With stores across 31 countries and more than 18,400 employees, Costa struggled with its manual and siloed approach to compliance management. Each unit had its separate processes. They were using spreadsheets to manage compliance programs and maintain risk registers. This led to many duplications of efforts and made analyzing risks maintained in different registers difficult. The lack of coordination between different outlets use of different technologies and processes led to limited risk visibility and compliance management challenges.

Again, these files did not have proper access controls or version history, and changes can make it challenging to understand who made the changes. Without proper collaboration, the compliance and risk management teams were requested to assess the same types of risk resulting in duplicity. Regarding evidence management, the proof was stored in different folders, making it extremely difficult for internal auditors to execute audits successfully.