In 2013, John Sampson, Senior Vice President of Operations, Manufacturing & Engineering at Dow, gave presentations and participated in panel discussions at the ARC World Industry Forum on the topics of enterprise risk management (ERM) and resiliency. Sampson described Dow's ERM system as having evolved from a "gut feel" approach to a "highly data driven and highly integrated" system with built-in resiliency. He stated that Dow partners with Homeland Security on "many fronts" to understand the company's role in overall enterprise reliability and resiliency. Sampson also remarked that he found "80 percent of the time it was just poor mismanagement of strategic risk" and that "you can't just delegate risk management; you have to participate." During a panel discussion, Sampson described Dow's use of "triggers" that would elevate risk issues to the company's sustainability team, which he said is "accountable to the board of directors." He noted that if a risk "hits a corporate target it's out of my control and the sustainability team gets involved and makes decisions for you," adding that "you get decisions handed to you, not money, and then you have to use the capital to go buy that risk down."