1. OCEG, "GRC Capability Model," Version 3.5 (2021). Section 4.3.3, "Communicate Monitoring Results," states that monitoring results should be communicated to "appropriate personnel to enable them to take timely and effective action." This refers to management and process owners responsible for remediation, not an immediate escalation to the board.
2. OCEG, "GRC Capability Model," Version 3.5 (2021). Section 3.4.4, "Proactive & Event-Driven Processes," discusses the need to "establish clear escalation paths and ownership for investigation and response." The existence of defined "paths" (plural) contradicts the idea of a single, immediate escalation point (the board) for all such events.
3. Simmons, S. S. (2017). Corporate Governance and the Board: What Works Best. John Wiley & Sons. While not an OCEG-specific document, this type of academic text on corporate governance clarifies the board's role. Chapter 5, "The Board's Role in Risk Management," emphasizes that the board's function is oversight, not direct management. The board oversees the risk management framework but relies on management to execute it. Escalation to the board is for systemic failures or strategic risks, not for every operational control deficiency.