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CORPORATE GOVERNANCE – Interesting Examples of Self- Assessments
Self-evaluations are now seen in other forum and make useful points of comparison for anyone undertaking a comprehensive look at this vital area.
In 2006, the OSC drafted NI 81-107 – Independent Review Committee for Investment Funds. The National Instrument sets out a comprehensive code of the Independent Review Committee’s role and functions and includes a requirement for the IRC to conduct self-evaluations as set out below.
These regular assessments also ask the IRC to evaluate the adequacy and effectiveness of the manager’s work product and adherence to policies, procedures and standing instructions. Query whether a board might someday be called upon to do something similar in evaluating and commenting on its management’s effectiveness and disclosing same to the stakeholders.
Enjoy reading the section from NI 81-107 and of the OSC’s Commentary.
4.2 Regular assessments
(1) At least annually, the independent review committee must review and assess the adequacy
and effectiveness of
(a) the manager’s written policies and procedures required under section 2.2;
(b) any standing instruction it has provided to the manager under section 5.4;
(c) the manager’s and the investment fund’s compliance with any conditions imposed by
the independent review committee in a recommendation or approval it has provided
to the manager; and
(d) any subcommittee to which the independent review committee has delegated, under
paragraph 3.11(1)(d), any of its functions.
(2) At least annually, the independent review committee must review and assess
(a) the independence of its members; and
(b) the compensation of its members.
(3) At least annually, the independent review committee must review and assess its effectiveness
as a committee, as well as the effectiveness and contribution of each of its members.
(4) The review by the independent review committee required under subsection (3) must include
a consideration of
(a) the independent review committee’s written charter referred to in section 3.6;
(b) the competencies and knowledge each member is expected to bring to the
independent review committee;
(c) the level of complexity of the issues reasonably expected to be raised by members in
connection with the matters under review by the independent review committee; and
(d) the ability of each member to contribute the necessary time required to serve
effectively on the independent review committee.
Commentary
1. Section 4.2 sets out the minimum assessments the independent review committee
must perform. Subject to these requirements, the IRC may establish a process for
(and determine the frequency of) additional assessments as it sees fit.
2. The annual self-assessment by the IRC should improve performance by strengthening
each member’s understanding of his or her role and fostering better communication
and greater cohesiveness among members.
3. When evaluating individual performance, it is expected that the IRC consider factors
such as the member’s attendance and participation in meetings, continuing education
activities and industry knowledge. The manager may also provide IRC members with
feedback which the IRC may consider.
It is expected the self-assessment should focus on both substantive and procedural
aspects of the IRC’s operations. When evaluating the IRC’s structure and
effectiveness, the IRC should consider factors such as the following:
• the frequency of meetings;
• the substance of meeting agendas;
• the policies and procedures that the manager has established to refer matters to the
IRC;
• the usefulness of the materials provided to the members of the IRC;
• the collective experience and background of the members of the IRC;
• the number of funds the IRC oversees; and
• the amount and form of compensation the members receive from an individual
investment fund and in aggregate from the fund family.
4. The CSA expect the members of an IRC to respond appropriately to address any
weaknesses found in a self-assessment. For example, it may be necessary to improve
the IRC members’ continuing education, recommend ways to improve the quality and
sufficiency of the information provided to them, or recommend to the manager
decreasing the number of investment funds under the IRC’s oversight.
In rare circumstances, the IRC may consider removing a member of the IRC as
contemplated under paragraph 3.10(2)(c) as a result of the self-assessment.
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CORPORATE GOVERNANCE – How to create the questionnaire
While it is now accepted practice that companies should undertake a self-evaluation, there has been a tendency to develop a questionnaire and to leave it unaltered year on year. This has led to the concern that it has become a “tick the box” exercise and a less than useful one for the directors, the organization and for the stakeholders.
In order to be properly drafted, the Chair must work with the committee chairs to set the questions that will determine and measure whether individual and collective responsibilities are being met. The questionnaire should begin with rudimentary matters such as attendance, preparedness, courtesy and then move to the more advanced areas such as meeting committee mandates and corporate objectives. The former questions are most important to the smooth functioning of a board and can be the issues that begin to undermine its functioning. Think of your own reaction to a colleague who is perennially late or ill-prepared or who dominates conversation with matters irrelevant to the discussions.
But it is the latter group of questions which speak to whether the board is effective. Those questions are not easily drafted but are key to the evaluation.
There is no doubt that the questionnaire must be customized by the organization to reflect its business, the mandates of its board committees and any matters that are specific to the organization. The questions must reflect where the company is in its life cycle. Presuming it is a start-up, then it is important that an organization begin with a questionnaire and that one director or third party take the responsibility for collating the information and disseminating it to the directors. It should have set of questions pertaining to the organization and board as a whole and some specific to the individual directors. The responses pertaining to the individual directors should initially only be reported to them and not to the group. If however there is an “across the board” view of one director, then the Chair ought to become involved. If the Board is dysfunctional, then a third party and perhaps even a lawyer, may need to become involved to give much needed distance to the directors giving difficult answers.
Whither third party interviews? In order to avoid a tick the box exercise, some organizations use director interviews. This may involve more cost as often the interviews are conducted by third parties who are at arms’ length. In the ICSA’s recent newsletter of Summer 2012, James Beck, Managing Director and Mark Watson, Senior Advisor, EFFECTIVE GOVERNANCE, argued that
“Interviews provide an opportunity to collect rich and complex data, but require an experienced interviewer and can be very resource intensive in terms of designing lines of questioning and subsequent analysis of directors’ responses.” (p.5)
Their analysis points to the usefulness of such interviews but also to a major deterrent. If an organization has grown up with interviews being an integral part of the self-evaluation process, then it is ingrained in their corporate culture. However most organization have not and so the board may feel that the interviews are intrusive, cumbersome and costly. Some may even argue that it is preferable for the board members to talk to one another. While this is a valid argument, there are many notable examples where the atmosphere in the board room makes it unlikely for open dialogue to occur. In that case, interviews would be needed.
However conducted, self-evaluations are here to stay and so organizations are best to embrace the process.
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CORPORATE GOVERNANCE – Board self- evaluations.
This week’s blogs will focus on board self-evaluations; their genesis, their usefulness and evolution, the proliferation of reviews now undertaken by other groups (such as Independent Review Committees) and the new standard being put forward by various regulators such as OSFI and the OSC’s notice 58-306, the 2010 Corporate Governance Disclosure Compliance Review. It is now the accepted view that boards ought to evaluate themselves by conducting an annual self-assessment – how did we get there?
While most people would point to the Sarbanes-Oxley legislation (2002) as the beginning of real corporate governance. In Canada, it began with the TSX report in 1994 entitled “Where were the Directors?” (the Dey Report) and was followed up five years later with a further report on corporate governance to review whether issuers were adhering to the principles put forward. While there was an adoption of the general principles, adherence and full adoption were mixed. The TSX and TSX-V established the Saucier Committee in 2001 to review current standards and to recommend the manner by which the rules could be brought up to international standards.
The Enron and Worldcom scandals in 2002 culminating with the new U.S. legislation, Sarbanes-Oxley, jump started most of the world’s regulators to review their processes and to develop and require their issuers to adopt and to adhere to best practices. In Ontario, Multilateral policy 58-201 was created and codified many of the standards that we would think of today as commonplace. (http://www.osc.gov.on.ca/en/SecuritiesLaw_pol_20040116_58-201_pro-multi-pol.jsp ). The instrument called for this level of self-assessment.
18. The board should regularly assess its own effectiveness, as well as the effectiveness and contribution of each board committee and each individual director. An assessment should consider
(a) the board’s written mandate,
(b) the charter of each board committee, and
It makes great reading as it deals with the history of these developments and makes the reader realize how engrained they are now. Apart from the regulatory requirements, the Standards may have become the accepted view due to articles like the Globe & Mail’s annual assessment of issuers (Board Games – http://www.theglobeandmail.com/report-on-business/careers/management/board-games-2011/detailed-survey-results-for-board-games-2011/article4181477/ ).
Companies began to conduct performance evaluations of their boards relative to mandates and objectives and to disclose that information to the shareholders. One of the difficult issue is that boards often do not set out objectives for themselves against which they can measure their performance. Accordingly, the initial forms were drafted at a very high level.
It was never doubted though that conducting a self-assessment evaluation can be very important to setting the “tone from the top” by indicating to the entire organization that the board values performance reviews and holds itself accountable. Naturally, the results of the evaluation need to be disseminated broadly so that all the stakeholders can review it.
Tomorrow – how to avoid a review that is merely ticking the box.
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MINING LAW – Keeping current
The mining industry is as vibrant as ever with commodity prices bouncing all over the place, both in the precious and base metals sectors and with companies reacting and dealing with the startling increase in the costs of operating around the world. Against this backdrop, countries (and provinces/states within countries) are busy changing the laws affecting mining companies and in some cases, increasing royalty or other tax-based payments. The question is how to keep abreast of those developments in order to safeguard an investment or to decide whether a jurisdiction is a proper place to make an investment.
Many of the Canadian law firms have very good Security Law/Mining newsletters. One of my favourites is Fraser Milner’s (and in the interest of full, true and plain disclosure – this is the law firm where I got my start). Subscriptions can be obtained at Securities Mining Law at FMC-law.com. Another good source is the websites of the securities commission whether Ontario, Alberta or others. Browsing their “What’s new” Section is a must-read every week or so.
On an international scale, it is more difficult to get timely and useful information. Having been fortunate to attend a conference at Watson, Farley & Williams in London, UK last year, I am now receiving their email newsletter service (
comms@wfw.com) This service is brilliant as it gives a global perspective with respect to new laws and regulations in parts of the world that one might not easily find them. Recently, their newsletter featured the New Mongolian Foreign Investment Law, the Indonesian Mining Export Tax and a reprise of an article by one of their partners on the impact of resource nationalism on investors. While the reader might not have an immediate need for information about Indonesia or other parts of the mining world, it is good to know where to find this information when it suddenly becomes relevant and topical.
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EMPLOYMENT MATTERS – AGF and the Emerging Market Team Defendants.
A couple of weeks ago, AGF launched a lawsuit against the Emerging Market team that left AGF in April 2012, the Dallas-based wealth management company that they went to work for and the recruiting firm that allegedly “lifted the team out”. (http://www.theglobeandmail.com/globe-investor/funds-and-etfs/funds/agf-alleges-unlawful-conspiracy-in-suit/article4468532/ ). That initial volley was covered by most of the business commentators across Canada. This type of case is big news and has not been seen since the CIBC and Genuity Capital Markets case of 2004/5.
AGF put this statement in its press release: “In our view, this action is about a breach of legal obligations involving ethically wrong behaviour by this U.S. investment company with full participation by individuals including Patricia Perez-Coutts, our ex fund manager,” said AGF Chairman and Chief Executive Officer Blake C. Goldring. “We have a duty to act, and to protect Canadian investors from this type of interference. Integrity is the most important part of our business. “
(http://www.agf.com/static/en/about_agf/release57126.html)
The relief sought against the Defendants is far reaching but open ended as to the amount of damages sought. Although the discovery process is going to bring to light the real damages. strangely enough, AGF should be in a good position today to quantify the damages that it has suffered. Its damages are based on lost revenues, lost opportunities and lost customers, all of which should be quantifiable. The Plaintiffs also want to look at the Defendants’ records to see what else can be claimed. Apart from the loss of revenue, the plaintiffs also sued for the losses associated with the taking and misuse of AGF’s confidential information. That information included AGF’s plans, strategies and compensation patterns. The lawsuit will open up a virtual Pandora’ box of information about the industry and one that rivals and the media will enjoy.
But the claim and its timing leave one puzzled with a whole host of questions emerging after a read of the statement of claim. Why did the plaintiffs not move more quickly to protect itself and the Canadian investors if this team was so pivotal to its business? How did AGF retain some of the team and did those team members give AGF interesting information about the meetings that occurred before the team quit (see paragraphs 58 to 65 in the statement of claim). Why wasn’t an injunction sought back in April and why none sought now?
From the defendants’ side, there are as many questions that are yet unanswered? Why did the defendants make such a splash of quitting one day and popping up at a potential rival the next? Did they get advice that the restrictive covenants in their employment contracts were unenforceable? Did they assume that the indemnity from their new employer would hold them truly harmless? Did they hope that the publicity would range from neutral to beneficial to them?
As this case unfolds, we will get a seldom-seen glimpse into the entrails of the industry. Once the pre-trial motions start, we will be a lot wiser.
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BANK REGULATORY – Lessons for Standard Chartered Bank and for others
Rahm Emanuel, the former Chief of Staff to President Obama, is famous for many things during his tenure in the White House. One of them is his unforgettable saying “you never want a serious crisis to go to waste”. (http://www.youtube.com/watch?v=1yeA_kHHLow ). Mr. Emanuel went on to explain that a crisis allows an institution to do things that it could not do otherwise. It is a mantra that should be adopted by any institution that has encountered, endured and overcome a serious regulatory probe.
Standard Chartered Bank has had quite a week commencing with the Order of the New York State banking regulator, the publicity of the sanctions being sought by that regulator, its being labelled a “rogue institution” by Mr. Lawsky (http://business.financialpost.com/2012/08/07/iran-accusations-wipe-us15-billion-off-standard-chartered-shares/ ) and yesterday’s settlement.
What can and should be learned by Standard Chartered Bank and others?
· Sensitivity – this may be an odd concept for an institution; however the members of management responsible for dealing with Mr. Lawsky’s office needed to be attuned to the fact that their negotiations pre-Order were not addressing the regulator’s timetable and issues. SCB said it was taken by surprise by the issuance of the Order and by the fact that the New York banking regulator acted alone. Someone on their team must not have been listening.
· Reputational risk – nothing is more important than the reputation of an institution especially at a time when so many other financial institutions are being taken out to the woodshed. Great results and earnings are no balm for shareholders who hear in the press that their holdings have lost more than 15% in a day due to a regulatory probe. Even a swift settlement will not completely cleanse the name of the institution and restore investor confidence.
· Management moved too slowly to solve it – Once the Order was made public, the matter was solved in four days. Only people familiar with the earlier negotiations can comment on whether SCB had shown any movement prior to that time. The moral for a regulator who is meeting with intransigence seems to be that the issuance of an Order and making public statements brings an institution to heal and causes the CEO to return from his/her holidays.
· Tone matters – the first salvo from SCB post-Order was an aggressive defence of itself. (http://www.business-standard.com/india/news/standard-chartered-refutes-us-chargesiran-deals/181822/on ) While the organization is entitled to do so, one wonders whether that helped their settlement position or whether they had to tell the regulator privately that those comments were for the press and that they were truly interested in making a settlement. Is this a prudent stance or one that merely muddies the waters?
· Who is the team going forward? – the New York banking regulator should take some solace that SCB is taking the matter seriously if SCB selects and puts a strong and well-known team of subject matter experts in place to work through the long list of requirements set out in the Joint Written Agreement. This will go a long way to re-building the regulatory relations between the SCB and its regulator. It will be a strong signal that SCB truly takes the matter seriously.
So one lesson for handling these regulatory complaints in the future might be: “listen, be responsive, be aware of the downside and speak to them as you would wish to be spoken to.”
Undoubtedly SCB hopes not to be front page news after Friday.
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BANK REGULATORY – Settlement Achieved
As we anticipated in our earlier blogs, Standard Chartered Bank settled the case today, one day before Wednesday’s hearing. The early disclosure concerning the settlement sets a civil penalty of $340 M. This penalty seems rather light in face of what the New York Banking regulator had described as violations involving $250B of Iranian transactions. A monitor will be onsite for at least two years and will report to the New York state banking regulators. (http://www.bloomberg.com/news/2012-08-14/new-york-settles-probe-of-standard-chartered-for-340-million.html).
The Joint Written Agreement also requires an Anti-Money Laundering program with independent testing and audit to improve internal controls and to ensure compliance with the Bank Secrecy Act. It is a good read for any financial institution carrying on business in the United States, even peripherally. (http://www.dfs.ny.gov/banking/ea041008.htm )
With this case behind them, SCB will have two main jobs: firstly, resolving the case brought by the US Department of Justice and the Manhattan district attorney; and secondly, deploying a team to develop the compliance and AML program required by the JWA which is attuned to and in keeping with U.S. laws. These are better uses of its management time rather than defending itself against the regulatory charges on Wednesday.
Most importantly, SCB keeps its New York banking license.
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BANK REGULATORY – The tone sounds like a settlement
Following on yesterday’s blog about Standard Chartered Bank (SCB) and its travails with the New York state Banking regulator, the signals are all toward a speedy settlement. This strategy is consistent with and follows in the footsteps of much larger institutions which have run afoul of regulatory authorities including among others, JPMorgan Chase & Co., ING Bank N.V. and Barclays.
Notwithstanding the aggressive tone taken by the CEO of SCB when the Order became public that the allegations about the Iranian transactions were incorrect as a matter of law, SCB’s legal team is working to reach a settlement. Even the CEO himself is now in New York to lend credence to the message that a settlement is seriously being negotiated. (http://www.theglobeandmail.com/report-on-business/international-business/european-business/standard-chartered-ceo-takes-lead-in-iran-probe-talks/article4479955/ ) The hearing is still set for this Wednesday however the form of it has yet to be made public. Mr. Sands’ presence in New York also indicates that he is prepared to appear.
SCB is also dealing with the 2010 probe by the US Department of Justice and the Manhattan district Attorney with regard to violations of U.S. sanction laws. (http://www.theglobeandmail.com/report-on-business/international-business/european-business/standard-chartered-weighs-settling-iran-laundering-probe/article4478305/ ) These two probes will need to be resolved quickly if SCB wants to indicate to the U.S. regulators that it takes U.S. laws seriously (and by extension, wants to keep its U.S. license) and if it wants to assuage the concerns of its shareholders that management understands the regulatory world within which it operates.
Given the heightened regard for corporate governance and given the impact of the new Basel III rules, one wonders how an institution could continue to carry on business while treating these investigations as ordinary course matters.
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BANK REGULATORY – Standard Chartered Bank, the saga continues but the tone is changing.
Standard Chartered Bank seems to have realized that tone is vital if one wants to settle a huge regulatory crisis. SCB is said to have agreed to a compliance monitor to ensure that the transactions conducted by the bank are compliant with U.S. anti-money laundering laws. Although this compliance monitor has yet to be named (and will not be Deloitte’s as they are implicated in the Order issued by the New York Banking regulator), it goes a long way to indicating to the marketplace that SCB is taking this matter seriously. (see today’s Report on Business p. 3)
Another indicator are the anonymous leaks about the cooperative tone that SCB is taking to settle matters in advance of the first appearance before the New York regulator scheduled for this Wednesday. (http://ca.reuters.com/article/businessNews/idCABRE87C04O20120813 ) Those leaks are indicating what the potential fine might be. The amount being bandied about is a staggering payment of up to $1 Billion USD. Undoubtedly the fall in the stock price has sharpened the focus of the CEO and the board at SCB.
Politicians are wading in on both sides of the Atlantic, including the Bank of England governor (http://www.theglobeandmail.com/report-on-business/international-business/european-business/bank-of-england-governor-questions-us-approach-to-stanchart-probe/article4469935/) . While their pressure and input will be a factor in any settlement, it is the potential of SCB losing its New York license which will be the driving force in the settlement. SCB’s President and CEO may still be emphatic in rejecting the claims of money-laundering but his legal team has likely been instructed to make this whole matter go away as quickly as possible. A resolution before Wednesday and the beginning of hearings would be exceptionally good news for SCB but can they possibly settle it in the way often done in the U.S. without admission of liability?
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Update: BANK REGULATORY – Standard Chartered Bank and the New York State Bank regulator
The facts surrounding the Order issued by the New York state banking regulator, Benjamin Lawsky, is being analyzed on both sides of the Atlantic. There appears to have been a loophole in the US banking law until 2008 which facilitated certain transactions with Iranian banks. That loophole is discussed in today’s New York times.
http://mobile.nytimes.com/2012/08/09/business/how-a-lax-banking-law-obscured-money-flow.xml
On the other side of the Atlantic, the BBC News is wading in and provides the interesting schematic of how these so-called U-turn transactions were accomplished. They commenced out of the U.S. by non-Iranian banks passed through the U.S. financial system on their way to other non-Iranian foreign banks and were done to facilitate the oil exports from Iran. http://www.bbc.co.uk/news/business-19159286.
The Order makes very interesting reading as it paints a picture of bank representatives engaging in a scheme to evade federal laws. It alleges that Standard Chartered “provided step-by-step, wire-stripping instructions for any payment messages containing information that would identify Iranian clients,”
To date, all the attention has been on Standard Chartered as an institution, but institutions are made up of directors, officers and employees. The next shoe to drop will be the identification of those individuals who participated in the scheme. The New York State Department of Financial Services has so far brought this matter on its own which is unusual. Bank of England’s Mervyn King has indicated that the other regulators involved in the investigation both in the UK and in the US should work together. While they decide on their course of action, (if and when they do so) the important question is whether there will be charges against Standard Chartered’s individual representatives.
In any event, there ought to be tremendous scrutiny of the compliance and anti-money laundering programs in place at Standard Chartered.
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