NORWAY Law and Practice Contributed by: Elisabeth Roscher, Tine Vigmostad, Geir Sviggum and Kristin Nordland Brattli, Wikborg Rein Advokatfirma AS
3.4 Crisis Management Team Composition of Teams
led by the head of security or chief operations officer. The board of directors would have the overall responsibility, and a severe crisis situa- tion should commonly be escalated to the board of directors. The steering committee would often have the overall responsibility of the prevention and management of crises, reporting to the board of directors. Such committees may have a sub- ordinated crisis management team or task force responsible for the effective implementation of crisis management plans established by the cri- sis committee. Small and medium-sized compa- nies might not have the same formal governance structures in place, and would therefore tend to handle crisis situations on more of an ad hoc basis (thus relying heavily on external support), while larger corporations could handle more of the key functions internally with external sup- port on the project management and regulatory expertise sides. 3.3 Crisis Committees: Composition and Attributes Companies may form permanent or ad hoc crisis committees (or both), depending on the size of the company and risks inherent in the business. Such committees typically include senior execu- tives or heads of departments, but may in some cases also include less-senior employees with more hands-on experience from different parts of the corporation. Some companies may also appoint independent members (for instance, external legal counsel), while other companies choose to appoint external members to the crisis management team. Crisis committees usually report directly to the board of directors and/or senior management, but tend to have significant autonomy with regards to crisis prevention and response actions.
Crisis management teams may consist of heads of departments and members from senior man- agement, as well as less-senior employees within various areas of the corporation, so that immediate response actions may be more easily implemented across the entire corporation in the event of a crisis. In some cases, the company may also choose to appoint an external member – for instance, legal counsel. The relevant crisis situation would often inform the composition of the committee. Roles and Positions Within the committee and team, commonly there should always be one resource with pro- ject management responsibility, and with a direct reporting line to the steering committee. This can be the chief compliance officer, general coun- sel or external counsel. The relevant functions and resources as part of the task force would vary. As mentioned, a regulatory breach would commonly involve significant resources from the legal team, while a security breach would com- monly involve significant contributions by the security team. The communications team would also typically be involved in the preparedness of any crisis situation. Frequency The frequency of meetings may be daily or weekly, with a report to the steering committee weekly or bi-weekly. The type and urgency of the relevant crisis would naturally inform the fre-
quency of the meetings. 3.5 External Advisory
Larger corporations might have experienced internal crisis management teams, but it is com- mon to seek external assistance. Naturally, this is because a company will often not see as many
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