You’ve built your business continuity management program to the highest standards. You faithfully maintain it each year. You’ve performed exercises to ensure everyone’s role is clear. Is it enough? No.
As companies become more comfortable with their own ability to recover from a disaster, they are becoming increasingly uncomfortable with a vendor’s ability to do the same. Regulations and standards — such as, OCC Bulletin 2013-29 (United States), BDDK Official Gazette No: 26333 (Turkey), ISO 22301 (international), and NCEMA 7000 (United Arab Emirates) — are beginning to require companies to extend their continuity plans into the trusted relationships with third-party vendors. In fact, the newest version of the U.S. banking regulation, OCC Bulletin 2013-29, even requires companies to look into fourth-party vendor business continuity. Fourth parties are defined as the critical vendors of your critical vendors (thus extending the trusted relationship of continuity further).
What does all this mean to you? It means that your business continuity management program must include
vendor business continuity management to ensure protection from internal and external hazards. Vendor business continuity management (BCM) is a program that extends internal business continuity protections to critical vendors, suppliers, third parties, and in some cases fourth parties. Common components include:
- Identifying critical vendors
- Developing minimum business continuity guidelines and amending master service agreements (MSAs) and service level agreements (SLAs) to include the right to audit BCM programs
- Developing an internal response plan or the failure of a critical vendor
- Creating sample tools and templates to support critical vendors (they may not have the internal knowledge or resources to hire a consultant)
- Implementing an assessment/verification program to ensure critical vendors’ BCM programs are compliant with your minimum BCM guidelines
The Place to Start
The first step in starting a vendor BCM program is to understand which vendors support the company’s critical business processes. This requires the company to perform an analysis of all vendors to determine those that may be:
- Have cash flow issues
- Operating under a lean/just-in-time model
- Susceptible to other, related risks
If vendors do not fall into any of the aforementioned categories, they may not be categorized as critical or be part of the vendor BCM program. However, it is recommended critical vendors be evaluated annually or sooner if there are major changes/additions to critical vendors.
In some cases, a vendor is more than just critical. Some vendors may provide key components, without which, the company could fail. This is especially true of sole-source vendors. In the cases of manufacturing, consumer products, pharmaceutical, transportation, and other industries, the lead time to replace a critical vendor may be too long. Not having products on the shelf, combined with negative publicity, may effectively shut a company’s product out of the market.
In these special circumstances, a company should consider building an internal recovery plan to prepare for a vendor’s failure. An internal plan should consider available external supply/outsourced manufacturing, lead times to obtain government (i.e. FDA) approval for alternate manufacturing lines, as well as safety stock. The company may decide to identify alternate vendors, begin regulatory approval of second manufacturing lines, or move away from the sole-source vendor altogether.
For critical vendors, establish a set of guidelines that explain the BCM requirements with which they must comply. These guidelines should mirror the company building the vendor BCM program’s BCM methodology to ensure a true extension of the trusted relationship. Common components include:
- Senior management commitment
- An established BCM methodology
- A BIA requirement to identify critical business processes and related impacts
- Recovery plans
- Regular exercises
- Regular maintenance
These guidelines should be part of all new SLAs and MSAs with critical vendors. The company also should use the same contractual language with existing critical vendors as contracts are renewed. This will protect the company and hold vendors contractually liable for their BCM programs.
Smaller vendors may not have the ability, knowledge, or resources to comply with a vendor BCM program. It may be necessary, and certainly would be helpful, to provide vendors with a BCM toolkit to support their efforts. Companies should be careful to include legal language that holds the issuing company harmless and states that use of the BCM toolkit does not implicitly or explicitly guarantee recovery from a disaster.
The final step in the process is to monitor and verify vendors’ compliance with the vendor BCM program. This usually can be part of an annual, or regular, vendor compliance assessment. To be both productive and meaningful, the assessment can be neither overly intrusive nor superficial. Questions should dig deeper than “Was a BIA completed?” and ask about specifics such as the date of the last BIA update or the critical processes and associated recovery times.
In summary, a vendor BCM program is not only another company policy. Rather, it is enhancing and changing the behavior a company takes in selecting, evaluating, and monitoring its collective vendors. Companies must understand that recovery and protection have to extend beyond the company walls. Modern organizations are integrated with and vitally dependent upon many other entities. Even companies in service and financial sectors are vitally dependent on critical vendors. Successful companies focus on their core competencies and rely on partners to fill in the gaps.
So, the next time you’re evaluating your company’s BCM program, remember to look out the door as well as in the mirror.
For Example . . .
The March 17, 2000 Philips microchip plant fire in Albuquerque, NM is one of the best cases for vendor BCM programs. Nokia and Ericsson, two of the largest mobile phone operators in the world at the time, both sourced critical microchip components from this Philips plant. When a lighting strike caused a small fire, the plant’s clean room was damaged resulting in the loss of production capacity.
Prior to the fire Nokia held about a 32 percent market share while Ericsson held about 12 percent in worldwide mobile phone sales. Post fire, Nokia’s mobile phone shipments increase 10.5 percent over the previous year, while Ericsson’s dropped by 35 percent. Why? Nokia reacted quickly and had already prepared for a critical vendor loss prior to the fire, identifying an alternate supplier of microchips. Ericsson, on the other hand, reacted slowly and believed early reports that the fire was small and posed no long-term supply risk to the supply of microchips.
The total cost to Ericsson was over $400 million USD, including a second quarter 2000 loss of $200 million USD.
BIO: Jerome Ryan is CEO of both GRM Solutions and DRI Istanbul, where he implements and oversees client deliverables in crisis management, business continuity management, emergency response, pandemic planning, and other risk management practices. GRM Solutions has offices in New York and Istanbul. He may be reached at firstname.lastname@example.org or www.linkedin.com/in/jeromeryan/