‘A culture of compliance’

After a solid four months of collecting, sorting and submitting documents and data from dozens of departments, May 25 offered some relief to Minnkota’s Compliance team. That relief came in the form of another document – sent by the Midwest Reliability Organization (MRO).

“We just received our audit briefing this morning,” said Minnkota Compliance Manager Theresa Allard, unable to hide her excited energy. “It was fantastic. We are feeling very happy with how it all turned out.”

Allard and Andy Fuhrman, Minnkota’s North American Electric Reliability Corporation (NERC) compliance coordinator, had just guided the co-op through its latest audit of NERC electric reliability standards. The audit is performed every three years at NERC-registered entities that contribute to the bulk electric system.

The Minnkota processes subject to review are vast, with nearly 1,100 requirements falling under the umbrella of approximately 70 NERC standards. Those standards cover several aspects of electricity reliability, including cybersecurity, physical security, information security, operations and planning.

For the latest audit, Minnkota was asked to prove compliance with 19 requirements. Not a single point of noncompliance was discovered and there were no areas of concern. Allard said it’s rare for the MRO to formally comment on above-and-beyond findings – but sometimes perfection needs to be applauded.

“We were thrilled when we had not one, but two ‘Positive Observations’ in our final report,” Allard said. One of those kudos referred to Minnkota’s strong supply chain risk management program, which allowed the cooperative to avoid several pitfalls many of the other audited agencies experienced. “The other ‘Positive Observation’ was something that Andy and I are very proud of: our culture of compliance.”

Allard explained that compliance culture is not specific to a requirement or standard, but rather the framework of the compliance program and “story” of how it successfully functions among more than 60 Minnkota subject-matter experts (SMEs).

“During one of the interviews of the audit, they pointed out that when they interview SMEs, they expect almost an adversarial tone,” Fuhrman said. “They really appreciated that our SMEs would politely answer their questions, and there was even a little laughter at times. It’s a pleasant interview for them.”

Proactively programmed

This isn’t the first time Minnkota has earned a clean audit. Audits run smoothly due to Allard and Fuhrman’s hard work over four audit cycles to develop a proactive compliance program. Every SME is trained to thoroughly document internal controls so they can be called upon in an instant.

“We try to operate in a state of audit readiness, for every single requirement, every single day,” Fuhrman explained. “We think through the evidence up front, so when audit time comes, we are already preprepared.”

The Compliance team won’t rest on its laurels – it simply can’t. Every year, NERC develops new requirements to ensure the reliability and security of the bulk electric system. The power grid is under stress, currently navigating a period of rapid change and several emergent risks in the areas of cybersecurity and operations. NERC is trying to get ahead of those risks before they’re realized.

Minnkota’s Compliance department will remain adaptable as the team begins preparations for the next audit cycle in 2025. But for just a moment, they’re allowing the satisfaction of a clean review to settle in.

“I was proud. I felt pride not only for the Compliance department but for the whole team – we have 60 SMEs who are continuously doing compliance work for us. Whether they were directly involved in the audit or not, they are still a part of that culture,” Allard said. “Our leadership is very supportive of Compliance, and that tone that we hear from the top is really making its way all the way down. I think that, as a company, we all get to take a little bit of credit for that compliment. And it’s a big compliment – it really is.”

MAIN IMAGE: Minnkota's Andy Fuhrman (left) and Theresa Allard of the Compliance department share laughs.