Frequency Estimates
Frequency estimates should be based on direct observations of physical site conditions and documented occurrences of incidents, events, insurance claims, regulatory actions/inspections, etc. You may also use information on industry trends or developing risks (such as NGO and media reports, shareholder proposals and investor activism and international ESG/sustainability disclosure trends). Contemplate sequences of events and other interrelationships that could develop — without considering controls at this stage. This is done in order to present exposures in the context of their “gross risk.”