Organisations today are increasingly reliant on a complex web of suppliers and outsource providers to help them run their business, and many have third parties numbering in the high hundreds or thousands. A growing number of incidents in company supply chains, borne out by recent high-profile outages causing wide-spread disruption, have caught the attention of senior management, and regulators are also increasingly focussing in on this area.
For some organisations, supplier risk management remains an area that hasn’t always kept pace with other developments. At the same time, organisations’ work on operational resilience, management of supplier-related technology and cyber risks, and their focus on managing sustainability-related risks and objectives through their supply chain, mean procurement teams require an increasingly broad focus. This could be seen as a necessary change to focus on downside risk. But with the right approach, organisations can enhance resilience, improve efficiency, access capacity and capability - and support the business to accelerate growth, meet its objectives and deliver on its strategy.
Below, we outline key areas that organisations should consider for effective supplier risk management, and what best practices look like.
With so many third parties to consider, it’s not practical to apply the same level of oversight and assessment rigour to all suppliers, irrespective of their impact on cost, risk and resilience and their strategic importance. Resource constraints, information overload and supplier responsiveness can worsen challenges.
Firms with effective supplier risk management frameworks adopt a proportionate and risk-based approach. They maintain a clear view of all their suppliers, key opportunities, risk and resilience drivers, and their relative criticality to the organisation. These definitions of criticality support an assessment of the downside risks and upside potential of any given relationship, which correspond to clear requirements in respect of due diligence, wider pre-onboarding activity, and ongoing monitoring.
When this works well, there is a joined-up approach across procurement, technology, risk, and operations teams, and clear ownership and responsibilities to support embedding. Good management information (MI) helps maintain focus on the performance of the most material suppliers, risks, and actions, and in turn monitors the delivery of meaningful business outcomes. However, without a robust framework, firms may lack the necessary oversight and control, leading to increased risks and inefficiencies.
For increasing numbers of organisations, leveraging Governance, Risk, and Compliance (GRC) or supplier management systems helps reduce some of administrative and operational burden of supplier management.
Over the last three years, organisations have been using the regulatory transition period to build resilience in line with regulatory objectives on operational resilience. This has required firms to set impact tolerances for their most important business services (IBS) – those that if disrupted could cause intolerable harm to customers, financial stability of the organisation, or threaten the integrity of the market. Organisations have been required to take steps to ensure they are able to continue to deliver their IBS within impact tolerances, including in the event of severe but plausible operational disruption.
Firms doing this well have built on strong foundations in resource mapping and testing, with a clear line of sight through mapping, vulnerability assessment, scenario development, testing of technical recovery capabilities and operational preparedness, and remediation as required. However, without a robust framework, firms may struggle to maintain resilience, leading to increased risks and potential disruptions.
Organisations are increasingly focusing on increasing their understanding of the third parties that enable delivery of organisations’ IBSs, and how through testing, business continuity and exit strategies, they can continue to operate within impact tolerances in the event of disruption. The most effective approaches are those that are joined-up across business functions and related areas of testing and engage suppliers through the process. This helps them to enhance dialogue and understanding, enabling them to build trust and confidence in their partners, and an alignment in culture as well as process.
Cyber supplier risk management is crucial in today’s interconnected digital world. This has been evidenced by numerous high-profile supply chain cyber-attacks and related incidents that have crippled organisations, causing significant financial and reputational damage. These events highlight the critical need for a robust and resilient supply chain capable of responding effectively to incidents. No organisation is immune to a cyber attack, but they can be more resilient and better prepared to respond.
It’s essential that suppliers adhere to minimum standards to protect data, maintain business continuity and that organisations can assess whether suppliers are maintaining those minimum standards. This is not a simple task and organisations that do this well are able to identify the cyber risk profiles of each supplier in its eco-system. These organisations are classifying suppliers beyond the normal tier one-three, with some extending this to four-five and sub-contractors. Once the risk is quantified, appropriate and comprehensive work can be delivered to maintain baseline standards for a range suppliers with different risk profiles. An important and often overlooked aspect of supplier management is also the internal ‘supplier’, or group relationships, which also exist but should be treated similarly.
Nevertheless, a challenge for many procurement teams is interpreting, at times what can be, highly complex technical policies, controls and processes deployed by suppliers. Expert analysis is critical in delivering a robust and comprehensive analysis. The use of well-defined and tested cyber frameworks, such as the UK’s National Cyber Security Centre’s Cyber Assessment Framework or the US’s National Institute of Standards and Technology’s Cybersecurity Framework, can help establish key domains to assess and set minimum standards. These frameworks focus on technical controls and security, but also emphasise key governance arrangements, employee awareness and, importantly, how prepared the business is to respond and recover from attacks. This comprehensive approach ensures that organisations are better equipped to handle cyber threats and maintain operational continuity.
Moving from a mere box-ticking exercise to expert analysis of key technical controls is essential, especially for high-risk suppliers. A superficial compliance check may overlook critical vulnerabilities, whereas a thorough analysis can identify and mitigate potential emerging threats. Well-developed organisations have shifted to deliver this alongside proactive ongoing external testing of key suppliers to evaluate how effectively some of these controls and process are being deployed. They then analyse this information, complemented by active threat intelligence of wider data sources, such as the dark web. This could be the difference between identifying a significant risk and mitigating it or falling victim to another significant business interruption with potentially catastrophic implications.
The cloud supply chain is a complex network of numerous organisations and processes involved in delivering agile technology solutions. It’s not just the major cloud service providers (CSPs) like AWS, Azure, and Google Cloud that supply compute resources and capabilities; it’s an entire ecosystem of technology providers working to optimise technology architecture through coding.
Cloud technology leverages software capabilities for agility, which differs from traditional data centre resource provisioning. Cloud services, particularly Software as a Service (SaaS) applications, consist of loosely coupled services often developed by a diverse group of global developers.
To mitigate cloud supply chain risks, organisations should implement processes for detecting third-party risks, including asset inventory and visibility into effective permissions. Compliance and assurance mechanisms should ensure that third-party technology vendors adhere to the same internal security standards as the organisation. Cloud security compliance requirements should be embedded within the supplier onboarding process (e.g., procurement), periodic vulnerability scans, secure configuration of SaaS solutions, and regular supplier audits to identify vulnerabilities.
By addressing these risks proactively, organisations can better secure their cloud environments and maintain the integrity of their supply chains.
SS2/21 is more than a compliance or tick-box exercise, it requires changes both to how organisations manage outsourcing and to their broader operating models. Organisations need to make changes in five key areas of their operating model to embed resilience into their operating models.
Today, suppliers not only support the delivery of organisations’ services, but are key to achieving their sustainability-related goals. While many organisations we speak with have made good progress implementing responsible procurement processes, it’s not always clear whether they’re asking the right questions, or how the information is being used. Part of the challenge is that sustainability is often being looked at discretely, outside of the procurement process.
Organisations with more effective approaches avoid standalone responsible procurement processes. They define how sustainability is being considered at each stage of the procurement process, including risk assessment and due diligence, ongoing monitoring and performance, and set minimum expectations at each stage. This makes it clear how sustainability informs supplier selection and decision making.
The principle of proportionality, as set out above, also applies here. The level of questioning should be proportionate to the risk, and it should be understood how sustainability is considered alongside other risk factors when making decisions. Equally, information on suppliers’ greenhouse gas (GHG) emissions is increasingly required for emissions reporting, but it should be clear how all information collected is being used.
When it comes to engagement, efforts should be targeted at those partners that are identified as having the most significant impact on the overall sustainability profile of the organisation; the principal reason for engaging suppliers on sustainability is to ensure there is an alignment of interests, particularly over sustainability objectives and climate transition plans.
To build resilience in today’s complex supply chains, organisations need a holistic approach to supplier risk management. By focusing on robust frameworks for supplier oversight, operational resilience, cyber security, technology, change and transformation, and sustainability, organisations can reduce risks, improve efficiency, and support growth. Effective collaboration between teams is key to ensuring a resilient and adaptable supply chain that can withstand disruptions and help drive long-term success.
Crowe can assist by implementing a holistic approach to improve effectiveness, build resilience, and increase efficiency in your supply chain. For more information, please contact Justin Elks, Tim Robinson, Mustafa Iqbal or your usual Crowe contact.
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