What modern policy management looks like: lessons from a private equity governance overhaul

Most organizations do not struggle with policy management because they lack policies. 

They struggle because policies stop at documents. Writing more of them does not fix the problem. No matter how often policies are drafted, reviewed, updated, approved, and filed away, the same issues return. 

Organizations grow. Roles change. Regulations shift. And before long, it becomes unclear who needs to know what, who actually owns each policy, or whether any of it is being followed in practice. 

That gap between intention and reality is where risk lives. 

Why does traditional policy management break down?

In theory, policy governance should be simple. 
Define expectations. Communicate them. Monitor compliance. 

In reality, it rarely works that cleanly. 

Industry research captures this problem well:

McKinsey’s 2025 Global GRC Benchmarking Survey found 93% of organizations have a governance framework or policy document, but nearly half still lack formal governance procedures, showing how quickly policy turns into paperwork without an operating model behind it. 

From conversations with our expert community at CoreStream GRC, we see the same pattern play out once organizations reach scale. What looks manageable on paper starts to break down in practice. 

We see the same pattern time and again: 

• Hundreds of policies scattered across shared drives or document tools 

• Review cycles that drift into box-ticking exercises 

• “Ownership” assigned on paper, but rarely enforced in practice 

• Limited confidence that the right people have seen the right policies at the right time 

• Audit evidence reconstructed after the fact, instead of created through the workflow 

Michael Rasmussen, founder of GRC 20/20, has been calling this out for years. His core point is simple; 

“Too often, risk management is seen as a compliance exercise and not truly quantitative analysis that is of value to the organization’s strategy, decision-making, and objectives.” 

Michael Rasmussen, GRC 2020 founder and pundit 

The problem is not effort. Governance teams are working hard. The problem is that documents are being treated as the end goal, rather than the starting point. 

Case study: how we worked with a private equity organization for a full governance reset

This was exactly the challenge faced by a global investment group operating across a diverse and growing portfolio of businesses. 

Profile:  

• Industry: global investment group operating in 100+ markets worldwide 

• Employees: 25,000+ 

• Market value: roughly $40–50 billion market cap as of 2025  

As portfolio complexity increased, their existing document management tool could not keep up. Policies were hard to maintain, harder to navigate and almost impossible to govern with confidence. Even though reviews happened, visibility was limited and accountability was unclear. The result was that leadership lacked a real line of sight. 

However, this is the point where the private equity firm made a decisive shift. Instead of adding yet another layer of process, they changed the model entirely. 

Policies were rebuilt inside an interactive policy management framework: 

• Policies were broken into targeted, searchable content rather than long PDFs 

• Clear RACI ownership was established for every policy and review stage 

• Policy content was explicitly linked to regulatory obligations and business requirements 

• Compliance findings and actions were connected back to the policy source 

• Leadership dashboards showed review status, gaps, and exposure in real time 

The impact was immediate. Policy governance stopped being retrospective and reviews became proactive. Ownership became visible and governance moved from “we think this is covered” to “we can prove it.” 

They came to the conclusion so many companies fail to; the answer is not more policies, it is better control. 

What modern policy management programs look like in practice 

The most effective policy programs do one thing well: they deliver relevance. 

The benefit of embedding policy management into operational systems is not theoretical.  

Some of our clients have policy management built directly into everyday processes through integration with their HR system. When a new employee joins, the policies relevant to their role and group are issued automatically. No blanket emails. No manual chasing. No guesswork about who needs to see what. 

“The resulting solution has dramatically increased our productivity through automation, with tasks such as drafting review wording now handled by the system rather than through time-intensive manual work.” 

And this approach is not limited to HR systems. 

Wherever policies intersect with day-to-day work, they can be delivered in context. Policies reach the right people at the right moment, and evidence is created as part of the process. 

That is the difference. When policy delivery is automated and tied to real workflows, governance teams stop chasing compliance and start managing it. 

Want to hear from more of our happy clients?  

The takeaway: policy management is becoming people-led and operational 

The next generation of policy management is not about fixing broken systems. It is about designing governance that helps people run the business with control, not just maintain a library of documents. 

The pattern we see in strong programs is consistent: 

• Policies delivered with purpose and relevance, not mass distribution 

• Ownership that is clear, visible, and enforced 

• Real-time visibility that supports decisions, not just reporting 

• Evidence created through workflows, not reconstructed at audit time 

When policies are connected to obligations, ownership, and daily operations, governance becomes something teams can run confidently, even under scrutiny. 

If you want to see what this looks like in practice, we can show you. 

 

Frequently asked questions about policy management in private equity