erm2012_day1_04-rami_wadie_erm_and_cg_final_nov_25v3 by saad alshammari

ERM: A Governance Mandate

26 November 2012

Rami Wadie

Agenda Introduction Codes, Standards & Leading Practices Building the Risk Intelligent Enterprise – Nine Principles Towards Risk Intelligent Governance - Six Actions to consider

The Board’s Role In Risk Management Question and Answers

ERM: A Governance Mandate

ERM & Corporate Governance Introduction

Corporate governance is the system by which enterprises are directed and managed. It influences how the corporate objectives are set and achieved, how risk is monitored and assessed, and how performance is optimized. Good corporate governance structures, including risk governance, encourage organizations to create value through entrepreneurism, innovation, development and exploration, and provide the accountability and control systems commensurate with the risks involved in such activities. Good governance promotes compliance with agreed risk management policies and provides for corrective action in cases where the rules have been ignored or misconstrued. Effective corporate governance requires a clear understanding of the respective risk management roles by all the concerned people in the organization.

ERM: A Governance Mandate

ERM & Corporate Governance Introduction

Companies spend too much time and effort managing the myriad, inconsequential risks, rather thanâ&#x20AC;Ś

ERM: A Governance Mandate

ERM & Corporate Governance Introduction

â&#x20AC;Śthe big, enterprise-wide risks that could significantly affect shareholder value

ERM: A Governance Mandate

ERM & Corporate Governance Introduction

Why does ANY Organization need Risk Intelligence?

“Why do cars have brakes?”

So that you can slow down?

Or is it so you can go faster and still be in control? Organizations that are most effective and efficient in managing risks to both existing assets and to future growth will, in the long run, outperform those that are less so 6

ERM: A Governance Mandate

ERM & Corporate Governance Codes, Standards & Leading Practices

US Security Exchange Commission In 2009, the Securities and Exchange Commission (SEC) identified the absence of risk management as a root cause of the economic downturn and announced it is considering action to promote greater board of directorsâ&#x20AC;&#x2122; oversight. Indirectly, this development could strengthen ERM programs and broaden the role of risk managers. While it is applicable to public companies only, under proposed rule No. 33-9052, corporations would have to disclose board measures to manage enterprise-wide risks, including polices related to risk identification, risk tolerance, and management of risk/reward tradeoffs throughout the enterprise. This proposed rule extends beyond the C-suite and seeks to enhance risk management awareness for all employees. It is expected that companies will establish new mechanisms to centralize and report data so board members and senior managers receive frequent and consistent updates regarding the enterpriseâ&#x20AC;&#x2122;s risks.

ERM: A Governance Mandate

ERM & Corporate Governance Codes, Standards & Leading Practices

According to the 2011 Board Practices Report put forth by the Society of Corporate Secretaries and Deloitte Governance Professionals, the following was mentioned:

• The Risk oversight is a fundamental role of any director, and in the current governance environment, there is increased pressure from investors and regulators for boards to spend more time on overseeing risk management. • How boards approach risk oversight appears to be decidedly mixed, with many respondents assigning primary responsibility to the audit committee at small- and mid-cap companies, but only 30% of large-cap companies indicating this. • With regard to the industry business units, 32% of financial services companies, as compared to 8% of non-financial services companies, have a board risk committee. • Given the nature of their business, the risks they face, and a rapidly evolving regulatory climate, companies in the financial services industry tend to have more developed risk oversight and management practices.

ERM: A Governance Mandate

ERM & Corporate Governance Codes, Standards & Leading Practices

While there is no legal obligation for public companies to establish a management disclosure committee, the SEC recommends it and 89% of all public companies have one. There has been a trend for public companies to form one, especially in the small- and large-cap companies, which have shown 20% and 12% increases, respectively, since 2008. From an industry perspective, fewer financial services companies (82%) have this committee, compared to non-financial services companies (91%). Of the companies with a management disclosure committee, 45% of small-cap companies say the committee reports to the board or a board committee, compared to 37% and 29% of mid- and large-cap companies, respectively. Across all company sizes and industries, a majority of the management disclosure committees who do report directly to the board or a board committee do so on a quarterly basis.

ERM: A Governance Mandate

ERM & Corporate Governance Codes, Standards & Leading Practices

• It is management's responsibility to see that risk management is embedded in everyday business decisions throughout the company on an enterprise-wide basis.

• Two thirds of the companies identified as leaders currently delegate risk oversight responsibility to the Audit Committee. However, a small number of companies distinguish between financial risk and other business risk, and they charge another committee with broader-based business risk oversight. Where one or more committees oversee risk, they coordinate and report to the full board which maintains the overall strategic responsibility. • Leading companies establish an executive risk management committee that includes the chief financial officer. Many companies are creating a chief risk officer role to coordinate risk management strategies across business units, and the risk management committee supports how this role is undertaken. 10

ERM: A Governance Mandate

ERM & Corporate Governance Codes, Standards & Leading Practices A number of industry, regulatory, and standard setting bodies have proposed principles and guidance with regard to corporate governance in general and specifically as it relates to risk, such as: Standard and Poor’s As of 2008, the Standard and Poor’s Rating Services has decided to take into account Enterprise Risk Management practices while rating organizations. The benefits of the ERM enhancement will be to make the process of forming S&P rating opinions more forward looking, achieve finer differentiation among ratings. According to S&P, ERM is perceived to address several topics including: • A method to shift focus from "cost/benefit" to "risk/reward"; • A way to help fulfill a fundamental responsibility of a company's board and senior management; • An approach to assure the firm is attending to all risks; • A set of expectations among management, shareholders, and the board about which risks the firm will and will not take; • A set of methods for avoiding situations that might result in losses that would be outside the firm's tolerance; and • A toolkit for trimming excess risks and a system for intelligently selecting which risks need trimming; 11

ERM: A Governance Mandate

ERM & Corporate Governance Codes, Standards & Leading Practices

Director 360Â° Survey for 2011 Issues on Board Agendas in the last 12-24 months

Issues on Board Agendas in the next 12-24 months

Capital Management

29%

Strategy

36%

Strategy

27%

Growth

27%

Regulations Governance and Compliance

27%

Capital Management

25%

23%

Global Financial Crisis and recovery

24%

Regulations, governance and compliance

Growth

21%

Performance

22%

Performance

20%

Management succession

18%

Operational management

18%

Global financial crisis and recovery

15%

Management succession

17%

Mergers and acquisitions

15%

Mergers and acquisitions

14%

Operational management

13%

Organizational structure

14%

Talent management

13%

Risk management

13%

Risk management

12%

ERM: A Governance Mandate

ERM & Corporate Governance Codes, Standards & Leading Practices

Global Codes •

OECD survey of Corporate Governance developments & issuance of a Corporate Governance Guide

•

Sarbanes-Oxley Act was passed by the U.S. congress

•

ASX Code

•

Issuance of the Combined Code (Supersedes and replaces the 1998 Combined Code issued by the Hampel Committee)

•

KING (I,II, III) report on Corporate Governance in South Africa

•

Hong Kong Code

•

And many others

ERM & Corporate Governance Codes, Standards & Leading Practices

ASX The Australian Stock Exchange (ASX) Corporate Governance Council was formed in August 2002 with a mission to develop an industry-wide, supportable, and supported framework for corporate governance which would provide a practical guide for listed companies, their investors, and the wider community. In support of this mission the ASX Corporate Governance Council developed the Principles of Good Corporate Governance and Best Practice Recommendations. These principles state that good corporate governance is supported by the establishment of a sound system of risk oversight and management. Further, in Principle 7â&#x20AC;&#x201D;Recognize and Manage Risk, it states: "It is part of the board's oversight role to oversee the establishment and implementation of the risk management system, and to review at least annually the effectiveness of the company's implementation of that system. Management should establish and implement a system for identifying, assessing, monitoring and managing material risk throughout the organization."

ERM: A Governance Mandate

ERM & Corporate Governance Codes, Standards & Leading Practices

Regional Codes •

Kuwait – Corporate Governance Guidelines for Kuwait Banks

•

Saudi Arabia – Corporate Governance Regulations in the Kingdom of Saudi Arabia

•

United Arab Emirates – Corporate Governance Code for Joint-Stock Companies

•

Qatar – Corporate Governance Code for Listed Companies

•

Qatar – Corporate Governance Guidelines for Banks & Financial Institutions

•

Jordan – Corporate Governance Code for Banks in Jordan

•

Lebanon – Corporate Governance Guidelines for Listed Companies

•

Bahrain – The Corporate Governance Code

•

UAE: SCA

ERM: A Governance Mandate

ERM & Corporate Governance Codes, Standards & Leading Practices

Central Bank of Kuwait The Governor Date: 20 June 2012 Ref.: 2/105/7995 Instructions No. (2/BS/IBS/284/2012) to all Kuwaiti Banks Risk Management had 36 matches (e) Review, in cooperation with executive management and on regular basis, the policies, controls and functions of internal control (including internal audit, risk management and compliance) in order to determine areas needing improvement, as well as to identify and address significant risks and issues. The board should ensure that the control functions are properly positioned, staffed and resourced and that the underline staff members in these positions are carrying out their responsibilities independently and effectively.

ERM: A Governance Mandate

ERM & Corporate Governance Codes, Standards & Leading Practices

• UAE Ministerial Resolution No. (518) of 2009 Concerning Governance Rules and Corporate Discipline Standards - Risk Management was mentioned 5 times • Capital market authority corporate governance regulations in the Kingdom of Saudi Arabia – Article 10: Main Functions of the Board of Directors Among the main functions of the Board is the following: a) Approving the strategic plans and main objectives of the company and supervising their implementation; this includes: - Laying down a comprehensive strategy for the company, the main work plans and the policy related to risk management, reviewing and updating of such policy.

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

The value of taking intelligent risks • Companies make money by taking risks intelligently • They lose money by failing to manage risks intelligently through execution

• In the long run, companies who are most effective and efficient in managing risks will outperform those who are less so • How do you calculate risk and reward? What is your typical time horizon? • How do you determine which risks to take and which to avoid?

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

A Risk Intelligent Enterpriseâ&#x201E;˘ protects and creates shareholder value Manage risks to create shareholder value (future growth) New product development New pricing models Target new markets VALUE

Penalties and fines Fraud Labour relations

Manage risks to protect shareholder value (existing assets)

Companies make money by taking intelligent risks, and lose by failing to manage them intelligently 19

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

While the business environment has changed rapidly…. External factors • Global interconnectedness of businesses and speed of advent of events • Increasing overseas presence and domestic growth • Increasing uncertainty around customer preferences and business models

Internal drivers • Placing enormous strategic bets on growth; however, risk considerations are not embedded into decision making • Existing risk processes in India focus on market risk (currency, commodity, etc.)

• Pressure from institutional stakeholders for good risk management practices

• Siloed risk management practices preventing identification of risk interactions across the enterprise

• Increasing volume and complexity of regulations

• Risk management is viewed as a project, not a culture

• Current financial market volatility

• Insufficient risk awareness and knowledge of individual responsibilities pertaining to managing risks

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

However, very few enterprises intelligently manage the full spectrum of risk

Characteristics of a Risk Intelligent Enterprise: • Develops full-spectrum vision across divisions, departments, and geographies • Bridges different risk management silos across the organization

• Speaks a common language by developing a common risk terminology • Assesses impact areas instead of identifying/evaluating universe of events • Weighs vulnerability as part of risk management in addition to conventional emphasis

on probability • Considers risk scenarios and the interaction of multiple risks

A Risk Intelligent Enterprise has the ability to convert unrewarded risks into opportunities 21

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

Rewarded risks

• Companies deliberately take risks to benefit from potential upside, (e.g. investing in new markets, products, services, business models) • How could we fail or sub-optimize achievement of our objectives? Unrewarded risks • Those for which there is only a downside, e.g. noncompliance with laws and regulations, lack of integrity in financial reports or operational failure • Companies get no premium simply for protecting their existing assets, but failure to do so can result in significant negative impact on shareholder value and damage to reputation

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

Building the Risk Intelligent Enterprise Risk Intelligent Enterprises adopt a balanced perspective of risk management, supported by fundamental principles: Nine Principles for Building a Risk Intelligent Enterprise

The Risk Intelligent Enterprise

Common Definition of Risk Common Risk Framework Roles and Responsibilities Transparency for Governing Bodies

Common Risk Infrastructure Executive Management Responsibility Objective Assurance &Monitoring Business Unit Responsibility

Support of Pervasive Functions

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

Nine principles for developing a Risk Intelligence Program Principle #1: A common definition of risk, which addresses both value preservation and value creation, is used consistently throughout the organization. • Risk can oftentimes be an uncomfortable topic of conversation • Discussion can flow freely if you consider the other side of risk – risk taking for reward • If the risks associated with challenging endeavors are not properly managed, you may not reap the potential rewards • Consider adopting a more expansive definition of risk to include growth and profitability, should not be limited to the bad things that could happen to your business

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

Nine principles for developing a Risk Intelligence Program Principle #2: A common framework supported by appropriate standards is used throughout the organization to manage risks. • A framework is the coat rack on which you hang your risk management program

• Risk frameworks – such as COSO ERM, Turnbull, and ISO – provides a structure that assists in the decision-making process • Which opportunities do we pursue and which hazards do we avoid? • Whichever framework you choose, it must accommodate your strategies, initiatives, and organizational structure • Be adaptable to your industry and regulatory requirements • No need to lose sight in the details, just need to make sure its appropriate for your organization

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

Nine principles for developing a Risk Intelligence Program Principle #3: Key roles, responsibilities, and authority relating to risk management are clearly defined and delineated within the organization. • Risk management is a coordinated effort – multiple roles are played simultaneously in often complex arrangements • Change the mindset of the organization – convey what Risk Intelligence means, communicate its importance to the organization – collectively and individually, and what needs to be done on a daily basis • Requires clear communications, a strong risk-focused culture driven from the top down, reward programs that incorporate risk-related objectives and learning programs to promote intelligent risk management

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

Nine principles for developing a Risk Intelligence Program Principle #4: A common risk management infrastructure is used to support the business units and functions in the performance of their risk responsibilities. • Risk doesn’t exist in isolation, so risk managers can’t either • Organizational silos must be bridged to effectively and efficiently manage risks and reap the rewards • Create a common infrastructure – all business units and functions use the same processes and technologies

Synchronize – coordinate across institutional boundaries

Harmonize – ensure that all the risk managers speak the same language

Rationalize – eliminate duplication of effort

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

Nine principles for developing a Risk Intelligence Program Principle #5: Governing bodies have appropriate transparency and visibility into the organization’s risk management practices to discharge their responsibilities. • Boards have a fiduciary responsibility to ensure that management has appropriate processes in place to manage risk • Board members should:

Put risk on the agenda

Inventory the current risk structure

Engage with the management team

Discuss risk scenarios for all key decisions

Check organizational appetite – and diet

Get reasonable assurance from those responsible for execution

Get independent assurance

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

Nine principles for developing a Risk Intelligence Program Principle #6: Executive management is charged with primary responsibility for designing, implementing, and maintaining an effective risk program. • Consider forming a Risk Intelligence group, which can help create a Risk Intelligence program • An executive level committee - consists of a chief risk officer (CRO) along with other top executives

• CRO helps develop policy and common approaches, communicates, and monitors the organization’s risk appetite and reports risk information to the management and board-level oversight functions

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

Nine principles for developing a Risk Intelligence Program Principle #7: Business units are responsible for the performance of their business and the management of risks they take within the risk framework established by executive management. • If you own the business unit, you own the risk • Risk owners have the responsibility to identify, measure, monitor control, and report risks to executive management • Business unit managers must operate under certain constraints established by the organization’s management

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

Nine principles for developing a Risk Intelligence Program Principle #8: Certain functions (e.g. Finance, legal, IT, HR) have a pervasive impact on the business and provide support to the business units as it relates to the organization’s

risk program. • These functions help support risk management • Responsible for developing and enforcing company-wide policies, procedures, and controls that help mitigate risk

• They support each business unit and help them understand their requirements for intelligent risk taking • These key functions should join the risk team and participate in risk committees or risk forums

ERM: A Governance Mandate

ERM & Corporate Governance Building A Risk Intelligent Enterprise

Nine principles for developing a Risk Intelligence Program Principle #9: Certain functions (e.g. Risk Management, Internal Audit, and Compliance) provide objective assurance as well as monitor and report on the effectiveness of an

organization’s risk program to governing bodies and executive management. • Major responsibility of the internal audit, compliance, and risk management functions is to provide “comfort” – reassurance that the internal control and risk structure operates effectively • Potential roles that expand the job description: - Visionary

- Advocate

- Champion

- Subject matter resource

- Aggregator

- Troubleshooter

- Efficiency expert 32

ERM: A Governance Mandate

ERM & Corporate Governance Towards Risk Intelligence Governance – Six Actions To Consider

Risk intelligent governance stands among the most valuable contributions boards can make to their organizations. The combined breadth of perspective, depth of expertise, and knowledge of the enterprise that a board can bring to a risk management program lends support to management that is not only invaluable, but also unavailable elsewhere. Moreover, risk intelligent governance can help management and the enterprise to: • allocate risk management resources in the most cost-effective manner • assist in shaping the organization’s response to regulatory issues

• employ risk management for competitive advantage • drive growth in long-term shareholder value while preserving assets Whether you are a board member, senior executive, risk manager, or other stakeholder in your risk management program, we trust that the actions suggested in this document — and the questions and tools presented here — will help your board to move toward risk intelligent governance of your enterprise. 33

ERM: A Governance Mandate

ERM & Corporate Governance Towards Risk Intelligence Governance – Six Actions To Consider

1. Define the board’s risk oversight role The essence of risk governance for board is oversight —while risk management rests with senior management, and ownership resides in the business units. Given those realities, what are the board’s risk oversight responsibilities? Generally, they are to set the tone, elevate risk as a priority, and initiate the communication and activities that lead to sound risk management. This means helping management to create a cohesive risk management process across the organization, and replacing the “silo” approach with one in which risk-related interdependencies are routinely investigated, evaluated, and understood.

ERM: A Governance Mandate

ERM & Corporate Governance Towards Risk Intelligence Governance â&#x20AC;&#x201C; Six Actions To Consider

2. Foster a risk intelligent culture In a risk intelligent culture, people at every level view managing risk as an intrinsic part of their jobs. Rather than being risk averse, they understand the risks of any activity they undertake and manage them accordingly. A risk intelligent culture supports open discussion about uncertainties, encourages employees to express concerns, and maintains processes to elevate concerns to appropriate levels.

ERM: A Governance Mandate

ERM & Corporate Governance Towards Risk Intelligence Governance – Six Actions To Consider

3. Help management to incorporate risk intelligence into strategy Incorporating risk intelligence into strategy requires a practical understanding of value creation and preservation in the enterprise. That understanding helps the board and management to move in collaboration from a negative “incident” or compliance view of risk to a more positive “portfolio” view that considers risks and rewards in a broader context.

ERM: A Governance Mandate

ERM & Corporate Governance Towards Risk Intelligence Governance – Six Actions To Consider

4. Help set the risk appetite While the CEO proposes the organization’s risk appetite, the board must approve it and ensure that it is consistent with the business strategy and stakeholders’ expectations. Setting the risk appetite calls for value optimization: too high appetite creates unnecessary, unmanageable, or unacceptable exposures; too low appetite causes missed opportunities and yields advantages to competitors. The enterprise should also translate the risk appetite into risk tolerances. Risk tolerances provide guidelines and controls that create awareness and inform decisions and behaviors.

ERM: A Governance Mandate

ERM & Corporate Governance Towards Risk Intelligence Governance â&#x20AC;&#x201C; Six Actions To Consider

5. Execute the risk intelligent governance process A risk intelligent governance process should be strategic in design, promote awareness of the relationship between risk and value, and improve the allocation of risk management resources. Process execution requires a disciplined, yet collaborative approach focused on process design, process monitoring, and accountability.

ERM: A Governance Mandate

ERM & Corporate Governance Towards Risk Intelligence Governance â&#x20AC;&#x201C; Six Actions To Consider

6. Benchmark and evaluate the governance process Boards need systematic methods and mechanisms for assessing and reinforcing their risk governance proficiency. These methods and mechanisms should enable the board to gauge its current stage of development on a continuum relative to peers. The board should also obtain periodic independent assessments of their risk governance processes. With such tools and feedback, the board can identify, prioritize, and implement corrective actions and improvements.

ERM: A Governance Mandate

ERM & Corporate Governance The Boardâ&#x20AC;&#x2122;s Role In Risk Management

Key to risk oversight is to ask the right questions 1. Do we create a risk profile for each acquisition, market entry, or other strategic decision and develop alternative scenarios? 2. Are risk programs aligned with our entry into new markets and new relationships, new market conditions, and new compliance requirements in those markets? 3. Do we have the right in-house skills or strategic partners to help manage new/complex risk issues for new ventures? 4. Have we quantified the impact of the current strategy on the Portfolio Recovery brand? 5. Do we really understand the consequences and interactions or domino effects that can impact our existing value and assets?

ERM: A Governance Mandate

ERM & Corporate Governance The Board’s Role In Risk Management

Oversight of major risks

- Periodic briefings on the most significant risks: strategic, reputation, operational, etc. - Understand aggregated risk exposure – residual risk view - Assure management has defined and communicated its risk appetite and risk tolerances

- Monitor emerging risk trends and management’s response - Encourage development of risk management capability as a core competency

ERM: A Governance Mandate

ERM & Corporate Governance The Board’s Role In Risk Management

Practical advice on risk oversight • Be willing to challenge assumptions

• Maintain constant vigilance • Factor in velocity and momentum • Manage the key connections

• Anticipate causes of failure • Verify sources and corroborate information

• Maintain a margin of safety • Set your enterprise time horizons • Sustain operational discipline

• Take enough of the right risks

Source: Surviving and Thriving in Uncertainty, John Wiley and Sons, New York

ERM: A Governance Mandate

Questions

ERM: A Governance Mandate

About Deloitte: Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms. Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member firms in more than 150 countries, Deloitte brings world-class capabilities and high-quality service to clients, delivering the insights they need to address their most complex business challenges. Deloitte has in the region of 200,000 professionals, all committed to becoming the standard of excellence. Deloitte's professionals are unified by a collaborative culture that fosters integrity, outstanding value to markets and clients, commitment to each other, and strength from cultural diversity. They enjoy an environment of continuous learning, challenging experiences, and enriching career opportunities. Deloitte's professionals are dedicated to strengthening corporate responsibility, building public trust, and making a positive impact in their communities. About Deloitte & Touche (M.E.): Deloitte & Touche (M.E.) is a member firm of Deloitte Touche Tohmatsu Limited (DTTL) and is the first Arab professional services firm established in the Middle East region with uninterrupted presence for over 85 years. Deloitte is among the regionâ&#x20AC;&#x2122;s leading professional services firms, providing audit, tax, consulting, and financial advisory services through 26 offices in 15 countries with over 2,500 partners, directors and staff. It is a Tier 1 Tax advisor in the GCC region (International Tax Review World Tax 2010, 2011 and 2012 Rankings) and was recognized as the 2010 Best Consulting Firm of the Year in the Complinet GCC Compliance Awards. In 2011, the firm received the Middle East Training & Development Excellence Award by the Institute of Chartered Accountants in England and Wales (ICAEW).

Member of Deloitte Touche Tohmatsu Limited