COUNT – compliance consulting and co-sourcing

COUNT Group positions itself as a Supply Chain Partner in the global energy and renewables markets. The company is active in Europe and North America. By offering expertise, service and convenience, COUNT Group distributes petrochemicals while helping to bridge the gap between what is possible and what is sustainable in their industry. In fact, COUNT has embedded sustainability into their mission, vision and core values with the clear purpose of contributing to the industry by advocating the transition towards more sustainable practices and products. The group is made up of three separate entities:

• COUNT Energy Trading- a competitive international trader of petrochemicals.
• COUNT Distribution- a complete logistics service provider that sources and distributes selected chemicals around the globe.
• COUNT Westgass- an independent merchant that specializes in supplying and distributing Norwegian natural gas to British and European markets.

COUNT started its operations in 2017 in Rotterdam. Two years afterwards, a new team was introduced focusing exclusively on petrochemicals and the shift to sustainable alternatives. Soon after COUNT expanded into Switzerland. In January 2021, we took our trading activities into the United States, and two months later they set foot in the UK with their distribution entity. Their latest acquisition took place in December 2021 when the company acquired a Norwegian natural gas company, adding COUNT Westgass AS to the brand.

The group experienced immense growth since its inception; with revenues of EUR 300 million in 2019 mounting to EUR 18 billion in 2022 leading to a staff expansion of 67% over the same period. This growth together with COUNT’s plans to consolidate their bulk trading business, grow their USA activities and solidify their gas & power activities while investing in their ESG activities, urged the need for strengthening of their corporate governance structure and solidification of their risk & internal control frameworks.

To realize this, BR1GHT was approached to become COUNT’s partner on this journey supporting COUNT with the development and implementation of a Governance, Risk & Compliance (GRC) strategy in line with their overall strategic ambitions. Execution of this strategy included BR1GHT’s support with the selection and implementation of a best-in-class risk management & compliance system that would be a right fit for COUNT.

The overall effort was endorsed by COUNT’s board of directors but led by COUNT’s Risk Manager. The project was divided into two phases:

1. Developing the GRC strategy & Project Plan
2. Executing the GRC strategy & Project Plan

The process started with a GRC Strategy workshop and follow up sessions to assess where COUNT stood in terms of its internal control efforts and maturity scale as well as determining where they wanted to be in three years. We used horizon planning and plateau-thinking to project the strategy elements in time. These efforts resulted in a clear GRC strategy and project plan with milestones in the areas of Structure, Processes, People and Technology for the period from 2022- 2024. This is an example of our strategic compliance services and concluded the first phase of the project.

Phase 2 started with a materiality and scoping exercise to identify COUNT’s critical business processes in scope and determine materiality.

This was input for the next step: assessment of which critical policies and procedures needed to be developed or updated to support COUNT in reaching their desired levels of control, transparency, and trust.

COUNT being a lean and flat organisation valuing efficiency had identified the desire for a Risk Management and Compliance system from the start of phase 1. At the start of phase 2 it quickly became clear that COUNT would also benefit from a Business Processing Management system. So, when BR1GHT guided COUNT in the tool selection process we made sure to include systems that offered both features. It was also important to choose a system that would support COUNT’s long-term growth not only in size, but in strategic ambition and maturity as well. We guide COUNT through our proven software package selection approach with the phase (1) requirement identification, (2) software-orientation, (3) market enquiry, and (4) long and short listing of solution. CERRIX turned out to be the best fit for COUNT and the implementation led by BR1GHT started quickly after the contracting phase.

Beside the implementation of CERRIX, phase 2 of the project (which is still ongoing) included specialist consulting in the following areas:

• Definition of the company profile and set up of a Corporate Governance structure that met the needs of COUNT, including establishment of three lines structure.
• Design and implementation of a risk & control framework including the development of a Risk & Control Matrix, design of key controls for all major risk areas.
• Set up of an Internal Control Improvement program
• Controls Test Plans design & IT General Controls design & implementation.
• Development of COUNT’s critical policies (Corporate Governance Code, Risk Management, Controls Testing, Compliance, Legal, Procurement, Accounting & Reporting, Document Control, IT Governance, Export Control, etc.) to support their new GRC strategy.
• Development of COUNT’s critical procedures including business process flows with descriptions added to CERRIX.
• Support with the development of a 3–5-year IT plan.
• Set up of the Business Intelligence (BI) environments
• Support with the selection and implementation of a SOD (Segregation of Duties) monitoring tool.

The approach to reaching the above objectives has been a practical one. BR1GHT defines what is best practice and designs the structures and policy frameworks and programs accordingly and COUNT reviews, adjusts where necessary and ultimately approves. This approach worked well for COUNT as they have a relatively small team. The whole project including the CERRIX implementation was executed digitally as most of the team members were situated in the BR1GHT Suriname office.

Even though CERRIX is live and the design phase is coming to an end, our journey with COUNT continues as BR1GHT has become a real partner in the implementation of the structures, systems and frameworks that were designed together. Our work going forward will include assisting with GRC awareness sessions for COUNT’s employees to ensure that everyone in the organization learns the new way of working and understands the thinking behind it. Also, BR1GHT will take a dive into the operations, supporting COUNT with the execution of controls testing activities, operational effectiveness reviews, KPI and KRI management and the design & implementation of MOIs (measures of improvement). We now are true partner of COUNT where we provide Risk Management and Compliance Managed Services out of Suriname with local presentation in The Netherlands (feet-on-the-ground).