Conditions For A Speed Trap

“A hidden scaffolding of financial incentives underpins the policing of motorists in the United States, encouraging some communities to essentially repurpose armed officers as revenue agents searching for infractions largely unrelated to public safety.” – New York Times (2021)

According to one report, the average police officer writes 100 to 150 tickets each month. While that number can vary from city to city, town to town, it is safe to say that when it comes to moving violations such as speeding tickets, there is a noticeable police presence, e.g., speed traps at the end of the month. Yes, this is an anecdotal observation, more than a scientific conclusion. But does that make it any less accurate?

Here is the reality. During tough economic times, government deficits increase. There are primarily two ways to plug deficits. The first is to cut spending and the direct and indirect taxation of people and businesses. This approach rarely happens.

When you look at the size of fiscal deficits and all the fines that businesses across the globe will eventually face, you can see how governments understand that they have a unique speed trap set from an enforcement perspective, as companies have no good way to effectively and efficiently manage their large and extended supply networks from a compliance perspective.

To be clear, this is not an anti-government rant. It is a reality.

If you disagree with me, google the term “sin tax.”

According to one of many definitions, “sin taxes are usually placed on the sale of cigarettes, liquor, tobacco and other goods that are considered dangerous to individuals or society.”

There is a clear parallel here when you think about conflict minerals, global warming, modern slavery, data privacy, etc.; these are also societal issues that negatively affect us all.

Stay tuned for Part 2: How To Avoid The Non-Compliance Speed Trap (What’s The Opposite of Cynical?)

April Harrison Blog, Risk & Compliance 1 Comment ,

What Is The Real Cost Of Missing Or Inaccurate Data?

by Sai Nidamarty, Trust Your Supplier Co-Founder & CEO

Let’s get the cursory narrative regarding the cost of missing data out of the way first. 

We have all heard Peter Drucker’s business maxim, “If you can’t measure it, you can’t manage it,”. It is a timeless guidepost of how we run our businesses. By the way, Peter never actually said that, but that is a story for another day. 

 Then we can turn to the various articles and studies over the past few years reporting that bad or poor-quality data costs the U.S. economy $31 trillion annually. That’s a big number, and so is the finding that 90% of the world’s data was created in the last two years. 

The above are all facts and verifiable. But what do they really mean? What does missing or inaccurate data really cost on a practical, everyday level?  

There are better venues for a deep analysis than the limitations of an article or blog post. My focus today is to start a dialogue enabling you to transition data strategy from a broad horizon concept to an actionable on-the-ground understanding. In other words, you already know that data is important and that there are consequences for missing or inaccurate data. What’s needed now is to answer the question, what will you do about it? 

Data Challenges 

In an upcoming webinar, we will convene a panel of industry experts and thought leaders to closely examine data challenges from the following three critical points: 

  • Data consequence 
  • Data culture 
  • 3-Point centralized planning & supplier oversight data framework 

When we talk about “data consequence,” we are not talking about broad-stroke generalizations but a fundamental and accessible understanding of impact. 

For example, a news article reported that due to a data glitch, Hawaiian Airlines charged dozens of customers “hundreds of thousands of dollars in credit card fees.” 

One customer reported being “mistakenly charged more than $150,000,” even though they have a “$10,000 limit on their Hawaiian Miles credit card.”  

While another customer was charged $674,000 for airline tickets, others obtained free travel vouchers by paying taxes and associated fees. You can imagine the frustration when the airline canceled their flights. 

Beyond a financial mess, the airline’s reputation also took a significant hit. How do you measure that in dollars? 

Unfortunately, examples like the one above are not rare or isolated incidences limited to the travel industry. Nor do most cases present themselves in such a prominent and noticeable way. Data quality erosion is an even bigger problem because you may only recognize it once its impact is evident on a larger, less manageable scale. 

Creating The Right Culture 

Given the volatility of supply networks in the post-pandemic world, it isn’t surprising to hear the C-Suite talk about supply chain visibility, resilience, and risk management. 

A recent post by Nick Picone regarding a contentious issue about inflationary price increases between a large, national grocery chain and Frito-Lay underscores the importance of data visibility and transparency. 

But how do you get to the point of leveraging tools and technology to move from data darkness to data insight and understanding? 

A May 2021 article in Procurement Insights highlighted the importance of creating a data culture starting at the C-Suite level. According to the author, CEOs must “recognize the importance of data beyond a conceptual perspective and see it in a practical bottom-line context.” Citing everything from “customer satisfaction and regulatory compliance” to employee empowerment, they make a strong case for “becoming a data-driven organization.” 

The 3-Point Supplier Data Plan  

Partner, Mitigate, Comply is at the heart of the 3-Point centralized planning & supplier oversight data framework. Going forward, I will call it the 3-Point supplier data plan.   

The 3-Point supplier data plan focuses on providing tools and data for organizations to efficiently partner with trusted suppliers, mitigate risk, and ensure ongoing compliance.  

In addition to data consequence and culture, during the upcoming webinar, the panel will get into the specifics of the above 3-Point plan highlighting how you can introduce it to your organization. Register to save your seat. 

April Harrison Blog, Risk Management, Supplier Information Management 0 Comments

One Woman, Three Companies, Graceful Leadership: Meet Sri Mudunuri

Managing one global business in an ever-changing world is tough enough but managing three?! Now, that requires nearly superhuman leadership skills.  

Meet Sri Mudunuri, the co-founder of IT People Corporation, Chainyard, & Trust Your Supplier, who has been making a name for herself in the technology, staffing, and services industries. With 23 years of experience in the staffing and services industry and her desire to provide an end-to-end solution for her customers, Sri was moved to co-found Trust Your Supplier. Her motivation to become a leader stemmed from two female trailblazers, Indira Gandhi and Jayalalithaa, who played a significant role in shaping the future state of India. From a business perspective, Indra Nooyi, PepsiCo’s former CEO, and chairperson is Sri’s inspiration. 

Apart from being a co-founder, Sri also plays multiple roles in the organizations she leads. As a CFO, she manages financial activities and ensures the balance sheet lines up. As a President, she is responsible for board meetings, compliance with state and federal laws, and managing certifications from organizations such as WBENC and NMSDC.  In addition to all this, she also manages the staffing side of the business, Workforce Solutions, and keeps the recruitment team on their toes. 

The most significant obstacle Sri has faced in her career is proving herself to get the respect she (and all women) deserve. She noted that women must do more to get the same respect as men with the same title. But Sri’s persistence, ability to not take things personally, and work with trusted partners have helped her succeed. 

Sri’s advice to women who aspire to become leaders is simple: follow your dreams, be decisive, and don’t be afraid to make tough decisions. Sometimes conversations and decisions are tough, but we’re tougher.  

Let’s continue celebrating women’s history month by empowering and inspiring women to be anything and everything they want. 

April Harrison Blog, Spotlight 0 Comments ,

Breaking Barriers: TYS’s Michelle Armstrong, Global VP of Value Engineering

In 2023, women are defying expectations and shattering glass ceilings 👏 every 👏 single 👏 day. And Michelle Armstrong is a prime example of this. Michelle, who hails from Ireland, is the Global VP of Value Engineering at Trust Your Supplier, a position that requires her to excel in building strong relationships with clients, colleagues, and partners. And excel she most certainly does.

When you meet Michelle, it’s easy to see why she was chosen for this role. Her kind and intuitive nature makes her an expert in understanding and connecting with others. Her ability to know the minute details of all her customers’ schedules is a testament to her excellent organizational skills and attention to detail. It’s no wonder she’s been so successful in building strong relationships with people from all walks of life.

At Trust Your Supplier, Michelle leverages her exemplary change management skillset to analyze issues, devise continuous process improvements, and incorporate business process initiatives to increase efficiency and streamline operations. She excels in building strong relationships with clients and third-party vendors and is highly skilled in translating their business needs into key features for our product development team.

But Michelle’s success is not just about her skills and experience. It’s also about her determination and resilience in the face of adversity. She grew up in a society that expected women to marry farmers and take care of the home. Yet, she refused to be held back by these expectations and chose to follow her own path, which has taken her all over the world. Michelle is a role model for women everywhere, showing that it’s possible to have a successful career while also prioritizing family and personal relationships.

Despite her busy schedule, Michelle has been married to her husband for 30 years and has gracefully raised strong, independent, and humble children while traveling around the globe. She embodies the idea that balancing personal and professional life is possible while excelling in both.

In a world where women are still fighting for equality, Michelle’s success is a shining example of what’s possible. She proves that with determination, resilience, and a willingness to break through societal expectations, women can achieve anything they set their minds to. We can’t wait to see what she’ll accomplish next.

#womeninleadership #breakingbarriers #femaleempowerment #diversityandinclusion #leadership #successstories #careergoals #genderequality #womenwholead #inspiration #supplychain #vendormanagement #businessrelationships

April Harrison Blog, Spotlight 0 Comments ,

Digital Readiness and Your Degree For Success

Last week was one of the more interesting ones on the social media circuit, e.g., LinkedIn.

To start, a post referencing Dirk Spijkers raised an interesting debate regarding technology and partnerships. According to Spijkers, “at a high level, you must do more than provide great technology,” although great technology is still important. However, beyond the technology, you also “need to become a trusted “expert” partner who understands procurement organisations’ challenges across the enterprise and beyond.”

In my comment to that post, I said I would write an article about “breaking down the functional silos that limit the ability of internal and external stakeholders to work collectively toward a mutually beneficial outcome.” Today’s post is the fulfilment of that promise. I will also discuss the “critical role that a service provider will play in facilitating this collaboration to ensure seamless integration and user adoption.

The “Right” Skills

According to an August 2022 CIPS report, success in breaking down silos is directly linked to an organisation’s effectiveness at “facilitating collaboration to ensure seamless integration and user adoption” of new technologies. In short, and as intuitively user-friendly and effective digital tech – including AI is today, it still requires people with the right skills to work collaboratively toward a mutually beneficial result.

The report’s skills included “communication, internal stakeholder management, influencing, supplier relationship management, and negotiation.”

While the above observations sound entirely reasonable, a Deloitte Global Survey of CPOs indicates that a significant gap between recognition and realisation of skills still exists. The survey’s findings suggest that most CPOs are dissatisfied with the progress and results of their digital transformation strategies.

You may be wondering where I am going with this track. I will now come to the point. No matter how great the technology, digital success is built on the foundation of an organisation’s “digital readiness.” The core component of digital readiness means having the right talent and skills to communicate and collaborate with internal and external stakeholders. The collective and proactive application of these skills breaks down silos and paves the way for digital transformation success.

A Degree For Success

Several studies and corresponding articles indicate that in the five years leading up to the pandemic, many CPOs did not believe their existing teams possessed the necessary skills to deliver their strategic objectives. As I thought about these findings – which were somewhat surprising, a post by Iain Campbell-Mckenna caught my attention.

The post “Procurement’s Conscious Degree Bias” lamented the profession’s continuing practice of screening job candidates using a university or college degree as the proverbial “golden ticket” to get their foot in the door. How important is a candidate’s degree pedigree for choosing the next great hire? To what degree (excuse the pun) is having a diploma a predictor of success? Based on CPOs’ views of their team’s capabilities, prioritising education isn’t working.

There are a couple of great articles about “hiring for skills” by Chris Burt (University Business, July 2022) and Jonathan Finkelstein (Forbes May 2021) regarding the shift from diploma knowledge to “skilled experience.”

The message from a growing number of procurement industry experts and executives is becoming clear. Organisations need a team with the “right skills” to successfully break down the silos to achieve the level of digital readiness that leads to success.

Partner Skill and Experience Is Also Key

So, why am I talking about end-user skills as a solution provider?

Because when you are selecting a digital transformation partner, you have to look beyond the great technology to find the right skills, experience, and expertise to turn the digital promise into a digital success reality.

In a future post, I will talk about how you can assess a service provider’s technology and industry knowledge to optimise your success by leveraging advanced intelligent solutions.

Michelle Armstrong
TYS, Chief Relationship Officer

April Harrison Blog, Digital Transformation 0 Comments

How does improving supplier relationships through greater supply chain visibility help the battle against inflation/shrinkflation?

Inflation is a hot topic, and of course, outside of my personal wallet, my procurement background means that I usually view inflation/shrinkflation through a supply chain lens – more specifically, relationships and visibility.

For example, Dawn Tiura’s recent article on the introduction of a “grocery conduct code” was worthwhile reading for several reasons.

To start, citing the inflation battle between a large grocery retailer and Frito-Lay explains why price hikes are happening and why the manufacturer pulled some of my favorite snacks from the grocer’s shelves. By the way, some consumers have benefited from the situation because they discovered that alternative boutique brands were tastier and easier on the budget—more savings in their wallets.

That said, according to reports, by “providing clarity for business practices and establishing guiding principles” to “improve industry relationships” across supply chains, this new code will “ultimately benefit consumers as well.”

Of course, the code alone will not improve supply chain visibility resulting in a mutually positive buyer-supplier result. Companies will have to leverage real-time digital capabilities to assess market conditions and potential price hikes to allow them to collaborate on a solution with suppliers before it gets to the point of a loggerhead.

A State of Ready Visibility

The conduct code, or any legislative intervention, can be positive, especially when it “motivates” organizations to examine the state of their extended supply chains. I emphasize the words “extended supply chains.”

Not surprisingly, there is usually a greater familiarity and a much better understanding of the relationship with tier-one suppliers. These relationships can still be challenging, e.g., the retail grocer and Frito-Lay example from Dawn’s article.

What stood out to me from that example was the grocer’s ability to quickly tap into their second and possibly third-tier network to fill their empty shelves with quality product alternatives when their primary supplier stopped shipping their product.

It is clear that the retailer’s ability to engage their extended supply chain partners occurred long before the impasse with their leading supplier came to a head.

Here is the question: If you were to find yourself in the same position as the grocer, how quickly would you be able to identify and engage your next-tier suppliers? What is your state of ready visibility?

Extended Visibility by the Numbers

According to McKinsey, many organizations wouldn’t be able to respond to disruption by inflation or otherwise as quickly as they would need to or would want. Only 21 percent of companies have “visibility beyond their tier-one suppliers,” with only 2 percent having sufficient insight to engage their tier-three suppliers on short notice effectively.

Regardless of whether you are contending with inflation or geopolitical instability, or any other possible or probable supply chain challenge having complete line-of-site visibility throughout all tiers of your extended supply network is a state of readiness you should always want to achieve.

Nick Picone
Trust Your Supplier VP of Advisory Practice

April Harrison Blog, Supply Chain 0 Comments

Team Member Spotlight: Director of Product Strategy & Solutions

“Rowing harder doesn’t help if the boat is headed in the wrong direction.” -Kenichi Ohmae 

Our Trust Your Supplier (TYS) platform doesn’t remain static. Data, market conditions, and new regulations are constantly in flux, which means the information our customers need invariably changes on a regular basis. 

With a distinct ability to anticipate and scan the global environment for signals of change, Shyam Adivi serves as our Director of Product Strategy and Solutions. As a strategic leader, Shyam engages with our customers and partners to determine the direction of TYS’s roadmap.  

Shyam’s strategy around features, timings, and offerings is often influenced by external occasions and regulations that affect procurement, supply chain, risk and compliance management, and digital transformation. 

With these insights, Shyam aligns our customers’ needs with a streamlined development process. The results are an agile, innovative platform that provides continuous value and business results for our customers and partners. 

April Harrison Blog, Spotlight 0 Comments

The “Q” Word – Questionnaires

A favorite character in the James Bond series (other than James himself) is Q. Q always has these amazing hi-tech gadgets that save James from a certain demise at just the right time. Explosive alarm clocks, the Knife Shoe, exploding pens, a submarine Lotus Esprit, and of course the attacking sofa. He also has little patience for James and his laissez-faire attitude.  Q is cool.  

For your suppliers, what’s not cool is the “Q” word: Questionnaires.

Suppliers receive and return countless questionnaires containing dozens to hundreds of questions from each customer. Many of these questions are similar from customer to customer with slight variations and various formats. Just google “supplier questionnaires” and you’ll be overwhelmed with many template options and suggestions of what to include in your questionnaires. 

So as a procurement organization, what should you include in your questionnaires? And how do you keep them up to date? Key global risks, evolving market conditions, geopolitical issues, and new compliance mandates require revisions to your questionnaires to collect crucial pieces of information from your suppliers. This is necessary to mitigate any risk to your organization. 

Each time a company sends out a questionnaire or sends an updated questionnaire, the supplier must respond to each customer separately. The queue for having your specific questionnaire updated and returned can be quite lengthy, therefore creating a lag in the transfer of information. This lag leads to stale data and a lack of visibility to manage your company’s risk in current market conditions.

So, what’s the solution?  The “S” word: Standardization. Trust Your Supplier (TYS) has pulled together a conglomerate of major buying organizations to develop a set of questionnaires that are standardized. These questionnaires cover industry, location, and buyer-specific issues that allow each organization to assign the relevant questionnaires to their suppliers. And these questionnaires are kept updated to reflect new requirements and regulations.

Here’s an example of how it works: 

A set of questionnaires can be assigned to a supplier by a customer. Once those questionnaires have been completed and published by the supplier, the procurement team can review the answers. But there’s more!  Suppliers can then share the same completed questionnaires with other customers…with just a click of a button. So instead of sending the same 200 answers separately to each customer, the supplier now just needs to focus on any unique questions a customer may have. This dramatically reduces the supplier’s administrative burden as well as the onboarding time and keeps their information current and accurate.  

Let’s suppose this supplier has added a new product and now they are working with conflict minerals. No problem. The supplier can update the Conflict Minerals questionnaire and once published, the system will automatically notify every connected customer. The supplier’s new motto is now: “Do Once, Share with Many.”

These standardized questionnaires offer additional benefits to buyer teams. The TYS approvals workflow can be customized and automated with each questionnaire. Each answer can be “scored” based on your internal risk threshold. Any answer that does not align with your company’s preferred score will then be directed to the appropriate team role for further review and approval. This allows your team to focus on undesirable answers rather than spending time reviewing all answers.

Another TYS feature that softens the blow of the Q word is Questionnaire Groups. Depending on the supplier segmentation strategy, buyer organizations can use a targeted approach to send relevant questionnaires to a configured group of suppliers. These groups are customized by the buyer team and then assigned as a group to suppliers that fit into that category (i.e., location). This simplifies the questionnaire assignment process for the buyer team. 

And the newest TYS feature is Predictive Questionnaires. Buyer teams can create a set of rules that will predict which questionnaires should be assigned to a particular supplier. This is tremendously valuable as new compliance regulations and laws come into play throughout the world, and provides the opportunity to reach more of your supplier base without further manual outreach.

Ultimately, standardization and automation result in benefits for both supplier and buyer organizations. The reduction in the onboarding cycle time allows transactions to occur faster and there is reduced administrative effort on both sides. Buyer organizations can also then benefit from having full visibility into their supplier base for strategic decision-making and risk management.  

Check out a real example of how quickly suppliers can complete their profiles and questionnaires on the TYS system.

April Harrison Blog, Risk & Compliance, Risk Management, Supplier Information Management 0 Comments , , , ,

UN Anti-Corruption & Human Rights 2022

As part of our mission, Trust Your Supplier allows organizations to manage a broad spectrum of subject areas to inform compliance with global regulations. We would like to recognize the work being done by the United Nations in the areas of Anti-Corruption and Human Rights. 

Over the next couple of days, the United Nations will launch yearlong campaigns to recognize the 75th anniversary of the Universal Declaration of Human Rights and the 20th anniversary of the United Nations Convention against Corruption. These issues impact areas such as financial, human potential, societal trust, and our future.  

Read more about the Cost of Corruption and how ‘dirty money’ breaks everything – and what we can do to fight back here: https://undp.medium.com/the-cost-of-corruption-a827306696fb  

Learn more about the Universal Declaration of Human Rights here: https://www.standup4humanrights.org/en/declaration.html  

#UnitedAgainstCorruption #IACD2022 #UNCAC20 #STANDUP4HUMANRIGHTS 

April Harrison Blog, Risk & Compliance 0 Comments
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