Implications of Privatisation for Data Governance and Community Expectation Management

Executive Summary

The purpose of this investigation is to critically examine corporate governance approaches with respect to stakeholder expectations, as global markets shift to include value-added management services that involve big data. Such business-model shifts present a challenge to established players, because the barriers to entry in software and data management are both lower, and also are poorly understand by procurers (typically Governments).

Fundamentally, we enquire whether good corporate governance practices in one area are an indicator of good practices and ethical approaches in another, especially for emerging issues such as data where the intersection between regulation and human rights is falling behind technical capability.

In this study, stakeholder and societal perspectives of corporate governance are relevant, and will be examined with respect to Bombardier’s exploitation of good governance and transparency as an effective tool in the strategic marketing of the company. We examine here whether good corporate governance practices, and the effective communication thereof, present an antidote to these challenges and a competitive edge in this low-barrier marketplace.

Following Bombardier’s example, as the world’s leading manufacturer of rail rolling stock, we will investigate how a startup might compare, and indeed, improve upon, Bombardier’s performance as the company shifts to vertically-integrate value-added services such as system management.

The qualitative approach for analysis will determine whether a) Bombardier represents a global benchmark in the brave new world of big data, and b) how new entrants must meet or exceed this benchmark in order to compete. If railway companies are now also data companies, how does using good corporate governance as a marketing strength, rather than as a compliance checklist, contribute to the high standards required of new market entrants?

We hypothesise that in this context, for an emerging startup in a global market, transparency and ethical business processes will lead to competitive superiority.

Introduction and Review

Background

Companies have always collected data on their customers. However, with 21st-century advances in high-tech transportation, and massive global innovations in ‘smart’ technologies, artificial intelligence, and big data analytics, mega-companies that provide previously-innocuous public services (such as rail transportation) (Bombardier 2017a) find themselves now also providers of secondary services – both value-added services to consumers, and data services to governments and third parties. In other words, the manufacturing technology company now is also in the business of product-as-a-service asset management, systems and connectivity software, and data analytics, across the entire supply chain and straddling multiple industry verticals (Goulet-Langlois, Koutsopolous & Zhao 2016). In addition, companies’ ability to glean information on customers and potential customers without the person even being aware of it has caused widespread concern that this information could be used unethically.

Increasingly, consumers are aware of how this access to data and its implications for nefarious use (vis-à-vis for democracy, mass surveillance, identity fraud, etc), as well as the risk of data security breaches by third parties, impact the control that corporations have over daily life. Consequently, company managers and governance structures are under scrutiny to ensure that adequate protections and privacy provisions are in place. So, it is crucial that companies use their corporate governance processes, standards, and goals as publicly marketable assets in themselves, to demonstrate transparency, accountability, and due process.

While these companies may have been used to a business-to-government model, they are now business-to-business and also business-to-consumer, raising the potential to interface with vast data and metadata sources. In this environment, good corporate governance becomes much more than a compliance exercise, and much more than an internal accountability exercise. Following stakeholder theory, the reputation that comes from good corporate governance is itself a company’s biggest marketable asset. This is especially the case in a sector overwhelmingly dominated by public (government) procurement, where tenders are awarded on financial transparency, compliance, and political risk management bases.

This paper will examine the global passenger transportation industry, and specifically focus on the railways segment, from the perspective of a hypothetical new market entrant in Australia, using one of the most dominant global leaders as an exemplar of corporate governance and transparency.

We will pose the question: if railway companies are now also data companies, how does using good corporate governance as a marketing strength, rather than as a compliance checklist, contribute to the high standards required of new market entrants? Additionally, can good corporate governance processes (and good reputation for those processes) act as a proxy for a high expectation of ethical data management in the eyes of the consumer?

The qualitative approach for analysis will examine a) how Bombardier performs against a range of corporate governance pillars, b) whether Bombardier therefore represents a global benchmark in the brave new world of big data, and c) how new Australian entrants must meet or exceed this benchmark in order to compete.

Pelletier, Trépanier and Morency (2011) articulate that data can be used at strategic (long-term business planning and gaps analysis), tactical (service changes and network development), and operational (using measurable indicators and ridership statistics to measure performance). Clearly, this potential goes far beyond the rail industry, and the incentive for corporations to collect these data is high because of the returns possible through business improvement. However, the regulatory environment in Australia, and indeed, the complexity of public discourse, is as yet inadequate to address and define human rights, consumer rights, and privacy rules, as well as what data can and cannot be collected in the first place. In this study, however, we will constrain the scope to assess the specific example of vertical integration and how this presents competitive challenges to Bombardier.

The ‘Railway Equipment Manufacturing and Repair’ Industry

With increasing globalisation, and a trend toward concentration of market share in few companies, the barriers to market entry are high. In Australia, there are only three major industry players, with a combined market share of 67.7% (IBISWorld 2016). However, as companies shift their strategy to vertically integrate manufacture with management services, they must field competition in both segments. The barriers to entry in data management are significantly lower and prone to continual disruption from startup entrants as new technologies, protocols, and standards are developed.

The case organisation within this industry, Bombardier Inc., is a design and engineering company, manufacturing and supplying aftermarket service to primarily commercial and government customers of transit and aerospace vehicles (Bombardier 2018a). They are perhaps best known for their passenger railcars and business aircraft, including Learjet, Challenger, and Global families. Bombardier is a global company, headquartered in Montréal, Canada, with its Transportation division headquartered in Berlin, Germany. Its privately-held Australian subsidiary operates as Bombardier Transportation Australia Pty Ltd (ACN 010 699 804). Global revenue in the 2017 fiscal year to 31 December 2017 was USD16.2 billion (Bombardier 2018b), and its current market capitalisation is USD8.425 billion (Bloomberg Markets 2018). IBISWorld (Mustafoff 2017) estimates Bombardier’s Australian market share as 17.7%, with $440.5m revenue in the Australian market in 2017.

Global firms like Bombardier have a large public profile; as such, reputational risk is also high. Given the incredible volumes of private-user data now collectable, societies are under increasing pressure to ensure that entrenched firms use their concentrated power in a future-focussed, socially responsible way (Bombardier 2017b).

Additionally, consumers, the public, and other stakeholders have faster and more effective means to voice concerns about non-core deliverables supplied through Government contracts, and also immediate access to (and voracious appetite for) assurances of due-diligence and good corporate governance. For Bombardier and other transport providers, this means that not only must rail rolling stock deliver on comfort, reliability and speed, but the company itself must be ethical, transparent, and hold itself to high standards of environmental and social leadership.

Therefore, as the pace of development increases, with technological advancements like rapid prototyping, computer-assisted design, simulation modelling, and internet-enabled access to talent and information, Bombardier is under pressure both from established players, and from emerging startups with new technologies, to ensure it remains a respected market leader by virtue of its corporate governance standards.

Existing Barriers to Entry for a New Market Player in Australia (Manufacturing and Supply)

For a hypothetical Australian market entrant, the following factors contribute toward high barriers to entry:

• Highly globalised industry, where existing players have access to large capital pools, de-risked asset portfolios, factories in places where production costs are low, and large research and development budgets
• Concentration of market share among few large players, leading to confidence issues for new entrants
• The overall small size of the domestic market
• A procurement culture of demonstrable safety records, where a global track record is advantageous
• Ability to service long-term contracts for delivery, and maintain redundant cashflow to cover interim overheads, even in periods of low demand
• Reputation and track record of ‘on-time on-budget’ project delivery, all important for government procurement
• Actual technological superiority and points of difference
• A volatile political environment, with variable attitudes to public transport, regional rail and rail freight effecting large changes in the availability of public cash for rail infrastructure, leading to high uncertainty for a new entrant and for their investors
• Close relationships with transit authorities are required to win tenders, and lobby for future budgeted work over the political life of a government
• Passenger rail operators are all owned and run by governments. This means that there are no private capital opportunities for market growth

Consequently, in Australia:

Most growth in enterprise numbers occurs at the smaller end of the industry through owner-operators that provide repair services, generally to resource companies and freight railways in remote areas.

IBISWorld, Mustafoff 2017

Despite these barriers, the future of rail appears bright, particularly due to massive advances in technology and global megatrends such as urbanisation, population growth, and a move toward integrated journeys and seamless connectivity, as well as post-consumerism and the incorporation of big data into individualised service provision (Bagchi & White 2005; Utsunomiya, Attanucci & Wilson 2006). According to Colin Stewart, Global Rail Leader at multidisciplinary engineering firm Arup, passengers will choose rail because “it is a mode that offers convenience, comfort, speed, safety, and reliability, and because it is a sustainable and efficient option” (Goulding 2014). Additionally, Stewart notes that the likely driver of innovation in the sector will be the passenger experience, including better service, loyalty, and the ability to tailor preferences to a person’s individual expectations and needs.

Companies that are well placed to deliver the historically-important technological advancements (speed, efficiency, etc), and also the factors that will important in the new economy of transit and mobility (data security, integrated services, reliability, and digital added-value) will have a competitive advantage.

Opportunities for Rail Management Services

New startup companies proposing to manage data faster and more efficiently, more securely, and more creatively, are emerging every month. With vast capital resources, Bombardier are well placed to vertically integrate these services as value-adds to Government providers. This is attractive because the seamlessness between the hardware and software implies fewer compatibility and maintenance issues. Additionally, the software and management can be white-labelled; Governments in Australia manage the public transport systems, and so this is attractive to them for closed-circuit networks. Finally, Bombardier is already a preferred vendor for many Governments, and this gives them the relationships they need to cross-sell new services, potentially using proprietary tools that lock out competitors by setting industry expectations.

At the same time, governments have a fiscal responsibility to maximise the value for taxpayers’ money. This means that often, tenderers must compete on cost in addition to quality and other risk-mitigation factors. Because the regulatory environment around data governance is in its infancy, however, assessors must use proxies within other aspects of corporate governance to determine the residual risk with respect to data.

Consequently, new market entrants must deliver a superior service that is cheaper, adds value, and gives confidence that Bombardier does not.

Bombardier is not a publicly listed company in Australia, but its parent company is listed in Canada. The company takes a proactive disclosure approach, apparently going above the legal requirements to share information that might otherwise be considered internal. In this way, it shows commitment to transparency, which ultimately makes the company more trustworthy and therefore more likely to win contracts.

We therefore argue that a proactive approach to corporate governance is therefore good for business, and in the context of data services and management, will make the difference for a new market entrant looking to supply rail management services to governments in Australia.

The “Data Industry”

The collection and analysis of data is not new, and neither is it inherently dangerous. In the last ten years however, the advent of internet-enabled devices has meant that data sets are becoming more and more passively and continuously generated, and increasingly include meta-data that surround actual collected information, such as in South Korea, where fares are calculated by distance and so a variety of “detailed user data” are collected (Park, Kim & Lim 2014).

There are, indeed, many benefits to digital journey management and information systems that plan services, manage inventory, fuel and energy, staff, and virtually every other aspect of operations and logistics, including the ability to interface with artificial intelligence that optimises resources (Falvo et al. 2011; Pelletier, Trépanier & Morency 2011).

So why is this an issue? Firstly, the relationship between vendor and customer is now highly individualised and resolved at the person-by-person level. Customers are individually tracked wherever they go, not only in their interactions with the vendor but in their interactions with other brands as well. These data and metadata are often available for sale.

Secondly, the pervasiveness of internet-connected devices, especially smartphones, has monetised even the simplest game app into a data-hungry business model either indirectly, for ad revenue through aggregated ad buying, or directly through data capture and sale.

Thirdly, it’s clear that the vast majority of people are completely oblivious to their data being shared around the corporate world. In many cases, policies that allow a person to access and delete their own data are not enough to protect their privacy because consumers are unaware their data are being tracked and stored in the first place.

While recent initiatives to establish a regulatory environment around the collection and use of these data have provided much-needed guidelines (such as the European Union’s General Data Protection Regulation), the trade-offs for consumers are becoming increasingly one-sided. If a person is unable, for example, to catch public transport without signing away their privacy and giving up personal information, this adds an interesting dimension to the provision of essential services in instances where private and public corporations are handling and managing these services, and when multiple datasets are fused to infer other characteristics about the consumer such as behavioural intent (Kusakabe & Asakura 2014), jobs-housing relationships (Long & Thill 2015), and even demographic patterns compared to the type of fare a person uses (Goulet-Langlois, Koutsopolous & Zhao 2016). In Australia, privacy legislation is currently not adequate to address the rapid pace of change, although the introduction of the Consumer Data Right in over 2018-2022 may boost public confidence in Government-held data assets.

Additionally, a mindset-shift around data ‘custodianship’ rather than data ‘ownership’ is underway. This is a direct example of why well-communicated corporate governance can boost consumer confidence and therefore competitive advantage in the meantime, in the absence of adequate regulatory frameworks.

Methodology

Research Method and Scope

This research is a single case study, with the unit of analysis being Bombardier Inc. The company was critically analysed from the perspective of a hypothetical new Australian rail-sector market entrant undertaking a benchmarking study in the corporate governance standards required, and the competition presented in the communication of those standards, as the sector changes from one of manufacturing to value-added services in rail system management and data capture.

Secondary data were collected from industry reports, such as from IBIS World (IBIS World 2016; McGregor 2017a; McGregor 2017b; McGregor 2017c; Mustafoff 2017), Bombardier’s websites (including their subdomains targeted to investor relations) and annual reports (Bombardier 2018a), and competitors’ websites and annual reports. All data gathered are publicly available.

Transportation is a highly globalised industry, often with a geographically-widespread supply chain, and an international footprint of customers. Therefore, this study considered Bombardier in its international context, rather than its position only in Australia, because of the key role that the global parent plays in supporting commercial activities in a given jurisdiction. Moreover, although Bombardier’s corporate governance efforts span the entire business, we focus the scope herein on the competitive landscape within the rail industry and value-added services such as public transit management.

Bombardier’s performance will be examined against established standards and their own internal metrics, as well as considering stakeholder theory and a higher moral expectation of global citizenship. If the company performs highly, we will infer that they will also have an ethical approach to data stewardship.

Findings

Data and data privacy are key considerations when it comes to stakeholders in any organisation, and yet are only cautiously included in formal corporate governance guidelines. Furthermore, until recently, the concept of data ownership (as a leverageable business asset) has not been challenged. Under the European Union’s recent (2018) General Data Privacy Regulations (GDPR), the concept that the customer owns their own data is central to new thinking around privacy and the governance associated with being a data custodian.

Bombardier, while no doubt complying with the GDPR, does yet not appear to translate this philosophy into their customer-facing communications, as evidenced by their published Privacy Statement.

Analysis of Bombardier’s Corporate Governance Metrics

Bombardier appears to take the approach of proactive disclosure on their consumer-facing publications. Our brief assessments across a of range corporate governance areas follows:

Aspects of Corporate Governance

Environmental Stewardship

• A clear environmental imperative, which is light on detail but is communicated through video using a manager within the organisation, to give the message credibility
• An acknowledgement that some things are a work in progress lends credibility and authenticity to the message
• An expertise-based approach will satisfy people who critique sustainability messaging, which is often riddled with ‘greenwashing’ and misleading or hypocritical statements
• An awareness that being the best product environmentally is good for business and represents a point of differentiation
• Supplier Code of Conduct, which addresses Bombardier’s expectations around supply chain environmental standards and other corporate governance checks

Anti-corruption and Anti-bribery

• A stated zero-tolerance policy

Board/Management/Employee Diversity

• The Board has a published diversity policy with targets for gender diversity
• Despite the target being 30% of directors being women, the current published composition includes only 27% women (4 of 15 directors). This is expected to rise to 28.6% at the company AGM (on May 3rd 2018), assuming that all the nominated women are elected to the Board.
• Not a single one of the top fifteen published management positions is filled by a woman, and none of the top six-most highly compensated company officials (as published for named executive officer (NEO) positions in the Management Proxy Circular 2017) are women, although the number of women in overall management positions across the company is 19.4%.
• Across the organisation, excepting in the Asia-Pacific region, employees are 22% women.
• Corporate membership of Young Rail Professionals, and a number of regional programmes to support career pathways for women in technical and engineering jobs.
• Presence of a Diversity and Inclusion Committee, which also oversees programmes such as professional development scholarships for employees

Independence of the Corporate Governance and Nominating Committee, and the Human Resources and Compensation Committee

• The two committees are comprised of independent directors only
• The two committees are identical in composition
• The two committees include no women
• Appointment of an independent external auditor to assess the risks associated with compensation programmes (i.e. to balance appropriate business risk with excessive risk-taking behaviour)

Addressing Agency Theory

• Strong stock ownership guidelines for executives, such that the top five NEOs are required to build and hold a share portfolio equal to a multiple of their base salary, in order to align executive interests with those of shareholders

Addressing Conflicts of Interest on the Board

• Culture of ethics flows to employees through ubiquitous training, a Code of Ethics and Business Conduct, and reporting about how many internal allegations were received by the Ethics and Compliance Office.
• Transparent and detailed-explanations given for pay structure and compensation schemes in the annual notes to shareholders, and also providing shareholders with an opportunity to vote annually on executive pay packages

Performance Reporting

• A very detailed interactive reporting matrix published online, showing how the company performs on a wide variety of metrics across Health and Safety, Environment, Employees, and Tax Contribution categories.

Transparency in publishing dissenting views

• Shareholder proposals to AGM are publicly available in the notes to the AGM. Specifically, the dissatisfaction generally by shareholders other than members of the Bombardier family, who collectively hold a majority stake

Performance vs Conformance

• According to the management proxy circular before the Annual General Meeting scheduled for May 3rd this year, a Class B shareholder proposal to proactively declare lobbying expenditure and political contributions is recommended for rejection by the company. While reasonable and legitimate reasons are given for this recommendation, here was a missed opportunity for Bombardier to show leadership in a corporate climate of political uncertainty and distrust.

Data Security and Privacy

Privacy Policy

• Is the privacy policy in legalese?
• Is the policy comprehensible as a contract between Bombardier and the consumer?
• It the policy reasonable? i.e. does a rejection of the policy disqualify a person from using public transport and other essential services?

Bombardier’s privacy policy (updated July 31st 2018) is well-written and easy to understand. https://www.bombardier.com/en/toolbar/privacy.html

It is explicitly acknowledged that Bombardier collects a wide range of data types on people, whether or not they are a customer. This includes metadata such as location tracking. The company also collects information “obtained from third parties” such as data brokers, as well as scraping information from social media sites. The company claims to be compliant in every country in which it operates.

However, included in the justifications for lawful use are ‘contract’ obligations, which are of course undefined, and with respect to the way many people purchase public transit services, not explicitly entered into. These ‘lawful bases’ for data use are very broad and catch almost all cases. Additionally, Bombardier here takes a compliance approach when it comes to privacy, and in an environment where regulation lags behind technical capability, mere compliance may not be competitively advantageous.

Other than the cost of compliance and legal advice, a new market entrant is therefore highly likely to be able to replicate Bombardier’s privacy statement and indeed, enhance the sense of confidence with further controls on cybersecurity and encryption, a focus on future-proof human rights, and more clarity on how datasets might be ‘fused’ to feed predictive statistics and demographic profiling.

Further philosophical questions are raised in circumstances where Bombardier requires personal information in order to fulfil its function as a provider of essential services. If a person opts to have their data destroyed, does this act preclude that person from using the services? These are unanswered ethical dilemmas with respect to fundamental rights and the role of governments in a) upholding those rights, and b) extending that responsibility to companies when they are contracted to deliver a service on the government’s behalf (such as public transport services).

Implications for Bombardier

Against all the above metrics, Bombardier’s approach to corporate governance appears to be mixed, and thus will not present an adequate proxy measure for whether the company will respond ethically to current and future technical capability with data.

Bombardier is a global company with high liquidity and strong opportunity to invest in processes that lend it credibility as a leader in the value-added sectors into which it is expanding. This kind of resource will be crucial not only in developing the processes, the software systems, the policies, and the intellectual property safeguards, but also in using them as marketing opportunities to raise expectations and set the benchmark high for new, more agile, market entrants.

Implications for new market entrants

Over the last twenty years, the rapid development of both silicon and internet technologies have accelerate the emergence of entirely new sectors, and disruptive technologies that have challenged traditional supply-chain views of the global economy. A number of these new sectors comprise value-added services, especially digital integrations, that enhance the real-world user experience of a product.

In the case of rail transit, customers around the world have benefited from the problem-solving potential of internet and other technologies such as smartphone GPS, algorithmic trip analysis, predictive route planning, and personalised customer service services including digital transactions.

For new market entrants, providing this superior value will be a focus from a consumer perspective, and enabling that consumer confidence through market-leading privacy standards and data management are likely to be the key risk-mitigation factors influencing government tenders.

Conclusion and Recommendations

This brief study examined whether a) Bombardier’s approach to corporate governance represents a proxy for an expected approach to data governance and privacy with respect to human rights, b) whether Bombardier’s approach can be used as a governance benchmark in a world where precious little regulation exists to protect consumers’ rights and prioritise ethical behaviour, especially in Australian jurisdictions, and c) whether a new market entrant, competing in a market segment with Bombardier’s vertically-integrated value-adds, might do so on the basis of competitive advantage in privacy governance.

On overall review, it is clear that Bombardier has a proactive and comprehensive approach to corporate governance from a stakeholder perspective. Dealing as they are with human transportation, there is a public need to show a public commitment to safety and compliance, and the company shows good communication with respect to beyond-compliance metrics, such as leadership in environmental sustainability. On the other hand, the company’s approach to data guardianship appears to preference pre-GDPR principles on the concept of data ‘ownership’ rather than custodianship, and therefore it is suggested that an otherwise marketable and sector-leading corporate governance framework is not an adequate indicator of approach to data from a human rights perspective.

We therefore do not believe that a benchmark can be drawn from Bombardier’s company policies. It is likely that data governance benchmarks will be instead led by smaller market entrants, which, through being more agile and competing only in the transit management segment, are able to demonstrate competitive strategy that markets the superiority of data guardianship values.

It is therefore recommended that, on the one hand, Bombardier prioritises a human rights approach to data guardianship, making an effort to proactively market the significant capabilities of technology in data collection, and leveraging an excellent liquidity position to lead the sector in data security. On the other hand, Australia (and many other jurisdictions) must rapidly examine the technological capability anticipated in the coming years, and put in place both ambitious regulations to constrain unethical practices (for both publicly listed and private companies), and higher-level legislative and guideline changes to vest responsibility for data custodianship within the field of corporate governance, as well as explicitly pursuing a review of the way data custodianship and associated managed services are procured and preferred through tender processes.

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